   SEQ CHAPTER \h \r 1 	INFORMATION COLLECTION REQUEST (ICR)

	SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	STRATOSPHERIC OZONE PROTECTION

1.   Identification of Information Collection

a)   Title: Significant New Alternatives Policy (SNAP) Program Final
Rulemaking under Title VI of the Clean Air Act Amendments of 1990 (OMB
Control Number: 2060-0226, ICR Number 1596.07)

b)   Short Characterization

Title VI of the Clean Air Act Amendments of 1990 (the Act) implements
the obligation of the United States under the Montreal Protocol to phase
out the use of ozone-depleting substances.  Section 612 of Title VI
establishes as U.S. policy the requirement that Class I and Class II
ozone-depleting substances shall be replaced, to the maximum extent
practicable, by chemicals, product substitutes, or alternative
manufacturing processes that reduce overall risks to human health and
the environment.

EPA developed its Significant New Alternatives Policy (SNAP) program to
fulfill the requirements of Section 612.  The five major provisions of
Section 612 are:

Rulemaking:  Section 612(c) requires EPA to enact rules making it
unlawful to replace any Class I or II substance with any substitute that
the Administrator determines may present adverse effects to human health
or the environment where an alternative has been identified that (1)
reduces the overall risk to human health and the environment, and (2) is
currently or potentially available.

Listing of Unacceptable/Acceptable Substitutes:  Section 612(c) also
requires EPA to publish a list of the substitutes prohibited for
specific uses.  EPA must publish a corresponding list of acceptable
alternatives for specific uses as well.

 	Petition Process:  Section 612(d) grants the right for any person to
petition EPA to add or delete a substance from the lists published in
accordance with Section 612(c).  EPA has 90 days to grant or deny a
petition.

	90-day notification:  Section 612(e) authorizes EPA to require any
person who produces a chemical substitute for a Class I substance to
notify EPA not less than 90 days before the new or existing chemicals
are introduced into interstate commerce for significant new uses as
substitutes for a Class I substance.  The producer must also provide EPA
with all unpublished health and safety studies on such substitutes.

   Clearinghouse:  Section 612(b)(4) requires EPA to set up a public
clearinghouse of alternative chemicals, product substitutes, and
alternative manufacturing processes that are available for products and
manufacturing processes which use Class I and II substances.

	

EPA issued regulations on March 18, 1994, in 59 FR 13043, which are
codified at 40 CFR Part 82, Subpart G (Section 82.170 et seq.),
establishing the SNAP program.  EPA’s major activities in the SNAP
program are to review proposed substitutes based on the risk-assessment
criteria and the procedures set forth in the regulations, and to publish
(and update) a list of acceptable and unacceptable substitutes by end
use categories.

The information required for collection under the SNAP regulations is
described below in Section 4 of this statement, and is currently
approved by OMB for use through April 30, 2000.

EPA is in the process of publishing a notice of intention to renew this
information collection request.  This notice of intention will be
published in the Federal Register.  

The previous ICR of 2001 had the following Terms of Clearance:

  SEQ CHAPTER \h \r 1 This collection is approved. OMB questions the
need for respondents to retain information for five years. EPA should
reconsider this requirement and amend it as appropriate.  OMB notes
further that the cost estimate associated with this collection and
reported in block 14 of the 83-I appears to be erroneous. In particular,
OMB notes that the cost estimates contained in the supporting statement
do not appear to be properly discounted. EPA should revise its cost
estimate, also explaining how the costs have changed since the
previously approved collection.

EPA has addressed each of the items.  Section 3d contains a
justification for retaining records.  Cost estimates have been
discounted per OMB guidance (7% discount rate).  Section 6 contains
additional clarification.

2.   Need for and Use of the Collection 

a)   Authority for the Collection

Information required to be collected under the SNAP program is intended
to fulfill the general mandate in Section 612(c) of identifying
acceptable substitutes that can serve as replacements for
ozone-depleting substances being phased out under the Act, as well as
unacceptable substances which may not be used as replacements for
ozone-depleting substances being phased out under the Act.  Section 612
(42 U.S.C. 7671k) is attached as Appendix B, and EPA’s implementing
regulations (40 CFR Part 82, Subpart G, Sect. 82.170 et seq.) are
attached as Appendix C.

b)   Use/Users of the Data

EPA's Stratospheric Protection Division (SPD) will use the information
submitted to evaluate the acceptability or unacceptability of the
proposed alternatives for Class I and Class II ozone-depleting
substances. 

3.   Non-duplication, Consultations, and Other Collection Criteria 

a)   Non-duplication	

The specific information requested by this notice is not currently
collected by EPA or any other government agency.  Use of the TSCA/SNAP
Addendum form (described in section 4(b) of this statement) will insure
that companies participating in the Toxic Substances Control Act (TSCA)
Pre-Manufacture Notice (PMN) program will not have to duplicate their
data for the SNAP program. 

Public Notice Required Prior to ICR Submission to OMB

In compliance with the Paperwork Reduction Act, EPA solicited comments
for a 60-day comment period prior to submission of the ICR to OMB.  No
comments were received.

c)   Consultations

In developing the regulations under the Act, EPA established an advisory
committee for issues relating to stratospheric ozone. The Stratospheric
Ozone Protection Advisory Committee (STOPAC) membership included
representatives from affected industries, environmental interest groups,
and academics in related fields. Within the STOPAC, subcommittees were
formed to look at more detailed issues.  The subcommittee on the SNAP
program met several times to discuss possible substitutes for
ozone-depleting substances, guiding principles for SNAP evaluations, and
strategies to obtain information about substitutes from industry.  This
consultation was invaluable in developing the SNAP Information Notice
form (described below in section 4(b).)  EPA also received comments on
its proposed SNAP regulations, which identified the information to be
collected through the SNAP program, and these comments were also helpful
in developing the SNAP Information Notice form.

In preparing to renew this information collection request, EPA consulted
with fewer than nine actual or potential respondents to discuss
estimated burden hours and costs associated with this information
collection request.  The respondents with whom EPA consulted are from
various industries, companies, and organizations.  They include: Mary
Koban of Dupont (302) 999-2692; Kurt Werner of 3M (651) 733-8494; and
David Ferguson of AGC Chemicals (704) 904-7452. 

c)   Effects of Less Frequent Collection

The SNAP program has minimized the number of reporting and
record-keeping requirements as much as possible by requiring only a
one-time application, in the case of reporting requirements, or a
one-time record-keeping.  

d)   General Guidelines 

This rule does not exceed any of the guidelines, except for records
retention for more than 3 years.  Retention periods for the two SNAP
record-keeping requirements (described below in section 4(b) of this
statement) are not specified in Title VI of the Act or in the SNAP
regulations, but EPA requires retention of these records for five years
for enforcement purposes, pursuant to statutory authority under 28
U.S.C. Section 2462, the applicable statute of limitations.  Sec. 2462
states,

Except as otherwise provided by Act of Congress, an action, suit or
proceeding for the enforcement of any civil fine, penalty, or
forfeiture, pecuniary or otherwise, shall not be entertained unless
commenced within five years from the date when the claim first accrued
if, within the same period, the offender or the property is found within
the United States in order that proper service may be made thereon.

e)   Confidentiality and Sensitive Questions 

i)   Confidentiality

Measures to protect confidentiality of information collected under the
SNAP program are based on EPA’s confidentiality regulations (40 CFR
2.201 et seq., or Subpart B.)  SNAP regulations (at 40 CFR 82.182)
describe these measures, which are also mentioned on the front page of
each of the SNAP forms.  Each form mentions basic information about
asserting confidentiality claims, and also instructs the submitter to
read the Guidance Document, which contains more detailed discussion of
the procedures for confidentiality claims.  (See pages 2-4 of the
Guidance Document, which, as described in section 4(b), is attached as
Appendix F).  These procedures are described briefly below.

Submitters may designate all or portions of their forms or petitions as
confidential.  EPA requires the submitters to substantiate their claim
of confidentiality.  The submitter is advised that, under Section 114(c)
of the Act, emissions data may not be claimed as confidential.  The
submitter is also advised that there are further instances, described in
the provisions of 40 CFR Part 2, Subpart B, in which confidential
assertions may be reopened or denied even when confidentiality claims
are initially received.  The submitter will be contacted as part of such
an evaluation process. 

If required substantiation is not provided along with the submission of
information claimed as confidential, EPA may make the information
available to the public without further notice.  The submitter must
provide three copies of all submissions under the SNAP program, one of
which contains no information claimed as confidential.  The
non-confidential submission will be put in the public docket.

If toxicity or health and safety studies are listed as confidential,
this information cannot be maintained as confidential where such data
are also submitted under TSCA or FIFRA, to the extent that confidential
treatment is prohibited under those statutes.  However, information in a
toxicity study that is not health and safety data and is not relevant to
the effects of a substance on human health and the environment, e.g.,
discussion of process information, or proprietary blends, can be
maintained as confidential subject to 40 CFR Part 2, Subpart B.

Information submitted as part of a joint submission to either SNAP/ TSCA
or SNAP/ FIFRA must adhere to the security provisions of the program
offices implementing these statutes.  For such submissions, the SNAP
handling of such notices will follow the security provisions under these
statutes.

ii)  Sensitive Questions

This section does not apply because the SNAP regulations and the
associated information collection request do not seek information of a
sensitive nature.

4.   The Respondents and the Information Requested 

a)   Respondents

Respondents for reporting requirements, as well as for the recordkeeping
requirement for the exemption for small volume use, include
manufacturers, importers, formulators and processors of substitutes for
ozone-depleting substances.  Principally, these respondents are in the
following major categories of industry groups, by Standard Industry Code
(SIC) and North American Industry Classification System (NAICS):

Manufacturers, Chemicals and Allied Products

Industry	SIC	NAICS

Plastics materials and synthetics	282	 HYPERLINK "NAICS32B.HTM" \l
"N325211" 325211  



Soap, cleaners, and toilet goods	284	 HYPERLINK "NAICS32B.HTM" \l
"N325611" 325611  

Paints and allied products	285	 HYPERLINK "NAICS32B.HTM" \l "N32551"
32551  

Industrial organic chemicals	286	 HYPERLINK "NAICS32B.HTM" \l "N325191"
325191  

Agricultural chemicals	287	 HYPERLINK "NAICS32B.HTM" \l "N32532" 32532  

Miscellaneous chemical products	289	 HYPERLINK "NAICS32B.HTM" \l
"N325998" 325998  



Manufacturers, Rubber and Misc. Plastics Products

Industry	SIC	NAICS

Plastics foam products	3086	 HYPERLINK "NAICS32B.HTM" \l "N32615" 32615 




Wholesale Trade- Nondurable Goods

Industry	SIC	NAICS

Chemicals and allied products	516	 HYPERLINK "NAICS42.HTM" \l "N42261"
42261  

Miscellaneous nondurable products	519	 HYPERLINK "NAICS42.HTM" \l
"N42299" 42299  



 

Respondents for the narrowed use limit recordkeeping requirement include
end users of the substitutes in the following industrial sectors:

Construction- Special Trade Contractors

Industry	SIC	NAICS

Plumbing, heating, and air-conditioning	171	 HYPERLINK "NAICS23.HTM" \l
"N23511" 23511  



 

Manufacturing- Industrial Machinery & Equipment

Industry	SIC	NAICS

Computer and office equipment	357	 HYPERLINK "NAICS33B.HTM" \l "N334111"
334111  ,  HYPERLINK "NAICS33B.HTM" \l "N333313" 333313  



Refrigeration and service machinery	358	 HYPERLINK "NAICS33B.HTM" \l
"N333415" 333415  





Manufacturing- Electronic & Other Electric Equipment

Industry	SIC	NAICS

Electric distribution equipment	361	 HYPERLINK "NAICS33B.HTM" \l
"N335311" 335311  

Electric industrial apparatus	362	 HYPERLINK "NAICS33B.HTM" \l "N335312"
335312  

Communications equipment	366	 HYPERLINK "NAICS33B.HTM" \l "N33421" 33421
 

Electronic components and accessories	367	 HYPERLINK "NAICS33B.HTM" \l
"N334411" 334411  





Manufacturing- Transportation Equipment

Industry	SIC	NAICS

Aircraft and parts	372	336412

Ship and boat building and repairing	373	336611





Manufacturing- Instruments & Related Products

Industry	SIC	NAICS

Search and navigation equipment	381	334511 



Medical instruments and supplies	384	339112 



Ophthalmic goods	385	339115 



 

Services

Industry	SIC	NAICS

Services to buildings	734	56179 

Computer and data processing services	737	541511



Refrigeration service and repair	7623	811412, 81131 





b)   Information Requested 

i)   Data Items (for reporting and recordkeeping requirements):

To simplify and expedite the submission and review of SNAP notices, EPA
has developed the following forms and a guidance document:

-    SNAP Information Notice (Appendix D)

-    TSCA/SNAP Addendum (Appendix E)

-    Guidance Document for the SNAP Program Information Notice (Appendix
F)

The SNAP Information Notice is the form used in most submissions to give
notice of a respondent’s plans to introduce a proposed substitute into
the marketplace.  The TSCA/SNAP Addendum is an abbreviated SNAP form for
submissions in situations where there is joint statutory review between
the TSCA PMN program and the SNAP program.  The full SNAP Information
Notice should be used in the case of a joint review with the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA).  A petition should
include the same information that is requested in the SNAP Information
Notice.  No additional information is required for a petition.  The
guidance document provides further information for a respondent
preparing any of these submissions.

The forms were developed to minimize the reporting burden for the
submitter; however, their use is optional.  Respondents with more
efficient means of submitting the information are encouraged to use
them.  EPA has based the estimated respondent burden and cost on the use
of the recommended forms; to the extent a respondent uses more efficient
means to submit the data, the estimates contained in this analysis may
overestimate the respondent burden and cost. 

1.   SNAP Information Notice/ Petition Data Items:  Reference: Sections
82.176(a), 82.178, 82.180(a)(5), 82.184(c)

The information requested on the SNAP Information Notice includes the
following data items:

Name and description of the substitute.  To the extent possible, the
substitute should be identified by its (1) commercial name, (2) chemical
name, (3) trade name(s), (4) generic name, (5) identification numbers
(e.g., CAS registry, NIOSH RTECS, EPA hazardous waste, OHM-TADS,
DOT/UN/NA/IMCO shipping, HSDB, NCI), (6) chemical formula, and (7)
chemical structure.

Physical and chemical information.  Key properties that should be
included to characterize the substitute are:  molecular weight; physical
state;  melting point;  boiling point;  density;  odor threshold; 
solubility;  partition coefficients (Log Kow, Log Koc);  and vapor
pressure.

Substitute applications.  Identification of the applications in which
the substitutes are likely to be used is required.  It is essential to
provide a complete list of potential uses as the substitute listing
required by section 612(c) is specific to application.

Process description.  For each application identified, EPA is requesting
available descriptive data on processing, including in-place pollution
controls. Such information will be helpful in characterizing workplace
and environmental releases and exposures.

Ozone depletion potential.  The predicted ozone depletion potential
(ODP) of substitute chemicals is requested.  The submitter should also
provide sufficient supporting documentation-- either a citation or the
background information used to develop the ODP.  For purposes of
calculating ODP, EPA recommends the methodology used in the most recent
Scientific Assessment of Ozone Depletion: 1991, which was prepared for
the United Nations Environment Programme.  [1] If a submitter is
uncertain about a compound's ODP, he or she should contact EPA to
receive a list of Class I and II compounds.  In those few cases where a
compound is believed to have an ODP but is not on this list, EPA will
work directly with the submitter to determine the appropriate course of
action.

Global warming potential.  EPA is requesting readily available data on
the total global warming potential (GWP) of the substitute in its
particular application (e.g., as a refrigerant, foam blowing agent,
etc.)  The total GWP considers both direct and indirect effects. Direct
effects comprise the direct global warming impacts of using a
substitute.  EPA is requesting that all GWPs be referenced to CO2 using
the methodology recommended by the Intergovernmental Panel for Climate
Change (IPCC).  [2] Indirect effects explicitly consider the impact on
global warming arising from changes in energy consumption associated
with the use of a substitute (e.g., an alternative refrigerant).  This
latter measure can be identified as changes in energy efficiency or
demand relative to the substitute being replaced.

Toxicity data.  Information on toxicity from acute and chronic exposure
by inhalation of a substitute chemical, its impurities, and its
degradation products on any organism (e.g., humans, mammals, fish,
wildlife, and plants) is required. For mammals, EPA is requesting a
minimum submission of the following tests to characterize substitute
risks: a range-finding

study, and a 90-day subchronic repeated dose study in an appropriate
rodent species.  For substitutes that are being evaluated as fire
suppressants, a cardiotoxicity study, usually performed on a dog, is
also required.  Additional mammalian toxicity tests will be identified
based on the substitute and application being evaluated.  To
sufficiently characterize aquatic toxicity concerns, both acute and
chronic toxicity test results for a variety of species is required.  EPA
requires a minimum data set as described in "Guidelines for Deriving
Numerical National Water Quality Criteria for the Protection of Aquatic
Organisms and their Uses," which is available through the National
Technical Information Service (#PB 85-227049).  Other relevant
information and data summaries, such as the Material Safety Data Sheets,
should also be submitted.  Submission of the actual toxicity studies is
most beneficial; however, it is not necessary to submit these reports if
they have been supplied to EPA as part of other regulatory submissions. 
To assist in locating these studies, the submitter must provide a
sufficiently clear citation to ensure that these studies can be located
by EPA in a timely fashion.  EPA requires that submitters providing
information on new chemicals for joint review under TSCA and SNAP adhere
to the TSCA minimum testing requirements described in TSCA section 5.

Environmental Fate and Transport.  Where available, information must be
submitted on the environmental fate and transport of substitutes.  Such
data shall include information on bioaccumulation, biodegradation,
adsorption, volatility, transformation, and other data necessary to
characterize movement and reaction of substitutes in the environment.

Flammability.  Data on the flammability of a substitute chemical or
mixture are required.  Specifically, data on flash point and
flammability limits are needed, as well as information on the procedures
used for determining the flammability limits.  For substitutes that will
be used in consumer applications, documentation of testing results
conducted by independent laboratories (e.g., Underwriters Laboratories)
should be submitted where appropriate.  Detail on any suggested
abatement techniques to minimize the risks associated with the use of
flammable substances or blends should also be provided.  EPA recognizes
that many promising alternatives may be considered marginally flammable,
but can be used safely and effectively.  The information requested on
this topic will help EPA make a balanced decision regarding the use of a
flammable alternative, which one commenter supported.

Exposure data.  The submitter should provide extant modeling or
monitoring data on exposures associated with the manufacture,
formulation, transport, and use of a substitute.  Descriptive process
information for each substitute application, as requested above, will be
used to develop exposure estimates where exposure data are not readily
available.  Depending on the application, exposure profiles will be
needed for workers, consumers, and the general population.

Environmental release data.  Available data on emissions from the
substitute application and equipment, as well as pollutant releases or
discharge to all environmental media (ambient air, surface water,
hazardous/solid waste), are needed to complete the risk
characterization.  Submitters should provide information on release
locations, if known.  Any information on any pollution controls used or
that could be used in association with the substitute (e.g., emissions
reduction technologies, wastewater treatment, treatment of hazardous
waste) and the costs of such technology are also requested.

Replacement ratio for a chemical substitute.  EPA is requesting
information on the replacement ratio for a chemical substitute versus
the Class I or II substances being replaced.  For example, in the case
of a degreasing agent, how much more or less of the substitute chemical
is needed?  This will have an impact on the estimated incremental cost
and environmental effects associated with use of the substitute.

Required changes in technoloqy.  Detail on the changes in technology
needed to use the alternative is requested.  Such information should
include a description of whether the substitute can be used in existing
equipment-- with or without some retrofit--or in new equipment.  Data on
the cost (capital and operating) and estimated life of the technology
modifications should also be submitted.  These economic data are
essential to understanding the near-term potential of using an
alternative.

Cost of substitute.  EPA is requesting data on the expected average cost
of the alternative.  The cost of the substitute can be expressed, for
example, in terms of $/pound (for a chemical substitute) or as
incremental capital and operating costs associated with a retrofit or
new equipment.  In addition, information is needed on the expected
equipment lifetime for an alternative technology.  Other critical cost
considerations should be identified, as appropriate.  For example, it is
important to understand the incremental costs associated with losses or
gains in energy efficiency associated with use of a substitute relative
to current experience.

Availability of substitute.  EPA needs to understand the extent to which
a substitute is already commercially available or the expected date at
which it may become available.  The timing of availability is an
important factor in assessing the overall health and environmental
impacts of the substitute.

Anticipated market share.  Data on the anticipated near-term and
long-term (over the next five years) nationwide substitute sales (not
just those of the submitter) is requested.  This information can be
presented in several ways, for example:  a percentage of existing
nationwide use of Class I or Class II chemicals in a particular
application; number of units/products to be produced; or pounds of
substitute sold.  This information is required to assess the potential
impacts related to total consumption and environmental releases.

Applicable regulations under other environmental statutes.  The
submitter is requested to provide information on whether the
substitute(s) are regulated under other statutory authorities, in
particular the Clean Water Act, Safe Drinking Water Act, the Resource
Conservation and Recovery Act, the Federal Insecticide, Fungicide, and
Rodenticide Act, the Toxic Substances Control Act, and other titles
under the CAA.  EPA will evaluate substitutes under the SNAP program
subject to these existing regulatory constraints.

Information already submitted to EPA.  Individuals may have already
submitted information being requested in the SNAP program notice to EPA
as part of past regulatory and information-gathering activities.  If
such a situation exists, and to minimize reporting burden, the submitter
should provide the following information to help locate the data already
maintained at EPA:  type of information submitted; the date of
submission; the name of the EPA office to which the data were sent;
description of the regulatory program; and a document-control number, if
assigned (e.g., a PMN number).  If the submitter cannot provide
references to data sent previously to EPA, he or she should include all
requested information in the SNAP notice. 

Information already available in the literature.  If any of the data
needed to complete the SNAP program notice are available in the
literature, the submitter should provide EPA with references for such
information.  Failure to provide EPA with sufficient citation, however,
will delay review of the notice.  Additionally, submitters are
encouraged to provide copies of any literature to expedite review,
particularly if the citation is from a source not readily available to
EPA researchers.  Any references from sources in foreign languages
should be translated.  

Additional information.  If critical new information becomes available
during the review period that may influence EPA’s evaluation of a
substitute, the submitter must notify EPA of the existence of such
information within 10 days of learning of such data.  The submitter must
also inform EPA of new studies underway, even if the results will not be
available within the review period.

2.   TSCA/SNAP Addendum Form Data Items:  Reference:  Sections
82.176(a), 82.178, 82.180(a)(5)

EPA has identified only a few additional data elements, beyond those
already required by the Premanufacture Notice (PMN) program that would
need to be included for review under the SNAP program. For this reason,
the added burden to respondent from the SNAP program, above that already
required by the PMN program, is very small.

The additional data elements in the TSCA/SNAP Addendum include: 

-    The ozone-depletion potential, 

-    The global-warming potential,

-    Explicit quantification of the cost of using the substitute
(including the chemical replacement data, chemical cost data,
incremental equipment expenditures needed to use the substitute, and
information on the cost implications resulting from changes in energy
consumption), and 

-    Documentation of testing results regarding the flammability of
substitutes that will be used in consumer applications.

If critical new information becomes available during the review period
that may influence EPA’s evaluation of a substitute, the submitter
must notify EPA of the existence of such information within 10 days of
learning of such data.  The submitter must also inform EPA of new
studies underway, even if the results will not be available within the
review period.

3.   Notification for Test Marketing Activity Data Items Reference: 
Section 82.176(b)(5)

Uses of substitutes for the sole purpose of test marketing are exempt
from SNAP notification requirements until 90 days prior to the
introduction of such substitutes for full-scale commercial sale in
interstate commerce.  Persons taking advantage of this exemption are,
however, required to notify EPA in writing that they are conducting test
marketing 30 days prior to the commencement of such marketing. 
Notification shall include the following data items:

-    Name of the substitute

-    Volume used in the test marketing

-    Intended sector end uses

-    Expected duration of the test marketing period

4.   Recordkeeping for Substitutes Acceptable Subject to Narrowed Use
Limits Data Items Reference:  Section 82.180(b)(3)

If a substitute is listed by EPA, in a decision on a SNAP information
notice, TSCA/SNAP addendum, or petition, as acceptable subject to
narrowed use limits, end users intending to use the substitute must
determine that other alternatives are not technically feasible.  Such
end users must document the results of their evaluation and retain the
results on file for the purpose of demonstrating compliance.  This
documentation shall include the following data items:

-    Descriptions of substitutes examined and rejected 

-    Processes or products in which the substitute is needed

-    Reason for rejection of other alternatives, e.g., performance,
technical or safety standards

-    The anticipated date other substitutes will be available and
projected time for switching to other available substitutes.

Respondents are required to maintain these records five years.  See
section 3(d) of this statement for the justification for this length of
time.

5.   Recordkeeping for Small Volume Use Exemption Data Items Reference: 
Section 82.176(b)(3)

Within the eight principal SNAP sectors, persons introducing a
substitute whose expected volume of use amounts to less than 10,000
pounds per year within a SNAP sector are exempt from notification
requirements.  Persons taking advantage of this exemption for small uses
must maintain documentation for each substitute describing how the
substitute meets this small use definition.  This documentation must
include the following data item:

-    Annual production and sales information by sector

Respondents are required to maintain these records five years.  See
section 3(d) of this statement for the justification for this length of
time.

ii)  Respondent Activities

There are five types of respondent reporting and recordkeeping
activities required pursuant to Section 612 of the Act and the SNAP
regulations promulgated thereunder, 40 CFR Sections 82.170- 82.184:

Reporting: SNAP Information Notice/ Petition

This includes the following types of activities:

-    Pre-submittal contact with EPA.

-    Prepare and submit notice or petition to EPA.

-    Respond to EPA requests for additional information and/or notify
EPA of additional information as it becomes available.

Reporting: TSCA/SNAP Addendum

This includes the following types of activities:

-    Pre-submittal contact with EPA.

-    Prepare and submit form to EPA.

-    Respond to EPA requests for additional information and/or notify
EPA of additional information as it becomes available.

Reporting: Notification for Test Marketing Activity

-    Compile information, and prepare and submit letter to EPA with the
information.

Recordkeeping: Substitutes Acceptable Subject to Narrowed Use Limits

-    Assess other acceptable alternative substitutes.

-    Compile and prepare record of assessment.

Recordkeeping: Small Volume Uses

-    Assess sector sales.

-    Compile and prepare record of sector sales.

 5.   The Information Collected - Agency Activities, Collection
Methodology and Information Management.

a)   Agency Activities

 EPA activities associated with reviewing SNAP submissions consist of
the following:

Pre-submittal contact with respondent

-    Send forms and guidance document to potential respondents.

  -    Answer questions regarding the completion of SNAP program forms
and the need to submit a SNAP notice.

Review and Communication regarding submission

-    Assign tracking number to SNAP notice or petition.

-    Review SNAP notice or petition for sufficiency of information
provided, send letter of receipt, and notify submitter if additional
information is required.

-    Review requests for confidentiality and provide appropriate
protection.

-    Review SNAP notice or petition, and notify submitter of decision.

-    Review TSCA/SNAP Addendum in detail, coordinate with TSCA office,
and notify submitter of decision.

 -    Prepare and evaluate EPA-initiated changes to the SNAP
determinations.

Administrative operations

-  Maintain administrative tracking system for all submissions.

-  Maintain technical clearinghouse to help users identify acceptable
substitutes that are listed under the SNAP.

-  Prepare and publish in the Federal Register periodic notices and
rulemakings to inform the public of any changes to the SNAP lists and of
all pending determinations.

b)   Collection Methodology and Management (including discussion of the
items mentioned in OMB’s remarks in the 1994 approval of the original
ICR)

EPA collects information through submission by respondents of a SNAP
Information Notice, a TSCA/SNAP Addendum, or a petition.  In each case,
the collection methodology is the same.  EPA has 90 days from receipt of
a complete submission to respond to the filing, and EPA must publish its
decisions in these submissions in its periodic Federal Register notices
and rulemakings.  

Initially, EPA reviews each submission for completeness within 15 days
of receipt of the submission.  If information is incomplete, the
submitter will be contacted for this information.  Thus, the 15 day
completeness review period begins on the date EPA receives a submission,
and it ends 15 days after the date of receipt.  

The 90-day review period will not commence until EPA judges the
submission complete, although manufacturers of a new substitute may
introduce the substitute into interstate commerce 90 days after EPA
receives a submission if EPA has not already rendered an unacceptability
determination.  Once the 90-day review period has begun, EPA may
determine that additional data are necessary, or the submitter may
notify EPA of additional information, which has become available and may
influence EPA’s evaluation of the proposed substitute.  In either
case, EPA may contact the submitter to explore extending or suspending
the review period, depending on the type of data and the stage of
review.  Thus, the 90-day review period begins on the date a complete
submission is received by EPA, and it ends 90 days thereafter, unless
EPA and the submitter have agreed to another date.

EPA will check data quality of each submission by its review of the data
in each submission.  EPA will use its existing systems for telephones
and computers to process each submission.  Each submission is assigned a
tracking number, which will identify the submission in the public docket
where non-confidential versions of each submission are filed, as well as
the filing system at EPA for the confidential versions of each
submission.  The public can get access to non-confidential data in each
submission by visiting the public docket maintained in Washington, DC.

There is a means for filing electronic SNAP submissions with EPA.  EPA
has established both a telephone “hotline” clearinghouse and an
electronic clearinghouse of useful information about the SNAP program,
including updated lists of acceptable and unacceptable substitutes,
which helps some respondents reduce the burden of gathering information
to prepare a SNAP submission.

c)   Small Entity Flexibility

Submission of a notice to EPA 90 days before introducing a new
substitute into commerce is required by statute, regardless of the size
of the submitter.  The information requested in the SNAP program is
necessary for EPA to evaluate the proposed substitute chemicals which
will be listed as acceptable or unacceptable, depending on the
evaluations.  The SNAP program has directed the burden on manufacturers
and formulators, rather than the end user, which greatly reduces the
potential burden on small entities.   

Additionally, SNAP reporting requirements provide an exemption for
persons introducing a substitute whose expected volume of use amounts to
less than 10,000 pounds per year within a SNAP industrial sector.  This
exemption reduces the potential burden on small entities, although such
persons are subject to a recordkeeping requirement documenting their
qualification for this exemption.  

d)   Collection Schedule

The SNAP regulations were promulgated March 18, 1994, and collection of
information as required therein commenced on that date.  EPA accepts and
reviews SNAP submissions as they are provided to EPA by respondents. 
Information in the public docket on these submissions has been available
since submissions have been received.

6.    Estimating the Burden and Cost of Collection

a/b)    Estimating Respondent Burden and Costs

The following tables (6A/B-1 through 6A/B-5) present estimates of annual
respondent burden hours and costs for each of the respondent activities
described in section 4(b)(ii), with explanations of the assumptions made
in each table.  All cost values are in 2006 $ and reflect inflation
since the previous ICR.  Labor costs are from the Bureau of Labor
Statistics.

Exhibit 6A/B-1: SNAP Information Notice/Petition:  Annual Respondent
Burden and Cost (1)

	

The following table shows estimates of respondent burden hours and costs
for the first set of activities listed above in section 4(b)(ii).  In
making these estimates, relied on its experience in thirteen years of
implementing the SNAP program and its consultations with respondents,
and made the following assumptions:

- The number of inquiries about filing a SNAP Information Notice or
petition is 12 per year, of which 50% submit the filing.  The number of
CBI requests is 67% of the 6 submittals.  The number of filings for
which additional information is required is 67% of the 6 submittals. 

- Labor cost of $60.00 represents an average hourly rate of pay,
including overhead and benefits, for a private company for labor that
would be classified as “technical” time for the bulk of the effort
and “clerical” time for a small part of the effort. 

- Estimated start-up cost is based on the cost of required toxicological
data which, in 25% of SNAP filings, is a one-time event incurred for the
sole purpose of fulfilling SNAP requirements.  EPA estimates the cost of
such data ranges from $30,000 to $350,000, with more than half of
respondents incurring such costs in an amount equal to or less than
$75,000.  EPA multiplied a weighted average of these costs ($133,610) by
.25 to get an estimated average start-up cost of $33,402 which
represents the cost distributed among all respondents.  This total
start-up cost was discounted to present value using 20 years as the
useful life of the chemical for which data was collected and 7% as the
discount value.

- There is no annual operating and maintenance cost associated with this
reporting requirement.



Table 6A/B-1: SNAP INFORMATION NOTICE / PETITION

 	(A) Hours/ 

Year Resp.	(B) Labor 

Cost (@ $60/

hr) per Resp.

per Year	(C) Annua-lized Start-up Cost per Resp.	(D) No. of Resp.
(E)Total Hrs/Year (All Resp.)

(A*D)	(F)

Total Annualized Cost per Year (All Resp.)

(C*D)	(G) Total 

Labor Cost per Year (All Resp.)

(B*D)	(H) Total  Cost per Year (All Resp.)

(F+G)

a) Pre-submittal contact with EPA	 	 	 	 	 	 	 	 

Obtain form and guidance document from EPA	0.7	$42 	$0 	6	4.2	$0 	$252 
$252 

Review form and guidance document from EPA	2	$120 	 	 	0	 	$0 	$0 

Identify chemical and applications	14	$840 	$0 	6	84	$0 	$5,040 	$5,040 

b) Prepare and submit form to EPA	 	 	 	 	 	 	 	$0 

Collect data for form	122	$7,320 	$3,153 	6	732	$18,918 	$43,920 
$62,838 

Prepare notification form	5	$300 	$0 	6	30	$0 	$1,800 	$1,800 

Prepare non-confidential version of form if CBI is declared	4	$240 	$0 
4	16	$0 	$960 	$960 

c)  Respond to EPA requests for add’l information and/or notify EPA of
add’l. info.	 	 	 	 	 	 	 	 

Communicate with EPA	3	$180 	$0 	4	12	$0 	$720 	$720 

Collect data	97	$5,820 	$0 	4	388	$0 	$23,280 	$23,280 

Prepare data to send to EPA	5	$300 	$0 	4	20	$0 	$1,200 	$1,200 

                             Subtotals	252.7	$15,162 	$3,153 	varies but
6 is most	1,286.2 	$18,918 	$77,172 	$96,090 



Exhibit 6A/B-2: TSCA/SNAP ADDENDUM: Annual Respondent Burden and Cost
(2)

The following table shows estimates of respondent burden hours and costs
for the second set of activities listed above in section 4(b)(ii).  In
making these estimates, EPA relied on its experience in thirteen years
of implementing the SNAP program and its consultations with respondents,
and made the following assumptions:

- One inquiry per year comes in regarding a TSCA/SNAP Addendum.  EPA
receives one submittal per year.  One CBI request comes from that 1
submittal.  Additional information is usually required by the submitter.


- Labor cost of $60.00 represents an average hourly rate of pay,
including overhead and benefits, for a private company for labor that
would be classified as “technical” time for the bulk of the effort
and “clerical” time for a small part of the effort.

-There is no start-up or operating and maintenance cost associated with
the TSCA/SNAP Addendum.



Table 6A/B-2:  TSCA/SNAP Addendum

 	(A) Hours/ 

Year Resp.	(B) Labor 

Cost (@ $60/

hr) per Resp.

per Year	(C) No. of Resp.	(D)Total Hrs/Year (All Resp.)

(A*C)	(E) Total 

Labor Cost per Year (All Resp.)

(B*C)

a) Pre-submittal contact with EPA	 	 	 	 	 

Obtain form and guidance document from EPA	0.5	$30 	1	0.5	$30 

Review form and guidance document from EPA	3	$180 	1	3	$180 

Identify chemical and applications	0.5	$30 	1	0.5	$30 

b) Prepare and submit form to EPA	 	 	1	 	 

Collect data for form	30	$1,800 	1	30	$1,800 

Prepare notification form	5	$300 	1	5	$300 

Prepare non-confidential version of form if CBI is declared	2	$120 	1	2
$120 

c)  Respond to EPA requests for add’l information and/or notify EPA of
add’l. info.	 	 	1	 	 

Communicate with EPA	1	$60 	1	1	$60 

Collect data	3	$180 	1	3	$180 

Prepare data to send to EPA	1	$60 	1	1	$60 

                             Subtotals	46	$2,760 	1	46.0 	$2,760 



Exhibit 6A/B-3: Notification for Test Marketing Activity:  Annual
Respondent Burden and Cost (3)

The following table shows estimates of respondent burden hours and costs
for the third set of activities listed above in section 4(b)(ii).  In
making these estimates, EPA relied on its experience in thirteen years
of implementing the SNAP program and its consultations with respondents,
and made the following assumptions:

- The number of notifications for test marketing activity is one per
year, and the number of hours per notification is two.  

- Labor cost of $60.00 represents an average hourly rate of pay,
including overhead and benefits, for a private company for labor that
would be classified as “technical” time for the bulk of the effort
and “clerical” time for a small part of the effort.

- There is no start-up or operating and maintenance cost associated with
the notification.

 

Table 6A/B-3:  Notification for Test Marketing Activity

	(A) Hours/ 

year Resp.	(B) Labor 

Cost (@ $60/

hr) per resp.

per year	(C) No. of Resp.	(D)Total Hrs/Year

(A*C)	(E) Total 

Labor Cost per resp. per year

(B*C)

a) Compile information and prepare letter	2	$120 	1	2	$120 

Subtotal	2	$120 	1	2	$120 

                                   

Exhibit 6A/B-4: Record-Keeping For Substitutes Acceptable to Narrowed
Used Limits:  Annual Respondent Burden and Cost (4)

The following table shows estimates of respondent burden hours and costs
for the fourth set of activities listed above in section 4(b)(ii).  In
making these estimates, EPA relied on its experience in thirteen years
of implementing the SNAP program and its consultations with respondents,
and made the following assumptions:

- The number of record-keeping collections is 250 per year.  Each
collection is a one-time occurrence.  Users of restricted alternatives
may periodically reevaluate alternatives available.

- Labor cost of $60.00 represents an average hourly rate of pay,
including overhead and benefits, for a private company for labor that
would be classified as “technical” time for the bulk of the effort
and “clerical” time for a small part of the effort.

- There is no start-up cost associated with the record-keeping
collection.

-  Annual operating and maintenance cost represents an estimate of cost
of storage space for keeping the records.

Table 6A/B-4: Record-Keeping For Substitutes Acceptable to Narrowed Used
Limits

 	(A) Hours/ 

Year Resp.	(B) Labor 

Cost (@ $60/

hr) per Resp.

per Year	(C) Annua-lized Start-up Cost per Resp.	(D) No. of Resp.
(E)Total Hrs/Year (All Resp.)

(A*D)	(F)

Total Annualized Cost per Year (All Resp.)

(C*D)	(G) Total 

Labor Cost per Year (All Resp.)

(B*D)	(H) Total  Cost per Year (All Resp.)

(F+G)

a) Assessment of other acceptable alternatives	25	$1,500 	$0 	250	6,250
$0 	$375,000 	$375,000 

b) Compile information and prepare recordkeeping	2	$120 	$1 	250	500
$250 	$30,000 	$30,250 

Subtotal	27	$1,620 	$1 	250	6,750	$250 	$405,000 	$405,250 

                                    

Exhibit 6A/B-5: Record-Keeping for Small Volume Uses:  Annual Respondent
Burden and Cost (5)

The following table shows estimates of respondent burden hours and costs
for the fifth set of activities listed above in section 4(b)(ii).  In
making these estimates, EPA relied on its experience in thirteen years
of implementing the SNAP program and its consultations with respondents,
and made the following assumptions:

- The number of record-keeping collections is 10 per year, and each
collection is a one-time occurrence.  

- Labor cost of $60.00 represents an average hourly rate of pay,
including overhead and benefits, for a private company for labor that
would be classified as “technical” time for the bulk of the effort
and “clerical” time for a small part of the effort.

- There is no start-up cost associated with the record-keeping
collection.

- Annual operating and maintenance cost represents an estimate of cost
of storage space, filing materials and other associated, non-labor costs
for keeping the records.

Table 6A/B-5:  Record-Keeping for Small Volume Uses:  Annual Respondent
Burden and Cost

 	(A) Hours/ 

Year Resp.	(B) Labor 

Cost (@ $60/

hr) per Resp.

per Year	(C) Annua-lized Start-up Cost per Resp.	(D) No. of Resp.
(E)Total Hrs/Year (All Resp.)

(A*D)	(F)

Total Annualized Cost per Year (All Resp.)

(C*D)	(G) Total 

Labor Cost per Year (All Resp.)

(B*D)	(H) Total  Cost per Year (All Resp.)

(F+G)

a/ Assessment of sector sales	10	$600 	$0 	10	100	$0 	$6,000 	$6,000 

b/ Compile information and prepare recordkeeping	2	$120 	$1 	10	20	$10 
$1,200 	$1,210 

Subtotal	12	$720 	$1 	10	120	$10 	$7,200 	$7,210 



                                                                        
   

c)    Estimating Agency Burden and Costs

Exhibit 6C-1: Annual Agency Burden and Costs

The following table shows estimates of EPA burden hours and costs
(including the cost of contractor services) for the activities listed in
section 5 above.  In making these estimates, EPA made the following
assumptions:

- The number of occurrences is based on the number of inquiries and
submittals by respondents estimated above in tables 6A-1 and 6A-2.

- The number of EPA-initiated changes in SNAP determinations is
estimated to be two per year.

- The number of hours per detailed review of a TSCA/SNAP Addendum
assumes 60 hours per form.

- Labor cost is based on the annual 2006 salary for a GS 12/ Step 2
employee ($67,216), which is divided by 2,080 hours, the number of hours
in a federal work year  (resulting in an hourly rate of $32.32), then
multiplied by 1.6, the standard government benefits multiplication
factor (resulting in a final hourly rate of $51.71).  

- The cost of contractor services in the two circumstances noted in the
chart is based on a percentage of the total annual cost to SPD of the
contractor’s charges under the respective contracts.  The percentage
in each case represents an estimate of the time spent by the contractor
on SNAP issues as distinguished from other SPD issues not related to
SNAP.  The hourly rate noted in each case represents the average rate
charged per hour under these contracts.



 Table 6C1: EPA burden hours and costs

 	No. of Occur-rences	No. of Hours per Occur-rence	Total no. of Hours
per Year	Labor Cost (@ $51.71/hr) per Year	Cost of Contract Services per
Year	Total Cost per Year

1) Pre-submittal contact w/ respondent	 	 	 	 	 	 

Send forms/ guidance to potential submitters	12	0.1	1.2	$62.05 	   n/a
$62 

Answer questions re potential submissions	12	3	36	$1,861.56 	   n/a
$1,862 

2) Review & communication re submission	 	 	 	 	 	 

Assign tracking number to submission	6	0.5	3	$155.13 	   n/a	$155 

Review submission, send receipt, notify if add’l info required	6	2	12
$620.52 	   n/a	$621 

Review CBI requests and protect as appropriate	4	4	16	$827.36 	   n/a
$827 

Review submission in detail and notify submitter of decision	6	120	720
$37,231.20 	   n/a	$37,231 

Contractor assistance in reviewing submissions (@ $98/per hr)	    n/a	  
 n/a	1382	    n/a	$135,436 	$135,436 

Review TSCA/SNAP Addendum in detail and notify submitter of decision	3
60	180	$9,307.80 	   n/a	$9,308 

Prepare and evaluate EPA-initiated changes to determinations	2	40	80
$4,136.80 	   n/a	$4,137 

3) Administrative operations	 	 	 	 	 	 

Maintain system of tracking submissions	on-going	75	75	$3,878.25 	   
n/a	$3,878 

Maintain clearinghouse to help users	on-going	80	80	$4,136.80 	    n/a
$4,137 

Contractor assistance for clearinghouse(@ $85/per hr)	   n/a	     n/a
3701	n/a	$314,585 	$314,585 

Prepare FR notices and rule-makings re changes to SNAP lists	5	80	400
$20,684.00 	    n/a	$20,684 

Totals	varies	varies	6686.2	$82,901.47 	$450,021 	$532,922 



d)    Estimating the Respondent Universe and Total Burden and Costs  See
the tables in section 6(a) and (b) for these estimates.

Bottom Line Burden Hours and Cost Tables



Exhibit 6E-1:  Information Collection Activity: Total Estimated
Respondent Burden and Cost Summary

Table 6E1:  Total Estimated Respondent Burden and Cost Summary

	No. of Resp-ondents per year	No. of Activities per year	Total Hours per
Year	Total Labor Cost per Year @$60	Total Annua-lized Start-up Costs
Total Annua-lized O&M Costs	Total Annua-lized Costs	Total Costs

SNAP Information Notice/ Petition	6	6	1,286	$77,172 	$18,918 	$0 
$18,918 	$96,090 

TSCA/SNAP Addendum	1	1	46.0 	$2,760 	$0 	$0 	$0 	$2,760 

Notification for test marketing activity	1	1	2	$120 	$0 	$0 	$0 	$120 

Recordkeeping for Substitutes Acceptable Subject to Use Limits	250	250
6,750	$405,000 	$0 	$250 	$250 	$405,250 

Recordkeeping for Small Volume Uses	10	10	120	$7,200 	$0 	$10 	$10 
$7,210 

                 Totals	268	268	8,204	$492,252 	$18,918 	$260 	$19,178 
$511,430 



These numbers are from the subtotals of tables in 6(a) and 6(b), and are
used to complete items 13 and 14 in Form 83-1. 

Exhibit 6E-2: Total Estimated Agency Burden and Cost Summary

Table 6E2:  Total Estimated Agency Burden and Cost Summary

 	No. of Respondents	No. of Activities	Total Hours per Year 	Total Govt
Labor Hours per Year	Total Annual Govt Labor Cost @$51.71	Cost of
Contract Services per Year	Total Cost per Year

Pre-submittal contact with respondents	12	12	37.2	37.2	$1,924 	 $       
     -   	$1,924 

Review and communicate re submission	6	6	2,393	1,011	$52,279 	$135,436 
$187,715 

Administrative operations	varies	varies	4,256	555	$28,699 	$314,585 
$343,284 

Totals	varies	varies	6,686.2	1,603	$82,901 	 $   450,021 	$532,922 



f)    Reasons for Change in Burden

The total number of burden hours requested for this information
collection has decreased from 2003 from 8,927 to 8,204.  The SNAP burden
hours have been decreasing since 2000 from 10,363 to 8,927 to 8,204
hours.  The reason for this change in burden is the smaller number of
respondents keeping records for alternatives that are subject to
narrowed use limits than three years ago because of the development of
new substitutes.  For example, users of some restricted fire
suppressants now have other options available with no restriction, and
thus, no paperwork requirement.  In addition, smaller number of SNAP
petitions are being filed than EPA estimated three years ago.  The
recordkeeping estimates remain the same.

g)    Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 31 hours per response.

Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.  An agency may not
conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB
control number.  The OMB control numbers for EPA's regulations are
listed in 40 CFR part 9 and 48 CFR chapter 15.     

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OAR-2004-0077, which is available for online viewing at
www.regulations.gov, or in person viewing at the Air and Radiation
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
Air and Radiation Docket and Information Center is (202) 566-1742.  An
electronic version of the public docket is available at
www.regulations.gov.  This site can be used to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the Docket ID Number identified above.  Also, you can send comments to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OAR-2004-0077 and OMB Control Number 2060-0226 in any
correspondence.

