ECONOMIC
ANALYSIS
OF
EXPEDITED
SIGNIFICANT
NEW
USE
RULES
FOR
65
CHEMICAL
SUBSTANCES

DOES
NOT
CONTAIN
TSCA
CBI

Prepared
by:

Economic
and
Policy
Analysis
Branch
Economics,
Exposure
and
Technology
Division
Office
of
Pollution
Prevention
and
Toxics
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
1200
PENNSYLVANIA
AVENUE,
N.
W.
WASHINGTON,
DC
20460
September,
2003
OPPT­
2002­
0078­
0194
RECEIVED
OPPT
NCIC
2003
September
30
8:
41AM
i
CONTRIBUTORS
The
EPA
analyst
responsible
for
this
report
was
Carol
Rawie.
Analytical
and
draft
preparation
support
was
provided
by
Abt
Associates
Inc.
under
EPA
Contract
No.
68­
W­
02­
077.
ii
ABSTRACT
This
report
estimates
costs
of
a
Significant
New
Use
Rule
(
SNUR)
covering
65
chemicals
with
recent
TSCA
Premanufacturing
Notifications
(
PMNs).
The
SNUR
defines

Significant
New
Uses

that
trigger
EPA
notice
requirements.
To
submit
a
Significant
New
Use
Notice
or
request
SNUR
modification,
a
firm
incurs
a
$
4,456
to
$
6,956
submission
cost,
plus
a
potentially
much
higher
cost
if
it
performs
full
health
and
ecological
effects
testing
to
support
the
submission.
Potential
test
costs
range
from
under
$
20,000
to
over
$
2
million
per
chemical.

By
avoiding
a
Significant
New
Use,
a
firm
can
avoid
submission
and
testing
costs,
but
may
incur
other
compliance
costs.
For
example,
it
may
incur
costs
of
preventing
water
releases,
not
quantified
here
but
potentially
affecting
33
of
the
65
chemicals.
It
may
incur
costs
of
providing
worker
protection
and/
or
hazard
communications,
affecting
6
chemicals
at
$
931
to
$
20,482
per
chemical.
Estimates
assume
25
exposed
workers
per
site
with
annual
shipments
of
roughly
10,000
kg.
The
firm
may
also
incur

hidden

costs,
not
quantified
here,
for
example
if
it
foregoes
profitable
opportunities
to
use
the
chemical
in
ways
not
listed
in
the
PMN
(
17
chemicals)
or
limits
production
volume
(
4
chemicals).

Costs
are
estimated
for
one
chemical
at
one
site,
and
reflect
SNUR
restrictions
and
testing
specific
to
each
chemical,
but
are
not
otherwise
chemical­
specific.
EPA
receives
an
average
of
ten
notices
per
year
due
to
SNURs.
The
number
of
firms
affected
but
not
making
submissions
is
not
known,
and
costs
are
not
aggregated.
iii
TABLE
OF
CONTENTS
Page
CONTRIBUTORS
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i
ABSTRACT
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ii
LIST
OF
TABLES
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v
1.0
INTRODUCTION
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.
1
2.0
COSTS
ASSOCIATED
WITH
A
SIGNIFICANT
NEW
USE
RULE
(
SNUR),
BY
OPTION
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4
2.1
Comply
with
SNUR
Limits
(
Option
1)
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5
2.2
Modification
or
Revocation
of
a
SNUR
(
Option
2)
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10
2.3
Submission
of
a
SNUN
(
Option
3)
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13
2.4
Request
for
an
Equivalency
Determination
(
Option
4)
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14
2.5
Decision
Not
to
Produce
Chemical
(
Option
5)
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15
2.6
Summary
of
Costs
for
Each
Option
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15
3.0
EXPORT
NOTIFICATION
COSTS
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24
4.0
AGENCY
COSTS
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24
5.0
ADDITIONAL
ANALYSES
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24
5.1
Regulatory
Flexibility
Act
(
RFA)
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25
5.2
Unfunded
Mandates
Reform
Act
(
UMRA)
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26
5.3
Paperwork
Reduction
Act
(
PRA)
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26
5.4
Executive
Order
12866
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26
5.5
Executive
Order
13132
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26
5.6
Executive
Order
12898
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27
5.7
Executive
Order
13045
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27
APPENDIX
A
LIST
OF
PMNS
AND
THEIR
CHEMICAL
NAMES
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A­
1
APPENDIX
B
INFLATORS
AND
WAGE
RATES
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B­
1
B.
1.
Derivation
of
Loaded
Wage
Rates
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B­
1
B.
2.
Derivation
of
Inflation
Factors
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B­
6
iv
APPENDIX
C
COSTS
OF
COMPLIANCE
WITH
A
SNUR
(
OPTION
1):
HAZARD
COMMUNICATION,
PROTECTION
IN
THE
WORKPLACE,
AND
RECORDKEEPING
REQUIREMENTS
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C­
1
C.
1
Modifying
the
Hazard
Communication
Program
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C­
1
C.
2
Protection
in
the
Workplace
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C­
6
C.
3
Recordkeeping
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C­
19
APPENDIX
D
COSTS
OF
TESTING
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D­
1
APPENDIX
E
COSTS
OF
SUBMITTING
A
SNUN,
REQUEST
FOR
MODIFICATION
OR
REVOCATION
OF
A
SNUR,
OR
EQUIVALENCY
DETERMINATION
.
.
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E­
1
APPENDIX
F
AGENCY
COSTS
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F­
1
APPENDIX
G
REFERENCES
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G­
1
v
LIST
OF
TABLES
Table
1
Compliance
Options
and
Associated
Costs
Incurred
by
a
Firm
due
to
SNUR
.
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4
Table
2
Production
and
Use
Restrictions/
Requirements
.
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.
5
Table
3
Annual
Costs
of
Hazard
Communication
Requirements
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7
Table
4
Annual
Costs
of
Workplace
Protection
Requirements
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8
Table
5
Annual
Costs
of
Workplace
Protection
Requirements
­
Summary
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9
Table
6
Annual
Costs
of
Recordkeeping
Requirements
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10
Table
7
Costs
of
Testing
Requirements
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12
Table
8
Costs
of
Request
to
Modify/
Revoke
SNUR
or
Submit
SNUN
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13
Table
9
Costs
by
PMN
Chemical
and
Option
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18
Table
10
Annual
Per­
Site
Haz­
Comm,
Protection
in
the
Workplace,
and
Recordkeeping
Costs,
by
Chemical
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22
Table
A­
1
PMNs
and
Chemical
Names
Referenced
in
this
SNUR
.
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A­
1
Table
B­
1
Derivation
of
Loaded
Wage
Rates
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B­
4
Table
B­
2
Derivation
of
Inflation
Factors
.
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B­
6
Table
C­
1
Annual
Costs
of
Labeling
for
Distribution
in
Commerce
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C­
3
Table
C­
2
Annual
Costs
of
Labeling
for
Use
in
Workplace
.
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.
C­
4
Table
C­
3
Annual
Costs
for
Material
Safety
Data
Sheets
(
MSDSs)
.
.
.
.
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.
.
.
.
.
.
.
C­
5
Table
C­
4
Annual
Costs
for
Employee
Training,
Per
Chemical
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
C­
6
Table
C­
5
Annual
Costs
for
Dermal
Protection
Selection
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
C­
7
Table
C­
6
Annual
Costs
of
Impermeability
Testing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
C­
8
Table
C­
7
Annual
Cost
of
Gloves
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
C­
9
Table
C­
8
Annual
Cost
of
Protective
Eyewear
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
C­
10
Table
C­
9
Annual
Cost
of
Protective
Clothing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
C­
11
Table
C­
10
Annual
Costs
for
Respiratory
Protection
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
C­
12
Table
C­
11
Respirator
Prices
and
Average
Costs
in
1997,
by
NIOSH
Type
.
.
.
.
.
.
.
.
.
.
.
.
.
C­
15
Table
C­
12
Annual
Costs
of
Personal
Protective
Equipment
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
C­
18
Table
C­
13
Annual
Costs
of
Recordkeeping
Requirements
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
C­
21
Table
D­
1
Default
Parameters
for
Species,
Route,
and
Study
Type
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
D­
2
Table
D­
2
Cost
Estimates
for
Test
Guidelines
Cited
in
Batch
SNUR
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
D­
4
Table
D­
3
SNUR
Testing
Requirements
and
Cost
for
65
Chemicals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
D­
7
Table
E­
1
Industry
Costs
for
SNUN,
Request
to
Modify/
Revoke
SNUR,
or
Equivalency
Determination
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
E­
1
Table
F­
1
Agency
Costs
for
SNUN
and
Other
Submission
Review
and
Processing
.
.
.
.
.
.
.
.
F­
2
1
1.0
INTRODUCTION
This
report
presents
the
U.
S.
Environmental
Protection
Agency
(
EPA),
Office
of
Pollution
Prevention
and
Toxics

(
OPPT

s)
analysis
of
the
potential
costs
incurred
as
a
result
of
a
Significant
New
Use
Rule
(
SNUR)
being
promulgated
for
65
chemical
substances.
EPA
promulgates
a
SNUR
for
a
substance
when
potential
uses
could
result
in
increased
exposure
to
or
releases
of
the
substance,
and
in
turn
an
unreasonable
risk
to
health
or
the
environment.
Each
substance
in
this
group
was
the
subject
of
at
least
one
premanufacture
notice
(
PMN),
and
is
now
being
regulated
directly
as
a
result
of
the
PMN
review
process.
Appendix
A
lists
the
generic
or
specific
chemical
name
and
CAS
number
(
if
available)
for
each
PMN.

A
SNUR
specifies
the
conditions
under
which
the
manufacture,
import,
and/
or
processing
of
the
PMN
substance
is
allowed
without
prior
notice
to
EPA,
thus
defining
its
permissible
uses
that
do
not
constitute
a

Significant
New
Use.

Anything
that
exceeds
what
is
specified
as
allowable
in
the
SNUR
is
considered
a
Significant
New
Use
and
triggers
a
submission
to
EPA.
For
example,

"
if
the
SNUR
specifies
that
the
chemical
may
only
be
imported
but
not
manufactured
in
the
U.
S.,
then
manufacture
in
the
U.
S.
is
considered
a
Significant
New
Use;

"
if
the
SNUR
specifies
a
limit
to
the
quantity
of
the
chemical
that
a
firm
may
produce
in
the
U.
S.,
then
manufacture
of
any
quantity
exceeding
that
limit
is
considered
a
Significant
New
Use;

"
if
the
SNUR
limits
the
use
of
the
chemical
to
uses
(
products,
applications,
and/
or
functions)
listed
in
the
PMN,
then
any
other
use
is
considered
a
Significant
New
Use;

"
if
the
SNUR
limits
the
amount
of
the
chemical
that
may
be
released
to
water,
then
any
amount
exceeding
that
limit
is
considered
a
Significant
New
Use;
or
"
if
the
SNUR
requires
workplace
protection
or
hazard
communication
(
haz
comm)
for
the
chemical,
then
not
providing
the
required
workplace
protection
or
haz
comm
is
considered
a
Significant
New
Use.

If
the
firm
produces,
imports,
or
processes
the
chemical
in
commercial
quantities,
then
to
avoid
engaging
in
a
Significant
New
Use
that
would
trigger
submission
requirements,
the
firm
must
meet
the
specifications
in
the
SNUR
(
Option
1).
This
and
four
other
options
are
described
below.

"

Option
1:
Produce
the
chemical
within
SNUR
restrictions.
As
described
above,
the
firm
may
avoid
engaging
in
a
Significant
New
Use
by
manufacturing,
importing,
or
processing
within
the
SNUR
restrictions
for
that
chemical.
This
entails
compliance
costs
if
the
firm
must
change
its
practices.
The
firm
may
also
pursue
this
option
temporarily
2
while
also
pursuing
options
2,
3,
and/
or
4
(
see
below).

"
Option
2:
Request
for
modification
or
revocation
of
the
SNUR.
Under
40
CFR
§
721.185,
the
firm
may
request
modification
or
revocation
of
the
SNUR.
If
the
request
is
successful,
then
the
costs
associated
with
this
option
are
the
costs
of
submitting
a
request
for
modification
or
revocation
of
the
SNUR,
including
the
costs
of
developing
supporting
data
(
e.
g.,
testing),
plus
the
possible
costs
of
following
Options
1
or
5
during
EPA
review
of
the
request.

"
Option
3:
Submission
of
a
SNUN.
Alternatively
or
concurrently
with
other
options,
the
firm
may
submit
a
Significant
New
Use
Notification
(
SNUN).
A
SNUN
indicates
to
EPA
that
the
firm
would
like
to
manufacture,
import,
or
process
the
chemical
for
a
Significant
New
Use

i.
e.,
in
some
way
other
than
what
is
specified
as
allowable
in
the
SNUR.
The
SNUN
must
be
provided
to
EPA
at
least
90
days
before
the
firm
plans
to
commence
the
manufacture,
import,
or
processing
of
the
substance;
it
provides
EPA
with
the
opportunity
to
evaluate
the
intended
use
and,
if
necessary,
to
prohibit
or
limit
that
activity
before
it
occurs.
If
EPA
allows
the
new
use,
then
the
costs
associated
with
this
option
are
the
costs
of
submitting
the
SNUN
(
including
user
fee)
plus
the
possible
costs
of
following
Options
1
or
5
during
EPA
review
of
the
SNUN.

"
Option
4:
Request
for
an
equivalency
determination.
Under
40
CFR
§
721.30,
manufacturers,
importers
and
processors
may
petition
EPA
to
consider
alternative
controls
to
prevent
release
or
exposure
that
are
equivalent
to
those
identified
in
the
SNUR.
If
EPA
allows
the
alternative
controls,
then
the
costs
of
this
option
are
the
costs
of
submitting
a
request
for
equivalency
determination,
plus
the
possible
costs
of
following
Options
1
or
5
during
EPA
review
of
the
request.

"
Option
5:
Decision
not
to
manufacture,
import,
or
process
the
substance.
The
firm
may
decide
simply
not
to
proceed
to
manufacture,
import,
or
process
the
substance.
While
this
option
avoids
the
costs
of
meeting
the
specifications
in
the
SNUR
or
submitting
a
request
for
some
alternative,
it
entails
the

hidden

cost
of
the
profit
that
will
be
foregone
as
a
result
of
not
engaging
in
the
commercial
activity
originally
planned.

"
Pursue
multiple
options.
The
firm
may
pursue
more
than
one
option
simultaneously.
For
example,
it
may
temporarily
produce
within
the
SNUR
restrictions
(
Option
1)
while
submitting
both
a
request
to
modify
the
SNUR
(
Option
2)
and
a
SNUN
(
Option
3).
As
another
example,
the
firm
may
temporarily
refrain
from
production
(
Option
5)
while
petitioning
for
an
equivalency
determination
(
Option
4).

If
the
firm
makes
a
submission,
there
will
be
a
period
during
which
EPA
will
review
the
request
or
SNUN
submitted.
Even
if
EPA
grants
the
firm

s
request,
in
addition
to
the
submission
costs,
the
firm
would
incur
the
costs
resulting
from
following
Option
1
or
Option
5
for
the
length
of
the
EPA
review
period.
If
EPA
does
not
approve
the
request,
the
firm
may
fall
back
to
3
Options
1
or
5
as
a
longer
term
strategy,
with
their
associated
costs.

In
previous
analyses
of
SNURs,
EPA
has
identified
those
requirements
under
Subparts
A,
B,
C,
and
D
of
40
CFR
721
that
may
impose
costs
on
manufacturers,
importers,
and
processors
of
PMN
substances
(
e.
g.,
RIB
1989).
Some
of
these
costs,
such
as
providing
personal
protective
equipment
under
§
721.63,
are
estimated
and
presented
as
part
of
this
analysis.
Other
costs,
such
as
for
limiting
releases
to
water,
avoiding
uses
not
listed
in
the
PMN,
or
keeping
production
below
a
specified
level,
are
described
only
qualitatively.

The
different
options
available
to
a
firm
considering
the
manufacture,
import,
and/
or
processing
of
a
PMN
substance
covered
under
a
SNUR,
and
the
types
of
associated
costs
to
the
firm,
are
summarized
in
Table
1.
The
remainder
of
this
report
presents
estimates
of
the
quantified
portion
of
costs
associated
with
the
SNUR
being
promulgated
for
the
65
chemical
substances
listed
in
Appendix
A.
Section
2
presents
estimates
of
the
costs
incurred
by
manufacturers,
importers,
and/
or
processors
under
each
of
the
possible
SNUR
options
outlined
in
Table
1.
Section
3
addresses
one­
time
export
notification
costs.
Section
4
presents
estimates
of
the
costs
to
EPA
of
administering
the
SNUR,
while
Section
5
presents
an
analysis
of
other
impacts,
as
required
by
various
statutes
and
executive
orders.
4
Table
1
Compliance
Options
and
Associated
Costs
Incurred
by
a
Firm
due
to
SNUR
Option
Costs
1
Satisfy
the
limits
and/
or
requirements
specified
in
the
SNUR,
such
a
s
limiting
w
ater
releases,
stick
ing
to
PMN
uses
only,
impo
rting
only,
limiting
vo
lumes,
providing
workplace
protection,
or
providing
h
azard
comm
unications.
Costs
of
meeting
hazard
communication,
personal
protective
equipment,
and
recordk
eeping
re
quirem
ents
are
qu
antified
in
this
report.

Other
costs,
such
as
costs
of
assessing
compliance
with
water
release
restrictions
and,
if
needed,
limiting
water
releases,
or
foregoing
non­
PM
N
uses,
m
ay
exist
bu
t
are
not
qu
antified.

2
Submit
a
request
for
modification
and
revocation
of
the
SNUR
(
§
72
1.185).
Costs
of
submitting
a
request
for
modification
or
revocation,
including
costs
of
developing
suppor
ting
data
(
e
.
g.,
testing,
if
nee
ded).*

3
Submit
a
Significant
New
Use
Notice
(
SNUN),
indicating
to
EPA
that
the
firm
would
like
to
manufacture,
import,
or
process
the
chem
ical
for
a
Significant
New
Use

i.
e.,
in
some
way
other
than
what
is
specified
as
allowable
in
the
SNUR.
Costs
of
submitting
a
SNUN,
including
user
fee.
Testing
costs
are
also
possible,
but
only
for
a
small
minority
of
chemicals,
and
so
are
not
assigned
to
this
option.*

4
Petition
EP
A
for
an
equivale
ncy
dete
rminatio
n
to
consider
alternative
controls
to
prevent
release
or
exposure
that
are
equivalent
to
those
identified
in
the
SNUR.(
§
721.30)
Costs
of
submitting
a
request
for
equivalency
determ
ination.*

5
Decide
not
to
manufacture,
import,
or
process
the
substance,
or
manufacture
only
for
R&
D
(
The
R&
D
exem
ption
is
cov
ered
in
40
CFR
§
7
21.47).
Cost
of
the
profit
foregone
as
a
result
of
not
engag
ing
in
the
commercial
activity
o
riginally
planned
.
R&
D
recordk
eeping
c
osts
if
manufacture
for
R&
D.

§
numb
ers
refer
to
40
CFR
721
(
in
the
Co
de
of
Federal
R
egulations)
*
Firms
may
follow
Options
1
or
5
while
pursuing
Options
2,
3,
and/
or
4
(
i.
e.,
during
the
period
in
which
EPA
reviews
a
submitte
d
reque
st
or
SNU
N),
and
may
fa
ll
back
to
O
ptions
1
o
r
5
if
Optio
ns
2,
3
or
4
are
unsu
ccessful,
thus
incu
rring
costs
from
m
ore
than
o
ne
Optio
n.

2.0
COSTS
ASSOCIATED
WITH
A
SIGNIFICANT
NEW
USE
RULE
(
SNUR),
BY
OPTION
As
indicated
in
the
introduction,
the
SNUR
specifies
the
requirements
a
facility
must
meet
if
it
chooses
to
commence
manufacturing,
importing,
or
processing
a
PMN
chemical.
When
faced
with
a
SNUR,
however,
a
facility
may
take
one
of
several
courses
of
action
(
see
Table
1).
These
options
are
described
below
in
turn,
along
with
estimates
of
the
costs
of
each.
Unless
otherwise
indicated,
all
costs
are
in
year
2002
dollars.
Wage
rates
and
inflators
used
are
given
in
5
Appendix
B.

2.1
Comply
with
SNUR
Limits
(
Option
1)

Compliance
with
a
SNUR
entails
meeting
one
or
several
requirements
related
to
production
and
use,
as
shown
in
Table
2
below.
While
some
SNUR
requirements
or
restrictions
may
apply
to
all
PMN
substances
covered
in
the
SNUR,
most
do
not.
Among
the
65
chemicals
covered
in
this
SNUR,
for
example,
the
requirement
to
provide
hazard
communication
applies
to
only
four
(
see
Table
2).

Table
2
Production
and
Use
Restrictions/
Requirements
40
CFR
Reference
(
Code
of
F
ederal
Reg
ulations)
Restriction/
Requirement
Number
of
PMN
C
hemica
ls
Affected*

§
721.125
Recordkeeping
All
§
721.90
Limit
releases
to
water
33
§
721.80(
j)
Stick
to
uses
listed
in
PMN
17
§
721.8
0(
f)
Import
only
(
do
not
m
anufacture)
10
§
721.80
(
p)(
q)(
r)(
s)(
t)
or
(
u)
Limit
production
volume
4
§
721.63
Workplace
protection
3
§
721.72
Hazard
communication
4
§
721.80
(
o
ther
paragraph
s)
Conform
to
other
restrictions
10
*
Some
chemicals
have
more
than
one
type
of
restriction.

Water
releases,
production
volume
limits,
PMN
uses,
import­
only
Costs
associated
with
hazard
communication
(
§
721.72),
protective
equipment
(
§
721.63),
and
recordkeeping
(
§
721.40)
are
quantified
in
this
report.
Other
restrictions
may
also
result
in
costs
not
quantified
for
this
report.
For
example:

%
A
producer
could
incur
costs
of
determining
whether
discharges
to
water
would
constitute
a
Significant
New
Use
and
of
limiting
releases
in
order
to
avoid
the
Significant
New
Use.

%
Keeping
production
volume
below
specified
limits
to
avoid
a
Significant
New
Use
could
result
in
a
decrease
in
profits
if
the
firm
is
producing
for
sale,
a
potential

hidden

cost.
If
the
firm
is
producing
the
chemical
for
internal
use,
it
may
have
to
substitute
to
a
less
cost­
effective
chemical,
another
potential

hidden

cost.

%
Similarly,
avoiding
uses
not
listed
in
the
original
PMN
could
result
in

hidden

costs
of
6
foregone
profits
if
the
firm
cannot
market
the
chemical
for
certain
applications.
If
the
firm
wants
to
use
the
chemical
for
internal
use,
it
may
have
to
substitute
to
other
chemicals
or
technologies
which
cost
more
or
have
lesser
performance
resulting
in
higher
production
costs.

%
Importing
could
be
costlier
than
manufacturing
a
PMN
substance
in
the
US.

The
requirements
and
costs
of
meeting
the
hazard
communication
(
Haz­
Comm),
protective
equipment,
and
recordkeeping
requirements
are
summarized
below.
A
more
detailed
presentation
of
the
derivation
of
these
costs
is
given
in
Appendix
C.
The
costs
of
meeting
all
Haz­
Comm,
workplace
protection,
and
recordkeeping
requirements
are
presented,
separately
for
each
PMN,
at
the
end
of
Section
2
in
Table
10.
For
the
present
group
of
65
PMN
substances,
the
per­
chemical
annual
quantified
costs
of
complying
with
these
SNUR
restrictions
to
avoid
Significant
New
Uses
range
from
$
923
for
chemicals
requiring
only
recordkeeping
(
most
chemicals)
to
$
21,405
for
a
chemical
requiring
both
recordkeeping
and
workplace
protection
(
including
the
annual
cost
of
supplying
Type
4
respirators).

Hazard
Communication
Requirements
Each
SNUR
may
require
facilities
manufacturing,
importing,
or
processing
one
of
the
PMN
substances
to
implement
those
provisions
of
their
hazard
communication
(
Haz­
Comm)
program
that
pertain
to
new
chemical
substances.
In
the
current
batch
SNUR,
compliance
with
the
Haz­
Comm
requirements
is
specified
for
four
of
the
65
chemicals.

For
purposes
of
the
economic
analysis,
it
is
assumed
that
each
facility
has
in
place
a
Haz­
Comm
program
consistent
with
that
required
by
OSHA

s
Hazard
Communication
standard
(
29
CFR
1910;
November
25,
1983).
The
major
elements
of
the
Haz­
Comm
program
that
could
apply
to
a
new
chemical,
based
on
the
requirements
in
§
721.72,
are:

%
Revision
of
the
existing
written
Haz­
Comm
program
to
incorporate
information
about
the
new
chemical
[
§
721.72(
a)];

%
Creation
of
labels
and
application
of
labels
to
containers
used
for
distributing
the
chemical
in
commerce
[
§
721.72(
b)];

%
Creation
of
labels
or
signage
and
posting
of
hazard
data
in
areas
of
the
facility
where
the
chemical
is
used
or
stored
[
§
721.72(
b)];

%
Creation
and
distribution
of
material
safety
data
sheets
(
MSDSs)
[
§
721.72(
c)];
and
%
Employee
awareness
training
on
where
and
how
the
chemical
is
used,
the
hazards
associated
and
availability
of
hazard
information
about
the
chemical,
and
protective
7
equipment
and
other
measures
in
place
to
reduce
and
minimize
exposure
to
the
chemical
[
§
721.72(
d)].

Hazard
Communication
Costs
The
annual
costs
of
compliance
with
the
Haz­
Comm
requirements
for
PMN
substances
subject
to
Haz­
Comm
requirements
are
estimated
at
$
931
and
15
hours
per
substance,
as
summarized
in
Table
3.
Costs
are
for
substances
with
full
Haz­
Comm
requirements,
and
may
overstate
Haz­
Comm
costs
for
substances
with
partial
requirements.
The
derivation
of
these
costs
is
given
in
more
detail
in
Appendix
C.

Table
3
Annual
C
osts
of
Hazard
Co
mmunication
R
equirements
Requirement
Cost
($
2002)
Hours
Update
written
program
$
194
4.0
Labeling
Distribution
in
commerce
$
108
0.5
Use
in
the
workplace
$
311
1.5
MSDS
preparation
$
96
2.25
Employee
training
$
222
6.75
TOTAL
$
931
15.0
Figures
are
roun
ded
to
who
le
dollars.
Substances
n
ot
subject
to
all
of
these
requ
irements
ma
y
have
low
er
costs.
(
See
Ap
pendix
C
for
der
ivations.)

Protection
in
the
Workplace
Requirements
Under
§
721.63,
manufacturers,
importers,
or
processors
must
comply
with
any
worker
protection
requirements
specified
in
the
SNUR
for
a
chemical.
The
core
components
of
the
worker
protection
requirements
include
provision
of
personal
protective
equipment
(
PPE)
such
as
gloves,
goggles,
protective
clothing,
and
respirators.
PPE
requirements
are
specified
for
three
of
the
65
PMNs
covered
by
this
SNUR.

In
some
cases,
EPA
specifies
the
type
of
PPE
required.
In
other
cases,
EPA
requires
adequate
dermal
protection
but
does
not
specify
particular
PPE.
Instead,
it
requires
the
employer
to
evaluate
worker
exposure
conditions
and
hazards,
and
select
appropriate
PPE.
Generally
the
employer
is
also
required
to
do
one
or
both
of
the
following:
(
1)
perform
impermeability
testing
on
the
PPE
to
ensure
the
equipment
will
be
impervious
to
the
PMN
substance
under
the
expected
conditions
of
exposure,
and/
or
(
2)
rely
on
equipment
manufacturers
specifications
to
determine
whether
the
equipment
will
provide
adequate
protection.
Employers
not
already
providing
adequate
dermal
protection
would
need
to
do
so.
8
Protection
in
the
Workplace
Costs
The
costs
of
worker
protection
were
originally
estimated
in
a
1989
report,
Economic
Analysis
of
Final
Significant
New
Rules:
General
Provisions
for
New
Chemical
Follow­
Up
(
RIB
1989).
They
were
estimated
as
a
range
of
costs,
depending
on
the
assumed
number
of
workerdays
of
exposure.
The
current
analysis
uses
the
high­
end
of
the
assumptions
about
worker­
day
exposure,
and
updates
costs
to
2002
dollars.

Table
4
Annual
C
osts
of
Workplace
Pro
tection
Requirements
Requirement
Cost
Hours
Dermal
Protection
(
industrial
h
ygienist)
$
486
10.0
Impermeability
Testing
$
1,064
2.0
Evaluation
of
Manufacturer

s
Specifications
$
194
4.0
Subtot
al
$
1,745
16.0
Personal
Protective
Equipment
Gloves
(
disposable)
Gloves
(
heavy
duty)
$
3,012
$
9,527
­

Eyewea
r
(
standard
gog
gles)
Eyewea
r
(
heavy
du
ty
goggles)
$
340
$
509
Clothing
(
coverall,
no
hood)
Clothing
(
coverall
with
hood)
$
3,047
$
5,145
Respirators*

(
i)­
Type
1
Respirator
$
22,530
­

(
ii)­
Type
2
Respirator
$
22,530
­

(
iii)­
Type
3
Respirator
$
26,121
­

(
iv)­
Type
4
Respirator
$
18,737
­

(
v)­
Type
5
Respirator
$
67,321
­

(
vi)­
Type
6
Respirator
$
52,399
­

(
vii)­
Type
7
Respirator
$
10,159
­

(
viii)­
Type
8
Respirator
$
27,392
­

(
ix)­
Type
9
Respirator
$
67,321
­

(
x)­
Type
10
Respirator
$
52,385
­

(
xi)­
Type
11
Respirator
$
12,870
­

(
xii)­
Type
12
Respirator
$
20,050
­

(
xiii)­
Type
13
Respirator
$
80,812
­

(
xiv)­
Type
14
Respirator
$
75,583
­

(
xv)­
Type
15
Respirator
$
12,829
­

*
The
num
bers
in
parentheses
()
refer
to
paragraphs
at
40CFR721.63(
a)(
5)
listing
respirator
types.
Total
respirator
costs
include
costs
of
the
re
spirator
plus
the
costs
of
an
y
add­
on
item
s
such
as
hood
s,
helmets,
cartridges,
filters,
and
cap
s,
if
these
item
s
are
requ
ired
for
a
p
articular
resp
irator.
(
See
A
ppend
ix
C
for
d
erivations.)
9
The
costs
of
purchasing
protective
equipment
are
derived
in
Appendix
C,
and
have
been
annualized
based
on
the
assumptions
listed
above
regarding
their
use
and
lifetime
in
the
workplace.
Costs
for
evaluating
hazards
when
PPE
is
not
specified
in
the
SNUR
are
based
on
estimates
of
the
reasonable
time
required
for
a
safety
professional
to
perform
such
evaluations.
Costs
for
conducting
impermeability
testing
are
based
on
consultation
with
PPE
vendors,
as
described
in
Appendix
C.
Table
4
summarizes
the
annual
costs
associated
with
protection
in
the
workplace,
including
the
PPE
itself,
as
well
as
selecting
required
dermal
protection,
and
performing
impermeability
testing
and/
or
evaluating
manufacturer

s
information.

Table
5
below
is
a
summary
of
the
quantified
costs
of
the
worker
protection
requirements
for
substances
in
this
batch
SNUR.
Costs
are
per
chemical
produced
at
a
single
site.
The
costs
are
tabulated
for
each
PMN
substance
in
Appendix
C.

In
cases
where
the
SNUR
specified
the
type
of
protective
gear,
the
estimates
assume
workers
do
not
currently
wear
adequate
protective
equipment.
To
the
extent
that
workers
may
already
be
adequately
protected
(
as
a
result
of
the
company

s
own
safety
program
related
to
other
chemical
hazards,
or
to
comply
with
OSHA

s
PPE
standards),
these
costs
may
be
an
overestimate
of
the
actual
costs.
In
cases
where
the
SNUR
required
dermal
protection
but
did
not
specify
any
particular
gear,
it
was
not
feasible
to
determine
which
particular
gear
might
be
needed,
and
so
only
the
costs
of
assessing
needs
and
demonstrating
impermeability
were
included.
This
would
reflect
a
situation
where
the
dermal
protection
is
already
in
place
but
the
manufacturer
must
demonstrate
that
it
is
adequate.
If
companies
also
have
to
purchase
additional
protective
gear,
costs
would
be
higher
than
those
shown
here.
For
example,
if
a
firm
already
providing
gloves
and
goggles
determined
that
it
would
have
to
add
protective
clothing
(
coverall
without
hood)
to
avoid
engaging
in
a
Significant
New
Use,
annual
costs
would
be
$
3,047
higher
than
costs
in
the
table.

For
the
three
chemicals
requiring
workplace
protection,
costs
range
from
$
1,745
to
$
20,483
per
chemical.

Table
5
Annual
Costs
of
Workplace
Protection
Requirements
­
Summary
Protection
in
the
workplace
costs
No.
of
C
hemica
ls
Percen
t
of
Che
micals
Chemicals
with
no
costs
62
595.4%

Chemicals
with
costs
3
4.6%

equal
to
$
1,745
*
1
1.5%

equal
to
$
10,164
**
1
1.5%

equal
to
$
20,483
*,
**
1
1.5%

Total:
65
100.0%

*
Covers
dermal
protection
evaluation
only,
not
equipm
ent
costs
(
if
any).
**
Includes
costs
of
respirators
10
Recordkeeping
Requirements
Recordkeeping
requirements
are
specified
for
all
PMN
substances
based
on
the
requirements
in
§
721.125(
a­
k).
While
the
requirements
vary
somewhat
between
substances
(
i.
e.,
there
are
variations
in
terms
of
the
types
of
records
that
must
be
kept),
the
differences
are
judged
to
have
a
negligible
impact
on
the
type
of
recordkeeping
activities
that
must
be
performed
and
thus,
on
the
costs
that
will
be
incurred.

All
recordkeeping
requirements
essentially
involve
copying
and
filing
relevant
records,
including
those
related
to:
manufacturing,
importing,
or
processing
volumes;
shipment
amounts
and
customer
information;
labels
(
documentation
of
labeling
procedures
and
copies
of
labels);
MSDS;
and
compliance
with
any
additional
restrictions
on
use,
disposal,
and
discharge
limitations.

Recordkeeping
Costs
Annual
costs
for
compliance
with
the
recordkeeping
requirements
for
PMN
substances
subject
to
the
SNUR
are
derived
in
Appendix
C.
The
costs
include
technical
and
clericallabor
time,
reproduction
charges,
and
costs
for
records
storage.
As
shown
in
Table
6,
the
recordkeeping
requirements
are
estimated
to
cost
$
923
annually
per
substance.

Table
6
Annual
C
osts
of
Recordkeeping
R
equirements
Requirement
Cost
Hours
Technical
labor
$
98
2.25
Clerical
labor
$
551
23.0
Photocopies
$
130
­
File
cabinet
$
109
­
Miscellan
eous
m
aterials
$
35
­
TOTAL
$
923
25.25
Figures
are
roun
ded
to
who
le
dollars.
(
See
Ap
pendix
C
for
der
ivations.)

2.2
Modification
or
Revocation
of
a
SNUR
(
Option
2)

Under
40
CFR
§
721.185,
EPA
may
modify
or
revoke
a
SNUR
upon
review
of
a
submittal
from
a
manufacturer,
importer,
or
processor.
The
cost
of
the
option
to
the
manufacturer,
importer,
or
processor
includes
the
costs
of
submitting
a
request
for
modification
or
revocation,
plus
the
cost
of
developing
and
submitting
data
related
to
the
health
and
environmental
effects
of
the
chemical
(
e.
g.,
testing
costs).
This
option
could
have
some
or
all
of
the
following
costs:
11
%
Costs
of
testing
to
develop
health
and
environmental
effects
data
for
each
chemical
subject
to
the
batch
SNUR;

%
Costs
of
submitting
a
request
for
modification
or
revocation;

%
Costs
of
complying
with
SNUR
restrictions
(
or
of
avoiding
production)
while
the
modification
request
is
being
processed,
and
costs
of
complying
with
any
SNUR
restrictions
that
are
not
ultimately
revoked
(
see
the
discussion
of
Option
1
for
compliance
costs).

These
costs
are
discussed
below.

Costs
of
Developing
and
Submitting
Required
Testing
Data
For
each
PMN
substance,
the
SNUR
identifies
any
health,
ecological,
and/
or
fate/
transport/
transformation
testing
that
would
help
characterize
the
risks
associated
with
the
substance.
Such
testing
is
recommended
but
not
required
in
the
SNUR,
and
may
be
provided
by
the
submitter
to
support
a
request
for
modification
and
revocation
of
a
SNUR.
40
CFR
721.185(
b)(
1)
requires
that
a
modification
request
include

information
sufficient
to
support
the
request.

This
analysis
assumes
the
firm
elects
to
perform
all
of
the
tests.
In
some
cases
the
recommended
testing
is
indeed
needed
for
the
request
to
be
granted.
However,
in
other
cases,
full
testing
may
not
be
needed

for
example,
if
toxicity
information
has
become
available
from
another
source

and
costs
would
be
lower
than
shown
here.
If
no
testing
at
all
is
needed
with
a
modification
request,
costs
would
be
similar
to
costs
of
a
SNUN,
less
the
user
fee.
(
See
SNUN
discussion
below.)

The
SNUR
lists
recommended
tests
by
guideline
numbers
which
can
be
used
to
look
up
published
test
protocols.
Testing
costs
for
each
PMN
substance
are
calculated
by
adding
up
costs
for
individual
test
protocols
listed
in
the
SNUR
for
that
substance.
The
costs
for
individual
test
protocols
have
been
developed
by
EPA
over
the
years
to
support
TSCA
rule
development.
For
this
analysis,
costs
have
been
inflated
to
2002
dollars.
Detailed
information
on
the
procedure
used
to
estimate
testing
costs
for
each
PMN
substance
is
found
in
Appendix
D.

Table
7
below
summarizes
the
cost
ranges
of
the
testing
requirements
specified
for
63
of
the
65
PMN
chemicals.
For
two
chemicals,
the
SNUR
did
not
recommend
tests.
The
table
shows
a
range
of
test
costs
for
persistant
bioaccumulator
toxic
(
PBT)
chemicals
identified
for
tiered
testing,
since
tests
in
later
tiers
are
not
always
triggered
by
results
of
earlier
test
tiers
(
see
Appendix
D
for
details).

For
chemicals
with
tests,
testing
costs
range
from
$
19,980
to
$
2,070,673
per
chemical,
and
the
mean
testing
cost
is
$
298,649
per
chemical
using
the
low
end
of
testing
cost
range
and
12
$
325,026
using
the
high
end.
Test
costs
are
per
company,
and
are
one­
time
costs
(
not
annualized).
For
many
chemicals,
if
full
testing
is
needed,
the
test
costs
could
dominate
the
costs
quantified
in
this
report.
However,
essential
hazard
data
may
become
available
from
other
sources,
so
tests
are
not
always
needed.
Test
costs
in
Table
7
most
likely
represent
a
high­
side
estimate
of
testing
costs
attributable
to
the
SNUR.

Table
7
Costs
of
Testing
Requ
irements
Testing
Costs
No.
of
C
hemica
ls
Percen
t
of
Che
micals
Less
than
$
30,000
1
1.6%
Between
$
30,001
and
$
50,000
23
36.5%
Between
$
50,001
and
$
100,000
9
(
7)
14.3%
(
11.1%)
Between
$
100,001
and
$
500,000
22
(
24)
34.9%
(
38.1%)
Between
$
500,000
and
$
1,000,000
2
3.2%
Over
$
1,000,000
6
9.5%
Total:
63*
100.0%
Mean:
$
298,649
($
325,026)
Median:
$
98,595
($
118,008)
Minimum:
$
19,980
Maximum:
$
2,070,673
Numb
ers
in
parenthesis
are
de
rived
using
the
h
igh
end
of
testing
co
sts.
*
The
SN
UR
did
no
t
list
tests
for
two
of
the
65
chem
icals.
(
See
Ap
pendix
D
for
de
tails.)

Costs
for
Submitting
a
Request
for
Modification
or
Revocation
of
a
SNUR
The
costs
associated
with
submitting
a
request
for
modification
and
revocation
of
a
SNUR
are
estimated
to
be
similar
to
the
costs
for
preparing
a
PMN
submission.
In
its
Regulatory
Impact
Analysis
for
the
amendments
to
the
PMN
regulations,
EPA
relied
on
industry
estimates
of
the
effort
needed
to
collect
and
compile
all
data
required
for
a
PMN
submission,
prepare
the
form,
and
submit
the
form
and
data
to
EPA
(
RIB
1994).
These
estimates,
based
on
a
1991
survey
conducted
by
the
Chemical
Manufacturers
Association,
indicate
that
the
average
effort
required
to
prepare
and
submit
a
PMN
is
between
95
and
114
hours.
This
analysis
uses
the
average
of
the
estimated
hours
for
each
step,
resulting
in
a
cost
of
$
4,456.
The
costs
associated
with
these
labor
time
estimates
are
derived
in
Appendix
E.

Other
Costs
EPA

s
review
of
the
submitter

s
request
may
cause
delays
in
the
start
of
manufacturing
or
processing
activities.
Such
delays
could
cause
the
company
to
forego
opportunities
to
earn
13
profits
for
the
duration
of
the
review
period.
Alternatively,
the
submitter
may
elect
to
produce
under
the
constraints
of
the
SNUR
during
the
review
period,
so
as
to
avoid
a
Significant
New
Use.
EPA
may
not
revoke
all
SNUR
provisions
as
a
result
of
the
request.
If
the
company
is
allowed
to
continue
production
and
chooses
to
do
so,
it
would
bear
costs
of
complying
with
any
SNUR
restrictions
that
are
not
revoked.
Costs
of
complying
with
SNUR
restrictions
are
not
quantified
in
Table
8,
but
were
discussed
under
Option
1.

Table
8
Costs
of
Request
to
Modify/
Revoke
SNUR
or
Submit
SNUN
Request
to
Modify
or
Revoke
SNUR
(
Option
2)
Submit
a
SNUN
(
Option
3)

Hours
Total
Lab
or
Cost
(
wage
×
h
ours)
Hours
Total
Lab
or
Cost
(
wage
×
h
ours)

Costs
of
preparing
submission
105
$
4,456
105
$
4,456
User
fees
NONE
$
2,500
TOTAL
$
4,456
$
6,956
Test
Cos
ts
More
likely
Less
likely
Figures
are
rounded
to
whole
dollars.
(
See
Appendix
E
for
derivation)

Total
Costs
for
Option
2
The
total
costs
associated
with
requesting
a
modification
or
revocation
of
a
SNUR
include
the
costs
of
performing
any
needed
testing
plus
the
administrative
cost
of
preparing
the
submittal.
As
shown
above,
for
chemicals
with
tests,
testing
costs
may
range
from
$
19,980
to
$
2,070,673
per
chemical.
Other
quantified
costs
of
submitting
a
request
for
revocation
or
modification
are
$
4,456.
These
costs
are
combined
in
Table
9,
which
shows
total
costs
by
option
for
each
of
the
PMNs.
If
full
testing
is
not
needed,
costs
could
be
much
lower
than
shown
in
Table
9.

2.3
Submission
of
a
SNUN
(
Option
3)

Under
40
CFR
§
721.5,
manufacturers,
importers,
or
processors
who
would
like
to
undertake
a
Significant
New
Use
of
a
PMN
substance
listed
in
a
SNUR
are
required
to
submit
a
Significant
New
Use
Notice
(
SNUN).
For
example,
they
could
submit
a
SNUN
if
they
wish
to
produce
above
the
volume
limit
listed
in
the
SNUR
for
a
given
chemical,
since
any
production
beyond
that
volume
would
be
defined
as
a
Significant
New
Use.
The
notice
form
used
to
submit
a
SNUN
is
the
same
as
that
for
a
PMN,
and
the
costs
of
submitting
a
SNUN
are
estimated
based
14
on
the
costs
incurred
to
submit
a
PMN.
This
option
could
have
the
following
costs:

%
Costs
of
preparing
the
SNUN.

%
Cost
of
the
$
2500
user
fee.

%
Costs
of
complying
with
SNUR
restrictions
(
or
of
avoiding
production)
while
the
SNUN
is
being
processed;
costs
of
complying
with
any
restrictions
resulting
from
the
SNUN
review.
(
see
the
discussion
of
Option
1
for
compliance
costs).

%
The
SNUN
submitter
may
need
to
perform
some
of
the
tests
listed
in
the
batch
SNUR.
However,
the
likelihood
of
testing
being
needed
is
judged
to
be
less
for
a
SNUN
than
for
the
request
to
modify
the
SNUR
(
Option
2).
This
analysis
assumes
the
firm
would
not
perform
testing
for
the
SNUN.
(
If
testing
were
needed,
then
Option
3
costs
may
be
closer
to
those
estimated
for
Option
2.)

Another
option
available
to
sites
before
the
SNUR
is
promulgated
is
to
seek
an
advance
compliance
exemption
under
§
721.45(
h).
The
submission
cost
for
the
option
is
the
same
as
that
for
a
SNUN,
but
by
negotiating
an
advance
compliance
agreement
with
EPA
a
company
can
diminish
the
loss
of
profits
due
to
delay.
This
option
is
not
available
after
the
SNUR
is
promulgated.

Costs
for
Submitting
a
SNUN
As
with
Option
2
above
(
Modification
or
Revocation
of
a
SNUR),
the
costs
for
submitting
a
SNUN
are
estimated
to
be
equivalent
to
the
costs
of
completing
a
PMN
submission.
From
Table
8,
the
costs
of
preparing
a
SNUN
are
$
6956,
including
the
$
2500
user
fee
(
as
shown
in
Appendix
E).
If
the
SNUN
is
submitted
at
the
same
time
as
a
request
to
modify
a
SNUR
(
Option
2),
the
added
would
be
less
than
shown
here
due
to
overlap
in
information
in
the
two
submissions.
In
addition,
as
was
mentioned
above,
there
could
be
testing
costs,
delay
costs,
or
other
costs
not
included
in
Table
9
for
this
option.

2.4
Request
for
an
Equivalency
Determination
(
Option
4)

Under
40
CFR
§
721.30,
EPA
may
review
applications
from
facilities
who
propose
alternative
methods
of
controlling
or
preventing
exposures
or
releases
to
those
specified
in
the
SNUR.
In
these
cases,
EPA
evaluates
the
alternatives
using
an
abbreviated
review
process.
The
costs
of
submitting
an
equivalency
determination
request
are
expected
to
be
the
same
as
those
for
submitting
a
SNUN
in
Option
3,
except
that
no
user
fee
is
required.
Thus,
the
costs
for
this
option
are
estimated
at
$
4456.
15
For
this
option
the
EPA
review
period
is
45
days
compared
to
90
days
for
a
SNUN,
therefore
any
potential
loss
of
profits
due
to
delays
may
be
less
than
for
a
SNUN
under
Option
3.

In
addition
to
the
costs
of
submitting
the
equivalency
determination
request,
each
submitter
will
also
incur
costs
to
develop
data
to
support
the
request.
These
costs
were
not
quantified.
Presumably,
however,
a
submitter
would
not
choose
this
option
unless
the
total
costs
of
this
option,
including
the
costs
of
complying
with
the
proposed
alternative
requirements,
were
less
than
the
costs
of
complying
with
controls
listed
in
the
SNUR

for
example,
controls
related
to
workplace
protection
or
environmental
release
(
Option
1).
Otherwise
there
would
be
no
incentive
for
the
submitter
to
choose
this
alternative.

2.5
Decision
Not
to
Produce
Chemical
(
Option
5)

Some
firms
may
find
that
the
costs
of
meeting
the
SNUR
requirements
and/
or
restrictions
(
Option
1)
or
preparing
a
SNUN
or
other
submission
(
Options
2,
3,
or
4)
are
financially
unattractive.
In
these
cases,
the
firm
could
choose
not
to
manufacture,
import,
or
process
the
PMN
substance.
If
the
firm
chooses
this
option,
it
would
avoid
the
costs
that
would
be
incurred
under
these
other
options,
but
could
instead
incur

hidden

costs
as
a
result
of
not
manufacturing,
importing,
or
processing
the
PMN
substance.
For
example,
if
the
firm
does
not
produce
the
PMN
substance,
then
it
will
forego
the
profit
it
would
have
achieved
by
producing
it.
That
foregone
profit
is
a
potential

hidden

cost
of
Option
5.
Similarly,
if
the
firm
would
have
used
a
given
amount
of
the
PMN
substance
in
the
production
of
another
product
and
must
substitute
to
a
more
costly
substance,
it
will
incur
those
additional
costs
of
production.
If
the
firm
elects
to
produce
for
R&
D
purposes
only,
it
may
have
costs
associated
with
R&
D
recordkeeping.

2.6
Summary
of
Costs
for
Each
Option
Table
9
presents,
for
each
PMN,
the
quantified
costs
of
the
first
four
options.
Companies
may
pursue
more
than
one
option
at
a
time,
such
as
temporarily
producing
in
conformance
with
Option
1
restrictions,
while
also
submitting
a
SNUN
and
requesting
a
modification
to
the
SNUR.

Costs
are
estimated
for
one
chemical
at
one
site,
and
reflect
SNUR
restrictions
and
testing
specific
to
each
chemical.
They
are
not
otherwise
adjusted
for
the
nature
of
the
chemical
or
process,
volume,
location,
or
other
firm­
specific
or
chemical­
specific
factors.
EPA
receives
an
average
of
ten
notices
per
year
due
to
SNURs,
but
the
number
of
firms
affected
but
not
making
submissions
is
not
known,
and
costs
are
not
aggregated.

Most
or
all
of
the
PMN
chemicals
in
the
SNUR
are
subject
to
recordkeeping
and
testing
costs.
Most
are
also
subject
to
unquantified
costs
due
to
use,
water
release,
volume
or
other
restrictions
for
which
the
magnitude
of
impact
is
not
known.
By
contrast,
only
a
few
are
subject
to
workplace
protection
or
hazard
communication
costs,
which
appear
to
be
relatively
modest.
16
Of
the
quantified
costs,
testing
costs
have
the
potential
to
dominate
all
other
costs,
but
only
if
testing
is
indeed
needed
to
support
a
submission.

Table
10
shows
the
annual
per­
site
costs
of
haz­
comm,
protection
in
the
workplace,
and
recordkeeping
by
chemical.
All
of
the
chemicals
had
recordkeeping
costs
of
$
923.
As
mentioned
previously,
those
chemicals
with
haz­
comm
costs
were
assumed
to
have
the
same
cost
at
$
931.19.
Two
of
the
three
chemicals
that
had
quantifiable
protection
in
the
workplace
requirements
had
respirator
costs
and
two
of
the
three
chemicals
had
costs
for
dermal
protection
selection
and
equipment
evaluation.

The
salient
features
of
the
costs
of
each
of
the
five
options
are
summarized
as
follows:

Option
1

Compliance
with
the
SNUR
restrictions
to
avoid
Significant
New
Use
Three
categories
of
cost

hazard
communication,
workplace
respiratory
protection,
and
recordkeeping

have
been
quantified
for
this
report.
Workplace
dermal
protection
has
been
partly
quantified.
These
quantified
costs,
presented
in
Table
10,
are
modest
for
most
of
the
SNUR
chemicals,
when
estimated
for
an
assumed
25
exposed
workers
and
roughly
10,000
kg
annual
shipment
volume
per
plant
for
one
chemical.

"
Most
PMN
chemicals
(
61
of
the
65)
require
only
recordkeeping,
which
is
estimated
to
cost
$
923
per
year.

"
Three
PMN
chemicals
require,
in
addition,
hazard
communication,
which
is
estimated
to
cost
$
931
per
year,
for
a
total
annual
cost
of
$
1,854.

"
Quantified
annual
costs
among
the
remaining
three
chemicals
are
estimated
to
be
$
2,668,
for
dermal
protection
evaluation
(
excluding
equipment
costs),
and
$
12,013
and
$
21,405
for
two
different
levels
of
respiratory
protection.

In
addition,
there
are
a
variety
of
potential
costs
that
have
not
been
quantified
in
this
report

not
because
these
costs
are
necessarily
small,
but
because
they
are
difficult
to
quantify

for
example,
the
cost
of
limiting
releases
to
water,
the
cost
of
limiting
production
volume,
the
cost
of
avoiding
non­
allowed
uses
of
the
PMN
substance,
and
the
cost
of
importing
rather
than
manufacturing
the
PMN
substance.
Most
chemicals
listed
in
the
SNUR
have
restrictions
that
could
lead
to
nonquantified
costs.

Option
2

Modification
or
revocation
of
the
SNUR
As
noted
in
Section
2.2,
there
are
three
potential
components
to
the
cost
of
Option
2:
submitting
the
request,
testing,
and
non­
quantified
costs.

"
The
cost
associated
with
submitting
a
request
for
modification
or
revocation
of
a
SNUR
is
17
estimated
to
be
$
4,456
and
will
be
incurred
if
this
option
is
chosen.
There
is
no
user
fee.

"
In
addition,
there
may
be
testing
costs.
Testing
is
recommended
for
most
chemicals,
and
while
not
mandatory,
may
be
performed
by
the
submitter
to
support
a
request
for
modification
or
revocation
of
a
SNUR.
The
costs
of
testing
are
highly
variable,
depending
on
the
particular
test(
s)
listed
in
the
SNUR
for
each
chemical.
If
all
listed
tests
are
performed,
testing
costs
are
estimated
to
range
from
$
19,980
to
$
2,070,673
per
chemical;
however,
the
bulk
of
the
PMN
chemicals
would
require
testing
costs
between
$
30,000
and
$
500,000.
For
most
chemicals,
if
all
listed
tests
are
performed
as
a
result
of
the
SNUR,
test
costs
would
dominate
other
quantified
costs.

Both
the
costs
of
submission
of
the
request
and
testing
costs
are
one­
time
costs
(
not
annualized).
The
total
quantified
cost
of
this
option
thus
ranges
from
a
one­
time
cost
of
$
24,436
to
a
one­
time
cost
of
$
2,075,129,
if
testing
is
involved,
and
could
be
as
low
as
$
4,456
if
it
is
not.

As
with
Option
1,
there
may
also
be
costs
that
have
not
been
quantified
in
this
report,
and
this
lack
of
quantification
reflects
the
difficulty
of
quantifying
these
costs
rather
than
their
relative
magnitude.

Option
3

Submission
of
a
SNUN
The
quantified
cost
of
Option
3
consists
of
the
cost
of
submitting
the
SNUN,
$
4,456,
plus
a
user
fee
of
$
2,500,
for
a
total
quantified
cost
of
$
6,956.
As
with
the
cost
of
Option
2,
this
is
a
one­
time
cost.

In
addition,
there
could
be
testing
costs
like
those
in
Option
2.
These
are
judged
to
be
needed
in
relatively
few
cases,
so
were
not
included
in
Option
3
quantified
costs.
There
also
could
be
delay
costs,
or
other
costs
not
quantified
in
this
report.

Option
4

Request
for
an
equivalency
determination
The
quantified
cost
of
requesting
an
equivalency
determination
consists
of
the
one­
time
cost
of
$
4,456
for
the
submittal
of
the
request.
There
is
no
user
fee
involved.

Option
5

Avoid
manufacture
(
except
for
R&
D
uses)

Although
none
of
the
costs
of
Option
5
are
direct
costs
of
satisfying
requirements
or
preparing
submissions,
and
none
of
the
costs
of
this
option
have
been
quantified
in
this
report,
there
may
nevertheless
be

hidden

costs
if
the
firm
decides
to
avoid
the
manufacture,
import,
or
processing
of
the
PMN
substance.
The
magnitude
of
these
hidden
costs
is
unknown
and
will
depend
on
particular
circumstances.
18
Table
9
Costs
by
PMN
Chemical
and
Option
Option
1
Option
2
Option
3
Option
4
Produce
within
SNUR
criteria
to
avoid
signif.
new
use
(
a)
Modification
or
Revocation
of
SNUR
(
b)
Submission
of
SNUN
(
c)
Request
for
Equivalency
Determination
(
d)(
e)
Cost
Range
Hours
Range
No.
PMN
Cost
Hours
Low
High
Low
High
Cost
Hours
Cost
Hours
1
P­
97­
1108
$
923
25.3
$
122,464
$
122,464
1,168
1,168
$
6,956
105
$
4,456
105
2
P­
98­
848
$
923
25.3
$
2,075,129
$
2,075,129
25,310
25,310
$
6,956
105
$
4,456
105
3
P­
98­
1033
$
1,854
40.3
$
301,972
$
301,972
3,392
3,392
$
6,956
105
$
4,456
105
4
P­
98­
1034
$
1,854
40.3
$
301,972
$
301,972
3,392
3,392
$
6,956
105
$
4,456
105
5
P­
98­
1035
$
1,854
40.3
$
301,972
$
301,972
3,392
3,392
$
6,956
105
$
4,456
105
6
P­
99­
783
$
923
25.3
$
24,435
$
24,435
218
218
$
6,956
105
$
4,456
105
7
P­
99­
817
$
923
25.3
$
345,009
$
345,009
2,562
2,562
$
6,956
105
$
4,456
105
8
P­
99­
897
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
9
P­
99­
920
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
10
P­
99­
928
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
11
P­
99­
951
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
12
P­
99­
952
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
13
P­
99­
1075
$
923
25.3
$
81,653
$
81,653
628
628
$
6,956
105
$
4,456
105
14
P­
99­
1202
$
923
25.3
$
422,207
$
422,207
3,086
3,086
$
6,956
105
$
4,456
105
15
P­
99­
1288
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
16
P­
99­
1295
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
17
P­
99­
1304
$
923
25.3
$
378,613
$
378,613
2,742
2,742
$
6,956
105
$
4,456
105
18
P­
99­
1341
$
923
25.3
$
34,673
$
34,673
302
302
$
6,956
105
$
4,456
105
19
P­
99­
1342
$
923
25.3
$
34,673
$
34,673
302
302
$
6,956
105
$
4,456
105
20
P­
00­
7
$
923
25.3
$
345,009
$
345,009
2,562
2,562
$
6,956
105
$
4,456
105
21
P­
00­
368
$
12,013
40.3
$
411,223
$
411,223
3,026
3,026
$
6,956
105
$
4,456
105
22
P­
00­
636
$
2,668
41.3
$
1,333,813
$
1,333,813
13,404
13,404
$
6,956
105
$
4,456
105
23
P­
00­
838
$
923
25.3
$
38,939
$
38,939
396
396
$
6,956
105
$
4,456
105
24
P­
00­
912
$
923
25.3
$
1,081,076
$
1,399,774
10,154
13,659
$
6,956
105
$
4,456
105
Option
1
Option
2
Option
3
Option
4
Produce
within
SNUR
criteria
to
avoid
signif.
new
use
(
a)
Modification
or
Revocation
of
SNUR
(
b)
Submission
of
SNUN
(
c)
Request
for
Equivalency
Determination
(
d)(
e)
Cost
Range
Hours
Range
No.
PMN
Cost
Hours
Low
High
Low
High
Cost
Hours
Cost
Hours
19
25
P­
00­
966
$
923
25.3
$
48,273
$
48,273
396
396
$
6,956
105
$
4,456
105
26
P­
00­
991
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
27
P­
00­
1055
$
923
25.3
$
1,488,592
$
1,488,592
14,902
14,902
$
6,956
105
$
4,456
105
28
P­
00­
1205
$
923
25.3
$
38,959
$
38,959
326
326
$
6,956
105
$
4,456
105
29
P­
00­
1220
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
30
P­
01­
1
$
923
25.3
$
57,814
$
57,814
516
516
$
6,956
105
$
4,456
105
31
P­
01­
7
$
923
25.3
$
902,690
$
902,690
9,536
9,536
$
6,956
105
$
4,456
105
32
P­
01­
9
$
923
25.3
$
160,308
$
479,006
1,045
4,550
$
6,956
105
$
4,456
105
33
P­
01­
22
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
34
P­
01­
69
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
35
P­
01­
71
$
923
25.3
$
88,747
$
88,747
710
710
$
6,956
105
$
4,456
105
36
P­
01­
77
$
923
25.3
$
147,524
$
147,524
1,430
1,430
$
6,956
105
$
4,456
105
37
P­
01­
85
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
38
P­
01­
97
$
923
25.3
$
925,224
$
925,224
9,214
9,214
$
6,956
105
$
4,456
105
39
P­
01­
144
$
923
25.3
$
279,249
$
279,249
3,306
3,306
$
6,956
105
$
4,456
105
40
P­
01­
149
$
923
25.3
$
125,584
$
125,584
938
938
$
6,956
105
$
4,456
105
41
P­
01­
152
$
923
25.3
$
98,637
$
501,626
559
4,669
$
6,956
105
$
4,456
105
42
P­
01­
170
$
21,405
41.3
$
4,456
$
4,456
104
104
$
6,956
105
$
4,456
105
43
P­
01­
298
$
923
25.3
$
103,051
$
103,051
1,262
1,262
$
6,956
105
$
4,456
105
44
P­
01­
320
$
923
25.3
$
345,009
$
345,009
2,562
2,562
$
6,956
105
$
4,456
105
45
P­
01­
397
$
923
25.3
$
81,653
$
81,653
628
628
$
6,956
105
$
4,456
105
46
P­
01­
420
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
47
P­
01­
423
$
923
25.3
$
345,009
$
345,009
2,562
2,562
$
6,956
105
$
4,456
105
48
P­
01­
432
$
923
25.3
$
1,513,379
$
1,513,379
14,680
14,680
$
6,956
105
$
4,456
105
49
P­
01­
433
$
923
25.3
$
378,613
$
378,613
2,742
2,742
$
6,956
105
$
4,456
105
Option
1
Option
2
Option
3
Option
4
Produce
within
SNUR
criteria
to
avoid
signif.
new
use
(
a)
Modification
or
Revocation
of
SNUR
(
b)
Submission
of
SNUN
(
c)
Request
for
Equivalency
Determination
(
d)(
e)
Cost
Range
Hours
Range
No.
PMN
Cost
Hours
Low
High
Low
High
Cost
Hours
Cost
Hours
20
50
P­
01­
441
$
923
25.3
$
98,637
$
501,626
559
4,669
$
6,956
105
$
4,456
105
51
P­
01­
459
$
923
25.3
$
345,009
$
345,009
2,562
2,562
$
6,956
105
$
4,456
105
52
P­
01­
460
$
923
25.3
$
345,009
$
345,009
2,562
2,562
$
6,956
105
$
4,456
105
53
P­
00­
992
and
P­
01­
471
$
923
25.3
$
81,653
$
81,653
628
628
$
6,956
105
$
4,456
105
54
P­
01­
481
$
923
25.3
$
4,456
$
4,456
104
104
$
6,956
105
$
4,456
105
55
P­
01­
561
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
56
P­
01­
573
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
57
P­
01­
578
$
923
25.3
$
34,673
$
34,673
302
302
$
6,956
105
$
4,456
105
58
P­
01­
646
$
923
25.3
$
34,673
$
34,673
302
302
$
6,956
105
$
4,456
105
59
P­
01­
716
$
923
25.3
$
260,670
$
479,006
1,908
4,550
$
6,956
105
$
4,456
105
60
P­
01­
781
$
923
25.3
$
1,351,498
$
1,351,498
12,442
12,442
$
6,956
105
$
4,456
105
61
P­
01­
833
$
923
25.3
$
345,009
$
345,009
2,562
2,562
$
6,956
105
$
4,456
105
62
P­
02­
17
$
923
25.3
$
103,051
$
103,051
1,262
1,262
$
6,956
105
$
4,456
105
63
P­
02­
90
$
923
25.3
$
345,009
$
345,009
2,562
2,562
$
6,956
0105
$
4,456
105
64
P­
02­
207
$
923
25.3
$
38,060
$
38,060
284
284
$
6,956
105
$
4,456
105
65
P­
02­
262
$
923
25.3
$
378,613
$
378,613
2,742
2,742
$
6,956
105
$
4,456
105
Minimum
$
923
25
$
4,456
$
4,456
105
105
$
6,956
105
$
4,456
105
Maximum
$
21,405
41
$
2,075,129
$
2,075,129
25311
25311
$
6,956
105
$
4,456
105
Average
$
1,479
27
$
293,916
$
319,481
2746
3021
$
6,956
105
$
4,456
105
Median
$
923
25
1$
98,637
$
103,051
710
1168
$
6,956
105
$
4,456
105
21
(
a)
Option
1
includes
annual
costs
for
recordkeeping
($
923),
haz­
comm
($
931),
and
worker
protection.
Costs
of
other
restrictions
were
not
quantified
(
limiting
water
discharges,
avoiding
uses
not
listed
in
PMN,
import
only,
limiting
production
volume,
etc.).
See
Table
10
and
Appendix
C.

(
b)
Option
2
includ
es
one­
time
costs
of
request
to
modify/
revoke
SNUR
($
4,456)
and
for
testing.
For
chemicals
with
PBT
testing,

low

cost
assumes
Tier
1
test
results
do
not
trigger
more
testing.

High

costs
assume
Tier
1
test
results
trigger
more
testing.
(
See
Appendix
D.)
Costs
of
following
SNUR
restrictions
pending
Agency
revocation
of
SNUR
were
not
quantified.
If
full
testing
is
not
needed,
costs
would
be
lower.
For
test
costs
by
PMN
chemical,
see
Table
D­
3.

(
c)
Option
3
include
s
one­
time
costs
of
SNUN
($
4,456)
plus
a
$
2500
user
fee.
Costs
of
following
restrictions
during
or
resulting
from
Agency
review
were
not
quantified.
Analysis
assumes
no
testing
costs
for
this
option.
If
testing
is
also
needed,
costs
would
be
higher.

(
d)
Option
4
includ
es
one­
time
costs
of
request
for
equivalency
determination
($
4,456).
Costs
of
following
SNUR
restrictions
during
review
and
of
alternative
controls
were
not
quantified.

(
e)
Option
5
(
no
production
or
import
except
for
R&
D),
has
no
quantified
costs
and
so
is
not
listed
in
this
table.
However,
most
PMN
chemicals
have
other
restrictions
which
could
lead
to
unq
uantified
costs,
such
as
restrictions
on
releases
to
water,
uses
not
listed
in
PM
N,
or
produc
tion
volumes.
22
Table
10
Annual
Per­
Site
Haz­
Comm,
Protection
in
the
Workplace,
and
Recordkeeping
Costs,
by
Chemical
Hazard
Commun
Workplace
Protection
Record
Keeping
Total
Total
Cost
Hours
Cost
Hours
Cost
Hours
Cost
Hours
No.
PMN
1
P­
97­
1108
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
2
P­
98­
848
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
3
P­
98­
1033
$
931.19
15
$
0.00
0
$
923
25.3
$
1,854
40.3
4
P­
98­
1034
$
931.19
15
$
0.00
0
$
923
25.3
$
1,854
40.3
5
P­
98­
1035
$
931.19
15
$
0.00
0
$
923
25.3
$
1,854
40.3
6
P­
99­
783
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
7
P­
99­
817
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
8
P­
99­
897
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
9
P­
99­
920
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
10
P­
99­
928
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
11
P­
99­
951
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
12
P­
99­
952
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
13
P­
99­
1075
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
14
P­
99­
1202
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
15
P­
99­
1288
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
16
P­
99­
1295
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
17
P­
99­
1304
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
18
P­
99­
1341
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
19
P­
99­
1342
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
20
P­
00­
7
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
21
P­
00­
368
$
931.19
15
$
10,158.75*
0
$
923
25.3
$
12,013
40.3
22
P­
00­
636
$
0.00
0
$
1,744.65**
16
$
923
25.3
$
2,668
41.3
23
P­
00­
838
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
24
P­
00­
912
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
25
P­
00­
966
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
26
P­
00­
991
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
27
P­
00­
1055
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
28
P­
00­
1205
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
29
P­
00­
1220
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
30
P­
01­
1
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
31
P­
01­
7
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
32
P­
01­
9
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
33
P­
01­
22
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
34
P­
01­
69
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
35
P­
01­
71
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
36
P­
01­
77
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
37
P­
01­
85
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
38
P­
01­
97
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
39
P­
01­
144
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
Hazard
Commun
Workplace
Protection
Record
Keeping
Total
Total
Cost
Hours
Cost
Hours
Cost
Hours
Cost
Hours
No.
PMN
23
40
P­
01­
149
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
41
P­
01­
152
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
42
P­
01­
170
$
0.00
0
$
20,481.99
16
$
923
25.3
$
21,405
41.3
43
P­
01­
298
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
44
P­
01­
320
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
45
P­
01­
397
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
46
P­
01­
420
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
47
P­
01­
423
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
48
P­
01­
432
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
49
P­
01­
433
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
50
P­
01­
441
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
51
P­
01­
459
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
52
P­
01­
460
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
53
P­
00­
992
and
P­
01­
471
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
54
P­
01­
481
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
55
P­
01­
561
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
56
P­
01­
573
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
57
P­
01­
578
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
58
P­
01­
646
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
59
P­
01­
716
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
60
P­
01­
781
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
61
P­
01­
833
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
62
P­
02­
17
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
63
P­
02­
90
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
64
P­
02­
207
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
65
P­
02­
262
$
0.00
0
$
0.00
0
$
923
25.3
$
923
25.3
*
This
cost
consists
of
the
annual
cost
of
supplying
respirators.
For
this
chemical,
the
SNUR
listed
a
choice
between
Type
3,
4,
5,
6,
or
7
respirators.
The
annual
cost
of
the
least
expensive
respirator
(
Type
7)
is
used
here.
**
This
cost
consists
of
dermal
protection
selection
($
486.04)
and
impermeability
testing
/
evaluation
of
manufacturer

s
specifications
($
1258.61).
Costs
of
added
dermal
protection
equipment,
if
any,
not
included.
***
This
cost
consists
of
dermal
protection
selection
($
486.04),
impermeability
testing
/
evaluation
of
manufacturer

s
specifications
($
1258.61),
and
the
annual
cost
of
supplying
Type
4
respirators
($
18,737.34).
Costs
of
added
dermal
protection
equipment,
if
any,
not
included.
24
3.0
EXPORT
NOTIFICATION
COSTS
Under
Section
12(
b)
of
TSCA,
exporters
must
notify
EPA
if
they
export
or
intend
to
export
a
chemical
substance
or
mixture:

"

For
which
submission
of
data
is
required
under
Section
4
or
5(
b);
"

For
which
an
order
has
been
issued
under
Section
5;
"

For
which
a
rule
has
been
proposed
or
promulgated
under
Section
5
or
6;
or
"

With
respect
to
which
an
action
is
pending
or
relief
has
been
granted
under
Section
5
or
7.

Notifications
must
be
submitted
in
writing
and
must
include
the
following
information:
exporter

s
name
and
address,
name
of
the
regulated
chemical,
the
date(
s)
of
export
or
intended
export,
the
importing
country
(
or
countries),
and
the
section
of
TSCA
under
which
EPA
has
taken
action.
This
is
a
one­
time
notification
requirement,
and
the
exporter
need
only
submit
the
notice
when
it
is
exporting
a
particular
chemical
for
the
first
time
to
a
country
for
which
it
has
not
previously
submitted
a
notification.

In
an
economic
analysis
of
an
amendment
to
the
rules
implementing
TSCA
Section
12(
b),
EPA
estimated
that
the
one­
time
cost
of
preparing
and
submitting
an
export
notification
was
$
62.60
in
1992
(
Silagi
1992),
or
$
89.29
when
inflated
to
2002
dollars
by
a
factor
of
approximately
1.43,
from
the
Employment
Cost
Index
for
White
Collar
Occupations
(
BLS
2003a;
see
Appendix
B).
The
total
costs
of
export
notification
will
vary
per
chemical,
depending
on
the
number
of
required
notifications
(
i.
e.,
number
of
countries
to
which
the
chemical
is
exported).
EPA
is
unable
to
make
any
estimate
of
the
likely
number
of
export
notifications
for
chemicals
covered
in
this
SNUR.

4.0
AGENCY
COSTS
EPA

s
costs
to
review
and
process
industry
submissions
(
SNUNs,
requests
to
modify
SNUR,
and
requests
for
equivalency
determination)
are
assumed
to
be
the
same
as
EPA
costs
to
review
PMNs.
These
costs
are
estimated
at
$
4,034
per
case.
The
Agency
actions
required,
fulltime
equivalent
(
FTE)
staff
needs,
and
extramural
costs
such
as
for
contractor
support
are
derived
in
Appendix
F
from
EPA

s
analysis
of
the
Agency
costs
of
processing
PMN
submissions
(
RIB
1994),
with
updates
to
2002
prices.
The
original
EPA
analysis
used
a
range
of
salaries,
but
this
analysis
uses
only
the
average
salary.
See
Appendix
F
for
details.

5.0
ADDITIONAL
ANALYSES
This
section
presents
additional
analysis
of
other
potential
impacts
of
this
rulemaking,
as
required
under
various
statutes
and
executive
orders.
1Bona
fides
are
submitted
to
EPA
by
manufacturers
and
importers
to
determine
a
chemical

s
TSCA
Chemical
Inventory
and
regulatory
status.

2
Due
to
timing
and
resource
limitations,
another
possible
source
of
data
­­
the
year
2002
industry
reporting
under
the
1986
Inventory
Update
Rule
(
51
FR
21438)
­­
was
not
tapped
for
this
report.

25
5.1
Regulatory
Flexibility
Act
(
RFA)

The
Regulatory
Flexibility
Act
(
RFA)
(
5
U.
S.
C.
601
et.
seq.),
as
amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act,
requires
regulators
to
consider
the
impact
of
regulations
on
small
entities,
in
particular
small
businesses.
EPA

s
experience
to
date
is
that,
in
response
to
the
promulgation
of
SNURS
covering
over
1000
chemicals
,
the
Agency
receives
an
average
of
only
ten
notices
per
year.
Of
those
SNUNs
submitted,
none
appear
to
be
from
small
entities
in
response
to
any
SNUR.
In
fact,
EPA
expects
to
receive
few,
if
any,
SNUNs
from
either
large
or
small
entities
in
response
to
any
SNUR.

This
leaves
open
the
question
of
how
many
small
businesses
are
affected
but
do
not
submit
SNUNs.
For
example,
businesses
may
change
their
behavior
in
order
to
use
a
chemical
in
a
manner
that
avoids
triggering
the
SNUR.

Data
and
resources
were
not
available
to
estimate
the
number
of
small
businesses
affected
by
the
current
rule.
However,
a
1989
analysis
suggested
that
few
small
businesses
would
be
affected
by
SNURs
for
chemicals
that
have
undergone
PMN
review.
The
1989
report
estimated
that
9%
of
firms
subject
to
SNURs
would
be
small
businesses,
based
on
the
portion
of
PMN
submitters
who
were
small
businesses.
(
Long
1989)
The
cutoff
for

small
business

was
$
40
million
in
sales,
which
is
consistent
with
the
definition
used
at
40
CFR
700.43
to
set
PMN
fees.

Past
bona
fide
submissions
also
suggest
that
few
firms
other
than
possibly
some
PMN
submitters
will
be
affected.
1
EPA
has
received
few
bona
fides
indicating
interest
in
manufacturing
or
importing
chemicals
subject
to
past
SNURs.
EPA
also
has
received
few
public
comments
during
rulemaking
on
SNURs
covering
PMN
chemicals.
For
example,
a
SNUR
published
in
the
Spring
of
2003
covering
62
chemicals
resulted
in
industry
comments
on
only
three
PMNs,
none
from
small
businesses
(
EPA
Docket
#
OPPT­
2002­
0060).
2
It
remains
possible
that
some
small
businesses
are
affected
by
SNURs
without
EPA
being
aware,
if
the
firms
have
made
no
submissions
or
comments
to
EPA.
However,
even
if
a
small
business
were
interested
in
supplying
a
SNUR
chemical,
the
SNUR

s
impact
on
profits
is
generally
expected
to
be
minor.
For
example,
the
firm
may
have
a
small
expense
of
keeping
records
and/
or
of
changing
workplace
practices
to
comply
with
restrictions.
If
modifying
production
practices
would
be
overly
costly,
or
if
the
firm
wishes
to
engage
in
a
Significant
New
Use
but
believes
that
expensive
testing
is
needed
to
support
a
submission
to
EPA,
it
may
instead
forego
production,
thus
sacrificing
profits.
The
amounts
of
lost
profits,
if
any,
were
not
quantified
26
for
this
report,
but
usually
should
be
low.
This
is
because
SNUR
chemicals
are
relatively
new
and
few
compared
to
the
many
thousands
of
chemicals
on
the
TSCA
Inventory,
and
so
are
unlikely
to
be
central
to
a
firm

s
business.

Based
on
these
considerations
and
on
the
limited
data
available,
EPA
expects
that
any
compliance
with
a
SNUR
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.

5.2
Unfunded
Mandates
Reform
Act
(
UMRA)

EPA
has
determined
that
this
SNUR
does
not
impose
any
enforceable
duty
or
contain
any
unfunded
mandate
as
described
in
the
Unfunded
Mandates
Reform
Act
of
1995
(
P.
L.
104­
4).

5.3
Paperwork
Reduction
Act
(
PRA)

According
to
the
Paperwork
Reduction
Act
(
PRA),
44
USC
3501
et
seq.,
an
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond,
to
a
collection
of
information
that
requires
Office
of
Management
and
Budget
(
OMB)
approval
under
the
PRA,
unless
it
has
been
approved
by
OMB
and
displays
a
currently
valid
OMB
control
number.
The
information
collection
requirements
related
to
this
action
have
already
been
approved
by
OMB
pursuant
to
the
PRA
under
OMB
control
number
2070­
0012
(
EPA
ICR
No.
574).
This
action
does
not
impose
any
additional
burden
requiring
OMB
approval.

5.4
Executive
Order
12866
Executive
Order
12866,
Regulatory
Planning
and
Review,
requires
OMB
review
for
rules
with
an
impact
on
the
economy
of
$
100
million
or
more,
or
with
any
other
potential
significant
impact.
OMB
has
previously
determined
that
this
type
of
SNUR
is
not
a

significant
regulatory
action

that
would
require
OMB
review
under
this
E.
O.

5.5
Executive
Order
13132
Executive
Order
13132,
Federalism
(
64
FR
43255,
August
10,
1999),
requires
EPA
to
develop
an
accountable
process
to
ensure

meaningful
and
timely
input
by
State
and
local
officials
in
the
development
of
regulatory
policies
that
have
federalism
implications.

This
action
does
not
have
federalism
implications
because
it
will
not
have
substantial
direct
effects
on
the
States,
on
the
relationship
between
the
national
government
and
the
States,
or
on
the
distribution
of
power
and
responsibilities
among
the
various
levels
of
government.
27
5.6
Executive
Order
12898
This
action
does
not
involve
special
considerations
of
environmental
justice
related
issues
as
required
by
Executive
Order
12898,
Federal
Actions
to
Address
Environmental
Justice
in
Minority
Populations
and
Low­
Income
Populations
(
59
FR
7629,
February
16,
1994).

5.7
Executive
Order
13045
Executive
Order
13045,
Protection
of
Children
from
Environmental
Health
Risks
and
Safety
Risks
(
62
FR
19885,
April
23,
1997),
requires
EPA
to
identify
and
assess
environmental
health
and
safety
risks
that
may
disproportionately
affect
children.
This
type
of
analysis
is
required
for
rules
that
will
have
an
impact
of
$
100
million
or
more
only.
This
impact
of
this
SNUR
will
be
less
than
$
100
million
and
therefore
no
analysis
of
such
impacts
on
children
is
required.
APPENDIX
A
LIST
OF
PMNS
AND
THEIR
CHEMICAL
NAMES
A­
1
APPENDIX
A
LIST
OF
PMNS
AND
THEIR
CHEMICAL
NAMES
Table
A­
1
PMNs
and
Chemical
Names
Referenced
in
this
SNUR
No.
PMN
CAS
Name
1
P­
97­
1108
N/
A
(
generic)
Polycarboxylic
acid
ester
2
P­
98­
848
181828­
07­
9
Silicic
acid
(
H6SiO2O7),
magnesium
strontium
salt(
1:
1:
2),
dysprosium
and
europium­
doped
3
P­
98­
1033
N/
A
(
generic)
Halogen
substituted
oxetanes
4
P­
98­
1034
N/
A
(
generic)
Halogen
substituted
oxetanes
5
P­
98­
1035
N/
A
(
generic)
Halogen
substituted
oxetanes
6
P­
99­
783
N/
A
(
generic)
Chromate(
2­),
[
3­
hydroxy­
4­[(
2­
hydroxy­
1­
naphthenyl)
azo]­
7­
nitro­
1­
substituted][
N­[
7­
hydroxy­
8­[(
2­
hydroxy­
5­
nitrophenyl)
azo]­
1­
substituted]­,
salt
7
P­
99­
817
N/
A
(
generic)
Salt
of
an
acrylic
acid
­
acrylamide
terpolymer
8
P­
99­
897
N/
A
(
generic)
Substituted
benzothiazole­
azo­
substituted
benzoquinoline
nickel
complex.
9
P­
99­
920
58857­
49­
1
Poly(
oxy­
1,2­
ethanediyl),
alpha­(
9Z)­
9­
octadeceny
l­.
omega.­
hydroxy­,
phosphate,
ammonium
salt
10
P­
99­
928
222975­
06­
6
2­
propanol,
1,1',
1'­
nitrilotris­,
compds.
with
ethanol
2­[
2­(
C12­
14­
alkyloxy)
ethoxy]
derivs.
hydrogen
sulfates
11
P­
99­
951
N/
A
(
generic)
Polyisobutene
epoxide
12
P­
99­
952
N/
A
(
generic)
Polyisobutene
epoxide
13
P­
99­
1075
43048­
08­
4
2­
Propenoic
acid,
2­
methyl­,
(
octahydro­
4,7­
methano­
1H­
indene­
5,­
diyl)
bis(
methylene)
ester
14
P­
99­
1202
N/
A
(
generic)
Sulfonyl
azide
intermediate
15
P­
99­
1288
N/
A
(
generic)
Substituted
anilino
halobenzamide
16
P­
99­
1295
N/
A
(
generic)
Chlorohydroxyalkyl
butyl
ether
17
P­
99­
1304
N/
A
(
generic)
Substituted
benzenesulfonic
acid
salt
18
P­
99­
1341
235083­
90­
6
2­
Naphthalenecarboxylic
acid,
4,4'­
methylenebis
[
3­
hydroxy­,
strontium
salt
19
P­
99­
1342
235083­
88­
2
2­
Naphthalenecarboxylic
acid,
4,4'­
methylenebis
[
3­
hydroxy­,
zinc
salt
20
P­
00­
7
125005­
87­
0
D­
Glucuronic
acid,
polymer
with
6­
deoxy­
L­
mannose
and
D­
glucose,
acetate,
calcium
magnesium
potassium
sodium
salt
21
P­
00­
368
N/
A
(
generic)
Benzenesulfonamide,
alkylphenylsubstitutedphenylsubstitutedcarbonyl­
22
P­
00­
636
N/
A
(
generic)
Alkylated
nitroso­
phenylenediamine
23
P­
00­
838
N/
A
(
generic)
Substituted
alkyl
sulfonamide
24
P­
00­
912
N/
A
(
generic)
Epoxy
resin
containing
phosphorus
25
P­
00­
966
N/
A
(
generic)
Haloarylalkylketoester
26
P­
00­
991
300371­
38­
4
Formaldehyde,
polymer
with
(
chloromethyl)
oxirane
and
phenol,
reaction
products
with
6H­
dibenz[
c,
e][
1,2]
oxaphosphorin­
6­
oxide
27
P­
00­
1055
N/
A
(
generic)
Sulfonated­
copper
phthalocyanine
salt
of
a
triarylmethane
dye
28
P­
00­
1205
N/
A
(
generic)
6­
Methoxy­
1H­
benz[
de]
isoquinoline­
2
[
3H]­
dione
derivative
29
P­
00­
1220
N/
A
(
generic)
Phenol
­
biphenyl
polymer
condensate
30
P­
01­
1
N/
A
(
generic)
Chloroformate
31
P­
01­
7
N/
A
(
generic)
Aliphatic
polycarboxylic
acid
metal
salt
32
P­
01­
9
N/
A
(
generic)
Halogenated
arylsilane
33
P­
01­
22
137787­
41­
8
Propanoic
acid,
2­(
trimethoxysilyl)­,
ethyl
ester
A­
2
34
P­
01­
69
N/
A
(
generic)
Substituted
naphthalene
hydrazide
35
P­
01­
71
208343­
47­
9
Phenol,
2,2'­[
6­(
2,4­
dibutoxyphenyl)­
1,3,5­
triazine­
2,4­
diyl]
bis[
5­
butoxy­
36
P­
01­
77
N/
A
(
generic)
Disubstituted
benzenedicarboxcylic
acid
37
P­
01­
85
N/
A
(
generic)
Mono
esters
from
2­
propenoic
acid
38
P­
01­
97
N/
A
(
generic)
Polyaziridinyl
ester
of
an
aliphatic
alcohol
39
P­
01­
144
35544­
45­
7
Propanamide,
N­(
2­
hydroxyethyl)­
3­
methoxy­
40
P­
01­
149
84501­
49­
5
Sulfuric
acid,
mono­
C9­
11­
alkyl
esters,
sodium
salts
41
P­
01­
152
93072­
06­
1
Benzenamine,
4­
methoxy­
2­
methyl­
N­(
3­
methylphenyl)
42
P­
01­
170
99607­
70­
2
Acetic
acid,
[(
5­
chloro­
8­
quinolinyl)
oxy­]­,
1­
methylh
exyl
ester
43
P­
01­
298
N/
A
(
generic)
Substituted
propane
44
P­
01­
320
375­
03­
1
Propane,
1,
1,1,2,2,3,3­
heptafluoro­
3­
methoxy­
45
P­
01­
397
N/
A
(
generic)
Dihydro
quinacridone
derivative
46
P­
01­
420
N/
A
(
generic)
Aromatic
acrylate
47
P­
01­
423
N/
A
(
generic)
Substituted
benzoic
acid
48
P­
01­
432
N/
A
(
generic)
Bis
heterocyclic
phenylene
derivative
49
P­
01­
433
N/
A
(
generic)
Halogenated
alkane
50
P­
01­
441
N/
A
(
generic)
Modified
phenolic
resin
51
P­
01­
459
178452­
72­
7
Chromate(
3­),
bis[
3­[[
6­
amino­
1,4­
dihydro­
2­[[[
4­[(
2­
hy
droxy­
1­
naphthalenyl)
azo]
phenyl]
sulfon
yl]
ami
no]­
4­(
oxo­.
kappa.
O)­
5­
pyrimidinyl]
azo­.
k
appaN1]­
4­
hydroxy­.
kappa.
O)­
5­
nitrobenzen
esulfonato(
3­)]­,
trisodium
52
P­
01­
460
327177­
98­
0
Chromate(
3­),
bis[
3­[[
6­
amino­
1,4­
dihydro­
2­[[[
4­[(
2­
hy
droxy­
1­
naphthalenyl)
azo]
phenyl]
sulfon
yl]
ami
no]­
4­(
oxo­.
kappa.
O)­
5­
pyrimidinyl]
azo­.
k
appaN1]­
4­
hydroxy­.
kappa.
O)­
5­
nitrobenzen
esulfonato(
3­)]­,
sodium
triethanolamine
salts
53
P­
00­
992
and
P­
01­
471
N/
A
(
generic)
Phosphorous
modified
epoxy
resin
54
P­
01­
481
N/
A
(
generic)
Polyurethane
polymer
55
P­
01­
561
N/
A
(
generic)
Modified
phenolic
resin
56
P­
01­
573
N/
A
(
generic)
Aromatic
aldehyde
phenolic
resin
57
P­
01­
578
N/
A
(
generic)
Alkoxylated
alkyl
amine
58
P­
01­
646
391232­
99­
8
1­
propanaminium,
3­
amino­,
N,
N,
N­
trimethyl­
N­
soya
acyl
derivs.,
chloride
59
P­
01­
716
N/
A
(
generic)
Polyurea
60
P­
01­
781
2602­
34­
8
Silane,
triethoxy[
3­
oxiranylmethoxy)
propyl]­
61
P­
01­
833
N/
A
(
generic)
Polyethyleneamine
crosslinked
with
substituted
polyethylene
glycol
62
P­
02­
17
N/
A
(
generic)
Phenyl
azo
dye
63
P­
02­
90
N/
A
(
generic)
Nickel,
cobalt
mixed
metal
oxide
64
P­
02­
207
24307­
26­
4
Piperdinium,
1,1­
dimethyl­,
chloride
65
P­
02­
262
N/
A
(
generic)
Substituted
benzophenone
APPENDIX
B
INFLATORS
AND
WAGE
RATES
3
Many
Labor
hourly
rates
in
this
analysis
are
lower
than
hourly
rates
for
the
same
labor
categories
in
an
earlier
SNUR
economic
analysis
(
EPAB
1999).
EPA
does
not
mean
to
suggest
that
actual
hourly
rates
declined.
Rather,
the
apparent
decline
is
due
to
a
changed
method
of
calculating
hourly
costs
for
the
same
labor
categories.
There
were
three
changes:
(
1)
Previously
the
17%
overhead
was
applied
to
wages­
plus­
fringe
benefits.
Now
it
is
applied
only
to
wages.
(
See
Appendix
B,
footnote
3.)
This
change
reduces
calculated
overhead.
(
2)
Before,
most
wage
rates
were
based
on
older
data
and
then
inflated
to
current
dollars.
Here,
most
wage
rates
are
based
on
recent
data.
(
3)
Finally,
fringe
benefits
were
based
on
an
assumed
percent
of
wages.
Here,
private
industry
fringe
benefits
are
based
on
actual
fringe
benefits
taken
from
recent
BLS
data.

4
Employer
Costs
for
Employee
Compensation,
Private
industry
workers,
Goods­
pro
ducing
industries,
white­
collar
occupations,
as
published
by
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics.
The
December
2002
values
for
these
series
are
listed
in
Table
11
of
the
Employer
Costs
for
Employee
Compensation
Summary,
released
March
18,
2003.

B­
1
APPENDIX
B
INFLATORS
AND
WAGE
RATES
This
appendix
provides
a
brief
discussion
of
the
wage
rates,
inflators,
and
methods
that
were
used
to
derive
the
final

fully
loaded

wages
and
costs
of
equipment
and
supplies
used
in
the
calculation
of
the
quantified
costs
for
each
of
the
possible
options.
Base
hourly
wages
for
relevant
labor
categories
were
loaded
with
factors
for
benefits
and
overhead
to
derive
a
loaded
hourly
rate.
If
the
loaded
hourly
rate
was
not
already
in
year
2002
dollars,
it
was
then
inflated
to
year
2002
dollars
by
multiplying
by
the
appropriate
inflation
factor.
The
derivation
of
fully
loaded
wages
in
year
2002
dollars,
for
each
of
the
labor
categories
used
in
the
report,
is
discussed
in
Section
B.
1
and
is
summarized
in
Table
B.
1.
The
derivation
of
the
different
inflation
factors
used
to
inflate
wages
and/
or
costs
of
equipment
and
supplies
to
year
2002
dollars
is
discussed
in
Section
B.
2
and
is
summarized
in
Table
B.
2.

B.
1.
Derivation
of
Loaded
Wage
Rates3
B.
1.1
Technical,
Managerial,
and
Clerical
Labor
The
basic
method
used
to
derive
loaded
wage
rates
for
technical,
managerial,
and
clerical
personnel
is
described
more
fully
in
Wage
Rates
for
Economic
Analysis
of
the
Toxics
Release
Inventory
Program
(
Rice,
2002).

December
2002
average
wages
for
technical,
managerial,
and
clerical
labor
were
taken
from
the
Employer
Costs
for
Employee
Compensation
(
ECEC)
report
from
the
Bureau
of
Labor
Statistics
(
BLS)
for
all
goods­
producing,
private
industries.
4
The
additional
cost
of
benefits,
such
as
paid
leave
and
insurance
(

fringe
benefits

)
,
specific
to
each
labor
category,
are
also
taken
from
the
same
BLS
series.
Fringe
benefit
as
a
percentage
of
wage
is
then
calculated
separately
for
each
labor
category.
For
example,
the
average
wage
rate
in
December
2002
for
technical
labor
was
$
27.00;
the
average
fringe
benefit
was
$
11.75.
So
fringe
benefit
as
a
percentage
of
wage
rate
for
technical
labor
was
11.75/
27.00,
or
approximately
43.5%.
5An
overhead
rate
of
17
percent
applied
to
wages
is
used
for
consistency
with
recent
EPAB
economic
analyses
for
two
majo
r
rulemaking
s:
Wage
Rates
for
Economic
Analyses
of
the
Toxics
Release
Inventory
Program,
June
10,
2002,
and
the
Revised
Eco
nomic
An
alysis
for
the
Amen
ded
Invento
ry
Update
R
ule:
Final
Rep
ort,
August
20
02.
In
reports
for
an
earlier
SNUR
(
EPAB
1999),
the
17%
was
applied
to
wages­
plus­
fringe
benefits.
Applying
it
only
to
wages
reduces
calculated
overhead.

B­
2
An
additional
loading
factor
of
17
percent
is
applied
to
wages
for
overhead.
5
This
overhead
loading
factor
is
added
to
the
benefits
loading
factor,
and
the
total
is
then
applied
to
the
base
wage
to
derive
the
fully
loaded
wage.
The
fully
loaded
wage
for
technical
labor,
for
example,
is
$
27.00*(
1+
0.435
+
0.17)
=
$
27.00*(
1.605)
=
$
43.34.

Fully
loaded
costs
for
managerial
and
clerical
labor
were
calculated
in
a
similar
manner.

B.
1.2
Production
Workers
For
production
workers,
the
wages
are
specific
to
the
chemical
industry,
but
the
fringe
benefits
factor
comes
from
a
different
BLS
series
and
is
for
blue
collar
workers
in
general.
The
December
2002
wage
for
production
workers,
taken
from
the
National
Employment,
Hours,
and
Earnings,
Average
Hourly
Earnings
of
Production
Workers
(
BLS,
2003c),
is
$
19.44.
Fringe
benefits
as
a
percentage
of
wage
in
December
2002
was
calculated
from
the
Employer
Costs
for
Employee
Compensation
­
December
2002:
Private
industry,
goods­
producing
workers
by
occupational
group
(
BLS
2003d),
by
dividing
total
benefits
for
blue­
collar
occupations
in
December
2002
($
7.37)
by
the
corresponding
December
2002
average
wage
among
blue­
collar
occupations
($
15.39).
The
result
is
47.9
percent.

As
with
other
labor
categories,
an
additional
loading
factor
of
17
percent
of
wages
was
applied
for
overhead.
The
loaded
wage
for
production
workers
was
thus
calculated
as
$
19.44*(
1
+
0.479
+
0.17)
=
$
19.44*(
1.649)
=
$
32.06.

B.
1.3
Industrial
Hygienists
Unlike
other
labor
categories,
the
wage
rate
for
Industrial
Hygienists
came
from
1997
non­
BLS
data
and
was
inflated
to
2002
dollars.
The
fringe
benefits
factor,
on
the
other
hand,
came
from
recent
BLS
data
and
is
generic
to
professional
occupations.

We
used
a
wage
rate
of
$
25.05
in
1997
dollars,
based
on
a
1997
survey
specific
to
industrial
hygienists
(
IHSN
1997).
Fringe
benefits
as
a
percentage
of
wages
in
December
2002
was
taken
from
Employee
Compensation
­
December
2002:
Private
industry,
goods­
producing
workers
by
occupational
group(
BLS
2003d),
by
dividing
total
benefits
for
professional
specialty
and
technical
occupations
in
December
2002
($
11.75)
by
the
corresponding
December
2002
average
wage
among
professional
specialty
and
technical
occupations
($
27.00).
The
result
is
43.5
percent.
6Calculations
are
base
d
on
unro
unded
va
lues,
so
the
total
may
n
ot
equal
the
prod
uct
of
the
round
ed
factors.

B­
3
An
additional
loading
factor
of
17
percent
of
wages
was
applied
for
overhead.
The
loaded
wage
for
industrial
hygienists
in
1997
dollars
was
thus
calculated
as
$
25.05*(
1
+
0.435
+
0.17)
=
$
25.05*(
1.605)
=
$
40.21.
Using
the
fourth
quarter
Employment
Cost
Index,
Total
Compensation
for
White
Collar
Occupations
(
BLS
2003a),
this
was
then
inflated
to
year
2002
dollars
using
an
inflation
factor
of
approximately
1.209,
to
yield
$
48.60
in
fourth
quarter
2002
dollars.
6
B.
1.4
EPA
Staff
FTE
The
annual
salary
for
EPA
staff
used
for
calculations
of
Agency
costs
is
an
average
of
the
Office
of
Personnel
Management
(
OPM)
year
2002
annual
salaries
for
GS­
12
Steps
1
and
10

$
55,694
and
$
72,400,
respectively,
or
$
64,047.
Multiplying
by
an
assumed
loading
factor
of
1.6
to
reflect
fringe
benefits
and
overhead
(
OPPE
1992),
the
loaded
annual
salary
of
EPA
staff
was
calculated
to
be
$
102,475.
B­
4
Table
B­
1
Derivation
of
Loaded
Wage
Rates
Labor
Category
Data
Sources
Uninflated
wages
and
fringes
/
hour
Fringe
benefits
as
%
of
wage
Overhead
as
%
of
wage*
Fringe
+
Overhead
factor
Loaded
Wage
Rate
before
inflation
Inflation
factor
Loaded
Wage
Rate
(
2002
dollars)
Date
Wage
s
$
Fringe
benefits
$

Technical
BLS
Employer
Costs
for
Employee
Compensation,
Table
1
1.
Private
ind
ustry,
goods­
prod
ucing
industries,
Profess.
specialty
&
technical.
Dec
02.
[
BLS
2003d]
Dec
2002
$
27.00
$
11.75
43.5%
17%
1.605
$
43.34
1
$
43.34
Manag
erial
BLS
Employer
Costs
for
Employee
Comp
ensation
,
Table
11.
Private
ind
ustry,
goods­
p
roducing
industries,
Exe
c,
admin,
&
managerial.
Dec
02.
[
BLS
2003d]
Dec
2002
$
33.09
$
14.57
44.0%
17%
1.610
$
53.29
1
$
53.29
Clerical
BLS
Employer
Costs
for
Employee
Compensation,
Table
1
1.
Private
ind
ustry,
goods­
p
roducing
industries,
Ad
min
suppo
rt,
incl.
clerical.
Dec
02.
[
BLS
2003d]
Dec
2002
$
14.89
$
6.54
43.9%
17%
1.609
$
23.96
1
$
23.96
Production
worker
Wage:
BLS
Natl
Em
pl,
Hrs,
and
Ea
rnings:
Aver
Hourly
Earnings
of
Production
Workers,
Chem
&
Allied
Pro
d,

Annual

(
EEU32280006)
[
BLS
200
3c]

Fringes
%:
BLS
Employer
Costs
for
Employee
Compensation,
Table
11.
Private/
goods­
producing
industries,
bluecollar
occupations.
Dec
02.
[
BLS
2003d]
Dec
2002
$
19.44
­
47.89%
17%
1.6489
$
32.05
1
$
32.05
Labor
Category
Data
Sources
Uninflated
wages
and
fringes
/
hour
Fringe
benefits
as
%
of
wage
Overhead
as
%
of
wage*
Fringe
+
Overhead
factor
Loaded
Wage
Rate
before
inflation
Inflation
factor
Loaded
Wage
Rate
(
2002
dollars)
Date
Wage
s
$
Fringe
benefits
$

B­
5
Industrial
hygienist
Wages:
1997
trade
survey
(
IHSN
1997)

Fringes
%:
BLS
Employer
Costs
for
Employee
Compensation,
Table
11.
Private/
goods­
producing,
Professional
specialty
&
techn,
Dec
02.
[
BLS
2003d]

Inflation:
BLS
ECI,
White
Collar
Occupations,
Series
ECS11102I,
Fourth
Q
(
see
Table
B­
2)
[
BLS
2003a]
1997
$
25.05
­
43.5%
17%
1.605
$
40.21
1.209
4$
48.60
EPA
sta
ff
FTE
Office
of
Personnel
Management
(
OPM)
pay
rates
for
GS­
12
Steps
1
and
10
for
2002.
[
OPM
2003]
(
Average
of
$
55,694
and
$
72,400)
2002
$
64,047
per
year
­
­
­
1.6
$
102,475
per
year
1
$
102,475
per
year
*
An
overh
ead
rate
o
f
17
perce
nt
applied
to
wages
is
used
for
consistenc
y
with
recent
EPAB
econom
ic
analyses
for
two
major
rule
makings:
Wage
Rates
for
Economic
Analyses
of
the
Toxics
Release
Inventory
Program,
June
10,
2002,
and
the
Revised
Economic
Analysis
for
the
Amended
Inventory
Update
Rule:
Final
Report,
August
2002.

Note:
Calculations
are
based
on
unrounded
values,
so
the
total
may
not
equal
the
product
of
the
rounded
factors.
B­
6
B.
2.
Derivation
of
Inflation
Factors
In
general,
costs
of
equipment
and
supplies
were
inflated
to
year
2002
dollars
using
the
Consumer
Price
Index

All
Urban
Consumers
(
not
seasonally
adjusted);
wages
were
inflated
using
the
appropriate
Employment
Cost
Index
(
ECI),
seasonally
adjusted.
For
example,
the
wage
for
industrial
hygienists
was
inflated
from
1997
dollars
to
2002
dollars
using
the
ECI
for
White
Collar
Occupations.
In
those
cases
in
which
both
labor
and
equipment
and
supplies
were
involved
(
e.
g.,
test
costs),
we
used
the
inflator
corresponding
to
the
dominant
cost
category.
For
example,
test
costs
are
presumably
based
on
a
mix
of
labor
categories
and
include
the
costs
of
equipment
and
supplies.
Assuming
that
the
largest
component
of
test
costs
comes
from
labor,
we
used
the
ECI
for
private
industry,
all
workers.
Complete
information
on
the
derivation
of
the
inflation
factors
used
is
given
in
Table
B­
2
below.

Table
B­
2
Derivation
of
Inflation
Factors
Report
section
Item
Inflator
data
source
Starting
year
Inflator
for
starting
year
(
A)
Inflator
for
2002
(
B)
Inflation
factor
(
B)
/
(
A)

Chapter
3
Export
notification
BLS
Em
ploy.
Cost
Index,
Seas.
Adj.,
White
Collar
Occupations
Series
ECS11102I,
Fourth
Q
1992
116.1
165.6
1.426
Appendix
C
Industrial
hygienist
Impermeab
ility
test
BLS
E
mploy.
Co
st
Index,
Sea
s.
Adj.,
White
Collar
Occupations
Series
ECS11102I,
Fourth
Q
1997
137.0
165.6
1.209
Appendix
C
Labels,
placards,
gloves,
clothes,
eyewear,
respirators,
file
cabinet
BLS
C
onsumer
P
rice
Index,
a
ll
urban
co
nsumers,
no
t
seasonally
adjusted,
CUUR0000SAO,
Annual
1997
160.5
179.9
1.121
Appendix
C
Photocopies
Record
keeping
materials
BLS
C
onsumer
P
rice
Index,
a
ll
urban
co
nsumers,
no
t
seasonally
adjusted,
CUUR0000SAO,
Annual
1988
118.3
179.9
1.521
Appendix
D
Test
cost
BLS
E
mpl.
Cost
In
dex,
Seaso
nally
Adj,
Private
industry,
All
workers
(
Series
ID:
ECS10002I)
December
[
Published
Jan
2003]
varies
varies
162.5
varies*

Ex.
for
test
costed
out
in
1993
1993
119.9
162.5
1.355
Ex.
for
test
costed
out
in
2000
2000
151.1
162.5
1.075
Appendix
F
Agency
Extramural
costs
BLS
Em
ploy.
Cost
Index,
Seas.
Adj.,
White
Collar
Occupations
Series
ECS11102I,
Fourth
Q
1993
120.4
165.6
1.375
*
Test
costs
were
first
estimated
in
different
years,
depending
on
the
test,
so
that
inflation
factors
vary
depending
on
when
the
test
wa
s
costed
ou
t.
APPENDIX
C
COSTS
OF
COMPLIANCE
WITH
A
SNUR
(
OPTION
1):
HAZARD
COMMUNICATION,
PROTECTION
IN
THE
WORKPLACE,
AND
RECORDKEEPING
REQUIREMENTS
C­
1
APPENDIX
C
COSTS
OF
COMPLIANCE
WITH
A
SNUR
(
OPTION
1):
HAZARD
COMMUNICATION,
PROTECTION
IN
THE
WORKPLACE,
AND
RECORDKEEPING
REQUIREMENTS
Section
2.1
of
this
economic
analysis
presents
a
discussion
of
the
methodology
for
assessing
the
costs
of
the
worker
protection,
hazard
communication,
and
recordkeeping
requirements
of
the
batch
SNUR.
This
appendix
presents
the
dollar
costs
and
labor
hours
of
these
requirements,
for
each
PMN
chemical.
The
hazard
communication
(
Haz­
Comm)
costs
reflect
the
annual
costs
of
updating
the
written
program,
creating
and
applying
labels
for
chemical
distribution
and
storage,
creating
and
distributing
material
safety
data
sheets,
and
employee
training.
The
personal
protective
equipment
(
PPE)
costs
shown
reflect
the
annualized
costs
of
providing
required
equipment
(
i.
e.,
gloves,
goggles,
clothing,
or
respirators),
assessing
dermal
protection
needs
associated
with
the
chemical,
and
performing
required
impermeability
testing,
and/
or
evaluating
manufacturer

s
information.
Finally,
the
annual
recordkeeping
costs
include
technical
and
clerical
labor
time,
reproduction
charges,
and
costs
for
the
storage
of
records.

To
estimate
the
costs
of
haz­
comm
and
worker
protection
requirements,
a
number
of
assumptions
were
made.
In
the
original
analysis
for
generic
SNUR
provisions
(
RIB
1989),
EPA
estimated
that
the
number
of
workers
exposed
to
any
one
substance
would
range
from
10
to
25,
and
that
a
worker
potentially
would
be
exposed
to
a
substance
for
a
minimum
of
50
days
per
year
to
a
maximum
of
250
days
per
year.
The
current
analysis
uses
the
high
ends
of
those
two
ranges.
Thus,
each
site
is
assumed
to
have
25
chemically­
exposed
workers
requiring
training
and/
or
protective
equipment,
with
each
of
them
assumed
to
be
exposed
for
250
days
per
year.

Labor
costs
are
derived
from
the
Employer
Costs
for
Employee
Compensation
(
BLS
2003d)
as
described
in
Appendix
B.
Material
costs
were
primarily
obtained
from
a
national
safety
equipment
supply
house
catalog
(
LSS
1997)
and
are
inflated
to
2002
dollars
using
the
BLS
Consumer
Price
Index
(
BLS
2003b).
Please
refer
to
Appendix
B
for
further
details
on
the
sources
and
methodology
of
calculating
labor
and
material
costs.

Haz­
Comm
costs,
costs
of
providing
protection
in
the
workplace,
and
recordkeeping
costs
are
discussed
in
Sections
C.
1,
C.
2,
and
C.
3,
respectively.
These
costs,
as
well
as
total
costs
calculated
by
summing
the
Haz­
Comm,
protection
in
the
workplace,
and
recordkeeping
costs,
are
summarized
for
each
PMN
in
Table
10
above.

C.
1
Modifying
the
Hazard
Communication
Program
As
mentioned
in
Section
2.1,
it
is
assumed
that
each
facility
has
in
place
a
Haz­
Comm
program
consistent
with
that
required
by
OSHA

s
Hazard
Communication
standard
(
29
CFR
1910;
November
25,
1983),
so
that
costs
attributable
to
the
SNUR
are
costs
of
adding
one
chemical
to
the
program.
Much
of
the
Haz­
Com
methodology
and
assumptions
came
from
an
EPA
report,
Economic
Analysis
of
Final
Significant
New
Use
Rules:
General
Provisions
for
New
Chemical
C­
2
Followup
(
RIB,
1989),
which
in
turn
relied
partly
on
the
1993
OSHA
study,
Final
Regulatory
Impact
and
Regulatory
Flexibility
Analyses
of
the
Hazard
Communication
Standard.

It
was
assumed
that
the
Haz­
Comm
costs
would
be
incurred
each
year

for
example,
there
would
be
worker
turnover
and
need
for
refresher
training,
the
MSDS
would
need
revision
due
to
changing
information,
placards
would
wear
out
(
RIB
1989).
To
the
extent
that
some
steps
would
not
need
repeating
each
year,
costs
could
be
lower
than
estimated
here.
The
hazard
communication
costs
of
$
931,
summarized
in
Table
3
above,
are
detailed
here.

C.
1.1
Updating
the
Written
Program
If
the
SNUR
cites
40
CFR
§
721.72(
a),
then
to
avoid
engaging
in
a
Significant
New
Use
which
would
trigger
other
SNUR
requirements,
manufacturers
must
update
their
written
Haz­
Comm
program
to
incorporate
information
about
the
chemical.
The
written
part
of
the
program
includes
data
and
information
about
hazardous
chemicals
present
in
the
workplace,
the
hazards
associated
with
such
chemicals,
procedures
for
employees
who
routinely
work
with
or
around
such
chemicals,
procedures
for
non­
routine
tasks
that
may
involve
exposure
(
e.
g.,
tank
cleaning),
and
personal
protective
equipment
requirements
when
working
with
or
around
such
chemicals.

Costs
of
the
haz
comm
program
update
are
$
194.42
per
chemical,
as
described
below.

While
MSDS
data
may
provide
much
of
the
information
needed
to
update
the
written
Haz­
Comm
program,
many
employers
may
perform
a
more
detailed
assessment
of
exposure
risks
associated
with
the
chemical
and
develop
more
site­
specific
procedures
for
workers
potentially
exposed
to
such
chemicals.
For
purposes
of
the
economic
analysis,
EPA
assumes
that
each
employer
will
engage
the
services
of
a
professional
industrial
hygienist
(
IH),
either
in­
house
or
on
a
consulting
basis,
for
four
hours
to
perform
such
an
assessment.
Costs
for
IH
services
were
obtained
from
a
1997
salary
survey
conducted
by
Industrial
Hygiene
and
Safety
News,
a
professional
trade
journal
(
IHSN
1997).
The
survey
results
are
based
on
602
respondents
from
the
environmental,
health
and
safety
professions,
with
a
range
of
age,
experience,
and
professional
training.
The
median
gross
salary
for
all
respondents
in
1997
was
$
52,100,
which
represents
$
25.05
on
an
hourly
basis.
This
wage
was
inflated
to
year
2002
wages
and
loaded
with
fringe
benefits
and
overhead
as
described
in
in
Appendix
B,
for
a
fully
loaded
hourly
cost
of
$
48.60.
Costs
for
four
hours
of
IH
time,
fully
loaded,
are
$
194.42.
The
estimates
in
Table
10
assume
that
this
cost
is
repeated
annually.

C.
1.2
Labeling
If
the
SNUR
cites
40
CFR
§
721.72(
b),
then
to
avoid
engaging
in
a
Significant
New
Use,
manufacturers
must
ensure
that
containers
used
to
distribute
the
PMN
substance
in
commerce
are
labeled
with
the
necessary
hazardous
substance
warnings
and
procedures.
In
addition,
containers
used
in
the
workplace
must
bear
similar
labels
or,
alternatively,
the
employer
must
provide
equivalent
signage,
operating
procedures,
or
other
written
material
to
communicate
hazard
7
Data
on
PMN
notices
suggest
that
some
PMN
submitters
expected
to
produce
less
than
10,000
kilograms
per
year
of
the
SNUR
chemicals,
but
many
expected
to
produce
much
more,
often
over
100,000
kg.
It
is
not
known
whether
expected
volumes
were
realized
in
practice.
Production
volumes
of
secondary
suppliers
affected
by
the
SNUR
is
also
unknown.
Annual
volumes
significantly
greater
than
10,000
kg
could
lead
to
higher
haz­
comm
costs
than
those
estimated
here.

C­
3
information
to
workers.
The
cost
of
providing
such
labeling
has
been
estimated
previously
(
RIB
1989)
and
has
been
updated
here
using
more
recent
cost
information.

Standard
formats
are
assumed
to
be
used
for
creating
labels
or
other
signage,
and
the
information
required
for
the
labels
is
assumed
to
be
already
available
from
the
MSDS
for
the
chemical
(
see
below).

C.
1.2.1
Chemicals
Distributed
in
Commerce
For
chemicals
distributed
in
commerce,
the
labeling
process
is
assumed
to
require
0.5
hours
of
technical
labor
time
per
chemical
to
compile
label
information
and
480
labels
per
chemical.
The
assumption
of
480
labels
per
chemical
is
from
RIB
(
1989),
and
is
based
on
the
assumption
that,
on
average,
each
chemical
is
shipped
twice
monthly
to
20
customers.
This
is
consistent
with
roughly
10,000
kilograms
of
chemical
per
year
shipped
in
40
five­
gallon
containers
per
month
(
RIB
1989).
7
Labor
costs
for
technical
labor
are
based
on
the
Employer
Costs
for
Employee
Compensation
(
BLS
2003d).
The
2002
loaded
hourly
wage
derived
for
technical
labor
is
$
43.34.
Methods
of
calculating
labor
costs
for

technical

and
other
labor
categories
are
explained
in
Appendix
B.

Labeling
materials
costs
were
obtained
from
a
national
safety
equipment
supply
house
catalog
(
LSS
1997)
and
were
inflated
to
2002
dollars
using
the
BLS
Consumer
Price
Index
(
BLS
2003b).
As
shown
in
Table
C­
1,
the
resulting
costs
of
labeling
for
chemicals
distributed
in
commerce
are
$
107.75
per
chemical
substance
at
one
site,
in
2002
dollars.

Table
C­
1
Annu
al
Costs
of
Labeling
for
Distribution
in
Com
merce
[
40
CF
R
§
721.72(
b)(
2)]

Cost
Element
Unit
Co
st
(
1997
D
ollars)
Inflator
Unit
Co
st
(
2002
D
ollars)
Hours
Total
Cost*

0.5
hours
technical
time
$
43.34
per
hour
0.5
$
21.67
480
lab
els
$
0.16
per
label
1.121
$
0.18
per
label
$
86.08
Total
0.5
$
107.75
Source
:
1997
lab
el
cost,
EPA
B
1998
,
LSS
19
97;
cost
ele
ments,
q
uantities,
RIB
1989;
in
flators,
labor
,
Appen
dix
B.
*
Totals
were
calculated
using
unrounded
values
from
Appendix
B,
and
may
not
equal
product
of
the
rounded
values
shown
in
this
table.
C­
4
C.
1.2.2
Chemicals
Used
in
the
Workplace
Workplace
labeling
requirements
are
costed
by
assuming
the
facility
purchases
six
large
(
14"
×
10")
signs,
priced
at
$
38.30
each
in
1997
dollars
(
LSS
1997,
EPAB
1998).
These
signs
are
estimated
to
cost
$
42.93
in
year
2002
dollars
(
updated
by
using
the
CPI)
(
BLS
2003b).
These
signs
will
be
mounted
in
areas
where
the
chemicals
are
used
or
formulated.
For
example,
a
placard
might
be
posted
at
each
of
six
vessels:
a
mixing
tank,
a
reactor,
two
separators,
and
two
storage
vessels
(
RIB
1989).
The
labeling
process
is
also
assumed
to
require
0.5
hours
of
technical
time
to
compile
label
informaiton
and
10
minutes
of
production
worker
time
to
post
each
placard.
Technical
labor
is
costed
at
$
43.34
per
hour,
as
described
in
Appendix
B.

The
resulting
costs
of
labeling
for
chemicals
in
the
workplace
are
shown
in
Table
C­
2
to
be
$
311.30
per
chemical
substance.

Table
C­
2
Annu
al
Costs
of
Labeling
for
Use
in
W
orkplace
[
40
CFR
§
721.72(
b)(
1)]

Cost
Element
Unit
Co
st
(
1997
D
ollars)
Inflator
Unit
Co
st
(
2002
D
ollars)
Hours
Total
Co
st*

0.5
hours
technical
time
$
43.34
per
hour
0.5
$
21.67
6
labels
or
placards
(
14"
x
10")
$
38.30
per
item
1.121
$
42.93
per
item
$
257.58
10
minutes
per
label/
placard
production
time
$
32.05
per
hour
1.0
$
32.05
Total
1.5
$
311.30
Source
:
1997
p
lacard
co
st,
EPAB
1998,
L
SS
199
7;
cost
elem
ents
and
q
uantities,
RIB
1989;
in
flators
and
labor
un
it
costs,
Ap
pendix
B.
*
Totals
were
calculated
using
unrounded
values
from
Appendix
B,
and
may
not
equal
product
of
the
rounded
values
shown
in
this
table.

C.
1.3
Preparing
Material
Safety
Data
Sheet
(
MSDS)
Information
If
the
SNUR
cites
40
CFR
§
721.72(
c),
then
to
avoid
engaging
in
a
Significant
New
Use,
each
facility
is
required
to
create,
post,
and
distribute
material
safety
data
sheets
(
MSDSs).
Based
on
estimates
in
OSHA
1983,
RIB
(
1989)
has
estimated
that
creation
of
MSDS
for
a
new
PMN
substance
requires
2.0
hours
of
technical
labor
time
and
0.25
hours
of
clerical
time.
Further,
EPA
assumes
that
the
manufacturer
provides
20
copies
of
the
MSDS
to
customers
and
to
retain
20
copies
for
use
onsite,
for
a
total
of
40
copies
(
RIB
1989).
The
loaded
hourly
wage
rates
and
the
inflator
used
in
estimating
unit
photocopy
costs
are
derived
in
Appendix
B.
The
resulting
cost
of
MSDS
preparation
is
$
95.71
per
chemical,
as
shown
in
Table
C­
3.
C­
5
Table
C­
3
Annu
al
Costs
for
Material
Safety
Da
ta
Sheets
(
MSDSs)
[
40
C
FR
§
721.72
(
c)]

Cost
Element
Unit
Co
st
(
1988
D
ollars)
Inflator
Unit
Cost
(
2002
D
ollars)
Hours
Total
Co
st*

2.0
hours
technical
time
$
43.34
per
hour
2.0
$
86.68
0.25
hours
clerical
time
$
23.96
per
hour
0.25
$
5.99
40
copies
$
0.5
1.521
$
0.08
per
copy
$
3.04
Total
2.25
$
95.71
Source
:
Cost
elem
ents,
quan
tities,
and
19
88
cop
y
cost,
RIB
1989;
in
flators
and
labor
un
it
costs,
App
endix
B
.
*
Totals
were
calculated
using
unrounded
values
from
Appendix
B,
and
may
not
equal
product
of
the
rounded
values
shown
in
this
table.

C.
1.4
Employee
Training
The
final
required
component
of
the
Haz­
Comm
program
is
employee
training,
based
on
§
721.72(
d).
RIB
(
1989)
assumes
that
a
training
program
currently
is
in
place,
but
the
existing
program
must
be
modified
to
add
new
information
pertaining
to
the
PMN
substance.
Subsequently,
the
training
program
must
be
expanded
to
include
such
material
each
time
the
training
course
is
presented.
Costs
of
modifying
the
program
and
presenting
the
modified
program
are
mainly
labor
costs
for
the
trainer
and
the
trainees.

Inserting
the
new
information
about
the
PMN
substance
into
the
training
program
and
conducting
the
revised
training
is
assumed
to
require
0.5
hours
of
the
trainer

s
time.
An
additional
0.25
hours
per
trainee
is
estimated
to
be
required,
and
an
average
of
25
affected
workers
is
assumed
per
facility
(
RIB
1989).
If
additional
production
workers
needed
to
be
trained,
for
example
because
they
might
come
into
contact
with
the
chemical
due
to
spills
or
leaks,
training
costs
could
be
higher
than
estimated
here
(
RIB
1989).

Labor
rates
for
trainers
are
based
on
the
rates
derived
in
Appendix
B
for
chemical
technicians
($
43.34
per
hour)
and
chemical
industry
production
workers
($
32.05
per
hour).
Based
on
these
labor
costs,
the
total
cost
of
the
employee
training
requirement
is
$
222.01,
as
shown
in
Table
C­
4.
C­
6
Table
C­
4
Annu
al
Costs
for
Employee
T
raining,
Per
Chemical
[
40
C
FR
§
721.72
(
d)]

Cost
Element
Unit
Cost
Hours
Total
Co
st*

0.5
hours
technical
time
(
trainer)
$
43.34
per
hour
0.50
$
21.67
0.25
hours
per
production
employee
×
average
of
25
workers
per
plant
=
6.25
ho
urs
$
32.05
per
hour
6.25
$
200.34
Total
6.75
$
222.01
Source
:
Cost
elem
ents
and
q
uantities,
RIB
1989;
L
abor
un
it
costs,
App
endix
B
.
*
Totals
calculated
using
unrounded
values
from
Appendix
B,
may
not
equal
product
of
rounded
values
in
table.

C.
2
Protection
in
the
Workplace
The
following
section
estimates
costs
of
assessing
needs
for
dermal
protection
and
evaluating
protective
gear
for
impermeability,
as
well
as
the
costs
of
gloves,
goggles,
protective
clothing,
and
respirators.

C.
2.1
Dermal
Protection
Selection
If
the
SNUR
cites
40
CFR
§
721.63(
a)(
1),
then
to
avoid
engaging
in
a
Significant
New
Use,
the
employer
must
ensure
that
each
person
who
is
likely
to
experience
dermal
exposure
to
a
PMN
chemical,
must
be
provided
with
and
is
required
to
wear
personal
protective
equipment
(
e.
g.,
gloves)
that
will
prevent
dermal
exposure
to
the
substance.
The
equipment
must
be
selected
and
used
in
accordance
with
29
CFR
1910.132
and
1910.133
(
promulgated
by
the
Occupational
Safety
and
Health
Administration,
OSHA).
The
selection
and
administration
of
this
dermal
protection
is
estimated
to
require
10
hours
labor
by
an
industrial
hygienist,
annually
(
EPAB
1999).
The
wage
rate
of
the
hygienist
was
calculated
as
described
above
in
Section
C.
1.1
and
in
Appendix
B.
The
cost
calculations
for
the
dermal
protection
selection
requirement
are
given
in
Table
C­
5.
This
covers
only
costs
of
selecting
the
dermal
protection
needed,
not
costs
of
the
items
themselves.
For
costs
of
purchasing
dermal
protective
items,
see
the
sections
below
on
costs
of
gloves,
eyewear,
and
clothing.
C­
7
Table
C­
5
Annu
al
Costs
for
Dermal
Pro
tection
Selection
[
40
CFR
§
7
21.63(
a)(
1)]

Cost
Element
Unit
Cost
Hours
Total
Co
st*

10
hours
industrial
hygienist
(
IH)
time
$
48.60
per
hour
10.0
$
486.04
Source:
Labor
rates,
IHSN
1997
and
Appendix
B;
Cost
elements
and
quantitites,
EPAB
1999.
*
Totals
were
calculated
using
unrounded
values
from
Appendix
B,
and
may
not
equal
product
of
the
rounded
values
shown
in
this
table.

C.
2.2
Impermeability
Testing
As
part
of
the
workplace
protection
requirements
specified
under
40
CFR
§
721.63(
a)(
3),
to
avoid
engaging
in
a
Significant
New
Use,
the
SNUR
may
require
that
employers
demonstrate
that
each
item
of
protective
equipment
provided
(
e.
g.,
gloves)
provides
an
impervious
barrier,
to
prevent
employees
from
dermal
exposure
Requirements
outlined
in
§
721.63(
a)(
3)
are
provided
in
two
parts,
§
721.63(
a)(
3)(
i)
and
(
ii).
The
employer
may
use
a
combination
of
(
i)
testing
and/
or
(
ii)
evaluating
manufacturer
specifications.
The
following
discussion
is
based
on
the
Economic
Analysis
of
Expedited
Significant
New
Use
Rules
for
168
Chemical
Substances
and
Background
Support
Document
for
Economic
Analysis
of
Significant
New
Use
Rules
(
EPAB
1998)
and
assumes
that
the
manufacturer
uses
both
testing
and
evaluation
of
manufacturer
specifications.
Costs
were
assumed
to
be
repeated
annually.

The
first
step
(
i)
is
to
perform
actual
impermeability
testing.
To
determine
the
costs
of
impermeability
testing
compliance,
Best
Manufacturing
Company,
a
leading
manufacturer
and
tester
of
chemical
resistant
articles,
was
consulted
(
Best
1997).

As
described
in
EPAB
1998,
Best
used
one
of
two
methodologies
for
impermeability
testing.
In
the
first
method,
chemical
samples
were
submitted
to
Best
with
a
specific
article
to
be
tested
for
impermeability.
This
method
was
cheaper,
costing
$
200
per
chemical,
but
the
burden
of
finding
an
appropriate
article
of
protection
lay
with
the
chemical
manufacturer.
In
the
second
method,
the
chemical
manufacturer
simply
submitted
chemical
samples
to
Best,
who
in
turn
determined
the
most
appropriate
product,
even
if
the
product
were
manufactured
by
a
competitor.
This
method
was
more
costly
at
$
800
per
chemical.

The
second
method
of
impermeability
testing
is
favored
in
this
analysis
for
several
reasons.
First,
the
burden
of
finding
and
submitting
an
article
of
protection
is
shifted
from
the
chemical
manufacturer
to
the
testing
company,
who
would
have
greater
experience
in
PPE
selection.
Second,
should
the
article
submitted
fail
the
impermeability
test,
other
articles
may
have
to
be
submitted
until
satisfactory
test
results
are
obtained.
Furthermore,
substances
subject
to
SNURs
may
include
new
and/
or
rare
chemicals,
which
may
have
undiscovered
or
unknown
properties.
C­
8
This
uncertainty
may
impede
chemical
manufacturers

ability
to
effectively
submit
appropriate
PPE
articles
for
testing.
Finally,
the
first
method
is
essentially
a
pass­
fail
test.
If
an
article
passes
the
impermeability
test,
then
it
is
acceptable.
In
the
second
method,
several
articles
may
be
tested
and
compared,
and,
while
one
or
more
acceptable
articles
may
result,
the
most
impermeable
article
is
always
determined
for
the
chemical.
To
obtain
the
best
article
rather
than
merely
a
satisfactory
article
of
protection,
the
second
method
of
testing
is
more
appropriate.
For
these
reasons,
unit
costs
of
$
800
per
chemical
(
1997
dollars)
are
assumed
for
impermeability
testing.
The
cost
of
the
impermeability
testing
is
assumed
to
be
driven
by
labor
costs
of
the
company
performing
the
testing,
thus
test
costs
were
inflated
with
the
Employment
Cost
Index
(
BLS
2003a).
When
inflated
to
2002
dollars,
the
cost
of
the
test
is
$
967.01.
The
administration
of
this
test
would
also
require
two
hours
of
industrial
hygienist
labor.
As
discussed
in
Section
C.
1.1
and
in
Appendix
B,
this
labor
is
estimated
to
cost
$
48.60
per
hour.

The
second
step
to
compliance
with
the
workplace
protection
requirements
at
§
721.63(
a)(
3)(
ii)
is
the
evaluation
of
specifications
from
the
manufacturer
or
supplier
of
the
protective
equipment.
This
requirement
helps
ensure
that
the
protective
equipment
will
be
impervious
to
the
PMN
chemical(
s).
The
evaluation
of
manufacturer
specifications
requires
an
estimated
four
hours
of
industrial
hygienist
labor.

Annual
costs
of
the
impermeability
testing
requirements
are
presented
in
Table
C­
6.

Table
C­
6
Annu
al
Costs
of
Impermea
bility
Testing
[
40
CFR
§
721
.63(
a)(
3)]

Cost
Element
Unit
Cost
(
1997
D
ollars)
Inflator
Unit
Cost
(
2002
D
ollars)
Hours
Total
Cost*

Impermeability
Testing
[
§
721.63(
a)(
3)(
i)]
2.0
$
1,064.21
Imperme
ability
Test
$
800
1.209
$
967.01
per
chemical
967.01
2.0
hour
s
industrial
hygienist
time
$
48.60
per
hour
2.0
$
97.20
Evaluation
of
Manufacturer

s
Specifications
[
§
721.63(
a)(
3)(
ii)]
4.0
$
194.40
4.0
hour
s
industrial
hygienist
time
$
48.60
per
hour
4.0
$
194.40
Total
6.0
$
1,258.61
Source:
1997
costs,
Best
1997;
Cost
elements
and
quantities,
EPAB
1998;
inflators
and
labor
rates,
Appendix
B.
*
Totals
were
calculated
using
unrounded
values
from
Appendix
B,
and
may
not
equal
product
of
the
rounded
values
shown
in
this
table.
C­
9
C.
2.3
Gloves
If
the
SNUR
cites
40
CFR
§
721.63(
a)(
2)(
i),
then
gloves
must
be
worn
to
avoid
engaging
in
a
Significant
New
Use.
Gloves
may
also
be
acquired
as
a
result
of
the
dermal
protection
selection
at
721.63(
a)(
1).
Gloves,
where
required,
are
assumed
to
be
worn
and
discarded
by
the
worker
following
each
day
of
exposure,
unless
otherwise
specified.
Each
site
is
assumed
to
have
25
workers,
each
of
them
exposed
250
days
per
year.
EPA
assumes
that
standard,
disposable,
medical­
grade
gloves
are
selected
and
used
for
the
PPE
glove
requirements
outlined
in
§
721.63(
a)(
2)(
i).
Each
pair
was
estimated
to
cost
$
0.43
in
1997
(
LSS
1997)
and
has
been
inflated
to
2002
dollars
using
the
Bureau
of
Labor
Statistics
Consumer
Price
Index
(
BLS
2003b).
Total
annual
costs
of
providing
gloves
are
developed
by
applying
the
assumptions
above
regarding
the
number
of
workers
exposed
(
25
per
site)
and
frequency
of
replacement
(
one
pair
per
worker
per
day
of
exposure
×
250
days
of
exposure
per
year).
For
some
chemicals,
the
SNUR
may
require
heavier­
duty
gloves,
which,
are
generally
not
disposed
of
daily,
but
are
more
expensive.
The
estimated
costs
of
gloves
purchased
in
compliance
with
SNUR
PPE
requirements
are
presented
below
in
Table
C­
7.

Table
C­
7
Annu
al
Cost
of
Gloves
[
40
CF
R
§
721.63(
a)(
2)(
i)]

Cost
Element
Unit
Co
st
(
1997
do
llars)
Inflator
Unit
Cost
(
2002
D
ollars)
Number
of
Pairs
Required
Total
Co
st*

Disposable
nitrile
gloves
(
replaced
daily)
$
0.43
1.121
$
0.48
per
pair
6250
$
3,012
Heavy
duty
butyl
gloves
(
replaced
every
25
work
days)
$
34.00
1.121
$
38.11
per
pair
250
$
9,527
Source:
1997
item
costs,
LSS
1997;
item
type
and
quantity,
EPAB
1998;
Inflator,
Appendix
B.
*
Totals
were
calculated
using
unrounded
values
from
Appendix
B,
and*
Totals
were
calculated
using
unrounded
values
from
Appendix
shown
in
this
table.

C.
2.4
Eyewear
If
the
SNUR
cites
40
CFR
§
721.63(
a)(
2)(
iii),
then
to
avoid
engaging
in
a
Significant
New
Use,
employer
must
provide
eye
protection.
Eye
protection
may
also
be
aquired
as
a
result
of
the
dermal
protection
selection
at
721.63(
a)(
1).
Protective
goggles
are
expected
to
be
used
at
a
rate
of
one
set
per
worker
and
replaced
every
four
months.
Each
site
is
assumed
to
have
25
workers,
each
of
them
exposed
250
days
per
year.
The
SNUR
may
not
specify
the
exact
type
of
eyewear
required.
OSHA
guidelines
in
29
CFR
1910.133(
b)(
1),
however,
state
that

protective
eye
and
face
devices
purchased
after
July
5,
1994
shall
comply
with
ANSI
Z87.1­
1989.

To
determine
the
C­
10
cost
of
goggles
that
meet
this
standard,
EPA
consulted
with
eyewear
specialists
at
equipment
supplier
LSS.
A
standard
pair
of
goggles
that
meets
the
ANSI
Z87.1­
1989
specification
was
priced
at
$
4.05
per
pair
in
1997
(
LSS
1997;
RIB
1998).
When
inflated
to
2002
dollars
using
BLS
Consumer
Price
Index
(
BLS
2003b),
the
cost
is
$
4.54
per
pair.
Costs
of
protective
eyewear
are
presented
in
Table
C­
8
below.
A
price
estimate
for
a
heavy­
duty
pair
of
goggles
compliant
with
the
ANSI
standard
is
also
included
in
Table
C­
8,
should
the
SNUR
require
such
eyewear.

Table
C­
8
Annu
al
Cost
of
Protective
Eyew
ear
[
40
CFR
§
721.63(
a)(
2)(
iii)]

Cost
Element
Unit
Co
st
(
1997
D
ollars)
Inflator
Unit
Cost
(
2002
D
ollars)
Number
of
PairsRequired*
Total
Cost**

Goggles
$
4.05
1.121
$
4.54
per
pair
75
$
340
Heavy
duty
ch
emicalsplash
impact
goggles
$
6.05
1.121
$
6.78
per
pair
75
$
509
Source:
1997
item
costs,
LSS
1997;
item
type
and
quantity,
EPAB
1998;
Inflator,
Appendix
B.
*
25
workers
replacing
gog
gles
three
times
per
year.
**
To
tals**
Totals
were
calculated
using
unrounded
values**
Totals
were
calculated
using
unrounded
values
from
Appendix
B,**
Totals
shown
in
this
table.

C.
2.5
Clothing
If
the
SNUR
cites
40
CFR
§
721.63(
a)(
2)(
iv),
then
to
avoid
engaging
in
a
Significant
New
Use,
employer
must
provide
protective
clothing.
Protective
clothing
may
also
be
aquired
as
a
result
of
the
dermal
protection
selection
at
721.63(
a)(
1).
Protective
clothing
and
full­
body
chemical
resistant
clothing
are
assumed
to
last
four
months.
Each
site
is
assumed
to
have
25
workers,
each
of
them
exposed
250
days
per
year.
For
costing
purposes,
a
standard
coverall
clothing
set
(
LSS
1997)
was
assumed
to
satisfy
protective
clothing
requirements.
As
shown
in
Table
C­
9
below,
this
basic
set
of
clothing
costs
approximately
$
40.63
after
inflating
to
2002
dollars
using
the
BLS
Consumer
Price
Index
(
BLS
2003b);
however,
costs
for
full­
body
protective
clothing
(
if
specified
by
the
SNUR)
are
based
on
the
coverall
clothing
set
with
a
hood
(
LSS
1997)
and
are
estimated
at
$
68.60
per
set
with
inflation.
C­
11
Table
C­
9
Ann
ual
Cost
of
Protective
Clothing
[
40
CFR
§
72
1.63(
a)(
2)(
iv)]

Cost
Element
Unit
Co
st
(
1997
D
ollars)
Inflator
Unit
Co
st
(
2002
D
ollars)
Number
Required*
Total
Cost**

Coverall
with
hood
[
full­
body
clothing]
$
61.20
1.121
68.20
per
set
75
$
5,145
Covera
ll
$
36.25
1.121
$
40.63
per
set
75
$
3,047
Source:
1997
item
costs,
LSS
1997;
item
type
and
quantity,
EPAB
1998;
Inflator,
Appendix
B.
*
25
workers
replace
item
three
times
per
year.
**
Totals
were
calculated
using
unrounded
values
from
Appendix
B,
and
may
not
equal
product
of
the
rounded
values
shown
in
this
table.

C.
2.6
Respirators
For
some
PMN
chemicals,
to
avoid
engaging
in
a
Significant
New
Use,
the
SNUR
requires
the
use
of
respirators,
as
defined
in
40
CFR
§
721.63
(
a)(
5).
The
respirators
specified
in
Section
(
a)(
5)
are
all
comprised
of
a
respirator
unit
and
any
number
of
the
following:
special
cartridges
(
such
as
high
efficiency
particulate
filters,
organic
vapor
cartridges,
and
paint,
lacquer,
and
enamel
filters),
hoods
or
helmets,
and
filter
caps.

Paragraphs
(
a)(
5)(
i)
through
(
xv)
of
§
721.63
reference
specific
types
of
NIOSH­
approved
respirator
units.
Table
C­
10
describes
the
types
of
NIOSH­
approved
respirators
with
their
average
costs
in
1997
and
2002
dollars,
and
estimates
costs
per
plant
site
for
each
chemical
requiring
respirators.

The
costs
for
each
site
of
providing
respirators
to
chemically­
exposed
workers,
shown
in
Table
3
of
Section
2
of
the
report,
are
calculated
based
on
the
assumptions
stated
there,
that
(
1)
there
are
25
chemically­
exposed
workers
requiring
protective
equipment,
(
2)
respirators
are
replaced
once
a
year,
and
(
3)
cartridges
(
and
cartridge
filters
and
caps)
are
replaced
at
a
rate
of
one
pair
(
2)
every
five
of
the
250
days
that
workers
are
exposed,
or
50
times
per
year.
For
example,
if
type
15
respirator
is
used,
the
total
annual
cost
would
be
($
12.14
+
$
10.02*
50)*
25
=
$
12,829.

For
some
PMN
chemicals
the
SNUR
may
list
more
than
one
NIOSH­
type
respirator,
but
only
one
type
of
respirator
is
needed
to
comply
with
the
workplace
protection
requirements.
In
such
cases,
the
NIOSH­
type
with
the
lowest
average
cost
was
assumed
in
order
to
estimate
workplace
protection
costs
in
Table
10.
C­
12
Table
C­
10
An
nual
Costs
for
Respiratory
P
rotection
[
40
CFR
§
721.63(
a)(
5)]

40
CFR
§
721.63
(
a)(
5)
NIOSH
Approval
Type
Averag
e
Costs
(
199
7
Dollars)
Average
Co
sts
(
2002
Dollars)*

Per
Respirator
Per
Respirator
Annual
Per
Worker**
Annual
Per
Site
(
25
work
ers)
Unit
Cartridge
Unit
Cartridge
(
i)
19C
T
ype
C
S
upplied
­
air
with
full
facepiece
$
804.03
­­
$
901.21
­­
$
901.21
$
22,530
(
ii)
19C
T
ype
C
S
upplied
­
air
with
tight­
fitting
facepiece
$
804.03
­­
$
901.21
­­
$
901.21
$
22,530
(
iii)
19C
T
ype
C
S
upplied
­
air
with
hood
or
helmet
or
tight­
fitting
facepiece
$
932.15
­­
$
1,044.82
­­
$
1,044.82
$
26,121
(
iv)
21C
A
ir­
purifyin
g
with
fu
ll
facepiece
and
high
efficiency
particulate
filters
(
HEPA
s)
$
180.67
$
9.76
$
202.51
$
10.94
$
749.49
$
18,737
(
v)
21C
Powered
air­
purifying
(
PAPR)
with
tight
fitting
facepiece
and
HEPAs
$
627.45
$
35.50
$
703.29
$
39.79
$
2,692.84
$
67,321
(
vi)
21C
PAPR
with
loose
hood
or
helmet
and
HEPAs
$
525.43
$
26.89
$
588.94
$
30.14
$
2,095.95
$
52,399
(
vii)
21C
Air­
purifying
with
HEPA
and
disposable
respirators
$
12.53
$
7.00
$
14.04
$
7.85
$
406.35
$
10,159
(
viii)
23C
air­
p
urifying
with
full
facepiece
and
combination
cartridges
approve
d
for
paints,
lacquers
and
enamels
(
PLE)
$
192.02
$
15.71
$
215.23
$
17.61
$
1,095.68
$
27,392
(
ix)
23C
PAPR
with
tight­
fitting
facepiece
and
combination
cartridges
approved
PLE
$
627.45
$
35.50
$
703.29
$
39.79
$
2,692.84
$
67,321
(
x)
23C
PAPR
with
loose­
fitting
hood
or
helmet
and
combination
cartridges
for
PLE
$
525.43
$
26.88
$
588.94
$
30.13
$
2,095.39
$
52,385
40
CFR
§
721.63
(
a)(
5)
NIOSH
Approval
Type
Averag
e
Costs
(
199
7
Dollars)
Average
Co
sts
(
2002
Dollars)*

Per
Respirator
Per
Respirator
Annual
Per
Worker**
Annual
Per
Site
(
25
work
ers)
Unit
Cartridge
Unit
Cartridge
C­
13
(
xi)
23C
A
ir­
purifying
with
combination
cartridges
for
PLE,
inc
luding
dispo
sable
respirators
$
14.30
$
8.90
$
16.03
$
9.98
$
514.82
$
12,870
(
xii)
23C
A
ir­
purifying
with
fullfacepiece
and
orga
nic
gas/
vapor
cartridges
$
192.02
$
10.47
$
215.23
$
11.74
$
802.00
$
20,050
(
xiii)
23C
PAPR
with
tight­
fitting
facepiece
and
orga
nic
gas/
vapor
cartridges
$
826.40
$
41.15
$
926.29
$
46.12
$
3,232.48
$
80,812
(
xiv)
23C
PAPR
with
a
loose­
fitting
hood
o
r
helmet
and
organic
gas/
vapor
cartridges
$
639.80
$
41.15
$
717.13
$
46.12
$
3,023.33
$
75,583
(
xv)
23C
A
ir­
purifying
with
org
anic
gas/
vapor
cartridges,
including
disposable
cartridges
$
10.83
$
8.94
$
12.14
$
10.02
$
513.17
$
12,829
Source:
S
ee
Tab
le
C­
11
for
derivation
o
f
1997
av
erage
cos
ts
*
Inflated
to
2002
dollars
using
Consumer
Price
Index
BLS
Series
CUUR0000SA0
(
BLS
2003b)
**
Assumes
cartridge
sets
(
2
cartridges
an
d
any
filters
or
caps
required)
replac
ed
every
5
days
or
5
0
times
during
250
e
xposure
days.
Respirato
r
costs
includ
e
costs
of
add­
on
item
s
such
as
hood
s
and
helme
ts,
if
these
items
are
required
for
a
particular
respirator.
Cartridge
c
osts
reflect
the
costs
of
cartridges,
filters,
and
cap
s.
C­
14
Table
C­
11
shows
how
the
average
costs
per
NIOSH­
type
respirator
were
calculated,
based
on
prices
of
respirators
listed
in
a
1997
catalog.
To
calculate
the
cost
of
respirators
that
meet
the
NIOSH
criteria,
the
prices
of
all
units
in
the
supplier
catalog
(
LSS
1997)
that
meet
each
NIOSH
criteria
were
averaged.
Costs
of
additional
items
such
as
hoods,
helmets,
cartridges,
and
filter
caps
were
also
obtained.
These
are
added
to
the
cost
of
the
basic
respirator
unit
if
they
are
required
under
the
SNUR
regulation
and
if
the
unit
does
not
already
include
the
item.
For
example,
§
721.63(
a)(
5)(
x)
requires
a
hood
or
helmet.
One
model
in
the
catalog
that
satisfies
the
requirement
already
includes
a
hood,
while
another
unit
requires
that
a
separate
hood
be
purchased.
The
cost
of
the
hood
was
added
to
the
unit
cost
and
the
combined
cost
was
then
averaged
with
the
model
with
integrated
hood.

Many
respirator
specifications
also
require
cartridges.
The
costs
of
the
cartridges
listed
in
LSS
(
1997)
were
averaged
for
the
corresponding
requirements.
In
some
instances,
certain
cartridges
or
filters
require
a
secondary
cartridge
to
function
properly
(
e.
g.,
some
paint,
lacquer
and
enamel
filters
required
the
organic
vapors
cartridges
and
filter
retainer
caps).
These
additional
items
were
priced
and
added
to
the
cost
for
the
basic
cartridge
before
averages
were
taken.

Some
cartridge
prices
were
unavailable
from
LSS
(
1997).
For
instance,
§
721.63(
a)(
5)(
ix)
and
(
x)
require
a
powered
air­
purifying
respirator
(
PAPR)
with
a
paint,
lacquer
and
enamel
cartridge.
The
only
cartridges
available
for
these
models
of
respirators
in
LSS
(
1997)
are
HEPA
cartridges.
In
these
cases
the
costs
of
a
paint,
lacquer,
and
enamel
cartridge
are
assumed
to
be
the
same
as
for
a
HEPA
cartridge.

The
1997
purchase
costs
of
the
varying
types
of
respiratory
protective
equipment,
are
shown
in
Table
C­
11.
C­
15
Table
C­
11
Respirator
Prices
and
Average
Costs
in
1997,
by
NIOSH
Type
40CFR
§
721.63
(
a)(
5)
NIOSH
type
Catalog
Item
Number
Description
1997
Cost
1997
Average
Cost
Unit
Cartridge
(
i)
19C
Type
C
Supplied­
air
with
full
facepiece
$
804.03
­­

7A­
24506
Allegro
Economical
Full­
Face
Airline
Kits,
p144
$
758.95
7A­
32366
311Survivair
Supplied
Air
Respirator
Kits,
p144
$
849.10
(
ii)
19C
Type
C
Supplied­
air
with
tight­
fitting
facepiece
$
804.03
­­

7A­
24506
Allegro
Economical
Full­
Face
Airline
Kits,
p144
$
758.95
7A­
32366
Survivair
Supplied
Air
Respirator
Kits,
p144
$
849.10
(
iii)
19C
Type
C
Supplied­
air
with
hood
or
helmet
or
tight­
fitting
facepiece
$
932.15
­­

7A­
29363
Allegro
Hood
Systems,
p144
$
932.15
(
iv)
21C
Air­
purifying
with
full
face
piece
and
hig
h
efficiency
particulate
filters
(
H
EPAs)
$
180.67
$
9.76
7A­
9838
North
Full­
Face
Respirator,
p114
$
210.10
7A­
7122
North
HEPA
Cartridge,
p115
$
11.15
7A­
12338
Willson
Full­
Face
Silicone
Respirator,
p116
$
215.10
7A­
7526
Willson
HEPA
Cartridge,
p117
$
11.75
7A­
10516
3M
7800
Full­
Facepiece
Respirator,
p118
$
202.10
7A­
11839
3M
HEPA
Cartridge,
p118
$
7.00
7A­
33446
Pro­
Tech
Full­
Face
Respirator,
p122
$
106.45
7A­
3070­
1
Pro­
Tech
HEPA
Cartridge,
p123
$
9.87
7A­
3195
Willson
1600/
1700
Series
Full­
Fave
Respirators,
p124
$
215.10
7A­
3202
Willson
HEPA
Cartridge,
p125
$
12.50
7A­
23959
AO7Star
Full­
Face
Respirator
(
Silicone),
p126
$
203.25
7A­
9940
AO7Star
HEPA
Cartridge,
p127
$
9.44
7A­
24158
MSA
Advantage
1000
Full­
Face
Respirator,
p134
$
112.60
7A­
29946
MSA
HEPA
Cartridge,
p134
$
6.60
(
v)
21C
Powered
air­
purifying
(
PAPR)
with
tight
fitting
facepiece
and
HEPAs
$
627.45
$
35.50
7A­
13599
3M
Face­
Mounted
PAPR
System,
p142
$
720.00
7A­
13601
3M
HEPA
Replacement
Cartridge,
p142
$
36.50
7A­
32505
RACAL
Powerflow
PAPR,
p142
$
534.90
7A­
11936
RACAL
Replacement
Cartridge,
p142
$
34.50
(
vi)
21C
PAPR
with
loose
hood
or
helmet
and
HEPAs
$
525.43
$
26.89
7A­
32506
RACAL
Air­
Mate
PAPR
12,
p143
$
411.05
7A­
24505
RACAL
HEPA
Replacement
Cartridge,
p143
$
24.65
7A­
32477
RACAL
Breathe­
Easy
HEPA
Cartridges
and
Turbo
Unit,
p141
$
548.50
7A­
12838
RACAL
HEPA
Replacement
Cartridge
$
29.12
7A­
12840
RACAL
Breathe­
Easy
10
Tyvek
Hood,
p140
$
91.30
(
vii)
21C
Air­
purifying
with
H
EPA
an
d
disposable
resp
irators
$
12.53
$
7.00
7A­
15255
3M
6000
Series
Low­
Maintenance
Respirator,
p135
$
10.90
7A­
12518P
3M
Adaptor,
p135
$
1.63
40CFR
§
721.63
(
a)(
5)
NIOSH
type
Catalog
Item
Number
Description
1997
Cost
1997
Average
Cost
Unit
Cartridge
C­
16
7A­
11839
3M
HEPA
Cartridge,
p135
$
7.00
(
viii)
23C
air­
purifying
with
full
facep
iece
and
com
bination
cartridges
a
pproved
fo
r
paints,
lacquers
and
enamels
(
PLE)
$
192.02
$
15.71
7A­
9838
North
Full­
Face
Respirator,
p114
$
210.10
7A­
7117
North
Organic
Vapors
Cartridge,
p115
$
10.50
7A­
7125
North
Paint
Spray/
Mists
Prefilter,
p115
$
2.38
7A­
7125­
2
North
Filter
Covers,
p115
$
4.35
7A­
12338
Willson
Full­
Face
Silicone
Respirator,
p116
$
215.10
7A­
7527
Willson
Organic
Vapors
Cartridge,
p117
$
10.25
7A­
7531
Willson
Dusts/
Mists/
Pesticides/
Paint
Spray
Prefilter,
p117
$
2.52
7A­
7532
Willson
Retainer
Caps,
p117
$
4.00
7A­
10516
3M
7800
Full­
Facepiece
Respirator,
p118
$
202.10
7A­
9279
3M
Organic
Vapors
Cartridge,
p119
$
8.91
7A­
9284
3M
Paint
Spray
Prefilter,
p119
$
2.37
7A­
9292
3M
Retainer
Caps,
p119
$
3.90
7A­
33446
Pro­
Tech
Full­
Face
Respirator,
p122
$
106.45
7A­
955­
4
Pro­
Tech
Organic
Vapors
Cartridge,
p123
$
9.27
7A­
9605
Pro­
Tech
Paint
Spray
Prefilter,
p123
$
1.95
7A­
3195
Willson
1600/
1700
Series
Full­
Fave
Respirators,
p124
$
215.10
7A­
3197
Willson
Organic
Vapors
Cartridge,
p125
$
11.22
7A­
3203
Willson
Pesticides/
Paint
Spray
Prefilter,
p125
$
3.36
7A­
3858
Willson
Retainer
Caps,
p125
$
4.27
7A­
23959
AO7Star
Full­
Face
Respirator
(
Silicone),
p126
$
203.25
7A­
9935
AO7Star
Organic
Vapors
Cartridge,
p127
$
8.76
7A­
10043
AO7Star
Dusts/
Mists/
Paint
Spray
Prefilter,
p127
$
3.07
7A­
10044
AO7Star
Retainer
Clips,
p
127
$
3.20
(
ix)
23C
PAPR
with
tight­
fitting
facepiece
and
combination
cartridges
approved
PLE
$
627.45
$
35.50
7A­
13599
3M
Face­
Mounted
PAPR
System,
p142
$
720.00
­­­
Paint,
Lacquer,
Enamel
Cartridge*
$
36.50
7A­
32505
RACAL
Powerflow
PAPR,
p142
$
534.90
­­­
Paint,
Lacquer,
Enamel
Cartridge*
$
34.50
(
x)
23C
PAPR
with
loose­
fitting
hood
or
helmet
and
combination
cartridges
for
PLE
$
525.43
$
26.88
7A­
32506
RACAL
Air­
Mate
PAPR
12,
p143
$
411.05
­­­
Paint,
Lacquer,
Enamel
Cartridge*
$
24.65
7A­
32477
RACAL
Breathe­
Easy
HEPA
Cartridges
and
Turbo
Unit,
p141
$
548.50
7A­
12840
RACAL
Breathe­
Easy
10
Tyvek
Hood,
p140
$
91.30
­­­
Paint,
Lacquer,
Enamel
Cartridge*
$
29.10
(
xi)
23C
Air­
purifying
with
co
mbination
c
artridges
for
PLE
,
including
disposa
ble
respirators
$
14.30
$
8.90
7A­
12711
Willson
Freedom
2000
Series
Organic
Vapors
Respirator,
p136
$
17.85
7A­
7531
Willson
Dusts/
Mists/
Paint
Spray/
Pesticides
Prefilter,
p136
$
2.52
40CFR
§
721.63
(
a)(
5)
NIOSH
type
Catalog
Item
Number
Description
1997
Cost
1997
Average
Cost
Unit
Cartridge
C­
17
7A­
13509
Willson
Retainer
Caps,
p136
$
2.03
7A­
33826
Moldex
8000
Series
Half­
Mask
Respirator,
p139
$
10.75
7A­
22751
Moldex
Organic
Vapors
Cartridge,
p139
$
8.03
7A­
22753
Moldex
Paint
Spray/
Pesticides
Prefilter,
p139
$
2.56
7A­
22754
Moldex
Retainer
Caps,
p139
$
2.65
(
xii)
23C
Air­
purifying
with
full­
facepiece
and
organic
gas/
vapor
cartridges
$
192.02
$
10.47
7A­
9838
North
Full­
Face
Respirator,
p114
$
210.10
7A­
7117
North
Organic
Vapors
Cartridge,
p115
$
10.50
7A­
12338
Willson
Full­
Face
Silicone
Respirator,
p116
$
215.10
7A­
7527
Willson
Organic
Vapors
Cartridge,
p117
$
10.25
7A­
10516
3M
7800
Full­
Facepiece
Respirator,
p118
$
202.10
7A­
9279
3M
Organic
Vapors
Cartridge,
p119
$
8.91
7A­
9292
3M
Retainer
Caps,
p119
$
3.90
7A­
33446
Pro­
Tech
Full­
Face
Respirator,
p122
$
106.45
7A­
955­
4
Pro­
Tech
Organic
Vapors
Cartridge,
p123
$
9.27
7A­
3195
Willson
1600/
1700
Series
Full­
Fave
Respirators,
p124
$
215.10
7A­
3197
Willson
Organic
Vapors
Cartridge,
p125
$
11.22
7A­
23959
AO7Star
Full­
Face
Respirator
(
Silicone),
p126
$
203.25
7A­
9935
AO7Star
Organic
Vapors
Cartridge,
p127
$
8.76
(
xiii)
23C
PAPR
with
tight­
fitting
facepiece
and
organic
gas/
vapor
cartridges
$
826.40
$
41.15
7A­
32473
RACAL
Breathe­
Easy
Organic
Vapors
and
Turbo
Unit,
p141
$
548.50
7A­
12844
RACAL
Breathe­
Easy
7
Full
Face,
p140
$
277.90
7A­
12830
RACAL
Organic
Vapors
Replacement
Cartridges,
p141
$
41.15
(
xiv)
23C
PAPR
with
a
loose­
fitting
hood
or
helmet
and
organic
gas/
vapor
cartridges
$
639.80
$
41.15
7A­
32473
RACAL
Breathe­
Easy
Organic
Vapors
and
Turbo
Unit,
p141
$
548.50
7A­
12840
RACAL
Breathe­
Easy
10
Tyvek
Hood,
p140
$
91.30
7A­
12830
RACAL
Organic
Vapors
Replacement
Cartridges,
p141
$
41.15
(
xv)
23C
Air­
purifying
with
organic
gas/
vapor
cartridges,
including
disposable
cartridges
$
10.83
$
8.94
7A­
15255
3M
6000
Series
Low­
Maintenance
Respirator,
p135
$
10.90
7A­
15256
3M
Organic
Vapors
Cartridge,
p135
$
9.85
7A­
33826
Moldex
8000
Series
Half­
Mask
Respirator,
p139
$
10.75
7A­
22751
Moldex
Organic
Vapors
Cartridge,
p139
$
8.03
Source:
LSS
1997;
EPAB
1999
*
Paint,
lacq
uer
and
ename
l
(
PLE)
c
artridges
fo
r
PAPR
s
were
no
t
listed
in
the
cata
log.
The
costs
for
PL
E
cartridg
es
are
assum
ed
to
be
the
same
a
s
HEPA
cartridges.
C­
18
C.
2.7
Annual
Costs
of
Protection
in
the
Workplace
Requirements
Based
on
the
equipment
purchase
costs
shown
above
in
Tables
C­
7,
C­
8,
C­
9
C­
10,
and
the
assumptions
made
regarding
replacement
intervals
for
the
equipment,
Table
C­
12
below
shows
the
annual
costs
of
providing
the
various
types
of
personal
protective
equipment
in
the
workplace,
per
chemical,
at
one
manufacturing
site,
with
25
exposed
workers.

Table
C­
12
Annual
Costs
of
Personal
Protective
Equipment
PPE
and
Requirement
Citation
at
40
CFR
Unit
Cost
(
2002
D
ollars)
Quantity
Required
Annual
Cost
(
2000
D
ollars)

Gloves
§
721.6
3(
a)(
2)(
i)

Standard
(
disposable)
$
0.48
6250
$
3,012
Heavy­
duty
butyl
$
38.11
250
$
9,527
Protective
clothing
§
721.63(
a)(
2)

(
ii)­
Full­
body
(
coverall
with
hood)
$
68.60
75
$
5,145
(
iv)­
Coverall
(
no
hood)
$
40.63
75
$
3,047
Eyew
ear
§
72
1.63(
a)(
2)(
i)

Standard
goggles
$
4.54
75
$
340
Heavy­
duty
goggles
$
6.78
75
$
509
Respirators
§
721.63(
a)(
5)
Respirator
Cartridge
Unit
Cost
Quan
tity
Unit
Cost
Quan
tity
Total
(
i)­
Type
1
Respirator
$
901.21
25
­­
­­
$
22,530
(
ii)­
Type
2
Respirator
$
901.21
25
­­
­­
$
22,530
(
iii)­
Type
3
Respirator
$
1,044.82
25
­­
­­
$
26,121
(
iv)­
Type
4
Respirator
$
202.51
25
$
10.94
1250
$
18,737
(
v)­
Type
5
Respirator
$
703.29
25
$
39.79
1250
$
67,321
(
vi)­
Type
6
Respirator
$
588.94
25
$
30.14
1250
$
52,399
(
vii)­
Type
7
Respirator
$
14.04
25
$
7.85
1250
$
10,159
(
viii)­
Type
8
Respirator
$
215.23
25
$
17.61
1250
$
27,392
(
ix)­
Type
9
Respirator
$
703.29
25
$
39.79
1250
$
67,321
(
x)­
Type
10
Respirator
$
588.94
25
$
30.13
1250
$
52,385
(
xi)­
Type
11
Respirator
$
16.03
25
$
9.98
1250
$
12,870
(
xii)­
Type
12
Respirator
$
215.23
25
$
11.74
1250
$
20,050
(
xiii)­
Type
13
Respirator
$
926.29
25
$
46.12
1250
$
80,812
(
xiv)­
Type
14
Respirator
$
717.13
25
$
46.12
1250
$
75,583
(
xv)­
Type
15
Respirator
$
12.14
25
$
10.02
1250
$
12,829
Note:
To
tal
annua
l
costs
assum
e:
1)
25
w
orkers
ex
posed
2
50
day
s
per
year
;
2)
standar
d
glove
s
replaced
daily
and
heavy­
duty
gloves
replaced
every
25
days;
3)
respirators
replaced
annually
and
cartridge
sets
replaced
every
five
days;
4)
goggles
and
protective
clothing
re
placed
th
ree
times
y
early
Source:
Tables
C­
6,
C­
7,
C­
8,
C­
9,
and
C­
11.
C­
19
C.
3
Recordkeeping
Recordkeeping
requirements
are
specified
for
all
PMN
substances
listed
in
the
current
SNUR.
Companies
submitting
a
SNUN
must
keep
records
under
40
CFR
§
721.40.
In
addition,
whether
or
not
they
submit
a
SNUN,
all
manufacturers,
importers,
and
processors
of
the
SNUR
substance
must
keep
records
based
on
§
721.125(
a)
through
(
k),
to
document
compliance
with
SNUR
conditions
for
avoiding
a
Significant
New
Use.
(
Companies
manufacturing
only
for
R&
D
use
must
add
the
SNUR
chemical
to
their
R&
D
records
system.)

For
example,
for
all
chemicals
in
the
current
SNUR,
manufacturers,
importers,
and
processors
must
keep
records
on
quantities
supplied
or
purchased
under
§
721.125(
a),
(
b),
and
(
c).
For
chemicals
with
water
discharge
restrictions,
companies
must
keep
records
concerning
water
discharge
compliance,
under
§
721.125(
k).
For
those
few
chemicals
with
workplace
protection
or
hazard
communication
restrictions,
companies
must
keep
records
to
document
compliance.

The
requirements
vary
between
substances
(
i.
e.,
there
are
variations
in
terms
of
the
types
of
records
that
must
be
kept,
reflecting
differences
in
SNUR
restrictions)
.
This
analysis
estimates
recordkeeping
costs
for
a
chemical
with
numerous
SNUR
restrictions,
including
workplace
protection,
hazard
communication,
water
discharge,
and
disposal.
Since
few
if
any
chemicals
will
have
all
of
those
restrictions,
actual
recordkeeping
costs
may
be
less
than
estimated
here.
However,
the
differences
are
judged
to
have
a
minimal
impact
on
the
type
of
recordkeeping
activities
that
must
be
performed
and
the
costs
that
will
be
incurred.

All
recordkeeping
requirements
basically
involve
copying
and
filing
relevant
records,
including
those
related
to:
manufacturing,
importing,
or
processing
volumes;
shipment
amounts
and
customer
information;
labels
(
documentation
of
labeling
procedures
and
copies
of
labels);
MSDS;
and
compliance
with
any
additional
restrictions
on
use,
disposal,
and
discharge.
Records
must
be
maintained
for
five
years
from
the
date
of
their
creation.

Costs
for
compliance
with
the
recordkeeping
requirements
for
substances
subject
to
a
SNUR
are
based
on
the
approach
in
RIB
(
1989).
On
an
annual
basis,
recordkeeping
associated
with
each
substance
is
estimated
to
require:
2.3
hours
technical
time,
23
hours
clerical
time,
1,715
photocopies,
one
half
of
a
4­
drawer
file
cabinet,
and
other
miscellaneous
materials
such
as
folders.

To
calculate
labor
costs
associated
with
these
requirements,
EPA
used
the
labor
rates
for
chemical
technicians
and
clerical
support
described
earlier
in
this
report
and
in
Appendix
B
(
BLS
2003d).
Also
as
before,
photocopying
was
inflated
from
$
0.5
per
page
in
1988.
A
standard,
four­
drawer,
full­
suspension
file
cabinet
was
priced
from
a
national
office
products
supplier
at
$
195.00
(
BT
Office
Products
1997;
Item
#
LGM­
202401),
or
$
218.57,
when
inflated
to
2002
dollars
(
BLS
2003b).
Miscellaneous
materials
costs
were
estimated
at
$
23.00
per
chemical
in
1989
(
RIB
1989),
or
$
33.37
when
inflated
to
2002
dollars
(
BLS
2003b).
C­
20
Other
assumptions
underlying
the
recordkeeping
cost
estimates,
based
on
RIB
1989
and
information
used
in
preparing
the
RIB
1989
report
(
Kearney
1988),
are
listed
below.

"
The
SNUR
chemical
is
present
at
one
of
a
company

s
sites.

"
Manufacture
and
import
volume,
and
sales
and
transfer
data
require
480
pages
of
records
per
year.
This
reflects
40
invoices
per
month
(
see
Haz­
Comm
Section
C.
1
above).

"
Disposal
compliance
records,
if
required,
cover
items
such
as
waste
production,
shipping
manifests,
permits,
and
transfer
receipts.

"
The
ratios
of
labor
hours
to
page
count
for
each
labor
category,
file
drawer
space
to
page
count,
and
cost
of
miscellaneous
supplies
such
as
folders
and
labels
to
page
count,
are
the
same
as
those
estimated
for
EPA

s
Comprehensive
Assessment
and
Reporting
Rule
(
CAIR).

Total
costs
for
recordkeeping,
as
shown
in
Table
C­
13,
are
$
923
per
chemical
with
numerous
SNUR
restrictions.
Recordkeeping
costs
would
be
lower
for
chemicals
with
relatively
few
SNUR
restrictions
and
therefore
fewer
pages
needed
to
document
SNUR
compliance.
C­
21
Table
C­
13
Annual
Costs
of
Recordkeeping
Requirements
[
40
CFR
§
721.125]

Cost
Element
Unit
Cost
(
2002
D
ollars)
Hours
Total
Cost
2.25
hours
technical
time
$
43.34
per
hour
2.25
$
97.52
23
hours
clerical
time
Pages
$
23.96
per
hour
23.0
$
551.11
1,715
pages
of
copying
resulting
from
40
CFR
§
721.125
(
a)
through
(
k):*

(
a),
(
b),
(
c)
V
olume
s
&
data
**
(
d)
Protective
clothing
[
721.63]
(
e)
Impermeability
[
721.63(
a)(
3)]
(
f)
Haz
com
program
[
721.72]
(
g)
Label
copies[
721.72(
b)]
(
h)
MSDS
copies
[
721
.72(
c)]
(
i)
Use
limitations
compliance
[
721.80]
(
j)
Disposal
compliance
[
721.85]
(
k)
Water
discharge
compliance
[
721.90
]
485
20
250
5
5
250
600
100
1715
$
0.076
per
copy
$
130.34
Half
of
a
four­
drawer
filing
cabinet
($
195
in
1997,
inflated
using
a
factor
of
1.121)
$
218.57
each
$
109.29
Misc.
materials
($
23
in
1988,
inflated
using
a
factor
of
1.521)
$
34.98
per
chemical
$
34.98
Total
25.3
$
923
Source:
File
cabinet
1997
price,
LSS
1997;
quantities,
RIB
1989
and
Kearney
1988;
labor
rates,
Appendix
B;
inflators,
BLS
2003b
and
Appendix
B.
*
40
CFR
721.125(
a)
through
(
k)
lists
recordkeeping
requirements
that
are
triggered
by
other
SNUR
restrictions,
indicated
in
the
bracketed
CFR
references
§
721.63,
§
721.72,
§
721.80,
§
721.85,
and
§
721.90.
**
Kearney
1988
had
5
pages
for
manufacture/
import
volume
and
480
pages
for
sales/
transfer
data.

Protective
clothing

pages
assumed
same
as
pages
for

protective
gloves

in
RIB
1989.

Haz
com

pages
assumed
same
as
pages
for

employee
information
and
training

in
RIB
1989.

Impermeability

not
separately
costed
in
RIB
1989.
Assume
it
is
included
under

Protective
clothing.

Inflated
from
$
0.5
per
copy
in
1988
using
Consumer
Price
Index
factor
1.521.
See
Appendix
B.
NOTE:
Totals
were
calculated
using
unrounded
values
from
Appendix
B,
and
may
not
equal
product
of
the
rounded
values
shown
in
this
table.
APPENDIX
D
COSTS
OF
TESTING
D­
1
APPENDIX
D
COSTS
OF
TESTING
This
appendix
presents
a
detailed
description
of
the
methodology
used
to
estimate
costs
for
health
and
environmental
effects
testing
recommended
for
chemicals
subject
to
the
current
SNUR.

Table
D­
2
contains
a
master
list
of
all
guidelines
cited
in
the
batch
SNUR
and
the
dollar
cost
and
hours
estimate
for
each,
based
on
the
assumptions
and
adjustments
discussed
below.
In
cases
where
cost
information
was
not
available
for
a
particular
guideline,
cost
information
was
obtained
from
a
corresponding
test
as
indicated
by
parenthesis
in
the
Guideline
column.

Testing
Guidelines
For
some
or
all
chemicals
in
a
SNUR,
EPA
identifies
tests
that
can
be
used
by
submitters
to
characterize
risks
of
the
PMN
substances.
The
tests
are
recommended
in
the
SNUR,
not
mandatory,
and
they
are
identified
by
guideline
numbers
which
can
be
used
to
look
up
published
test
protocols.
The
types
of
guidelines
are
described
below.

"
OPPTS
Harmonized.
Most
SNUR
tests
are
identified
by
their
OPPTS
number
from
the
series
of
OPPTS
Harmonized
Test
Guidelines
and
OPPTS
harmonized
public
drafts
not
yet
promulgated
as
OPPTS
guidelines.
For
example,
the
OPPTS
835
series
covers
Fate,
Transport
and
Transformation;
the
850
series
covers
Ecological
Effects,
and
the
870
series
covers
Health
Effects.
An
example
is
OPPTS
Guideline
850.1400,
Fish
Early
Life
Stage
Toxicity.
These
guidelines
may
have
equivalent
Code
of
Federal
Regulations
(
CFR)
or
Organization
for
Economic
Cooperation
and
Development
(
OECD)
guidelines.
They
are
available
electronically
on
EPA

s
website.

"
CFR.
A
few
SNUR
tests
are
identified
as
coming
from
the
Code
of
Federal
Regulations.
An
example
is
the
two­
year
bioassay
test
at
40
CFR
799.9420.
These
CFR
guidelines
may
have
equivalent
OPPTS
harmonized
guidelines,
but
are
listed
in
the
SNUR
by
their
CFR
reference.

"
OECD.
A
few
SNUR
tests
are
identified
by
their
OECD
number.
The
OECD
guidelines
may
also
have
OPPTS
equivalents.
For
example,
OECD
407
28­
Day
Oral
Toxicity
in
Rats
is
essentially
equivalent
to
OPPTS
870.3050.

"
PBT
Category.
Finally,
for
some
chemicals,
the
SNUR
cites
tiered
testing
according
to
a
testing
strategy
published
in
the
Federal
Register
(
FR),
Category
for
Persistant,
Bioaccumulative,
and
Toxic
New
Chemical
Substances,
November
4,
1999
(
64
FR
60194),
which
in
turn
refers
to
a
number
of
tests
by
OPPTS
or
OECD
guideline
number.
D­
2
Testing
Costs
Testing
costs
for
each
PMN
substance
are
calculated
by
adding
up
costs
of
individual
tests
listed
in
the
SNUR
for
that
substance.
EPA
regularly
develops
cost
estimates
of
many
test
guidelines
to
support
TSCA
rule
development.
These
costs
are
used
where
possible.
If
costs
of
a
test
have
not
been
estimated,
EPA
identifies
an
equivalent
guideline
for
which
the
cost
have
been
developed,
and
uses
that
cost.
All
test
costs
have
been
updated
to
2002
dollars
using
Employment
Cost
Index
inflators
from
the
Bureau
of
Labor
Statistics
(
see
Appendix
B).

In
cases
where
EPA
had
not
estimated
costs
of
the
exact
test
called
for
in
the
SNUR,
or
where
the
SNUR
left
open
aspects
of
method,
EPA
made
the
adjustments
described
below.

Default
parameters
and
other
adjustments
Costs
for
many
of
the
guidelines
have
been
estimated
for
different
combinations
of
species,
route,
length
of
study
and
other
aspects
of
methodology,
but
in
some
cases
the
SNUR
may
not
specify
all
of
these
variables.
Where
this
occurs,
EPA
has
used
certain
default
parameters,
which
are
listed
in
Table
D­
1.

Table
D­
1
Default
Parameters
for
Species,
Route,
and
Study
Type
Variab
le
Defau
lt
Species
Mammals
Fish
Invertebrates
Algae
Rats
Fathead
minnow*
Daphnids
[
Four
spe
cies

see
text]

Route/
Method
Mammalian
Fish
Invertebrates
Gavage
Flow­
through
Flow­
through
*
For
guide
line
850.1
400
tests
d
uplicated
in
P
BT
tier
te
sts,
rainbow
tro
ut
is
the
default.
(
See
PB
T
test
discus
sion
below
.)

There
were
other
adjustments
as
well:

"
The
SNUR
recommends
algal
acute
toxicity
testing
following
OPPTS
Guideline
850.5400
for
several
PMNs.
This
guideline
has
been
previously
costed
by
EPA
for
four
separate
algal
species
(
Navicula
pelliculosa,
Skeletonema
costatum,
Anabaena
flos­
aquae,
and
Selenastrum
capricornutum).
Since
the
SNUR
does
not
specify
the
algal
species
to
be
used,
the
average
costs
of
the
four
algal
species
tests
were
used
in
this
analysis.
D­
3
"
For
OPPTS
test
guideline
870.3700
for
prenatal
developmental
toxicity,
the
SNUR
specified
twospecies
testing
using
rats
and
mice.
Test
cost
information
was
not
available
for
testing
rats
and
mice
as
the
two
species
or
for
mice
testing
by
the
gavage
route.
For
a
corresponding
CFR
test
(
40
CFR
798.4900),
costs
for
testing
rats
are
greater
than
for
testing
mice.
Therefore,
cost
information
was
used
for
rats
by
the
gavage
route
for
870.3700.
Cost
information
for
870.3700
was
used
instead
of
798.4900
because
the
cost
information
was
more
recent.
Using
the
rat
testing
by
gavage
cost
information
errs
on
the
conservative
side
(
presents
an
overestimate
of
cost).

"
In
cases
where
OECD
421
and
OECD
422
reproductive
and
developmental
toxicity
tests
were
listed
as
alternatives,
costs
for
the
more
expensive
test,
OECD
422,
were
used.

Persistent
Bioaccumulative
Toxic
(
PBT)
tiered
testing
For
some
chemicals,
the
SNUR
cites
tiered
testing
for
Persistant
Bioaccumulative
Toxic
chemical
substances
(
PBTs)
according
to
the
testing
strategy
in
Category
for
Persistant,
Bioaccumulative,
and
Toxic
New
Chemical
Substances,
November
4,
1999,
at
64
FR
60194.
In
64
FR
60194,
there
are
three
tiers
of
testing.
The
results
of
tier
1
determine
whether
tier
2
testing
is
needed
and
the
results
of
tier
2
testing
determine
whether
tier
3
testing
is
needed.
To
obtain
a
cost
estimate
for
chemicals
citing
this
tiered
testing,
two
estimates
were
made:
a
low
estimate
which
includes
Tier
1
test
costs
plus
any
additional
tests
listed
in
the
SNUR
for
that
chemical,
and
a
high
estimate
that
includes
Tiers
1,
2,
and
3
testing
as
well
as
any
additional
testing
listed
in
the
SNUR.
Costs
were
adjusted
to
avoid
doublecounting
tests
listed
in
both
the
PBT
tiers
and
in
the
SNUR.
Further
details
are
provided
in
Table
D­
2.

Other
assumptions
are
described
below:

"
For
some
chemicals,
test
guideline
850.1400
is
referenced
both
explicitly
in
the
SNUR
and
implicitly
as
part
of
PBT
tier
3.
The
PBT
test
referenced
at
64
FR
60194
specifies
rainbow
trout
as
the
species.
Test
costs
for
those
chemicals
assume
the
test
explicitly
listed
in
the
SNUR
would
be
conducted
with
rainbow
trout,
to
be
consistent
with
the
species
designated
in
PBT
tier
3
for
the
same
test.

"
For
PBT
tier
1
ready
biodegradability
tests,
firms
may
either
choose
among
six
methods
in
test
guideline
835.3110
or
follow
test
guideline
835.3120.
The
costs
estimates
assume
835.3110
was
used
and
calculates
the
average
cost
of
its
six
methods.

Costs
by
test
and
by
PMN
chemical
Table
D­
3
presents
recommended
test
guidelines,
the
costs
associated
with
each
guideline,
and
the
total
testing
costestimates
for
each
of
the
65
chemicals.
An
asterisk
denotes
that
the
SNUR
did
not
specify
which
species
or
route/
method
to
use
and
the
default
assumptions
mentioned
above
were
used.
No
tests
were
listed
in
the
SNUR
for
two
of
the
65
chemicals.
D­
4
Table
D­
2
Cost
Estimates
for
Test
Guidelines
Cited
in
Batch
SNUR
Guideline
Test
Species
Route/
Method
Cost
($
2002)
Hours
799.9420
Two
year
bioassay
Rats
inhalation
$
1,730,120.19
22748
835.1110
Activated
sludge
sorption/
desorption
isotherm
$
9,904.29
82
835.2120
(
796.3500)
Hydrolysis
study
at
25
degrees
centigrade
and
pH
7
$
9,541.00
120
835.3110
Ready
biodegradability
avg
of
6
tests
$
10,213.00
112
835.3170
Shake­
flask
die­
away
(
biodegradability)
$
41,645.29
88
835.3220
Porous
pot
study
$
40,810.68
539
850.1010
(
797.1300)
Daphnid
acute
toxicity
Daphnid
flow­
through
$
8,995.98
54
850.1010
(
797.1300)
Daphnid
acute
toxicity
Daphnid
static
$
8,834.23
53
850.1075
(
797.1400)
Fish
acute
toxicity
static
$
10,398.79
84
850.1075
(
797.1400)
Fish
acute
toxicity
Fathead
Minnow
flow­
through
$
13,624.62
65
850.1085
Fish
acute
toxicity
mitigated
by
humic
acid
Fathead
Minnow
static
$
10,974.19
74
850.1300
Daphnid
chronic
toxicity
Daphnid
flow­
through
$
31,730.77
173
850.1400
Fish
early
life
stage
chronic
toxicity
Fathead
Minnow
flow­
through
$
34,483.17
291
850.1400
Fish
early
life
stage
chronic
toxicity
Rainbow
trout
flow­
through
$
52,560.10
432
850.1730
Fish
bioaccumulation
(
BCF)
Fathead
Minnow
flow
through
$
58,716.50
775
850.5400
Algal
acute
toxicity
Average
of
four
species
$
10,983.68
60
870.1100
Acute
oral
toxicity
Rats
gavage
$
3,533.69
44
870.3100
90­
day
subchronic
oral
study
in
rats
Rats
gavage
$
121,128.45
834
870.3465
90­
day
inhalation
toxicity
study
Rats
inhalation
$
340,553.22
2458
870.3700
Prenatal
developmental
toxicity
Rats
gavage
$
98,594.95
1157
870.3800
Two
generation
reproductive
and
toxicity
study
Rats
gavage
$
529,717.65
5024
870.4200
2­
year,
two­
species
oral
carcinogenicity
Rats
gavage
$
799,639.42
8275
870.4300
Combined
chronic
toxicity/
carcinogenicity
study
Rats
gavage
$
972,884.62
9701
870.5100
Ames
assay/
salmonella
Direct
plate
$
7,892.53
48
870.5265
Salmonella
typhimurium
reverse
mutation
assay
Average
of
Direct
plate
and
Azo
reduction
$
7,347.50
48
Guideline
Test
Species
Route/
Method
Cost
($
2002)
Hours
D­
5
870.5395
In
vivo
mouse
micronucleus
assay
(
intraperitoneal)
Mice
gavage
(
avg
of
1
and
3
day
doses)
$
14,687.50
114
OECD
407
28­
day
oral
toxicity
study
in
rats
Rats
gavage
$
43,750.00
328
OECD
407
(
mod
:
FOB
+
histo)
28­
day
oral
toxicity
study
in
rats
modified
with
FOB
and
histopathology
Rats
gavage
$
150,629.43
1838
OECD
421
Reproductive/
Development
Toxicity
Rats
gavage
$
51,875.00
445
OECD
422
Combined
Repeated
Dose
with
Reproductive/
Developmental
Toxicity
Rats
gavage
$
109,464.00
1146
60
FR
60194
Persistent
Bioaccumulative
Toxic
(
PB
T)
Tiered
Testing
TIER
1
$
60,577.38
275.5
830.7570
(
796.1570)
Log
Kow
(
liquid
chromatography)
Liquid
chromatography
$
2412.11
28
830.7560
Log
Kow
(
generator
column)
Generator
column
$
3,316.65
39
Log
Kow
(
liquid
chromatography
or
generator
column)
Average
of
2
tests
$
2,864.38
33.5
835.2110
Hydrolysis
in
water
$
47,500.00
130
835.3110
Ready
biodegradability
(
chose
one
of
six
methods)
Average
of
6
methods
$
10,213.00
112
TIERS
2
and
3
$
402,989.02
4110
TIER
2
835.3170
Shake­
flask
die­
away
(
biodegradability)
$
41,645.29
88
850.1730
Fish
bioaccumulation
(
BCF)
Fathead
minnow
Flow­
through
$
58,716.50
775
TIER
3
OECD
422
Combined
Repeated
Dose
Oral
Toxicity
with
Reproductive/
Developmental
Toxicity
screen
Rat
gavage
$
109,464.00
1146
Guideline
Test
Species
Route/
Method
Cost
($
2002)
Hours
D­
6
835.3180
Sediment/
water
microcosm
biodegradation
Flow­
through
$
108,872.37
1496
850.1400
Fish
chronic
toxicity
Rainbow
trout
Flow­
through
$
52,560.10
432
850.1300
Daphnid
chronic
toxicity
Daphnid
Flow­
through
$
31,730.77
173
TIERS
2
and
3
excluding
850.1400
and
850.1300
$
318,698.16
3505
TIERS
2
and
3
excluding
850.1400,
850.1300,
835.3170,
and
850.1730
$
218,336.37
2642
Guidelines
in
parenthesis
indicate
corresponding
test
guidelines
from
which
cost
information
was
calculated.
D­
7
Table
D
­
3
SNU
R
Testin
g
Requ
irements
a
nd
Co
st
for
65
C
hemicals
No.
PMN
Guideline
Species
Route/
Method
Cost
($
2002)
Hours
Total
Cost
($
2002)
Total
Hours
1
P­
97­
1108
850.1400
Fathead
Minnow*
flow­
through*
$
34,483.17
291
$
118,008.30
1,063
850.1300
Daphn
id
flow­
through*
$
31,730.77
173
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
835.3220
­
­
$
40,810.68
539
2
P­
98­
848
870.3465
Rats*
inhalation
$
340,553.22
2458
$
2,070,673.41
25206
799.9420
Rats*
inhalation
$
1,730,120.19
22748
3
P­
98­
1033
OECD
407
(
mod
:
FOB
+
histo)
Rats
gavage*
$
150,629.43
1838
$
297,516.16
3288
870.5395
Mice
gavage
(
avg
of
1
and
3
day
doses)*
$
14,687.50
114
870.3700
Rats*
gavage*
$
98,594.95
1157
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
4
P­
98­
1034
OECD
407
(
mod
:
FOB
+
histo)
Rats
gavage*
$
150,629.43
1838
$
297,516.16
3288
870.5395
Mice
gavage
(
avg
of
1
and
3
day
doses)*
$
14,687.50
114
870.3700
Rats*
gavage*
$
98,594.95
1157
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
5
P­
98­
1035
OECD
407
(
mod
:
FOB
+
histo)
Rats
gavage*
$
150,629.43
1838
$
297,516.16
3288
870.5395
Mice
gavage
(
avg
of
1
and
3
day
doses)*
$
14,687.50
114
870.3700
Rats*
gavage*
$
98,594.95
1157
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
No.
PMN
Guideline
Species
Route/
Method
Cost
($
2002)
Hours
Total
Cost
($
2002)
Total
Hours
D­
8
6
P­
99­
783
850.1010
Daphn
id
flow­
through
$
8,995.98
54
$
19,979.66
114
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
7
P­
99­
817
870.3465
Rats*
inhalation
$
340,553.22
2458
$
340,553.22
2458
8
P­
99­
897
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
$
33,604.28
179
850.1010
Daphnid*
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
9
P­
99­
920
850.1075
Fathead
Minnow*
flow­
through
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
10
P­
99­
928
850.1075
Fathead
Minnow*
flow­
through
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
11
P­
99­
951
850.1075
Fathead
Minnow*
flow­
through
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
12
P­
99­
952
850.1075
Fathead
Minnow*
flow­
through
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
13
P­
99­
1075
850.1400
Fathead
Minnow*
flow­
through*
$
34,483.17
291
$
77,197.62
524
850.1300
Daphn
id
flow­
through*
$
31,730.77
173
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
14
P­
99­
1202
850.1400
Fathead
Minnow*
flow­
through
$
34,483.17
291
$
417,750.84
2982
850.1300
Daphn
id
flow­
through
$
31,730.77
173
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
870.3465
Rats*
inhalation
$
340,553.22
2458
15
P­
99­
1288
850.1075
Fathead
Minnow*
flow­
through
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
16
P­
99­
1295
850.1075
Fathead
Minnow*
flow­
through
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
No.
PMN
Guideline
Species
Route/
Method
Cost
($
2002)
Hours
Total
Cost
($
2002)
Total
Hours
D­
9
17
P­
99­
1304
850.1075
Fathead
Minnow*
flow­
through
$
13,624.62
65
$
374,157.49
2637
850.1010
Daphn
id
flow­
through
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
870.3465
Rats*
inhalation
$
340,553.22
2458
18
P­
99­
1341
850.1075
­
static
$
10,398.79
84
$
30,216.70
197
850.1010
Daphn
id
static
$
8,834.23
53
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
19
P­
99­
1342
850.1075
­
static
$
10,398.79
84
$
30,216.70
197
850.1010
Daphn
id
static
$
8,834.23
53
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
20
P­
00­
7
870.3465
Rats*
inhalation
$
340,553.22
2458
$
340,553.22
2458
21
P­
00­
368
870.3465
Rats*
inhalation
$
340,553.22
2458
$
406,767.16
2922
850.1400
Fathead
Minnow*
flow­
through*
$
34,483.17
291
850.1300
Daphn
id
flow­
through*
$
31,730.77
173
22
P­
00­
636
870.3800
Rats*
gavage*
$
529,717.65
5024
$
1,329,357.07
13299
870.4200
Rats*
gavage*
$
799,639.42
8275
23
P­
00­
838
850.1400
Fathead
Minnow*
flow­
through
$
34,483.17
291
$
34,483.17
291
24
P­
00­
912
(
low
estimate)
64
FR
60194
­
PBT
T
ier
1
$
60,577.38
275.5
$
1,076,619.80
10049
.5
850.1400
Rainbow
Trout
flow­
through*
$
52,560.10
432
850.1300
Daphn
id
flow­
through
$
31,730.77
173
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
870.4200
Rats*
gavage*
$
799,639.42
8275
870.3100
Rats
gavage*
$
121,128.45
834
24
P­
00­
912
(
high
estimate)
64
FR
60194
­
PBT
T
ier
1
$
60,577.38
275.5
$
1,395,317.95
13554
.5
64
FR
60194
­
PBT
Tiers
2
and
3
(
a)
$
318,698.16
3505
850.1400
Rainbow
trout*
flow­
through
$
52,560.10
432
850.1300
Daphn
id
flow­
through
$
31,730.77
173
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
870.4200
Rats*
gavage*
$
799,639.42
8275
No.
PMN
Guideline
Species
Route/
Method
Cost
($
2002)
Hours
Total
Cost
($
2002)
Total
Hours
D­
10
870.3100
Rats
gavage*
$
121,128.45
834
(
a)
Excluding
850.1400
and
850
.1300
to
avoid
doublecounting
25
P­
00­
966
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
$
43,817.28
291
850.1010
Daphnid*
flow­
through
$
8,995.98
54
850.1075
Fathead
Minnow*
flow­
through
$
13,624.62
65
835.3110
Ready
biodegradation
avg
of
6
tests*
$
10,213.00
112
26
P­
00­
991
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
27
P­
00­
1055
870.3700
Rats*
gavage
$
98,595.00
1157
$
1,484,136.38
14797
870.3800
Rats*
gavage*
$
529,717.65
5024
870.5100
Salmone
lla
Direct
plate*
$
7,892.53
48
870.5395
Mice
gavage
(
avg
of
1
and
3
day
doses)*
$
14,687.50
114
870.4200
Rats
gavage*
$
799,639.42
8275
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
28
P­
00­
1205
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
$
34,503.10
221
850.1085
Fathead
Minnow*
static*
$
10,974.19
74
835.1110
­
­
$
9,904.29
82
29
P­
00­
1220
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
$
10,983.68
60
30
P­
01­
1
835.2130
­
­
$
9,541.00
120
$
53,358.28
411
835.3110
­
avg
of
6
tests*
$
10,213.00
112
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
31
P­
01­
7
870.3700
Rats*
gavage*
$
98,594.95
1157
$
898,234.37
9432
870.4200
Rats*
gavage*
$
799,639.42
8275
No.
PMN
Guideline
Species
Route/
Method
Cost
($
2002)
Hours
Total
Cost
($
2002)
Total
Hours
D­
11
32
P­
01­
9
(
low
estimate)
64
FR
60194
­
PBT
T
ier
1
$
60,577.38
275.5
$
155,851.93
940.5
850.1400
Rainbow
Trout
flow­
through
$
52,560.10
432
850.1300
Daphn
id
flow­
through
$
31,730.77
173
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
32
P­
01­
9
(
high
estimate)
64
FR
60194
­
PBT
T
ier
1
$
60,577.38
275.5
$
474,550.09
4445.5
64
FR
60194
­
PBT
Tiers
2
and
3
(
a)
$
318,698.16
3505
850.1400
Rainbow
Trout
flow­
through
$
52,560.10
432
850.1300
Daphn
id
flow­
through
$
31,730.77
173
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
(
a)
Excluding
850.1400
and
850
.1300
to
avoid
doublecounting
33
P­
01­
22
850.1075
Fathead
Minnow*
flow­
through
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
34
P­
01­
69
850.1075
Fathead
Minnow*
flow­
through
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
35
P­
01­
71
850.1400
Rainbow
Trout
flow­
through
$
52,560.10
432
$
84,290.87
605
850.1300
Daphn
id
flow­
through
$
31,730.77
173
36
P­
01­
77
OECD
422
or
OECD
421
Rats*
gavage
$
109,464.00
1146
$
143,068.28
1325
850.1075
Fathead
Minnow*
flow­
through
$
13,624.62
65
850.1010
Daphn
id
flow­
through
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
37
P­
01­
85
850.1075
Fathead
Minnow*
flow­
through
$
13,624.62
65
$
33,604.28
$
179.00
850.1010
Daphnid*
flow­
through
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
38
P­
01­
97
870.3100
Rats
gavage*
$
121,128.45
834
$
920,767.87
9109
870.4200
Rats
gavage*
$
799,639.42
8275
39
P­
01­
144
870.3700
Rats*
gavage*
$
98,594.95
1157
$
274,793.07
3201
No.
PMN
Guideline
Species
Route/
Method
Cost
($
2002)
Hours
Total
Cost
($
2002)
Total
Hours
D­
12
OECD
407
(
mod:
FOB
+
histo)
Rats
gavage
$
150,629.43
1838
870.1100
Rats*
gavage
$
3,533.69
44
870.5395
Mice*
gavage
(
avg
of
1
and
3
day
doses)*
$
14,687.50
114
870.5265
Average
of
Direct
p
late
and
Azo
reduction*
$
7,347.50
48
40
P­
01­
149
870.3100
Rats*
gavage
$
121,128.45
834
$
121,128.45
834
41
P­
01­
152
(
low
estimate)
64
FR
60194
­
PBT
T
ier
1
$
60,577.38
275.5
$
94,181.66
454.5
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
$
10,983.68
60
41
P­
01­
152
(
high
estimate)
64
FR
60194
­
PBT
T
ier
1
$
60,577.38
275.5
$
497,170.68
4564.5
64
FR
60194
­
PBT
Tiers
2
and
3
$
402,989.02
4110
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
42
P­
01­
170
N/
A
[
No
tests
listed
in
SNUR]
N/
A
N/
A
$
0.00
0
43
P­
01­
298
870.3700
Rats*
gavage*
$
98,594.95
1157
$
98,594.95
1157
44
P­
01­
320
870.3465
Rats*
inhalation
$
340,553.22
2458
$
340,553.22
2458
45
P­
01­
397
850.1400
Fathead
Minnow*
flow­
through
$
34,483.17
291
$
77,197.62
524
850.1300
Daphn
id
flow­
through
$
31,730.77
173
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
46
P­
01­
420
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
47
P­
01­
423
870.3465
Rats*
inhalation
$
340,553.22
2458
$
340,553.22
2458
48
P­
01­
432
870.5395
Mice
gavage
(
avg
of
1
and
3
day
doses)*
$
14,687.50
114
$
1,508,923.02
14575
OECD
407
Rats
gavage
$
43,750.00
328
No.
PMN
Guideline
Species
Route/
Method
Cost
($
2002)
Hours
Total
Cost
($
2002)
Total
Hours
D­
13
870.3100
Rats
gavage
$
121,128.45
834
870.3800
Rats
gavage*
$
529,717.65
5024
870.4200
Rats*
gavage*
$
799,639.42
8275
49
P­
01­
433
870.3465
Rats*
inhalation
$
340,553.22
2458
$
374,157.49
2637
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
50
P­
01­
441
(
low
estimate)
64
FR
60194
­
PBT
T
ier
1
$
60,577.38
275.5
$
94,181.66
454.5
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
50
P­
01­
441
(
high
estimate)
64
FR
60194
­
PBT
T
ier
1
$
60,577.38
275.5
$
497,170.68
4564.5
64
FR
60194
­
PBT
Tiers
2
and
3
$
402,989.02
4110
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
51
P­
01­
459
870.3465
Rats*
inhalation
$
340,553.22
2458
$
340,553.22
2458
52
P­
01­
460
870.3465
Rats*
inhalation
$
340,553.22
2458
$
340,553.22
2458
53
P­
00­
992
and
P­
01­
471
850.1400
Fathead
Minnow*
flow­
through
$
34,483.17
291
$
77,197.62
524
850.1300
Daphn
id
flow­
through
$
31,730.77
173
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
54
P­
01­
481
N/
A
[
No
tests
listed
in
SNUR]
N/
A
N/
A
$
0.00
0
55
P­
01­
561
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
56
P­
01­
573
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
$
33,604.28
179
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
No.
PMN
Guideline
Species
Route/
Method
Cost
($
2002)
Hours
Total
Cost
($
2002)
Total
Hours
D­
14
57
P­
01­
578
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
$
30,216.70
197
850.1010
Daphn
id
static
$
8,834.23
53
850.1075
­
static
$
10,398.79
84
58
P­
01­
646
850.1075
­
static
$
10,398.79
84
$
30,216.70
197
850.1010
Daphn
id
static
$
8,834.23
53
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
59
P­
01­
716
(
low
estimate)
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
$
256,213.72
1803.5
850.1400
Rainbow
Trout
flow­
through*
$
52,560.10
432
850.1300
Daphn
id
flow­
through*
$
31,730.77
173
850.1730
Fathead
Minnow*
flow
through*
$
58,716.50
775
835.3170
­
­
$
41,645.29
88
64
FR
60194
PBT
T
ier
1
$
60,577.38
275.5
59
P­
01­
716
(
high
estimate)
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
$
474,550.09
4445.5
850.1400
Rainbow
Trout
flow­
through*
$
52,560.10
432
850.1300
Daphn
id
flow­
through*
$
31,730.77
173
850.1730
Fathead
Minnow*
flow
through*
$
58,716.50
775
835.3170
­
­
$
41,645.29
88
64
FR
60194
­
PBT
T
ier
1
$
60,577.38
275.5
64
FR
60194
­
PBT
Tiers
2
and
3
(
b)
$
218,336.37
2642
(
b)
Excluding
OPPT
S
850.1400,
850.13
00,
850.1730,
and
835
.3170
to
avoid
doublecounting
60
P­
01­
781
870.4300
Rats*
gavage*
$
972,884.62
9701
$
1,347,042.11
12338
870.3465
Rats*
inhalation
$
340,553.22
2458
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
61
P­
01­
833
870.3465
Rats*
inhalation
$
340,553.22
2458
$
340,553.22
2458
62
P­
02­
17
870.3700
Rats*
gavage*
$
98,594.95
1157
$
98,594.95
1157
63
P­
02­
90
870.3465
Rats*
inhalation
$
340,553.22
2458
$
340,553.22
2458
64
P­
02­
207
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
$
33,604.28
179
No.
PMN
Guideline
Species
Route/
Method
Cost
($
2002)
Hours
Total
Cost
($
2002)
Total
Hours
D­
15
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
65
P­
02­
262
870.3465
Rats
inhalation
$
340,553.22
2458
$
374,157.49
2637
850.1075
Fathead
Minnow*
flow­
through*
$
13,624.62
65
850.1010
Daphn
id
flow­
through*
$
8,995.98
54
850.5400
Average
of
four
spec
ies*
­
$
10,983.68
60
*
default
assumptions
used
in
cases
where
species
and/
or
route/
method
not
specified
in
SNUR
APPENDIX
E
COSTS
OF
SUBMITTING
A
SNUN,
REQUEST
FOR
MODIFICATION
OR
REVOCATION
OF
A
SNUR,
OR
EQUIVALENCY
DETERMINATION
8In
the
economic
analysis
for
an
earlier
SNUR
(
EPAB
1999),
EPA
estimated
SNUN
submission
costs
(
before
user
fee)
at
$
6005
to
$
7240
(
95
to
114
hours),
compared
with
$
4456
for
105
hours
here.
This
is
not
meant
to
suggest
that
actual
costs
declined.
Rather,
the
apparent
decline
is
due
to
a
revised
method
for
calculating
labor
rates.
The
method
was
revised
to
use
more
current
data
and
to
be
consistent
with
recent
EPAB
economic
analyses.
See
Appendix
B
for
details.

E­
1
APPENDIX
E
COSTS
OF
SUBMITTING
A
SNUN,
REQUEST
FOR
MODIFICATION
OR
REVOCATION
OF
A
SNUR,
OR
EQUIVALENCY
DETERMINATION
Estimates
of
the
costs
of
completing
a
SNUN
form
are
based
on
the
costs
of
completing
a
PMN
submission,
since
the
data
requirements
and
the
submission
form
are
essentially
identical.
EPA

s
Regulatory
Impact
Analysis
(
RIA)
for
amendments
to
the
PMN
regulations
(
RIB
1994)
relied
on
industry
estimates
of
the
effort
needed
to
collect
and
compile
all
data
required
for
a
PMN
submission,
prepare
the
form,
and
submit
the
form
and
data
to
EPA
(
RIB
1994).
These
estimates,
based
on
a
survey
conducted
by
the
Chemical
Manufacturers
Association
(
CMA
1991),
indicate
that
the
average
effort
required
to
prepare
and
submit
a
PMN
is
95
to
114
hours.
For
this
analysis,
the
costs
of
a
preparing
a
SNUN
were
derived
using
the
2002
loaded
wage
rates
and
average
of
the
hours
for
clerical,
technical,
and
managerial
labor.
Wage
rate
derivations
are
discussed
in
Appendix
B.
As
shown
in
Table
E­
1,
the
resulting
cost
of
submitting
a
request
to
modify
or
revoke
a
SNUR
is
$
4,456,
the
cost
of
submitting
a
SNUN
is
$
6,956,
including
a
$
2500
user
fee,
and
the
cost
for
an
equivalency
determination
is
$
4,456.8
Table
E­
1
Industry
Costs
for
SNUN,
Request
to
Modify/
Revoke
SNUR,
or
Equivalency
Determination
Labor
Category
Hours
Range*
Averag
e
Hours
Loaded
Wage
Rate**
(
2002
dollars)
Total
Labor
Cost
(
loaded
wage
×
hours)

Request
to
Modify
SNUR
(
Option
2)
SNUN
(
Option
3)
Equivalency
Determination
(
Option
4)

Clerical
12
­
14
13.0
$
23.96
$
311
$
311
$
311
Technical
67­
80
73.5
$
43.34
$
3,185
$
3,185
$
3,185
Manageri
al
16
­
20
18.0
$
53.29
$
959
$
959
$
959
Subtotal
95
­
114
104.5
$
4,456
$
4,456
$
4,456
User
fees
(
SNUN
only)
$
0
$
2,500
TOTAL
$
4,456
$
6,956
$
4,456
Figures
may
not
add
due
to
rounding.
*
Hours
range
for
each
labor
category
are
from
the
PMN
Amendments
RIA
(
RIB
1994)
**
Loaded
wages
include
fringe
benefits
and
overhead.
See
Appendix
B
for
derivation.
APPENDIX
F
AGENCY
COSTS
F­
1
APPENDIX
F
AGENCY
COSTS
EPA

s
costs
to
review
and
process
industry
submissions
(
SNUNs,
requests
to
modify
SNUR,
and
requests
for
equivalency
determination)
are
assumed
to
be
the
same
as
EPA
costs
to
review
PMNs.
EPA

s
costs
associated
with
SNUR
submissions
are
presented
in
Table
F­
1.
The
EPA
staff
level
(
GS­
12),
staff­
year
full­
time
equivalents
(
FTEs)
and
extramural
costs
such
as
costs
for
contractor
support
are
derived
from
the
costs
estimated
for
processing
PMN
submissions
(
RIB
1994).
The
percent
of
cases
are
from
RIB
1994
and
from
an
1999
SNUR
economic
analysis
(
EPAB
1999).
FTE
costs
have
been
calculated
using
2002
GS­
12
salary
data
(
OPM
2002)
and
a
loading
factor
of
1.6
to
reflect
fringe
benefits
and
overhead
(
OPPE
1992).

The
original
PMN
cost
estimates
were
presented
as
low
and
high
estimates,
based
on
the
most
junior
(
Step
1)
and
the
most
senior
(
Step
10)
GS­
12
pay
rates,
respectively.
For
simplicity,
this
analysis
uses
the
average
of
the
two
pay
rates.

The
GS­
12
costs
in
the
table
below
are
calculated
by
multiplying
the
number
of
FTEs
(
in
the
first
column)
by
the
fully
loaded
average
salary,
$
102,475.
This
shows
EPA
staff
cost
for
those
chemicals
requiring
this
review
step.
The
Extramural
Cost
column
shows
costs
for
contractor
support
and
other
outside
purchases
for
those
chemicals
requiring
this
review
step,
inflated
from
1993
prices
to
2002
using
the
Employment
Cost
Index,
Total
Compensation
for
White­
Collar
Occupations
(
BLS
2003a).
The
Weighted
Cost
column
is
calculated
by
multiplying
GS­
12
staff
cost
plus
extramural
costs
(
Unweighted
Cost)
by
the
percentage
of
cases
requiring
this
review
step.
This
calculation
yields
total
Agency
costs
for
submission
review
and
processing
of
$
4,034
per
case.
F­
2
Table
F­
1
Agency
Costs
for
SNUN
and
Other
Submission
Review
and
Processing
Review
Step
EPA
FTE
EPA
staff
(
GS­
12)
(
a)
Extra­
mural
Cost
Unweighted
Cost
Pct.
of
Cases
Weighted
Cost
1993
dollar
s
2002
dollars
(
b)

(
1)
(
2)
(
3)
(
4)
(
5)=(
2)+(
4)
(
6)
(
7)=(
5)*(
6)

Prenotice
consultation
0.0024
$
245.94
4
$
5.52
$
251.46
41%
$
103.10
Administrative
prescreen/
notice
receipt/
user
fee
0.0024
$
245.94
92
$
126.96
$
372.90
100%
$
372.90
CRSS
(
Chemical
Review
and
Search
Strategy)
0.0025
$
256.19
268
$
369.84
$
626.03
100%
$
626.03
SAT
(
Structure
Activity
Team)
0.0006
$
61.49
14
$
19.32
$
80.81
100%
$
80.81
Engineering/
Exposure
0.0015
$
153.71
56
$
77.28
$
230.99
100%
$
230.99
Exposure/
Fate
0.0008
$
81.98
0
$
0.00
$
81.98
100%
$
81.98
Focus
0.0009
$
92.23
23
$
31.74
$
123.97
100%
$
123.97
Standard
Review
Functions
0.0219
$
2,244.21
511
$
705.18
$
2,949.39
29%
$
855.32
Division
Directors
Meeting
0.0129
$
1,321.93
113
$
155.94
$
1,477.87
15%
$
221.68
Order
Development/
Negotiation
Review
0.0171
$
1,752.33
22
$
30.36
$
1,782.69
3%
$
53.48
Post
Order
Data
Review
0.0886
$
9,079.30
0
$
0.00
$
9,079.30
3%
$
272.38
Order
Modification
0.2167
$
22,206.38
0
$
0.00
$
22,206.38
3%
$
666.19
New
Chemical
SNUR
Development
0.0277
$
2,838.56
85
$
117.30
$
2,955.86
7%
$
206.91
Notices
of
Commencement
0.0012
$
122.97
40
$
55.20
$
178.17
31%
$
55.23
FOIA
(
Freedom
of
Information
Act)
Requests
0.0333
$
3,412.42
287
$
396.06
$
3,808.48
1%
$
38.08
CBI
(
Confidential
Business
Information)
Substantiation
0.0004
$
40.99
3
$
4.14
$
45.13
100%
$
45.13
TOTAL
$
4,034
Sources:
FTEs
per
review
step
and
1993
extramural
costs
are
from
RIB
1994.
Percents
of
cases
are
from
RIB
1994
and
EPAB
1999.
GS­
12
salaries
are
from
OPM
2002.

(
a)
The
average
of
GS­
12
Step
1
and
GS­
12
Step
10
salaries
for
2002
was
($
55,694
+
$
72,400)
/
2
=
$
64,047.
This
was
multiplied
by
an
assumed
loading
factor
of
1.6
to
reflect
fringe
benefits
and
overhead,
resulting
in
a
fully
loaded
cost
per
FTE
of
1.6
X
$
64,047
=
$
102.475.
F­
3
(
b)
Extramural
costs
consist
of
contracting
support
and
other
purchases
directly
attributable
to
the
PMN
review
process.
They
were
inflated
from
1993
prices
to
2002
prices
using
a
factor
of
approximately
1.38
(
see
Appendix
B).
APPENDIX
G
REFERENCES
G­
1
APPENDIX
G
REFERENCES
29
CFR
1910.
Occupational
Safety
and
Health
Standards.
Code
of
Federal
Regualtions,
Part
1910,
Title
29,
November
25,
1983.

Best
1997.
Personal
communication
between
Tom
DeCoff
of
Eastern
Research
Group,
Lexington,
MA
and
Best
Manufacturing
Co.
technical
support
services,
Austin,
TX,
December
1997.

BLS
2003a.
Bureau
of
Labor
Statistics.
Employment
Cost
Index,
Total
Compensation:
White­
Collar
Occupations
(
Series
ID:
ECS11102I),
extracted
May
28,
2003.

BLS
2003b.
Bureau
of
Labor
Statistics.
Consumer
Price
Index­
All
Urban
Consumers,
U.
S.
City
Average
(
Series
ID:
CUUR0000SA0),
extracted
May
28,
2003.

BLS
2003c.
Bureau
of
Labor
Statistics.
National
Employment,
Hours,
and
Earnings,
Average
Hourly
Earnings
of
Production
Workers
(
Series
ID:
EEU32280006),
extracted
May
28,
2003.

BLS
2003d.
Bureau
of
Labor
Statistics.
Employer
Costs
for
Employee
Compensation
­
December
2002:
Private
industry,
goods­
producing
workers
by
occupational
group
(
Table
11),
March
18,
2003.

BT
Office
Products
1997.
BT
Office
Products
International.
Office
Products
Catalog,
1997.

CMA
1991.
Chemical
Manufacturers
Association.
Responses
to
Questions
on
Burden
Associated
with
PMN
Submissions.
Distributed
by
the
Chemical
Manufacturers
Association,
Washington,
DC.

EPAB
1998.
Economic
Analysis
of
Expedited
Significant
New
Use
Rules
for
168
Chemical
Substances
and
Background
Support
Document
for
Economic
Analysis
of
Significant
New
Use
Rules.
Washington,
DC:
U.
S.
EPA/
OPPT/
EETD/
EPAB,
January
1998.

EPAB
1999.
Economic
Analysis
of
Expedited
Significant
New
Use
Rules
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