­
1
­
Supporting
Statement
for
a
Request
for
OMB
Review
under
the
Paperwork
Reduction
Act
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
Title:
TSCA
Section
12(
b)
Notification
of
Chemical
Exports
EPA
ICR
No.
0795.10
OMB
Control
No.
2070­
0030
1(
b)
Short
Characterization
Section
12(
b)(
2)
of
the
Toxic
Substances
Control
Act,
Public
Law
94­
469,
15
U.
S.
C.
2611(
b)(
2)
states,
in
part,
that
any
person
who
exports
or
intends
to
export
to
a
foreign
country
a
chemical
substance
or
mixture
for
which
submission
of
data
is
required
under
section
4
or
5(
b),
or
for
which
a
rule,
action
or
order
has
been
proposed
or
promulgated
under
section
5,
6,
or
7,
shall
notify
the
EPA
Administrator
of
such
export
or
intent
to
export
(
see
Attachment
1).
The
Administrator
in
turn
will
notify
the
government
of
the
importing
country
of
EPA's
regulatory
action
with
respect
to
the
substance.

On
December
16,
1980,
EPA
promulgated
a
rule
that
provided
final
guidance
for
section
12(
b)
(
45
Fed.
Reg.
82844).
This
final
rule
requires
exporters
to
submit
an
annual
notice
for
each
country
to
which
a
chemical
subject
to
section
12(
b)
requirements
is
exported.
On
July
27,
1993
(
58
Fed.
Reg.
40238),
EPA
issued
a
final
rule,
which
amended
the
December
16,
1980
rule,
for
chemicals
subject
to
section
4
test
rules
by
requiring
exporters
to
submit
a
one­
time
notice
to
EPA
for
export
of
a
section
4
chemical
to
a
particular
country,
instead
of
annual
notification.
There
are
no
changes
in
reporting
requirements
for
sections
5,
6
and
7
of
TSCA.
These
rules
are
codified
at
40
CFR
Part
707,
Subpart
D
(
see
Attachment
2).

The
export
notice
must
include
five
easily
ascertainable
items:
the
name
and
address
of
the
exporter,
the
name
of
the
chemical,
the
country
of
import,
the
date
of
export
or
intended
export,
and
the
section
of
TSCA
under
which
EPA
has
taken
action
(
4,
5,
6
or
7).
There
are
currently
over
1,000
substances
or
categories
of
substances
that
have
been
regulated
or
proposed
to
be
regulated
under
the
applicable
sections
of
TSCA.
RECEIVED
OPPT
NCIC
2003
July
25
11:
04AM
OPPT­
2003­
0039­
0002
­
2
­
1(
c)
Potential
Future
EPA
Actions
Affecting
this
Information
Collection
The
purpose
of
this
section
is
to
identify
EPA
actions
that
are
anticipated
to
occur
during
the
collection
period
that
could
affect
the
information
requirements
and
burden.
The
Agency
will
follow
appropriate
procedures
for
modifying
the
ICR
for
section
12(
b)
to
account
for
the
impacts
of
these
actions
at
such
time
they
actually
occur.

On
October
9,
1998,
EPA
announced
the
High
Production
Volume
Chemical
(
HPV)
Challenge
Program.
The
HPV
Program
is
a
key
element
of
the
Chemical
Right­
to­
Know
(
Chem­
RTK)
initiative
announced
by
Vice
President
Gore
and
EPA
Administrator
Browner
on
the
eve
of
Earth
Day
1998.
The
Chem­
RTK
initiative
challenges
government,
industry
and
the
environmental
community
to
develop
aggressive
strategies
that
will
rapidly
fill
the
gaps
in
our
understanding
about
the
potential
health
and
environmental
effects
associated
with
chemicals
used
widely
in
our
communities
and
make
this
information
easily
accessible
to
the
public.

The
HPV
Challenge
Program
is
a
major
new
voluntary
chemical
testing
effort
created
to
ensure
that
a
complete
set
of
baseline
health
and
environmental
effects
screening
data
on
thousands
of
HPV
industrial
chemicals
is
made
available
to
the
public.
EPA
in
partnership
with
industry
and
environmental
groups
have
outlined
an
approach
for
compiling
the
basic
information
for
2,800
HPV
chemicals.
HPV
chemicals
are
defined
as
those
that
are
manufactured
in,
or
imported
into,
the
United
States
in
amounts
exceeding
1
million
pounds
per
year.

For
those
chemicals
not
selected
by
companies
for
voluntary
testing,
EPA
will
promulgate
test
rules,
using
the
testing
authorities
contained
in
section
4
of
TSCA.
At
the
time
of
the
writing
of
this
ICR,
EPA
is
developing
options
for
a
proposed
rulemaking
expected
to
be
published
during
the
fourth
quarter
of
FY
1999.
This
includes
determining
which
chemicals
and
the
number
of
chemicals
potentially
affected
by
these
rulemaking
requirements.
The
chemicals
included
in
the
final
rulemaking
will
be
subject
to
section
12(
b)
export
notification
requirements.
EPA
anticipates
that
this
will
result
in
an
increase
of
the
information
collection
burden
for
section
12(
b).
The
calculation
for
the
increased
burden
will
likely
be
a
straightforward
multiplication
of
number
of
chemicals
not
currently
subject
to
section
12(
b)
requirements
by
the
average
number
of
hours
and
associated
cost.

The
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
has
been
working
with
industry
representatives
exploring
opportunities
for
electronic
submission
of
data
to
the
Agency.
One
pilot
includes
electronic
submission
of
section
12(
b)
export
notifications.
OPPT
has
recently
developed
a
new
database
for
accepting
electronic
submissions
under
section
12(
b).
The
new
database
incorporates
new
web
and
public
key
infrastructure
(
PKI)
technology
that
will
allow
for
submissions
via
the
Internet.
The
new
database
is
currently
undergoing
beta
testing
and
EPA
anticipates
it
will
be
available
for
implementation
later
this
calendar
year.
OPPT
hopes
to
announce
the
details
regarding
its
ability
to
accept
electronic
section
12(
b)
submissions
in
a
subsequent
Federal
Register
Notice
sometime
later
in
FY
1999.
EPA
expects
electronic
submission
will
result
in
an
overall
reduction
of
the
information
collection
burden
for
­
3
­
section
12(
b)
export
notification.
2
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
TSCA
section
12(
b)(
2)
requires
exporters
to
submit
a
notice
for
each
country
to
which
a
chemical
subject
to
section
12(
b)
requirements
is
exported.

2(
b)
Use/
Users
of
The
Data
Information
collected
under
section
12(
b)
will
be
used
by
the
Administrator
to
furnish
notice
of
EPA
action
on
the
exported
chemical
to
the
government
of
the
importing
country.

3
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
The
exporter
submits
one
notice
to
EPA.
There
is
no
duplication
except
for
some
similar
data
submitted
to
the
Bureau
of
the
Census.

Prior
to
promulgating
the
section
12
(
b)
rule,
EPA
considered
the
possibility
of
using
data
already
generated
under
the
Bureau
of
the
Census
requirements
in
lieu
of
a
section
12(
b)
rule.
However,
several
problems
with
the
Census
data
make
this
approach
impractical.
These
problems
include,
among
others,
the
fact
that
Census
data
are
often
not
chemical­
specific;
Census
exempts
certain
shipments
and
exporters
that
are
not
exempt
from
section
12(
b);
and
Census
data
would
not
be
available
for
up
to
eight
weeks
following
export,
a
delay
that
would
prevent
EPA
from
providing
foreign
governments
the
timely
notice
required
by
section
12(
b).

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
proposing
to
renew
this
ICR,
EPA
provided
a
60­
day
public
notice
and
comment
period
that
ended
on
March
15,
1999
(
64
FR
2486,
January
14,
1999).
EPA
received
comments
during
the
comment
period,
which
are
addressed
in
a
memorandum
accompanying
this
ICR.

3(
c)
Consultations
Prior
to
proposing
guidance
for
the
submission
of
section
12(
b)
notices,
EPA
held
informal
meetings
with
the
Manufacturing
Chemists
Association
(
now
Chemical
Manufacturers
Association),
and
with
representatives
of
the
Swedish,
Canadian
and
British
governments.
Twelve
comments
were
received
from
exporters,
environmental
groups
and
foreign
governments
during
the
public
comment
­
4
­
period
for
the
proposal.
We
also
met
with
members
of
the
Chemical
Manufacturers
Association
to
discuss
section
12(
b)
requirements
and
the
possible
need
for
some
changes
to
the
rule.

3(
d)
Effects
of
Less
Frequent
Collection
If
the
collection
of
information
was
conducted
less
frequently,
the
regulatory
requirements
would
not
be
met.

3(
e)
General
Guidelines
This
information
collection
is
necessary
to
implement
statutory
requirements
of
section
12(
b)
of
TSCA
and
is
consistent
with
the
requirements
of
5
CFR
1320.6.

3(
f)
Confidentiality
The
respondent
may
claim
all
or
part
of
a
notice
confidential.
EPA
will
disclose
information
that
is
covered
by
a
claim
of
confidentiality
only
to
the
extent
permitted
by,
and
in
accordance
with,
the
procedures
in
TSCA
and
40
CFR
Part
2.
However,
notwithstanding
any
claim
of
confidentiality,
the
foreign
government
of
the
importing
country
will
be
notified
of
the
export
of
the
substance(
s)
in
question.

3(
g)
Sensitive
Questions
This
section
is
not
applicable.
The
information
requested
is
not
sensitive
in
nature.

4
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
4(
a)
Agency
Activities
The
activities
routinely
conducted
by
EPA
related
to
the
receipt
and
processing
of
section
12(
b)
export
notices
include
the
following:

o
review­
export
notices
for
compliance;

o
respond
to
follow­
up
inquiries
from
foreign
governments;

o
consult
with
companies
on
complying
with
section
12(
b)
rule;
­
5
­
o
act
as
liaison
between
foreign
governments
and
companies
to
seek
additional
information
on
exports;

o
log
in
notices
for
tracking/
reporting;

o
prepare
letters
with
supporting
documents
to
foreign
governments.

4(
b)
Collection
Methodology
and
Management
With
the
exception
of
section
4
chemicals,
an
exporter
must
submit,
on
an
annual
basis,
one
section
12(
b)
notice
for
each
country
to
which
a
chemical
subject
to
section
12(
b)
is
exported.
The
notice
must
be
postmarked
within
seven
days
after
accepting
a
definite
contractual
obligation
or
no
later
than
the
date
of
export.
If
the
collection
of
information
was
conducted
less
frequently,
the
regulatory
requirements
would
not
be
met.

EPA
has
not
been
able
to
identify
a
more
efficient,
less
expensive
or
more
flexible
means
of
obtaining
the
required
data.
There
is
no
new
technology
applicable
to
the
collection
of
this
information
that
would
minimize
the
collection
burden.

4(
c)
Small
Entity
Flexibility
TSCA
section
12(
b)
does
not
exempt
small
businesses.
However,
most
reporting
has
been
by
large
companies.
The
burden
on
any
exporter
should
be
minimal;
it
should
take
no
more
than
one­
half
hour
to
prepare
a
section
12(
b)
notice.

4(
d)
Collection
Schedule
On
an
annual
basis,
excluding
section
4
chemicals,
an
exporter
must
submit
only
one
section
12(
b)
notice
for
each
country
to
which
a
chemical
subject
to
section
12(
b)
is
exported.
The
notice
must
be
postmarked
within
seven
days
after
accepting
a
definite
contractual
obligation
to
export
or
no
later
than
the
date
of
export.
If
the
collection
of
information
was
conducted
less
frequently,
the
regulatory
requirements
would
not
be
met.

5
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
5(
a)
Respondents/
SIC
Codes
Chemical
exporters/
SIC
Codes
28
and
29,
and
Wholesalers/
SIC
Code
51.

5(
b)
Information
Requested
­
6
­
(
i)
Data
Items
Respondents
are
required
to
report:
(
1)
the
name
and
address
of
the
exporter;
(
2)
the
name
of
the
chemical;
(
3)
the
country
of
import;
(
4)
the
date
of
export
or
intended
export;
(
5)
and
the
TSCA
section
4,
5,
6
or
7
action
that
triggers
the
notice.
(
ii)
Respondent
Activities
o
Compile
list
of
products
exported
by
the
company;

o
Check
list
against
outgoing
orders
to
determine
if
product/
chemical
is
on
the
list;

o
If
product/
chemical
is
on
the
list,
complete
an
export
notice
and
forward
to
EPA.

6
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
The
purpose
of
this
analysis
is
to
determine
the
incremental
cost
to
industry
and
to
the
EPA
associated
with
export
reports
that
are
submitted
to
the
Agency
under
the
TSCA
section
12(
b)
reporting
requirements.

6(
a)
Estimating
the
Respondent
Burden
The
burden
to
respondents
of
this
information
collection
activity
comprises
the
time
required
to
perform
the
steps
outlined
in
section
3
of
this
document.

Most
companies
comply
by
compiling
a
list
of
products
exported
by
the
company
that
are
subject
to
section
12(
b)
reporting.
Each
outgoing
order
is
checked
to
see
if
the
chemical
or
product
is
on
the
list
and,
depending
on
the
chemical,
whether
it
is
the
first
shipment
to
the
importing
country
or
the
first
shipment
of
the
calendar
year
to
that
country.
If
so,
a
completed
form
letter
is
sent
to
EPA.
In
most
cases
the
entire
process
is
computerized.

Compile
List.
Since
this
information
collection
activity
has
been
in
place
for
eighteen
years,
most
respondents
will
have
already
developed
a
list
of
their
products
subject
to
section
12(
b)
reporting.
Respondents
need
only
check
for
new
regulations
promulgated
and
any
new
products
exported
by
the
company.
Conversations
with
several
chemical
companies
suggest
that
small
companies
with
few
products
spend
a
minimal
amount
of
time
rechecking
regulations,
while
large
companies
with
many
products
may
expend
a
substantial
amount.
Based
on
past
experience,
approximately
350
companies
can
be
expected
to
report
under
section
12(
b).
Updating
the
list
is
estimated
to
take
from
two
hours
per
year
up
to
two
hours
per
month
of
technical
time
(
which
may
also
include
some
proportion
of
legal
time).
This
will
vary
depending
on
the
number
of
products
exported
by
the
company
and
the
number
of
their
products
subject
to
section
12(
b),
but
we
estimate
that
approximately
50
companies
are
near
the
upper
estimate
of
24
hours
per
year
and
300
companies
are
near
the
lower
estimate
of
2
hours
per
year.
Compiling
the
list
for
all
­
7
­
respondents
is
estimated
to
take
1800
hours
(
2
hours
x
300
firms
plus
24
hours
x
50
firms),
or
an
average
of
about
5.14
hours
per
firm.
About
100
of
those
companies
are
filing
notices
under
TSCA
section
12(
b)
for
the
first
time
and
thus
could
be
incurring
higher
costs
for
this
task.

Write
Letter.
Companies
that
export
chemicals
subject
to
section
12(
b)
reporting
must
prepare
an
export
notice
to
send
to
EPA.
Time
for
initial
preparation
of
the
export
notice
probably
varies
depending
on
whether
the
company
has
prior
experience
with
this
program,
but
this
step
is
estimated
to
take
an
average
of
one
hour
of
technical
time
(
which
may
also
include
some
proportion
of
legal
time)
per
year
for
each
company
subject
to
section
12(
b)
reporting.
Many
of
the
notifications
received
by
EPA
are
for
repeat
submissions
from
a
company.
Most
of
the
repeat
submissions
received
by
the
Agency
are
computer
generated
form
letters
and
it
is
assumed
that
no
additional
time
is
required
to
prepare
letters
for
repeat
submissions.
Thus
we
estimate
a
total
of
350
hours
(
1
hour
x
350
firms
=
350
hours)
per
year
in
letter
writing
or
revising.

Checking
Orders
and
Send
Notices.
The
350
companies
that
export
chemicals
subject
to
section
12(
b)
reporting
must
check
outgoing
shipments
against
the
list
of
their
products
described
above.
Where
the
shipment
is
for
a
section
12(
b)
chemical
and,
depending
on
the
chemical,
if
it
is
the
first
shipment
to
the
importing
country
or
the
first
shipment
of
the
calendar
year
to
that
country,
a
form
letter
notifying
EPA
is
printed
out.
Conversations
with
several
companies
indicate
that
roughly
half
of
the
export
shipments
checked
contain
section
12(
b)
chemicals,
and
notices
are
required
for
about
half
the
shipments
containing
those
chemicals.
Thus
for
every
notice
sent
there
are
approximately
three
shipments
checked
with
no
notice
required.
This
whole
process
is
estimated
to
take
on
average
one
half
hour
of
clerical
time
per
notice
sent
and
an
additional
five
minutes
for
each
shipment
checked
where
no
notice
is
sent,
for
a
total
of
45
minutes
per
notice
sent,
on
average.
The
previous
ICR
renewal
had
estimated
that
8,600
section
12(
b)
notices
would
be
received
by
the
Agency
in
1986.
The
Agency
actually
received
about
10,000
notices
in
1987.
Based
on
that
past
experience,
an
estimated
11,000
notices
will
be
sent.
Total
time
will
be
8,250
hours
(
11,000
notices
x
3/
4
hour
each).

TABLE
1:
ANNUAL
AVERAGE
BURDEN
PER
RESPONDENT
FACILITY
BURDEN
HOURS
ACTIVITY
TECHNICAL
CLERICAL
TOTAL
Compile
list
5.14
­
5.14
Write
letter
1
­
1.00
Check
order
and
send
notice
­
23.57
23.57
Total
6.14
23.57
29.71
­
8
­
TABLE
2:
ANNUAL
AGGREGATE
BURDEN
BURDEN
HOURS
ACTIVITY
TECHNICAL
CLERICAL
TOTAL
Compile
list
1,800
­
1,800
Write
letter
350
­
350
Check
order
and
send
notice
­
8,250
8,250
Total
2,150
8,250
10,400
Average
burden
hours
per
notice
0.195
0.75
.945
It
is
estimated
that
the
annual
number
of
notices
to
be
submitted
for
1999
to
2001
will
be
11,000.
Estimating
that
the
number
of
respondents
will
be
350
(
a
75%
increase
over
1995),
the
average
number
of
notices
submitted
per
respondent
will
be
31.43
6(
b)
Estimating
the
Respondent
Cost
The
costs
to
respondents
is
based
on
the
time
needed
to
complete
the
tasks
listed
in
section
3,
the
hourly
cost
of
labor
at
appropriate
levels
(
labor
rates),
the
number
of
facilities
affected,
and
the
number
of
reports
generated.
There
are
also
costs
for
mailing.
There
are
no
specific
capital
or
overhead
costs
associated
directly
with
this
information
collection
activity.

Labor
rates,
including
fringe
costs,
are
$
86.86
for
management
time,
$
64.30
for
technical
time,
and
$
25.63
for
clerical
time,
based
on
current
labor
market
estimates
produced
in
this
office.

Companies
will
also
incur
a
cost
of
$
7.58
per
export
notice
to
send
the
letter
to
EPA
via
registered
mail
($
6.00
for
registered
mail,
$
1.25
for
a
return
receipt,
and
$
0.33
postage).
Aggregate
annual
costs
for
mailing
will
be
$
83,380
($
7.58
x
11,000).
­
9
­
TABLE
3:
ANNUAL
COST
PER
RESPONDENT
FACILITY
ANNUAL
COST
ACTIVITY
TECHNICAL
$
64.30/
hr
CLERICAL
$
25.63/
hr
TOTAL
Compile
list
$
331
$
331
Write
letter
$
64
$
64
Check
order
and
send
notice
$
604
$
604
Mailing
cost
$
238
$
238
Total
$
633
$
604
$
1,237
TABLE
4:
ANNUAL
AGGREGATE
RESPONDENT
COST
ANNUAL
COST
ACTIVITY
TECHNICAL
$
64.30/
hr
CLERICAL
$
25.63/
hr
TOTAL
PRESENT
VALUE*

Compile
list
$
115,740
$
115,740
$
324,998
Write
letter
$
22,505
$
22,505
$
63,194
Check
order
and
send
notice
$
211,447
$
211,447
$
593,743
Mailing
cost
$
83,380
$
234,131
Total
$
138,245
$
211,447
$
433,072
$
1,216,066
*
Present
value
for
3
years
at
a
7%
discount
rate.

6(
c)
Federal
Government
Burden
and
Cost
Agency
unit
costs
are
based
on
past
section
12(
b)
analyses,
including
the
previous
ICR,
and
on
recent
contacts
with
the
Environmental
Assistance
Division
(
EAD)
and
with
an
EPA
contractor's
office.
EPA's
cost
estimates
are
based
on
current
experience
with
these
activities.
The
Agency
cost
can
be
divided
into
three
parts:
receiving
and
processing
incoming
notices,
preparing
and
mailing
notifications
to
importing
countries,
and
responding
to
requests
for
information
and
clarification
from
companies
and
importing
countries.
The
allocation
of
burden
hours
and
costs
among
these
three
parts
is
not
exact,
but
the
­
10
­
analysis
below
is
reasonably
accurate
in
terms
of
the
overall
burden
estimate
and
the
approximate
allocation
of
that
burden
among
these
tasks.

In
the
first
task,
notices
are
received
from
firms
that
intend
to
export
a
product
covered
by
this
rule,
the
forms
are
checked
for
completeness,
and
the
submissions
are
logged
into
a
document
control
system.
In
1997
EPA
received
and
processed
approximately
10,000
submissions.
Based
on
conversations
with
the
workers
responsible
for
this
task,
about
ten
submissions
can
be
processed
per
hour.
We
project
that
an
average
of
11,000
submissions
will
be
received
per
year
over
the
period
covered
by
this
ICR,
requiring
approximately
1,100
hours
of
contractor
support.
This
work
is
currently
done
by
contractor
staff
with
a
fully­
loaded
cost
to
EPA
of
approximately
$
20.00
per
hour
and
thus
is
projected
to
cost
$
22,000
per
year
over
the
period
of
this
ICR.

In
the
second
task,
workers
prepare
letters
of
notification
that
are
subsequently
reviewed
and
sent
to
importing
countries.
Not
all
notices
submitted
require
that
a
notification
be
sent.
Based
on
conversations
with
EPA
and
contractor
employees,
this
work
varies
considerably
depending
on
the
circumstances
of
any
particular
chemical,
but
averages
approximately
35
minutes
per
notification.
The
previous
ICR
estimated
2,266
notifications
to
importing
countries
per
year
but
the
recent
experience
has
been
approximately
1,700
per
year.
Assuming
a
10%
increase
in
these
notifications,
similar
to
the
projected
increase
in
submissions
from
companies,
total
notifications
would
project
to
1,870
per
year
or
a
total
of
approximately
1,090
hours.
This
work
is
currently
done
by
contractor
staff
with
a
fully­
loaded
cost
to
EPA
of
approximately
$
20.00
per
hour
and
thus
is
projected
to
cost
$
21,800
per
year
over
the
period
of
this
ICR.
The
cost
of
mailing
a
notifications
can
vary
from
$
2.00
to
$
12.00,
depending
on
whether
it
is
sent
to
an
embassy
in
the
US
or
to
an
overseas
destination,
and
depending
on
whether
the
notice
is
registered.
Based
on
current
experience,
mailing
costs
are
estimated
to
average
approximately
$
4.50
per
notification,
for
a
projected
annual
cost
of
$
8,415.

The
burden
described
above
covers
the
routine
tasks
of
handing
both
incoming
notices
and
outgoing
notifications.
The
totals
above
also
include
a
certain
amount
of
time
spent
responding
to
routine
requests
for
information,
since
data
are
not
available
to
separate
this
from
the
other
tasks.
Based
on
conversations
with
EAD
staff,
the
work
of
responding
to
non­
routine
requests
for
information
and
clarification
from
industry
and
importing
countries,
assisting
the
contractor
staff
in
handling
non­
routine
issues,
and
handling
other
tasks
associated
with
the
section
12(
b)
program
can
be
expected
to
require
about
20%
of
the
time
of
a
GS­
13
EPA
employee,
or
roughly
400
hours
per
year.
Following
the
1998
federal
employee
wage
scale,
and
assuming
an
additional
60%
to
cover
fringe
benefits
etc.,
that
represents
an
annual
cost
of
approximately
$
20,000.
­
11
­
TABLE
5:
ESTIMATED
COSTS
FOR
THE
FEDERAL
GOVERNMENT
ACTIVITY
ANNUAL
COST
PRESENT
VALUE
*

Processing
of
notices
from
companies
$
22,000
$
64,096
Processing
of
notifications
to
importing
countries
$
21,800
$
63,513
EPA
staff
time,
responding
to
information
requests,
etc.
$
20,000
$
58,269
Mailing
cost
of
notifications
$
8,415
$
24,517
Total
$
72,215
$
210,396
*
Present
value
calculated
for
3
years
at
a
3%
discount
rate.

6(
d)
Reasons
for
Change
in
Burden
This
analysis
shows
about
a
50%
increase
in
the
number
of
notices
sent
to
EPA,
a
75%
increase
in
the
number
of
firms
sending
notices,
and
about
a
30%
increase
in
labor
wage
rates
in
comparison
to
the
estimates
for
the
previous
ICR
renewal.
In
response
to
comments
and
based
on
interviews
with
several
firms,
the
Agency
has
increased
the
estimated
burden
hours
allocated
to
compiling
a
list
of
products
containing
section
12(
b)
regulated
chemicals,
from
an
average
of
one
hour
per
firm
per
year
to
an
average
of
slightly
over
five
hours
per
firm
per
year.
The
Agency
has
also
added
an
average
of
about
8
burden
hours
per
firm
per
year
for
checking
shipments
that
do
not
ultimately
result
in
12(
b)
notices,
an
aspect
of
burden
that
had
not
been
included
in
the
previous
ICR
renewal.
These
factors
in
combination
result
in
about
a
175%
increase
in
projected
burden
hours
(
from
3,800
to
10,400
hours
annually)
and
a
287%
increase
in
estimated
burden
cost
to
responding
firms
(
from
$
112,000
to
$
433,000
annually).
The
change
in
the
number
of
notices
received
and
the
number
of
companies
submitting
notices
is
based
on
data
and
EPA's
experience
in
collecting
these
data
during
the
previous
ICR
period
of
April
1996­
1998.

6(
e)
Burden
Statement
The
annual
public
burden
for
this
collection
of
information,
which
is
approved
under
OMB
Control
No.
2070­
0030,
is
estimated
to
be
0.945
hours
per
response.
According
to
the
Paperwork
Reduction
Act,
"
burden"
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
federal
agency.
For
this
collection
it
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
­
12
­
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information
;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
number
for
this
information
collection
appears
above.
In
addition,
the
OMB
control
numbers
for
EPA's
regulation,
after
initial
display
in
the
final
rule,
are
listed
in
40
CFR
part
9.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
to
the
Director,
Regulatory
Information
Division,
U.
S.
Environmental
Protection
Agency
(
Mail
Code
2137),
401
M
Street,
S.
W.,
Washington,
D.
C.
20460.
Include
the
OMB
control
number
in
any
correspondence,
but
do
not
submit
the
requested
information
to
this
address.
The
requested
information
should
be
submitted
in
accordance
with
the
instructions
accompanying
the
form,
or
as
specified
in
the
corresponding
regulation.
ATTACHMENT
1
Toxic
Substances
Control
Act
Section
12(
b)
ATTACHMENT
2
40
CFR
707,
Subpart
D
