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
8(
a)
Preliminary
Assessment
Information
Rule
(
PAIR)

EPA
ICR
No.:
0586.10
OMB
Control
No.:
2070­
0054
1(
b)
Short
Characterization
On
June
22,
1982,
EPA
promulgated
the
generic
section
8(
a)
Preliminary
Assessment
Information
Rule
(
PAIR)
(
40
CFR
Part
712,
see
Attachment
C)
under
the
Toxic
Substances
Control
Act
(
TSCA)
(
15
U.
S.
C.
2607,
see
Attachment
A).
EPA
uses
PAIR
to
collect
information
to
identify,
assess
and
manage
human
health
and
environmental
risks
from
chemical
substances,
mixtures
and
categories.
PAIR
requires
chemical
manufacturers
and
importers
to
complete
a
standardized
reporting
form
to
help
evaluate
the
potential
for
adverse
human
health
and
environmental
effects
caused
by
the
manufacture
or
importation
of
identified
chemical
substances,
mixtures
or
categories.
Attachment
B
provides
a
specific
section­
by­
section
listing
of
each
of
the
requirements
under
Title
40
of
the
Code
of
Federal
Regulation
related
to
this
ICR.

Chemicals
identified
by
the
existing
chemical
review
program,
any
other
EPA
office
or
federal
agency,
for
which
a
justifiable
information
need
for
production,
use,
or
exposure­
related
data
can
be
satisfied
by
the
use
of
the
PAIR,
is
a
proper
subject
for
a
chemical­
specific
TSCA
section
8(
a)
PAIR
rulemaking.
Many
of
the
chemical
substances,
mixtures
and
categories
listed
in
40
CFR
Part
712
have
been
recommended
by
the
Interagency
Testing
Committee
(
ITC)
to
EPA
for
test
rule
consideration.
In
most
instances,
such
as
in
a
preliminary
risk
determination,
or
in
reaching
a
decision
whether
testing
of
a
chemical
is
necessary
to
satisfy
an
identified
data
need,
the
information
that
EPA
receives
from
a
PAIR
report
is
sufficient
to
satisfy
its
information
needs.

This
information
collection
activity
also
covers
certain
specific
chemical
testing
and
reporting
requirements
under
Subpart
B
of
40
CFR
part
766
(
see
Attachment
E)
that
are
very
similar
to
the
PAIR
requirements.
The
Agency
rarely
receives
submissions
of
the
information
required
by
40
CFR
766.
EPA
received
no
more
than
5
submissions
over
the
course
of
the
last
OMB
approval
for
this
particular
aspect
of
the
information
collection.
However,
collection
of
this
information
is
covered
under
the
PAIR
ICR
because
the
requirements
are
similar
and
because
the
Paperwork
Reduction
Act
requires
that
recordkeeping
and
reporting
activities
contained
in
any
regulation
be
approved
by
OMB
even
if
they
involve
less
than
10
respondents
or
would
otherwise
not
require
approval
(
see
5
CFR
1320.3(
c)(
4)(
i)).

The
Dibenzo­
para­
dioxin/
dibenzofuran
regulations
at
part
766
require
that
any
person
who
manufactures,
imports,
or
processes
a
chemical
substance
listed
in
§
766.25
test
that
chemical
­
2­
substance
and
submit
appropriate
information
to
EPA
according
to
the
schedules
described
in
§
766.35.
These
chemical
substances
are
subject
to
testing
immediately
upon
manufacture,
import
or
processing.
Persons
who
manufacture
or
import
a
chemical
substance
listed
under
§
766.25
must
report
results,
using
the
Dioxin/
Furan
Report
form
(
EPA
Form
7710­
51,
see
Attachment
F)
of
all
existing
test
data
that
show
that
chemical
substance
has
been
tested
for
the
presence
of
halogenated
dibenzodioxins/
halogenated
dibenzofurans
(
HDDs/
HDFs),
as
defined
in
the
regulation,
no
later
than
90
days
after
the
person
first
manufactures
or
imports
the
chemical
substance.
Additionally,
any
manufacturer
or
importer
of
a
chemical
substance
listed
in
§
766.25
in
possession
of
unpublished
health
and
safety
studies
on
HDDs/
HDFs
is
required
to
submit
copies
of
such
studies
to
EPA,
in
accordance
with
various
provisions
of
40
CFR
716,
no
later
than
90
days
after
the
person
first
manufactures
or
imports
the
chemical
substance.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
Under
TSCA,
which
covers
the
production,
distribution,
and
disposal
of
commercial
and
industrial
chemicals
in
the
United
States,
EPA's
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
is
charged
with
the
responsibility
for
assuring
that
chemicals
made
available
for
sale
and
use
in
the
United
States
do
not
pose
any
unreasonable
adverse
risks
to
human
health
or
to
the
environment.
To
carry
out
this
mandate,
EPA
has
broad
authority
to
issue
regulations
designed
to
gather
health/
safety
and
exposure
information
on,
require
testing
of,
and
control
exposure
to
chemical
substances
and
mixtures.
Drugs,
cosmetics,
foods,
food
additives,
pesticides,
and
nuclear
materials
are
exempt
from
TSCA
and
are
subject
to
control
under
other
U.
S.
Government
statutes
(
e.
g.,
foods,
food
additives,
drugs
and
cosmetics
are
under
the
purview
of
the
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA)).

TSCA
section
8(
a)
gives
EPA
the
authority
to
promulgate
rules
under
which
manufacturers
(
which
by
statute
includes
importers)
and
processors
of
chemical
substances
must
maintain
records
and/
or
report
such
data
as
EPA
may
reasonably
require
to
carry
out
the
TSCA
mandates.
Examples
of
information
that
can
be
required
to
be
reported
under
TSCA
Section
8(
a)
includes:

°
chemical
or
mixture
identity;
°
categories
of
use;
°
quantity
manufactured
or
processed;
°
by­
product
description;
°
health
and
environmental
effects
information;
°
number
of
individuals
exposed;
°
method(
s)
of
disposal.
­
3­
Section
8(
a)
regulations
can
be
tailored
to
meet
unique
information
needs
(
e.
g.,
via
chemical­
specific
rules,
which
are
covered
under
EPA
ICR
#
1198.06;
OMB
Control
#
2070­
0067)
or
information
can
be
obtained
via
the
use
of
"
model"
or
standardized
reporting
rules.
One
example
of
a
model
TSCA
Section
8(
a)
reporting
rule
is
the
"
Preliminary
Assessment
Information
Rule"
(
or
PAIR).
Under
PAIR,
producers
and
importers
of
a
listed
chemical
are
required
to
report
the
following
site­
specific
information
on
a
two
page
form
(
described
in
more
detail
in
Chapter
4
of
this
ICR):

°
quantity
of
chemical
produced
and/
or
imported;
°
amount
of
chemical
lost
to
the
environment
during
production
or
importation;
°
quantity
of
enclosed,
controlled
and
open
releases
of
the
chemical;
°
per
release,
the
number
of
workers
exposed
and
the
number
of
hours
exposed.

Exemptions
for
such
reporting
are
as
follows:

°
Production
or
importation
for
the
sole
purpose
of
research
and
development
(
R&
D);
°
Production
or
importation
of
less
than
500
kilograms
during
the
reporting
period
at
single
plant
site;
°
Companies
whose
total
annual
sales
from
all
sites
owned
by
the
domestic
or
foreign
parent
company
are
below
$
30
million
for
the
reporting
period
and
who
produced
or
imported
less
than
45,400
kilograms
of
the
chemical;
°
Production
or
importation
of
the
listed
chemical
solely
as
an
impurity,
a
non­
isolated
intermediate,
and
under
certain
circumstances
as
a
by­
product.

This
ICR
addresses
the
information
collection
activities
associated
with
PAIR,
which
is
promulgated
at
40
CFR
712,
which
establishes
procedures
for
chemical
manufacturers
and
processors
to
report
production,
use,
and
exposure­
related
information
on
listed
chemical
substances.
Subpart
A
establishes
requirements
that
apply
to
all
reporting
under
PAIR,
and
Subpart
B
covers
manufacturers'
and
processors'
reporting.
Processors
are
not
required
to
report
PAIR
information
under
this
ICR.

In
addition,
as
described
in
the
previous
section,
this
ICR
addresses
information
collection
activities
associated
with
the
reporting
and
recordkeeping
requirements
contained
in
40
CFR
766.

2(
b)
Use/
Users
of
the
Data
EPA
uses
PAIR
data
to
(
1)
monitor
domestic
manufacture
and/
or
importation
of
chemical
substances,
mixtures
and
categories,
(
2)
identify
possible
routes
of
human
or
environmental
exposure,
(
3)
support
regulations
designed
to
prevent
possible
adverse
health
effects
and
(
4)
support
EPA
programs.
The
information
provided
by
PAIR
is
needed
to
complete
assessments
of
chemicals
of
interest
and
to
assist
in
the
development
of
regulations
to
control
hazardous
chemicals.
­
4­
All
EPA
program
offices
are
potential
users
of
the
PAIR.
The
information
helps
EPA
evaluate
the
potential
for
adverse
human
health
or
environmental
effects
caused
by
the
manufacture
and
importation
of
the
identified
chemical
substance,
mixture
or
category.
If
EPA
does
not
monitor
these
parameters,
adverse
human
health
or
environmental
effects
may
occur
without
EPA's
knowledge.
Without
this
information,
EPA
would
not
be
able
to
evaluate
the
need
for
additional
testing
or
further
regulatory
action.

Other
federal
agencies,
which
require
data
on
the
human
health
and
environmental
effects
of
a
chemical,
use
PAIR
information.
States
also
have
access
to
public
portions
of
PAIR
information.
Public
interest
groups
use
information
reported
under
the
public
portions
of
PAIR.

3.
NON­
DUPLICATION,
CONSULTATION
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
PAIR
reporting
data
assist
EPA
in
identifying,
evaluating
and
managing
the
human
health
and
environmental
effects
of
chemical
substances,
mixtures
and
categories.
EPA
has
developed
procedures
that
must
be
met
to
ensure
that
the
chemicals
added
to
the
rule
and
the
information
requested
on
these
chemicals
does
not
duplicate
other
activities
or
impose
a
burden
on
industry
that
outweighs
the
need
for
the
data.
These
procedures
are
for
rule
promulgation
and
implementation:

(
1)
A
continuing
evaluation
of
the
information
collection
and
management
activities;
(
2)
The
management
of
the
collected
information;
(
3)
A
chemical
nomination,
screening
and
selection
process;
and
(
4)
Technical
assistance
for
persons
subject
to
the
rule.

It
is
unlikely
that
the
information
to
be
reported
is
duplicative
because
(
1)
EPA
estimates
that
each
rule
will
generate
only
a
few
reports,
(
2)
the
information
required
by
the
PAIR
is
unique
to
the
manufacturer
or
importer,
and
(
3)
efforts
are
made
to
ensure
that
the
information
requested
is
not
currently
in
the
possession
of
EPA
or
easily
obtained
by
EPA
from
other
public
sources.
The
following
databases
and
sources
of
information
are
checked:


The
Chemical
Screening
Branch's
Existing
Chemical
Assessment
Tracking
System
(
CECATS),
a
database
containing
information
on
TSCA
section
8(
e)
and
For
Your
Information
(
FYI)
submissions
and
Chemical
Hazard
Information
Profiles
(
CHIPs);


The
Toxic
Substances
Control
Act
Test
Submissions
(
TSCATS)
database,
an
on­
line
index
to
the
compiled,
unpublished
health
and
safety
studies
submitted
to
EPA;
­
5­

The
Registry
of
Toxic
Effects
of
Chemical
Substances
(
RTECS),
a
file
containing
chemical
toxicity
data;


LEXIS/
NEXUS,
a
data
network
with
a
wide
range
of
fields
including
information
published
in
the
Code
of
Federal
Regulations
(
CFR)
and
BNA's
Environmental
Reporter
and
Chemical
Regulation
Reporter;


The
Toxicology
Data
Network
(
TOXNET),
run
by
the
National
Library
of
Medicine;
and,


The
Toxic
Substances
Control
Act
section
8(
b)
inventory
data
(
CICIS)
and
inventory
update
data
(
CUS).

Similar
searches
are
conducted
for
each
list
of
chemical
substances,
mixtures
or
categories
added
to
the
PAIR.

Some
chemicals
in
PAIR
are
referred
to
EPA
by
other
federal
agencies.
These
agencies
conduct
searches
of
their
own
databases
for
existing
chemical
information
before
they
refer
any
chemical
to
EPA.
Referrals
are
made
to
EPA
only
after
a
decision
has
been
made
that
an
agency's
existing
chemical
information
is
inadequate
to
meet
its
needs.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
Prior
to
submission
to
OMB,
this
ICR
will
be
made
available
to
the
public
for
comment
through
a
Federal
Register
notice.
The
public
will
have
60
days
to
provide
comments.
Any
comments
received
will
be
given
consideration
when
completing
the
supporting
statement
that
is
submitted
to
OMB.

3(
c)
Consultations
On
numerous
occasions,
EPA
has
published
in
the
Federal
Register
notices
requesting
comments
on
the
reporting
requirements
of
TSCA
section
8(
a)
PAIR
rules.
Industry
and
environmental
groups
generally
respond
to
these
requests
for
comment.

The
American
Chemistry
Council
(
ACC),
formerly
the
Chemical
Manufacturers
Association
(
CMA),
has
responded
to
several
Federal
Register
notices.
The
ACC
is
a
nonprofit
trade
association
whose
members
account
for
more
than
90
percent
of
the
total
U.
S.
production
capacity
for
basic
industrial
chemicals.
The
ACC
encourages
EPA
to
use
PAIR
and
has
not
strongly
objected
to
any
of
the
information
requirements
contained
in
PAIR.

The
Natural
Resources
Defense
Council
(
NRDC)
has
also
responded
to
Federal
Register
notices.
NRDC
is
a
national
nonprofit
environmental
organization
dedicated
to
the
protection
of
human
health
and
the
environment.
NRDC
generally
urges
EPA
to
adopt
a
more
detailed
set
of
information
requirements.
­
6­
Also,
EPA
routinely
consults
with
other
federal
agencies
(
e.
g.,
OSHA,
CPSC,
DOT).
These
consultations
include
exchanging
information
on
existing
chemicals,
and
referrals
of
chemicals
to
EPA
by
other
federal
agencies
for
information
collection
when
the
other
agency's
own
authority
or
information
collection
requirements
have
not
met
their
information
needs.

3(
d)
Effects
of
Less
Frequent
Collection
Under
PAIR,
persons
are
required
to
report
only
once
for
a
chemical
listed
in
the
PAIR.
However,
if
information
received
from
the
initial
report
indicates
human
health
and
environmental
risks,
then
the
Agency
may
require
that
additional
information
be
submitted
at
some
future
date
to
monitor
any
changes
pertaining
to
that
chemical.
As
such,
the
reporting
frequency
for
PAIR
cannot
be
reduced
without
effectively
suspending
the
information
collection
requirement.

3(
e)
General
Guidelines
This
collection
does
not
exceed
any
of
the
Paperwork
Reduction
Act
guidelines
at
5
CFR
1320.6.
Note
that
when
this
information
collection
was
last
approved
by
OMB
in
October
2001,
OMB
established
the
following
terms
of
clearance:

"
The
Agency
shall
ensure
that
the
approximate
annual
burden
estimates
for
each
PAIR
rule
are
provided
in
the
preamble
to
each
rule.
Upon
renewal
of
this
ICR,
the
Agency
shall
provide
a
list
of
the
chemicals
covered
by
the
final
PAIR
rules
issued
by
EPA
over
the
next
three
years."

As
requested,
in
the
preamble
to
each
PAIR
rule
issued
during
the
last
ICR
approval
period,
EPA
has
provided
an
annual
burden
estimate
for
the
rules.
The
list
of
chemicals
in
those
final
PAIR
rules,
along
with
the
burden
estimate
provided
for
those
rules,
is
found
under
Attachment
H
to
this
supporting
statement.

3(
f)
Confidentiality
Submitters
may
designate
information
reported
under
PAIR
and
Subpart
B
of
40
CFR
766
as
confidential
business
information
(
CBI).
EPA
has
implemented
procedures
to
protect
any
confidential,
trade
secret
or
proprietary
information
from
disclosure.
These
procedures
comply
with
EPA's
confidentiality
regulations
at
40
CFR
Part
2,
Subpart
B,
and
TSCA
Section
10.

3(
g)
Sensitive
Questions
This
information
collection
does
not
include
questions
of
a
sensitive
nature.
­
7­
4.
THE
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
4(
a)
Respondent
NAICS
Codes
PAIR's
respondents
are
manufacturers
and
importers
of
chemical
substances,
mixtures
or
categories.
Respondents
affected
by
this
collection
are
included
primarily
in
the
following
NAICS
codes:

3251
Basic
Chemical
Manufacturing
3252
Resin,
Synthetic
Rubber,
and
Artificial
Synthetic
Fibers
and
Filaments
Manufacturing
3255
Paint,
Coating,
and
Adhesive
Manufacturing
3253
Pesticide,
Fertilizer,
and
Other
Agricultural
Chemical
Manufacturing
3259
Other
Chemical
Product
and
Preparation
Manufacturing
32411
Petroleum
Refineries
4(
b)
Information
Requested
i.
Data
Items
PAIR
requires
manufacturers
or
importers
of
the
listed
chemical
substances,
mixtures
or
categories
to
report
to
EPA
information
such
as
the
substances'
chemical
identification,
quantity
produced
or
imported,
chemical
processes,
employee
exposure,
environmental
releases,
uses
and
products.
Respondents
are
only
required
to
report
information
that
is
known
or
reasonably
ascertainable
by
them.
As
described
in
the
previous
section,
extensive
files
searches
are
not
required.
The
PAIR
reporting
requirements
are
included
in
the
PAIR
form
and
instructions
(
EPA
Form
7710­
35).

ii.
Respondent
Activities
A
representative
respondent
would
engage
in
the
following
activities:


Conduct
an
initial
review
of
the
rule
to
determine
if
their
company
must
report;


Familiarize
themselves
with
the
PAIR
reporting
form;


Complete
the
PAIR
reporting
form;


Provide
trade
name
notification;


Indicate
CBI
status
if
so
desired;


Keep
a
copy
for
recordkeeping
requirements.

The
PAIR
generally
requires
one­
time
reporting
and
establishes
the
reporting
period
for
the
listed
chemical
substances,
mixtures
or
categories.
Typically,
the
reporting
period
is
30
days
from
the
effective
date
of
the
PAIR
rule.
Effective
dates
of
PAIR
rules
are
typically
30
days
after
publication
of
the
rule
in
the
Federal
Register.
In
other
words,
the
reporting
period
is
typically
60
­
8­
days
from
the
publication
of
a
final
PAIR
rule
in
the
Federal
Register.
Therefore,
a
reporting
schedule
is
not
required.

5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
activities
routinely
conducted
by
EPA
related
to
the
rule
development,
processing,
analysis
and
storage
of
the
information
collected
under
a
PAIR
rule
are
as
follows:


Chemical
nomination,
review
and
selection;


Rule
development;


Evaluation
of
the
rule
(
including
impact
assessments);


Industry/
public
assistance;


Compliance
monitoring;
and

Processing
of
data
received
for
listed
chemicals
(
includes
receipt,
dissemination,
evaluation,
etc.).

5(
b)
Collection
Methodology
and
Management
The
PAIR
requires
respondents
to
submit
TSCA
section
8(
a)
notices
to
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics
(
OPPT),
using
EPA
Form
7710­
35.
Information
collected
under
PAIR
is
logged
in
and
assigned
a
document
control
number
(
DCN),
distributed
to
appropriate
EPA
personnel
for
further
processing,
review,
analysis,
etc.
The
information
is
maintained
by
EPA's
Information
Management
Division.

5(
c)
Small
Entity
Flexibility
In
accordance
with
TSCA
section
8(
a)(
1)(
B),
PAIR
contains
a
small
business
exemption.
A
manufacturer
or
importer
is
considered
a
small
business
if
(
1)
the
firm's
total
annual
sales
when
combined
with
those
of
its
parent
company
(
if
any)
are
less
than
$
30
million
for
the
reporting
period
and
(
2)
its
total
production
and/
or
importation
of
the
chemical
substances,
mixture
or
category,
for
the
reporting
period,
does
not
exceed
100,000
pounds
(
45,000
kilograms)
at
an
individual
site
owned
and
controlled
by
the
firm.

The
small
manufacturer/
importer
exemptions
apply
to
PAIR,
regardless
of
which
office
or
agency
nominates
a
chemical.
In
some
instances,
the
EPA
Administrator
can
remove
these
exemptions
on
a
chemical­
specific
basis,
provided
notice
and
comment
rulemaking
is
utilized.
EPA
expects
that
those
offices
that
have
a
critical
need
for
reporting
from
small
businesses
usually
exempt
from
PAIR
reporting
will
use
other
mechanisms
to
gather
the
data.
EPA
does
not
expect
to
issue
a
PAIR
rule
during
the
next
3
years
that
would
impact
such
small
businesses.
­
9­
5(
d)
Collection
Schedule
Information
collection
under
PAIR
occurs
after
publication
of
a
Federal
Register
notice
establishing
the
reporting
period
for
the
listed
chemical
substances,
mixtures
or
categories.
Respondents
are
asked
to
respond
once,
within
30
days
of
the
effective
date
of
the
final
PAIR
rule
(
which
is
usually
30
days
after
publication
of
the
rule
in
the
Federal
Register).
The
Agency
has
no
plans
to
publish
the
data
collected
by
PAIR,
although
non­
CBI
information
may
be
made
available
to
the
public
upon
request.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
This
section
presents
the
Agency's
estimates
of
the
burden
associated
with
the
reporting
and
recordkeeping
requirements
under
the
TSCA
section
8(
a)
PAIR.
The
total
annual
industry
burden
for
both
reporting
and
recordkeeping
is
estimated
to
be
580
hours.
These
estimates
are
based
on
the
level
of
PAIR
reporting
activity
expected
during
the
ICR
period
of
FY2005
through
2008.
In
conducting
any
study
that
will
be
submitted
to
EPA
under
TSCA,
the
respondent
must
comply
with
the
Good
Laboratory
Practice
Standards
(
GLPS)
at
40
CFR
part
792
(
see
Attachment
G).
Since
the
GLPS
represent
basic
standard
practices
used
by
laboratories,
any
burden
and
costs
related
to
the
GLPS
are
fully
captured
in
the
cost
and
burden
estimates
provided
below.

The
PAIR
report
is
submitted
on
EPA
Form
7710­
35,
which
is
two
pages
long
(
see
Attachment
D).
The
first
page
asks
the
respondent
to
provide
basic
identifying
information,
such
as
the
identity
of
the
chemical
(
CAS
number),
the
physical
location
of
the
plant
and
mailing
address
of
the
responding
entity.
The
second
page
requires
the
respondent
to
provide
general
information
on
the
quantities
of
the
chemical
used
and
number
of
workers
exposed
and
some
additional
information
on
the
categories
of
products
(
e.
g.,
industrial
and
consumer)
associated
with
manufacture
or
processing
of
the
reported
substance.

Much
of
the
information
requested
under
this
ICR
is
routinely
collected
by
manufacturers
and
processors
for
the
maintenance
and
upkeep
of
health
and
safety
information
but
has
not
previously
been
made
available
to
the
Agency.
This
information
should
be
readily
available
to
the
firm
as
it
is
generated
and
maintained
as
part
of
their
normal
business
practices.
In
fact,
the
regulations
specifically
state
that
the
respondent
is
not
required
to
conduct
an
exhaustive
search
of
their
files
(
see
40
CFR
712.7).
The
EPA
has
reviewed
the
average
per­
report
burden
estimate
in
light
of
the
Agency's
experience
and
feedback
received
from
actual
submitters.
Our
average
estimate
of
29.52
hours
per
report
is
consistent.

The
methodology
used
to
develop
these
cost
estimates
follow
principles
that
have
been
used
in
previous
ICRs.
The
methodology
and
calculations
used
in
this
analysis
assumes
the
1
Chemicals
are
added
to
the
PAIR
(
via
Federal
Register
(
FR)
notices)
based
on
Interagency
Testing
Committee
(
ITC)
reports
as
published
in
the
FR.
The
number
of
chemicals
added
to
the
PAIR
recently
are
not
­
10­
employee
responsible
for
filling
out
the
form
has
a
reasonable
level
of
familiarity
with
the
company
and
knowledge
of
the
operation
at
the
site.
The
analysis
deals
with
the
marginal
costs
of
complying
with
this
specific
request
and
not
the
total
costs
to
the
company
of
initial
employee
training
and
costs
associated
with
collecting
and
storing
records
or
of
file
maintenance
that
enable
a
company
to
comply
with
a
range
of
other
Federal
and
state
environmental,
health
and
safety
regulations
or
accounting
requirements
that
rely
on
this
type
of
information.
The
8(
a)
PAIR
requests
are
issued
infrequently
and
it
is
our
experience
based
on
conversations
with
respondents,
that
this
duty
is
similar
to
other
duties
they
perform
which
require
familiarity
with
EPA,
state
and
other
Federal
agency
requests
for
chemical
information
and
does
not
involve
additional
familiarization
or
training
to
comply
with
information
requested
under
this
ICR.

The
Agency
is
not
asserting
an
exact
measurement
of
the
burden
and
costs
that
all
potential
respondents
will
incur
while
complying
with
this
information
collection
activity.
The
Agency's
burden
and
cost
estimates
are
based
on
averages.
Some
respondents
may
indeed
require
more
time
to
respond
the
information
collection
than
the
Agency's
estimated
average
of
29.52
hours
per
report;
however,
the
Agency
believes
some
respondents
will
be
able
to
complete
their
response
activities
in
less
time.
The
Agency
also
intends
to
continue
to
provide
rule­
specific
estimates
of
burden
and
costs,
presenting
them
in
the
preamble
to
the
PAIR
rule.
Should
the
Agency
determine
in
that
context
that
this
average
estimate
is
insufficient,
it
will
adjust
the
ICR
accordingly.
Upon
renewal,
EPA
will
reassess
its
burden
estimate
based
on
the
next
three­
year
approval
period
and
make
adjustments
as
appropriate
Based
on
information
provided
by
EPA's
Information
Management
Division
(
IMD),
an
average
of
11.00
sites
submitted
a
total
of
19.67
reports
per
year
(
an
average
of
1.79
reports
per
site
per
year)
during
the
period
of
FY
2001
through
FY
2004.
In
general,
the
analysis
uses
data
and
methodological
assumptions
from
previous
economic
analyses
of
the
individual
PAIR
rules
and
other
government
data
sources.
This
analysis
also
assumes
that
future
annual
reporting
levels
will
be
similar
to
the
annual
reporting
levels
of
the
FY
2001
through
FY
2004
period,
even
though
the
Agency
only
issued
2
PAIR
rules
during
the
last
ICR
approval
period.
A
detailed
description
of
the
methodology
used
to
derive
the
estimates
follows.

Number
of
Sites
and
Reports
per
Site
The
burden
hour
estimates
in
this
analysis
are
based
on
an
estimate
of
the
level
of
PAIR
reporting
activity
during
the
next
three­
year
ICR
approval
period
(
FY2005
to
FY
2008).
This,
in
turn,
is
related
to
the
number
of
PAIR
chemical
reports
and
reporting
sites.
This
report
utilizes
data
from
the
reporting
period
2001
to
2003
and
annualizes
the
number
of
sites
reporting
and
the
number
of
reports
submitted
to
develop
estimates
of
future
burden.
During
the
2001
to
2003
period,
an
annual
average
of
11.00
sites
(
respondents)
submitted
a
total
of
19.67
reports
(
forms).
Some
PAIR
reports
submitted
during
the
2001
to
2003
period
may
have
resulted
from
chemicals
added
to
the
PAIR
prior
to
2001.1
used
in
estimating
burden
but
are
provided
as
background
(
Source:
US
EPA,
IMD,
Darryl
Ballard
(
8(
a)
chemicals)):

No.
of
Chemicals
Fiscal
Yr
Added
to
PAIR
­­­­­­­­­­­
­­­­­­­­­­­­­­­­­­­
2001
2
2002
12
2003
23
­­­­­­­­­­­
­­­­­­­­­­­­­­­­­
Total
37
­
11­
Sites
Reporting
and
PAIR
Reports
Submitted
FY
2001
­
2003
Fiscal
Year
Sites
Reporting
Reports
Submitted
2001
2
2
2002
11
18
2003
20
39
Totals
33
59
3­
Yr
Average
11.00
19.67
Ratio
Forms/
Sites
1.79
Ratio
Sites/
Forms
0.56
Source:
U.
S.
EPA/
IMD,
Darryl
Ballard,
Section
8(
a)
sites
and
reports
Unit
Burden
Estimates
To
estimate
the
burden
and
costs
to
industry
respondents,
several
reporting
activities
(
or
burden
factors)
are
analyzed.
These
burden
items
include:
form
familiarization;
reporting;
trade
name
notification;
CBI
substantiation;
recordkeeping;
and,
report
submission.
Each
of
these
activities
requires
the
skills
of
various
labor
categories.
The
section
below
details
each
separate
activity
and
presents
the
estimated
labor
hours
required
by
each
task,
by
labor
category
(
secretarial,
technical
and
managerial).
2
Economic
Impact
and
Small
Business
Definition
Analysis
for
the
Final
TSCA
Section
8(
a)
Preliminary
Assessment
Information
Rule,
Final
Report,
prepared
for
the
EPA
by
ICR,
Inc.,
Washington,
D.
C.,
1981.

3
Internal
EPA
memorandum
from
Nicolaas
Bouwes
(
ETD)
to
Tess
Bateman
(
ECAD)
regarding
burden
hour
and
cost
estimates
for
TSCA
section
8(
a)
reporting
(
dated
March
25,
1992).

­
12­
1.
Form
Familiarization
In
the
1981
PAIR
economic
analysis2
it
was
estimated
that
form
familiarization
would
require
3
hours
of
effort
from
managerial
personnel
and
4
hours
from
technical
personnel
for
a
total
of
7
hours
per
site.
The
estimate
includes
efforts
for
rule
familiarization
and
to
determine
if
reporting
is
required.
To
calculate
the
burden
on
a
per
report
basis,
the
above
estimate
was
multiplied
by
0.56,
the
expected
average
number
of
sites
per
report
(
i.
e.,
11.00
sites
/
19.67
reports).
This
results
in
a
per
report
burden
of
3.92
hours.

Per
Report
Burden
Hours
for
Form
Familiarization
Activity
Secretarial
Technical
Managerial
Total
Form
Familiarization
0.00
2.24
1.68
3.92
Given
that
each
site
produces
an
average
of
1.79
reports
(
i.
e.,
the
expected
average
number
of
reports
per
site
(
19.67
reports
/
11.00
sites)),
the
per
site
burden
for
form
familiarization
is
estimated
to
be
3.92
x
1.79,
or
7.02
hours.

2.
Report
Preparation
The
1981
PAIR
economic
analysis
estimated
that
direct
reporting
activities
would
require
a
total
of
16
hours
of
effort
per
report.
This
consists
of
the
burden
related
to
the
completion
of
the
PAIR
form.
As
indicated
previously,
the
respondents
are
not
expected
to
conduct
an
exhaustive
search
of
their
files.
Respondents
are
only
required
to
report
what
is
known
or
reasonably
ascertainable
to
them
(
see
40
CFR
712.7).
The
relative
distribution
of
reporting
burden
between
managerial,
technical
and
secretarial
personnel
used
in
the
1992
PAIR
ICR
update3
has
been
retained
and
is
reflected
below.

Per
Report
Burden
Hours
for
Report
Preparation
Activity
Secretarial
Technical
Managerial
Total
Reporting
1.25
9.25
5.50
16.00
Given
that
each
site
produces
an
average
of
1.79
reports
(
i.
e.,
the
expected
average
number
of
reports
per
site
(
19.67
reports
/
11.00
sites)),
the
per
site
burden
for
report
preparation
is
1.79
x
16
hours,
or
28.64
hours.
4
40
CFR
712.28
(
July
1,
1993).

5
Burden
Hour
and
Cost
Estimates
for
PAIR
Section
8(
a)
Reporting
(
1994
Update),
internal
U.
S.
EPA
memorandum
from
Carol
Rawie,
Economics,
Exposure,
and
Technology
Division
to
Karen
Boswell,
Chemical
Testing
and
Information
Branch,
May
16,
1994.

­
13­
3.
Trade
Name
Notification
Some
companies
may
report
their
customers'
uses
as
unknown
for
more
than
twenty
percent
of
their
volume.
These
companies
must
list
under
Item
10
of
the
PAIR
reporting
form
the
market
(
trade)
name(
s)
under
which
they
distribute
the
chemical.
This
reporting
is
referred
to
as
trade
name
notification.
4
All
commercial
manufacturing,
importing
and
processing
sites
that
distribute
any
of
the
chemicals
subjected
to
a
PAIR
reporting
rule
under
a
trade
name
must
take
steps
to
ensure
that
information
about
the
downstream
processors
is
submitted
to
EPA.
Firms
may
chose
among
several
options
to
meet
trade
name
notification
requirements,
including:

1)
Submit
trade
name
data
to
EPA
for
listing
in
the
Federal
Register;
2)
Notify
all
customers
of
the
need
to
report;
or,
3)
Complete
the
reporting
requirements
for
each
customer.

This
ICR
assumes
that
companies
will
adopt
the
least­
costly
reporting
alternative
of
providing
a
trade
name
list
to
EPA
for
inclusion
in
the
Federal
Register.
However,
trade
name
notification
is
not
relevant
if
processor
reporting
is
not
required.
Furthermore,
this
ICR
also
assumes
that
all
manufacturers
and
importers
will
incur
trade
name
notification
costs,
but
does
not
address
processors
due
to
the
lack
of
data
on
processor
reporting.
In
the
1994
EPA
PAIR
ICR,
5
the
unit
burden
of
trade
name
notification
was
given
as
3.2
hours
(
i.
e.,
2.2
hours
managerial
and
1.0
hours
secretarial).
This
unit
burden
assumption
was
retained
for
this
analysis.

Per
Report
Burden
Hours
for
Trade
Name
Notification
Activity
Secretarial
Technical
Managerial
Total
Trade
Name
Notification
1.00
0.00
2.20
3.20
Given
that
each
site
produces
an
average
of
1.79
reports,
the
trade
name
notification
per
site
burden
for
trade
name
notification
is
1.79
x
3.2
hours,
or
5.73
hours.

4.
CBI
Substantiation
A
company
may
make
claims
of
confidentiality
for
any
data
element
contained
in
its
submission.
For
each
CBI
(
confidential
business
information)
claim,
generic
information
must
be
supplied
for
a
non­
CBI
copy
of
the
submission
(
i.
e.,
a
sanitized
version
must
also
be
submitted).
6
The
alternative
Comprehensive
Assessment
Information
Rule
(
CAIR)
estimate
was
developed
to
account
for
CAIR­
listed
chemicals
for
which
respondents
were
required
to
answer
only
a
limited
number
of
questions.
A
discussion
of
the
alternative
CAIR
burden
and
cost
estimates
is
found
in
Section
6.6
(
pp.
67­
69)
of
the
Estimated
Cost
of
the
Final
Comprehensive
Assessment
Information
Rule,
Final
Report,
U.
S.
EPA/
OPPT/
EETD,
June
1,
1986
(
prepared
for
EPA
by
Kearney/
Centaur).

­
14­
It
is
assumed
that
most
of
the
time
required
for
CBI
substantiation
involves
managerial
staff
discussion
of
whether
or
not
to
make
a
CBI
claim.
Furthermore,
it
is
assumed
that
all
firms
will
review
their
submissions
for
CBI
content.
As
used
in
the
previous
PAIR
ICR,
the
1986
alternative
CAIR6
CBI
substantiation
burden
estimates
have
been
used
in
this
analysis
with
substantial
downward
adjustments
to
account
for
the
less
rigorous
substantiation
requirements
in
PAIR
reporting
rules.
CBI
claims
for
a
PAIR
report
can
be
made
by
simply
checking
the
appropriate
boxes
on
the
PAIR
reporting
form.
It
is
assumed
that
most
of
the
time
required
for
PAIR
CBI
substantiation
involves
staff
discussion
of
whether
or
not
to
make
a
CBI
claim.
As
a
result,
burden
estimates
used
in
CAIR
has
been
reduced
by
one­
half
in
both
labor
categories
to
0.5
hours
of
secretarial
time
and
4
hours
of
managerial
time
per
report.

Per
Report
Burden
for
CBI
Substantiation
Activity
Secretarial
Technical
Managerial
Total
Trade
Name
Notification
0.50
0.00
4.00
4.50
Based
on
an
analysis
of
CBI
claims
for
reporting
to
the
TSCA
Inventory
(
discussed
in
the
1986
CAIR
economic
analysis)
only
75
percent
of
sites
or
reports
are
expected
to
make
CBI
claims.
The
burden
distributed
across
all
reports
is
4.5
hours
x
0.75,
or
3.38
hours.
Multiplying
the
adjusted
report
burden
and
cost
by
1.79,
in
turn,
provides
the
per
site
burden
for
CBI
substantiations
of
6.04
hours.

5.
Recordkeeping
Pursuant
to
TSCA
Section
8(
a),
the
manufacturer/
importer
or
processors
of
the
chemical
substances
identified
under
PAIR
must
also
maintain
records
of
the
information
submitted
to
EPA.
In
addition,
since
manufacturer/
importer
or
processors
that
submit
data
to
EPA
must
comply
with
the
GLPs
in
40
CFR
792,
this
ICR
also
generally
covers
the
burden
associated
with
maintaining
records
as
required
under
the
GLPs.
These
records
are
used
for
compliance
monitoring
and
enforcement
purposes.

As
in
the
previous
ICR,
EPA
estimates
that
the
recordkeeping
burden
associated
with
this
ICR
involves
about
an
hour
of
time
for
both
the
secretarial
and
the
technical
labor
category.
This
burden
estimate
represents
the
time
necessary
for
the
individuals
to
identify
the
information,
determine
the
appropriate
location
for
the
record
to
be
kept,
and
placing
the
record
in
such
a
location.
The
per
report
recordkeeping
burden
is
therefore
estimated
to
be
2
hours.
­
15­
Per
Report
Burden
Estimates
for
Recordkeeping
Activity
Secretarial
Technical
Managerial
Total
Trade
Name
Notification
1.00
1.00
0.00
2.00
The
per
site
burden
for
recordkeeping
is
1.79
reports
x
2.0
hours,
or
3.58
hours.

6.
Report
Submission
Report
submission
consists
of
three
elements:
preparation
and
review
of
a
transmittal
letter
to
accompany
the
submission
of
a
report,
photocopying
the
report
and
mailing
costs.

As
with
the
previous
ICR,
EPA
estimates
that
the
per
report
submission
will
require
0.5
hours
of
secretarial
time
and
0.5
hours
of
managerial
time
for
a
total
of
one
hour.
The
secretarial
burden
includes
the
time
required
to
type
the
transmittal
letter,
to
photocopy
the
report,
and
the
steps
necessary
to
mail
the
report
package
to
EPA
after
management
review
and
approval.
The
managerial
time
assumes
an
involvement
in
the
preparation
of
the
transmittal
letter
and
review
of
the
report
package
before
it
is
submitted
to
EPA.

Per
Report
Burden
Estimates
for
Report
Submission
Activity
Secretarial
Technical
Managerial
Total
Trade
Name
Notification
0.50
0.00
0.50
1.00
Given
that
each
site
produces
an
average
of
1.79
reports,
the
per
site
burden
for
report
submission
is
1.79
x
1
hour,
or
1.79
hours.

Total
Industry
Burden
Estimates
The
following
table
presents
the
compilation
of
the
annual
burden
hour
estimates
for
respondents.
7
The
primary
reference
is:
William
Silagi,
Wage
Rates
for
Economic
analyses
of
Rulemakings
Under
EPCRA
Section
313,
U.
S.
Environmental
Protection
Agency/
OPPT/
EETD/
RIB,
Washington,
D.
C.,
November
12,
1993,
Appendix
A.
The
secondary
reference
is:
Economic
Impact
Analysis
of
the
Proposed
Significant
New
Use
Rule
for
Methylcyclopentane,
Draft
Report,
U.
S.
EPA/
OPPT/
EETD/
RIB,
January
21,
1997.

­
16­
Burden
Item
Hours
Per
Report
Hours
Per
Site
Total
Annual
Hours
(
a)

Form
Familiarization
3.92
7.02
77
Reporting
16.00
28.64
315
Trade
Name
Notification
3.20
5.73
63
CBI
Substantiation
3.38
6.04
66
Recordkeeping
2.00
3.58
39
Report
Submission
1.00
1.79
20
Industry
Totals
29.50
52.80
580
(
a)
Assumes
19.67
reports
and
11.00
reporting
sites
per
year.

In
summary,
an
average
of
11.00
respondents
would
be
required
to
spend
an
estimated
total
of
580
hours
each
year
to
respond
to
PAIR
rules
during
the
period
of
FY
2005
through
FY
2008.

6(
b)
Estimating
Respondent
Costs
This
section
presents
estimates
of
the
cost
expected
to
be
incurred
as
a
result
of
reporting
under
the
TSCA
section
8(
a)
PAIR.
The
total
annual
industry
cost
for
both
reporting
and
recordkeeping
is
estimated
to
be
$
48,972.
This
estimate
is
based
on
the
cost
of
the
burden
estimate
provided
in
section
6(
a)
above,
and
includes
other
costs
associated
with
this
ICR.

Costs
in
this
report
have
been
updated
using
the
most
recently
available,
revised
wage
rates.
These
wage
rates
were
developed
by
EPA
for
each
labor
category
and
were
originally
derived
from
1993
wage
information
published
by
the
Bureau
of
Labor
Statistics
(
BLS)
for
white
collar
occupations
in
all
goods­
producing
private
industries,
and
further
adjusted
for
benefits
and
overhead.
7
Wages
have
been
updated
to
the
fourth­
quarter
2003
using
the
Bureau
of
Labor
Statistics'
Employment
Cost
Index.
Current
labor
rates
used
to
calculate
cost
to
respondents
are
listed
below.
­
17­
The
three
labor
categories
identified
and
their
2003
loaded
hourly
wage
rates
are
as
follows:

LABOR
CATEGORY
LOADED
HOURLY
RATE
Managerial
$
103.53
Technical
$
78.35
Clerical
$
31.49
These
labor
costs
are
multiplied
by
the
estimated
burden
hours
per
activity
and
added
to
any
non­
labor
costs
to
develop
total
unit
costs
per
report.
It
is
estimated
that
recordkeeping
and
report
submission
tasks
will
require
expenditures
other
than
labor.
Recordkeeping
is
estimated
to
require
an
additional
$
28.29
per
report
for
miscellaneous
filing
materials
while
report
submission
is
estimated
to
require
an
additional
$
17.03
per
report
for
photocopying
and
mailing
expenses.
Total
non­
burden
costs
per
report
are
estimated
to
be
$
45.32.
With
an
annual
estimate
of
19.67
reports
expected,
the
total
non­
burden
cost
for
this
ICR
is
$
891
(
rounded
to
the
nearest
whole
dollar).
These
non­
burden
hour
costs
are
identified
separately
on
the
OMB
Form
83­
I
pursuant
to
OMB
guidance,
but
are
included
in
the
total
costs
here.
Finally,
unit
costs
per
report
are
multiplied
by
the
number
of
reports
per
site
per
year
to
arrive
at
unit
costs
per
site
(
respondent
costs).

1.
Form
Familiarization
The
per
report
cost
of
form
familiarization
is:

Managerial
labor:
1.68
hours@
$
103.53/
hour
=
$
173.93
Technical
labor:
2.24
hours
@
$
78.35/
hour
=
$
175.50
Cost
per
report
=
$
349
The
per
site
cost
of
form
familiarization
is:

Cost
per
report
of
$
349
x
1.79
reports
per
site
=
$
625
­
18­
2.
Report
Preparation
The
per
report
cost
for
report
preparation
is:

Managerial
labor:
5.5
hours
@
$
103.53/
hour
=
$
569.42
Technical
labor:
9.25
hours
@
$
78.35/
hour
=
$
724.74
Secretarial
labor:
1.25
hours
@
$
31.49/
hour
=
$
39.36
Cost
per
report
=
$
1,334
The
per
site
cost
of
report
preparation
is:

Cost
per
report
of
$
1,334
x
1.79
reports
per
site
=
$
2,388.

3.
Trade
Name
Notification
The
per
report
cost
for
trade
name
notification
is:

Managerial
labor:
2.20
hours
@
$
103.53/
hr
=
$
227.77
Secretarial
labor:
1
hour
@
$
31.49/
hr
=
$
31.49
Cost
per
report:
$
259
The
per
site
cost
of
trade
name
notification
is:

Cost
per
report
of
$
259
x
1.79
reports
per
site
=
$
464.

4.
CBI
Substantiation
The
per
report
cost
for
CBI
substantiation
is:

Managerial
labor:
4.0
hours
@
$
103.53/
hour
=
$
414.12
Secretarial
labor:
0.5
hours
@
$
31.49/
hour
=
$
15.75
Cost
per
report
=
$
430
Adjusted
cost
per
report
=
$
322
(
adjustment
for
75
percent
of
reports
claiming
CBI)

The
per
site
cost
of
CBI
substantiation
is:

Cost
per
report
of
$
322
x
1.79
reports
per
site
=
$
576.
8
The
figures
for
filing
materials
(
item
5,
$
28.29)
and
photocopying
and
mailing
($
17.03)
were
obtained
by
inflating
the
estimates
from
the
previous
ICR
($
27.23
and
$
16.39,
respectively),
using
the
consumer
Price
Index
for
urban
areas
(
2001=
177.1,
2003=
184.0).

­
19­
5.
Recordkeeping
The
per
report
cost
for
recordkeeping
is:

Technical
labor:
1.0
hours
@
$
78.35/
hour
=
$
78.35
Secretarial
labor:
1.0
hours
@
$
31.49/
hour
=
$
31.49
Filing
materials
=
$
28.29
Cost
per
report
=
$
138
The
per
site
cost
of
recordkeeping
is:

Cost
per
report
of
$
138
x
1.79
reports
per
site
=
$
247.

6.
Report
Submission
The
per
report
cost
of
report
submission:

Managerial
labor:
0.5
hours
@
$
103.53/
hour
=
$
51.77
Secretarial
labor:
0.5
hours@
$
31.49/
hour
=
$
15.75
Photocopying
and
mailing8
=
$
17.03
Cost
per
report
=
$
85
The
per
site
cost
of
report
submission
is:

Cost
per
report
of
$
85
x
1.79
reports
per
site
=
$
152.

The
unit
cost
per
report
and
unit
cost
per
site,
including
a
breakdown
of
costs
by
labor
category,
are
summarized
in
the
following
table:
9
The
annual
costs
per
FTE
are
derived
by
multiplying
the
annual
pay
rate
by
1.6
(
the
benefits
multiplication
factor).
The
multiplication
factor
used
is
recommended
in
EPA's
Office
of
Policy,
Planning,
and
Evaluation's
Instructions
for
Preparing
Information
Collection
Requests
(
ICRs),
(
June
1,
1992).

10
Data
processing
costs
for
the
1996
PAIR
ICR
update
were
estimated
to
be
approximately
$
199.56
per
report.
Adjusting
this
number
to
2003
with
the
GDP
implicit
price
deflator
yields
an
adjusted
data
processing
cost
of
$
223.40
per
report
(
i.
e.,
$
199.56
x
1.1265
=
$
223.40).
Thus,
the
total
annual
data
processing
cost
is
$
4,394
($
223.40
per
report
x
19.67
annual
reports).

­
20­
Report
Activity
Secretarial
Technical
Managerial
Other
Direct
Cost
Cost
per
Report
Cost
per
Site
(
a)

Form
Familiarization
$
0.00
$
175.50
$
173.93
$
0.00
$
349
$
625
Reporting
$
39.36
$
724.74
$
569.42
$
0.00
$
1,334
$
2,388
Trade
Name
Notification
$
31.49
$
0.00
$
227.77
$
0.00
$
259
$
464
CBI
Substantiation
$
15.75
$
0.00
$
414.12
$
0.00
$
322
$
576
Recordkeeping
$
31.49
$
78.35
$
0.00
$
28.29
$
138
$
247
Report
Submission
$
15.75
$
0.00
$
51.77
$
17.03
$
85
$
152
Total
Unit
Costs
$
45.32
$
2,487
$
4,452
TOTAL
COSTS
(
b)
$
48,972
Note:
totals
may
not
add
due
to
rounding
(
a)
Cost
per
report
x
1.79
reports
per
site
per
year
(
b)
Cost
per
site
x
11.00
reporting
sites
per
year.

The
average
respondent
is
assumed
to
spend
$
2,487
per
report,
or
$
4,452
in
total
per
year.
Over
all
sites,
responding
to
PAIR
rules
is
estimated
to
cost
industry
a
total
of
$
48,972
per
year
during
the
period
of
FY
2005
through
FY
2008.

6(
c)
Estimating
Agency
Burden
and
Cost
The
estimated
annual
cost
of
the
PAIR
to
the
Federal
government
is
calculated
on
an
annual
basis.
The
FY
2003
cost
to
EPA
of
a
full­
time
equivalent
employee
(
FTE),
Grade
12,
Step
1
in
the
Baltimore­
Washington
pay
area
is
$
58,070
(
U.
S.
Office
of
Personnel
Management
Internet
site
at
http://
www.
opm.
gov).
One
FTE
is
equivalent
to
2,080
hours
per
year.
The
fully
loaded
FTE
cost
is
$
92,912.9
Data
processing
costs
have
been
updated
from
1996
to
1999
dollars
using
the
GDP
implicit
price
deflator
from
the
Bureau
of
Economic
Statistics.
10
This
analysis
assumes
that
an
annual
average
of
19.67
reports
will
be
submitted
over
the
three
year
period
of
FY
2005
through
2008.
Personnel
costs
associated
with
industry
assistance
11
From
the
1989
PAIR
ICR
update
it
has
been
derived
that
industry/
public
assistance
required
approximately
1.5
hours
per
report
(
29.5
hours
total,
or
0.001
FTEs),
and
data
processing/
system
support
personnel
required
about
3.75
hours
per
report
(
or
73.8
hours
total,
or
0.003
FTEs).

­
21­
and
data
processing
activities
have
been
similarly
adjusted.
11
These
adjustments
were
carried
through
in
this
analysis.

The
table
presented
below
summarizes
the
government's
activities
in
developing
and
administrating
the
PAIR.
The
required
FTEs
per
activity
are
retained
from
the
1996
PAIR
ICR
update
except
where
noted.
Therefore,
it
is
estimated
that
the
annual
cost
to
the
Federal
Government
will
be
$
4,394
in
data
processing
costs
plus
1.60
FTEs.
At
an
estimated
loaded
annual
salary
of
$
92,912
per
FTE,
the
total
of
1.60
FTEs
will
cost
EPA
$
148,659
in
salaries,
bringing
the
total
costs
to
the
Federal
government
to
$
153,053
annually
(
i.
e.,
$
4,394
+
$
148,659).

Below
is
a
summary
of
the
costs
to
the
federal
government
for
this
information
collection.

GOVERNMENT
BURDEN
AND
COST
SUMMARY
Activity
Annual
Cost
Chemical
nomination,
review
and
selection
0.25
FTE
Rule
development
0.90
FTE
Evaluation
of
rule
0.05
FTE
Industry/
public
assistance
0.09
FTE
Compliance
monitoring
0.10
FTE
Data
processing
and
system
support
personnel
costs
0.21
FTE
Total
FTEs
1.60
FTE
Total
hours
(@
2,080
hrs/
FTE)
3328
hrs
Loaded
Annual
Activity
Costs/
FTE
$
92,912
Subtotal
Activity
Costs
$
148,659
Data
processing
costs
for
listed
chemicals
$
4,394
TOTAL
ANNUAL
GOVERNMENT
COSTS
$
153,053
­
22­
6(
c)
Bottom
Line
Burden
Hours
and
Costs:
Master
Tables
Respondent
Burden
and
Costs
Total
respondent
annual
burden
hours
=
580
Total
respondent
annual
costs
=
$
48,972
Agency
Burden
and
Costs
Agency
burden
hours:
1.60
FTEs
=
3,328
hours
Agency
annual
costs
=
$
153,053
6(
d)
Reason
for
Change
in
Burden
This
request
reflects
a
decrease
in
the
total
estimated
burden
of
2,775
hours
(
from
3,355
hours
to
580
hours)
from
that
currently
in
the
OMB
inventory.
This
decrease
is
attributable
to
a
reduction
in
the
assumed
number
of
PAIR
reports
filed
annually,
from
an
average
of
118.00
per
year
to
19.67
per
year.
The
more
recent
average
is
based
on
the
past
three
years
(
2001­
2003)
of
PAIR
reporting
data.
The
annual
average
numbers
of
respondents
(
reporting
sites)
is
11.00,
has
also
decreased
from
the
previous
assumed
average
of
48.00.

6(
e)
Burden
Statement
The
annual
public
burden
for
this
collection
of
information,
which
is
approved
under
OMB
Control
No.
2070­
0054,
is
estimated
to
average
29.53
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
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.
The
OMB
control
numbers
for
EPA's
regulations
in
title
40
of
the
CFR,
after
appearing
in
the
Federal
Register,
are
listed
in
40
CFR
part
9
and
included
on
the
related
collection
instrument
or
form,
if
applicable.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OPPT­
2004­
0095,
which
is
available
for
public
viewing
at
the
Pollution
­
23­
Prevention
and
Toxics
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1544
and
the
telephone
number
for
the
Pollution
Prevention
and
Toxics
Docket
is
(
202)
566­
0280.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
OPPT­
2004­
0095
and
OMB
control
number
2070­
0054
in
any
correspondence.
­
24­
ATTACHMENTS
TO
THE
SUPPORTING
STATEMENT
ATTACHMENT
A*
Section
8(
a)
of
the
Toxic
Substances
Control
Act
(
15
U.
S.
C.
2607a)

ATTACHMENT
B*
Display
Related
to
OMB
Control
#
2070­
0054
­
Listings
of
Related
Regulations
in
40
CFR
9.1.

ATTACHMENT
C*
Chemical
Information
Rules
 
40
CFR
712
ATTACHMENT
D
PAIR
Reporting
Form
(
EPA
Form
7710­
35)
and
Instructions.
Available
electronically
via
Internet
at
http://
www.
epa.
gov/
opptintr/
chemtest/
pairform.
pdf
ATTACHMENT
E*
Dibenzo­
para­
dioxins/
dibenzofurans
 
40
CFR
766
ATTACHMENT
F
Dioxin/
Furan
Report
Form
(
EPA
Form
7710­
51)
and
instructions.
This
attachment
is
not
available
electronically.

ATTACHMENT
G*
Good
Laboratory
Practice
Standards
 
40
CFR
792
ATTACHMENT
H*
List
of
Chemicals
Covered
by
Final
PAIR
Rules,
1998­
2000
*
Attachment
available
as
part
of
the
electronic
file
for
this
supporting
statement.
