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:
Partial
Update
of
the
TSCA
Section
8(
b)
Inventory
Data
Base,
Production
and
Site
Reports
EPA
ICR
No.:
1884.03
OMB
Control
No.:
2070­
0162
1(
b)
Short
Characterization
This
is
a
combined
request
for
a)
renewal
of
an
approved
information
collection
for
basic
information
requirements
of
the
Toxic
Substances
Control
Act
(
TSCA)
via
the
Inventory
Update
Rule
(
IUR
­
see
OMB
Control
No.
2070­
0070,
EPA
ICR
No.
1011.05),
and
b)
renewal
of
an
approved
information
collection
for
the
2003
Amendments
to
the
Inventory
Update
Rule
(
see
OMB
Control
No.
2070­
0162,
EPA
ICR
No.
1884.02).
The
next
IUR
reporting
cycle
will
collect
information
currently
approved
under
both
ICRs,
so
to
simplify
the
renewal
process,
EPA
is
submitting
this
one
consolidated
request
to
the
Office
of
Management
and
Budget
(
OMB),
under
OMB
Control
No.
2070­
0162
/
EPA
ICR
No.
1884.03
and
under
the
title,
"
Partial
Update
of
the
TSCA
Section
8(
b)
Inventory
Data
Base,
Production
and
Site
Reports."

Under
TSCA
section
8(
b),
the
Environmental
Protection
Agency
(
EPA)
is
required
to
compile
and
keep
current,
via
periodic
inquiry,
the
Inventory
of
Chemical
Substances
in
Commerce
(
TSCA
Inventory).
The
TSCA
Inventory
is
a
listing
of
chemical
substances
manufactured,
imported
and
processed
for
commercial
purposes
in
the
United
States.
EPA
has
used
the
IUR
to
update
the
basic
chemical
identity
and
production
volume
information
in
the
TCSA
inventory
five
times
on
a
four­
year
cycle:
1986,
1990,
1994,
1998,
and
2002.
In
January
2003,
EPA
amended
to
IUR
to
require
reporting
of
additional
basic
information,
primarily
exposure
and
use
information,
so
that
EPA's
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
can
better
fulfill
its
obligation
to
protect
human
health
and
the
environment
from
unreasonable
risks
associated
with
chemicals.

The
Office
of
Pollution
Prevention
and
Toxics
(
OPPT),
Office
of
Prevention,
Pesticides
and
Toxic
Substances
(
OPPTS)
will
collect
the
IUR
information
and
will
use
it
to
update
the
TSCA
Inventory,
as
well
as
in
its
risk­
management
efforts.
Individual
plant
or
factory
sites
producing
or
importing
chemicals
will
submit
the
required
information.
The
information
will
be
stored
and
used
in
both
hard­
copy
and
electronic
forms
for
reference
by
EPA
staff
and
others.

This
document
provides
the
estimated
burden
hours
and
costs
associated
with
the
amended
TSCA
Inventory
Update
Rule.
Under
the
2003
Amendments
to
the
IUR,
the
Agency
has
retained
the
current
four­
year
reporting
cycle,
although
it
intends
to
change
that
cycle
to
five­
2
years
after
the
next
submission
period,
which
is
in
2006.
This
change,
along
with
other
changes
that
will
reduce
burden,
are
included
in
the
proposed
IUR
Revisions
rule
(
70
FR
3658).
Because
these
changes
have
not
been
finalized,
this
ICR
presents
an
estimated
annual
average
burden
and
cost
for
respondents
based
on
the
current
status
of
the
IUR,
including
the
four­
year
cycle.

Under
previous
ICRs,
the
Office
of
Prevention,
Pesticides
and
Toxics
Substances
(
OPPTS)
updates
this
inventory
every
four
years
by
collecting
volume
and
manufacturing
site
information
on
about
8,900
of
the
more
than
76,000
chemicals
on
the
Inventory.
The
previous
IUR
required
submission
of
information
on
primarily
organic
chemicals
produced
or
imported
in
volumes
greater
than
10,000
pounds
per
year.
EPA
amended
the
IUR
for
three
principle
reasons:
(
1)
to
tailor
the
chemical
substance
reporting
requirements
to
more
closely
match
the
Agency's
information
needs
without
unreasonably
increasing
the
reporting
burdens
on
industry;
(
2)
to
obtain
updated
information
relating
to
the
potential
human
and
environmental
exposures
of
chemical
substances
listed
on
the
TSCA
Inventory;
and
(
3)
to
improve
the
utility
of
the
information
reported
under
the
IUR.
The
Amendments
allow
EPA
to
obtain
critical
information
that
will
enable
EPA
and
other
government
agencies,
industry,
and
the
public
to
better
screen
and
assess
chemical
exposures
and
risks.
A
primary
user
of
this
information
will
be
EPA.
Other
Federal
Agencies,
states,
industry
groups,
and
the
public
are
also
expected
to
use
this
information.

EPA
currently
maintains
the
information
collected
through
IUR
on
the
Chemical
Update
System
(
CUS)
database.
This
database
will
be
modified
to
incorporate
the
new
information.
Information
is
supplied
by
respondents
either
mailing
or
electronically
submitting
a
completed
IUR
form
to
EPA
during
the
reporting
cycle
that
occurs
every
four
years.
The
collection
is
expected
to
involve
about
3,000
respondents
at
an
annual
cost
of
$
28
million.
The
details
of
the
paperwork
burden
cost
estimates
are
discussed
in
this
document.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
Under
TSCA,
EPA
is
required
to
identify,
assess
and
control
risks
of
injury
to
human
health
and
the
environment
posed
by
commercial
chemicals.
Under
TSCA
section
8(
b),
EPA
is
required
to
compile
and
keep
current
a
complete
list
of
chemical
substances
manufactured
or
processed
in
the
United
States.
Under
TSCA
section
8(
a)
the
Administrator
shall
promulgate
rules
to
provide
for
the
maintenance
and
collection
of
records
from
manufacturers,
importers
and
processors
of
commercial
chemicals.
The
Inventory
Update
Rule
(
IUR)
is
codified
at
40
CFR
710.
Copies
of
the
relevant
sections
of
TSCA
and
of
the
Code
of
Federal
Regulations
are
attached
(
see
Attachments
1
and
2).

Sections
8(
a)
(
1)
and
(
2)
of
TSCA
authorize
the
Agency
to
collect
information
on
the
chemical
manufacturing
and
importing
industry.
Table
1
lists
examples
of
the
type
of
information
3
TSCA
authorizes
EPA
to
collect,
although
it
is
not
all
currently
being
collected.
EPA
possesses
broad
discretion
in
determining
the
information
to
be
reported
under
TSCA
section
8(
a).

Table
1.
Examples
of
Chemical­
specific
Information
EPA
Is
Authorized
To
Collect
Under
Section
8(
a)
of
the
Toxic
Substances
Control
Act
1.
Common
or
trade
name,
chemical
identity,
and
molecular
structure
of
each
chemical
substance
or
mixture
for
which
reports
are
required.

2.
Categories
or
proposed
categories
of
use
for
each
substance
or
mixture
reported.

3.
The
total
amount
of
each
substance
and
mixture
manufactured
or
processed
and
each
of
its
categories
of
use;
reasonable
estimates
of
the
total
amount
to
be
manufactured
or
processed
and
each
of
its
categories
of
use.

4.
A
description
of
the
byproducts
resulting
from
the
manufacture,
processing,
use,
or
disposal
of
each
such
substance
or
mixture.

5.
All
existing
data
concerning
the
environmental
and
health
effects
of
such
substances
or
mixtures.

6.
The
number
of
individuals
exposed,
and
reasonable
estimates
of
the
number
who
will
be
exposed,
to
such
substances
or
mixtures
in
their
places
of
employment
and
the
duration
of
such
exposure.

7.
The
manner
or
method
of
disposal,
and
in
any
subsequent
report
on
such
substance
or
mixture,
any
change
in
the
manner
or
method.

EPA
collected
basic
production
and
site
identification
information
under
the
original
IUR.
The
basic
production
information
includes
chemical
name,
chemical
identification
number,
annual
production
volume,
and
chemical
site­
limited
status.
Site
identification
information
includes
manufacturer
or
importer
and
site
name
and
address
and
the
name,
address,
and
phone
number
of
a
technical
contact.
EPA
will
continue
to
collect
this
information.

The
Agency
needs
the
information
that
will
be
collected
under
the
2003
Amendments
to
the
IUR
to
augment
and
expand
databases
of
exposure
information
that
the
Agency
uses
in
everyday,
basic
decision
making.
OPPT
must
be
able
to
screen
chemicals
based
on
the
potential
for
risk
in
order
to
protect
human
health
and
the
environment
as
required
by
TSCA.
Exposure
is
a
key
component
of
risk.
EPA
will
use
the
exposure
information
collected
through
the
amended
IUR
to
determine
which
chemicals
need
to
be
further
evaluated.
By
using
this
limited
set
of
exposure
and
use
data,
the
Agency
can
focus
testing
and
analysis
priorities
on
those
chemicals
with
the
greatest
potential
for
risk.
Without
this
information,
chemicals
must
be
evaluated
using
conservative
generic
assumptions
for
exposure
and
use.
The
data
on
use
and
exposure
will
allow
the
Agency
and
others
to
potentially
avoid
more
burdensome
requirements
by
allowing
for
a
more
effective
and
efficient
early
evaluation
of
chemicals
that
may
be
identified
for
further
evaluation.

In
the
past,
EPA's
approaches
to
setting
priorities
for
reviewing
chemical
for
further
evaluation
or
potential
risks
were
primarily
based
on
relative
chemical
substance
hazards.
The
hazard
approach
evolved
into
a
risk­
based
approach,
where
production
volume
was
used
as
a
1
It
is
generally
recognized
that
risk
is
comprised
of
two
parts
­
hazard
and
exposure.
For
the
Agency
to
take
a
risk­
based
approach
to
screening
chemicals,
information
on
both
components
of
risk
is
necessary.

4
proxy
for
exposure.
1
The
Agency
now
recognizes
that
exposure
is
best
determined
using
exposure
scenarios,
i.
e.,
that
volume
alone
can
be
a
poor
and
misleading
substitute
for
exposure.
Exposure
scenarios
rely
on
information
such
as
how
the
chemical
is
used
and
the
number
of
people
involved
with
its
use.
The
new
data
elements
included
in
the
amended
IUR
will
provide
the
essential
basic
exposure­
related
data
needed
to
more
accurately
evaluate
a
chemical
substance
for
potential
risk
concerns
and/
or
further
evaluation,
and
will
also
improve
the
Agency's
risk
assessments.
By
providing
the
means
for
better
prioritization
of
limited
resources
on
the
basis
of
risk,
the
amended
IUR
will
greatly
enhance
the
Agency's
efforts
to
achieve
better
public
health,
sustainable
development,
environmental
justice,
pollution
prevention,
sound
science,
partnerships,
and
ecosystem
protection.
The
success
of
the
New
Chemicals
Program
 
where
over
32,000
chemicals
have
been
screened
using
data
similar
to
the
IUR
data
 
demonstrates
the
value
of
having
sufficient
information
to
screen
chemicals
based
on
an
adequate
representation
of
risk.

2(
b)
Practical
Utility/
Users
of
the
Data
The
Inventory
Update
Rule
information
collection
enables
EPA
to
procure
basic
information
on
TSCA
commercial
chemicals,
including
current
production
volume
and
site­
related
data.
In
addition,
as
a
result
of
amendments
promulgated
in
2003,
in
all
upcoming
reporting
periods
EPA
will
collect
limited
exposure,
processing
and
use
data.
This
information
collection
is
necessary
because
it
is
the
only
mechanism
through
which
EPA's
need
for
basic
information
on
the
chemical
industry
can
be
fully
and
effectively
satisfied.
The
information
collected
is
utilized
in
the
following
ways:

(
1)
Parent
company
and
technical
contact
information:
this
data
is
collected
to
identify
the
parent
company
responsible
for
the
data.

(
2)
Plant
site
information:
this
data
is
collected
to
identify
the
physical
site
where
the
manufacturing
and
import
takes
place.
These
data
can
assist
EPA
in
estimating
total
human
and
environmental
exposure,
and
to
identify
specific
plant
site
operators
so
as
to
be
able
to
communicate
with
them.
As
such,
this
information
is
sought
for
purposes
related
to
regulatory
activities
under
TSCA
sections
4,
6
and
8.

(
3)
Chemical
identification:
necessary
for
EPA
to
properly
identify
the
chemical.

(
4)
Manufacturing
information,
including
whether
each
chemical
is
either
manufactured
or
imported,
production
volume
for
the
reporting
year
for
each
chemical,
whether
each
chemical
is
site­
limited,
number
of
workers
potentially
exposed
to
each
chemical,
maximum
concentration
of
each
chemical,
and
physical
form(
s)
of
each
chemical:
this
information
is
utilized
in
chemical
screening,
testing/
review
priority
setting
and
exposure
estimation
required
by
the
Interagency
Testing
Committee
(
ITC)
under
TSCA
section
4,
2
INFORM
is
a
nonprofit
environmental
research
organization.

5
for
EPA
monitoring
activities
of
newly
manufactured
substances
that
have
completed
PMN
review
under
TSCA
section
5(
a),
to
support
the
development
of
TSCA
regulations
under
section
6,
and
to
measure
potential
of
human
and
environmental
exposure
under
TSCA
section
8(
e).
Each
data
element
corresponds
to
a
data
point
necessary
for
basic
risk­
screening;
for
example,
a
site­
limited
substance
is
presumed
to
have
lower
exposure
potential
because
it
is
not
distributed
outside
the
manufacturing
plant
for
commercial
purposes.

Some
respondents
must
also
report
for
chemicals
produced
in
excess
of
300,000
pounds
(
5)
industrial
processing
and
use
data,
including
types
of
industrial
use
and
associated
industry
NAICS
codes,
industrial
function,
estimated
number
of
sites,
and
estimated
numbers
of
workers
exposed;
and
(
6)
commercial
and
consumer
end­
use
exposure
data,
including
categories
of
products,
and
whether
the
chemical
is
used
in
products
intended
for
children.

Information
secured
through
the
Inventory
Update
Rule
collections
is
increasingly
used
by
a
wide
variety
of
governmental
and
non­
governmental
users.
Consistent
with
Congress's
intent
that
TSCA
data
be
used
to
facilitate
any
government
public
health
and
environment
efforts,
IUR
data
have
been
used
by
EPA's
Office
of
Water,
Office
of
Solid
Waste
and
Emergency
Response,
and
Office
of
Air
and
Radiation
to
identify
and
characterize
particular
chemical
substances.
Nonconfidential
IUR
data
are
incorporated
into
a
number
of
databases
and
products
maintained
by
organizations
including
Right­
To­
Know­
Net
and
INFORM2.
IUR
data
were
used
to
identify
chemicals
of
particular
concern
for
the
National
Institutes
of
Health.
Non­
confidential
IUR
data
were
also
released
to
selected
states
to
help
them
identify
facilities
manufacturing
suspected
endocrine
disrupters.
For
more
specific
information
on
the
use
of
the
data
collected
through
the
IUR,
please
see
EPA's
IURA
Data
Use
Plan
(
Attachment
3).

Under
TSCA,
EPA
has
an
obligation
to
protect
human
health
and
the
environment
from
unreasonable
risks
associated
with
chemicals
under
its
jurisdiction.
In
order
to
evaluate
potential
chemical
risks,
EPA
has
determined
that
a
portion
of
the
chemicals
(
both
organic
and
inorganic)
on
the
TSCA
Inventory
currently
warrant
the
continued
collection
of
manufacturing
information,
and
that
a
subset
of
those
chemicals
(
i.
e.,
those
produced
in
quantities
of
300,000
pounds
or
more
at
a
site)
currently
warrant
the
collection
of
supplementary
processing
and
use
information.
EPA
has
amended
the
IUR
to
provide
an
accurate
and
readily
available
source
of
basic
processing
and
use
information
for
about
4,500
of
the
76,000
substances
listed
on
the
Inventory,
thus
significantly
limiting
industry's
reporting
burden
while
providing
EPA
with
information
necessary
to
screen
for
risks
to
human
health
and
the
environment.

Improving
the
Agency's
ability
to
set
priorities
results
in
a
variety
of
benefits.
Agency
resources
will
be
more
efficiently
and
effectively
used
since
chemicals
of
concern
will
be
more
accurately
identified.
Chemicals
not
of
current
concern
will
also
be
identified
earlier
in
the
review
6
process,
enabling
the
better
use
of
both
industry
and
Agency
resources.
Industry
efforts
to
address
chemicals
of
concern
will
also
be
better
targeted.
Overall,
public
and
private
resources
will
be
maximized
and
public
health
and
the
environment
will
be
better
protected.

EPA
will
use
the
new
information
submitted
through
this
collection
to
develop
a
comprehensive
chemical
exposure
and
use
database,
and
to
further
update
and
supplement
the
current
CUS
database.
The
CUS
database,
combined
with
the
Chemicals
In
Commerce
Information
System
(
CICIS)
database,
serves
as
a
primary
source
of
information
for
EPA,
as
well
as
other
Federal
Agencies,
about
the
chemical
industry
­
the
chemicals
used,
where
they
are
produced
and
how
much
is
produced
or
imported.
The
chemical
industry
is
dynamic,
therefore
continual
updating
of
the
database
is
necessary.

Under
the
IUR
as
amended,
EPA
will
collect
readily
obtainable
(
to
the
manufacturer
or
importer)
exposure­
related
data
that
can
be
used
to
better
establish
priorities
for
EPA's
Existing
Chemical
review
program.
The
new
IUR
data
elements
are
related
to
or
are
indicative
of
three
components
of
exposure.
These
components
are:
(
1)
the
size
of
human
populations
potentially
exposed,
(
2)
the
potential
routes,
magnitudes,
and
concentrations
of
exposures
experienced
by
the
environment
or
humans,
and
(
3)
the
frequency
and
duration
of
potential
exposures.
The
Amended
IUR
supplements
the
data
collected
under
the
original
IUR
with
additional
data
elements
that
can
improve
the
EPA's
ability
to
evaluate
each
of
these
components
of
exposure.
Examples
of
data
elements
of
interest
for
each
component
are:


The
size
of
human
populations
potentially
exposed
can
be
estimated
based
on
several
factors:
production
volume,
number
of
workers
potentially
exposed,
downstream
industrial
and
commercial
uses,
and
types
of
industries
using
the
chemical
substance.


The
potential
routes,
magnitudes,
and
concentrations
of
exposures
can
be
estimated
based
on
the
physical
state
of
the
chemical,
how
it
is
used,
and
the
concentration
of
the
chemical.


The
frequency
and
duration
of
potential
exposures
can
be
estimated
based
on
the
type
of
industrial
or
commercial
and
consumer
use
and
the
type
of
population.

Other
organizations
also
recognize
that
exposure­
related
data
can
be
used
to
better
evaluate
the
potential
risks
associated
with
a
particular
chemical.
For
example,
in
a
letter
to
EPA
(
CMA,
1996)
proposing
an
alternative
to
the
2003
Amendments
to
the
IUR,
the
Chemical
Manufacturers
Association
(
now
the
American
Chemistry
Council)
noted
that
data
on
chemical
use
volumes,
numbers
of
exposed
workers,
magnitudes
of
chemical
usage
per
worker,
number
of
use
sites,
and
environmental
releases
can
supplement
production
volume
data
in
evaluating
the
potential
risks
associated
with
a
particular
chemical.

Practical
Utility
7
Practical
utility
is
defined
in
the
Paperwork
Reduction
Act
of
1995
(
PRA)
(
44
USC
3502(
11))
to
mean
"
the
ability
of
an
agency
to
use
information,
particularly
the
capability
to
process
such
information
in
a
timely
and
useful
fashion."
OMB's
regulatory
definition
of
"
practical
utility"
at
5
CFR
Part
1320.3(
l)
addresses
not
only
the
theoretical
or
potential
usefulness
of
information
to
an
Agency,
but
its
actual
usefulness,
taking
into
account
its
accuracy,
validity,
adequacy,
and
reliability,
and
the
Agency's
ability
to
process
the
information
in
a
useful
and
timely
fashion,
and
taking
into
account
whether
the
Agency
demonstrates
actual
timely
use
of
the
data
by
the
Agency's
own
functions.
The
following
discussion
addresses
the
concerns
in
two
parts:
first,
the
adequacy,
accuracy,
validity,
and
reliability
of
the
data;
and
second,
the
timely
use
of
the
data
by
EPA.

EPA
considered
the
types
of
information
needed
for
screening­
level
exposure
and
risk
assessments
and
believes
the
information
to
be
collected
through
the
amended
IUR
will
have
the
necessary
level
of
adequacy,
accuracy,
validity,
and
reliability
for
these
assessments.
While
the
accuracy,
validity,
and
reliability
of
the
data
could
be
increased,
in
developing
the
amended
IUR
and
considering
various
alternatives,
EPA
relied
on
experience
from
programs
such
as
TSCA's
New
Chemicals
Program
and
the
UEIP
data
collection
and
maintained
a
balance
between
data
needs
for
exposure
screening
and
the
burden
associated
with
providing
the
information.
If
the
Agency
had
required
very
precise,
specific
reporting,
company
burden
would
have
increased
beyond
that
which
is
appropriate
for
a
screening­
level
data
collection.
Many
factors
can
affect
exposure
potential;
however,
the
data
provided
by
the
submitters
will
provide
baseline
information
sufficient
for
an
initial
screen
of
exposure
potential.

°
The
Right
Data
Elements.
Before
promulgating
the
IUR
Amendments,
EPA
analyzed
various
exposure
data
collections
and
analyses
to
determine
the
data
elements
needed
for
a
screening
level
exposure
assessment.
This
discussion
and
analysis
is
in
the
document
Inventory
Update
Rule
(
IUR)
Amendment
Technical
Support
Document:
Exposure­
Related
Data
Useful
for
Chemical
Risk
Screening.

°
The
Right
Level
of
Detail.
Risk
analyses
performed
by
the
Agency
in
general
and
OPPT
in
particular
are
graduated
and
data­
driven.
As
the
initial
levels
of
concern
and
the
quantity
and
quality
of
data
increase,
the
concomitant
need
for
and
methodologies
of
risk
review
become
more
detailed
and
exacting,
while
the
reviews
become
more
accurate
and
reliable.
Based
on
its
years
of
experience
assessing
chemical
risks
through
such
programs
as
the
New
Chemicals
Program,
the
Agency
believes
the
amended
IUR
data
will
provide
information
adequate
to
perform
initial
screens
of
chemicals,
and
to
prioritize
and
make
basic
risk
management
decisions
about
those
chemicals
of
greatest
concern
as
indicated
by
the
available
data.
These
better­
informed
decisions
can
enhance
confidence
that
the
most
appropriate
chemicals
are
selected
for
more­
detailed
assessments.

°
The
Right
Level
of
Accuracy
and
Reliability.
The
Agency
considered
the
data
accuracy
and
reliability
needed
for
screening
level
exposure
analyses
and
took
several
steps
to
ensure
that
the
amended
IUR
data
met
those
needs.
Screening­
level
data
need
8
not
be
absolutely
precise,
but
should
be
accurate
and
reliable
enough
to
make
usable
and
defensible
technical
assessments.
The
amended
IUR
will
supply
exposure­
related
information
the
Agency
does
not
currently
have,
recognizing
that
industry
has
a
greater
knowledge
than
EPA
about
its
own
operations,
and
the
uses
of
chemicals
it
manufactures
and
sells.
Without
this
information,
EPA
either
would
not
screen
these
chemicals,
would
screen
them
using
outdated
or
anecdotal
information,
or
would
rely
on
exposure
estimates
(
typically
conservative)
from
modeling
data.

°
EPA
recognizes
that
submitters
may
not
always
have
detailed
information
about
how
the
chemical(
s)
they
make
are
used.
Because
of
this,
the
amended
IUR
only
requires
submitters
to
report
this
information
to
the
extent
it
is
"
readily
obtainable."
In
addition,
the
Agency
believes,
based
on
its
experience
with
the
New
Chemicals
Program,
the
UEIP,
stakeholder
meetings,
discussions
with
industry
about
voluntary
risk
management
programs,
and
industry's
various
selfregulation
initiatives,
that
most
submitters
have
at
least
some
basic,
suitably
accurate
information
about
downstream
uses,
such
as
the
information
that
would
be
reported
under
the
amended
IUR.
For
instance,
industry
programs
such
as
the
American
Chemistry
Council's
(
ACC)
Responsible
Care
Program
require
that
member
companies
work
with
customers,
carriers,
suppliers,
distributors
and
contractors
to
foster
the
safe
use,
transport
and
disposal
of
chemicals.
The
Responsible
Care
Program,
coupled
with
basic
marketing
and
sales
force
activities,
ensure
that
companies
are
well
informed
about
downstream
uses
of
their
chemicals.

°
EPA
also
requires
much
of
the
amended
IUR
information
to
be
submitted
in
specified
ranges.
This
requirement
benefits
both
the
Agency
and
submitters.
First,
range
reporting
is
less
burdensome
for
the
submitter
than
calculating
specific
quantity
estimates.
Demanding
greater
data
accuracy
would
have
increased
the
burdens
associated
with
data
collection.
Second,
information
reported
in
discrete
numeric
values
tends
to
indicate
a
level
of
precision
that
is
not
necessarily
present.
EPA
feels
that
by
reporting
in
ranges,
a
higher
level
of
confidence
in
the
data
accuracy
is
attained.

Usability
of
Data
EPA
will
use
the
amended
IUR
processing
and
use
information
for
the
4,500
targeted
chemicals
submitted
through
the
amended
IUR
in
a
timely
fashion.
EPA
has
carefully
designed
the
amended
IUR
data
collection
to
facilitate
efficient
data
management
and
use.
Data
collected
through
the
amended
IUR
will
be
put
into
a
relational
database
format,
which
can
be
easily
searched,
compared,
and
used.
The
collection
of
specific
data,
organized
by
codes,
instead
of
textual
information
presented
in
a
unstructured
manner,
lends
itself
to
such
a
database
format.
In
addition,
providing
for
electronic
amended
IUR
submissions
allows
data
to
be
entered
into
the
database
more
accurately
and
expeditiously,
resulting
in
a
quick
turnaround
between
the
9
submission
of
the
data
to
the
Agency
and
the
availability
of
the
data
for
use.
More
than
half
of
all
reports
were
submitted
electronically
in
2002,
and
the
Agency
expects
that
figure
to
increase.
The
amended
IUR
data
will
therefore
be
quickly
available
for
the
Agency's
use
Data
Uses
Data
generated
by
the
amended
IUR
will
be
used
in
a
wide
variety
of
programs
fundamental
to
fulfilling
the
Agency's
TSCA
statutory
mandate.
EPA's
primary
use
of
these
data
will
be
to
identify
priority
TSCA
chemicals
for
more
detailed
information
gathering,
risk
assessment,
and
risk
management,
and
to
develop
targeted
programs
to
protect
human
health
and
the
environment.
Since
screening
chemical
risks
generally
requires
a
combination
of
both
hazard
and
exposure
information,
the
absence
of
exposure­
related
data
beyond
production
volume
data
in
the
original
IUR
has
severely
limited
the
utility
of
the
IUR
data
for
risk
screening.
This
lack
of
exposure­
related
data
has
made
it
difficult
for
EPA
and
others
to
identify
chemicals
with
exposures
of
concern,
or
has
resulted
in
generating
overly
conservative
exposure
assessments
based
on
incomplete
information.
The
addition
of
manufacturing
and
processing
and
use
exposure­
related
data
in
the
amended
IUR,
especially
when
compiled
into
a
searchable
database
format,
will
enable
EPA
and
others
to
more
readily
screen
chemicals
for
exposure
and
risk.
These
reviews
will
allow
EPA
and
others
to
better
prioritize
chemicals
to
identify
those
warranting
more
detailed
assessments,
and
to
eliminate
chemicals
of
lesser
concern
from
further
review.
Potential
uses
of
these
data
by
EPA
and
others
are
discussed
below.
Additional
examples
are
detailed
in
EPA's
IURA
Data
Use
Plan
(
Attachment
3).
Note
that
both
sets
of
examples
are
illustrative,
not
exhaustive.
Programs
using
the
IUR
data
will
range
from
the
more
traditional
existing
chemicals
risk
screening
efforts
to
voluntary
programs,
such
as
Design
for
the
Environment
(
DfE),
to
individual
requests
for
analysis
of
chemicals
not
specifically
associated
with
a
particular
program.
The
Agency
anticipates
that,
as
was
true
even
for
the
basic
production
data
reported
under
the
original
IUR,
new
uses
of
amended
IUR
data
by
EPA
and
by
others
will
continually
emerge
and
cannot
be
predicted
at
this
time.

Potential
Uses
of
the
Data
by
EPA
°
New
IUR
data
will
be
used
to
perform
preliminary
exposure
and
risk
screening
across
a
portion
of
the
Inventory
chemicals.
When
combined
with
data
from
workplace
monitoring
studies
and
modeling
approaches,
exposure­
related
information
of
the
type
the
IUR
will
collect
has
allowed
EPA
to
compile
screening­
level
workplace
exposure
assessments.
The
data
on
use
gives
crucial
information
to
allow
EPA
to
postulate
process
operations,
worker
activities,
and
possible
exposures.
Such
use
information
will
enable
EPA
to
generate
estimated
numbers
of
workers
in
very
small
businesses
(<
10
workers)
that
may
be
poorly
represented
by
National
Occupational
Exposure
Survey
(
NOES)
data.
Without
such
information,
exposed
populations
and
exposure
level
estimates
may
be
severely
underestimated
or
left
as
a
data
gap.
Such
underestimations
and
data
gaps
can
artificially
lower
a
chemical's
status
on
EPA's
risk
prioritization
list.
10
°
The
updated
IUR
database
will
be
searched
to
identify
chemicals
or
use
scenarios
meeting
specific
criteria.
For
instance,
if
there
were
a
need
to
identify
chemicals
that
have
the
greatest
potential
for
consumer
exposure,
the
database
could
be
searched,
resulting
in
a
listing
of
chemicals
arranged
according
to
the
production
volumes
associated
with
different
consumer
uses.

°
OPPTS
will
put
information
collected
through
the
HPV
Challenge
Program
into
context.
Through
the
HPV
Challenge,
EPA
is
collecting
hazard
information
on
certain
HPV
chemicals.
By
combining
the
amended
IUR
exposure
information
and
the
HPV
Challenge
hazard
information,
EPA
will
be
able
to
better
prioritize
the
HPV
chemicals
based
on
potential
risk.
The
IUR
data
will
similarly
be
used
to
prioritize
other
chemicals
for
which
EPA
has
hazard
data.

°
The
New
Chemicals
Program's
PMN
review
process
provides
an
excellent
example
of
how
IUR
data
will
assist
EPA
in
protecting
human
health
and
the
natural
environment.
EPA
uses
exposure­
related
data
from
PMNs
to
generate
screening­
level
risk
assessments
for
regulatory
decision
making
under
TSCA
section
5.
Using
this
information
in
combination
with
technical
references
and
other
research,
EPA
is
able
to
estimate
the
number
of
manufacturers
who
may
use
a
new
substance.
EPA
also
is
able
to
estimate
releases
of
the
new
substance
from
processing
and
from
product
manufacturing,
resulting
in
estimated
environmental
concentrations
of
the
new
substance
due
to
its
release
and
estimated
general
population
exposures
to
a
new
substance.
EPA
also
uses
the
information
on
processing
and
use
in
combination
with
data
and
modeling
to
estimate
the
numbers
of
workers
and
consumers
who
may
be
exposed
to
a
new
substance,
and
their
estimated
exposures
to
a
new
substance.
Based
on
the
estimated
hazards
of
a
new
substance,
it
is
determined
whether
the
exposures
to
the
new
substance
estimated
for
potentially­
exposed
workers,
general
population,
consumers,
and
aquatic
species
fall
below
levels
of
concern.
A
similar
process
for
existing
chemicals
will
be
possible
with
the
new
IUR
data.

°
EPA
will
also
employ
the
amended
IUR
data
in
several
newly­
developed
exposure
screening
tools
for
a
second­
tier
screening.
For
example,
the
Chemical
Screening
Tool
for
Exposures
and
Environmental
Releases
(
ChemSTEER),
will
also
use
information
from
the
amended
IUR
database
to
generate
estimates
of
worker
exposures
and
environmental
releases.
ChemSTEER
uses
most
of
the
new
IUR
data
in
combination
with
data
from
technical
references
and
other
research,
and
with
mathematical
and
empirical
models
and
methods,
to
estimate
these
releases
and
exposures
throughout
the
life
cycle
of
the
chemical
in
workplaces.
Another
tool,
E­
FAST
(
Exposure
and
Fate
Assessment
Screening
Tool),
uses
the
release
estimates
from
ChemSTEER
and
the
new
consumerexposure
related
IUR
data
in
combination
with
data
from
technical
references
and
other
research
and
with
mathematical
models
and
methods
to
estimate
exposures
to
the
general
public
and
aquatic
species
during
the
life
cycle
of
the
chemical.
The
estimates
generated
11
by
ChemSTEER
and
E­
FAST
will
be
used
in
screening
processes
for
potential
risks
that
chemicals
may
pose
to
people
and
the
environment.

°
Information
from
the
amended
IUR
may
also
be
used
in
efforts
to
identify
single
chemicals,
to
support
potential
exposure
prevention
efforts.
For
example,
EPA
recently
learned
that
certain
imports
of
zinc
sulfate
were
contaminated
with
cadmium.
Using
the
new
IUR
processing
and
use
data
on
inorganic
substances,
EPA
could
have
quickly
identified
importers
of
zinc
sulfate,
and
segments
of
industry
or
the
general
population
that
might
use
the
chemical.
EPA
could
then
have
targeted
warnings
of
the
potential
for
exposure
to
cadmium
more
effectively,
thereby
preventing
exposures
to
these
groups
likely
to
be
the
most­
highly
exposed.

°
OPPTS,
as
well
as
other
EPA
offices,
will
be
able
to
identify
chemicals
with
likely
exposure
to
children,
the
elderly,
or
other
special
populations
by
sorting
the
chemicals
by
specific
uses.
Using
the
consumer
and
commercial
use
categories,
EPA
can
identify
which
uses
most
likely
will
lead
to
exposures
to
potentially
sensitive
populations,
such
as
children.
The
Agency
can
further
refine
the
search
by
looking
at
the
industrial
function
for
a
smaller
set
of
chemicals
and
eliminate
reviewing
a
large
number.
For
instance,
a
product
that
has
a
consumer
use
category
of
"
paper
products"
and
an
industrial
function
category
of
"
absorbent"
may
lead
to
exposure
to
these
populations.
This
information
will
also
clarify
when
exposure
to
certain
sub­
populations
is
unlikely
or
not
possible,
thereby
avoiding
unnecessary
concerns
about
potential
risks
for
some
chemicals.

°
OPPT's
Chemical
Testing
Program
will
use
the
chemical
use
data
to
develop
screeninglevel
exposure
estimates
to
evaluate
the
potential
risks
of
thousands
of
chemicals,
ultimately
providing
information
used
for
the
Agency's
priority
setting.
One
specific
example
is
the
prioritization
of
chemicals
for
TSCA
test
rule
(
Section
4
Test
Rules)
consideration.
TSCA
section
4
authorizes
EPA
to
obtain
hazard
information
by
requiring
that
certain
studies
be
conducted
and
that
the
resulting
test
data
be
submitted
to
EPA.
The
data
on
potential
exposure
that
will
be
provided
by
the
amended
IUR
enable
the
Agency
to
prioritize
the
chemicals
for
which
testing
might
be
required,
and
eliminate
the
need
for
further
testing
for
other
chemicals.

°
The
amended
IUR
data
will
enhance
OPPTS's
ability
to
evaluate
clusters
of
chemicals
by
use
and
identify
lower
risk
alternatives
by
providing
exposure
information
for
the
Use
Cluster
Scoring
System
(
USCC).
The
USCC
is
a
computer­
based,
risk­
screening
tool
that
groups
chemicals
into
clusters
based
on
use.
The
Agency
will
utilize
the
USCC
to
evaluate
worker
exposure
and
risk
for
chemicals
by
use
categories
and
identify
chemical
alternatives
with
the
lower
potential
risks.
The
Science
Advisory
Board
(
SAB)
has
reviewed
this
risk
screening
tool
and
has
found
that
use
and
exposure
information
supporting
the
tool
needs
to
be
improved.
The
Agency
plans
to
use
the
information
obtained
through
the
amended
IUR
to
provide
the
necessary
use
and
exposure
data
to
improve
the
USCC,
making
it
a
more
effective
tool.
12
°
OPPTS
will
use
the
amended
IUR
data
to
better
evaluate
potential
worker
risks.
The
use
and
exposure
data
will
allow
EPA
to
prioritize
chemicals
based
on
various
levels
of
worker
exposure.
This
type
of
information
is
valuable
for
EPA
as
well
as
states,
OSHA
and
NIOSH
in
providing
a
basis
for
more
informed
risk
management
decision­
making.

°
The
IUR
data
will
enable
the
Agency
to
sort
chemical
use
by
industry
and
sector
to
improve
OPPTS
risk
management
decision­
making
and
related
activities.
This
will
enable
EPA,
as
well
as
states,
OSHA,
and
NIOSH,
to
consider
a
broader
range
of
options
when
addressing
potential
risks
and
mitigation.

°
The
Agency
has
relied
on
the
original
IUR
data
in
the
past
as
a
screening
mechanism
for
prioritizing
chemicals
for
listing
and
delisting
Toxics
Release
Inventory
(
TRI)
chemicals.
Some
decisions
involve
acute
hazards
with
exposure
concerns.
The
new
IUR
information
will
enable
EPA
to
better
refine
such
analyses.

°
EPA
has
a
large
number
of
voluntary
programs
that
OPPTS
could
help
to
document
the
progress
using
the
IUR
information.
OPPTS
could
trace
the
production
and
use
of
chemicals
using
the
time
series
data
from
the
IUR
and
identify
which
chemicals
are
being
used
less,
which
are
being
used
more,
and
which
are
being
used
differently.

°
The
Office
of
Water
(
OW)
may
use
the
amended
IUR
information
to
assist
them
in
selecting
chemicals
for
setting
effluent
guidelines
and
sampling
of
contaminants
in
river
and
surface
water
and
in
fish
tissues.
In
determining
effluent
guidelines
and
the
sampling
of
hazardous
chemicals
in
water
and
in
fish
tissues,
IUR
information
will
assist
OW
in
narrowing
their
focus
on
specific
industrial
chemical
uses
or
chemicals
most
likely
to
be
released
to
water.
The
IUR
will
help
the
OW
to
be
more
efficient
by
quickly
developing
a
narrow
set
of
chemicals,
organized
by
industry
or
use,
for
further
consideration
when
setting
effluent
guidelines,
developing
other
regulations,
or
making
other
risk
management
decisions.

°
The
Office
of
Solid
Waste
and
Emergency
Response
(
OSWER)
will
be
able
to
identify
hazardous
constituents
in
waste
streams
using
the
IUR
information.
Under
RCRA,
most
often,
industrial
wastes
are
assigned
a
waste
identification
code.
These
codes
are
based
on
the
process
rather
than
the
actual
chemical
constituents
in
the
waste.
As
a
result,
many
chemical
constituents
in
RCRA
wastes
are
not
yet
identified.
The
IUR
will
provide
chemical
use
information
that
will
allow
EPA
to
better
understand
the
actual
chemicals
present
in
RCRA
wastes.
Chemicals
absent
from
RCRA
waste
streams
will
also
be
identified.

°
Once
OSWER
identifies
waste
streams
that
contain
known
hazardous
chemicals,
the
IUR
will
help
to
encourage
and
advance
waste
minimization
activities.
The
IUR
will
also
enable
OSWER
to
identify
chemicals
for
Listing
and
Delisting
in
RCRA
rules.
OSWER
13
uses
chemical
usage
trends
to
determine
inclusion/
exclusion
of
chemicals
for
rule
making.
If
OSWER
determines
that
a
particular
chemical
is
no
longer
used
in
a
particular
process,
then
the
chemical
might
be
excluded
from
reporting
under
that
rule.

°
OSWER
may
identify
National
Priority
List
sites
[
i.
e.,
Superfund
sites]
using
the
IUR
Amendments
data.
Based
on
the
types
of
industry
and/
or
operations
that
existed
at
the
site,
IUR
information
could
provide
types
of
chemicals
handled
at
a
particular
site,
which
will
aid
EPA
to
eliminate
chemicals
as
potential
contaminants
in
the
soil
and
water.

°
The
Office
of
Air
and
Radiation
(
OAR)
will
be
able
to
identify
which
chemicals
may
or
may
not
be
released
to
the
air.
OAR
needs
to
determine
the
need
for
and
needs
to
revise
Clean
Air
Act
regulations
for
chemicals
released
to
the
air
from
stationary
and
mobile
sources.
The
new
IUR
data
can
provide
information
on
how
these
chemicals
are
used,
information
needed
to
determine
how
they
are
released.

°
The
Office
of
Research
and
Development
(
ORD)
will
be
able
to
use
the
new
IUR
data
as
a
tool
in
a
variety
of
EPA
programs.
The
IUR
data
could
enable
ORD
to
devise
more
precise,
sensitive
tools
that
are
used
in
EPA
programs
such
as
Project
XL,
sector
initiatives,
site­
specific
pollution
prevention
and
multimedia
initiatives,
Green
Chemistry,
and
DfE.

Potential
Uses
of
the
Data
by
Other
Federal
Agencies
°
The
TSCA
Interagency
Testing
Committee
(
ITC)
will
use
the
IUR
data
to
identify
chemicals
as
candidates
to
recommend
for
further
testing
or
information
reporting.
In
this
process,
many
chemicals
are
eliminated
for
which
they
do
recommend
further
testing.
The
ITC
has
sixteen
(
16)
U.
S.
Government
member
organizations:
the
Agency
for
Toxic
Substances
and
Disease
Registry
(
ATSDR),
Council
on
Environmental
Quality
(
CEQ),
Consumer
Product
Safety
Commission
(
CPSC),
Department
of
Agriculture
(
USDA),
Department
of
Defense
(
DOD),
Food
and
Drug
Administration
(
FDA),
Department
of
the
Interior
(
DOI),
EPA,
Department
of
Commerce
(
DOC),
National
Cancer
Institute
(
NCI),
National
Institute
of
Environmental
Health
Sciences
(
NIEHS),
National
Institute
for
Occupational
Safety
and
Health
(
NIOSH),
National
Library
of
Medicine
(
NLM),
National
Science
Foundation
(
NSF),
National
Toxicology
Program
(
NTP)
and
Occupational
Safety
and
Health
Administration
(
OSHA).)
The
ITC
could
use
the
IUR
information
to
refine
its
selection
of
chemicals
for
testing,
information
reporting,
or
another
recommendation.
Currently
the
primary
exposure
information
the
ITC
uses
is
production
volume
from
the
IUR;
the
addition
of
use
and
exposure
information
would
allow
ITC
to
refine
its
recommendations.
For
instance,
in
1991,
OSHA
asked
ITC
to
review
a
list
of
chemicals
to
recommend
for
dermal
absorption
testing
­
ITC
recommended
80
chemicals
for
testing.
With
the
additional
IUR
information,
ITC
could
have
screened
those
80
chemicals
and
provided
a
more
accurate,
targeted
recommendation.
14
°
The
addition
of
information
that
links
the
number
of
potentially
exposed
workers
to
specified
quantities
of
specific
chemicals
at
specific
establishments
would
be
extremely
useful
to
OSHA
in
setting
priorities,
developing
health
standards,
and
targeting
intervention
efforts
including
outreach
and
training.
OSHA
strongly
supports
EPA's
collection
of
information
on
the
processing
and
use
of
chemicals.
This
information
will
be
instrumental
in
helping
OSHA
identify
which
industry
groups
have
a
greater
potential
for
worker
exposure
issues,
to
identify
which
chemicals
have
limited
concerns
and
which
are
of
potential
concern
to
which
industries,
and
to
identify
changes
in
industry
behavior
and
use
patterns.
However,
OSHA
would
prefer
that
this
information
come
from
all
manufacturing
sites
required
to
report
and
not
just
from
chemicals
with
volumes
of
300,000
pounds
or
greater.

°
The
U.
S.
Consumer
Product
Safety
Commission
(
CPSC)
will
utilize
the
IUR
data
to
assist
in
identifying
household
chemical
product
ingredients,
which
may
lead
to
a
determination
of
which
products
should
be
labeled
as
"
hazardous
substances."
Currently,
there
is
no
comprehensive
source
of
information
on
the
ingredients
of
household
chemical
products
and
CPSC
does
not
have
the
authority
to
collect
this
type
of
information.
The
amended
IUR
use
and
exposure
information
can
be
used
to
screen
household
chemical
products
in
the
Chemical
Hazard
Program,
helping
to
determine
which
products
need
to
include
or
eliminate
use
restrictions.
CPSC
may
also
use
the
IUR
information
to
help
determine
which
products
should
be
in
child­
resistant
packaging
under
CPSC's
poison
prevention
activities.

°
The
National
Toxicity
Program
(
NTP)
will
identify
candidates
for
toxicity
testing.
NTP
determines
the
need
for
federally­
funded
research
for
determining
the
toxicity
of
chemicals.
The
IUR
information
could
be
used
to
identify
the
chemicals
with
exposure
concerns,
thereby
identifying
those
chemicals
for
which
NTP
will
need
to
determine
the
toxicity.

°
In
the
past,
the
Drug
Enforcement
Agency
(
DEA)
has
requested
IUR
data
on
specific
chemicals
in
their
fight
against
the
illegal
manufacture
of
controlled
substances.

Potential
Uses
of
the
Data
by
States
°
State
Pollution
Prevention
(
P2)
Initiatives:
The
IUR
can
provide
the
data
needed
by
states
to
focus
their
multimedia
pollution
prevention
(
P2)
initiatives.
These
initiatives
have
both
voluntary
and
regulatory
components.
While
the
initiatives
vary
from
state
to
state
in
focus
and
design,
a
shared
characteristic
is
that
there
is
an
initial
examination
of
the
whole
plant,
the
full
range
of
public
health
and
environmental
protection
issues,
and
existing
regulatory
controls.
Through
this
multifaceted,
multi­
media
review,
the
states
reexamine
the
overall
management
scheme
and,
in
partnership
with
industry,
rework
the
overall
management
plan
to
more
efficiently
address
environmental
and
public
health
risk.
15
Improved
targeting
of
these
programs,
possible
with
the
use
of
the
IUR
data,
would
save
both
the
program
office
and
industry
partners
time
and
money.

°
Other
State
Programs:
States
can
utilize
the
IUR
information
to
supporting
their
State
Regulatory
Development
Processes.
The
IUR
provides
information
to
states
for
use
in
addressing
Federal
delegated
responsibilities
(
CAA
and
CWA
permit
authorities,
etc.)
and
state
authorities
(
California
Proposition
65,
etc).

3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
The
data
included
in
this
information
collection
(
i.
e.,
production
volume,
chemical
exposure
and
use
data)
are
not
comprehensively
or
systematically
collected
at
the
national
level.
There
are
a
variety
of
sources
for
pieces
of
the
information,
but
the
sources
are
either
incomplete
or
incompatible.
For
instance,
information
currently
available
at
both
the
federal
and
state
levels
is
collected
to
support
specific
federal
and
state
programs,
initiatives,
or
regulatory
actions.
As
an
example,
under
EPCRA
sections
311
and
312,
states
collect
data
on
the
maximum
and
average
amount
of
a
chemical
onsite
for
the
purposes
of
emergency
response
planning.
This
information
does
not
substitute
for
the
annual
volume
of
a
chemical
and
is
not
available
for
use
in
a
nationallevel
screening
program.

Before
amending
the
IUR,
EPA
explored
a
wide
variety
of
public
data
sources,
as
demonstrated
by:
Inventory
Update
Rule
(
IUR)
Amendments
Technical
Support
Document:
Exposure­
Related
Data
Useful
for
Chemical
Risk
Screening
(
EPA
1996),
Revised
Economic
Analysis
of
the
Amended
Inventory
Update
Rule
(
EPA
2002),
and
A
Review
of
Existing
Exposure­
Related
Data
Sources
and
Approaches
to
Screening
Chemicals:
A
Response
to
CMA
(
EPA
1999).
These
documents
contain
extensive
discussions
of
current
chemical
information
collections
and
conclude
that
the
information
to
be
collected
in
the
amended
IUR
is
not
available
elsewhere.
EPA
has
spent
considerable
effort
and
resources
evaluating
other
data
sources
that
could
potentially
provide
the
accurate
and
up­
to­
date
information
that
the
Agency
needs.
A
primary
consideration,
as
mandated
by
TSCA,
was
not
to
subject
industry
to
unnecessary
or
duplicative
reporting.
The
information
sought
under
the
IUR
is
not
accessible
to
EPA
through
other
means.
Although
some
useful
data
exist
in
some
sources,
the
data
are
insufficient
due
to
a
lack
of
scope,
currentness,
and
detail.
Without
the
IUR,
EPA
can
not
update
the
TSCA
Inventory
as
required
by
law,
and
remains
unable
to
efficiently
screen
potential
risks
posed
by
a
large
number
of
chemicals
on
the
TSCA
Inventory.

One
mechanism
in
particular
received
scrutiny
from
EPA
as
an
alternative
to
the
updated
IUR:
the
TSCA
Preliminary
Assessment
Information
Reporting
(
PAIR)
rule
(
40
CFR
part
712).
EPA
does
not
feel
that
PAIR
would
be
an
efficient
or
cost­
effective
way
to
compile
a
database
to
16
allow
the
large­
scale
risk
screening
of
chemicals
on
the
TSCA
Inventory.
PAIR
is
a
useful
data
collection
tool
when
one
or
a
small
group
of
chemicals
is
targeted
for
risk
assessment;
however,
PAIR
is
limited
when
collecting
information
on
a
large
number
of
chemicals.
Additionally,
the
PAIR
rule
has
fewer,
less
definitive
data
elements
than
the
amended
IUR,
is
a
one­
time
collection
versus
the
four­
(
soon
to
be
five)
year
collection
cycle
of
the
IUR,
and
will
not
provide
data
sufficient
to
meet
the
goals
of
the
IUR.
Use
of
PAIR
only
implies
that
EPA
should
continue
to
set
risk­
screening
priorities
based
on
hazard
and
production
volume
alone,
or
in
response
to
requests
from
others.
This
approach
greatly
hinders
EPA's
ability
to
make
effective
and
efficient
risk
management
decisions.

EPA
plans
to
continue
using
existing
data
sources
and
information
sets.
However,
the
existing
sources
are
generally
best
used
when
conducting
a
more
detailed
risk
assessment
of
a
specific
chemical
of
concern,
rather
than
preliminary
risk
screening
of
a
large
set
of
chemicals.
The
amended
IUR
submissions
will
provide
a
consistent
set
of
screening­
level
exposure
data
that
will
allow
EPA
to
better
identify
on
a
relative
basis
the
chemicals
of
highest
priority
for
further
risk
evaluation.
EPA
will
use
the
amended
IUR
data
to
identify
those
specific
chemicals
that
are
of
potential
concern
and
need
follow
up
assessment.
For
instance,
the
IUR
exposure
data
coupled
with
the
HPV
Challenge
Program
hazard
data
will
provide
the
input
needed
to
effectively
develop
risk­
based
priorities
for
more
detailed
assessment
of
chemicals.
Once
EPA
has
determined
that
a
specific
chemical
(
or
group
of
chemicals)
has
sufficient
potential
for
exposure
to
warrant
further
assessment,
the
Agency
will
utilize
the
other
information
sources
and
data
gathering
tools
as
appropriate.

The
IUR
focuses
on
information
specific
to
the
manufacture
and
use
of
chemicals,
including
exposure
potentials
during
various
activities;
this
information
is
not
available
elsewhere.
One
past
source
of
data,
NIOSH's
National
Occupational
Exposure
Survey
(
NOES),
represented
a
valuable
source
of
data
concerning
the
number
of
exposed
workers.
NOES
was
completed
in
1981
and
is
now
recognized
as
being
significantly
dated.
Furthermore,
information
regarding
chemical
use
has
never
been
collected
in
a
systematic
manner.

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.
17
3(
c)
Consultations
During
and
since
promulgating
the
2003
Amendments
to
the
IUR,
EPA
has
consulted
with
potential
respondents
to
the
IUR
in
multiple
ways.
First,
a
series
of
three
focus
groups
were
held
across
the
U.
S.
to
solicit
input
into
refining
the
IUR
Instruction
Manual,
to
help
develop
Case
Studies,
and
to
compile
a
Questions
and
Answers
document.
The
focus
groups
were
designed
to
review
the
various
documents,
ensure
that
industry
concerns
were
addressed,
that
the
reporting
requirements
were
clear,
and
that
various
scenarios
experienced
by
industry
were
covered.
Industry
comments
resulted
in
major
changes
to
all
of
the
documents.

Second,
meetings
were
held
with
interest
groups
and
representatives
of
their
industrial
members
to
undertake
trial
reports
for
chemicals
subject
to
IUR
reporting
and
to
develop
case
studies
based
on
information
provided
by
the
industrial
representatives.
The
result
was
a
series
of
case
studies
illustrating
the
thought
process
and
steps
necessary
to
prepare
submissions
to
comply
with
the
IUR.

Third,
through
meeting
with
affected
industry
groups,
individuals,
and
participants
at
the
focus
groups
mentioned
above,
lists
of
questions
were
generated
that
were
compiled
into
an
IUR
Questions
and
Answers
document
intended
to
provide
persons
subject
to
the
IUR
a
reference
addressing
the
spectrum
of
anticipated
inquiries
concerning
reporting
under
the
IUR.

Fourth,
some
industry
volunteers
reviewed
a
prototype
of
the
IUR
electronic
reporting
form
and
others
provided
comments
during
presentations
describing
the
IUR
that
were
held
at
industry
meetings.
The
industry
comments
were
very
helpful
in
refining
the
form,
and
for
identifying
issues
that
many
of
the
larger
companies
face
in
responding
to
the
IUR
reporting
requirements.
For
instance,
the
Agency
now
plans
to
provide
companies
with
the
schema,
which
will
allow
the
larger
companies
to
skip
the
interactive
electronic
reporting
form.

And
fifth,
further
consultations
were
held
with
industry
through
settlement
discussions,
which
resulted
in
the
proposed
IUR
Revisions
rule
(
70
FR
3658)
that
reduce
the
burden
associated
with
this
reporting.
The
greatest
change
resulting
from
the
industry
discussion
is
to
restrict
the
reporting
of
processing
and
use
information
to
domestic
use
only,
thereby
eliminating
the
burden
associated
with
reporting
for
chemicals
processed
and
used
outside
of
the
U.
S.

3(
d)
Effects
of
Less
Frequent
Collection
The
Agency
needs
to
be
able
to
make
accurate
chemical
regulatory
decisions
in
a
timely
and
cost
effective
manner,
especially
since
alternative
data
sources
do
not
exist
for
these
data.
The
effect
of
less
frequent
collection
of
these
data
is
that
the
Agency's
ability
to
understand
the
chemical
industry
and
monitor
the
production
levels
of
chemicals
produced
or
imported
in
the
United
States
would
be
significantly
diminished.
Based
on
IUR
data,
the
statistics
show
that
chemical
industry
product
lines
and
manufacturing
in
the
United
States
change
rapidly
from
one
reporting
period
to
the
next.
This
demonstrates
that
the
IUR
exercise
needs
to
be
undertaken
on
18
an
ongoing
basis
in
order
for
the
Agency
to
fulfill
its
mandate
to
keep
the
TSCA
Inventory
current
under
section
8(
b)
of
TSCA.

EPA
retained
the
four
year
cycle
for
the
first
IUR
collection
subsequent
to
the
2003
Amendments
because
it
has
a
vital
need
for
the
new
information
added
by
the
2003
Amendments,
such
as
processing
and
use
information.
After
the
first
IUR
collection
of
the
new
data,
EPA
intends
to
increase
the
reporting
cycle
to
every
five
years,
as
proposed
in
the
IUR
Revisions
rule
(
70
FR
3658).

Any
further
decrease
in
the
reporting
frequency
would
jeopardize
the
utility
of
the
data
in
decision
making.
Experience
with
the
past
IUR
collections
illustrates
that
from
one
collection
to
the
next
(
four
years),
there
was
a
turnover
in
chemicals
reported
of
about
25­
30%,
that
is,
twentyfive
to
thirty
percent
of
the
chemicals
reported
in
one
year
were
not
reported
in
the
next
year.
Less
frequent
collection
would
increase
this
turnover,
reducing
the
utility
of
the
database.

Other
dynamic
aspects
of
the
chemical
industry
are
less
easy
to
measure.
Production
volumes
or
chemical
uses
can
change
from
one
year
to
the
next,
due
to
activities
such
as
changing
market
conditions,
batch
processing,
or
the
development
of
new
uses
for
the
chemical.
Production
sites
switch
owners
and
the
products
produced
at
a
site
can
change.
Less
frequent
collection
would
mean
the
EPA
could
be
using
outdated
information,
making
decisions
that
reflect
a
situation
no
longer
in
existence.

3(
e)
General
Guidelines
This
collection
does
not
exceed
any
of
the
Paperwork
Reduction
Act
guidelines
at
5
CFR
1320.6,
with
the
exceptions
listed
below.

EPA
has
increased
the
record
retention
period
of
this
collection
by
one
year,
resulting
in
a
retention
period
of
five
years
for
the
four­
year
reporting
cycle,
exceeding
the
PRA
maximum
of
three
years.
This
is
necessary
to
ensure
companies
retain
records
long
enough
to
facilitate
Form
U
completion
in
the
next
collection,
and
to
allow
EPA's
enforcement
activities
to
cover
two
IUR
reporting
cycles.

Confidential
Business
Information
(
CBI)
claims
limit
access
to
the
IUR
data,
especially
by
the
general
public.
EPA
recognizes
that
some
information
submitted
to
the
Agency
is
legitimately
business
confidential;
because
of
this,
EPA's
review
of
CBI
data
is
an
inherently
governmental
function
that
EPA
must
perform
to
protect
human
health
and
the
environment.
EPA
has
amended
some
IUR
CBI
policies
to
insure
CBI
claims
are
well­
considered
by
submitters,
to
insure
the
claims
are
limited
to
those
permitted
under
TSCA.
Specifically,
EPA
(
1)
allows
submitters
to
report
production
volume
in
ranges,
and
(
2)
insures
that
site
identity
is
claimed
as
CBI
only
when
such
information
is
not
publicly
available.
19
3(
f)
Confidentiality
Respondents
may
claim
information
submitted
to
EPA
under
this
rule
as
confidential
if
such
information
would
reveal
the
submitters'
trade
secrets
or
proprietary
information
as
defined
by
TSCA
section
14
and
existing
TSCA
regulations.
EPA
has
long­
established
procedures
for
handling,
storing,
processing
and
disposing
of
TSCA
confidential
information.
Transfers
of
this
information
to
other
governmental
agencies
can
only
be
accomplished
if
the
other
agency
agrees
to
adhere
to
all
TSCA
confidentiality
provisions.
EPA
will
maintain
standard
CBI
procedures
to
protect
any
confidential,
trade
secret,
or
proprietary
information
from
disclosure
in
accordance
with
EPA's
confidentiality
regulation,
40
CFR
Part
2,
Subpart
B.

3(
g)
Sensitive
Questions
This
collection
does
not
include
questions
of
a
sensitive
nature.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondent
NAICS
Codes
The
regulated
community
consists
of
companies
manufacturing
or
importing
chemicals
listed
on
the
TSCA
Inventory
and
regulated
under
TSCA
section
8.
In
general,
the
industry
segments
that
compose
the
regulated
community
for
the
rule
are
those
that
produce
or
import
organic
and
inorganic
chemicals.
Most
respondents
previously
reported
information
under
the
IUR;
some
manufacturers
of
inorganic
chemical
substances
that
were
exempt
are
now
required
to
report.
Due
to
the
past
experience
the
Agency
has
had
with
respondents
to
the
IUR,
it
is
anticipated
that
the
majority
of
the
respondents
affected
by
this
collection
activity
are
from
the
following
North
American
Industrial
Classification
System
(
NAICS)
code
categories:

325
­
Chemical
Manufacturing
(
including
importing)
324
­
Petroleum
and
Coal
Product
Manufacturing
(
including
importing)

The
subsectors
identified
above
represent
the
designation
of
sites
that
would
likely
be
subject
to
IUR
reporting.
However,
many
factors
relate
to
the
nature
of
these
sites,
making
identification
of
the
regulated
community
more
difficult.
For
example,
NAICS
codes
reflect
a
site's
primary
activity,
omitting
substantial
participation
a
company
may
have
in
other
industry
activities.
Secondly,
NAICS
codes
assigned
to
parent
companies
reflect
the
parent
company's
primary
activity,
although
many
parent
companies
are
primarily
holding
companies
with
small
subsidiaries.
Each
of
these
small
subsidiaries
may
belong
in
a
completely
different
industry
classification
based
on
its
own
primary
activity.
Information
on
parent
company
NAICS
codes
does
not
provide
a
very
accurate
characterization
of
the
types
of
sites
subject
to
reporting,
and
facilities
that
do
not
fall
under
these
categories
must
still
report
if
they
meet
the
reporting
criteria.
20
Generally,
TSCA
section
8
excludes
small
manufacturers
and
importers
from
reporting.
EPA
defines
small
manufacturers
and
importers
for
purposes
of
IUR
and
certain
other
reporting
in
40
CFR
704.3.

4(
b)
Information
Requested
(
i)
Data
items
The
IUR
data
elements
are
primarily
related
to
or
indicative
of
three
components
of
exposure.
These
components
are:
(
1)
the
number
of
ecosystems
or
size
of
human
populations
potentially
exposed,
(
2)
the
potential
exposures
or
concentrations
experienced
by
the
environment
or
humans,
and
(
3)
the
frequency
and
duration
of
potential
exposures.
These
data
can
improve
the
EPA's
ability
to
evaluate
each
of
these
components
of
exposure.
The
production
volume
information
collected
by
the
IUR,
while
valuable,
cannot
effectively
be
used
as
the
sole
surrogate
for
these
three
components
of
exposure
and
does
not
result
in
effective
risk
screening
or
a
reasoned
listing
of
EPA
priorities
for
follow
up
risk
assessment
and
risk
management.
Respondents
will
be
required
to
submit
certain
readily
obtainable
exposure­
related
information.

Using
Form
U
(
see
Attachment
4),
respondents
report
on
data
items
as
follows:


Certification.
Company
Official
must
certify
by
signature
and
date
that
to
the
best
of
their
knowledge
and
belief
1)
all
information
entered
on
Form
U
is
complete
and
accurate;
and
2)
that
the
confidentiality
statements
on
Form
U
are
true
and
correct.


Parent
Company
and
Technical
Contact
Information.
Company
name,
Dun
and
Bradstreet
number
for
company,
Technical
Contact
name,
phone
number,
mailing
address,
and
email
address.


Plant
Site
Identification.
Plant
Site
name,
Dun
and
Bradstreet
number
for
site,
and
street
address
(
including
county).


Chemical
Identification.
Identity
of
each
chemical
(
name
and
CAS
registry
number).


Manufacturing
Information.
Whether
chemical
is
site­
limited
or
not,
whether
chemical
is
manufactured
or
imported,
production
volume,
approximate
number
of
workers
potentially
exposed,
maximum
concentration
of
chemical,
and
physical
form
of
chemical.


Industrial
Processing
and
Use
Data
(
only
for
chemicals
with
production
volumes
greater
than
or
equal
to
300,000
lb/
year).
Functional
use
category
in
industrial
settings
of
chemical
substance,
North
American
Industrial
Classification
System
(
NAICS)
codes
of
processing
and
use
sites,
industrial
function
category,
percentages
of
respondent's
production
volume
in
each
industrial
use
category,
approximate
numbers
of
processing
and
use
sites,
and
approximate
number
of
exposed
workers.
21

Commercial
and
Consumer
End­
use
Exposure
Data
(
only
for
chemicals
with
production
volumes
greater
than
or
equal
to
300,000
lb/
year).
Consumer
use
category
of
chemical
substance,
whether
a
chemical
is
used
in
children's
products,
percentages
of
respondent's
production
volume
in
each
commercial
and
consumer
use
category,
and
maximum
concentration
of
chemical
in
each
commercial
and
consumer
use
category.

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

(
xxxii)
Compliance
Determination
­­
determining
whether
reporting
is
required
for
a
chemical
manufactured
at
a
particular
site,
based
on
the
production
volume
thresholds
and
the
applicability
of
certain
reporting
exemptions;

(
xxxiii)
Rule
Familiarization
­­
becoming
familiar
with
the
full
requirements
of
the
rule,
which
entails
reading
the
rule,
understanding
the
various
reporting
and
administrative
requirements,
and
determining
the
manner
in
which
reporting
requirements
will
be
met
for
each
chemical.

(
xxxiv)
Preparation
and
Submission
of
Reports
­­
compiling
the
required
information
and
completing
a
reporting
form,
including
determining
the
CBI
status
of
information
and
fulfilling
appropriate
substantiation
measures;
and
(
xxxv)
Recordkeeping
­­
retaining
records
for
five
years
following
a
submission
period.

In
addition
to
the
expanded
Form
U,
the
2003
amendments
to
the
IUR
included
the
following
changes:


Changes
to
the
set
of
chemical
substances
subject
to
reporting.
EPA
replaced
the
current
exemption
for
inorganic
chemical
substances
with
a
partial
exemption
in
the
2006
reporting
cycle,
followed
by
full
reporting
in
subsequent
cycles.
EPA
also
added
a
partial
exemption
for
non­
single
chemical
petroleum
streams
and
for
certain
specifically
listed
chemical
substances,
and
a
full
exemption
for
natural
gas.


Changes
to
the
reporting
threshold.
EPA
created
a
two­
tiered
threshold.
The
former
10,000­
pound
reporting
threshold
was
raised
to
25,000
pounds.
A
second
threshold
of
300,000
pounds
was
established
for
reporting
processing
and
use
information.


Changes
to
the
reporting
time
frame.
EPA
changed
the
time
frame
covering
production
or
import
of
a
chemical
to
a
calendar­
year
basis
from
the
current
corporate
fiscal­
year
basis.
22

Changes
to
CBI
requirements.
EPA
made
two
confidential
business
information
changes:
1)
up­
front
substantiation
requirement
for
site
identification
CBI
claims,
and
2)
requiring
respondents
to
make
a
separate
confidentiality
claim
for
production
volume
ranges,
in
addition
to
those
for
exact
production
volumes.
This
second
requirement
would
be
rescinded
by
the
proposed
IUR
Revisions
Rule
(
70
FR
3658).


Changes
the
recordkeeping
requirement.
EPA
increased
the
recordkeeping
requirement
from
four
years
to
five
years.

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


review
and
verify
forms
as
they
are
received;


answer
respondent's
questions
and
provide
any
necessary
assistance;


process
submissions
for
inclusion
in
IUR
database;


review
requests
for
confidentiality
in
the
submissions;


maintain
the
database;


distribute
the
data.

5(
b)
Collection
Methodology
and
Management
The
information
collection
activity
under
this
rule
includes
an
initial
reporting
period
(
which
took
place
during
1986)
and
subsequent
reporting
periods
(
1990,
1994,
1998
and
2002).
For
each
reporting
period,
all
manufacturers
(
including
importers),
except
for
those
defined
as
"
small
manufacturers,"
are
required
to
submit
on
every
substance
required
under
this
rule.
After
the
initial
reporting
period,
subsequent
reports
are
required
every
four
years,
although
EPA
plans
to
extend
this
reporting
cycle
to
five
years
after
the
next
IUR
collection
in
2006.
The
substantive
information
requirements
of
the
2006
reporting
period
have
been
revised
substantially
from
the
2002
collection.
Under
the
2003
Amendments
to
the
IUR,
which
published
in
January
2003
(
68
FR
848),
U.
S.
manufacturers
of
chemicals
(
no
longer
limited
to
just
organic
chemicals)
are
now
required
to
report
to
EPA
every
4
years
the
identity
of
chemical
substances
manufactured
during
the
reporting
year
in
quantities
of
25,000
pounds
or
more
at
any
plant
site
they
own
or
control.
The
IUR
continues
to
exclude
several
categories
of
substances
from
its
reporting
requirements,
i.
e.,
polymers,
microorganisms,
and
naturally
occurring
chemical
substances.
Inorganic
chemicals
are
no
longer
exempt
and
certain
natural
gas
substances
are
now
exempt.
In
addition
to
the
information
reported
prior
to
the
amendments,
submitters
now
also
are
required
to
report
23
additional
manufacturing
exposure­
related
data,
including
the
physical
form
and
maximum
concentration
of
the
chemical
substance
and
the
number
of
potentially
exposed
workers.

The
2003
Amendments
to
the
IUR
also
established
a
second
reporting
threshold
for
larger
volume
chemicals
of
300,000
pounds
or
more
manufactured
during
the
reporting
year
at
any
plant
site
for
reporting
of
certain
processing
and
use
information
(
40
CFR
710.52(
c)(
4)).
This
information
includes
process
or
use
category,
NAICS
code,
industrial
function
category,
percent
production
volume,
number
of
use
sites,
number
of
potentially
exposed
workers,
and
consumer/
commercial
information
such
as
use
category,
use
in
or
on
products
intended
for
use
by
children,
and
maximum
concentration.
For
the
first
IUR
submission
period
subject
the
these
Amendments,
occurring
in
2006,
inorganic
chemicals,
regardless
of
production
volume,
are
partially
exempt
(
i.
e.,
submitters
do
not
report
processing
and
use
information
for
inorganic
chemicals).
After
the
first
reporting
period,
the
partial
exemption
for
inorganic
chemicals
will
no
longer
be
applicable,
and
submitters
will
be
required
to
fully
report
information
on
inorganic
chemical
substances.
In
addition,
specifically
listed
petroleum
process
streams,
and
other
specifically
listed
chemical
substances,
are
partially
exempt,
and
manufacturers
of
such
substances
are
not
required
to
report
processing
and
use
information.

(
i)
Collection
Methodology
Respondents
will
be
able
to
obtain
the
reporting
form
in
a
variety
of
ways,
as
follows:


EPA
will
mail
a
reporting
package
to
companies
who
reported
during
the
previous
reporting
cycle.


Respondents
will
be
able
to
obtain
reporting
packages
from
the
TSCA
Hotline.


Respondents
will
be
able
to
download
the
reporting
form
from
the
Internet.

In
submitting
the
information
associated
with
this
data
collection,
respondents
will
be
able
to
choose
either
a
mail­
in
form
or
an
electronic
form
(
on
a
disk).
EPA
has
considered
electronic
submissions
using
the
Internet,
but
at
this
time
is
unable
to
guarantee
security
of
CBI
submitted
in
that
manner.
Respondents
are
encouraged
to
use
electronic
submission
whenever
possible.
About
half
of
the
respondents
reported
electronically
during
the
2002
collection.
This
is
expected
to
increase
for
the
2006
collection.
Increased
use
of
electronic
submissions
have
increased
the
quality
of
the
IUR
database
by
reducing
errors
due
to
manually
adding
information
to
the
database.

To
aid
persons
subject
to
the
IUR
information
collection,
OPPT
has
set
up
a
TSCA
Hotline
that
provides
information
regarding
the
TSCA
Inventory
reporting,
as
well
as
other
regulatory
information.
When
Hotline
staff
are
unable
to
answer
questions
regarding
the
IUR,
the
questions
are
referred
to
EPA's
Information
Management
Division
(
IMD)
staff
for
appropriate
resolution.
Other
Divisions
within
OPPT
will
be
used
as
necessary.
IMD
is
also
responsible
for
providing
access
to
the
data.
24
Companies
reporting
to
the
IUR
will
be
encouraged
to
report
electronically
on
magnetic
media.
Initial
data
receipt
and
processing
activities
(
data
entry,
quality
assurance,
CBI
claim
reviews,
etc.)
will
be
expedited
by
the
receipt
of
the
data
electronically.
EPA
expects
that
receiving
the
additional
information
required
under
the
rule
will
have
a
negligible
impact
on
its
front
end
processing
activities.
Optional
Character
Recognition
(
OCR)
technology
will
be
employed
to
facilitate
processing
of
reports
received
in
hard
copy.

(
ii)
Data
Management
This
section
describes
the
Agency
tasks
required
for
efficiently
processing
submissions
under
the
IUR.
The
tasks
for
which
the
Agency
is
responsible
are
presented
under
four
main
categories:
database
systems
development,
guidance
document
development,
Form
U
processing,
and
additional
tasks.
The
task
descriptions
presented
below
generally
do
not
change.

Information
will
be
used
to
update
and
augment
the
CUS
and
Chemicals
in
Commerce
Information
System
(
CICIS)
databases.
These
databases
will
then
be
available
to
EPA
technical
reviewers
for
export
into
their
various
analytical
modeling
systems
and
databases.
The
IUR
database
will
also
be
available
for
quick
screening
and
other
direct
uses.
Non­
CBI
information
will
be
publically
available.


Database
Systems
Development
and
Maintenance
­­
The
Agency
is
responsible
for
having
adequate
information
systems
in
place
to
support
the
CUS
that
serves
as
the
primary
data
storage
medium
for
IUR
collections.
File
servers
with
appropriate
backup
are
used
to
contain
the
IUR
databases.
In
addition,
IUR
data
are
tracked
via
the
correspondence
tracking
system
utilized
by
the
Confidential
Business
Information
Tracking
System
(
CBITS)
located
within
the
Confidential
Business
Information
Center
(
CBIC).


Guidance
Document
Development
­­
The
Agency
is
responsible
for
developing
guidance
for
the
IUR
to
assist
reporters
in
complying
with
IUR
requirements.
The
guidance
documents
usually
are
developed
by
a
contractor
with
oversight
by
Agency
personnel.


Form
U
Processing
­­
The
Agency
is
responsible
for
handling
processing
of
IUR
submissions.
This
includes
developing
standard
operating
procedures
and
documentation
for
all
stages
in
the
IUR
document
life
cycle,
document
receipt
and
tracking,
data
input,
quality
control,
file
and
database
maintenance,
information
security,
CBI
aggregation
policy,
data
dissemination,
and
staff
training.


Additional
Activities
­­
The
Agency
publishes
and
prints
the
IUR
form
and
other
miscellaneous
materials.
In
addition,
the
Agency
is
responsible
for
providing
the
TSCA
Hotline
with
standardized
responses
for
frequently
asked
questions;
25
preparing
mailings,
mailing
lists,
and
labels;
and
developing
outgoing
information
materials.

The
2003
Amendments
to
the
IUR
will
require
that
the
Agency
expand
the
database
to
handle
the
additional
reporting
requirements.
Revising
the
CUS
entails
the
following
tasks:

­­
procurement
of
new
hardware
and
software;
­­
contractor­
supported
programming
for
database
redesign;
­­
development
of
new
input
modules
to
facilitate
scanning
and
text
recognition
of
paper
versions,
these
include
a
manual
data
entry
module,
an
electronic
(
ASCII)
version
of
the
form,
and
subsequent
upload
modules;
­­
creation
of
retrieval
modules
that
standardize
reports;
and
­­
incorporation
of
CBI
protection
into
the
design
of
the
system.

5(
c)
Small
Entity
Flexibility
Ample
flexibility
is
provided.
This
regulation
affects
only
businesses;
governmental
jurisdictions
and
not­
for­
profit
organizations
are
not
required
to
take
any
action.
Small
manufacturers,
including
importers,
as
defined
in
the
rule,
are
generally
not
subject
to
any
of
the
reporting
or
recordkeeping
requirements
and
are
exempt.
In
accordance
with
TSCA
section
8(
b)
(
40
CFR
Sections
710.29
and
710.28),
the
Inventory
Update
Rule
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
$
40
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
Economic
Analysis
for
the
Amended
Inventory
Update
Final
Rule
determined
that
the
impact
on
these
companies
is
significantly
less
than
1%
of
revenues
(
EPA,
2002).
EPA
has
determined
that
there
is
not
a
significant
economic
impact
on
a
significant
number
of
small
entities.

5(
d)
Collection
Schedule
The
reporting
period
shall
be
from
August
25
to
December
23,
2006,
though
the
proposed
IUR
Revisions
rule
would
move
the
reporting
period
forward
to
the
first
part
of
the
year
(
January
through
April)
to
allow
companies
to
report
as
soon
as
they
compile
the
data.
This
reporting
period/
schedule
follows
the
requirements
of
40
CFR
Ch.
1
Section
710.33(
b).

Federal
Register
Notice
May
2006
Letter
to
2002
IUR
mailing
list
June
2006
Send
out
letter
to
2002
IUR
mailing
list
June
2006
with
instructions
describing
how
to
obtain
the
26
reporting
documents;
Information
is
also
available
on
EPA's
web
page;
http://
www.
epa.
gov/
oppt/
iur.

Going
Public
efforts:
Include
June
2006
articles
in
industry
press,
meetings
with
regulated
community,
and
information
available
through
the
Internet.

Open
period
for
filing
2006
August
25,
2006
­
IUR
information
December
23,
2006
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
This
ICR
estimates
burden
for
an
information
collection
effort
that
reflects
the
requirements
of
the
2003
Amendments
to
the
Inventory
Update
Rule
(
IUR).
The
previous
IUR,
which
covered
five
collections
from
1986
to
2002,
required
chemical
manufacturers
and
importers
to
collect,
maintain,
and
submit
location
and
production
volume
information
for
chemicals
with
annual
production
volumes
of
10,000
pounds
or
higher.
The
IUR
Amendments
changed
this
reporting
threshold
to
25,000
pounds,
and
augmented
the
required
site
and
production
information.
The
Amendments
also
require
sites
with
production
volumes
of
300,000
pounds
or
higher
of
a
reportable
chemical
to
collect,
maintain,
and
submit
additional
information
to
EPA
regarding
chemical
processing
and
use.
In
addition,
manufacturers
of
inorganic
chemicals
are
no
longer
fully
exempt.
For
this
2006
submission
period,
inorganic
chemicals,
regardless
of
production
volume,
are
partially
exempt
(
i.
e.,
submitters
do
not
report
processing
and
use
information
for
inorganic
chemicals).
After
the
first
reporting
period,
the
partial
exemption
for
inorganic
chemical
manufacturers
is
no
longer
applicable
and
submitters
are
required
to
fully
report
information
on
inorganic
chemical
substances.
In
addition,
petroleum
process
streams
and
other
chemical
substances
specifically
listed
are
partially
exempt
from
the
information
collection.
Manufacturers
of
such
substances
are
not
required
to
report
processing
and
use
information.

The
burden
estimates
for
report
preparation
and
submission
were
derived
from
a
survey
conducted
by
EPA
in
1996
(
under
OMB
Control
No.
2070­
0034)
to
assess
the
potential
burden
associated
with
the
amended
IUR.
The
survey
was
distributed
to
previous
IUR
reporters
selected
from
the
CUS
database.
Burden
estimates
are
developed
for
the
compliance
activities
and
then
multiplied
by
the
number
of
facilities
or
reports
(
as
appropriate)
to
estimate
the
total
burden
to
respondents.
The
amount
of
effort
(
and
therefore
cost)
required
for
each
of
these
steps
varies
depending
on
the
type
of
chemical,
company
size,
and
the
variety
of
uses
of
the
chemical.
The
tasks
associated
with
IUR
reporting
during
the
period
of
this
ICR
are
those
listed
in
Section
4(
b)(
ii).
To
complete
the
collection,
the
respondent
would:
27
°
Determine
compliance;
°
Become
familiar
with
rule;
°
Prepare
and
submit
report;
and
°
Keep
records.

Worksheet
1
illustrates
the
respondents'
burden
of
collection
on
a
per­
collection
basis.
The
Agency
estimates
the
average
annual
respondent
burden
for
this
information
collection
activity
to
be
609
hours
for
organic
chemicals,
which
corresponds
to
a
cost
of
$
41,723.
All
estimates
are
based
on
the
"
high"
scenarios
in
the
Revised
Economic
Analysis
of
the
Amended
Inventory
Update
Rule
(
EPA
2002).
This
burden
estimate
assumes
that
each
of
the
2,482
organic
chemical
respondents
will
report
IUR
information
for
an
average
of
9
organic
chemicals
of
which
5.2
forms
will
be
partial
(
i.
e.,
chemicals
produced
in
quantities
less
than
300,000
pounds)
and
3.8
forms
will
be
full
(
i.
e.,
chemicals
produced
in
quantities
greater
than
300,000
pounds).
This
burden
estimate
results
in
an
average
per
chemical
burden
of
67.7
hours.

The
Agency
estimates
the
average
annual
respondent
burden
for
this
information
collection
activity
to
be
265
hours
for
inorganic
chemicals,
with
a
cost
of
$
18,185.
This
burden
estimate
assumes
that
each
of
the
544
inorganic
chemical
respondents
will
report
IUR
information
for
an
average
of
8.3
inorganic
chemicals
based
on
information
in
the
CUS
database,
with
an
average
per
chemical
burden
of
31.9
hours.
The
IUR
requires
reporting
on
a
"
per
site"
basis
rather
than
a
"
per
company"
basis.
There
are
no
third
party
burdens
associated
with
these
activities.

6(
b)
Estimating
Respondent
Cost
The
wage
rates
for
managerial,
technical,
and
clerical
skill
levels
were
developed
from
information
provided
by
the
Bureau
of
Labor
Statistics
(
BLS)
and
an
analysis
adopted
from
the
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313
(
EPA,
1997).
Worksheet
1
also
illustrates
the
respondents'
cost
of
reporting
on
a
per­
collection
basis.
The
costs
in
worksheet
1
have
been
updated
to
reflect
wages
rates
in
2000
dollars.
See
Attachment
5
for
a
discussion
of
the
development
of
rates
process.
28
Worksheet
1:
Respondent
Burden
and
Cost
Estimates,
Per
Activity
(
2000
$)

Activity
Burden
Hours
Total
Hours
Total
Costs
Managerial
@
$
95.55
Technical
@
$
65.96
Clerical
@
$
27.37
Compliance
Determination
(
per
site)
0.00
4.00
0.00
4.00
$
263.84
Rule
Familiarization
(
per
site)
10.00
20.00
0.00
30.00
$
2,274.68
Report
Preparation
and
Submission
(
per
report)

Partial
Form
5.73
11.36
2.56
19.65
$
1,366.70
Full
Form
25.98
66.75
12.54
105.27
$
7,228.54
Recordkeeping
(
per
report)
2.00
4.00
2.00
8.00
$
509.67
6(
c)
Estimating
Agency
Burden
and
Cost
Annual
costs
and
burden
to
the
Agency
under
the
IUR
have
been
estimated
by
calculating
the
number
of
full­
time
equivalents
(
FTEs)
required
to
undertake
certain
prescribed
tasks.
FTEs
are
converted
to
dollars
by
multiplying
estimated
FTE
yearly
earnings
for
the
appropriate
staff
level
(
GS
level)
by
the
number
of
FTEs
for
each
staff
level,
and
then
summing
the
products.
Yearly
earnings
have
been
calculated
to
include
fringe
benefits
of
41
percent
of
the
base
salary
and
overhead
costs
of
17
percent
of
the
base
salary
plus
the
fringe
benefits.
Additional
Agency
costs
have
been
estimated
based
on
the
budget
that
is
appropriated
for
the
IUR.

In
developing
the
cost
estimates
for
determining
Agency
burden,
activities
associated
with
one­
time
events
that
will
be
incurred
in
this
2006
reporting
period
are
distinguished
from
costs
incurred
in
each
collection
cycle.
Worksheet
2
presents
the
per­
cycle
Agency
costs
of
the
IUR
information
collection
including
the
amendments
while
worksheet
3
presents
the
one­
time
Agency
costs.
The
estimated
total
annualized
cost
incurred
by
the
Agency
is
calculated
by
summing
the
recurring
costs
and
the
one­
time
costs,
and
dividing
by
the
four
years
of
the
reporting
cycle,
which
yields
$
221,652.
29
Worksheet
2.
Estimated
Per­
Cycle
Agency
Costs
for
the
IUR
(
recurring
every
four
years)

Task
IUR
Costs
(
2000
$)

Tasks
Performed
by
Agency
Personnel
Quality
Control
of
Data
Entry
Data
Processing,
Systems
Development,
and
Contract
Oversight
and
Management
$
180,206
(
2
FTE,
GS­
12)
$
214,292
(
2
FTE,
GS­
13)

Subtotal
$
394,498
Extramural
Tasks
(
contractor)

Document
Receipt
and
Tracking
and
Data
Entry
Backup
Systems
Operation
$
84,960
$
53,100
Subtotal
$
138,060
Additional
Tasks
Publication
and
Printing
Forms
and
Materials
Hotline
Mailing
$
5,298
$
42,855
$
426
Subtotal
$
48,579
Total
Annual
Cost
$
581,137
Note:
All
costs
associated
with
FTEs
include
41
percent
fringe
benefits
and
17
percent
overhead.

Sources:

Office
of
Personnel
Management,
2000.
"
2000
General
Schedule
Locality
Notes
of
Pay
for
Washington­
Baltimore,
DC­
MD­
VA­
WV."
<
http://
www.
opm.
gov/
oca/
2000tbls/
GSannual/
html/
GSDCB.
HTM>
As
obtained
on
May
30,
2000.

Information
Management
Division,
1996.
Questions
for
Branches
within
OPPT
with
Responsibility
for
IUR
Data
Collection,
Processing,
and
Storage.
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

EPA,
1996b.
Transcribed
Telephone
Conversation
with
Ruth
Heikkinen
on
Hotline
and
Mailing
Costs,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

EPA,
1996c.
IUR
Amendments
 
Agency
Costs
Question.
Memorandum
from
Ward
Penberthy
to
Susan
Krueger,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency.,
Washington,
DC.
30
Worksheet
3.
Estimated
One­
Time
Agency
Costs
for
the
2003
Amendments
to
the
IUR
a
Task
IUR
Amendment
Costs
(
2000
$)

Tasks
Performed
by
Agency
Personnel
Guidance
Document
Development
$
53,573
(
0.5
FTE,
GS­
13)

Subtotal
$
53,573
Extramural
Tasks
(
contractor)

Systems
Development
Hardware
and
Software
Guidance
Document
Development
$
100,505
$
8,464
$
105,794
Subtotal
$
214,763
Additional
Tasks
Hotline
Mailing
$
31,738
$
5,396
Subtotal
$
37,134
Total
One­
Time
Cost
$
305,470
Note:
All
costs
associated
with
FTEs
include
41
percent
fringe
benefits
and
17
percent
overhead.

a
These
costs
are
the
costs
that
would
be
incurred
in
the
first
year
of
reporting
under
the
2003
Amendments
to
the
IUR.
No
incremental
costs
are
expected
for
these
tasks
in
subsequent
years.

Sources:

Information
Management
Division
(
IMD),
1996.
Questions
for
Branches
within
OPPT
with
Responsibility
for
IUR
Data
Collection,
Processing,
and
Storage.
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

U.
S.
Environmental
Protection
Agency.
July
30,
1996c.
IUR
Amendments
 
Agency
Costs
Question.
Memorandum
from
Ward
Penberthy
to
Susan
Krueger,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

Office
of
Personnel
Management
(
OPM),
2000.
"
2000
General
Schedule
Locality
Notes
of
Pay
for
Washington­
Baltimore,
DC­
MD­
VA­
WV."
<
http://
www.
opm.
gov/
oca/
2000tbls/
GSannual/
html/
GSDCB.
HTM>.
As
obtained
on
May
30,
2000.

6(
d)
Bottom
Line
Burden
Hours
and
Cost:
Master
Table
The
total
burden
per
reporting
cycle
collection
is
estimated
to
be
1,654,300
hours.
The
total
cost
per
reporting
cycle
collection
is
estimated
to
be
$
113.5
million.
At
an
average
cost
of
$
41,723
per
organic
chemicals
respondent,
the
cost
per
reporting
cycle
collection
for
organic
chemicals
is
$
103.6
million.
At
an
average
cost
of
$
18,185
per
inorganic
chemicals
respondent,
the
cost
per
reporting
cycle
collection
for
inorganic
chemicals
is
$
9.9
million.
Since
this
31
collection
occurs
every
four
years,
the
total
annual
burden
is
413,575
and
the
annual
cost
is
$
28.4
million.
Details
are
provided
in
Worksheets
4
and
5.

EPA
estimates
that
Agency
costs
will
be
$
886,607
for
the
collection,
or
$
221,652
annually.

Worksheet
4:
Total
Estimated
Burden
Hours
and
Costs
(
2000
$)

Activity
Unit
of
Analysis
Total
per
Unit
Number
of
Units
Totals
per
Collection1
Hours
Cost
Hours
Cost
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)

Compliance
Determination
Site
4.00
$
263.84
2,482
9,928
654,839
Rule
Familiarization
Site
30.00
$
2,274.68
2,482
74,460
5,645,766
Report
Preparation
and
Submission
Partial
Form
Report
19.65
$
1,366.70
12,794
251,402
17,485,512
Full
Form
Report
105.27
$
7,228.54
9,466
996,486
68,425,342
Recordkeeping
Report
8.00
$
509.67
22,260
178,080
11,345,322
Subtotal
Per
Collection
1,510,356
103,556,781
Subtotal
Annually1
377,589
25,889,195
Inorganic
Chemicals
Compliance
Determination
Site
4.00
$
263.84
544
2,176
143,529
Rule
Familiarization
Site
30.00
$
2,274.68
544
16,320
1,237,426
Report
Preparation
and
Submission
Partial
Form
Report
19.65
$
1,366.70
4,537
89,152
6,200,718
Full
Form
Report
105.27
$
7,228.54
0
0
0
Recordkeeping
Report
8.00
$
509.67
4,537
36,296
2,312,373
Subtotal
Per
Collection
143,944
9,894,046
Subtotal
Annually1
35,986
2,473,511
1
This
collection
occurs
every
four
years
(
the
proposed
IUR
Revisions
rule
would
change
this
to
five
years).
32
Worksheet
5:
Bottom
Line
Hours
and
Costs
for
Respondents
(
2000
$)

Activity
Total
per
Collection
Total
Annually1
Hours
Cost
Hours
Cost
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)
1,510,356
$
103,556,781
377,589
$
25,889,195
Inorganic
Chemicals
143,944
$
9,894,046
35,986
$
2,473,511
Total
1,654,300
$
113,450,827
413,575
$
28,362,706
1
This
collection
occurs
every
four
years
(
the
proposed
IUR
Revisions
rule
would
change
this
to
five
years).

6(
e)
Reasons
for
Change
in
Burden
EPA
estimates
the
total
public
burden
to
be
1,654,300
hours,
or
413,575
hours
per
year
during
the
IUR
reporting
cycle.
This
is
an
increase
of
1,588,660
burden
hours
from
the
65,640
hours
estimated
under
previous
clearance
for
this
ICR
(
or,
an
increase
of
397,165
hours
annually,
from
16,410
hours
annually).
The
increase
in
the
estimate
of
total
burden
of
approximately
1.6
million
hours
is
the
result
of
program
changes,
specifically
the
2003
Amendments
to
the
IUR.
Amendments
made
include
the
following:

°
Changing
the
reporting
threshold
from
production
volumes
of
10,000
pounds
or
higher
to
25,000
pounds.
°
Augmenting
the
required
site
and
production
information.
°
Requiring
sites
with
production
volumes
of
300,000
pounds
or
higher
of
a
reportable
chemical
to
collect,
maintain,
and
submit
additional
information
to
EPA
regarding
chemical
processing
and
use.
°
Manufacturers
of
inorganic
chemicals
are
no
longer
exempt.
For
this
2006
submission
period,
inorganic
chemicals,
regardless
of
production
volume,
are
partially
exempt
(
i.
e.,
submitters
do
not
report
processing
and
use
information
for
inorganic
chemicals).
°
Specifically
listed
petroleum
process
streams
and
other
specifically
listed
chemical
substances
are
partially
exempt,
and
manufacturers
of
such
substances
are
not
required
to
report
processing
and
use
information.

6(
f)
Burden
Statement
The
total
public
burden
for
this
collection
of
information,
which
is
approved
under
OMB
Control
No.
2070­
0162,
is
estimated
to
average
609
hours
per
organic
chemical
response
and
265
hours
per
inorganic
chemical
response,
with
an
estimated
cost
of
$
41,723
per
organic
chemicals
respondent
and
an
average
cost
of
$
18,185
per
inorganic
chemicals
respondent.
The
total
estimated
annual
burden
is
413,575
hours,
with
an
estimated
total
annual
cost
$
28,362,706.
This
activity
occurs
only
every
four
years,
and
the
burden
and
cost
vary
depending
on
the
specific
chemical
and
company
activities.
According
to
the
Paperwork
Reduction
Act
(
PRA),
"
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
33
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
2005­
0006,
which
is
available
for
public
viewing
at
the
Pollution
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
2005­
0006
and
OMB
control
number
2070­
0162
in
any
correspondence.
34
SOURCES
EPA,
2002a.
Revised
Economic
Analysis
of
the
Amended
Inventory
Update
Rule.
Economics,
Exposure
and
Technology
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

EPA,
2002b.
EPA's
IURA
Data
Use
Plan.
Economics,
Exposure
and
Technology
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

EPA,
1999.
A
Review
of
Existing
Exposure­
Related
Data
Sources
and
Approaches
to
Screening
Chemicals:
A
Response
to
CMA.
Economics,
Exposure
and
Technology
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

EPA,
1997.
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313.
Economics,
Exposure
and
Technology
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

EPA,
1996a.
Inventory
Update
Rule
(
IUR)
Amendment
Technical
Support
Document:
Exposure­
Related
Data
Useful
for
Chemical
Risk
Screening.
Economics,
Exposure
and
Technology
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

EPA,
1996b.
Transcribed
Telephone
Conversation
with
Ruth
Heikkinen
on
Hotline
and
Mailing
Costs,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
D.
C.

EPA,
1996c.
IUR
Amendments
 
Agency
Costs
Question.
Memorandum
from
Ward
Penberthy
to
Susan
Krueger,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
D.
C.

Information
Management
Division,
1996.
Questions
for
Branches
within
OPPT
with
Responsibility
for
IUR
Data
Collection,
Processing,
and
Storage.
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

Office
of
Personnel
Management,
2000.
"
2000
General
Schedule
Locality
Notes
of
Pay
for
Washington­
Baltimore,
DC­
MD­
VA­
WV."
<
http://
www.
opm.
gov/
oca/
2000tbls/
GSannual/
html/
GSDCB.
HTM>
As
obtained
on
May
30,
2000.
ATTACHMENTS
TO
THE
SUPPORTING
STATEMENT
(
Attachments
are
available
as
part
of
the
electronic
file
for
this
supporting
statement
unless
otherwise
noted).

Attachment
1
Toxic
Substances
Control
Act,
Section
8
(
15
USC
2607)

Attachment
2
40
CFR
710
­
TSCA
Inventory
Update
Rule
Attachment
3
IURA
Data
Use
Plan
Attachment
4
Draft
2006
Form
U
(
EPA
Form
7740­
8)

Attachment
5
Draft
Instructions
for
Reporting
for
the
2006
Partial
Updating
of
the
TSCA
Chemical
Inventory
Database
Attachment
6
Methodology
for
Determination
of
Wage
Rates
