Supporting
Statement
for
a
Request
for
OMB
Review
under
the
Paperwork
Reduction
Act
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
Title:
TSCA
Section
5(
a)(
2)
Significant
New
Use
Rules
for
Existing
Chemicals
EPA
ICR
No.:
1188.08
OMB
Control
No.:
2070­
0038
1(
b)
Short
Characterization
Section
5
of
the
Toxic
Substances
Control
Act
(
TSCA),
15
U.
S.
C.
2604
(
see
Attachment
1),
authorizes
EPA
to
determine
that
a
use
of
a
chemical
substance
is
a
"
significant
new
use."
EPA
must
make
this
determination
by
rule
after
considering
all
relevant
factors,
including
those
listed
in
TSCA
section
5(
a)(
2).
Once
EPA
determines
that
a
use
of
a
chemical
substance
is
a
significant
new
use,
TSCA
section
5(
a)(
1)(
B)
requires
persons
to
submit
a
notice
to
EPA
at
least
90
days
before
they
manufacture,
import
or
process
the
substance
for
that
use.
Regulations
implementing
significant
new
uses
appear
at
40
CFR
part
721
(
see
Attachment
2).

Once
EPA
receives
a
significant
new
use
rule
(
SNUR)
notice,
EPA
may
take
regulatory
action
under
TSCA
sections
5(
e),
5(
f),
6
or
7
to
control
the
activities
for
which
it
has
received
a
SNUR
notice.
If
EPA
does
not
take
action,
TSCA
section
5(
g)
requires
EPA
to
explain
in
the
Federal
Register
its
reasons
for
not
taking
action.

Persons
who
intend
to
export
a
substance
identified
in
a
proposed
or
final
SNUR
are
subject
to
the
export
notification
provisions
of
TSCA
section
12(
b).
The
regulations
that
interpret
TSCA
section
12(
b)
appear
at
40
CFR
part
707.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
TSCA
section
5(
a)(
2)
provides
the
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
with
the
authority
to
monitor
and
control
significant
new
uses
of
existing
chemical
substances.
The
factors
considered
by
the
Administrator
in
determining
a
significant
new
use
are:

1)
The
projected
volume
of
manufacturing
and
processing
of
a
chemical
substance;
2)
The
extent
to
which
a
use
changes
the
type
or
form
of
exposure
of
human
beings
or
the
environment
to
a
chemical
substance;
3)
The
extent
to
which
a
use
increases
the
magnitude
and
duration
of
exposure
of
human
beings
or
the
environment
to
a
chemical
substance;
and
1TSCA
section
5(
e)
allows
the
Administrator
to
prohibit
or
limit
the
manufacture,
import,
processing,
distribution
in
commerce,
use,
or
disposal
of
the
substance
when
the
substance
may
present
an
unreasonable
risk.
TSCA
section
5(
f)
allows
the
Administrator
to
use
a
TSCA
section
6
regulation
to
prohibit
or
limit
the
manufacture
of
the
substance
when
the
substance
will
present
an
unreasonable
risk.

­
2­
4)
The
reasonably
anticipated
manner
and
methods
of
manufacturing,
processing,
distribution
in
commerce,
and
disposal
of
a
chemical
substance.

Once
the
Administrator
makes
such
a
designation,
the
Agency
proposes
a
Significant
New
Use
Rule
(
SNUR).
If
a
final
rule
is
promulgated,
a
person
who
intends
to
engage
in
a
significant
new
use
of
a
chemical
covered
by
a
SNUR
must
notify
EPA
of
his/
her
intentions.
This
notification,
made
via
the
Significant
New
Use
Notice
(
SNUN),
must
occur
at
least
90
days
prior
to
commencing
the
new
use
of
the
identified
substance.
The
required
notice
must
be
submitted
on
EPA's
Premanufacture
Notice
(
PMN)
form.
The
PMN
form
provides
data
on
the
identity
and
use
of,
and
possible
exposures
to,
the
chemical
substance.
In
addition,
the
PMN
form
provides
test
data
plus
descriptions
of
health
and
environmental
effects
data
based
on
the
manufacture,
processing,
use,
distribution
in
commerce,
and
disposal
of
the
chemical.

The
Agency
has
90
days
to
evaluate
a
SNUN
once
it
has
been
received.
This
evaluation
focuses
on
the
health
and
environmental
effects
of
the
substance's
significant
new
use.
Should
EPA
find
cause
for
concern,
the
Agency
can
take
regulatory
action
as
per
TSCA
sections
5(
e)
and
5(
f)
1.
Likewise,
the
Agency
may
extend
the
evaluation
period
by
up
to
90
days
with
good
cause.
If
EPA
takes
no
action
at
the
end
of
the
review
period,
the
submitter
can
engage
in
the
intended
new
use
without
any
restrictions.

2(
b)
Practical
Utility/
Users
of
the
Data
EPA
uses
this
information
to
evaluate
the
health
and
environmental
effects
of
the
significant
new
use.
During
the
evaluation
period
EPA
can
take
further
regulatory
action
pursuant
to
TSCA
sections
5(
e)
and
5(
f).
Under
TSCA
section
5(
e),
the
Administrator
may
issue
an
order
to
prohibit
or
limit
the
manufacture,
import,
processing,
distribution
in
commerce,
use,
or
disposal
of
such
substance.
TSCA
section
5(
f)
allows
the
Administrator
to,
among
other
things,
prohibit
or
limit
the
manufacture
of
the
chemical
substance,
if
the
substance
presents
or
will
present
an
unreasonable
risk
of
injury
to
health
or
the
environment.

To
date
EPA
has
promulgated
SNURs
on
156
existing
chemicals.
Presented
in
Attachment
6
are
selected
case
history
abstracts
for
some
of
these
substances.
These
abstracts
highlight
the
needs
of
a
particular
office
and
the
facts
surrounding
a
substance.
This
information
when
applied
to
the
Regulatory
Selection
Criteria
has
resulted
in
final
SNURs.
­
3­
3.
NON­
DUPLICATION,
CONSULTATIONS
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
EPA
is
the
only
Federal
Agency
that
collects
information
on
significant
new
uses
of
chemical
substances.
A
notification
of
an
intent
to
engage
in
a
significant
new
use
serves
two
functions:
as
a
notice,
and
as
a
document
that
contains
information
about
a
chemical
substance
and
potential
exposures
to
that
substance.
The
notification
element
is
unique
to
SNURs
and
therefore
not
obtainable
elsewhere.
The
chemical
information
aspect
will
also
contain
unique
information.
Only
the
person
who
intends
to
commence
a
significant
new
use
of
a
chemical
substance
will
know
the
potential
for
human
and
environmental
exposures
to
that
substance,
the
quantity
intended
to
be
produced,
imported,
or
processed,
and
the
manner
in
which
the
person
will
engage
in
the
significant
new
use.

A
person
submitting
a
significant
new
use
notice
is
not
required
to
develop
test
data.
However,
the
person
must
submit
data
that
are
known
to
or
reasonably
ascertainable
by
that
person.
For
published
data
the
submitter
need
only
provide
a
literature
citation
(
40
CFR
720.50(
d)(
3)(
ii)).
For
existing
chemicals
that
are
related
to
the
chemical
substance
that
is
the
subject
of
the
SNUR
(
e.
g.,
impurities,
byproducts),
neither
the
published
data
nor
a
literature
citation
need
be
submitted.
Also,
notices
need
not
include
information
previously
submitted
to
EPA
(
unless
the
previously
submitted
information
was
claimed
confidential,
in
which
case
it
must
be
resubmitted).

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

3(
c)
Consultations
EPA
received
comments
in
response
to
several
individual
proposed
SNURs.
All
comments
were
considered
in
developing
the
final
rules.
It
is
EPA
policy
to
consider
all
comments
received
in
response
to
proposed
SNURs.

3(
d)
Effects
of
Less
Frequent
Collection
Whenever
a
person
intends
to
engage
in
a
significant
new
use,
they
must
notify
EPA.
This
is
an
explicit
requirement
of
TSCA.
TSCA
section
5(
a)(
1)(
B)
states,
"...
no
person
may
...
manufacture
or
process
any
chemical
substance
for
a
use
which
the
Administrator
has
determined
...
is
a
significant
new
use
...
unless
such
person
submits
to
the
Administrator
...
a
notice
..."
The
­
4­
consequence
of
less
frequent
collection
of
information
(
i.
e.,
requiring
only
the
first
person
who
intends
to
engage
in
a
significant
new
use
to
submit
notice)
is
a
violation
of
TSCA
and
would
allow
manufacturers,
importers
and
processors
to
use
a
substance
in
a
manner
that
EPA
has
determined
may
cause
significant
adverse
exposures
to
the
substance
without
prior
notification
to
EPA.

3(
e)
General
Guidelines
This
information
collection
activity
is
necessary
to
implement
the
statutory
requirements
of
TSCA
section
5(
a)(
2)
and
is
consistent
with
the
requirements
of
5
CFR
1320.6.

3(
f)
Confidentiality
Information
provided
in
a
significant
new
use
notice
may
receive
confidential
treatment.
TSCA
section
14
allows
a
manufacturer,
importer
or
processor
to
designate
submitted
information
as
confidential
business
information
(
CBI).
The
Agency
has
developed
a
comprehensive
system
to
prevent
the
unauthorized
disclosure
of
CBI.
This
system
includes
procedures
for
logging
CBI
in
and
out
of
designated
locked
file
cabinets,
for
photocopying
and
transmitting
CBI,
and
for
restricting
confidential
information
only
to
personnel
with
CBI
security
clearance.
No
one
is
allowed
access
to
CBI
until
they
have
received
instructions
for
handling
CBI.

Special
procedures
also
restrict
access
to
computerized
CBI.
These
security
measures
apply
to
CBI
submitted
by
manufacturers
as
well
as
CBI
generated
by
EPA
staff
in
the
course
of
their
review.
A
wrongful
disclosure
of
CBI
may
result
in
either
a
fine
or
imprisonment.

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

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondent
NAICS
Codes
Respondents
affected
by
this
collection
activity
are
mainly
NAICS
categories
325
­
Chemicals
and
Allied
Products
Manufacturers
and
32411­
Petroleum
Refining.

4(
b)
Information
Requested
(
i)
Data
items,
including
record
keeping
requirements
­
5­
Information
submitted
under
this
collection
must
include,
insofar
as
it
is
known
to
or
reasonably
ascertainable
by
the
submitter,
information
described
in
TSCA
section
8(
a)(
2)
(
i.
e.,
chemical
identity,
use,
and
exposure
data),
as
well
as
test
data,
and
descriptions
of
other
data
related
to
the
effects
on
health
and
the
environment
of
the
manufacture,
processing,
use,
distribution
in
commerce,
and
disposal
of
the
chemical
substance
(
TSCA
section
5(
d)).
After
a
notice
has
been
received,
EPA
has
90
days
(
extendable
to
180
days)
to
evaluate
the
notice's
content.

(
ii)
Respondent
Activities
Only
those
persons
who
intend
to
engage
in
a
significant
new
use
of
a
chemical
substance
must
submit
notice
of
their
intentions
to
EPA.
Submitters
are
required
to
use
the
Premanufacture
Notice
(
PMN)
form
(
EPA
Form
7710­
25;
see
Attachment
3),
which
was
developed
to
facilitate
the
information
collection
process
for
new
chemical
substances.

5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
A
significant
new
use
rule
(
SNUR)
on
an
existing
chemical
substance
is
the
product
of
a
process
that
is
designed
to
develop
the
appropriate
information­
gathering
collection
for
a
substance.
This
process
has
three
major
steps:
Chemical
Referral,
Regulatory
Selection,
and
Regulation
Development.

Step
1.
Chemical
Referral:
EPA
offices
that
have
identified
information­
gathering
or
follow­
up
monitoring
needs
for
a
particular
chemical
may
refer
the
substance
to
OPPT.
A
systematic
process
has
been
developed
for
receiving
and
handling
chemical
referrals.
Offices
referring
substances
are
asked
to
prepare
concise
summaries
of
relevant
data.
This
information
is
used
to
select
a
regulatory
approach
and
for
rulemaking
activities.

Step
2.
The
Regulatory
Selection
Process
­
Referral
and
Review:
Once
an
office
has
detailed
its
need
for
information,
an
information
collection
approach
is
determined
that
best
satisfies
that
office's
needs.
The
rulemaking
options
are:
a
TSCA
section
8(
a)
reporting
rule,
a
TSCA
section
8(
c)
call­
in,
a
TSCA
section
8(
d)
health
and
safety
data
reporting
rule,
a
TSCA
section
5(
a)(
2)
SNUR,
or
any
combination
of
the
above.
It
may
also
be
determined
that
an
alternative
approach
is
more
appropriate
(
e.
g.,
use
of
existing
data
sources,
no
data­
gathering
at
the
present
time,
TSCA
section
4
or
6
action,
or
referral
to
another
office
for
informationgathering
under
a
different
statutory
authority).
­
6­
Step
3.
Regulatory
Development:
Prior
to
the
development
of
a
rule,
the
recommended
rulemaking
approach
must
be
reviewed
by
the
referring
office
and
approved
by
the
Office
Director
of
OPPT.
If
the
recommendation
is
approved,
then
the
rulemaking
process
begins.

A
SNUR
is
drafted
only
if
it
is
an
appropriate
approach
for
a
particular
substance
that
has
received
approval
prior
to
the
development
of
the
rule.
The
proposal
then
undergoes
intra­
agency
review,
OMB
review
and
public
comment.
Once
a
decision
has
been
made
to
promulgate
an
information
collection
rule,
the
next
decision
is
to
determine
whether
a
TSCA
section
8(
a)
rule
or
a
TSCA
section
5
SNUR
is
most
appropriate.
Attachment
5
identifies
the
selection
criteria
that
are
applied
in
determining
whether
a
TSCA
section
8(
a)
rule
or
SNUR
is
proposed.

5(
b)
Collection
Methodology
and
Management
EPA
has
not
been
able
to
identify
a
more
efficient,
less
expensive
or
more
flexible
means
of
obtaining
the
required
data
and
remain
within
the
constraints
of
TSCA.
There
is
no
new
technology
applicable
to
the
collection
of
this
information
that
would
minimize
the
collection
burden.

To
aid
persons
subject
to
this
information
collection,
OPPT
has
set
up
a
TSCA
Hotline
that
provides
information
regarding
TSCA
section
5(
a)(
2)
reporting
as
well
as
other
regulatory
information.
When
Hotline
staff
are
unable
to
answer
questions
regarding
TSCA
section
5(
a)(
2),
the
questions
are
referred
to
the
OPPT
Chemical
Control
Division
(
CCD)
staff
for
resolution.

5(
c)
Small
Entity
Flexibility
All
business,
regardless
of
size,
must
comply
with
the
requirements
of
TSCA
section
5.
However,
OPPT
has
taken
a
number
of
steps
intended
to
minimize
the
burden
placed
on
small
business.
For
instance,
TSCA
section
26(
d)
established
an
Assistance
Office
to
provide
technical
and
other
nonfinancial
assistance
to
manufacturers,
importers
and
processors
of
chemical
substances
and
mixtures.
This
office
has
established
a
toll­
free
hotline,
performs
on­
site
field
visits
and
consultations,
and
has
hired
a
contractor
to
assist
small
businesses,
free
of
charge,
in
complying
with
TSCA
requirements.

5(
d)
Collection
Schedule
Whenever
any
person
intends
to
engage
in
a
significant
new
use
of
a
chemical
substance,
they
are
required
to
submit
a
notice
of
their
intentions
to
EPA
not
less
than
90
days
before
beginning
to
manufacture,
import
or
process
the
substance
for
the
intended
use.
­
7­
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
This
section
presents
estimates
of
the
cost
and
burden
associated
with
the
recordkeeping
and
reporting
requirements
for
significant
new
use
rules
for
existing
chemicals
under
TSCA
section
5(
a)(
2).
The
methodology
used
to
estimate
the
recordkeeping
costs,
reporting
costs,
and
burden
for
this
ICR
renewal
is
largely
based
on
previous
experience
with
SNURs,
and
is
largely
consistent
with
the
analysis
presented
in
the
supporting
statement
prepared
for
the
previous
ICR.
A
summary
of
the
steps
employed
in
this
analysis
is
shown
below:

Step
1:
The
total
number
of
SNURs
promulgated
and
SNUNs
to
be
submitted,
on
an
annual
basis
and
for
the
three­
year
period
during
which
this
ICR
will
be
in
effect,
was
projected.
The
estimate
is
based
on
the
Agency's
experience
with
SNURs
and
submission
of
SNUNs
from
data
covering
2001­
2004
fiscal
year
time
frame.

Step
2:
The
average
industry
burden
associated
with
recordkeeping,
reporting,
and
customer
notification
was
estimated.
The
reporting
burden
estimates
used
here
are
taken
from
an
analysis
performed
in
connection
with
OPPT's
amendments
to
its
PMN
program.

Step
3:
The
unit
costs
for
the
different
activities
associated
with
TSCA
section
5(
a)(
2)
were
estimated
next
(
e.
g.,
submitting
a
SNUN).
The
costs
were
derived
by
multiplying
current
estimates
of
unit
labor
costs
by
the
burden
estimates
presented
in
Step
2.

Step
4:
Total
industry
costs
and
burden
were
computed
by
multiplying
the
average
burden
and
cost
per
activity
by
the
expected
number
of
activities.

Step
5:
The
final
step
estimates
the
cost
to
EPA.

6(
a)
Estimating
Respondent
Burden
During
the
years
2001
­
2004,
EPA
promulgated
two
SNURs
for
existing
chemicals
and
received
two
existing
chemical
SNUNs
(
US
EPA,
2004).
The
average
number
of
chemicals
per
existing
chemical
SNUR
during
this
time
period
was
41.
Based
upon
the
historic
information
and
projected
SNUR
activity
by
the
Agency,
EPA
maintains
its
estimate
of
three
SNURs
promulgated
and
five
SNUNs
submitted
per
year
consistent
with
the
previous
ICR.
Furthermore,
it
is
estimated
that
a
total
of
nine
SNURs
will
be
promulgated
and
15
SNUNs
will
be
received
over
the
three­
year
time
period
during
which
this
ICR
is
effective.
These
estimates
are
summarized
in
Table
1.
­
8­
TABLE
1
ANTICIPATED
NUMBER
OF
SNURs
AND
SNUNs
Year
Anticipated
Number
of
SNURs
Anticipated
Number
of
SNUNS
First
Year
3
5
Second
Year
3
5
Third
Year
3
5
Three
Year
Totals
9
15
Given
the
uncertainty
in
projecting
possible
new
uses
for
existing
chemicals,
it
is
not
possible
to
determine
if
a
large
or
small
number
of
firms
would
be
affected
by
any
given
SNUR,
or
whether
any
one
firm
might
engage
in
more
than
one
new
use.
Thus,
this
analysis
makes
the
assumption
that
no
firm
submits
more
than
one
SNUN.
The
total
number
of
firms
engaging
in
new
uses
cannot
be
estimated.

Alternative
Responses
The
burden
associated
with
a
SNUR
could
involve
a
number
of
possible
industry
responses.
That
is,
when
a
SNUR
is
promulgated,
a
firm
seeking
to
engage
in
a
new
use
for
a
subject
chemical
has
5
options
regarding
possible
courses
of
action
that
may
generate
reporting
burden:

1)
The
company
could
submit
a
SNUN.
This
option
would
be
chosen
by
any
company
not
intending
to
abide
by
the
provisions
of
the
SNUR.

2)
A
company
can
request
an
equivalency
determination.
This
option
would
be
chosen
if
a
manufacturer/
importer
had
reason
to
believe
that
there
may
be
alternative
methods
not
considered
by
EPA
that
provide
equivalent
or
superior
protection
from
exposure
or
release
of
the
subject
chemical.

3)
The
company
can
comply
with
the
SNUR,
ensuring
that
all
provisions
of
the
SNUR
are
implemented
in
connection
with
the
planned
use
of
the
subject
chemical.

4)
The
company
can
request
review
of
the
SNUR
for
possible
modification
or
revocation.

5)
The
company
may
simply
decide
to
forgo
the
new
use,
avoiding
regulatory
compliance
activities
altogether.
2Unless
manufacturers,
processors,
and
importers
of
chemicals
subject
to
SNURs
have
either
notified
recipients
of
such
chemicals
and
all
significant
new
uses,
verified
that
knowledge
of
the
SNUR
has
been
otherwise
acquired
by
recipients,
or
verified
that
recipients
are
unable
to
engage
in
significant
new
uses,
manufacturers,
processors,
and
importers
must
file
a
SNUN.

­
9­
Additionally,
under
current
regulations
at
40
CFR
721.5(
a)(
2),
all
manufacturers,
processors,
and
importers
of
chemicals
subject
to
SNURs
are
subject
to
certain
requirements
regardless
of
whether
they
engage
in
a
significant
new
use
unless
certain
information
can
be
documented.
2
However,
without
prior
knowledge
of
chemicals
that
would
be
the
subject
of
future
SNURs,
estimating
the
number
of
potentially
affected
entities
subject
to
40
CFR
721.5(
a)(
2)
is
not
possible.

The
following
section
estimates
the
cost
of
submitting
a
SNUN
(
option
1)
and
then
discusses
the
other
options.

Burden
Estimates
TSCA
section
5(
a)(
2)
imposes
two
requirements
on
industry.
First,
manufacturers,
processors,
and
importers
of
chemicals
must
choose
among
the
options
mentioned
above.
This
section
presents
estimates
of
submitting
SNUNs
(
i.
e.,
the
first
option)
and
then
briefly
discusses
the
other
four
options.
Second,
manufacturers,
processors,
and
importers
of
chemicals
covered
by
SNURs
will
incur
burden
and
costs
to
notify
customers
of
the
hazards
posed
by
the
covered
chemical.
Therefore,
they
must
first
determine
if
their
chemical
is
subject
to
the
SNUR
and
then
must
determine
how
to
notify
their
customers.

Burden
Estimates
­
Chemical
Verification
When
a
SNUR
is
published,
companies
must
review
the
rule
to
verify
if
their
chemical
is
subject
to
the
rule.
During
the
2001­
2004
time
frame,
the
majority
of
SNURs
promulgated
by
the
Agency
under
TSCA
section
5(
a)
applied
to
new
chemicals
submitted
to
the
Agency
under
the
Premanufacture
Notice
Program.
Only
two
SNURs
applying
to
existing
chemicals
were
promulgated
during
the
same
time
period.
The
Agency
typically
notifies
the
manufacturer(
s)
of
chemicals
subject
to
a
SNUR
prior
to
its
issuance.
Therefore
it
is
estimated
that
no
more
than
0.167
hours
(
10
minutes)
or
of
technical
time
per
chemical
is
used
to
verify
if
a
chemical
is
subject
to
the
rule.
This
is
equivalent
to
6.8
hours
(
0.167
hours/
chemical
x
41
chemicals)
per
SNUR.

Burden
Estimates
­
Submitting
a
SNUN
In
submitting
a
SNUN,
individuals
at
different
occupational
levels
must
spend
time
on
the
required
recordkeeping
and
reporting
activities.
In
estimating
the
burden
required
to
prepare
a
SNUN,
the
analysis
uses
the
breakdown
of
activities
and
activity
estimates
as
developed
for
the
premanufacture
notification
(
PMN)
baseline
model
in
the
Agency's
"
Regulatory
Impact
Analysis
of
Amendments
to
Regulations
for
TSCA
Section
5
Premanufacture
Notifications"
(
OPPT,
3The
burden
estimates
presented
in
Table
2
differ
from
the
PMN
Amendments
analysis,
which
were
based
on
a
Chemical
Manufacturers
Association
survey,
only
in
that
burden
for
researching
synonyms
and
generic
chemical
names
was
not
included
in
this
analysis.
This
is
because
subject
chemicals
would
be
existing
chemicals,
and
such
information
would
already
be
known.

­
10­
1994).
The
PMN
reporting
cost
estimates
were
used
because
SNUNs
would
be
filed
on
the
standard
PMN
form.
Table
2
presents
EPA's
estimate
of
respondent
reporting
burden
associated
with
the
filing
of
a
SNUN.
3
When
submitting
an
SNUN,
manufacturers
must
maintain
records
associated
with
the
SNUN
for
five
years.
In
keeping
with
the
conservative
assumptions
already
employed,
the
high
end
of
the
range
of
reporting
burden
hours
(
i.
e.,
113.25
hours)
will
be
used
in
subsequent
cost
calculations.
The
recordkeeping
associated
with
preparing
and
filing
a
SNUN
is
assumed
to
require
five
percent
of
the
time
spent
on
reporting.
Thus,
5.67
record
keeping
hours
([
113.25
hours]*[
5
percent])
will
be
spent
in
preparation
of
a
SNUN.
The
average
industry
burden
per
notice,
then,
is
118.92
hours
(
113.25
+
5.67).

The
estimates
shown
in
Table
2
are
average
burden
levels.
Thus,
it
is
entirely
possible
that
certain
respondents
may
incur
burden
above
or
below
the
estimates
shown
above;
nevertheless,
EPA
believes
the
upper
bound
of
the
range
of
average
burden
hours
to
be
an
appropriate
estimate
for
the
calculations
performed
in
this
analysis.

Burden
Estimates
­
Alternative
Options
Should
a
company
choose
to
request
an
equivalency
determination
(
i.
e.,
the
second
option),
or
review
for
modification/
revocation
(
i.
e.,
the
fourth
option),
EPA
estimates
that
a
data
collection
and
preparation
effort
similar
to
that
of
a
SNUN
would
be
required,
and
thus
the
burden
is
estimated
to
range
up
to
118.92
hours
for
these
alternatives,
the
same
as
for
submitting
a
SNUN.

In
complying
with
a
SNUR,
a
company
would
incur
costs
to
ensure
all
provisions
of
the
SNUR
were
implemented
at
the
subject
facility
(
i.
e.,
the
third
option).
Since
the
nature
of
such
provisions
will
vary
depending
on
the
significant
new
uses
identified
in
each
respective
SNUR,
estimating
burden
at
this
time
is
not
possible.

The
final
alternative
for
a
company
considering
a
significant
new
use
of
a
chemical
that
is
the
subject
of
a
SNUR
is
to
forgo
the
new
use
(
i.
e.,
the
fifth
option).
In
carrying
out
such
a
response,
no
direct
regulatory
burden
or
costs,
would
be
incurred.
­
11­
Burden
Estimates
­
Customer
Notification
As
noted
above,
unless
manufacturers,
processors,
and
importers
of
chemicals
subject
to
SNURs
have
either
notified
recipients
of
such
chemicals
and
all
significant
new
uses,
verified
that
knowledge
of
the
SNUR
has
been
otherwise
acquired
by
recipients,
or
verified
that
recipients
are
unable
to
engage
in
significant
new
uses,
manufacturers,
processors,
and
importers
must
file
a
SNUN.
Since
it
is
not
expected
that
all
such
entities
will
have
complete
knowledge
of
all
uses
of
any
products
subject
to
a
SNUR,
and
because
filing
a
SNUN
could
require
significantly
more
burden,
it
is
assumed
that
manufacturers,
processors,
and
importers
will
most
often
choose
to
notify
their
customers
of
SNUR
regulatory
activities.
As
this
notification
may
be
accomplished
by
simply
annotating
a
Material
Safety
Data
Sheet
(
MSDS),
EPA
estimates
the
associated
burden
to
be
about
one
hour
of
a
technical
employee's
time
per
manufacturer,
processor,
or
importer
per
chemical.
­
12­
TABLE
2
UNIT
REPORTING
BURDEN
ESTIMATES
ASSOCIATED
WITH
FILING
A
SNUN,
BY
LABOR
CATEGORY
Activity
Secretarial
Hours
Technical
Hours
Managerial
Hours
Total
Hours
General
information/
instructions
2
­
2.5
1.5
­
2
3
­
4
6.5
­
8.5
Chemical
identity
1.5
­
2
3
­
6
1
5.5
­
9
Trade
name
ID
.25
.25
Byproducts/
impurities
identification
1
1
Production
&
marketing
data
1.5
2
­
3
3.5
­
4.5
Production
volume
1
1
Category
of
use
3
3
Hazard
information
3
­
4
3
­
4
Human
exposure
and
environmental
release
2.5
­
3.5
6
­
7
8.5­
10.5
Site
information
14
­
16
14
­
16
Occupational
exposure
13
­
14
13
­
14
Environmental
release/
disposal
9
­
10
9
­
10
Sites
controlled
by
others
2
10
­
12
2
­
2.5
14
­
16.5
List
of
attachments
2
6
­
8
1
­
1.5
9
­
11.5
Certification
.5
.5
Data
submissions
.5
1.5
­
2
.5
2.5
­
3
Totals
12
­
14
66.25
­
79.25
16
­
20
94.25
­
113.25
Source:
OPPT,
1994.

6(
b)
Estimating
Respondent
Costs
The
unit
costs
of
filing
a
SNUN
are
estimated
by
monetizing
the
labor
time
spent
preparing
the
SNUN
and
then
adding
any
fixed
costs
associated
with
filing
a
SNUN.
This
section
derives
these
unit
costs.
­
13­
Estimating
Labor
Costs
The
basic
methodology
for
estimating
the
industry
wage
rates
used
in
this
analysis
is
presented
in
Appendix
A.
Wage
data
used
to
develop
the
basic
industry
wage
rates
are
derived
from
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics
(
BLS)
for
all
goods­
producing
private
industries.
The
annual
salary
estimates
were
adjusted
to
final­
quarter
(
December)
2003
dollars
using
the
BLS
Employment
Cost
Index
(
ECI)
for
white­
collar
occupations
for
all
private
industries.

An
overhead
rate
of
17
percent
was
applied
to
all
wages
based
on
information
provided
by
the
chemical
industry
and
chemical
industry
trade
associations.
Benefit
rates
were
applied
to
wages
as
follows:
managerial,
46.6
percent;
technical,
45.5
percent;
and
secretarial,
45.1
percent.
Thus,
total
load
factors
are
63.6
percent
for
managerial
labor,
62.5
percent
for
technical
labor,
and
62.1
percent
for
secretarial
labor.
The
estimated
hourly
wage
rates
are
presented
in
Table
3.
Details
on
the
calculation
of
the
wage
rates
can
be
found
in
Appendix
A.

TABLE
3
HOURLY
WAGE
AND
LOAD
RATES
FOR
INDUSTRY
Labor
Category
Wage
Rate
Managerial
$
53.82
Technical
$
46.08
Secretarial
$
24.47
Note:
Details
on
the
calculation
of
these
wages
can
be
found
in
Appendix
A.

Labor
Costs
­
Chemical
Verification
The
Agency
estimates
that
chemical
verification
will
require
6.8
hours
per
SNUR.
The
total
estimated
cost
per
SNUR
is
estimated
to
be
$
313
(
6.8
hours
per
SNUR
x
$
46.08).

Labor
Costs
­
Submitting
a
SNUN
Using
these
labor
wage
rates
and
the
burden
estimates
presented
above,
EPA
estimates
that
the
labor
cost
associated
with
filing
a
SNUN
ranges
from
$
4,208
to
$
5,071.
In
addition,
SNUN
filers
must
pay
a
$
2,500
user
fee
to
EPA.
Thus,
the
total
cost
of
filing
a
SNUN
ranges
from
$
6,708
to
$
7,571.
­
14­
TABLE
4
UNIT
REPORTING
BURDEN
ESTIMATES
ASSOCIATED
WITH
FILING
A
SNUN,
BY
LABOR
CATEGORY
Hours
Wage
Rate
Total
Cost
Secretarial
12­
14
$
24.47
$
294­$
343
Technical
66.25­
79.25
$
46.08
$
3,053­$
3,652
Managerial
16­
20
$
53.82
$
861­$
1,076
Totals
94.25­
113.25
­
$
4,208­$
5071
Labor
Costs
­
Recordkeeping
Recordkeeping
requires
5.67
hours
per
SNUN.
Assuming
that
the
recordkeeping
is
performed
by
clerical
staff,
the
costs
for
recordkeeping
are
$
139
[
5.67
hours
*
$
24.47
(
clerical
labor)].

Labor
Costs
­
Alternative
Responses
As
noted
above,
five
alternative
responses
to
any
particular
SNUR
could
be
chosen
by
firms
planning
to
engage
in
significant
new
uses
of
subject
chemicals.
Although
EPA
has
not
projected
or
quantified
how
frequently
these
alternatives
might
be
selected,
the
unit
costs
associated
with
each
option
are
discussed
briefly
below.

The
estimated
burden
of
requesting
an
equivalency
determination
(
the
second
option)
or
review
for
modification/
revocation
(
the
fourth
option)
was
judged
to
be
similar
to
filing
the
SNUN;
thus,
total
costs
including
the
EPA
user
fee
were
estimated
to
range
from
between
$
6,708
and
$
7,751.
However,
the
firm
may
incur
additional
costs
in
developing
the
data
necessary
to
justify
the
alternative.
This
option
will
be
preferable
to
compliance
with
the
SNUR
if
the
total
cost
of
obtaining
EPA
approval
of
a
request
is
less
than
the
costs
of
SNUR
compliance.

Labor
Costs
­
Customer
Notification
EPA
assumes
that
the
customer
notification
requirement
will
be
handled
by
technical
labor.
This
analysis
assumed
that
one
hour
of
labor
per
chemical
would
be
required
to
perform
the
notification,
thus
the
unit
cost
of
notification
is
estimated
to
be
$
46.08
(
i.
e.,
the
hourly
wage
for
technical
labor).
EPA
estimates
that
each
SNUR
will
cover
approximately
41
chemicals.
Furthermore,
EPA
assumes
that
there
are
two
manufacturers,
processors,
or
importers
per
4The
assumption
that
there
are
two
manufacturers,
processors,
or
importers
per
chemical
follows
from
previous
ICRs
for
these
requirements.

5This
percentage
increase
is
composed
of
three
annual
increases:
a
4.77
percent
increase
in
2002,
and
a
4.27
percent
increase
in
2003.
(
Office
of
Personnel
Management,
2005).

­
15­
chemical4.
Therefore,
the
burden
per
SNUR
is
estimated
to
be
82
hours
per
SNUR
([
41
chemicals
per
SNUR]*[
1
hour
per
manufacturer,
processor,
or
importer]*[
2
manufacturers,
processors,
or
importers
per
chemical]),
and
the
cost
per
SNUR
is
equal
to
$
3,779
[($
46.08
per
hour)*(
82
hours
per
SNUR)].

Labor
Costs
­
Summary
Table
5
summarizes
the
unit
costs
estimated
in
this
section.
Reviewing
a
SNUR
to
verify
that
a
chemical
is
included
is
estimated
to
cost
$
313
per
SNUR.
Submitting
a
SNUN
is
estimated
to
cost
between
$
6,708
to
$
7,751
per
SNUN
and
notifying
customers
is
estimated
to
cost
$
3,779
per
SNUR.
As
noted
above,
the
upper
bound
cost
for
filing
a
SNUN
($
7,751)
will
be
used
in
subsequent
calculations.

TABLE
5
SUMMARY
OF
UNIT
COSTS
Unit
Cost
Estimated
Cost
Chemical
Verification
$
313
per
SNUR
Submitting
a
SNUN
Between
$
6,708
and
$
7,751
per
SNUN
SNUN
Record
Keeping
$
139
per
SNUN
Notifying
Customers
$
3,779
per
SNUR
6(
c)
Estimating
Agency
Burden
and
Cost
EPA
will
incur
costs
associated
with
the
promulgation
of
SNURs
and
the
processing
of
SNUNs.
The
previous
ICR
estimated
that
the
cost
for
issuing
a
SNUR
can
be
as
high
as
$
33,207
in
2001
dollars.
The
Office
of
Personnel
Management
reports
that
federal
salaries
increased
by
9.04
percent
(
Washington,
D.
C.
salary
including
locality
adjustment)
from
2001
to
2003
(
Office
of
Personnel
Management,
2005)
5.
The
annual
salary
for
EPA
staff
used
for
calculations
of
Agency
costs
is
an
average
of
the
OPM
year
2003
annual
salaries
for
GS­
12
Steps
1
and
10
 
$
58,070
and
$
75,492,
respectively,
or
$
66,781.
Multiplying
by
an
assumed
loading
factor
of
1.6
to
reflect
fringe
benefits
and
overhead
(
Office
of
Policy
Planning
and
Evaluation,
1992),
the
loaded
annual
salary
of
EPA
staff
was
calculated
to
be
$
106,850.
Dividing
the
wage
by
a
12
person­
months/
year
results
in
$
8,904/
person­
month.
Consistent
with
the
previous
ICR,
it
is
6The
3.94
person­
months
estimate
is
from
a
memorandum
from
Michael
Shapiro,
Economics
and
Technology
Division,
to
Susan
Hazen,
Office
of
Toxic
Substances
(
Shapiro,
1984).

­
16­
estimated
that
it
will
take
3.94
person­
months
of
EPA
staff
time
to
develop
a
final
SNUR.
Therefore,
the
wage
per
person­
month
($
8,904)
multiplied
by
a
3.94
person­
months/
SNUR
yields
an
EPA
cost
per
SNUR
of
$
35,0826.

EPA's
costs
to
review
and
process
SNUNs
are
assumed
to
be
the
same
as
EPA
costs
to
review
PMNs.
These
costs
are
estimated
at
$
4,203
per
case.
The
Agency
actions
required,
fulltime
equivalent
(
FTE)
staff
needs,
and
extramural
costs
such
as
for
contractor
support
are
derived
in
Appendix
B
from
EPA's
analysis
of
the
Agency
costs
of
processing
PMN
submissions
(
RIB,
1994),
with
updates
to
2003
dollars.
The
original
EPA
analysis
used
a
range
of
salaries,
but
this
analysis
uses
only
the
average
salary.

Using
the
estimates
of
annual
SNUR
promulgation
and
SNUR
notice
submissions
presented
above,
EPA's
estimated
costs
are
presented
in
Table
6.
Promulgating
SNURs
and
processing
SNUNs
are
estimated
to
cost
the
Agency
$
126,261
annually,
and
$
378,783
for
three
years.
The
Agency
may
also
incur
a
cost
for
modifying
a
SNUR
if
submitted
data
indicate
a
need
for
such
an
action.
Costs
to
perform
such
a
modification
have
not
been
estimated.

TABLE
6
AGENCY
COSTS
Activity
Number
Per
Year
Cost
Per
Action
Annual
Cost
Three
Year
Cost
SNURs
3
$
35,082
$
105,246
$
315,738
SNUNs
5
$
4,203
$
21,015
$
63,045
Totals
8
$
39,285
$
126,261
$
378,783
Note:
Estimates
may
contain
some
rounding
error
caused
by
rounding
dollar
values
to
the
nearest
whole
dollar.

6(
d)
Total
Burden
and
Cost
to
Industry
This
section
provides
estimates
of
the
total
burden
and
costs
imposed
by
the
TSCA
section
5(
a)
requirements.
These
estimates
can
be
divided
into
three
categories:
chemical
verification,
submitting
SNUNs
and
notifying
customers.

Total
Burden
and
Cost
to
Industry
­
Verifying
Chemicals
The
total
cost
and
burden
imposed
on
industry
by
TSCA
section
5(
a)(
2)
requirements
can
be
calculated
by
multiplying
the
unit
burden
and
cost
estimates
by
the
expected
number
of
SNURs.
As
noted
above,
this
analysis
assumes
that
EPA
will
promulgate
three
SNURs
per
year.
7In
deriving
the
totals
for
this
analysis,
EPA
uses
the
upper
bound
estimates
for
the
number
of
hours
and
the
cost
of
submitting
SNUNs.

­
17­
Total
burden
and
costs
for
chemical
verification
are
presented
in
Tables
7
and
8.

TABLE
7
TOTAL
INDUSTRY
BURDEN
ASSOCIATED
WITH
CHEMICAL
VERIFICATION
Activity
Hours
Per
SNUR
SNURs
per
Year
Total
hours
Chemical
Verification
6.8
3
20.4
TABLE
8
TOTAL
INDUSTRY
COSTS
ASSOCIATED
WITH
CHEMICAL
VERIFICATION
SNURs
Per
Year
Cost
Per
SNUR
Total
Annual
Cost
Three
Year
Cost
3
$
313
$
939
$
2,817
Note:
Estimates
may
contain
some
rounding
error
caused
by
rounding
dollar
values
to
the
nearest
whole
dollar.

Total
Burden
and
Cost
to
Industry
­
Submitting
SNUNs
The
total
cost
and
burden
imposed
on
industry
by
TSCA
section
5(
a)(
2)
requirements
can
be
calculated
by
multiplying
the
unit
burden
and
cost
estimates
by
the
expected
number
of
SNURs
and
SNUNs.
As
noted
above,
this
analysis
assumes
that
EPA
will
promulgate
three
SNURs
and
receive
five
SNUNs
per
year.

Table
9
presents
the
total
burden
of
submitting
SNUNs.
This
analysis
estimated
that
the
reporting
requirements
for
submitting
SNUNs
would
impose
113.25
hours
for
each
SNUN.
An
additional
5.67
hours
are
assumed
to
be
required
to
satisfy
recordkeeping
requirements.
Thus,
a
total
of
118.92
hours
are
required
for
each
SNUN7.
Also
in
this
analysis,
EPA
estimates
that
it
will
receive
five
SNUNs
per
year.
Thus,
the
total
burden
imposed
on
industry
is
estimated
to
be
594.6
hours
annually,
or
1,783.6
hours
over
a
three­
year
period.
­
18­
TABLE
9
TOTAL
INDUSTRY
BURDEN
ASSOCIATED
WITH
SUBMITTING
SNUNs
Activity
Hours
Per
SNUN
SNUNs
per
Year
Total
hours
Reporting
113.25
5
566.25
Recordkeeping
5.67
5
28.35
Total
Annual
Burden
118.92
5
594.6
Three
Year
Burden
­
­
1,783.6
The
total
cost
of
submitting
SNUNs
is
presented
in
Table
10.
This
analysis
estimated
that
submitting
SNUNs
will
cost
affected
parties
$
7,751
per
SNUN.
Assuming
five
SNUNs
per
year
(
see
above)
implies
a
total
annual
cost
of
$
38,755
([
5
SNUNs]*[$
7,710
per
SNUN])
and
a
threeyear
cost
of
$
116,265
([$
38,755
per
year]*[
3
years]).

TABLE
10
TOTAL
INDUSTRY
COSTS
ASSOCIATED
WITH
SUBMITTING
SNUNs
SNUNs
Per
Year
Cost
Per
SNUN
Total
Annual
Cost
Three
Year
Cost
5
$
7,710
$
38,755
$
116,265
Note:
Estimates
may
contain
some
rounding
error
caused
by
rounding
dollar
values
to
the
nearest
whole
dollar.

Total
Burden
and
Cost
to
Industry
­
Customer
Notification
Table
11
presents
estimates
of
the
customer
notification
burden
and
costs.
EPA
estimates
that
burden
for
customer
notification
is
82
hours
per
SNUR.
EPA
estimates
that
three
SNURs
will
be
promulgated
per
year.
The
annual
burden
associated
with
customer
notification
is
estimated
to
be
246
hours
(
82
hours/
SNUR
*
3
SNURs/
year).
The
three­
year
burden
is
estimated
to
be
738
hours.

The
cost
of
customer
notification
is
estimated
by
multiplying
the
burden
hours
by
the
unit
cost
of
notification.
This
analysis
assumed
that
notification
would
be
accomplished
using
technical
labor,
valued
at
$
46.08
per
hour.
Thus,
the
total
annual
cost
of
customer
notification
is
$
11,336
and
the
three­
year
cost
is
$
34,008.
­
19­
TABLE
11
ESTIMATED
BURDEN
AND
COST
FOR
CUSTOMER
NOTIFICATION
Cost
Element
Value/
Estimate
Burden
Chemicals
per
SNUR
[
a]
41
Hours
per
manufacturers/
processors/
importers
[
b]
1.0
Manufacturers/
processors/
importers
per
chemical
[
c]
2
SNURs
per
year
[
d]
3
Total
annual
burden
[
e]
=
[
a]*[
b]*[
c]*[
d]
246
Three­
year
burden
[
f]
=
3*[
e]
738
Cost
Cost
per
hour
[
g]
$
46.08
Total
annual
cost
[
h]
=
[
e]*[
g]
$
11,336
Three­
year
cost
[
j]
=
3*[
h]
$
34,008
Total
Burden
and
Cost
to
Industry
­
Summary
of
Industry
Costs
The
total
estimated
industry
burden
associated
with
SNURs
is
equal
to
the
total
of
chemical
verification
burden
(
20.4
hours
annually),
reporting
and
record
keeping
burden
(
594.6
hours
annually)
plus
the
total
customer
notification
burden
(
246
hours
annually),
which
is
equal
to
861
hours
annually.
The
associated
cost
is
estimated
to
be
$
51,030
annually.
Over
a
three­
year
period,
the
burden
is
estimated
to
be
2,583
hours
and
costs
are
estimated
to
be
$
153,090.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
Annual
Respondent
Burden:
861
hours.

Annual
Respondent
Costs:
$
51,030.

(
ii)
The
Agency
Tally
Annual
Agency
Costs:
$
126,261.
­
20­
6(
f)
Reasons
for
Change
in
Burden
Since
the
last
clearance,
annual
industry
burden
estimates
have
decreased
from
1020.3
hours
to
861
hours.
This
change
results
from
updating
estimates
based
upon
historical
information
on
the
number
of
chemicals
per
SNUR
(
adjustment).
Based
upon
revised
estimates,
the
number
of
chemicals
per
SNUR
has
decreased
from
65.5
to
41.
The
overall
result
of
this
adjustment
is
a
decrease
in
estimated
annual
burden
of
159.3
hours.

6(
f)
Regulatory
Flexibility
TSCA
section
5(
a)(
c)
affects
new
uses
of
chemicals
and
requires
those
interested
in
engaging
in
such
a
use
to
notify
the
Agency
of
his/
her
intentions.
Because
the
rule
only
covers
uses
that
a
small
business
does
not
currently
undertake,
a
small
business
is
not
expected
to
immediately
be
affected
by
the
SNUR
unless
it
is
considering
such
a
use
in
the
future.
Although
there
may
be
some
small
businesses
that
may
decide
to
engage
in
significant
new
uses
associated
with
certain
chemicals,
it
is
impossible
to
estimate
the
number
at
this
time.
Additionally,
the
Agency
has
only
received
two
SNUNs
related
to
existing
chemical
SNURs
in
the
past
three
years,
suggesting
that
few,
if
any
small
business
would
be
affected.
This,
coupled
with
the
low
unit
costs
associated
with
filing
a
SNUN
suggest
that
the
overall
impact
will
be
low
for
any
business
that
may
choose
to
file
a
SNUN
or
notify
customers
of
SNUR
activity.
These
costs
are
not
differentiated
between
small
and
large
businesses.

6(
g)
Burden
Statement
The
annual
public
burden
for
this
collection
of
information,
which
is
approved
under
OMB
Control
No.
2070­
0038,
is
estimated
to
be
118.9
hours
per
response.
According
to
the
Paperwork
reduction
Act,
"
burden"
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
For
this
collection
it
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information
;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
number
for
this
information
collection
appears
above.
The
OMB
control
numbers
for
EPA's
regulations
in
title
40
of
the
CFR,
after
appearing
in
the
Federal
Register,
are
listed
in
40
CFR
part
9
and
included
on
the
related
collection
instrument
or
form,
if
applicable.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
­
21­
Docket
ID
No.
OPPT­
2005­
0009,
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
0009
and
OMB
control
number
2070­
0038
in
any
correspondence.
8
Many
Labor
hourly
rates
in
this
analysis
are
lower
than
hourly
rates
for
the
same
labor
categories
in
an
earlier
SNUR
economic
analysis
(
EPAB,
1999).
EPA
does
not
mean
to
suggest
that
actual
hourly
rates
declined.
Rather,
the
apparent
decline
is
due
to
a
changed
method
of
calculating
hourly
costs
for
the
same
labor
categories.
There
were
three
changes:
(
1)
Previously
the
17%
overhead
was
applied
to
wages­
plus­
fringe
benefits.
Now
it
is
applied
only
to
wages.
This
change
reduces
calculated
overhead.
(
2)
Before,
most
wage
rates
were
based
on
older
data
and
then
inflated
to
current
dollars.
Here,
most
wage
rates
are
based
on
recent
data.
(
3)
Finally,
fringe
benefits
were
based
on
an
assumed
percent
of
wages.
Here,
private
industry
fringe
benefits
are
based
on
actual
fringe
benefits
taken
from
recent
BLS
data.

9
Employer
Costs
for
Employee
Compensation,
Private
industry
workers,
Goods­
producing
industries,
white­
collar
occupations,
as
published
by
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics.
The
December
2003
values
for
these
series
were
extracted
on
June
21,
2004.

­
22­
APPENDIX
A
INFLATORS
AND
WAGE
RATES
This
appendix
provides
a
brief
discussion
of
the
wage
rates,
inflators,
and
methods
that
were
used
to
derive
the
final
"
fully
loaded"
wages
used
in
the
calculation
of
quantified
costs.
Base
hourly
wages
for
relevant
labor
categories
were
loaded
with
factors
for
benefits
and
overhead
to
derive
a
loaded
hourly
rate.
If
the
loaded
hourly
rate
was
not
already
in
year
2003
dollars,
it
was
then
inflated
to
year
2003
dollars
by
multiplying
by
the
appropriate
inflation
factor.
The
derivation
of
fully
loaded
wages
in
year
2003
dollars,
for
each
of
the
labor
categories
used
in
the
report,
is
discussed
in
Section
A.
1
and
is
summarized
in
Table
A.
1.
The
derivation
of
the
different
inflation
factors
used
to
inflate
wages
to
year
2003
dollars
is
discussed
in
Section
A.
2
and
is
summarized
in
Table
A.
2.

A.
1.
Derivation
of
Loaded
Wage
Rates8
A.
1.1
Technical,
Managerial,
and
Clerical
Labor
The
basic
method
used
to
derive
loaded
wage
rates
for
technical,
managerial,
and
clerical
personnel
is
described
more
fully
in
Wage
Rates
for
Economic
Analysis
of
the
Toxics
Release
Inventory
Program
(
Rice,
2002).

December
2003
average
wages
for
technical,
managerial,
and
clerical
labor
were
taken
from
the
Employer
Costs
for
Employee
Compensation
(
ECEC)
report
from
the
Bureau
of
Labor
Statistics
for
all
goods­
producing,
private
industries
(
BLS,
2004)
9.

The
additional
cost
of
benefits,
such
as
paid
leave
and
insurance
("
fringe
benefits"),
specific
to
each
labor
category,
are
also
taken
from
the
same
BLS
series.
Fringe
benefit
as
a
percentage
of
wage
is
then
calculated
separately
for
each
labor
category.
For
example,
the
average
wage
rate
in
December
2003
for
technical
labor
was
$
28.36;
the
average
fringe
benefit
was
$
12.90.
So
fringe
benefit
as
a
percentage
of
wage
rate
for
technical
labor
was
12.90/
28.36,
or
approximately
45.5%.
10An
overhead
rate
of
17
percent
applied
to
wages
is
used
for
consistency
with
recent
EPAB
economic
analyses
for
two
major
rulemakings:
Wage
Rates
for
Economic
Analyses
of
the
Toxics
Release
Inventory
Program,
June
10,
2002,
and
the
Revised
Economic
Analysis
for
the
Amended
Inventory
Update
Rule:
Final
Report,
August
2002.
In
reports
for
an
earlier
SNUR
(
EPAB,
1999),
the
17%
was
applied
to
wages­
plus­
fringe
benefits.
Applying
it
only
to
wages
reduces
calculated
overhead.

­
23­
An
additional
loading
factor
of
17
percent
is
applied
to
wages
for
overhead10.
This
overhead
loading
factor
is
added
to
the
benefits
loading
factor,
and
the
total
is
then
applied
to
the
base
wage
to
derive
the
fully
loaded
wage.
The
fully
loaded
wage
for
technical
labor,
for
example,
is
$
28.36*(
1+
0.455
+
0.17)
=
$
28.36*(
1.625)
=
$
46.08.

Fully
loaded
costs
for
managerial
and
clerical
labor
were
calculated
in
a
similar
manner.
­
24­

Table
A.
1
Derivation
of
Loaded
Wage
Rates
Labor
Category
Data
Sources
Uninflated
wages
and
fringes
/
hour
Fringe
benefits
as
%
of
wage
Overhead
as
%

of
wage*
Fringe
+
Overhead
factor
Loaded
Wage
Rate
before
inflation
Inflation
factor
Loaded
Wage
Rate
(
2003
dollars)

Date
Wages
$
Fringe
benefits
$

Technical
BLS
Employer
Costs
for
Employee
Compensation.

Private
industry,

goodsproducing
industries,
Profess.

specialty
&
technical.
Dec
03.

[
BLS,
2004]
Dec
2003
$
28.36
$
12.90
45.5%
17%
1.625
$
46.08
1
$
46.08
Managerial
BLS
Employer
Costs
for
Employee
Compensation.

Private
industry,

goodsproducing
industries,
Exec,

admin,
&
managerial.
Dec
03.

[
BLS,
2004]
Dec
2003
$
32.90
$
15.33
46.6%
17%
1.636
$
53.82
1
$
53.82
Clerical
BLS
Employer
Costs
for
Employee
Compensation.

Private
industry,

goodsproducing
industries,
Admin
support,
incl.
clerical.
Dec
03.

[
BLS,
2004]
Dec
2003
$
15.09
$
6.81
45.1%
17%
1.621
$
24.47
1
$
24.47
*
An
overhead
rate
of
17
percent
applied
to
wages
is
used
for
consistency
with
recent
EPAB
economic
analyses
for
two
major
rulemakings:
Wage
Rates
for
Economic
Analyses
of
the
Toxics
Release
Inventory
Program,
June
10,
2002,
and
the
Revised
Economic
Analysis
for
the
Amended
Inventory
Update
Rule:

Final
Report,
August
2002.

Note:
Calculations
are
based
on
unrounded
values,
so
the
total
may
not
equal
the
product
of
the
rounded
factors.
­
25­
A.
2.
Derivation
of
Inflation
Factors
In
general,
wages
were
inflated
using
the
appropriate
Employment
Cost
Index
(
ECI),
seasonally
adjusted.
Complete
information
on
the
derivation
of
the
inflation
factors
used
is
given
in
Table
A.
2
below.

Table
A.
2
Derivation
of
Inflation
Factors
Report
section
Item
Inflator
data
source
Starting
year
Inflator
for
starting
year
(
A)
Inflator
for
2003
(
B)
Inflation
factor
(
B)
/
(
A)

Section
3
Export
notificatio
n
BLS
Employ.
Cost
Index,
Seas.
Adj.,
White
Collar
Occupations
Series
ECS11102I,
Fourth
Q,
2003
1992
116.1
172.5
1.486
Appendix
C
Agency
Extramural
costs
BLS
Employ.
Cost
Index,
Seas.
Adj.,
White
Collar
Occupations
Series
ECS11102I,
Fourth
Q,
2003
1993
120.4
172.5
1.433
­
26­
APPENDIX
B
AGENCY
COSTS
EPA's
costs
to
review
and
process
industry
submissions
(
SNUNs,
requests
to
modify
SNUR,
and
requests
for
equivalency
determination)
are
assumed
to
be
the
same
as
EPA
costs
to
review
PMNs.
EPA's
costs
associated
with
SNUR
submissions
are
presented
in
Table
B.
1.
The
EPA
staff
level
(
GS­
12),
staff­
year
full­
time
equivalents
(
FTEs)
and
extramural
costs
such
as
costs
for
contractor
support
are
derived
from
the
costs
estimated
for
processing
PMN
submissions
(
RIB,
1994).
The
percent
of
cases
are
from
RIB
1994
and
from
an
1999
SNUR
economic
analysis
(
EPAB,
1999).
FTE
costs
have
been
calculated
using
2003
GS­
12
salary
data
(
OPM,
2003)
and
a
loading
factor
of
1.6
to
reflect
fringe
benefits
and
overhead
(
OPPE,
1992).

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

The
GS­
12
costs
in
the
table
below
are
calculated
by
multiplying
the
number
of
FTEs
(
in
the
first
column)
by
the
fully
loaded
average
salary,
$
106,850.
This
shows
EPA
staff
cost
for
those
chemicals
requiring
this
review
step.
The
Extramural
Cost
column
shows
costs
for
contractor
support
and
other
outside
purchases
for
those
chemicals
requiring
this
review
step,
inflated
from
1993
prices
to
2003
using
the
Employment
Cost
Index,
Total
Compensation
for
White­
Collar
Occupations
(
BLS,
2003a).
The
Weighted
Cost
column
is
calculated
by
multiplying
GS­
12
staff
cost
plus
extramural
costs
(
Unweighted
Cost)
by
the
percentage
of
cases
requiring
this
review
step.
This
calculation
yields
total
Agency
costs
for
submission
review
and
processing
of
$
4,203
per
case.
­
27­
Table
C.
1
Agency
Costs
for
SNUN
and
Other
Submission
Review
and
Processing
Review
Step
EPA
FTE
EPA
staff
(
GS­
12)
(
a)
Extramural
Cost
Unweighted
Cost
Pct.
of
Cases
Weighted
Cost
1993
dollars
2003
dollars
(
b)

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

Prenotice
consultation
0.0024
$
256.44
4
$
5.73
$
262.17
41%
$
107.49
Administrative
prescreen/
notice
receipt/
user
fee
0.0024
$
256.44
92
$
131.84
$
388.28
100%
$
388.28
CRSS
(
Chemical
Review
and
Search
Strategy)
0.0025
$
267.12
268
$
384.04
$
651.17
100%
$
651.17
SAT
(
Structure
Activity
Team)
0.0006
$
64.11
14
$
20.06
$
84.17
100%
$
84.17
Engineering/
Exposure
0.0015
$
160.27
56
$
80.25
$
240.52
100%
$
240.52
Exposure/
Fate
0.0008
$
85.48
0
$
0.00
$
85.48
100%
$
85.48
Focus
0.0009
$
96.16
23
$
32.96
$
129.12
100%
$
129.12
Standard
Review
Functions
0.0219
$
2,340.01
511
$
732.26
$
3,072.27
29%
$
890.96
Division
Directors
Meeting
0.0129
$
1,378.36
113
$
161.93
$
1,540.29
15%
$
231.04
Order
Development/
Negotiation
Review
0.0171
$
1,827.13
22
$
31.53
$
1,858.65
3%
$
55.76
Post
Order
Data
Review
0.0886
$
9,466.87
0
$
0.00
$
9,466.87
3%
$
284.01
Order
Modification
0.2167
$
23,154.31
0
$
0.00
$
23,154.31
3%
$
694.63
New
Chemical
SNUR
Development
0.0277
$
2,959.73
85
$
121.81
$
3,081.54
7%
$
215.71
Notices
of
Commencement
0.0012
$
128.22
40
$
57.32
$
185.54
31%
$
57.52
FOIA
(
Freedom
of
Information
Act)
Requests
0.0333
$
3,558.09
287
$
411.27
$
3,969.36
1%
$
39.69
CBI
(
Confidential
Business
Information)
Substantiation
0.0004
$
42.74
3
$
4.30
$
47.04
100%
$
47.04
TOTAL
$
4,203
Sources:
FTEs
per
review
step
and
1993
extramural
costs
are
from
RIB
1994.
Percentages
of
cases
are
from
RIB,
1994
and
EPAB,
1999.
GS­
12
salaries
are
from
OPM,
2005.
(
a)
The
average
of
GS­
12
Step
1
and
GS­
12
Step
10
salaries
for
2003
was
($
58,070
+
$
75,492)
/
2
=
$
66,781.
This
was
multiplied
by
an
assumed
loading
factor
of
1.6
to
reflect
fringe
benefits
and
overhead,
resulting
in
a
fully
loaded
cost
per
FTE
of
1.6
X
$
66,781
=
$
106,850.
(
b)
Extramural
costs
consist
of
contracting
support
and
other
purchases
directly
attributable
to
the
PMN
review
process.
They
were
inflated
from
1993
prices
to
2003
prices
using
a
factor
of
1.433
(
see
Appendix
A).
REFERENCES
BLS,
2004a.
Bureau
of
Labor
Statistics.
Employment
Cost
Index,
Total
Compensation:
White­
Collar
Occupations
(
Series
ID:
ECS11102I),
http://
data.
bls.
gov/
cgi­
bin/
srgate,
extracted
June
21,
2004.

BLS,
2004b.
Bureau
of
Labor
Statistics.
Employer
Costs
for
Employee
Compensation
­
December
2003:
Private
industry,
goods­
producing
workers
by
occupational
group,
wages
and
total
benefits
(
Series
IDs
CCU420000112000D,
CCU420000111000D,
CCU420000114000D,
CCU430000112000D,
CCU430000111000D,
CCU430000114000D),
http://
data.
bls.
gov/
cgi­
bin/
srgate,
extracted
June
21,
2004.

EPAB,
1999.
Economic
Analysis
of
Expedited
Significant
New
Use
Rules
for
41
Chemical
Substances
and
Background
Support
Document
for
Economic
Analysis
of
Significant
New
Use
Rules.
Washington,
DC:
U.
S.
EPA/
OPPT/
EETD/
EPAB,
July
20,
1999.
EPA
Docket.

Office
of
Personnel
Management
(
OPM),
2005.
Salary
Tables
2002­
DCB,
2003­
DCB.
www.
opm.
gov.

Office
of
Policy,
Planning,
and
Evaluation
(
OPPE),
1992.
Instructions
for
Preparing
Information
Collection
Requests
(
ICRs).
Washington,
DC:
U.
S.
EPA,
June
1,
1992.

Office
of
Pollution
Prevention
and
Toxics
(
OPPT),
1994.
Regulatory
Impact
Analysis
of
Amendments
to
Regulations
for
TSCA
Section
5
Premanufacture
Notifications.

RIB,
1994.
Regulatory
Impacts
Branch.
Regulatory
Impact
Analysis
of
Amendments
to
Regulations
for
TSCA
Section
5
Premanufacture
Notifications.
Washington,
DC:
U.
S.
EPA/
OPPT/
EETD/
RIB,
September
9,
1994.

Rice,
2002.
Cody
Rice.
Wage
Rates
for
Economic
Analysis
of
the
Toxics
Release
Inventory
Program.
Washington,
DC:
U.
S.
EPA/
OPPT/
EETD/
EPAB,
June
10,
2002.

Shapiro,
Michael,
1984.
"
Review
of
Agency
SNUR
Costs",
Memorandum
to
Susan
Hazen,
Office
of
Toxic
Substances,
November
16.

US
EPA,
2004.
MITS
report
on
SNUNs
received,
Years
2001
­
2004.
Management
Information
Tracking
System
Module
of
Confidential
Business
Information
Tracking
System.
December
21.

US
EPA,
1985.
Response
times
and
Labor
Costs
Final
Data
Element
List
Comprehensive
Assessment
Information
Rule,
April
30,
pp.
94­
106.
