Supporting
Statement
for
a
Request
for
OMB
Review
under
the
Paperwork
Reduction
Act
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
TITLE:
Voluntary
Cover
Sheet
for
TSCA
Submissions
EPA
ICR
No.:
1780.04
OMB
Control
No.:
2070­
0156
1(
b)
Short
Characterization
This
Information
Collection
Request
(
ICR)
pertains
to
the
voluntary
use
of
a
cover
sheet
that
has
been
developed
by
industry
and
EPA
to
facilitate
the
processing
of
information
that
is
submitted
to
the
Agency
under
sections
4
and
8
of
the
Toxic
Substances
Control
Act
(
TSCA),
or
under
the
Voluntary
Children's
Chemical
Evaluation
Program
(
VCCEP).
The
cost
and
burdens
related
to
the
submissions
under
TSCA
sections
4
and
8
and
VCCEP
have
already
been
approved
the
Office
of
Management
and
Budget
(
OMB)
and
are
contained
in
the
following
ICRs:

(
1)
TSCA
section
4
submissions
are
addressed
in
"
Section
4
Test
Rules
and
Consent
Orders,"
OMB
Control
No.
2070­
0033,
EPA
ICR
No.
1139.
(
2)
TSCA
section
8(
d)
submissions
are
addressed
in
"
TSCA
Section
8(
d)
Health
and
Safety
Data
Reporting
Rule,"
OMB
Control
No.
2070­
0004,
EPA
ICR
No.
0575.
(
3)
TSCA
section
8(
e)
reporting
requirements
are
addressed
in
"
Notification
of
Substantial
Risk
of
Injury
to
Health
and
the
Environment
under
TSCA
Section
8(
e),"
OMB
Control
No.
2070­
0046,
EPA
ICR
No.
0794.
(
4)
Certain
voluntary
reporting
requirements
are
addressed
in
"
Voluntary
Children's
Chemical
Evaluation
Program
(
VCCEP),"
OMB
Control
No.
2070­
0165,
EPA
ICR
No.
2055.

This
ICR,
therefore,
only
applies
to
the
burden
and
costs
associated
with
the
use
of
the
voluntary
cover
sheet
for
those
submissions.

Under
TSCA
sections
4
and
8,
industry
is
required
to
submit
certain
information
and
studies
for
existing
chemical
substances.
VCCEP
is
a
voluntary
reporting
program.
EPA
typically
receives
several
thousand
submissions
each
year,
with
each
submission
consisting
of
three
studies,
on
average.
In
addition,
EPA
may
impose
specific
data
call­
ins
on
industry.

The
submissions
EPA
receives
can
be
numerous,
lengthy
and
complex.
For
example,
EPA
received
10,000
submissions
in
FY
1992
in
response
to
the
TSCA
Section
8(
e)
Compliance
Audit
Program.
Processing
of
these
submissions
was
not
completed
until
FY
1995.
In
June
1994,
EPA
received
900
submissions,
representing
approximately
3,500
studies,
under
a
TSCA
section
8(
d)
data
call­
in
for
siloxanes
by
the
Interagency
Testing
Committee
(
ITC).
2
Submissions/
studies
are
received,
logged,
internally
tracked,
duplicated,
distributed
to
government
scientists
for
review
and
analysis,
indexed,
microfiched
and
made
publicly
available
through
the
TSCA
Test
Submissions
(
TSCATS)
database.
However,
TSCATS
is
only
an
online
index
of,
and
pointer
system
to,
the
large
volume
of
unpublished
studies;
the
full
texts
are
available
only
in
paper
or
on
microfiche.

Under
the
auspices
and
funding
of
the
Silicone
Environmental
Health
and
Safety
Council
(
SEHSC),
industry,
EPA,
and
the
ITC
developed
a
model
software
application
for
submitting
summary
data
for
the
section
8(
d)
siloxane
data
call­
in.
This
model
was
designed
around
the
TSCATS
data
structure
but
expanded
to
include
additional
data
elements
deemed
valuable
by
industry.
The
objective
was
to
capture
comprehensively
all
submissions
and
studies
from
the
ten
SEHSC
member
companies
for
EPA
=

s
more
efficient
and
effective
receipt,
tracking,
processing,
identification,
internal
and
external
search
and
retrieval,
and
upload
to
TSCATS
for
public
availability.
In
addition,
discussions
were
initiated
and
are
ongoing
for
the
electronic
transfer
by
electronic
medium
or
EDI
of
full
submissions.

OPPT
initiated
a
voluntary
pilot
program
to
accept
certain
Health
and
Safety
Data
submissions
in
an
electronic
format.
Participating
companies
submit
TSCA
Health
and
Safety
Study
Cover
Sheet(
s)
with
attached
electronic
copies
of
the
studies
over
the
Internet.
The
studies
are
submitted
in
Portable
Document
Format
(
PDF)
and
digitally
signed
using
the
Public
Key
Infrastructure
(
PKI)
standard.
Allowing
industry
to
submit
TSCA
Health
and
Safety
Studies
over
the
Web
will
reduce
burden
on
Industry
as
well
as
the
Agency
by
incorporating
standardization
and
indexing
of
data,
on­
line
help
and
automatic
processing.
This
will
also
assist
EPA
in
meeting
goals
established
in
the
Paperwork
Reduction
Act
(
PRA)
and
the
Government
Paperwork
Elimination
Act
(
GPEA).

As
a
follow­
up
to
the
experience
with
the
TSCA
section
8(
d)
siloxane
data
call­
in,
the
Chemical
Manufacturers
Association
(
CMA,
now
known
as
the
American
Chemical
Council
[
ACC]
and
so
referred
to
in
the
rest
of
this
document),
the
Specialty
Organics
Chemical
Manufacturers
Association
(
SOCMA),
and
the
Chemical
Industry
Data
Exchange
(
CIDX),
are
actively
and
cooperatively
pursuing
summary
data
transfer
by
software
application
and
EDI.
In
particular,
ACC
led
the
effort
to
develop
the
standardized
cover
sheet
for
voluntary
use
by
industry
as
a
first
step
to
an
electronic
future
and
to
begin
familiarizing
companies
with
standard
requirements
and
concepts
of
electronic
commerce.
This
form,
entitled
"
TSCA
Health
and
Safety
Study
Cover
Sheet,"
was
designed
by
ACC
for
voluntary
use
as
a
cover
sheet
for
submissions
of
information
under
TSCA
sections
4,
8(
d)
and
8(
e),
and
now
under
VCCEP
as
well.

The
voluntary
use
of
a
cover
sheet
facilitates
the
submission
of
information
by
displaying
certain
basic
data
elements,
permitting
EPA
more
easily
to
identify,
log,
track,
distribute,
review
and
index
submissions,
and
makes
information
publicly
available
more
rapidly
and
at
reduced
cost
via
TSCATS,
to
the
mutual
benefit
of
both
industry
and
EPA.
It
is
this
form/
cover
sheet
that
is
addressed
in
this
information
collection
request.
3
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
The
standardized
cover
sheet
discussed
in
this
ICR
is
used
in
conjunction
with
submissions
of
information
as
required
under
TSCA
sections
4,
8(
d),
8(
e)
and
VCCEP.
The
need
and
authority
for
these
reporting
requirements
are
discussed
in
detail
in
the
information
collection
requests
associated
with
these
requirements
and
are
not
themselves
relevant
to
the
discussion
of
the
use
of
the
standardized
cover
sheet
form
that
follows.

ACC
and
member
companies
actively
utilize
electronic
commerce
in
their
daily
business
operations.
They
recognize
the
future
importance
of
electronic
commerce
for
all
their
operations.
This
TSCA
Cover
Sheet
is
a
first
step
in
standardizing
data
and
terms
to
promote
the
acceptance
and
implementation
of
electronic
TSCA
submissions
to
and
communications
with
the
Agency.
ACC
has
determined
that
this
TSCA
Cover
Sheet,
as
a
paper
and
near
term
electronic
version,
will
achieve
efficiencies
through
industry­
industry
and
industry­
EPA
cooperation,
will
engender
more
efficient
systems,
and
will
result
in
significant
money
and
time
savings.

2(
b)
Use/
Users
of
the
Data
EPA
staff
members
in
the
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
are
the
primary
users
of
the
data
found
on
the
standardized
cover
sheet.
OPPT
employees
use
the
information
displayed
on
the
cover
sheet
to
identify
the
submission
when
it
reaches
EPA
without
having
to
examine
portions
of
a
submission
that
may
be
very
lengthy
and
complex.
OPPT
staff
members
subsequently
use
information
from
the
cover
sheet
to
distribute,
locate
and
track
the
submission
as
the
submission
moves
through
Agency
reviews
and
decision
points,
to
index
the
data,
and
to
identify
the
data
within
the
TSCATS
database
in
making
the
data
publicly
available.

OPPT
and
ACC
expect
that
the
use
of
the
TSCA
Cover
Sheet
by
industry
will
provide
EPA
the
following
benefits:
expedited
processing;
reduced
errors;
improved
data
quality;
more
timely
EPA
access
and
scientific
review;
improved
communication
between
EPA
and
industry
submitters;
quicker
public
availability;
and
overall
time
and
money
savings.

In
addition,
ACC
and
OPPT
expect
that
the
use
of
the
TSCA
Cover
Sheet
by
industry
will
provide
industry
the
following
benefits:
improved
internal
company
storage;
more
efficient
preparation
and
submission;
standardized
keywords;
improved
data
quality;
quicker
decisions;
improved
understanding
of
EPA
=

s
needs;
quicker
access
through
TSCATS
to
relevant
studies
by
industry
toxicologists;
and
significant
potential
cost
savings
from
non­
initiation/
non­
duplication
of
studies
through
rapid
TSCATS
availability.
4
3.
NON­
DUPLICATION,
CONSULTATIONS
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
The
use
of
the
Voluntary
TSCA
Cover
Sheet
is
not
a
separate
collection
activity;
rather
it
simply
offers
a
cover
form
that
may
be
used
in
conjunction
with
other
submissions.
These
submissions
still
occur
only
once.
As
such,
there
is
no
duplicative
collection.

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
This
effort
developed
from
the
cooperative
effort
among
the
Silicone
Environmental
Health
and
Safety
Council
(
SEHSC),
the
Interagency
Testing
Committee
(
ITC),
and
EPA
for
the
SEHSC­
developed
data
base
effort
in
response
to
the
30th
ITC
list/
TSCA
section
8(
d)
reporting.
Out
of
this
effort,
ACC
and
SOCMA
initiated
subsequent
discussions
with
EPA
for
their
design
and
pilot
of
the
Voluntary
TSCA
Cover
Sheet.
ACC
and
SOCMA
are
committed
to
encouraging
member
companies
to
use
the
cover
sheet
when
submitting
TSCA
studies
under
sections
4,
8(
d),
8(
e)
and
VCCEP
to
EPA.

EPA
will
pursue
additional
consultations
with
interested
parties
during
the
development
of
the
renewal
of
this
collection.

3(
d)
Effects
of
Less
Frequent
Collection
Since
the
use
of
this
cover
sheet
is
strictly
voluntary
on
the
part
of
respondents,
this
is
not
applicable.

3(
e)
General
Guidelines
The
use
of
this
cover
sheet
does
not
exceed
any
of
the
PRA
guidelines
at
5
CFR
1320.6.

3(
f)
Confidentiality
Any
information
included
on
the
cover
sheet
may
be
claimed
as
confidential
by
the
respondent.
Claims
of
confidentiality
are
handled
according
to
EPA
procedures
described
in
40
CFR
Part
2
and
in
the
TSCA
Confidential
Business
Information
Security
Manual,
which
call
for
careful
protection
of
confidential,
trade
secret
or
proprietary
information.
5
3(
g)
Sensitive
Questions
This
information
collection
does
not
include
questions
of
a
sensitive
nature.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
NAICS
Codes
Respondents
affected
by
this
activity
are
found
mainly
under
NAICS
codes
324
­
Petroleum
and
Coal
Products
Manufacturing,
and
325
­
Chemical
Manufacturing.

4(
b)
Information
Requested
(
i)
Data
Items
The
Voluntary
Cover
Sheet
simply
captures
certain
information
that
is
being
submitted
under
another
approved
ICR.
The
data
items
included
on
the
Cover
Sheet
are
already
contained
in
the
submission
to
which
the
cover
sheet
is
attached,
and
include
the
following:

Data
Element
Description
1.
Submission
Type
Identifies
the
submission,
including
the
type
of
submission
and
whether
it
is
the
initial
submission,
a
follow­
up
or
a
final
report.

2.
Summary
of
Attachment
Allows
the
respondent
to
provide
a
summary
or
abstract
of
the
attached
study
or
report,
any
internal
company
tracking
number,
an
EPA
tracking
number,
and
an
indication
of
the
number
of
studies
submitted.

3.
Chemical
Identification
Identifies
the
chemical(
s)
addressed
in
the
submission.

4.
Title
of
Attachment
Identifies
the
title
of
the
attached
study
or
report.

5.
Indexing
Terms
Allows
the
respondent
to
identify
the
proper
terms
to
use
for
indexing
purposes,
which
facilitates
the
search
and
retrieval
of
the
information.

6.
Study/
Report
Information
Provides
specific
information
regarding
the
attached
study
or
report,
including
the
source,
date
of
the
study
or
report,
sponsor(
s),
and
the
length
of
the
document.
6
7.
Submitter
Information
Identifies
the
submitter
and/
or
technical
contact,
including
name,
title,
company,
mailing
address,
phone
and
e­
mail
address.

8.
Comments
Allows
the
submitter
to
provide
any
additional
comments,
so
as
to
avoid
the
need
for
or
use
of
a
separate
cover
letter.

9.
Signature
A
signature
is
required
for
submissions
under
section
8(
e);
the
cover
form
provides
a
place
for
the
submitter
=

s
signature,
thereby
avoiding
the
need
for
or
use
of
a
separate
cover
letter.

10.
Continuation
Allows
the
submitter
to
expand
the
response
to
any
of
the
previous
items,
if
needed,
without
the
need
to
use
a
separate
cover
letter
or
additional
forms.

A
copy
of
the
sample
Voluntary
Cover
Sheet
for
TSCA
Submissions
is
attached
to
this
ICR,
along
with
the
instructions
provided
to
users.
ACC
designed
the
form
to
capture
all
data
and
information
required
under
"
Notification
of
Substantial
Risk
of
Injury
to
Health
and
the
Environment
under
TSCA
Section
8(
e),"
and
determined
there
was
significant
value
for
standardized
data
presentation
under
TSCA
sections
4,
8(
d)
and
8(
e).
Additionally,
TSCATS
index
codes
to
identify
study
type,
subject
organism
(
if
appropriate),
and
route
of
exposure
(
if
appropriate)
are
included.

(
ii)
Respondent
Activities
After
making
the
determination
to
submit
information
to
EPA
under
TSCA
sections
4
or
8,
VCCEP,
or
to
otherwise
submit
TSCA­
related
chemical
information
to
EPA,
the
submission
of
which
is
covered
under
separate
ICRs,
the
respondent
will
decide
whether
or
not
to
use
the
TSCA
Cover
Sheet
for
that
submission.
The
use
of
the
TSCA
Cover
Sheet
for
submissions
under
TSCA
is
completely
voluntary.
However,
ACC
and
SOCMA
explicitly
solicit
and
encourage
their
members
to
use
it
for
all
such
submissions.

Once
the
respondent
has
decided
to
use
the
Voluntary
TSCA
Cover
Sheet,
the
respondent
simply
completes
the
form
by
transferring
or
summarizing
the
information
that
the
respondent
has
already
assembled
as
part
of
its
submission.
In
many
cases
the
use
of
this
cover
sheet
takes
the
place
of
a
cover
or
transmittal
letter
to
EPA
that
the
respondent
might
otherwise
routinely
prepare,
containing
much
of
the
same
information
as
is
found
on
the
cover
sheet.
Respondents
are
not
obliged
to
prepare
or
develop
additional
data
or
information
in
order
to
use
the
cover
sheet.

The
completed
cover
sheet
is
then
included
as
part
of
the
submission
to
EPA.
Please
note,
this
ICR
does
not
include
any
burden
or
costs
associated
with
the
actual
transmittal
of
the
information
to
EPA,
or
that
associated
with
maintaining
a
copy
of
the
submission
in
their
records.
The
existing
ICRs
that
address
the
underlying
submission
already
include
the
burden
and
costs
7
associated
with
copying
and
mailing
the
submission
to
the
Agency,
and
with
keeping
a
copy
of
the
submission
in
their
records.

5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
OPPT
staff
use
the
information
found
on
the
cover
sheet
to
identify
the
type
of
submission
or
the
type
of
information
contained
in
a
submission,
to
route
a
submission
to
other
EPA
staff
for
review,
evaluation
or
action,
to
file
or
retrieve
a
submission,
and
to
conduct
other
routine
information­
management
tasks
associated
with
the
receipt
and
processing
of
a
submission.
Since
the
information
appears
in
a
consistent,
standardized
format,
OPPT
staff
members
are
able
to
complete
these
tasks
in
a
highly
efficient
manner.

OPPT
staff
members
review
and
take
action
upon
the
submissions
themselves
in
accordance
with
procedures
that
are
described
in
greater
detail
in
the
information
collection
requests
associated
with
the
specific
reporting
requirements
previously
referenced.

5(
b)
Collection
Methodology
and
Management
Since
this
is
a
standardized
cover
sheet
attached
to
a
more
detailed
and
lengthy
submission,
the
collection
methodology
and
management
of
this
cover
sheet
necessarily
follow
the
collection
methodology
and
management
associated
with
the
specific
information
collections
for
which
this
cover
sheet
will
be
utilized.
These
collections
are
described
in
greater
detail
in
the
information
collection
requests
associated
with
the
specific
reporting
requirements
previously
referenced.

In
general
EPA
enters
the
information
found
on
the
cover
sheet
into
Agency
information
management
systems
so
as
to
identify,
locate
and
track
the
submission
as
the
submission
moves
through
appropriate
Agency
reviews
and
actions.
EPA
anticipates
that
the
use
of
the
cover
sheet
by
respondents
will
result
in
cost
and
time
savings,
greater
data
accuracy
and
quality,
and
more
timely
public
availability
of
data.

5(
c)
Small
Entity
Flexibility
The
use
of
this
voluntary
cover
sheet
does
not
directly
affect
any
existing
small
entity
flexibility
applicable
to
respondents
to
the
reporting
requirements
under
TSCA
sections
4,
8(
d),
8(
e)
or
VCCEP.
Any
small
entity
flexibility
associated
with
these
collections
is
described
in
greater
detail
in
the
information
collection
requests
associated
with
these
reporting
requirements.
(
In
general,
reporting
requirements
under
TSCA
sections
8(
d)
and
8(
e)
apply
to
all
respondents,
regardless
of
size.
Small
entities
required
to
report
under
TSCA
section
4
have
certain
options
available
to
them
in
responding
to
those
requirements.
Under
VCCEP,
no
company
is
required
to
8
participate.)
For
those
respondents,
whether
large
or
small,
that
respond
to
these
information
collections,
the
use
of
this
cover
sheet
should
provide
a
more
efficient
means
of
submitting
required
information.
However,
since
the
use
of
this
cover
sheet
is
strictly
voluntary
(
although
the
underlying
reporting
requirement
may
be
mandatory),
a
respondent
may
choose
not
to
use
the
form
at
all.

5(
d)
Collection
Schedule
Since
this
is
a
standardized
cover
sheet
attached
to
a
more
detailed
and
lengthy
submission,
the
collection
schedule
associated
with
this
cover
sheet
necessarily
follows
the
collection
schedules
associated
with
the
specific
information
collections
for
which
this
cover
sheet
will
be
utilized.
In
general,
responses
to
reporting
requirements
under
TSCA
sections
4,
8(
d),
8(
e)
and
VCCEP
are
"
on­
occasion"
responses
for
which
a
strict
collection
schedule
does
not
apply.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
In
using
this
Voluntary
TSCA
Cover
Sheet
effort,
respondents
are
not
required
to
generate
any
new
data;
rather
they
simply
transfer
information
from
the
underlying
submission
to
the
cover
sheet.
Although
the
information
included
in
the
cover
sheet
is
often
included
in
a
cover
letter,
the
Agency
has
not
attempted
to
estimate
any
burden
adjustment
to
the
underlying
ICRs
to
reflect
the
use
of
the
Voluntary
TSCA
Cover
Sheet,
rather
than
a
cover
letter
to
the
Agency.
This
ICR
only
estimates
the
burden
and
costs
associated
with
the
use
of
the
Voluntary
TSCA
Cover
Sheet.
As
such,
it
estimates
the
burden
and
costs
related
to
the
respondent's
review
of
the
instructions,
completion
of
the
form,
and
the
identification
of
the
appropriate
TSCATS
study
index
terms.

6(
a)
Estimating
Respondent
Burden
Based
on
the
industry
estimates
provided
during
the
ACC­
initiated
pilot
of
the
cover
sheet
in
the
spring
of
1996,
which
ranged
from
15
minutes
to
an
hour,
EPA
estimates
that
the
average
burden
associated
with
the
use
of
the
cover
sheet
is
approximately
30
minutes
(
0.5
hour).

Using
recent
estimates
of
the
yearly
average
number
of
potential
submissions
expected
under
the
other
ICRs
for
submissions
related
to
TSCA
sections
4,
8(
d),
8(
e)
and
VCCEP,
and
assuming
that
respondents
used
the
Voluntary
TSCA
Cover
Sheet
for
every
submission,
Table
1
illustrates
the
total
potential
burden
related
to
this
ICR.
This
assumption
effectively
results
in
an
overstatement
of
the
total
burden
associated
with
the
use
of
the
Voluntary
TSCA
Cover
Sheet
since
not
all
respondents
will
choose
to
use
the
cover
sheet.
However,
there
are
no
reliable
data
available
to
suggest
a
lesser
level
of
use
of
the
form
that
EPA
could
use
to
calculate
the
burden
associated
with
its
use.
The
burden
identified
below
should
be
considered
the
maximum
upward
bound
for
the
total
burden
rather
than
a
precise
estimate
of
the
burden
based
on
the
actual
real­
life
use
of
the
form.
9
Table
1
B
Total
Potential
Burden
Submission
Type
Total
Average
Annual
Submissions
Burden
Hours
and
Cost
per
Submission
Burden
Costs
1
Total
Burden
Hours
and
Cost
TSCA
Sec.
4
2
1,425
0.5
$
24.86
712.5
$
35,426
TSCA
Sec.
8(
d)
3
36
0.5
$
24.86
18.0
$
895
TSCA
Sec.
8(
e)
­
initial
4
345
0.5
$
24.86
172.5
$
8,577
TSCA
Sec.
8(
e)
­
follow­
up
4
108
0.5
$
24.86
54.0
$
2,685
VCCEP
4
209
0.5
$
24.86
104.5
$
5,196
Total
Potential
Burden
2,123
0.5
$
24.86
1,061.5
$
52,779
Since
the
Voluntary
TSCA
Cover
Sheet
is
expected
to
be
used
in
lieu
of
the
letter
that
has
been
used
in
the
past
to
transmit
submission
to
the
Agency,
this
burden
should
not
be
considered
additive
to
the
existing
burden
estimates
provided
in
the
underlying
ICRs.
Accounting
for
this
separately
in
this
ICR
may
also
result
in
the
double
counting
of
this
particular
burden.
However,
the
Agency
wishes
to
continue
the
voluntary
use
of
this
cover
sheet
and
will
account
for
its
burden
separately
until
the
form
is
more
widely
used.

6(
b)
Estimating
Respondent
Cost
Based
on
information
provided
by
ACC,
a
technical
level
employee
is
expected
to
complete
the
Voluntary
TSCA
Cover
Sheet.
For
purposes
of
estimating
the
cost
associated
with
completing
this
form,
EPA
used
the
most
current
average
industry
labor
costs
for
technical
employees
of
$
49.72
per
hour
(
Source:
Labor
rates
are
unpublished
December
2004
data
from
BLS
for
all
manufacturing
industries,
the
most
recent
available.
The
estimates
include
fringe
benefits
and
17%
overhead).
As
shown
in
Table
1,
the
total
potential
cost
associated
with
1
This
is
based
on
an
estimated
labor
cost
of
$
49.72/
hour,
as
discussed
in
section
6(
b).

2
Section
4
Test
Rules
and
Consent
Orders,
including
HPV
Challenge
Program
Submissions;
OMB
No.
2070­
0033;
EPA
ICR
No.
1139.06;
February
2005.

3
TSCA
Section
8(
d)
Health
and
Safety
Data
Reporting
Rule;
OMB
No.
2070­
0004;
EPA
ICR
No.
0575.09;
April
2005.

4
Notification
of
Substantial
Risk
of
Injury
to
Health
and
the
Environment
under
TSCA
Section
8(
e);
OMB
No.
2070­
0046;
EPA
ICR
No.
0794.10;
September
2005.

5
Data
Submissions
for
the
Voluntary
Children's
Chemical
Evaluation
Program
(
VCCEP);
OMB
No.
2070­
0165;
EPA
ICR
No.
2055.02;
December
2005.
10
completing
the
cover
form
is
$
52,779.

6(
c)
Estimating
Agency
Burden
and
Cost
Industry
use
of
the
cover
sheet
does
not
increase
Agency
burden
and
cost
over
that
currently
associated
with
these
information
collections.
It
is
anticipated,
in
fact,
that
the
Agency
=

s
costs
for
data
processing,
system
support
and
storage
and
distribution
may
decrease.
Currently
EPA
staff
must
extract
cover
sheet
information
from
the
submission
itself
and
any
accompanying
cover
letter;
this
task
will
be
eased
by
EPA
staff
being
able
to
obtain
necessary
information
directly
from
the
standardized
form.

Current
Agency
burden
and
costs
are:

Section
4:
5,911
hours
/
$
327,883
(
Source:
Section
4
Test
Rules
and
Consent
Orders;
OMB
No.
2070­
0033;
EPA
ICR
No.
1139.07;
June
2005)

Section
8(
d):
5,720
hours
/
$
233,908
(
Source:
TSCA
Section
8(
d)
Health
and
Safety
Data
Reporting
Rule;
OMB
No.
2070­
0004;
EPA
ICR
No.
0575.09;
February
2003)

Section
8(
e):
$
50,685
(
Source:
Notification
of
Substantial
Risk
of
Injury
to
Health
and
the
Environment
under
TSCA
Section
8(
e);
OMB
No.
2070­
0046;
EPA
ICR
No.
0794.10;
June
2003)

VCCEP:
1,100
hours
/
$
575,242
(
Source:
Data
Submissions
for
the
Voluntary
Children's
Chemical
Evaluation
Program
(
VCCEP);
OMB
No.
2070­
0165;
EPA
ICR
No.
2055.01;
September
2003)

In
addition,
it
should
be
noted
that
the
time
and
costs
for
making
publicly
available
TSCA
data
and
information
in
TSCATS
is
estimated
to
be
reduced
by
approximately
25­
33%
for
studies/
submissions
utilizing
the
voluntary
cover
sheet.

6(
d)
Bottom
Line
Burden
Hours
and
Costs
(
i)
Respondent
Tally
Each
use
of
the
cover
sheet
is
estimated
to
result
in
a
burden
of
0.5
hours,
at
a
cost
of
$
24.86.
The
Agency
estimates
a
total
of
2,123
submissions
each
year,
so
the
total
potential
burden
associated
with
this
ICR
is
estimated
to
be
1,061.5
hours,
at
an
estimated
cost
of
$
52,779.
11
(
ii)
Agency
Tally
Industry
use
of
the
cover
sheet
does
not
increase
Agency
burden
and
cost
over
that
currently
associated
with
the
underlying
information
collections
with
which
the
cover
sheet
is
used,
which
are
covered
by
other
ICRs.

6(
e)
Reasons
for
Change
in
Burden
There
is
a
decrease
of
8,074.5
hours
(
from
9,136
hours
to
1,061.5
hours)
in
the
total
estimated
respondent
burden
compared
with
that
identified
in
the
information
collection
most
recently
approved
by
OMB.
This
decrease
reflects
a
decrease
in
the
estimated
number
of
submissions
under
TSCA
sections
4,
8(
d)
and
8(
e),
offset
by
the
estimated
number
of
submissions
under
VCCEP,
for
which
the
Voluntary
TSCA
Cover
Sheet
could
be
used,
in
particular
a
substantial
decrease
in
the
estimated
number
of
TSCA
section
4
submissions.
(
As
discussed
in
the
TSCA
section
4
ICR
identified
elsewhere
in
this
document,
this
decrease
results
from
a
reduction
in
the
estimated
number
of
section
4
test
rules
and
Enforceable
Consent
Agreements
EPA
expects
to
issue,
as
well
as
a
reduction
in
the
estimated
testing
remaining
for
the
HPV
Challenge
Program.
EPA
also
now
estimates
the
VCCEP
submissions
in
a
separate
ICR.)
Since
the
use
of
the
Voluntary
TSCA
Cover
Sheet
is
a
direct
reflection
of
the
number
of
submissions
received
under
TSCA
sections
4,
8(
d),
8(
e)
and
VCCEP,
any
change
in
the
estimated
numbers
of
submissions
under
those
requirements
will
result
in
a
parallel
change
in
the
burden
hours
associated
with
this
information
collection.
The
potential
number
of
annual
submissions
may
change
from
year
to
year,
but
the
Agency
believes
that
the
estimated
number
of
submissions
used
in
this
ICR
is
reasonable.
In
addition,
EPA
now
uses
more
accurate
BLS
data
for
labor
rates,
resulting
in
lowered
respondent
costs.
This
decrease
represents
an
adjustment.

6(
f)
Burden
Statement
The
annual
public
burden
for
this
collection
of
information,
which
is
approved
under
OMB
Control
No.
2070­
0156,
is
estimated
to
average
0.5
hours
per
response.
According
to
the
Paperwork
Reduction
Act,
A
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;
train
personnel
to
be
able
to
respond
to
the
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
and
on
the
form.
In
addition,
the
OMB
control
numbers
for
EPA
=

s
regulations,
after
initial
display
in
the
final
rule,
are
listed
in
40
CFR
part
9.

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
12
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
EPA­
HQ­
OPPT­
2006­
0499,
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
the
Federal
Docket
Management
System
(
FDMS)
at
www.
regulations.
gov.
Use
FDMS
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.
EPA­
HQ­
OPPT­
2006­
0499
and
OMB
control
number
2070­
0156
in
any
correspondence.
