ATTACHMENT 3

Premanufacture Notice (PMN) Form and Instructions

EPA Form 7710-25

[For electronic copies of the PMN Form and Instructions, see   HYPERLINK
"http://www.epa.gov/opptintr/newchems/pubs/pmnforms.htm" 
http://www.epa.gov/opptintr/newchems/pubs/pmnforms.htm  and follow the
appropriate links.]



ATTACHMENT 4

Calculation of Hourly Wage Rates

(Excerpt from Economic Impact Analysis)

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 2007 dollars, it was then inflated to year 2007 dollars by
multiplying by the appropriate inflation factor.  The derivation of
fully loaded wages in year 2007 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 2007 dollars is discussed in
Section A.2 and is summarized in Table A.2.

A.1.	Derivation of Loaded Wage Rates tc \l2 "A.1.	Derivation of Loaded
Wage Rates 

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 2007 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, 2008). 

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 2007 for technical labor was $33.25; the
average fringe benefit 

was $16.54.  So fringe benefit as a percentage of wage rate for
technical labor was 16.54/33.25, or approximately 49.7%.

An additional loading factor of 17 percent is applied to wages for
overhead.  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 $33.25*(1+0.497 + 0.17) = $33.25*(1.667) = $55.44.

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

Table A.1  Derivation of Loaded Wage Rates

Labor Category

	

Data Sources	

Uninflated wages and fringes / hour	

Fringe benefits as % of wage	

Over-

head 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,
goods-producing industries, Profess. specialty & technical. Dec 03.
[BLS, 2008]	

Dec

2007	

$33.25	

$16.54	

49.7%	

17%	

1.667	

$55.44	

1	

$55.44



Managerial 	

BLS Employer Costs for Employee Compensation. Private industry,
goods-producing industries, Exec, admin, & managerial. Dec 03. [BLS,
2008]	

Dec 2007	

$41.40	

$19.74	

47.7%	

17%	

1.647	

$68.18	

1	

$68.18



Clerical	

BLS Employer Costs for Employee Compensation.  Private industry,
goods-producing industries, Admin support, incl. clerical. Dec 03. [BLS,
2008]	

Dec

2007	

$16.40	

$8.28	

50.5%	

17%	

1.675	

$27.47	

1	

$27.47

*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.



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 notification	

BLS Employ. Cost Index, Seas. Adj.,  White Collar Occupations Series
ECS11102I, Fourth Q, 1992	

1992	

63.2	

103.6	

1.639



Appendix C

	

Agency Extramural costs	

BLS Employ. Cost Index, Seas. Adj.,  White Collar Occupations Series
ECS11102I, Fourth Q, 1993	

1993	

65.5	

103.6	

163.1



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 a 1999 SNUR economic
analysis (EPAB, 1999).   FTE costs have been calculated  using 2007
GS-12 salary data (OPM, 2008) 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,
$122,854.  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 2007 using the Employment Cost
Index, Total Compensation for White-Collar Occupations (BLS, 2008a). 
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.



Table B.1  Agency Costs for SNUN and Other Submission Review and
Processing



Review Step	

EPA 

FTE	

EPA staff (GS-12) (a)	

Extra-mural Cost	

Unweighted Cost	

Pct.

of Cases	

Weighted Cost



	

1993 dollars	

 2007 dollars (b)



	

	

(1)	

(2)	

(3)	

(4)	

(5)=(2)+(4)	

(6)	

(7)=(5)*(6)



Prenotice consultation	

0.0024	

$294.85	

4	

$6.32	

$301.17	

41%	

$123.48



Administrative prescreen/notice

receipt/user fee	

0.0024	

$294.85	

 92	

$145.54	

$440.39	

100%	

$440.39



CRSS (Chemical Review and Search Strategy)	

0.0025	

$307.14	

268	

$423.98	

$731.12	

100%	

$731.127



SAT (Structure Activity Team)	

0.0006	

$73.71	

14	

$22.15	

$95.86	

100%	

$95.86



Engineering/Exposure	

0.0015	

$184.28	

 56	

$88.59	

$272.87	

100%	

$272.87



Exposure/Fate	

0.0008	

$98.28	

0	

$0.00	

$98.28	

100%	

$98.28



Focus	

0.0009	

$98.28	

23	

$36.39	

$134.67	

100%	

$134.67



Standard Review Functions	

0.0219	

$2,690.50	

511	

$808.40	

$3,498.90	

29%	

$1,014.6896



Division Directors Meeting	

0.0129	

$1,584.82	

113	

$179.22	

$1,764.04	

15%	

$264.614



Order Development/Negotiation Review	

0.0171	

$2,100.80	

22	

$34.80	

$2,135.60	

3%	

$64.07



Post Order Data Review	

0.0886	

$10,884.86	

0	

$0.00	

$10,844.86	

3%	

$326.55



Order Modification	

0.2167	26,622.46	

0	

$0.00	

$26,622.46	

3%	

$798.67



New Chemical SNUR Development	

0.0277	

$3,403.06	

85	

$134.67	

$3,537.53	

7%	

$247.671



Notices of Commencement	

0.0012	

$147.42	

40	

$63.28	

$210.70	

31%	

$65.32



FOIA (Freedom of Information Act) Requests	

0.0333	

$4,091.04	

287	

$454.03	

$4,545.07	

1%	

$45.45



CBI (Confidential Business Information) Substantiation	

0.0004	

$49.14	

3	

$4.75	

$47.04	

100%	

$53.89



TOTAL	

	

	

	

	

	

	

$4,778

Sources: FTEs per review step and 1993 extramural costs are from RIB
1994.  Percents of cases are from RIB, 1994 and EPAB, 1999.  GS-12
salaries are from OPM, 2008. 

(a) The average of GS-12 Step 1 and GS-12 Step 10 salaries for 2007 was
($66,767 + $86,801) / 2 = $76,784.  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 $76,784 = $122,854.

(b) Extramural costs consist of contracting support and other purchases
directly attributable to the PMN review process.  They were inflated
from 1993 prices to 2007 prices using a factor of 1.433 (see Appendix
A). 



ATTACHMENT 5

Selection Criteria -- TSCA Section 8(a) Rule vs.  SNUR

SELECTION CRITERIA:	These criteria serve as guidelines and not as rigid
standards for the regulatory selection process.

SECTION 8(a) Rules – REQUIREMENTS, TYPES OF DATA, USES:

–    Statutory prerequisites: None (i.e., no required risk findings)
other than a legitimate Agency need for such data “as the
Administrator may reasonably require” and the use of notice and
comment rulemaking for the establishment of reporting requirements.

-__Scope: EPA can require reporting by manufacturers, importers, and
processors of both new (PMN) and existing (initial Inventory) chemical
substances.

-__Types of data: EPA may use section 8(a) rules to obtain a variety of
health and environmental data, including data on chemical identity and
structure, uses, volume of production/importation/processing,
byproducts, health and environmental effects, exposure, and disposal.

-__Data support functions: Section 8(a) rules provide background
exposure-related data to support chemical risk assessment; e.g., data
support for section 4 testing decisions, voluntary testing decisions,
section 6 rulemaking, section 9 referral actions, follow-up SNURs, and
chemical advisories.

-__Follow-up monitoring function: Section 8(a) rules can be used to
monitor certain chemical activities which may cause significant new or
ongoing exposures to the subject chemicals (i.e., section 8(a) reporting
rules can be triggered by the commencement of certain prescribed
chemical activities or by prescribed changes in chemical activities);
this type of section 8(a) rule ensures that EPA will receive
notification and information concerning the chemical activities
described in the rule; however, the Agency can only take follow-up
action through lengthy rulemaking (via section 4, 5(a)(2), or 6) or by
civil action in cases of extreme and imminent hazard (via section 7).

CRITERIA THAT FAVOR DEVELOPMENT OF A SECTION 8(a) RULE

-__A need to gather data for chemical risk assessment, with no perceived
need for immediate short-term control action: The basic data support
function described above is the primary function of section 8(a) rules.

-__Lesser health and environmental concerns: If EPA intends to develop a
follow-up/monitoring rule for a particular chemical substance, the
Agency would favor a section 8(a) rule when the level of OPPTS concern
regarding health and environmental effects of the chemical is not
sufficient to require that follow-up action be immediately available
(under section 5(e) or 5(f)) once the reporting requirement is triggered
and notification is received by EPA (e.g., the substances is an eye or
skin irritant; EPA lacks sufficient data on health and environmental
effects for purposes of risk assessment; the substance may cause
transient neurotoxic effects; the substances has moderate acute
toxicity; the substance may persist in the environment; the substance
may cause organ damage or reduced sperm counts; chronic exposure to the
substance may result in health effects that generally are reversible).

-__Activities are ongoing: If EPA intends to develop a
follow-up/monitoring rule for a particular chemical substance, the
Agency would favor a section 8(a) rule when the chemical activities in
question are ongoing at the time of rulemaking (i.e., currently taking
place or recently ceased and likely to resume) or are likely to be
ongoing when the rule is proposed.  By definition, a SNUR would not be
possible under such circumstances.

-__A need for long-term monitoring: A section 8(a) rule is favored if
OPPTS needs to monitor industry-wide production and exposure trends on a
long-term basis, as in the following examples:

(1) The rule may be triggered by a number of different firms over time,
and the activity eventually may be considered ongoing (thereby
preventing a SNUR);

(2) The rule may be triggered a number of times by the same firm, and
the activity may be considered ongoing;

(3) Potential increases in exposure are expected to occur gradually over
time and/or at a number of independent sites, making it necessary for
the Agency to gather, aggregate, and analyze exposure-related data
before making a decision about the potential for unreasonable risk.

SECTION 5(a)(2) SNURS – REQUIREMENTS, TYPES OF DATA, USES:

-__Statutory prerequisites: TSCA does not require a risk finding for
SNURs.  The only statutory requirements are (1) that EPA consider “all
relevant factors” (including the four exposure-related factors in
section 5(a)(2)) before designating a significant new use, and (2) that
the use not be ongoing at the time the SNUR is promulgated (i.e., not
currently taking place or recently ceased and likely to resume).

-__Scope: SNURs may be applicable to manufacturers, importers, and
processors of both new and existing chemical substances.

-__Types of data: EPA is authorized to require SNUR notice submitters to
report the same types of data as may be required under section 8(a),
plus certain types of test data in certain limited cases (note that
health and environmental data must already be in the “possession or
control” of the person submitting the notice (other health and
environmental data which are known to or reasonably ascertainable by the
person submitting the notice, which need only be described)); EPA
generally requires SNUR respondents to complete the PMN reporting form.

-__Follow-up monitoring function: SNURs can serve largely the same
monitoring/notification/ information function as section 8(a) rules,
with three important differences:

(1) A significant new use must be an activity that is not ongoing at the
time the SNUR is promulgated;

(2) A SNUR respondent cannot commence the significant new use while EPA
is evaluating the data in the SNUR notice;

(3) TSCA authorizes EPA to take immediate follow-up control action under
either section 5(e) (the Agency lacks data but determines that the
activity may present an unreasonable risk) or section 5(f) (the activity
will present an unreasonable risk and section 6 action is necessary).

CRITERIA THAT FAVOR DEVELOPMENT OF A SECTION 5(a)(2) SNUR:

– Greater health and environmental concerns: If the potential health
and environmental hazards posed by a chemical substance are of
sufficient concern to OPPTS that the Agency wants to be able to do the
following:

(1) Monitor potential exposure/risk which may be caused by non-ongoing
activities involving the subject chemical;

(2) Prevent these activities from occurring until OPPTS has completed
its assessment of the activities and has determined the potential for
release and exposure;

(3) Take immediately effective control action (if necessary) via section
5(e) or 5(f) to prevent the activities from occurring (at least on an
interim basis) after the completion of Agency review (e.g., the
substance is a possible or probably human carcinogen; the substance may
cause human teratogenic or reproductive effects; the substance has high
acute toxicity; the substance tends to bioaccumulate in living tissue
and is slow to biodegrade; chronic exposure to the substance may result
in health effects that generally are irreversible).

–    Likely that small businesses engage in the activities: Section
8(a) exempts small manufacturers, importers, and processors (as defined
by EPA) from reporting requirements under that section.  The Agency
therefore may not receive adequate data from a section 8(a) rule in some
cases if a substantial number of the firms subject to the rule qualify
as “small.”  If EPA can determine prior to rulemaking that there is
a likelihood that respondents will be small firms, the Agency may wish
to ensure that it will have access to information from these key
potential respondents by developing a SNUR for data-gathering purposes.

OTHER CRITERIA THAT MAY AFFECT THE REGULATORY SELECTION PROCESS
(examined in every case):

-__Federal regulatory action and state statutory/regulatory action
involving the subject chemical: Relevant to the current need for OPPTS
regulatory action, the likelihood of ongoing or future activities, and
past experiences involving the subject chemical.

-__Know past and present activities and projected future activities
involving the subject chemical (including the size of the firms
involved, the volume of production/importation/ processing, potential
releases and exposures, etc.): If available, this information is a
relevant supplement to all of the section 8(a)/SNUR criteria listed
above.

-__Concerns and objective of EPA and the technical staff responsible for
the subject chemical: CCD regulatory staff relies heavily on continuing
input from management (with regard to long-term regulatory objectives
for the subject chemical) and technical staff (with regard to health and
environmental concerns and short-term regulatory objectives).



ATTACHMENT 6

Selected SNUR Case History Abstracts

HEXACHLORONORBORNADIENE (CAS # 2432-99-7)

also known as HEX-BCH.

TOXICITY

•	Extremely persistent compound with a great tendency to
bioaccumulate.

Slow biodegradation.

Very toxic to fish.

Possible analogue to known carcinogens.

II.	REFERRING OFFICE’S CONCERNS/NEEDS

•	Monitor: its manufacture, importation, and processing; intended end
uses, and potential worker exposure and environmental releases.

Once production levels reach a certain point, EPA will reconsider its
decision not to text HEX-BCH.

III.	USES

A.	Past and Ongoing

Commercial batch manufacture and processing.

Intermediate in the production of isodrin which is an intermediate in
the production of 

endrin (both pesticides).

B.	Small Business

Capable of production by a small firm.

IV.	REGULATORY BACKGROUND

Listed on the Preliminary Assessment Information Rule.  (One-time
reporting only).

Listed on the section 8(d) model health and safety data reporting rule
(40 CFR Part 716).

Local limit on its discharge in a public treatment system.  Limit based
on plant’s treatment capacity and not on human health or environmental
risk.

V.	RECOMMENDATION/RATIONALE: Section 8(a) rule for ongoing uses and
significant new use rule for non-ongoing uses.

Well documented high toxicity concern.

Small businesses potential.

Satisfies referring office’s needs.

No federal regulation exists to provide a governmental entity with an
opportunity to

 evaluate potential human and environmental exposures to HEX-BCH from
its 

manufacture, importation, processing, and intended end use; and to
protect human beings 

and the environment from potentially adverse exposures before they
occur.

METHYL N-BUTYL KETONE (CAS # 591-78-6)

also known as MBK.

TOXICITY

           •            Causes central and peripheral neuropathy in
humans.  Nerve damage is irreversible at concentrations as low as 50
ppm.

Absorbed readily through the skin.

Eye and skin irritant.

Limited evidence suggests testicular atrophy.

II.	REFERRING OFFICE’S CONCERNS/NEEDS

•	Monitor: its resumption of commercial manufacture, importation, and
processing; intended end uses, and potential worker and consumer
exposure.  

III.	USES

A.	Past

Commercial manufacture, importation and processing.

Solvent in lacquers, sealers, varnish removers, oils, fats, and waxes. 
(i.e., consumer products).  

B.	Ongoing

Importation for toxicological research and development.

C.	Small Business

Capable of production by a small firm.

IV.	REGULATORY BACKGROUND

Occupational Safety and Health Administration standard (8 hour Time
Weighted Average (TWA) 100 ppm).

American Conference of Governmental Industrial Hygienists TWA 5 ppm.  No
binding effect.

National Institute of Occupational Safety and Health TWA 5 ppm.  No
binding effect.

V.	RECOMMENDATION/RATIONALE: Significant new use rule.

Well documented high toxicity concern.

Small businesses potential.

Satisfies referring office’s needs.

No federal regulation exists to provide a governmental entity with an
opportunity to

evaluate potential human and environmental exposures to MBK from its
manufacture,

 importation, processing, and intended end use; and to protect human
beings and the 

 environment from potentially adverse exposures before they occur.

URETHANE (CAS  # 51-79-6)

Urethane is a name commonly but improperly applied to high molecular
weight polyurethanes used as foams, elastomers, and coatings.  These
products are not made from the urethane, and do not generate urethane
upon decomposition.

TOXICITY

            •	Urethane is well established as a carcinogen.  Malignant
tumors have occurred in many species of animals following the
administration of urethane by the oral, inhalation, topical,
subcutaneous, and intraperitoneal routes.  Urethane is also a
transplacental carcinogen that readily traverses the placenta and
affects the fetus.

Toxic fumes when heated; liver toxin; bone marrow depressant.

II.	REFERRING OFFICE’S CONCERNS/NEEDS

•	Monitor: its resumption of manufacture, importation, and processing;
intended end uses, and potential worker and consumer exposure.  

III.	USES

A.	Past

Commercial manufacture, importation and processing.

Intermediate in the production of N-hydroxymethyl derivatives, which are
useful as cross-linking agents for imparting wash-and-wear properties to
fabrics.

Human medicine: sclerosing agent for varicose veins and hemorrhoids,
anti-neoplastic agent, hypnotic, treatment of chronic leukemia, and
multiple myeloma.

Pharmaceutical intermediate.

B.	Ongoing

Toxicological research.

C.	Small Business

Capable of production by a small firm.

IV.	REGULATORY BACKGROUND

Banned by the Food and Drug Administration as an active and inactive
ingredient in drugs.  FDA also prohibited the use of a food preservative
that produces urethane when it is used tin acidic beverages.

Designated by EPA as a Toxic Hazardous Waste #238.

Listed as a Hazardous material under the Hazardous Materials
Transportation Act.

V.	RECOMMENDATION/RATIONALE: Significant new use rule.

Well documented high toxicity concern.

Small businesses potential.

Satisfies referring office’s needs.

No federal regulation exists to provide a governmental entity with an
opportunity to

 evaluate potential human and environmental exposures from urethane’s
manufacture, 

importation, processing, and intended end use; and to protect human
beings and the 

environment from potentially adverse exposures before they occur.

The consequences of not collecting this information is to allow, without
EPA review, human and environmental exposures to toxic chemical
substances.

PENTABROMOETHYLBENZENE (CAS  # 85-22-3)

also known as PEB.

TOXICITY

	•	Carcinogenicity observed in other structurally related compounds
having a 

                        polyhalogenated aromatic moiety.

Persistent compound with a great tendency to bioaccumulate.

Slow biodegradation.

II.	REFERRING OFFICE’S CONCERNS/NEEDS

•	Monitor: its resumption of commercial manufacture, importation, and
processing; intended end uses, and potential worker exposure and
environmental release.

If production is to be reinstated, EPA will reconsider its decision not
to test HEX-BCH.

III.	USES

A.	Past and Ongoing

Has been used in the past as an additive-type flame retardant.

No known ongoing uses.

B.	Small Business

Capable of production by a small firm.

V.	REGULATORY BACKGROUND

The Interagency Testing Committee designed PEB for priority
consideration in its 15th report.

Listed on the section 8(d) model health and safety data reporting rule
(40 CFR Part 716).

Listed on the Preliminary Assessment Information Rule.  (40 CFR Part
712).

Proposed, pursuant to section 4(a)(1)(A) findings, that chemical fate
and environmental effects testing be performed.

Proposed Test Rule withdrawn due to termination of all known manufacture
and processing operations.

V.	RECOMMENDATION/RATIONALE: Significant new use rule.

Structurally analogous to substances of carcinogenic concern.

Small businesses potential.

Satisfies referring office’s needs.

No federal regulation exists to provide a governmental entity with an
opportunity to

evaluate potential human and environmental exposures to PEB from its
manufacture, importation, processing, and intended end use; and to
protect human beings and the environment from potentially adverse
exposures before they occur.

   9   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.

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
2007 values for these series were extracted onFebruary 29, 2008.

   .

    10 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. 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.

 PAGE  1 

