Supporting Statement for a Request for OMB Review under

The Paperwork Reduction Act

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

	1(a)	Title and Number of the Information Collection

	Title:	Partial Update of the TSCA Section 8(b) Inventory Data Base,
Production and Site Reports

EPA ICR No.:   1884.04	OMB Control No.:   2070-0162

	1(b)	 Short Characterization

	This document provides the estimated burden hours and costs associated
with the information collection activities of the Inventory Update
Reporting (IUR) program under the Toxic Substances Control Act (TSCA)
(40 CFR part 710). Approved under OMB Control No. 2070-0162, the
previous ICR (EPA ICR No. 1884.03) covered the information collection
activities contained in the IUR as amended in 2003. 

	Under TSCA section 8(b) (15 USC 2607), the Environmental Protection
Agency (EPA) is required to compile and keep current, via periodic
inquiry, the Inventory of Chemical Substances in Commerce (TSCA
Inventory).  The TSCA Inventory is a listing of chemical substances
manufactured, imported and processed for commercial purposes in the
United States.  The Office of Prevention, Pesticides and Toxic
Substances (OPPTS) has used the IUR to update the basic chemical
production information for selected larger volume chemicals in the TCSA
Inventory six times (every four years), beginning in 1986.  Prior to the
2006 collection, EPA implemented various amendments to the IUR,
including the requirement to report manufacturing, processing, and use
exposure-related information; changes to the chemical substances subject
to reporting, such as the addition of inorganic chemical substance to
the reporting requirement and the addition of partially-exempted
chemical substance lists; changes to the reporting frequency and the
records retention period; revisions to certain CBI requirements; and
changes to the reporting threshold.  The next collection, in 2011, will
also include the manufacturing, processing, and use exposure-related
data elements.

	OPPTS will use the updated IUR data in its risk-management efforts. 
Individual plant or factory sites producing or importing chemicals will
submit the required information.  The information will be stored and
used in both hard-copy and electronic forms for reference by EPA staff
and others.  Further discussion of how the information is used, stored,
and collected is included in this document.

	EPA maintains databases containing the IUR data.  Information submitted
prior to the 2006 IUR is maintained in a series of databases called the
Chemical Update System (CUS).  The 2006 IUR and future submissions are
maintained in an IUR database in the Manage Toxic Substances (MTS)
system. Respondents either mail or electronically submit a completed
Form U (EPA Form 7740-8), the IUR reporting form, to EPA during the
reporting cycle that now occurs every five years.

The collection is expected to involve about 4,200 respondents at an
annual cost of $20 million.  The details of the paperwork burden cost
estimates are discussed in this document.

2.	NEED FOR AND USE OF THE COLLECTION

2(a)	Need/Authority for the Collection

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

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

Table 1.  Examples of Chemical-specific Information EPA is Authorized to
Collect 

Under Section 8(a) of the Toxic Substances Control Act

Common or trade name, chemical identity, and molecular structure of each
chemical substance or mixture for which reports are required.

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

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

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

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

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

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



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

Beginning with the 2006 IUR, the Agency collected basic exposure-related
manufacturing, processing and use information in addition to the
production and site identification information.  These data are used to
augment and expand databases of exposure-related information that the
Agency uses in everyday, basic decision-making.  Because exposure is a
key component of risk, the IUR exposure-related information allows OPPT
to screen chemicals based on the potential for risk in order to protect
human health and the environment, as required by TSCA.  The
exposure-related data on manufacturing, processing, and use allow the
Agency and others to potentially avoid more burdensome requirements. 
These data allow a more effective and efficient screening level review
of chemicals to identify candidates for further evaluation.  By
providing the means for better prioritization of limited resources on
the basis of risk, the 2006 IUR greatly enhances the Agency’s efforts
to achieve better public health, sustainable development, environmental
justice, pollution prevention, sound science, partnerships, and
ecosystem protection.  The success of the New Chemicals Program—where
over 47,000 chemicals have been screened using data similar to the IUR
data—demonstrates the value of having sufficient information to screen
chemicals based on an adequate representation of potential risk.  These
improvements will continue with the information from the 2011 IUR.

2(b)	Practical Utility/Users of the Data

	The IUR information collection enables EPA to collect basic information
on TSCA commercial chemicals, including current production volume,
site-related data, and manufacturing, processing, and use
exposure-related data.  This information collection is necessary because
it is the only mechanism through which EPA’s need for basic
information on chemicals manufactured, produced, or imported can be
fully and effectively satisfied.  The information collected is utilized
in the following ways:

(1) Parent company and technical contact identification information: 
These data are collected to identify the parent company responsible for
the data.

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

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

(4) Manufacturing-related information for each chemical, including
whether the chemical is manufactured or imported, its reporting year
production volume, whether it is site-limited, the number of workers
reasonably likely to be exposed to the chemical, its maximum
concentration, and its physical form(s) and related percent production
volume: This information is used in chemical exposure and risk
screening, testing and/or review priority setting and exposure
estimation required by the Interagency Testing Committee (ITC) under
TSCA section 4; for EPA monitoring activities of newly manufactured
substances that have completed PMN review under TSCA section 5(a); to
support the development of TSCA regulations under section 6; and to
measure potential of human and environmental exposure under TSCA section
8(e).  Each data element corresponds to a data point necessary for basic
risk-screening -- for example, a site-limited intermediate chemical is
presumed to have lower exposure potential because it is not distributed
outside the manufacturing plant for commercial purposes.

Some respondents must also report for chemicals produced in excess of
300,000 pounds on a per-site basis:

(5) Industrial processing and use data, including types of industrial
use and associated industry NAICS codes, industrial function, estimated
number of sites, and estimated numbers of workers reasonably likely to
be exposed:  These data are used to determine exposure potential based
on industrial processing and use, including related environmental
releases.   

 

(6) Commercial and consumer end-use exposure data, including categories
of products, the maximum concentration in each category, and whether the
chemical is used in products intended for children:  These data are used
to determine exposure potential based on consumer and commercial use,
including related environmental releases.

	Information secured through the IUR collections is increasingly used by
a wide variety of governmental and non-governmental users.  Consistent
with Congress’s intent that TSCA data be used to facilitate any
government public health and environment efforts, IUR data have been
used by EPA’s Office of Water, Office of Solid Waste and Emergency
Response, and Office of Air and Radiation to identify and characterize
particular chemical substances.  Non-confidential IUR data are
incorporated into a number of databases and products maintained by
organizations including Right-To-Know-Net and INFORM.  IUR data were
used to identify chemicals of particular concern for the National
Institutes of Health.  Non-confidential IUR data were also released to
selected states to help them identify facilities manufacturing suspected
endocrine disrupters.  

	Under TSCA, EPA has an obligation to protect human health and the
environment from unreasonable risks associated with chemicals under its
jurisdiction.  In order to evaluate potential chemical risks, EPA has
determined that a portion of the chemicals (both organic and inorganic)
on the TSCA Inventory currently warrant the continued collection of
manufacturing information, and that a subset of those chemicals (i.e.,
those produced in quantities of 300,000 pounds or more at a site)
currently warrant the collection of supplementary processing and use
information.  The IUR provides an accurate and readily available source
of basic manufacturing information for about 7,600 of the 83,000
substances listed on the Inventory and basic processing and use
information for a subset of about 4,500 substances, thus significantly
limiting industry’s reporting burden while providing EPA with
information necessary to conduct screening level assessments for risks
to human health and the environment.

	Improving the Agency’s ability to set priorities results in a variety
of benefits.  Agency resources will be more efficiently and effectively
directed to high priority chemicals of concern.  Industry efforts to
address chemicals of concern will also be better targeted.  Overall,
public and private resources will be maximized and public health and the
environment will be better protected.

	EPA uses the information submitted through this collection to update
the Agency’s comprehensive chemical manufacturing, exposure, and use
database, maintained as part of the Manage Toxic Substances (MTS)
system.  IUR data prior to the 2006 collection are maintained in a
series of databases known as the Chemical Update System (CUS).  The MTS
IUR data, combined with CUS and the Chemicals in Commerce Information
System (CICIS) database, serves as a primary source of information for
EPA, as well as other Federal Agencies, about the chemical industry -
the chemicals used, where they are produced, how much is produced or
imported, and how they are processed and used.  The chemical industry is
dynamic, therefore continual updating of the database is necessary.

	EPA collects readily obtainable (to the manufacturer or importer)
exposure-related data that can be used to better establish priorities
for EPA’s Existing Chemical Assessment program.  The IUR data elements
are related to or are indicative of three components of exposure.  These
components are: (1) the size of human populations potentially exposed,
(2) the potential routes of exposures experienced by the environment or
humans, and (3) the frequency and duration of potential exposures. 
Examples of data elements of interest for each component are:

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

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

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

	EPA has demonstrated the usability of the 2006 IUR data by making
public, less than a year after the close of the 2006 IUR submission
period, risk-based prioritization documents providing screening-level
exposure and risk assessments for a number of chemicals in the
Agency’s HPV Challenge program.  These screening-level assessments
rely on the IUR manufacturing, processing, and use exposure-related
information. 

EPA’s careful design of the IUR data collection facilitated efficient
data management and use.  Data collected through the 2006 IUR are placed
into a relational database in the Agency’s Manage Toxic Chemicals
(MTS) system, which can be easily searched, compared, and used.  The
collection of specific data, organized by codes, instead of textual
information presented in an unstructured manner, lends itself to such a
database format.  In addition, electronic IUR submissions allow data to
be entered into the database more accurately and expeditiously,
resulting in a quick turnaround between the submission of the data to
the Agency and the availability of the data for use.  More than half of
all reports were submitted electronically for the 2006 IUR, and the
Agency expects that figure to increase in subsequent years.

Data Uses

	Data generated by the IUR are used in a wide variety of programs
fundamental to fulfilling the Agency’s TSCA statutory mandate. 
EPA’s primary use of these data is to identify priority TSCA chemicals
for more detailed information gathering, risk assessment, and risk
management, and to develop targeted programs to protect human health and
the environment.  Since screening chemical risks generally requires a
combination of both hazard and exposure information, the absence of
exposure-related data beyond production volume data in the previous
collection cycles severely limited the utility of the IUR data for risk
screening.  This lack of exposure-related data made it difficult for EPA
and others to identify chemicals of concern, or resulted in generating
overly conservative exposure assessments based on incomplete
information. The IUR manufacturing, processing, and use exposure-related
data, compiled into a searchable database format, enable EPA and others
to more readily screen chemicals for potential exposure and risk.  These
reviews allow EPA and others to better prioritize chemicals to identify
those warranting more detailed assessments, and to reprioritize
chemicals of lower concern for review.  Current and potential uses of
these data by EPA and others are discussed below.  Note that these
examples are illustrative, not exhaustive.  Programs using the IUR data
range from the more traditional existing chemicals risk screening
efforts, such as the Chemical Assessment and Management Program (ChAMP),
to voluntary programs, such as Design for the Environment (DfE), to
individual requests for analysis of chemicals not specifically
associated with a particular program.  The Agency anticipates that, as
was true even for the basic production data reported under previous
collections, new uses of current IUR data by EPA and by others will
continually emerge and cannot be predicted at this time.

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

Current Uses of the 2006 IUR Data 

The Security and Prosperity Partnership of North America (SPP) program
is a collaboration among the United States, Canada, and Mexico to
accelerate and improve effectiveness of actions to safeguard the health
and environment, provide cost-effectiveness for businesses and
governments, and strengthen regulatory authority.  

EPA initiated the Chemical Assessment and Management Program (ChAMP) to
fulfill commitments made under SPP.  The Agency is developing
screening-level Risk-based Prioritization (RBP) documents that summarize
basic hazard and exposure information on HPV Challenge program
chemicals, identify potential risks, note scientific issues and
uncertainties, and indicate the initial priority being assigned by the
Agency for potential future appropriate action.  The 2006 IUR data is
essential to the development of these RBP documents, providing the
screening level exposure-related data necessary for the initial priority
determination.  

The IUR data provides EPA with the ability to access and initiate
appropriate action on over 6,750 existing chemicals which have
production volumes of 25,000 pounds per year by 2012.  The Agency is
using the 2006 IUR data to develop screening-level assessments for
Medium Production Volume (MPV) Chemicals. 

The TSCA Interagency Testing Committee (ITC) has requested IUR data to
identify chemicals as candidates to recommend for further testing or
information reporting.  In this process, the ITC eliminates many
chemicals for which the ITC does not recommend further testing.  The ITC
has fourteen (14) U.S. Government member organizations:  the Agency for
Toxic Substances and Disease Registry (ATSDR), Council on Environmental
Quality (CEQ), Consumer Product Safety Commission (CPSC), Department of
Agriculture (USDA), Department of Defense (DOD), Food and Drug
Administration (FDA), Department of the Interior (DOI), EPA, Department
of Commerce (DOC), National Cancer Institute (NCI), National Institute
of Environmental Health Sciences (NIEHS), National Institute for
Occupational Safety and Health (NIOSH), National Science Foundation
(NSF), and Occupational Safety and Health Administration (OSHA). The ITC
will use the IUR information to refine its selection of chemicals for
testing, information reporting, or another recommendation.  In the past,
the primary exposure information the ITC used is production volume from
the IUR; the addition of use and exposure information allows ITC to
refine its recommendations.  For instance, in 1991, OSHA asked ITC to
review a list of chemicals to recommend for dermal absorption testing -
ITC recommended 80 chemicals for testing.  With the additional IUR
information, ITC could have screened those 80 chemicals and provided a
more accurate, targeted recommendation.

The U.S. Geological Survey (USGS) has requested IUR information to help
prioritize chemicals in their National Water Quality Assessment Program.

3.	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

	3(a)	Non-Duplication

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

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

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

	EPA continues to use existing data sources and information sets. 
However, the existing sources are generally best used when conducting a
more detailed risk assessment of a specific chemical of concern, rather
than preliminary risk screening of a large set of chemicals.  The 2006
and later IUR submissions provide a consistent set of screening-level
exposure data that allow EPA to better identify on a relative basis the
chemicals of highest priority for further risk evaluation.  EPA uses the
IUR data to identify those specific chemicals that are of potential
concern and need follow up assessment.  For instance, the IUR
exposure-related data coupled with the HPV Challenge Program hazard data
provide the input needed to effectively develop risk-based priorities
for more detailed assessment of chemicals.  Once EPA has determined that
a specific chemical (or group of chemicals) has sufficient potential for
exposure to warrant further assessment, the Agency will utilize the
other information sources and data gathering tools as appropriate.

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

	3(b)	Public Notice Required Prior to ICR Submission to OMB

	  SEQ CHAPTER \h \r 1    SEQ CHAPTER \h \r 1 In proposing to renew this
ICR, EPA provided a 60-day public notice and comment period that ended
on November 4, 2008 (73 FR 51805, September 5, 2008).  EPA received
comments from the American Petroleum Institute (API) and the Consumer
Specialty Products Association (CSPA). These comments are addressed in
Attachment 5, below.

	3(c)	Consultations

	  SEQ CHAPTER \h \r 1 Additionally, under 5 CFR 1320.8(d)(1), OMB
requires agencies to consult with potential ICR respondents and data
users about specific aspects of ICRs before submitting an ICR to OMB for
review and approval.  In accordance with this regulation and based on
OPPTS Regulatory Coordination Staff guidance, EPA submitted questions to
nine parties via email.  The individuals contacted were:

Bill Allmond

Director, Government Relations

Synthetic Organic Chemical Manufacturers Association

1850 M Street, NW, Suite 700

Washington, DC 20036

  HYPERLINK "mailto:allmondb@socma.org"  allmondb@socma.org  

William Carteaux

President

Society of the Plastics Industry, Inc.

1667 K Street, NW

Washington, DC 20006

  HYPERLINK "mailto:wcarteaux@plasticsindustry.org" 
wcarteaux@plasticsindustry.org  

Rod Dwyer

Deputy General Counsel

National Mining Association

101 Constitution Avenue, NW, Suite 500 East

Washington, DC 20001

  HYPERLINK "mailto:rdwyer@nma.org"  rdwyer@nma.org  

Howard Feldman

Director, Regulatory and Scientific Affairs

American Petroleum Institute

1220 L Street, NW

Washington, DC 20005

  HYPERLINK "mailto:feldman@api.org"  feldman@api.org  

Dennis Griesing

Vice President, Government Affairs

The Soap and Detergent Association

1500 K Street, NW, Suite 300

Washington, DC 20005

  HYPERLINK "mailto:dgriesing@sdahq.org"  dgriesing@sdahq.org  

	Brigid Klein

	General Counsel

	Consumer Specialty Products Association

	900 17th Street, NW, Suite 300

	Washington, DC 20006

	  HYPERLINK "mailto:bklein@cspa.org"  bklein@cspa.org  

Chuck O’Hara

Manager, Global Government Relations

Procter & Gamble

701 Pennsylvania Ave., NW, Suite 520

Washington, DC 20004

  HYPERLINK "mailto:ohara.cb@pg.com"  ohara.cb@pg.com  

Lawrence Robinson

President, Color Pigments Manufacturers Association

P.O. Box 20839

Alexandria, VA 22320

  HYPERLINK "mailto:jlr@cpma.com"  jlr@cpma.com  

	Mike Walls

	Director, Regulatory and Technical Affairs

	American Chemistry Council, Inc.

	1300 Wilson Boulevard

	Arlington, Virginia 22209

	  HYPERLINK "mailto:mike_walls@americanchemistry.com" 
mike_walls@americanchemistry.com  

	  SEQ CHAPTER \h \r 1 EPA received no responses to its solicitation for
consultations.  A copy of EPA’s consultation e-mail to the above nine
potential respondents is included below as Attachment 6.

	3(d)	Effects of Less Frequent Collection

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

	Despite these issues, EPA decreased the frequency of collection from
every four years to every five years when promulgating the 2003
Amendment (see 68 FR 848, January 7, 2003).  Any further decrease in the
reporting frequency would jeopardize the utility of the data in decision
making.  Experience with past IUR collections illustrates that from one
collection to the next collection, there was a turnover in chemicals
reported of about 25-30%; that is, twenty-five to thirty percent of the
chemicals reported in one collection year were not reported in the next
collection year.  Less frequent collection is expected to increase this
turnover, reducing the utility of the database.

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

	3(e)	General Guidelines

	This collection does not exceed any of the Paperwork Reduction Act
guidelines at 5 CFR 1320.6, with the exceptions listed below.

	The record retention period of this collection is five years, exceeding
the PRA maximum of three years.  This is necessary to ensure companies
retain records long enough to facilitate completion of Form U (EPA Form
7740-8) in the next collection, which is in five years, and to allow
EPA’s enforcement activities to cover two IUR reporting cycles.

	Confidential Business Information (CBI) claims limit access to the IUR
data, especially by the general public.  EPA recognizes that some
information submitted to the Agency is legitimately business
confidential; because of this, EPA’s review of CBI data is an
inherently governmental function that EPA must perform to protect human
health and the environment.

  

	3(f)	Confidentiality

	Respondents may claim information submitted to EPA under this rule as
confidential if such information would reveal the submitters’ trade
secrets or proprietary information as defined by TSCA section 14 and
existing TSCA regulations.  EPA has long-established procedures for
handling, storing, processing and disposing of TSCA confidential
information. Transfers of this information to other governmental
agencies can only be accomplished if the other agency agrees to adhere
to all TSCA confidentiality provisions.  EPA will maintain standard CBI
procedures to protect any confidential, trade secret, or proprietary
information from disclosure in accordance with EPA’s confidentiality
regulation, 40 CFR Part 2, Subpart B.

	3(g)	Sensitive Questions

	This collection does not include questions of a sensitive nature.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

	4(a)	Respondent NAICS Codes

	The regulated community consists of companies manufacturing or
importing chemicals listed on the TSCA Inventory and regulated under
TSCA section 8.  In general, the industry segments that compose the
regulated community for the rule are those that produce or import
organic and inorganic chemicals.  Most respondents previously reported
information under the IUR.  Due to the past experience the Agency has
had with respondents to the IUR, it is anticipated that the majority of
the respondents affected by this collection activity are from the
following North American Industrial Classification System (NAICS) code
categories:

	325 - Chemical Manufacturing (including importing)

	324 - Petroleum and Coal Product Manufacturing (including importing)

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

	Generally, TSCA section 8 excludes small manufacturers (including
importers) from reporting.  EPA defines small manufacturers (including
importers) for purposes of IUR and certain other reporting in 40 CFR
704.3.

	4(b)	Information Requested

		(i) Data items

	The IUR data elements are primarily related to or indicative of three
components of exposure.  These components are: (1) the number of
ecosystems or size of human populations potentially exposed, (2) the
potential exposures or concentrations experienced by the environment or
humans, and (3) the frequency and duration of potential exposures.  The
data enhances EPA’s ability to evaluate each of these components of
exposure.  Respondents are required to submit certain known or
reasonably ascertainable manufacturing exposure- related information and
readily obtainable processing and use exposure-related information.

	Using Form U (EPA Form 7740-8; see Attachment 4), respondents report on
data items as follows:

Certification.  Company Official must certify by signature and date that
to the best of their knowledge and belief 1) all information entered on
Form U has been completed in compliance with the regulatory
requirements; and 2) that the confidentiality statements on Form U are
true and correct.

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

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

Chemical Identification (for chemicals with reporting year,
site-specific production volume of 25,000 pounds or more).  Specific
chemical name and CAS registry or accession number, as applicable.  

Manufacturing Information.  Whether chemical is site-limited or not,
whether chemical is manufactured or imported, manufactured production
volume, imported production volume, number of workers reasonably likely
to be exposed (in ranges), maximum concentration of chemical (in
ranges), and physical form of chemical with associated percent
production volume.

Industrial Processing and Use Data (only for chemicals with reporting
year, site-specific production volumes greater than or equal to 300,000
pounds).  Up to 10 unique combinations of type of process or use (code),
North American Industrial Classification System (NAICS) code associated
with specific combination, and industrial function category.  For each
unique combination, the percentage of respondent’s production volume,
number of processing and use sites (in ranges), and number of reasonably
likely to be exposed workers (in ranges).

Commercial and Consumer End-use Exposure Data (only for chemicals with
reporting year, site-specific production volumes greater than or equal
to 300,000 pounds).   Commercial/consumer use category whether a
chemical is intended for use in children’s products, percentages of
respondent’s production volume in each commercial/consumer use
category, and maximum concentration of chemical in each
commercial/consumer use category (in ranges).

		(ii) Respondent Activities

	A representative respondent would engage in the following activities:

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

	Rule Familiarization -- become familiar with the full requirements of
the rule, which entails reading the rule, understanding the various
reporting and administrative requirements, and determining the manner in
which reporting requirements will be met for each chemical;

	Preparation and Submission of Reports -- compile the required
information and complete a reporting form, including determining the CBI
status of information and fulfilling appropriate substantiation
measures. Respondents use a software program (eIUR) to complete Form U
(EPA Form 7740-8), and either complete only Parts I and II for chemicals
produced in quantities less than 300,000 pounds or complete the full
form for chemicals produced in quantities of 300,000 pounds or greater.
Respondents must complete the form as applicable; and

	Recordkeeping -- retain records for five years following a submission
period.

5.	THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODOLOGY
AND INFORMATION MANAGEMENT

	5(a)	Agency Activities

	The activities routinely conducted by EPA related to the processing,
analysis and storage of the information collected under this rule
include the following:

review and verify forms as they are received

answer respondent’s questions and provide any necessary assistance

process submissions for inclusion in IUR database

review requests for confidentiality in the submissions

maintain the database

distribute the data

	5(b)	Collection Methodology and Management

	The information collection activity under this rule includes an initial
reporting period in 1986 and subsequent reporting periods every four
years to 2006.  The 2003 Amendments to the IUR extended the reporting
cycle to five years, therefore the next reporting will occur in 2011.
For each reporting period, all manufacturers (including importers),
except for those defined as “small manufacturers,” are required to
submit information on every substance required under this rule that they
manufacture, including import, in sufficient quantities.  

		(i) Collection Methodology

	All manufacturers (including importers) of subject chemicals are
required to report under the IUR rule.  Potential reporters are notified
of the need to report in three ways:  (1) EPA publishes a Federal
Register notice, (2) letters are sent to previous IUR submitters, and
(3) articles are published in the trade press.  Reporting materials,
including the eIUR reporting software and a variety of guidance
documents (Instruction Manual, Q&As, Case Studies), are available on the
EPA’s IUR website.  In addition, respondents can obtain the reporting
materials from the TSCA Hotline.

	To aid persons subject to this information collection, the Agency’s
TSCA Hotline is also available to answer questions regarding the IUR
requirements or submission process.  When Hotline staff are unable to
answer questions, the submitter is referred to OPPT’s Information
Management Division (IMD) or Chemical Control Division (CCD), as
appropriate.  Other Divisions within OPPT are used as necessary.  

	Respondents can submit information associated with this data collection
either through the Internet, as a file on a CD, or as a printed paper
copy.  Initial data receipt and processing activities (data entry,
quality assurance, CBI claim reviews, etc.) will be expedited by the
receipt of the data electronically.  Internet submissions require the
use of the eIUR software and the Agency’s Central Data Exchange (CDX).
 Reporting via the Internet is the most efficient of the choices, as the
respondent receives almost immediate feedback of the receipt of their
submission and EPA is able to directly load the information into the IUR
database.  Information submitted on a CD involves different levels of
human intervention, depending upon the format of the file – those
prepared with the eIUR software as encrypted files simply needed to be
uploaded to the IUR database, which those submitted as PDFs have to be
printed out and handled as paper submissions.  Paper submissions are
scanned using Optical Character Recognition (OCR) technology and hand
checked for accuracy.  Those that were handwritten or scanned poorly
were key-entered.  

(ii) Data Management

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

	IUR data are used to update and augment the Chemical Update System
(CUS) database.  Once updated, the database is then available to EPA
technical reviewers for export into their various analytical modeling
systems and databases.  The IUR database is also available for quick
screening and other direct uses.  Non-CBI information is publicly
available.

Database Systems Development and Maintenance -- The Agency is
responsible for having adequate information systems in place to support
the CUS database that serves as the primary data storage medium for IUR
collections.  File servers with appropriate backup are used to contain
the IUR databases.  Following the 2006 IUR collection, EPA updated the
technology used to store the IUR data, storing it in a larger Manage
Toxic Substances (MTS) database.  In addition, IUR data are tracked via
the correspondence tracking system utilized by the Confidential Business
Information Tracking System (CBITS) located within the Confidential
Business Information Center (CBIC).

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

Form U Processing -- The Agency is responsible for handling processing
of IUR submissions.  This includes developing standard operating
procedures and documentation for all stages in the IUR document life
cycle, document receipt and tracking, data input, quality control, file
and database maintenance, information security, CBI aggregation policy,
data dissemination, and staff training.  For the 2006 IUR submission
period, EPA developed new processes to receive IUR submissions over the
Internet, using the Agency’s Central Data Exchange (CDX) system. 

Additional Activities -- The Agency develops reporting software and
makes it available on the Internet, along with various supporting
documents.  In addition, the Agency is responsible for providing the
TSCA Hotline with standardized responses for frequently asked questions;
preparing mailings, mailing lists, and labels; and developing outgoing
information materials.

	5(c) Small Entity Flexibility

	Ample flexibility is provided.  This regulation affects only businesses
-- governmental jurisdictions and not-for-profit organizations are not
required to take any action.  Small manufacturers (including importers),
in accordance with TSCA section 8(b) (40 CFR Sections 710.29 and
710.28), are exempt and therefore are generally not subject to any of
the reporting or recordkeeping requirements.  A manufacturer (including
importer) is considered a small business if (1) the firm’s total
annual sales when combined with those of its parent company (if any) are
less than $40 million for the reporting period and (2) its total
production and/or importation of the chemical substances, mixture or
category, for the reporting period, does not exceed 100,000 pounds
(45,000 kilograms) at an individual site owned and controlled by the
firm.  The Revised Economic Analysis for the Amended Inventory Update
Final Rule determined that the impact on these companies is
significantly less than 1% of revenues (EPA 2002a).  EPA has determined
that there is not a significant economic impact on a significant number
of small entities.

	5(d)	Collection Schedule

	The reporting period shall be from June 1, 2011 to September 30, 2011. 
This reporting period/schedule follows the requirements of 40 CFR
710.53.

	Federal Register Notice				February 2011

	Send out letter to 2006 IUR mailing list		March 2011

	  with instructions describing how to obtain 

	  the reporting documents

	Going Public efforts:	articles in industry		March 2011

	  press, meetings with regulated community,

	  and information on the IUR website

	Open period for filing 2011 IUR Forms		June 1, 2011 - September 30,
2011

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

	6(a)	Estimating Respondent Burden

	This ICR estimates burden for an information collection effort that
reflects the requirements of the 2003 Amendments to the Inventory Update
Reporting rule (IUR).  The previous IUR, which covered one collection
from 2003 to 2008, required chemical manufacturers and importers to
collect, maintain, and submit location and production volume information
for chemicals with annual production volumes of 25,000 pounds or higher
and required site and production information.  The Amendments also
require sites with production volumes of 300,000 pounds or higher of a
reportable chemical to collect, maintain, and submit additional
information to EPA regarding chemical processing and use.  In the 2006
collection, manufacturers of inorganic chemicals, regardless of
production volume, were partially exempt (i.e., submitters do not report
processing and use information for inorganic chemicals).  For the
reporting period covered by this ICR, the partial exemption for
inorganic chemical manufacturers is no longer applicable and submitters
are required to fully report information on inorganic chemical
substances when production volumes at a site are 300,000 pounds or
higher. However, petroleum process streams and other chemical substances
specifically listed are partially exempt from the information
collection.  Manufacturers of such substances are not required to report
processing and use information.

	For this ICR, the burden estimates for report preparation and
submission were derived from a survey conducted by EPA in 1996 (under
OMB Control No. 2070-0034) to assess the potential burden associated
with the amended IUR.  The survey was distributed to previous IUR
reporters selected from the IUR database.  Burden estimates are
developed for the compliance activities and then multiplied by the
number of facilities or reports (as appropriate) to estimate the total
burden to respondents.  Estimates of facilities and reports are taken
from the October 2007 version of the IUR database which includes data
from the most recent (2006) IUR collection.  The amount of effort (and
therefore cost) required for each of these steps varies depending on the
type of chemical, company size, and the variety of uses of the chemical.
 The tasks associated with IUR reporting during the period of this ICR
are those listed in Section 4(b)(ii).  To complete the collection, the
respondent would:

	Determine compliance;

	Become familiar with rule;

	Prepare and submit report; and

	Keep records.

	Worksheet 1 illustrates the respondents’ burden of collection on a
per-collection basis.  All burden hour estimates are based on the
“high” scenarios in the Revised Economic Analysis of the Amended
Inventory Update Reporting Rule, Final Report (EPA 2002) (IUR EA). 
Estimates for numbers of reporters and reports come directly from 2006
reported data.  This analysis estimates that a total of 4,190 Form U’s
will be received with a total of 28,398 reports where reports represent
a unique site/chemical combination. Of the 28,398 reports, 51% are
estimated to be full reports and 49% are estimated to be partial
reports.  The total number of chemicals with reports is 7,641.	

	The IUR requires reporting on a “per site” basis rather than a
“per company” basis, therefore, each site is considered a
respondent.  A total of 4,190 respondents are estimated to report to
this information collection.  The Agency estimates the typical annual
respondent burden for this information collection activity to be 98
hours (a collection occurs once every five years).  This burden estimate
assumes that each of the respondents will report IUR information for an
average of 3.3 full reports and 3.4 partial reports.  There are no third
party burdens associated with these activities.

	6(b)	Estimating Respondent Cost

	Worksheet 1 provides the respondents’ cost of reporting on a
per-collection basis.  The costs in worksheet 1 have been updated to
reflect wages rates in 2007 dollars.  

Worksheet 1:  Respondent Burden and Cost Estimates, Per Activity (2007$)

Activity	

Burden Hours	Total Hours per Activity	Cost per Unit	Units per Site	Total
Cost per Activity	Total Burden Hours per site

	Managerial @$68.18	Technical @$55.44	Clerical  @$27.47





	Compliance Determination (per site)	0.00	4.00	0.00	4.00	$221.76	1
(4,190 sites)	$221.76	4.00

Rule Familiarization (per site)	2.00	2.00	0.00	4.00	$247.24	1 (4,190
sites)	$247.24	4.00

Report Preparation and Submission (per report)	Partial Form	5.73	11.36
2.56	19.65	$1,090.79	3.3 (13,989 partial reports)	$3,599.61	64.85

	Full Form	25.98	66.75	12.54	105.27	$5,816.41	3.4 (14,409 full reports
$19,775.79	357.92

Recordkeeping (per Report)	2.00	4.00	2.00	8.00	$413.06	6.8 (28,398
reports)	$2,808.81	54.4

Total Hours

35.71	88.11	17.1	140.92



485

Total Costs

$2,434.71	$4,884.82	$469.74

$7,789.27



	

	6(c)	Estimating Agency Burden and Cost

	Annual costs and burden to the Agency under the IUR have been estimated
by calculating the number of full-time equivalents (FTEs) required to
undertake certain prescribed tasks.  These tasks are outlined in the IUR
EA.  FTE requirements have been reduced from four FTE’s in the EA to
two because many activities in the EA were estimated to be one-time
costs. One time costs, associated with the requirements of the IUR
amendments, are not considered in this ICR.  FTEs are converted to
dollars by multiplying estimated FTE yearly earnings for the appropriate
staff level (GS level) by the number of FTEs for each staff level, and
then summing the products.  Yearly earnings have been calculated to
include fringe benefits of 41 percent of the base salary and overhead
costs of 17 percent of the base salary plus the fringe benefits.  

	EPA costs also include payment for extramural task completed by
contractors.  These costs were estimated at $84,960 for document receipt
and tracking entry and $53,100 for backup systems operation in the
previous ICR (2005).  Costs were inflated from 2005 to 2007 dollars
using the Employment Cost Index (ECI), seasonally adjusted, for
white-collar occupations in private industry (BLS, 2008).  The ECI for
4th quarter 2005 was 100.2 and 106.8 for 4th quarter 2007.  Using these
indices, the costs for document receipt and tracking entry and systems
operation are estimated at $90,737 and $56,711, respectively.

	Additional Agency costs have been estimated based on the budget that is
appropriated for the IUR and found in the previous ICR.

	  Worksheet 2 presents the per-cycle Agency costs of the IUR
information collection.  The Agency expects only one collection to occur
during the time period that this ICR is effective.  Therefore, the
estimated total annualized cost incurred by the Agency is calculated by
summing the recurring costs and the one-time costs, and dividing by the
five years of the reporting cycle, which yields $88,077.

	

Worksheet 2.  Estimated Per-Cycle Agency Costs for the IUR (recurring
every five years)

Task	IUR Costs (2007 $)

Tasks Performed by Agency Personnel

     Quality Control of Data Entry

     Data Processing, Systems Development, and Contract

     Oversight and Management	

$111,622 (1 FTE, GS-12, Step 1)

$132,737(1 FTE, GS-13, Step 1)

Subtotal	$244,359

Extramural Tasks (contractor)

     Document Receipt and Tracking and Data Entry

     Backup Systems Operation	

    $90,737

    $56,711

Subtotal	  $147,448

Additional Tasks

     Publication and Printing Forms and Materials

     Hotline

     Mailing	

    $5,298

  $42,855

       $426

Subtotal	  $48,579

Total Cost per Collection	$440,386

Total Annual Cost  (one collection per 5 years)	$88,077

Note:  All costs associated with FTEs include 41 percent fringe benefits
and 17 percent overhead.  For example, the GS-12 Step 1 salary for 2007
was $69,764.  This was multiplied by an assumed loading factor of 1.6
(rounded) to reflect fringe benefits and overhead, resulting in a fully
loaded cost per FTE of 1.6 X $69,764 = $111,622.

Sources:

Office of Personnel Management, 2007.  “2007 General Schedule Locality
Notes of Pay for Washington-Baltimore, DC-MD-VA-WV.”
<http://www.opm.gov/oca/2008tbls/GSannual/html/GSDCB.HTM> As obtained on
April 16, 2008.

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

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

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



	6(d) 	Bottom Line Burden Hours and Cost: Master Table

	The total burden per reporting cycle collection is estimated to be
2,052,422 hours.  Given that there is only one collection every 5 years,
the annual burden is estimated to be 410,484 hours.  The total cost per
reporting cycle collection is estimated to be $112.8 million.  The cost
per year is estimated to be $22.6 million.  Details are provided in
Worksheet 4.

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

Worksheet 4: Total Estimated Burden Hours and Costs (2007 $)

Activity	Unit of Analysis	Total per Unit	Number of Units	Totals per
Collection



Hours	Cost

Hours	Cost

Compliance Determination	Site	4.00	$221.76`	4,190	16,760	$929,174

Rule Familiarization	Site	4.00	$247.24	4,190	16,760	$1,035,936

Report Preparation and Submission	Partial Form	Report	19.65	$1,090.79
13,989	274,883	$15,259,061

	Full Form	Report	105.27	$5,842.66	14,409	1,516,835	$83,808,651

Recordkeeping	Report	8.00	$413.06	28,398	227,184	$11,730,078

Subtotal Per Collection	2,052,422	$112,762,900

Subtotal  Annually1	410,484	$22,552,580

1 This collection occurs every five years, therefore total annually is
equal to the total for the collection divided by five

	The IUR EA estimated that there would be 3,036 respondents of which
758, or 25%, would be small.  Applying the 25% to the 4,190 estimated
respondents for this ICR results in an estimated 1,048 small
respondents.  It is important to note that this is very likely an
overestimate.  The IUR exempts small businesses from reporting.  
However, there are some cases where a small business does report (e.g.,
they company may report a chemical subject to certain sections of TSCA
that require reporting) so an estimate is presented in this ICR. 
Worksheet 5 includes summary burden estimates.

Worksheet 5.  Summary Burden Estimates

Number of Small Respondents	Number of Respondents	Reports per Respondent
Burden per Response

(hours)

1,048	4,190	6.8	489



	6(e)	Reasons for Change in Burden

	There is a decrease in the number of annual burden hours of 3,091 (from
413,575 hours to 410,484) from the estimates in the information
collection request most recently approved by OMB.  This is expected to
be due to both a program change and an adjustment. 

	In the 2006 IUR collection covered by the previous ICR, inorganic
chemicals were partially exempt and therefore, only partial reporting
was required.  However, in subsequent reporting periods, including the
period covered by this ICR, respondents with inorganic chemicals must
complete full reports.  Full reports are estimated to take an additional
85 hours to complete.  This represents a program change and increases
the burden.

	EPA used data reported to the 2006 IUR collection to estimate numbers
of respondents.  Total sites reporting were estimated to be 4,190 for
this collection.  In the previous ICR, the number of sites responding
was estimated to be 3,026 sites.  This adjustment in estimates would
tend to increase burden hours somewhat and is another reason for the
change in burden hours.  An additional adjustment is reflected in a
reduction in the estimated burden hours for rule familiarization from 30
hours per site to 4 hours per site.  This change is made because
significant rule changes were made in the period covered by the previous
IUR and extra hours were allocated to interpret new requirements.  
During the period covered by this ICR, the rule is not expected to
change significantly; therefore, those additional hours were removed.   

	In the previous ICR, reporting was required every 4 years.  EPA has
revised the reporting period to once every five years.  This results in
the total estimated burden for reporting to be divided over five years
rather than four in order to calculate annual burden.  This program
change reduces the estimated annual burden.

	6(f)	Burden Statement

	The annual public burden for this collection of information, which is
approved under OMB Control No. 2070-0162, is estimated to average 98
hours.  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 when approved, are listed in 40
CFR part 9, are displayed either by publication in the Federal Register
or by other appropriate means, such as on the related collection
instrument or form, if applicable.  The display of OMB control numbers
in certain EPA regulations is consolidated in 40 CFR part 9.

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 when
approved, are listed in 40 CFR part 9, are displayed either by
publication in the Federal Register or by other appropriate means, such
as on the related collection instrument or form, if applicable.  The
display of OMB control numbers in certain EPA regulations is
consolidated 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 of automated collection techniques,
EPA has established a docket for this ICR under Docket ID No.
EPA-HQ-OPPT-2008-0504, 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 this docket is available at   HYPERLINK
http://www.regulations.gov/ http://www.regulations.gov/ .  Use the
federal government wide electronic docket and comment system at  
HYPERLINK http://www.regulations.gov www.regulations.gov  to submit or
view public comments, access the index listing of the docket contents,
and to access those documents in the docket that are available
electronically.  Once in the system, select “advance 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-2008-0504 and OMB control number 2070-0162 in any
correspondence.

SOURCES

BLS, 2008.  Employment Cost Index, Seasonally Adjusted, Total
compensation, private industry, White-collar occupation, Series ID
CIS2010000W00000I (B,D).  Years 1998-2007.  Extracted April 29, 2008.

EPA, 2002a.  Revised Economic Analysis of the Amended Inventory Update
Rule.  Economics, Exposure and Technology Division, Office of Pollution
Prevention and Toxics, U.S. Environmental Protection Agency, Washington,
DC.

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

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

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

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

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

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

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

Office of Personnel Management, 2007.  “2007 General Schedule Locality
Notes of Pay for Washington-Baltimore, DC-MD-VA-WV.”
<http://www.opm.gov/oca/2000tbls/GSannual/html/GSDCB.HTM>  As obtained
on April 16, 2008.

 The 2003 Amendments were published on January 7, 2003.  See 68 FR 848. 

 INFORM is a nonprofit environmental research organization.

 Certain chemicals, specifically listed in the IUR regulation at 40 CFR
710.46(b), are partially exempt and only report Parts I and II of Form
U, regardless of their production volume.

 Ibid.

 PAGE   

 PAGE   - 25 - 

