Supporting Statement for a Request for OMB Review under

the Paperwork Reduction Act

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title of the Information Collection

TITLE:	Voluntary Cover Sheet for TSCA Submissions

EPA ICR No.:  1780.05	OMB Control No.:  2070-0156

1(b)	Short Characterization

This Information Collection Request (ICR) pertains to the voluntary use
of a cover sheet that has been developed by industry and EPA to
facilitate the processing of information that is submitted to the Agency
under sections 4 and 8 of the Toxic Substances Control Act (TSCA), or
under the Voluntary Children’s Chemical Evaluation Program (VCCEP). 
The cost and burdens related to the submissions under TSCA sections 4
and 8 and VCCEP have already been approved the Office of Management and
Budget (OMB) and are contained in the following ICRs: 

TSCA section 4 submissions are addressed in “Section 4 Test Rules and
Consent Orders,” OMB Control No. 2070-0033, EPA ICR No. 1139. 

TSCA section 8(d) submissions are addressed in “TSCA Section 8(d)
Health and Safety Data Reporting Rule,” OMB Control No. 2070-0004, EPA
ICR No. 0575.

TSCA section 8(e) reporting requirements are addressed in
“Notification of Substantial Risk of Injury to Health and the
Environment under TSCA Section 8(e),” OMB Control No. 2070-0046, EPA
ICR No. 0794.

Certain voluntary reporting requirements are addressed in “Voluntary
Children’s Chemical Evaluation Program (VCCEP),” OMB Control No.
2070-0165, EPA ICR No. 2055.

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

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

The submissions EPA receives can be numerous, lengthy and complex.  For
example, EPA received 10,000 submissions in FY 1992 in response to the
TSCA Section 8(e) Compliance Audit Program.  Processing of these
submissions was not completed until FY 1995.  In June 1994, EPA received
900 submissions, representing approximately 3,500 studies, under a TSCA
section 8(d) data call-in for siloxanes by the Interagency Testing
Committee (ITC).

Submissions/studies are received, logged, internally tracked,
duplicated, distributed to government scientists for review and
analysis, indexed, microfiched and made publicly available through the
TSCA Test Submissions (TSCATS) database.  However, TSCATS is only an
online index of, and pointer system to, the large volume of unpublished
studies; the full texts are available only in paper or on microfiche.

Under the auspices and funding of the Silicone Environmental Health and
Safety Council (SEHSC), industry, EPA, and the ITC developed a model
software application for submitting summary data for the section 8(d)
siloxane data call-in.  This model was designed around the TSCATS data
structure but expanded to include additional data elements deemed
valuable by industry.  The objective was to capture comprehensively all
submissions and studies from the ten SEHSC member companies for EPA’s
more efficient and effective receipt, tracking, processing,
identification, internal and external search and retrieval, and upload
to TSCATS for public availability.

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

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

The voluntary use of a cover sheet facilitates the submission of
information by displaying certain basic data elements, permitting EPA
more easily to identify, log, track, distribute, review and index
submissions, and makes information publicly available more rapidly and
at reduced cost via TSCATS, to the mutual benefit of both industry and
EPA.  It is the use of this form/cover sheet that is addressed in this
information collection request.

	The specific reporting form used by this information collection is
known as the TSCA Health & Safety Study Cover Sheet (EPA Form No.
7710-58), a copy of which, along with its associated instructions,
appears below as Attachment 1.

2.	NEED FOR AND USE OF THE COLLECTION

2(a)	Need/Authority for the Collection

The standardized cover sheet discussed in this ICR is used in
conjunction with submissions of information as required under TSCA
sections 4, 8(d), 8(e) and VCCEP.  The need and authority for these
reporting requirements are discussed in detail in the information
collection requests associated with these requirements and are not
themselves relevant to the discussion of the use of the standardized
cover sheet form that follows.

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

2(b)	Use/Users of the Data

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

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

In addition, ACC and OPPT expect that the use of the TSCA Cover Sheet by
industry will provide industry the following benefits: improved internal
company storage; more efficient preparation and submission; standardized
keywords;  improved data quality; quicker decisions; improved
understanding of EPA(s needs; quicker access through TSCATS to relevant
studies by industry toxicologists; and  significant potential cost
savings from non-initiation/non-duplication of studies through rapid
TSCATS availability.

3.  NON-DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA

3(a)	Non-Duplication

The use of the Voluntary TSCA Cover Sheet is not a stand-alone
collection activity; rather it simply offers a cover form that may be
used in conjunction with other submissions.  As such, there is no
duplicative collection.

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

  SEQ CHAPTER \h \r 1 Prior to submission to OMB, this ICR will be made
available to the public for comment through a Federal Register notice. 
The public will have 60 days to provide comments.  Any comments received
will be given consideration when completing the supporting statement
that is submitted to OMB.

3(c)	Consultations

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

  SEQ CHAPTER \h \r 1 	  SEQ CHAPTER \h \r 1 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 original or
renewal ICR to OMB for review and approval.  In accordance with this
regulation, EPA will pursue additional consultations with interested
parties during the development of the renewal of this collection.

3(d)	Effects of Less Frequent Collection

Since the use of this cover sheet is strictly voluntary on the part of
respondents, this is not applicable.

3(e)	General Guidelines

The use of this cover sheet does not exceed any of the PRA guidelines at
5 CFR 1320.6.

3(f)	Confidentiality

Any information included on the cover sheet may be claimed as
confidential by the respondent.  Claims of confidentiality are handled
according to EPA procedures described in 40 CFR Part 2 and in the TSCA
Confidential Business Information Security Manual, which call for
careful protection of confidential, trade secret or proprietary
information.

3(g)	Sensitive Questions

This information collection does not include questions of a sensitive
nature.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)	Respondents and NAICS Codes

Respondents affected by this activity are found mainly under NAICS codes
324 - Petroleum and Coal Products Manufacturing, and 325 - Chemical
Manufacturing.

4(b)	Information Requested

(i)	Data Items 

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

Data Element	

Description



1.  Submission Type	

Identifies the submission, including the type of submission and whether
it is the initial submission, a follow-up or a final report.



2.  Summary of Attachment	

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



3.  Chemical Identification 	

Identifies the chemical(s) addressed in the submission.



4.  Title of Attachment 	

Identifies the title of the attached study or report.



5.  Indexing Terms	

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



6.  Study/Report Information	

Provides specific information regarding the attached study or report,
including the source, date of the study or report, sponsor(s), and the
length of the document.



7.  Submitter Information	

Identifies the submitter and/or technical contact, including name,
title, company, mailing address, phone and e-mail address.

  SEQ CHAPTER \h \r 1 8.  Comments

	  SEQ CHAPTER \h \r 1 Allows the submitter to provide any additional
comments, so as to avoid the need for or use of a separate cover letter.

9.  Signature	A signature is required for submissions under section
8(e); the cover form provides a place for the submitter(s signature,
thereby avoiding the need for or use of a separate cover letter.



10.  Continuation 	

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



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

(ii)	Respondent Activities

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

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

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

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

5(a)	Agency Activities

OPPT staff use the information found on the cover sheet to identify the
type of submission or the type of information contained in a submission,
to route a submission to other EPA staff for review, evaluation or
action, to file or retrieve a submission, and to conduct other routine
information-management tasks associated with the receipt and processing
of a submission.  Since the information appears in a consistent,
standardized format, OPPT staff members are able to complete these tasks
in a highly efficient manner.

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

5(b)	Collection Methodology and Management

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

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

5(c)	Small Entity Flexibility

The use of this voluntary cover sheet does not directly affect any
existing small entity flexibility applicable to respondents to the
reporting requirements under TSCA sections 4, 8(d), 8(e) or VCCEP.  Any
small entity flexibility associated with these collections is described
in greater detail in the information collection requests associated with
these reporting requirements.  (In general, reporting requirements under
TSCA sections 8(d) and 8(e) apply to all respondents, regardless of
size.  Small entities required to report under TSCA section 4 have
certain options available to them in responding to those requirements.  
 SEQ CHAPTER \h \r 1 Under VCCEP, no company is required to
participate.)  For those respondents, whether large or small, that
respond to these information collections, the use of this cover sheet
should provide a more efficient means of submitting required
information.  However, since the use of this cover sheet is strictly
voluntary (although the underlying reporting requirement itself may be
mandatory), a respondent may choose not to use the form at all.

5(d)	Collection Schedule

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

6.  	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

  SEQ CHAPTER \h \r 1 In using this Voluntary TSCA Cover Sheet effort,
respondents are not required to generate any new data; rather they
simply transfer information from the underlying submission to the cover
sheet.  Although the information included in the cover sheet is often
included in a cover letter, the Agency has not attempted to estimate any
burden adjustment to the underlying ICRs to reflect the use of the
Voluntary TSCA Cover Sheet, rather than a cover letter to the Agency. 
This ICR only estimates the burden and costs associated with the use of
the Voluntary TSCA Cover Sheet.  As such, it estimates the burden and
costs related to the respondent’s review of the instructions,
completion of the form, and the identification of the appropriate TSCATS
study index terms.

6(a)	Estimating Respondent Burden

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

  SEQ CHAPTER \h \r 1 Using recent estimates of the yearly average
number of potential submissions expected under the other ICRs for
submissions related to TSCA sections 4, 8(d), 8(e) and VCCEP, and
assuming that respondents used the Voluntary TSCA Cover Sheet for every
submission, Table 1 illustrates the total potential burden related to
this ICR.  This assumption effectively results in an overstatement of
the total burden associated with the use of the Voluntary TSCA Cover
Sheet since not all respondents will choose to use the cover sheet. 
However, there are no reliable data available to suggest a lesser level
of use of the form that EPA could use to calculate the burden associated
with its use.  The burden identified below should be considered the
maximum upward bound for the total burden rather than a precise estimate
of the burden based on the actual real-life use of the form.



Table 1 ( Total Potential Burden



Submission Type	

Total Average Annual Submissions	

Burden Hours and Cost per Submission 

    Burden Costs 	

Total Burden 

Hours and Cost



TSCA Sec. 4 	

   1,425	

0.5	

$24.86	

   712.5	

$35,426



TSCA Sec. 8(d) 	

       36	

0.5	

$24.86	

     18.0	

$895



TSCA Sec. 8(e) - initial 	

     345	

0.5	

$24.86	

   172.5	

$8,577



TSCA Sec. 8(e) - follow-up 4	

     108	

0.5	

$24.86	

     54.0	

$2,685



VCCEP 4	

     209	

0.5	

$24.86	

   104.5	

      $5,196



Total Potential Burden	

  2,123	

0.5	

$24.86	

1,061.5	

$52,779



  SEQ CHAPTER \h \r 1 	Since the Voluntary TSCA Cover Sheet is expected
to be used in lieu of the letter that has been used in the past to
transmit submission to the Agency, this burden should not be considered
additive to the existing burden estimates provided in the underlying
ICRs.  Accounting for this separately in this ICR may also result in the
double counting of this particular burden.  However, the Agency wishes
to continue the voluntary use of this cover sheet and will account for
its burden separately until the form is more widely used.

6(b)	Estimating Respondent Cost

  SEQ CHAPTER \h \r 1 	Based on information provided by ACC, a technical
level employee is expected to complete the Voluntary TSCA Cover Sheet. 
For purposes of estimating the cost associated with completing this
form, EPA used the most current average industry labor costs for
technical employees of $49.72 per hour (Source: Labor rates are
unpublished December 2004 data from BLS for all manufacturing
industries, the most recent available.  The estimates include fringe
benefits and 17% overhead).  As shown in Table 1, the total potential
cost associated with completing the cover form is $52,779.

6(c)	Estimating Agency Burden and Cost

Industry use of the cover sheet does not increase Agency burden and cost
over that currently associated with these information collections.  It
is anticipated, in fact, that the Agency(s costs for data processing,
system support and storage and distribution may decrease.  Currently EPA
staff must extract cover sheet information from the submission itself
and any accompanying cover letter; this task will be eased by EPA staff
being able to obtain necessary information directly from the
standardized form.

Current Agency burden and costs are:

Section 4: 5,911 hours / $327,883

(Source: Section 4 Test Rules and Consent Orders; OMB No. 2070-0033; EPA
ICR No. 1139.07; June 2005)

Section 8(d): 5,720 hours / $233,908

(Source: TSCA Section 8(d) Health and Safety Data Reporting Rule; OMB
No. 2070-0004; EPA ICR No. 0575.09; February 2003)

Section 8(e):  $50,685

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

	VCCEP: 1,100 hours / $575,242

	(Source:   SEQ CHAPTER \h \r 1 Data Submissions for the Voluntary
Children’s Chemical Evaluation Program 

	(VCCEP); OMB No. 2070-0165; EPA ICR No. 2055.01; September 2003)

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

6(d)	Bottom Line Burden Hours and Costs

(i)  Respondent Tally

Each use of the cover sheet is estimated to result in a burden of 0.5
hours, at a cost of $24.86.  The Agency estimates a total of 2,123
submissions each year, so the total potential burden associated with
this ICR is estimated to be 1,062 hours, at an estimated cost of
$52,779.

(ii) Agency Tally

Industry use of the cover sheet does not increase Agency burden and cost
over that currently associated with the underlying information
collections with which the cover sheet is used, which are covered by
other ICRs.

6(e)	Reasons for Change in Burden

  SEQ CHAPTER \h \r 1 There is a decrease of 8,074 hours (from 9,136
hours to 1,062 hours) in the total estimated respondent burden compared
with that identified in the information collection most recently
approved by OMB.  This decrease reflects a decrease in the estimated
number of submissions under TSCA sections 4, 8(d) and 8(e), offset by
the estimated number of submissions under VCCEP, for which the Voluntary
TSCA Cover Sheet could be used, in particular a substantial decrease in
the estimated number of TSCA section 4 submissions.  (As discussed in
the TSCA section 4 ICR identified elsewhere in this document, this
decrease results from a reduction in the estimated number of section 4
test rules and Enforceable Consent Agreements EPA expects to issue, as
well as a reduction in the estimated testing remaining for the HPV
Challenge Program.  EPA also now estimates the VCCEP submissions in a
separate ICR.)  Since the use of the Voluntary TSCA Cover Sheet is a
direct reflection of the number of submissions received under TSCA
sections 4, 8(d), 8(e) and VCCEP, any change in the estimated numbers of
submissions under those requirements will result in a parallel change in
the burden hours associated with this information collection.  The
potential number of annual submissions may change from year to year, but
the Agency believes that the estimated number of submissions used in
this ICR is reasonable.  In addition, EPA now uses more accurate BLS
data for labor rates, resulting in lowered respondent costs.  This
decrease represents an adjustment.

6(f)	Burden Statement

The annual public burden for this collection of information, which is
approved under OMB Control No. 2070-0156, is estimated to average 0.5
hours per response.  According to the Paperwork Reduction Act, (burden(
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, or disclose or provide information to or
for a Federal agency. For this collection it includes the time needed to
review instructions; train personnel to be able to respond to the
collection of information; search data sources; complete and review the
collection of information; and transmit or otherwise disclose the
information. An agency may not conduct or sponsor, and a person is not
required to respond to, a collection of information unless it displays a
currently valid OMB control number. The OMB control number for this
information collection appears above and on the form.  In addition, the
OMB control numbers for EPA(s regulations, after initial display in the
final rule, are listed in 40 CFR part 9.

  SEQ CHAPTER \h \r 1  To comment on the Agency’s need for this
information, the accuracy of the provided burden estimates, and any
suggested methods for minimizing respondent burden, including the use of
automated collection techniques, EPA has established a public docket for
this ICR under Docket ID No. EPA-HQ-OPPT-2009-xxxx, which is available
for public viewing at 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) 566-1744, and the telephone number for the Pollution
Prevention and Toxics Docket is (202) 566-0280.  An electronic version
of the public docket is available at http://www.regulations.gov.  Use
regulations.gov to submit or view public comments, access the index
listing of the contents of the public docket, and to access those
documents in the public docket that are available electronically.  Once
in the web site, click the Advanced Search link at the top of the page
and select Docket Search from the drop-down menu.  At the Advanced
Search page, select Environmental Protection Agency in the Agency field;
in the Docket ID field key in the docket ID number identified above;
scroll to the bottom of the page to click on Submit.  At the Docket
Search Results page click on the Docket ID to display all of the
documents found within this docket ID number.  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-2009-xxxx and OMB control number 2070-0156 in any
correspondence.

  SEQ CHAPTER \h \r 1 

 This is based on an estimated labor cost of $49.72/hour, as discussed
in section 6(b).

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

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

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

5 Data Submissions for the Voluntary Children’s Chemical Evaluation
Program (VCCEP); OMB No. 2070-0165; EPA ICR No. 2055.02; December 2005. 

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