  SEQ CHAPTER \h \r 1 Supporting Statement for a Request for OMB Review
under

The Paperwork Reduction Act

  SEQ CHAPTER \h \r 1 1.  IDENTIFICATION OF THE INFORMATION COLLECTION

	l(a)	Title of the Information Collection

	TITLE:	Chemical-Specific Rules, Toxic Substances Control Act Section
8(a)

	EPA ICR No.:	1198.09	OMB Control No:	2070-0067

	1(b)	Short Characterization

	This information collection request requires OMB’s approval for the
continued collection of chemical-specific information under section 8(a)
of the Toxic Substance Control Act (TSCA, 15 U.S.C. 2607); see
Attachment 1.  TSCA section 8(a) authorizes the Administrator of the EPA
to promulgate rules that require persons who manufacture, import or
process chemical substances and mixtures, or who propose to manufacture,
import, or process chemical substances and mixtures, to maintain such
records and submit such reports to EPA as may be reasonably required. 
Information that may be collected under TSCA section 8(a) includes, but
is not limited to, chemical names, categories of use, production volume,
byproducts of chemical production, existing data on deaths and
environmental effects, exposure data, and disposal information.  These
data are collected by the Office of Pollution Prevention and Toxics
(OPPT) and may be used by other EPA offices and/or Federal agencies to
ensure knowledge of specific practices that may affect human health and
the environment.

	There may be circumstances when EPA may require different information
than is readily available or information that is different from that
available through existing regulatory information collection tools, like
the TSCA section 8(a) Preliminary Assessment Information Rule (PAIR)
which is discussed in another ICR under a different OMB control number. 
EPA promulgated PAIR on June 22, 1982 (see 40 CFR Part 712).  Whenever a
substance is added to the PAIR, manufacturers and importers of the
substance are required to complete a PAIR report form.  The PAIR report
requests a very limited amount of information on listed chemicals
regarding activities occurring over a specific time period.

	Any chemical covered by TSCA for which OPPT, other EPA Offices or
another Federal agency has a reasonable need for information, and which
cannot be satisfied via readily available sources or by use of PAIR, is
a proper potential subject for a chemical-specific TSCA section 8(a)
rulemaking.  For instance EPA may wish to ask detailed questions in
regard to how industry oversees the use and production of a chemical. 
These specific monitoring capabilities could allow EPA to react to
change in market conditions that may warrant a change in EPA’s
regulatory strategy.  Therefore, EPA could promulgate a TSCA section
8(a) rule to gather this information by requesting that current or
potential manufacturers, importers or processors of the substance
provide chemical-specific information.

	EPA’s OPPT, other EPA Offices and/or other Federal agencies will
generally be the primary groups for which information will be collected.
 However, to the extent that reported information is not considered to
be confidential business information (CBI), environmental groups,
environmental justice advocates, state and local government entities and
other members of the public will have access to this information for
their own use.

	Rather than requiring respondents to submit information on reporting
forms such as those used for PAIR, EPA has in the past allowed
individual firms to choose the reporting means and format that is best
suited to their recordkeeping resources.  EPA believes that for TSCA
section 8(a) chemical-specific rules, this allowance keeps reporting
costs low.

	Total annual cost of a rule varies depending upon the number of
chemicals per rule and the number of respondents per chemical.  Based on
the recent past usage of chemical-specific TSCA section 8(a) rules and
expected future usage, EPA assumes  that it will promulgate one TSCA
section 8(a) chemical-specific rule with four respondents (notices) per
year  for the three-year duration of the ICR (see Section 6(b), below). 
The maximum total annual number of burden hours for respondents range
from 134 hours to 594 hours per TSCA section 8(a) chemical-specific
rule.  The maximum cost associated with the promulgation of a TSCA
section 8(a) chemical-specific rule is $6,868 to $30,504.  However, the
cost per respondent varies with the type of chemical-specific
information requested, and subsequently, the tasks required to comply
with a TSCA section 8(a) chemical-specific rule. Because all respondents
may not have to provide information on all data items listed (see
Sections 3 and 6(b), below), the ranges presented above are maximums. 
Assuming that all respondents do not have to complete all tasks
identified to comply with a TSCA section 8(a) chemical-specific rule,
total annual reporting costs to all respondents range from $3,375 to
$14,080 per rule.

2.  NEED FOR AND USE OF THE COLLECTION

	2(a)	Need/Authority for the Collection

	Generally, EPA may need chemical-specific information under TSCA
section 8(a) to evaluate the potential for adverse human health and
environmental effects caused by the manufacture, importation,
processing, use or disposal of identified chemical substances and
mixtures.  Additionally, EPA may use TSCA section 8(a) information to
assess the need or set priorities for testing and/or further regulatory
action.

	The information required in TSCA section 8(a) chemical-specific rules
can be custom-tailored to aid in achieving EPA’s goals of protecting
human health and the environment.  Information collected may vary
depending on the substance, its current and potential uses and EPA’s
concerns about potential human or environmental risks caused by
exposures to the substance.  Promulgated TSCA section 8(a) rules may
require persons manufacturing, importing or processing the chemical
substance to report to EPA on specific information such as: a
chemical’s composition, byproducts, quantity produced, employee
exposure and environmental release.  Persons have in the past also been
required to notify EPA of a management decision to initiate the
manufacturing, importing, or processing of a chemical substance or
mixture.

	The legal authority for this information collection is TSCA section
8(a), U.S.C. 2607(a).  TSCA section 8(a) chemical-specific rules have
been codified at 40 CFR 704, subpart B; see Attachment 2.

	2(b)	Use/Users of the Data

	EPA will use the information obtained through the TSCA section 8(a)
reporting rules to satisfy specifically identified data needs.  The
information collected will be relevant to risk identification, all
stages of risk assessment, and/or control action functions.  Receipt of
TSCA section 8(a) information may also give the Agency an opportunity to
work with the respondent, if necessary, to minimize exposure risks
associated with specific uses.  Generally, a specific information
collection request would be made by the Chemical Control Division,
Chemical Management Division, or the Chemical Screening and Risk
Assessment Division in OPPT.  However, other regulatory agencies and
departments, such as Occupational Safety and Health Administration
(OSHA), the Food and Drug Administration (FDA), and other members of the
Interagency Testing Committee (ITC) may also present a need for and
subsequently use TSCA section 8(a) data to, for example, assess worker
or consumer exposures.

	An example of a use of a TSCA section 8(a) chemical-specific rule that
was key in affecting a benefit to human health was 1,1-aminoundecanoic
acid (1,1-AA).  From submitted TSCA section 8(e) “substantial risk”
reports, EPA discovered that 1,1-AA is a carcinogen in one sex of one
rodent species (male rat), and that exposure is limited to workers
producing the nylon in which the chemical is an ingredient.  The
manufacturer was contacted to obtain exposure data for this chemical. 
From this contact EPA learned: (1) 1,1-AA was imported and converted
into nylon by one company and there was no domestic manufacture; (2)
1,1-AA was handled and transferred in a closed system and all 1,1-AA was
converted during the reaction to produce nylon.  Consequently, because
of limited exposure potential, 1,1-AA was dropped from further review. 
However, concern would arise if 1,1-AA were to be manufactured
domestically because of the greater likelihood for worker exposure.  To
alert EPA to domestic manufacture, on May 28, 1987, OPPT promulgated a
TSCA section 8(a)/5 (SNUR) rule for 1,1-AA (52 FR 19860) .  Users of
TSCA section 8(a) chemical-specific data rarely make a judgment based
solely on the content of the TSCA section 8(a) information received but
rather use the TSCA section 8(a) chemical-specific information as part
of the larger risk management strategy.  1,1-AA TSCA section 8(a)
information would be instrumental in affecting a benefit to human health
if a company were to begin to manufacture the substance.

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

	3(a)	Non-Duplication

	Section 8(a)(2) of TSCA states, “To the extent feasible, the
Administrator shall not require any reporting which is unnecessary or
duplicative.”  The reporting requirements of TSCA section 8(a) rules
only require information that EPA believes will assist in a reasoned
evaluation of the human health and environmental effects of chemical
substances and mixtures.  This information is unlikely to be duplicative
since, (1) EPA estimates that each rule will generate only a few
notices, (2) the information required by the TSCA section 8(a) rule is
unique to the manufacturer, importer or processor (e.g., the proposed
date of production or importation, the amount produced or imported, the
chemical composition, and uses of the chemical substance or mixture),
and (3) EPA thoroughly checks other public and unpublished sources to
see if the required data may already be available.  Finally, once EPA
became aware of a source of substantially similar information, for
example via comments on a proposed rule, EPA would not continue with the
information 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

	EPA has not published a proposed or final TSCA section 8(a)
chemical-specific information gathering rule for more than fifteen years
and, therefore, has received no comments since that time.  EPA has
received comments on the use of TSCA section 8(a) reporting rules
through published Federal Register notices.  Various organizations
responded to EPA’s request for comments during the 1985 to 1988 ICR
period.  For example, the Agency originally proposed a SNUR for
4,4,1-methylenebis (2-chloroaniline) (MBOCA) but public comments
received in July and August of 1986 on the  proposed SNUR suggested that
a TSCA section 8(a) rule would be more appropriate.  This suggestion was
followed, reducing the burden on the public since the TSCA section 8(a)
rule exempted small manufacturers, whereas the proposed SNUR would not
have had this exemption.

	Also, after receiving public comment on the proposed SNUR/8(a) rule for
1,1- aminoundecanoic acid (July 22, 1986), the proposed definition of
the term “enclosed process” was modified to account for possible
releases through emergency pressure relief, thus expanding the number of
processes that would be considered “enclosed” and lessening
compliance costs.

	The Natural Resources Defense Council (NRDC) has also responded to
several TSCA section 8(a) chemical-specific rules.  The NRDC is a
national nonprofit environmental organization dedicated to the
protection of human health and the environment.  The NRDC generally
urges EPA to adopt a more extensive, detailed set of information
requirements.

  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

	Generally companies are required to report only once under a TSCA
section 8(a) reporting rule.  EPA may consider requiring reporting on an
annual, semiannual, monthly or other basis if the Administrator deems
this necessary to protect human health and the environment.  EPA tailors
each rule to meet chemical-specific data requirements, thus reducing the
potential for too frequent data collections.

	3(e)	General Guidelines

	This information collection activity is necessary to implement the
statutory requirements of section 8(a) of TSCA and is consistent with
the requirements of 5 CFR 1320.6.

	3(f)	Confidentiality

	Submitters may designate information as confidential, trade secret or
proprietary.  EPA has implemented procedures to protect any
confidential, trade secret or proprietary information from disclosure. 
These procedures comply with EPA’s confidentiality regulation, 40 CFR
Part 2, Subpart B.

	3(g)	Sensitive Questions

	This section is not applicable.  TSCA section 8(a) reporting rules do
not include any questions of a sensitive nature.

4.  THE RESPONDENTS AND THE INFORMATION REQUESTED

	4(a)   Respondents/North American Industrial Classification System
(NAICS) Codes

	Respondents affected by this collection activity primarily include
those businesses that fall under NAICS codes 325, Chemical Manufacturers
and Processors, and 324110, Petroleum Refineries.

	4(b)	Information Requested

	4(b)(i)	 Data Items

	Section 8(a) of TSCA specifically lists a wide range of data items that
may be required by EPA, including information on use, production volume,
exposure, and health and safety.  Data items requested of manufacturers,
importers, or processors of certain chemicals vary with each collection
request, but will not repeat information previously requested in the
PAIR or other information gathering tools.  Some data items requested
under TSCA section 8(a) chemical-specific rules in the past include:
notification and description of changes in the end use of identified
substances and mixtures, information on planned manufacturing and
on-site processing, and notification of changes to the method of
manufacturing the substance (see 40 CFR subpart B).

	An example of a past TSCA section 8(a) chemical-specific rule is one
issued on 4,4,1-methylenebis (2-chloroaniline) (MBOCA).  It required
persons who propose to manufacture MBOCA to notify EPA of that intent
and to submit information on their planned manufacturing and on-site
processing activities.  The rule also required persons who are
manufacturing MBOCA to notify the Agency if they propose to alter their
manner or method of manufacturing the substance.

	4(b)(ii)  Respondent Activities

	Activities a respondent may be required to perform as a result of TSCA
section 8(a) chemical-specific rule are as follows:

9 to 29.5 Hours of Managerial Labor

- Identify listed chemicals;

- Assign principal technical contact person;

- Identify by-product;

- Review marketing data;

- Research the date of the initiation of manufacture or importation of
the chemical;

- Research occupational exposure, environmental release, health and
environmental data, disposal methods; and

- Process, compile, and review information for accuracy, substantiate a
claim of confidential business information.

17.5 to 98 Hours of Technical Labor

- Identify chemical and trade name and chemical composition;

- Identify by-product;

- Describe use of chemical;

- Report quantity manufactured or imported;

- Research workplace exposures, environmental releases, health and
environmental data, and disposal methods; and

- Provide occupational description.

7 to 21 Hours of Clerical Labor

- Format research on occupational exposures, environmental releases,
health and environmental data;

- Format attachments; and

- Prepare notice.

Recordkeeping Estimate

	TSCA section 8(a) chemical-specific rules may contain recordkeeping
requirements.  The recordkeeping estimate is rough, but it is reasonably
related to the maximum reporting burden.  EPA estimates that
recordkeeping will account for approximately five percent of the
reporting burden, or a maximum of 12 hours (see Table 2.)

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

	5(a)	Agency Activities Inventory

	For any TSCA section 8(a) chemical-specific rule the Agency would have
to perform a number of tasks.  They are:

o  	Industry/Public Assistance (answering questions regarding rule)

o  	Data Processing and System Support Personnel

o  	Storage and Distribution

o  	Compliance Monitoring

	5(b)	Collection Methodology and Management

	An improved information technology to minimize burden of a TSCA section
8(a) chemical-specific rule has not been found.  EPA has not been able
to identify a more efficient, less expensive, or more flexible means of
obtaining the required data than the one currently being used.  To the
extent data are not CBI, all information collected is made available to
the public through the public docket office.  At the present time, EPA
is not requiring firms to submit this information on one standard
reporting form.  Reporting facilities will be able to choose the format
that best suits their reporting resources.  TSCA section 8(a)
chemical-specific rules typically require one-time reporting.  As future
data needs arise, EPA will consider the use of electronic or other types
of reporting methods.  EPA believes the flexibility already allowed in
the reporting structure significantly eases burden.

	5(c)	Small Entity Flexibility

	Section 8(a) of TSCA generally exempts small manufacturers and
processors.  However, under TSCA section 8(a)(3), EPA may require small
manufacturers and processors to report or keep records if the substance
or mixture is subject to a rule proposed or promulgated under TSCA
sections 4, 5(b)(4), or 6 or with respect to which relief has been
granted pursuant to a civil action brought under sections 5 or 7 of
TSCA.  All respondents to TSCA section 8(a) chemical-specific rules,
including small businesses, are granted flexibility in their reporting
methods.

	5(d)	Collection Schedule

	TSCA section 8(a) chemical-specific rules are generally one-time
collections of specific information, usually regarding one chemical
substance.  Proposed TSCA section 8(a) chemical-specific rules request
comments.  The comments are then addressed and incorporated as
appropriate in the final rule, which specifies the reporting deadline. 
Generally, EPA requires that information be reported no sooner than 30
days after the effective date of a final rule.

6.  ESTIMATING THE BURDEN AND COST OF THE COLLECTION

	6(a)	Estimating Respondent Burden

	Wage rates including fringe benefits and overhead for three broad
categories of labor (managerial, technical, and clerical) were used in
this analysis.  The labor categories and methods for estimating loaded
wage rates were developed during previous studies.  The basis for
estimating wage rates for these purposes is the Bureau of Labor
Statistics (BLS) Employer Costs for Employee Compensation: Private
Manufacturing Industry by Occupation, December 2005. The data series
used for this and other analyses is no longer published directly by the
BLS, but the BLS continues to make this data available to EPA. Based on
the BLS data, the average hourly wage rates (as of December 2005) are
$38.22for managerial personnel, $31.02 for technical personnel and
$15.73 for clerical personnel.

	The benefits and overhead loading factors are calculated from the BLS
data on the cost of benefits, with 17 percent of the average wage added
for overhead. The overhead factor of 17 percent is based on information
provided by the chemical industry and chemical industry trade
associations. The loaded hourly wage rates are $63.61 for managerial
personnel, $53.02 for technical personnel and $26.37 for clerical
personnel, as shown in Table 1.

TABLE 1: LOADED HOURLY WAGE RATES BY LABOR CATEGORY

Labor Category	December 2005 

Average Wages	December 2005

Benefits and Overhead

Loading Factor	December 2005

Loaded 

Hourly Rate

Managerial	$38.22	1.66	$63.61

Technical	$31.02	1.71	$53.02

Clerical	$15.73	1.68	$26.37

Sources:	Unpublished Employer Costs for Employee Compensation: Private
Manufacturing Industry by Occupation, December 2005. Data received by
Carol Rawie, US EPA, from Raphael Branch, US Bureau of Labor Statistics,
May 10, 2006. 

	This ICR maintains the assumption of the previous ICR that on average
four notices per year are submitted in response to one section 8(a)
chemical-specific rule per year. Current labor rates and burden hours
used to calculate cost to respondents are listed below.

     Labor Category	Burden Hours	Hourly Rate

     Managerial	  9 to 29.5	$ 63.61

     Technical	17.5 to 98	$ 53.02

     Clerical	  7 to 21	$ 26.37

	6(b)	Estimating Respondent Costs

	

	The following are the tasks that managers, technical, and clerical
personnel are expected to perform in preparing a notice.  However, as
discussed at the end of this section and presented in Table 1, not all
respondents are likely to be required to perform all tasks under each
labor category.  Therefore, the ranges of labor hours presented below
for each labor category (e.g., 9 to 29.5 hours for managers) are the
maximums and are based on the assumption that all tasks are performed
for each notice.

Managerial Labor

1.  Manufacturer identifies listed chemicals;

2.  Assign principal technical contact person;

3.  Identify by-product;

4.  Review marketing data;

5.  Research the date of the initiation of manufacture or importation of
the chemical;

6.  Research occupational exposure, environmental release, health and
environmental data, disposal methods;

7.  Process, compile, and review information for accuracy, substantiate
a claim of 	     confidential business information.

	In performing these tasks, managerial labor hours have been estimated
to range from 9.5 to 29.5 hours per TSCA section 8(a) chemical-specific
rule.  At $63.61 per hour for management labor times the range of hours
predicted, [$63.61 x (9.5 to 29.5)], the range of cost for management
work is $604 to $1,876 per notice resulting from a TSCA section 8(a)
chemical-specific rule.  With an average of four notices per year for
the three-year ICR period, the range of  costs per year for managerial
labor is [4 x ($604 to $1,876)] = $2,416 to $7,504.

Technical Labor

1.  Identify chemical and trade name and chemical composition;

2.  Identify by-product;

3.  Describe use of chemical;

4.  Report quantity manufactured or imported;

5.  Research occupational exposures, environmental releases, health and
environmental data, and disposal methods; 

	6.  Provide occupational description.

	In performing these tasks, technical labor hours have been estimated to
range from 17.5 to 98 hours per notice resulting from a TSCA section
8(a) chemical-specific rule.  At $53.02 per hour for technical labor,
times the range of hours predicted, ($53.02 x [17.5 to 98]), a range of
cost for technical work is estimated to be $928 to $5,196 per notice
resulting from a TSCA section 8(a) chemical-specific rule.  With four
notices per year for a three-year period, the range of annual costs for
technical labor is [4 x ($928 to $5,196)] = $3,712 to $20,784.

Clerical Labor 

1.  Format research on occupational exposure, environmental releases,
health and 	     environmental data;

2.  Format attachments;

3.  Prepare Notice.

	In performing these tasks, clerical labor has been estimated to range
from 7 to 21 hours per notice resulting from a TSCA section 8(a)
chemical-specific rule.  At $26.37 per hour for clerical labor, times
the range of hours predicted, ($26.37 x [7 to 21]), the range of cost
for clerical work is estimated to be $185 to $554 per notice resulting
from a TSCA section 8(a) chemical-specific rule.  With four notices per
TSCA section 8(a) chemical-specific rule, the range of costs per year
for clerical labor is [4 x ($185 to $554)] = $740 to $2,216.

	The cost to a respondent for filing a TSCA section 8(a) notice depends
upon the various tasks performed.  These tasks could include gathering
the required data, preparing and submitting the TSCA section 8(a)
notice, and possibly keeping records.  Based on promulgated TSCA section
8(a) rules, EPA estimates that each respondent will submit one notice
per TSCA section 8(a) chemical-specific rule.  EPA anticipates issuing
one TSCA section 8(a) rule per year and expects to receive an average of
four notices per year.

	The cost to a respondent for submitting a TSCA section 8(a) notice is a
function of the number of hours and the hourly labor costs for the
individuals developing and preparing the notice.  The annual estimated
range of cost to the respondent is $1,717 ($604 +  $928 + $185) to
$7,626 ($1,876 + $5,196 + $554) per notice, and $6,868 to $30,504 per
TSCA section 8(a) chemical-specific rule (above estimates multiplied by
four, the number of notices expected per rule.) However, as mentioned
above, these figures are likely to overstate the true cost because not
all respondents may be required to supply information regarding each
activity. Thus, the average actual cost to the respondent will be lower
than the $1,717 to $7,626 per notice estimate calculated above. The
estimated frequency of each activity, along with total respondent cost
and burden calculations, is presented in Table 1.  The total cost to all
respondents of reporting under a TSCA section 8(a) chemical-specific
rule is estimated to range from $3,375 to $14,080 per year.  On a per
respondent basis, the annual cost is estimated to range from $894 to
$3,520 per notice, based on four notices per year.

Table 2.  Total Annual Respondent Burden and Costs Associated with
Preparing and Filing a TSCA Section 8(a) Notice

Activity	Managerial Hours $92.33/hr	Technical Hours $68.35/hr	Clerical
Hours $27.24/hr	Notices per Year	Annual Burden Hours	Annual Costs

Manufacturer ID

and Principal Technical Contact	1 - 4

	  4	 4 - 16	$254-

$1,018

Chemical and

Trade Name

1 - 4

  3	3 - 12	$159-

$636

Chemical

Composition

0.5 - 2

  4	2 - 8	$106-

$424

Byproduct ID	1	1 - 4

  2	4 - 10	$233-

$551

Use Description

1 - 4

  4	4 - 16	$212-

$848

Quantity Manufactured

or Imported

1 - 4

  4	4 - 16	$212-

$848

Marketing Data	1 - 2

	  2	2 - 4	$127-

$254

Date of Initiation

of  Manufacture or Importation	0.5

	  4	2	$127

Occupational Exposure	1 - 4	2 - 16	1 - 3	  2	8 - 46	$392-

$2,364

Environmental Release	1 - 4	1 - 8	1 - 3	  2	6 - 30	$286-

$1,515

Occupational Description

1 - 10

  1	1 - 10	$53-

$530

Health and Envi-ronmental Data	2 - 8	8 - 40	1-3	  1	11 - 51	$578-

$2,709

Disposal Methods	1 - 2	1 - 6

  1	2 - 8	$117-

$445

Attachments

	2 - 6	  1	2 - 6	$53-

$158

Preparation of

Notice

	1 - 3	  4	4 - 12	$105-

$316

Managerial/Legal Review of Submission	1 - 4

	  4	4 - 16	$254-

$1,018

Recordkeeping

	1 - 3	  4	4 - 12	$105-

$316

TOTAL	9.5 - 29.5	17.5 - 98	7 - 21

67 - 275	$3,375 -

$14,080



	6(c)	Estimating Agency Burden and Cost

	The Agency has developed the following burden hour estimates for
activities related to promulgating a section 8(a) Chemical Specific
rule.

	Activity							Burden

		o  Industry/Public Assistance	(answering		0.1  FTE

	     	    questions regarding the rule)

		o  Data processing and systems support personnel	0.2  FTE

		o  Storage and Distribution				0.1  FTE

		o Compliance monitoring				0.1  FTE

	Total FTEs							0.5  FTE

	The Office of Pollution Prevention and Toxics bases its burden hour and
labor cost estimates on prior experience in gathering and processing
information associated with other information collections.  Because
these activities involve a team approach, the Agency has used a
composite burden hour estimate containing workers at various GS levels
and calculated hourly costs based upon the wage rate for a GS-12 Step 1.
 The 2006 annual salary for a GS-12 Step 1 in the Washington DC area is
$65,048.  The cost for 0.5 FTE is $32,524.  Incorporation of an overhead
and benefits factor of .6 yields a fully loaded cost of $52,038 to the
Agency for promulgating and supporting a TSCA section 8(a)
chemical-specific rule. The full-time work year is considered to be
2,080 so that there are 1,040 burden hours associated with 0.5 FTE.

					

	6(d)	Bottom Line Burden Hours and Costs

	The following table displays the annual burden and costs borne by
respondents and EPA associated with preparing, filing and reviewing a
notice resulting from a TSCA section 8(a) chemical-specific rule.

Table 3.  Annual Burden and Cost of a TSCA Section 8(a)
Chemical-Specific Rule

	Annual Burden Hours	Annual Costs

Industry	67 to 275 	$3,375 to $14,080

Agency	1,040	 $52,038



	6(e)	Reasons for Change in Burden

	

	The current request for renewal estimates a total annual burden to
respondents of 275 hours, which is unchanged from the previous ICR
renewal.

 

	EPA anticipates issuing one TSCA section 8(a) chemical-specific rule
per year with an average of four respondents submitting notices per
rule.  EPA may promulgate more than one TSCA section 8(a)
chemical-specific rule per year over the next three years.  If EPA does
this, the Agency will submit a technical amendment to OMB to reflect the
change in estimated burden to the regulated industry and the government.

	6(f)	Burden Statement

	The public burden for this collection of information is estimated to
average 68.8 hours per response (one-quarter of maximum annual burden of
275 hours for four notices).  Of the 68.8 hours, 65.8 hours are
associated with reporting tasks such as reviewing instructions,
gathering the data needed, and completing and reviewing the collection
of information.  The remaining three hours are associated with
recordkeeping.  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.  This includes the
time needed to review instructions; develop, acquire, install, and
utilize technology and systems for the purposes of collecting,
validating, and verifying 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;
and transmit or otherwise disclose the information.  An Agency may not
conduct or sponsor such a request and a person or facility is not
required to respond to a collection of information unless it displays a
currently valid OMB control number.    SEQ CHAPTER \h \r 1 The OMB
control numbers for EPA’s regulations in title 40 of the CFR, after
appearing in the Federal Register, are listed in 40 CFR part 9 and
included on the related collection instrument or form, if applicable.

	To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-OPPT-2010-0488.  The docket is available for public viewing at
the Pollution Prevention and Toxics Docket in the EPA Docket Center
(EPA/DC).  The EPA/DC Public Reading Room is located in the EPA West
Building, Room 3334, 1301 Constitution Ave., NW., Washington, DC.  The
EPA/DC 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
EPA/DC Public 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 through the Federal
Docket Management System (FDMS) at   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov .  Use FDMS to submit
or view public comments, access the index listing of the contents of the
public docket, and to access those documents in the public docket that
are available electronically.  Once in the system, select “search,”
then key in the docket ID number identified above.  Also, you can send
comments to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, NW, Washington, DC 20503,
Attention: Desk Office for EPA.  Please include the EPA Docket ID No.
EPA-HQ-OPPT-2010-0488 and OMB control number 2070-0067 in any
correspondence.

