            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.:   1884.07	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 Chemical Data Reporting (CDR) program, previously known as the Inventory Update Reporting (IUR) program, under the Toxic Substances Control Act (TSCA).  Under TSCA section 8(a) (15 USC 2607), the Environmental Protection Agency (EPA) is authorized to collect certain information on chemical substances manufactured or processed in the United States. In addition, under TSCA section 8(b), the Agency is required to compile and keep current, via periodic inquiry, the TSCA Inventory of Chemical Substances (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 Pollution Prevention and Toxics (OPPT) has used the CDR to update the basic chemical substance production information for selected larger volume chemical substances on the TSCA Inventory seven times, beginning in 1986, and to collect additional information relating to the manufacture, processing, and use of those chemical substances, beginning in 2006. 

       Prior to the 2012 collection, EPA implemented various amendments to the IUR in order to clarify the reporting requirements, improve the quality and utility of the data submitted, better match data collected with the Agency's overall information needs, and where possible, reduce the paperwork burden on both regulated entities and EPA. Manufacturers (including importers) are required to use e-CDRweb (the Agency-provided reporting tool) to submit a completed Form U (EPA Form 7740-8; see Attachment 3) electronically via the Internet. (See epa.gov/iur/pubs/guidance/aboutsub.html for information on the use of e-CDRweb.) The 2016 CDR includes manufacturing, processing, and use exposure-related data elements, including the volume of the chemical substance used on the reporting site; the volume of the chemical substance directly exported; and whether the chemical substance is being recycled, remanufactured, reprocessed or reused. Amendments that are implemented for the first time during the 2016 CDR include production volumes for each year since the last principal reporting year; modifications to reporting thresholds, including thresholds for processing and use; and reduction of the 25,000 lb reporting threshold to 2,500 lb for certain chemical substances that are the subject to particular TSCA rules and/or orders.

	OPPT will use the CDR data in its chemical substance risk-management efforts. Individual sites manufacturing (including importing) chemical substances will submit the required information. The information will be stored electronically for reference by EPA staff and others. Within the constraints of confidentiality claims, the information will be made public through the Agency's CDR website (epa.gov/cdr). Further discussion of how the information is used, stored, and collected is included in this document.

      The collection is expected to involve an average of approximately 4,289 respondents at an annual cost of $41 million. The details of the paperwork burden and 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.  TSCA section 8(a) authorizes the Administrator to promulgate rules to provide for the maintenance and collection of records from manufacturers, importers, and processors of commercial chemical substances. Sections 8(a)(1) and (2) of TSCA also authorize the Agency to collect information on the chemical manufacturing and importing industry. EPA possesses broad discretion in determining the information to be reported under TSCA section 8(a). The CDR rule was codified at 40 CFR 711. Previously known as the IUR rule and codified at 40 CFR 710, EPA changed the name and certain reporting requirements through the IUR Modifications; Chemical Data Reporting final rule published August 16, 2011, 76 FR 158. Copies of the relevant sections of TSCA and of the Code of Federal Regulations (CFR) are attached (see Attachments 1 and 2).
      
      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
                                       
   1. Common or trade name, chemical identity, and molecular structure of each chemical substance or mixture for which reports are required.
   2. Categories or proposed categories of use for each substance or mixture reported.
   3. 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.
   4. A description of the byproducts resulting from the manufacture, processing, use, or disposal of each such substance or mixture.
   5. All existing data concerning the environmental and health effects of such substances or mixtures.
   6. 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.
   7. The manner or method of disposal, and in any subsequent report on such substance or mixture, any change in the manner or method.

      The CDR provides basic exposure-related manufacturing, processing and use information used by EPA and others in a wide range of Agency activities. Because exposure is a key component of risk, the CDR exposure-related information will allow OPPT to screen chemical substances 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 will potentially allow the Agency and others to avoid more burdensome regulatory requirements. These enhanced data will allow EPA to conduct a more effective and efficient screening level review of chemical substances to identify candidates for further evaluation. 

      2(b)	Practical Utility/Users of the Data
      	
      The CDR information collection is the only mechanism through which EPA can collect basic information on commercial chemical substances listed on the TSCA Inventory, including production volume and other manufacturing (including importing), processing, and use exposure-related data. This information collection is necessary because these data are not otherwise available. Examples of how EPA will use the information it is collecting include:

      (1)       U.S. Parent company identification information: These data are collected to identify the parent company responsible for the data. EPA will require reporting of company identification information associated with the location of the company, and will clarify that the company information is to be for the U.S. parent company associated with the reporting plant site. These data will help ensure the company information is consistently provided.  

      (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 of production volumes for each of the years since the last principal reporting year, the production volume of a manufactured (including imported) chemical substance used at the reporting site, the production volume directly exported and not domestically processed or used, 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, and whether a manufactured (including imported) chemical substance, such as a byproduct, is being recycled, remanufactured, reprocessed, or reused:  These data are used to determine exposure potential based on manufacturing scenarios.
      
      (5) Industrial processing and use data, including types of industrial use and associated industrial sector (IS) codes, industrial function, estimated number of sites, estimated associated percent production volume, 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, an indication of consumer or commercial use, the number of commercial workers and whether the chemical is used in products intended for children, and the percentage production volume associated with the use:  These data will be used to determine exposure potential based on consumer or commercial populations.
	
      These data will also be used in other ways, such as in chemical substance exposure and risk screening, testing and/or 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 human and environmental exposure under TSCA section 8(e). Each data element corresponds to a data point necessary for basic risk-screening.
      
      Information secured through the CDR 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, CDR 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 CDR data are incorporated into a number of databases and products maintained by organizations including Right-To-Know-Net and INFORM.  CDR data were used to identify chemicals of particular concern for the National Institutes of Health.  Non-confidential CDR 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 on the TSCA Inventory currently warrant the continued collection of manufacturing information, and processing and use information.  Data reported under the CDR will enhance the capabilities of the Agency and other Federal agencies to ensure risk management actions are taken on chemical substances posing the most concern. More in-depth reporting of the processing and use data, more careful consideration of the need for confidentiality claims, and adjustments to the specific data elements will better support a robust risk assessment and management program. By enhancing the data supplied to Agency risk-screening programs, EPA expects to more effectively and expeditiously identify and address potential risks posed by chemical substances and provide improved access and information to the public. 

	EPA will also use the information submitted through the 2016 collection to update the Agency's comprehensive chemical manufacturing, exposure, and use database, maintained as part of the Manage Toxic Substances (MTS) system. CDR data prior to the 2006 collection are maintained in a series of databases known as the Chemical Update System (CUS). The MTS CDR data, combined with CUS and the Chemicals in Commerce Information System (CICIS) database, serves as a primary source of information about the chemical industry for EPA, as well as other Federal Agencies. The MTS CDR data provide information about the chemical substances used, where they are produced, how much is produced or imported, and how they are processed and used. The chemical industry is dynamic, as demonstrated by the approximately 30 percent change in chemical substances reported from one CDR submission period to the next; therefore continual updating of the database is essential.
	
      Data Uses

	Data generated by the CDR 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.  Screening chemical risks generally requires a combination of both hazard and exposure information. The CDR 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 CDR data range from the more traditional existing chemicals risk screening efforts, such as the Existing Chemicals Action Plans 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 CDR 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 CDR 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 CDR data.

   Current Uses of the 2012 CDR Data 
   
   * The Agency's process to identify priority chemicals for review uses the CDR data both for determining the initial chemicals on which to focus, and to screen those chemicals to identify the candidates for priority review.  The 2012 IUR data is essential to the prioritization of these chemicals, providing the screening level exposure-related data necessary for the initial priority determination.  

   * The CDR 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.  The Agency expects to develop overviews for priority chemicals that summarize available hazard, exposure, and use information on chemicals; outline the risks that each chemical may present; and identify the specific steps the Agency is taking to address those concerns. 
      
   * The TSCA Interagency Testing Committee (ITC) has requested CDR 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 CDR information to refine its selection of chemicals for testing, information reporting, or another recommendation.  


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 otherwise 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 CDR 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 CDR 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 CDR, EPA cannot 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 CDR: the TSCA Preliminary Assessment Information Reporting (PAIR) rule (40 CFR part 712).  However, PAIR would not be an efficient or cost-effective way to compile a database to allow the large-scale risk screening of chemicals on the TSCA Inventory.  Although PAIR is a useful data collection tool when one or a small group of chemicals is targeted for risk assessment, it is limited when collecting information on a large number of chemicals.  Additionally, the PAIR rule has fewer, less definitive data elements than the CDR, is a one-time collection versus the five year collection cycle of the CDR, and will not provide data sufficient to meet the goals of the CDR.  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 CDR 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 CDR data to identify those specific chemicals that are of potential concern and need follow up assessment.   

	The CDR 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

	 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

	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

      EPA returned the reporting frequency to every four years when promulgating the 2011 Chemical Data Reporting rule (see 76 FR 158), which was the frequency in effect from 1986 to 2006. In an effort to reduce the reporting burden associated with the 2003 amendments, EPA had changed the reporting frequency to every five years. While the less frequent reporting does reduce burden, EPA now believes that reporting every five years does not provide data sufficiently current to meet Agency and public needs and now considers every four years to be the minimum acceptable frequency. In addition, the CDR Modifications proposed rule requested comment on even more frequent reporting. Comments from industry representatives led EPA to believe that more frequent reporting creates efficiencies, both for the respondent and for EPA. With more frequent reporting, companies will be able to establish standard systems and practices to collect the required information. 
   
	The Agency needs to be able to make accurate chemical substance risk management decisions in a timely and cost effective manner, especially because alternative data sources do not exist for these data. The effect of less frequent collection of these data is to diminish significantly the Agency's ability to understand the chemical industry and monitor the production levels of chemical substances manufactured (including imported) in the United States. As described above, the CDR data demonstrate that chemical industry product lines and manufacturing in the United States change substantially from one submission period to the next. The Agency needs up-to-date information in order to fulfill its mandate to keep the TSCA Inventory current under section 8(b) of TSCA; collecting the data every five years means the Agency is working with data which are potentially six or more years old, and therefore, cannot be considered current. 

	Less frequent collection could result in EPA using outdated information in its decision making. For example, changing market conditions, batch processing, or the development of new uses for the chemical substance can cause production volumes or chemical substance uses to change from one year to the next. Companies buy and sell plant sites, and the chemical substances produced at a site can change. Based on past CDR reporting, the Agency would be working with the CDR data which approximately 30 percent of the chemical substances known to be in commerce at volumes of 25,000 lb or more may not actually be in commerce at those levels. 

	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 in the next collection, which is in four years, and to allow EPA's enforcement activities to cover two CDR reporting cycles.

	Confidential Business Information (CBI) claims limit access to the CDR 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 CDR.  Due to the past experience the Agency has had with respondents to the CDR, 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 likely would be subject to CDR reporting.  However, activities at these sites may vary, 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.  Second, NAICS codes assigned by U.S. parent companies reflect the parent company's primary activity, even though many U.S. 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 U.S. 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 CDR and certain other reporting in 40 CFR 704.3.

	In addition to the anticipated respondents listed above, manufacturers (including importers) of byproducts are required to report under the CDR rule. Byproduct manufacturers (including importers) may be listed under a different primary activity for a site, such as NAICS codes 22, 322, 331, and 3344; e.g., utilities, paper manufacturing, primary metal manufacturing, and semiconductor and other electronic component manufacturing. For purposes of the CDR, a byproduct is a chemical substance produced without a separate commercial intent during the manufacture, processing, use or disposal of another chemical substance or mixture (40 CFR 704.3). Such a chemical substance, like any other manufactured chemical substance, is subject to CDR reporting if it is manufactured, is listed in EPA's Master Inventory File, is not otherwise excluded from reporting, and its manufacturer is not specifically exempted from CDR reporting requirements. For instance, a manufacturer (including importer) that uses a chemical substance in the production of an article may produce a byproduct substance that is chemically different from the starting substance; the manufacturer (including importer) therefore may incur reporting obligations under the CDR for that byproduct. While some manufacturers (including importers) of byproducts may not have reported to the CDR in the past, they should be aware now of their reporting obligations under the CDR rule. 

	4(b)	Information Requested

	(i) Data items

	The CDR 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 known or reasonably ascertainable information.

	Using e-CDRweb to create an electronic version of Form U, respondents report the data elements 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.

   * U.S. Parent Company and Technical Contact Information.  U.S. parent 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.  Specific chemical name and CAS registry or accession number, as applicable, for chemicals with reporting year, site-specific production volume of 25,000 pounds or more. The reporting threshold is reduced to 2,500 pounds for chemical substances that are the subject of a rule proposed or promulgated under TSCA section 5(a)(2), 5(b)(4), or 6, the subject of an order issued under TSCA section 5(e) or 5(f), or the subject of relief that has been granted under a civil action under TSCA section 5 or 7.

   * Manufacturing Information.  The production volume for each of the years since the last principal reporting year; the volume of the reported chemical substance used at the reporting site; whether an imported chemical substance is physically at the reporting site; the production volume directly exported and not domestically processed or used; whether a manufactured (including imported) chemical substance, such as a byproduct, is being recycled, reused, reprocessed, or remanufactured; the number of workers reasonably likely to be exposed (in ranges); the maximum concentration of chemical (in ranges); and the physical form of chemical with associated percent production volume.

   * Processing and Use Information. Up to 10 unique combinations of type of process or use (code), Industrial Sector (IS) 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 Use Data. 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:

   (i) 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;

   (ii) 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; 

   (iii) CDX Registration Activities -- The CDR rule requires electronic reporting, and therefore requires that all submitters complete the CDX registration process. As part of registering with CDX, each submitter will provide identifying information that will comprise all or most of the information requested in Part I of Form U. This information will then be pre-populated whenever the submitter prepares a partial or full report; 

   (iv) Prepare and Submit Report, and Maintain Records- Partial Report -- Compile the required information, determine the CBI status of information and fulfill appropriate substantiation measures, and use e-CDRweb to complete and submit only Parts I and II (and Part IV, if a joint submission) of Form U for chemical substances specifically listed in the regulation for which there is a partial reporting exemption. Retain all records related to the submission for five years after the submission period; and

   (v) Prepare and Submit Report, and Maintain Records- Full Report -- Compile the required information, determine the CBI status of information and fulfill appropriate substantiation requirements, and use e-CDRweb to complete and submit Parts I, II, and III for chemical substances manufactured (including imported) in volumes of 25,000 lb or more (or 2,500 lb or more, if applicable), and Part IV, if a joint submission, of Form U. Retain all records related to the submission for five years after the 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 CDR database
   * review requests for confidentiality in the submissions
   * maintain the database
   * distribute the data

	5(b)	Collection Methodology and Management

	The next CDR collection will occur in 2016. All manufacturers (including importers), except for those defined as "small manufacturers" by EPA's regulations, are required to submit information on every substance subject to the 2011 CDR rule that they manufacture (including import) in quantities that meet or exceed the CDR thresholds. The collection will occur every four years.

	(i) Collection Methodology

	All manufacturers (including importers) of subject chemicals are required to report under the CDR rule.  Submitters are required to submit information associated with this data collection electronically via the Internet using e-CDRweb and CDX.  Potential reporters are notified of the need to report in three ways:  (1) EPA publishes a Federal Register notice, (2) email notices are sent to previous CDR submitters, and (3) articles are published in the trade press.  Reporting materials, including a non-submission version of the e-CDRweb reporting tool and a variety of guidance documents (Instruction Manual, Q&As, Case Studies), are available on the EPA's CDR website.  Submitters can also obtain the reporting materials from the TSCA Hotline.
	 
      Information quality and validation begins with the e-CDRweb reporting tool, which is programmed to help the submitter provide the information required, in the correct format as required by the CDR rule. Use of e-CDRweb will eliminate many of the problems with incorrect chemical substance identifications experienced in the past by providing a current listing of the TSCA Inventory chemicals and their associated identification numbers. Other respondent-generated errors, such as incorrect codes, have also been eliminated due to the use of techniques such as drop-down menus, restrictions on the specific information that can be entered, and error-checking algorithms. 
      	
      Mandatory CDR reporting via the Internet is the most efficient collection method for submitters and EPA. Submitters receive almost immediate notification that EPA has received their submission, and EPA is able to upload the information directly into the CDR database, which improves the efficiency of EPA's data receipt and processing activities. This collection method also eliminates the introduction of errors by avoiding the need to scan or key-enter data submitted on paper or CD.  Additional validations have been programmed into the data-entry system to further ensure the quality of the data. 

	To aid persons subject to this information collection, the Agency's TSCA and CDX Hotlines are available to answer questions regarding the CDR requirements or submission process.  When Hotline staff is 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 or OEI are used as necessary.  

	(ii) Data Management

	This section describes the Agency tasks required for efficiently processing submissions under the CDR.  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 from collection to collection.

	CDR data is stored in a database managed by the Agency.  Once updated, the database is then available to EPA technical reviewers for export into their various analytical modeling systems and databases.  The CDR database is also available for quick screening and other direct uses.  The Agency makes publicly available as much information as possible, within the confines of protecting CBI.

   * 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 CDR collections.  File servers with appropriate backup are used to contain the CDR databases.  Following the 2006 IUR collection, EPA updated the technology used to store the data, storing it in a larger Manage Toxic Substances (MTS) database.  In addition, CDR 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 CDR 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 CDR Form U submissions.  This includes developing standard operating procedures and documentation for all stages in the CDR 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 2012 CDR submission period, EPA developed new processes to receive CDR submissions over the Internet, using the Agency's Central Data Exchange (CDX) system; these systems apply for the 2016 CDR. 

   * Additional Activities -- The Agency develops various supporting documents associated with the reporting tool and makes them available on the Internet.  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 Economic Analysis for the Final Inventory Reporting Modifications Rule determined that the impact on these companies is, on average, significantly less than 1% of revenues (EPA 2011).  

	5(d)	Collection Schedule

	The submission period shall be from June 1, 2016 to September 30, 2016. The submission period/schedule follows the requirements of 40 CFR 711.20.


6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION
                                       
      This section presents the burden and cost estimates incurred by all affected entities as a result of the CDR rule, and covers the period from 2012 to 2015. Therefore, it provides burden and cost estimates for the information collection corresponding to the 2016 reporting cycle. Although reporting occurs only once per reporting cycle (once every four years), EPA believes that rule compliance and data collection activities, and thus, costs and burdens, are incurred over the course of the reporting cycle. Therefore, for purposes of this analysis, the burden and cost for one reporting cycle are averaged over the number of years in the reporting cycle and are presented here as average annual figures. All costs are presented in year 2010 dollars. The CDR requires reporting on a "per site" basis rather than a "per company" basis. Therefore, each site which is subject to the CDR rule is considered a respondent and will submit one Form U containing one or more chemical-specific reports. EPA estimates that 4,289 respondents will respond in the 2016 reporting cycle.
      
      Burden and cost calculations are based on the assumption that EPA will receive an average of 30,287 full reports and 648 partial reports in the 2016 reporting cycle. Each report is for a single chemical/site combination. Each site is expected to submit an average of 7.06 full reports and 0.15 partial reports in the reporting cycle. The average burden per respondent, which is one site, is estimated to be 600 hours per cycle, or 150 hours annually over the three year period from 2012 through 2015. This is higher than the burden estimated for the currently approved ICR (EPA ICR No. 1884.05), due to an adjustment in reporting requirement criteria, including additional data requirements and modifications to reporting thresholds. 

	6(a)	Estimating Respondent Burden

	For the 2016 reporting cycle, each manufacturing site (including importers) must submit a Form U if the site meets or exceeds the 25,000 lb threshold for at least one chemical substance in any calendar year since the last principal reporting year. For purposes of the ICR, one manufacturing site is equivalent to one respondent. Form U contains four Parts. Part I contains basic site identification information and must be completed by all sites. Part II contains manufacturing data (production volumes, etc.) specific to each chemical substance, which also must be completed by all sites. Together, Part I and Part II are considered a "partial report." Part III contains processing and use information and is to be completed for all chemical substances unless the chemical substance is specifically exempted from the requirement to do so. Part IV contains secondary company identification information and specific information identifying a chemical substance. Part IV is completed only by a secondary respondent (see Section 2(b)). For purposes of this analysis, burden and costs associated with Part IV are considered part of the burden and costs estimates of Part I (respondent identification) and the beginning of Part II (chemical identification), and therefore were not separately calculated. Together, Parts I, II, and III (and Part IV, when applicable) are considered a "full report." One report is submitted for each unique chemical substance/site combination; that is, a site must complete a separate report for each applicable chemical substance, but Part I of Form U is completed and submitted only once per site. EPA anticipates that Part I will be completed automatically when respondents register with CDX. 

	To comply with the regulation, manufacturers (including importers) must complete the activities listed in Table 2. Table 2 also provides a cross-walk of the related Information Collection that corresponds to each activity.


Table 2: Cross-Walk between Industry Activities and Related Information Collections (ICs)

Activity
Description
Related IC(s)
Compliance Determination
Site staff must determine whether reporting is required for a chemical substance manufactured (including imported) at a particular site, based on the chemical substance's production volume and the applicability of certain reporting exemptions. 
Compliance Determination
Rule Familiarization
Site staff must familiarize themselves with the requirements of the rule. Staff from sites that reported previously must become familiar with new requirements, and staff from sites new to reporting must become familiar with all requirements. This entails reading the rule, understanding the various reporting and administrative requirements, and determining the manner in which the reporting requirements will be met.
Rule Familiarization
CDX Registration 
Before submitting Form U, all respondents must register with CDX. In addition, respondents must complete an Electronic Signature Agreement form, which is signed, dated, and either submitted electronically or mailed back to EPA.
CDX Registration Activities
Preparation of Reports
Site staff must collect all of the required information and complete partial and/or full reports using a Form U report form, for each of the reportable chemical substances at that site. The information must be reviewed, and submitted to EPA. This task involves any research necessary to identify the correct information to report, the act of completing Form U (technical and clerical burden), and managerial review. Once Form U is completed, company staff must submit it electronically to EPA via CDX.
Prepare and Submit Report, and Maintain Records  -  
Partial Report

Prepare and Submit Report, and Maintain Records  - 
Full Report
Recordkeeping
Respondents must keep records supporting their submissions for five years.
Prepare and Submit Report, and Maintain Records  -  
Partial Report 

Prepare and Submit Report, and Maintain Records  -  
Full Report

	Burden estimates were derived originally from a survey conducted by EPA in 1996 (under OMB Control No. 2070-0034) to assess the potential burden associated with the IUR, as amended at that time. The survey was distributed to previous CDR respondents selected from the CDR database. Burden estimates were updated for a 2005 amendment to the rule as described in Economic Analysis of IUR Modifications Final Rule (EPA, 2005). Burden estimates for new reporting elements in the 2011 final rule were derived as described in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a).

	Table 3 illustrates the burden for a typical respondent on a per-activity basis, including time required to complete each section of Form U. CDR reporting for all respondents occurs within a required timeframe (once every four years). The three years covered by this ICR renewal (2012 through 2015) will occur during the 2016 reporting cycle. Therefore, burden hour estimates for this period (Table 3) are based on the "future" reporting cycle burdens as calculated in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a). (The economic analysis also estimated costs for the "current" (2012) reporting cycle).EPA estimates the total industry burden for completing and submitting one partial report to be 28.39 hours, and the estimated burden for completing and submitting one full report to be 94.02 hours. Each site is expected to submit an average of 7.06 full reports and 0.15 partial reports in the 2016 reporting cycle. 

	EPA calculated burden estimates for each element of Form U individually, using the 1996 survey results, economic analyses for other rules with similar requirements (such as the Premanufacture Notification Electronic Reporting final rule), and EPA's best professional judgment. More detailed information on the derivation of these estimates is found in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a). 

Table 3: Total Industry Burden, by Activity
                                   Activity
                            Clerical Burden (hours)
                               Technical Burden
                                    (hours)
                               Managerial Burden
                                    (hours)
                                 Total Burden
                                    (hours)
                                       
                                      (a)
                                      (b)
                                      (c)
                               (d) = (a)+(b)+(c)
PREPARATION OF REPORT 
Part I. Site Identification Information

Certification
                                                                           0.00
                                                                           0.85
                                                                           1.01
                                                                           1.86

Company Information (U.S. Parent Company Name, D&B Number, Mailing Address, Technical Contact, Technical Contact Mailing Address)
                                                                           0.00
                                                                           0.01
                                                                          0.004
                                                                           0.01

Plant Site Identification (Site Name, D&B Number, Mailing Address)
                                                                           0.00
                                                                           0.01
                                                                          0.004
                                                                           0.02

Total for Part I
                                                                           0.00
                                                                           0.87
                                                                           1.02
                                                                           1.89
Part II. Manufacturing Information

Site-Limited, Activity, Production Volume (lb) (2015)
                                                                           0.00
                                                                           1.82
                                                                           0.45
                                                                           2.27
 
Chemical Substance Identification Upfront CBI Substantiation
                                                                           0.00
                                                                           1.16
                                                                           0.61
                                                                           1.77
 
Plant Site Upfront Substantiation
                                                                           0.00
                                                                           0.66
                                                                           0.41
                                                                           1.07
 
Total Number of Workers
                                                                           0.00
                                                                           1.14
                                                                           0.47
                                                                           1.61
 
Maximum Concentration, Physical Form, Percent Volume of Production
                                                                           0.00
                                                                           2.23
                                                                           0.86
                                                                           3.09
 
Production Volume for Each of the Years since Last Principal Reporting Year (2012 - 2014)
                                                                           0.00
                                                                           2.46
                                                                           0.60
                                                                           3.07
 
Production Volume Used On-Site
                                                                           0.00
                                                                           0.16
                                                                           0.04
                                                                           0.20
 
Whether Imported Chemical Substance is Physically at Reporting Site
                                                                           0.00
                                                                           0.09
                                                                           0.02
                                                                           0.11
 
Volume Exported
                                                                           0.00
                                                                           0.82
                                                                           0.20
                                                                           1.02
 
Whether a Chemical Substance is to be Recycled, Remanufactured, Reprocessed or Reused.
                                                                           0.00
                                                                           0.09
                                                                           0.02
                                                                           0.11

Total for Part II
                                                                           0.00
                                                                          10.65
                                                                           3.68
                                                                          14.33
Part III. Processing and Use Information
 
 
Upfront Substantiation for Processing and Use Information CBI Claims
                                                                           0.00
                                                                           0.43
                                                                           0.21
                                                                           0.64

Industrial Processing and Use Exposure-Related Data

 
Determination of Applicability
                                                                           0.00
                                                                           0.81
                                                                           0.23
                                                                           1.03

 
Industrial Function Category
                                                                           0.00
                                                                           3.53
                                                                           1.65
                                                                           5.18

 
Sector 
                                                                           0.00
                                                                           0.75
                                                                           0.32
                                                                           1.06

 
Percent of Production Volume
                                                                           0.00
                                                                           8.00
                                                                           4.22
                                                                          12.22

 
Total Number of Processing and Use Sites
                                                                           0.00
                                                                           7.31
                                                                           2.82
                                                                          10.13

 
Total Number of Potentially Exposed Workers
                                                                           0.00
                                                                          12.34
                                                                           3.06
                                                                          15.41

Consumer and Commercial Use Exposure-Related Data

 
Determination of Applicability
                                                                           0.00
                                                                           0.75
                                                                           0.20
                                                                           0.95
 
 
Identification of Production Category/Use by Children
                                                                           0.00
                                                                           0.67
                                                                           0.20
                                                                           0.87
 
 
Percent of Production Volume
                                                                           0.00
                                                                           1.01
                                                                           0.36
                                                                           1.37
 
 
Maximum Concentration by Category
                                                                           0.00
                                                                           1.09
                                                                           0.28
                                                                           1.36
 
 
Number of Commercial Workers Reasonably Likely to be Exposed
                                                                           0.00
                                                                          12.34
                                                                           3.06
                                                                          15.41

Total for Part III
                                                                           0.00
                                                                          49.03
                                                                          16.60
                                                                          65.63
COMPLIANCE DETERMINATION 

Compliance Determination
                                                                           0.00
                                                                           2.50
                                                                           0.00
                                                                           2.50
RULE FAMILIARIZATION 

Rule Familiarization 
                                                                           0.00
                                                                           2.00
                                                                           2.00
                                                                           4.00
CDX REGISTRATION ACTIVITIES 

 
CDX Registration
                                                                           0.00
                                                                           0.73
                                                                           0.18
                                                                           0.92
 
 
CDX Electronic Signature Agreement
                                                                           0.00
                                                                           1.00
                                                                           0.75
                                                                           1.75

Total for CDX Registration Activities
                                                                           0.00
                                                                           1.73
                                                                           0.93
                                                                           2.67
RECORDKEEPING

Recordkeeping
                                                                           0.75
                                                                           1.50
                                                                           0.75
                                                                           3.00
TOTAL BURDEN 
Burden for one Partial Report (Parts I, II, Compliance Determination, Rule Familiarization, Recordkeeping and CDX Registration Activities)
                                                                           0.75
                                                                          17.52
                                                                           7.45
                                                                          28.39
Burden for one Full Report (Parts I, II, III, Compliance Determination, Rule Familiarization, Recordkeeping and CDX Registration Activities)
                                                                           0.75
                                                                          66.54
                                                                          24.05
                                                                          94.02
Note: Totals may not sum due to rounding.
Source: Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a).

	6(b) 	Estimating Submitter Cost

      EPA multiplied burden estimates by standard wage rates for managerial, technical, and clerical levels developed from information published by the Bureau of Labor Statistics (BLS) and a method outlined in the document Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b). Wage data for the three occupational categories was gathered for manufacturing industries from Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006  -  December 2010 (BLS, 2011a).

      The cost of fringe benefits, such as health insurance and vacation, is taken for each labor category from the same ECEC series. Following the methodology outlined in EPA 2002b, fringe benefits are calculated as a percentage of total wages for each category. EPA added 17 percent to the wages in each category to account for overhead, based on information provided by the chemical industry and chemical industry trade associations in the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a). The wages for each of the three categories were then multiplied by benefits and overhead factors to estimate loaded, annual salaries in year 2010 dollars. Table 4 contains the loaded wage rates for the managerial, technical and clerical occupation categories. 

Table 4: Derivation of Loaded Wage Rates for the Private Manufacturing Sector in 2010$ 

                                       
                                       
                                       
                                    Wage[1]
                              Fringe Benefits[1]
                             Fringes as % of Wage
                             Overhead % of Wage[2]
                           Fringe + Overhead Factor
                                 Loaded Wages
                                       
                                      (a)
                                      (b)
                                 (c) = (b)/(a)
                                      (d)
                                (e)=(1)+(c)+(d)
                                (f) = (a) x (e)
Clerical
                                    $17.36 
                                    $8.67 
                                    48.37%
                                      17%
                                     1.67
                                    $28.98
Technical
                                    $36.93 
                                    $18.50 
                                    47.58%
                                      17%
                                     1.67
                                    $61.71
Managerial
                                    $42.82 
                                    $19.64 
                                    45.03%
                                      17%
                                     1.63
                                    $69.74 
[1] Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006  -  December 2010, US Bureau of Labor Statistics, March 2011 (BLS, 2011a).
[2] An overhead rate of 17 percent was estimated based on industry data gathered for the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a).

      Table 5 contains the cost per activity of completing Form U for one respondent in the 2016 reporting cycle. Burden hours presented in Table 4 were multiplied by the corresponding loaded wage rage in Table 5. EPA estimates the total cost for completing and submitting one partial report in future reporting cycles is $1,794 and the cost for completing and submitting one full report is $5,978. More information on the derivation of these costs is found in the IUR EA (EPA, 2011a).



Table 5: Total Industry Cost, by Activity, Future Reporting Cycles
                                   Activity
                                 Clerical Cost
                                    (2010$)
                                Technical Cost 
                                    (2010$)
                                Managerial Cost
                                    (2010$)
                                  Total Cost
                                    (2010$)
                                       
                                      (a)
                                      (b)
                                      (c)
                               (d) = (a)+(b)+(c)
PREPARATION OF REPORT 
Part I. Site Identification Information

Certification
                                                                         $0.00 
                                                                        $52.45 
                                                                        $70.44 
                                                                       $122.89 

Company Information (U.S. Parent Company Name, D&B Number, Mailing Address, Technical Contact, Technical Contact Mailing Address)
                                                                         $0.00 
                                                                         $0.49 
                                                                         $0.28 
                                                                         $0.77 

Plant Site Identification (Site Name, D&B Number, Mailing Address)
                                                                         $0.00 
                                                                         $0.74 
                                                                         $0.28 
                                                                         $1.02 

Total for Part I
                                                                         $0.00 
                                                                        $53.69 
                                                                        $70.99 
                                                                       $124.68 
Part II. Manufacturing Information

Site-Limited, Activity, Production Volume (lb) (2015)
                                                                         $0.00 
                                                                       $112.56 
                                                                        $31.24 
                                                                       $143.80 

Chemical Identification Upfront CBI Substantiation
                                                                         $0.00 
                                                                        $71.58 
                                                                        $42.68 
                                                                       $114.26 

Plant Site Upfront Substantiation
                                                                         $0.00 
                                                                        $40.97 
                                                                        $28.45 
                                                                        $69.43 

Total Number of Workers
                                                                         $0.00 
                                                                        $70.59 
                                                                        $32.64 
                                                                       $103.23 

Maximum Concentration, Physical Form, Percent Volume of Production
                                                                         $0.00 
                                                                       $137.73 
                                                                        $59.70 
                                                                       $197.43 

Production Volume for Each of the Years since Last Principal Reporting Year (2012 - 2014)
                                                                         $0.00 
                                                                       $151.95 
                                                                        $42.18 
                                                                       $194.13 

Production Volume Used On-Site
                                                                         $0.00 
                                                                         $9.83 
                                                                         $2.73 
                                                                        $12.55 

Whether Imported Chemical Substance is Physically at Reporting Site
                                                                         $0.00 
                                                                         $5.63 
                                                                         $1.56 
                                                                         $7.19 

Volume Exported
                                                                         $0.00 
                                                                        $50.65 
                                                                        $14.06 
                                                                        $64.71 

Whether a Chemical Substance is to be Recycled, Remanufactured, Reprocessed or Reused
                                                                         $0.00 
                                                                         $5.63 
                                                                         $1.56 
                                                                         $7.19 

Total for Part II
                                                                         $0.00 
                                                                       $657.12 
                                                                       $256.80 
                                                                       $913.92 
Part III. Processing and Use Information


Upfront Substantiation for Processing and Use Information CBI Claims
                                                                         $0.00 
                                                                        $26.35 
                                                                        $14.64 
                                                                        $40.98 

Industrial Processing and Use Exposure-Related Data


Determination of Applicability
                                                                         $0.00 
                                                                        $26.35 
                                                                        $15.89 
                                                                        $42.23 


Industrial Function Category
                                                                         $0.00 
                                                                         $0.00 
                                                                       $115.24 
                                                                       $115.24 

 
Sector
                                                                         $0.00 
                                                                        $49.72 
                                                                        $22.05 
                                                                        $71.78 


Percent of Production Volume
                                                                         $0.00 
                                                                       $217.95 
                                                                       $294.26 
                                                                       $512.21 


Total Number of Processing and Use Sites
                                                                         $0.00 
                                                                        $46.16 
                                                                       $196.57 
                                                                       $242.73 


Total Number of Potentially Exposed Workers
                                                                         $0.00 
                                                                       $493.68 
                                                                       $213.64 
                                                                       $707.32 

Consumer and Commercial Use Exposure-Related Data


Determination of Applicability
                                                                         $0.00 
                                                                        $49.72 
                                                                        $13.99 
                                                                        $63.71 


Identification of Production Category/Use by Children
                                                                         $0.00 
                                                                       $217.95 
                                                                        $13.75 
                                                                       $231.71 


Percent of Production Volume
                                                                         $0.00 
                                                                        $46.16 
                                                                        $25.13 
                                                                        $71.29 


Maximum Concentration by Category
                                                                         $0.00 
                                                                       $493.68 
                                                                        $19.21 
                                                                       $512.88 


Number of Commercial Workers Reasonably Likely to be Exposed
                                                                         $0.00 
                                                                       $451.30 
                                                                       $213.64 
                                                                       $664.94 

Total for Part III
                                                                         $0.00 
                                                                     $3,025.27 
                                                                     $1,158.00 
                                                                     $4,183.27 
COMPLIANCE DETERMINATION 

Compliance Determination
                                                                          $0.00
                                                                        $154.27
                                                                          $0.00
                                                                        $154.27
RULE FAMILIARIZATION 

Rule Familiarization 
                                                                          $0.00
                                                                        $123.42
                                                                        $139.48
                                                                        $262.90
CDX REGISTRATION ACTIVITIES


CDX Registration
                                                                         $0.00 
                                                                        $45.25 
                                                                        $12.79 
                                                                        $58.04 


CDX Electronic Signature Agreement
                                                                         $0.00 
                                                                        $61.71 
                                                                        $52.30 
                                                                       $114.01 

Total for CDX Registration Activities
                                                                          $0.00
                                                                        $106.96
                                                                         $65.09
                                                                        $172.05
RECORDKEEPING

Recordkeeping
                                                                        $21.74 
                                                                        $92.56 
                                                                        $52.30 
                                                                       $166.60 
TOTAL COST 
Cost for one Partial Report (Parts I, II, Compliance Determination, Rule Familiarization, Recordkeeping and CDX Registration Activities)
                                                                        $21.74 
                                                                     $1,188.01 
                                                                       $584.67 
                                                                     $1,794.42 
Cost for one Full Report (Parts I, II, III, Compliance Determination, Rule Familiarization, Recordkeeping and CDX Registration Activities)
                                                                        $21.74 
                                                                     $4,213.28 
                                                                     $1,742.67 
                                                                     $5,977.69 
Note: Totals may not sum due to rounding.
Source: Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a).


 	6(c)	Estimating Agency Burden and Cost

      EPA is responsible for the following activities associated with administering the CDR rule: 

   * Document receipt and tracking;
   * Data entry and quality control of data entry;
   * Backup systems operation;
   * Data processing;
   * Systems development; 
   * Contract oversight and management; 
   * Publication and printing of forms and materials; and 
   * Operation of the TSCA Hotline to handle CDR-related calls. 

      Costs related to EPA activities that involve using the data are not included. 

      EPA Staff Activities

      Of the tasks listed above, Agency personnel are responsible for (1) quality control of data entry; and (2) data processing, systems development, and contract oversight and management. Contractors perform the other activities, as described below.

      EPA estimates the total burden of completing Agency tasks to be one full-time equivalent at the GS 13 level for data processing, systems development, and contract oversight and management, per-reporting cycle. An estimated 0.193 FTEs are needed at the GS 12 level for quality control of data entry in this reporting cycle. Calculations of the Agency burden are presented in Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011). 

      EPA labor costs are based on annual federal wage rates published by the Office of Personnel Management for the Washington-Baltimore-Northern Virginia, DC-MD- VA-WV-PA locality pay area for 2010 (OPM, 2010). Wages are presented in terms of GS-level and step. Based on previous IUR economics analyses, a Step 3 is assumed for all FTEs (EPA, 2002a and EPA, 2005). Following the methodology outlined in Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a), EPA added 58 percent to the wage rate to account for fringe benefits and overhead costs. 
      
      Table 6 shows the loaded wage rates for Agency staff at the GS-12 Step 3, and GS-13 Step 3 levels.

Table 6: Derivation of Loaded Agency Wage Rates (2010$)

                                   Pay Grade
                                 Annual Salary
                         Overhead and Fringe Benefits 
                                 (% of wages)
                       Overhead and Fringe Benefit Cost 
                                    Total 
                                 GS 12 Step 3
                                    79,864
                                      58%
                                   $46,321 
                                   $126,185 
                                 GS 13 Step 3
                                    $94,969
                                      58%
                                    $55,082
                                   $150,051
Source: The unloaded Federal salary for 2010 is from the Office of Personnel Management salary table for Washington-Baltimore-Northern Virginia (OPM, 2010). 

      Table 7 contains the burden and cost per report for all EPA staff activities in the reporting cycle. The activities performed by the GS-13 level staff member, including systems development, and contract oversight and management, are fixed costs and are not dependent on the number of reports submitted to EPA. Therefore, the total burden for systems development and contract oversight is one FTE at the GS-13 level, with a cost of $150,051 in the 2016 reporting cycle. Quality control of data entry is performed by the GS-12 level staff member and is dependent on the number of reports received. The burden for quality control of data is approximately 0.000011 FTE per report. The total cost per-report is approximately $1.35. The burden and cost of processing each data element in Form U are derived in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a). EPA multiplied the burdens by the number of data elements in each section to estimate the total cost and burden of processing each Form U. For more detail on the derivation of these burdens, see the IUR EA (EPA, 2011a). 

Table 7: EPA Staff Burden and Cost of Processing One Report 

                                   Activity
                       Agency Burden per Activity (FTE)
                          Agency Burden per Activity
                                    (hours)
                                 Agency Cost 
                                 per Activity
                                    (2010$)
                        GS-12 Step 3 per-Report Burden
Quality Control of Data for Part I
                                   0.0000048
                                    0.0100
                                    $0.62 
Quality Control of Data for Part II
                                   0.0000026
                                    0.0054
                                    $0.34 
Quality Control of Data for Part III
                                   0.0000030
                                    0.0063
                                    $0.39 
Total GS-12 Burden, per report
                                   0.0000105
                                    0.0218
                                    $1.35 
                        GS-13 Step 3 Fixed Cost Burden
Systems development, and contract oversight and management
                                       1
                                     2,080
                                   $150,051 
Total GS-13 Burden, per reporting cycle
                                       1
                                     2,080
                                   $150,051 
Note: Costs may not exactly equal FTE times the wage rates in Table 6 due to rounding.
 
	Contractor Activities

	Agency costs also include payment for extramural tasks completed by contractors (this category includes costs to EPA, but not burden hours). Contractor activities include document receipt, tracking, data entry, maintaining backup systems, printing and publishing forms and materials, and managing the TSCA Hotline. With the exception of document receipt, tracking, and data entry, all contractor costs are fixed and are not dependent on the number of reports received. 

      As presented in Table 8, EPA calculated the cost estimate per report for document receipt, tracking, and data entry (variable costs), $0.66, by starting with the cost estimated in the 2011 ICR, and updated for inflation. To calculate the inflated the post-amendment cost attributed to contractor staff, EPA followed the approach outlined in the 2011 Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a) that estimates variables contractor staff costs as a portion of all data management costs. 
      
      All fixed costs are taken from the last published ICR and were inflated from 2008 to 2010 dollars with an inflation factor calculated using the Employment Cost Index (ECI), seasonally adjusted, for white-collar occupations in private industry (BLS, 2011b). 

Table 8: Cost of Contractor Activities 
                                   Activity
                               Annual Cost 2008$
                               Inflation Factor
                               Annual Cost 2010$
Variable Costs
Document receipt, tracking, and data entry for Part I
                                    $0.09 
                                      n/a
                                    $0.10 
Document receipt, tracking, and data entry for Part II
                                    $0.26 
                                      n/a
                                    $0.26 
Document receipt, tracking, and data entry for Part III
                                    $0.30 
                                      n/a
                                    $0.30 
Total Cost of Document receipt, tracking, and data entry, per full report
                                    $0.65 
                                      n/a
                                    $0.66 
Fixed Costs
Maintaining and Operating Back Up Systems
                                   $59,145 
                                     1.03 
                                      n/a
Printing and Publishing Forms and Materials
                                    $5,525 
                                     1.03 
                                      n/a
Managing the TSCA Hotline
                                   $44,694 
                                     1.03 
                                      n/a
Total Fixed Cost
                                   $109,365 
                                      n/a
                                      n/a

	6(d) 	Bottom-Line Industry Burden and Cost Estimates
		
	This section describes the estimated total social paperwork burden and cost of the CDR rule, including the final amendments. The next CDR submission period will occur in 2016. Although reporting occurs only once per reporting cycle (once every four years), EPA believes rule compliance and data collection activities, and thus, costs and burdens, are incurred over the course of the reporting cycle. Therefore, for purposes of this analysis, the burden and cost for one reporting cycle are averaged over the number of years in the reporting cycle and are presented here as average annual figures. This supporting statement is for the three-year period from 2012 through 2015; therefore, average annual figures for each of these three years are presented below.

      Respondent tally

      EPA calculated the numbers of sites and reports submitted based on submission information from the December 2008 version of the IUR database, which includes data from the most recent (2006) IUR collection. The EPA IUR database contains information collected under the IUR for previous submission periods and was used to generate estimates of expected reports for the 2016 reporting cycle. In this reporting cycle, EPA expects 4,289 sites to submit 30,287 full reports and 648 partial reports for a total of 30,935 reports (98 percent and two percent of all reports, respectively).

	Total Industry Burden and Cost. EPA estimates the total industry burden for this reporting cycle, including both current baseline burden and the burden resulting from the final amendments, to be 2.57 million hours. Given that this data collection will occur every four years, EPA estimates the annual industry burden for each year to be 642,823 hours. As presented in Table 9, EPA estimates the total cost to industry would be $163 million, or an annual cost of $40.8 million.

Table 9: Estimated Annual Respondent Burden and Cost 
                                   Activity
                       Total Burden per Activity (hours)
                             Total Number of Units
                            Total Cost per Activity
                                    (2010$)
                                 Total Burden
                          per Reporting Cycle (hours)
                    Total Cost per Reporting Cycle (2010$)
                             Annual Burden (hours)
                              Annual Cost (2010$)
Compliance Determination
(per Site)
                                     2.50
                                  4,289 Sites
                                    $154.27
                                    10,723
                                   $661,665 
                                     2,681
                                   $165,416
Rule Familiarization (per Site)
                                     4.00
                                  4,289 Sites
                                    $262.90
                                    17,156
                                  $1,127,557 
                                     4,289
                                   $281,889
CDX Registration Activities (per Site)
                                     2.67
                                  4,289 Sites
                                   $172.05 
                                    11,437
                                   $737,926 
                                     2,859
                                   $184,481
Part I Preparation
(per Site)
                                     1.89
                                  4,289 Sites
                                   $124.68 
                                     8,098
                                   $534,756 
                                     2,024
                                   $133,689
Partial Report Preparation
(Part II, per Report)
                                     14.33
                              648 Partial Reports
                                   $913.92 
                                     9,287
                                   $592,221 
                                     2,322
                                   $148,055
Full Report Preparation
(Part II and Part III, per Report)
                                     79.96
                              30,287 Full Reports
                                   $4,931.84
                                   2,421,786
                                 $154,378,510 
                                    605,447
                                  $38,594,627
Recordkeeping
(per Report)
                                     3.00
                                30,935 Reports
                                   $166.60 
                                    92,805
                                  $5,153,851 
                                    23,201
                                  $1,288,463
Total Industry Burden and Cost 
                                   2,571,291
                                 $163,186,486 
                                    642,823
                                  $40,796,621
Note: Totals may not sum due to rounding 

	Average Burden and Cost per Site. As shown in Table 10, the Agency estimates the typical respondent burden for this information collection activity to be 600 hours. Given that a collection would occur once every four years under the final rule, the average annual burden for each cycle would be 150 hours. These burden estimates assume each site will submit an average of 7.06 full reports and 0.15 partial reports in future reporting cycles. 

Table 10: Average Burden per Site 

                                   Activity
                                 Burden Hours
                           Total Hours per Activity
                           Reports per Average Site
                     Total Burden (hours per average site)
                    Annual Burden (hours per average site)

                                  Managerial 
                                  Technical 
                                   Clerical 




Rule Familiarization. Compliance Determination, CDX Registration Activities and Part I Preparation 
(per site)
                                     3.95
                                     7.10
                                     0.00
                                     11.05
                                     1.00
                                     11.05
                                     2.76
Partial Report Preparation (Part II, per Report)
                                     3.68
                                     10.65
                                     0.00
                                     14.33
                                     0.15
                                     2.17
                                     0.54
Full Report Preparation (Part II and Part III, per Report)
                                     20.29
                                     59.67
                                     0.00
                                     79.96
                                     7.06
                                    564.65
                                      141
Recordkeeping (per Report)
                                     0.75
                                     1.50
                                     0.75
                                     3.00
                                     7.21
                                     21.64
                                     5.41
                                  Total Hours
                                      600
                                      150
Note: Totals may not calculate due to rounding of unit burden estimates

      Table 11 presents the average cost per site, by activity, for a CDR respondent. EPA estimates the average site will submit 7.06 full reports and 0.15 partial reports and incur a total cost of $38,048 during the reporting cycle ($9,512 annually) for Form U completion and submission. 
Table 11: Average Cost per Site 
                                   Activity
                                     Cost
                                    (2010$)
                            Total Cost per Activity
                             Reports per Average 
                                     Site
                      Total Cost (2010$ per average site)
                     Annual Cost (2010$ per average site)

                                  Managerial 
                                  Technical 
                                   Clerical 




Rule Familiarization. Compliance Determination, CDX Registration Activities and Part I Preparation 
(per site)
                                     $276
                                     $438
                                     $0.00
                                     $714
                                     1.00
                                     $714
                                     $178
Partial Report Preparation (Part II, per Report)
                                     $257
                                     $657
                                     $0.00
                                     $914
                                     0.15
                                     $138
                                    $34.52
Full Report Preparation (Part II and Part III, per Report)
                                    $1,415
                                    $3,682
                                     $0.00
                                    $5,097
                                     7.06
                                    $35,994
                                    $8,999
Recordkeeping
 (per Report)
                                    $52.30
                                    $92.56
                                    $21.74
                                     $167
                                     7.21
                                    $1,202
                                     $300
                                  Total Cost
                                    $38,048
                                    $9,512
Note: Totals may not calculate due to rounding of unit burden estimates


      Table 12 presents the annual burden hours for the ICR period (2012  - 2015), organized by information collection for CDR respondents. 

Table 12: Annual Information Collection Tally for ICR Reporting Period (2012- 2015)

                            Information Collection
                                    No. of 
                                  Respondents
                         No. of Responses / Respondent
                              Responses Subtotal
                       Annual Burden Hours per Response
                         Annual Burden Hours Subtotal
Compliance Determination
                                     4,289
                                       1
                                     4,289
                                     0.63
                                     2,681
Rule Familiarization
                                     4,289
                                       1
                                     4,289
                                     1.00
                                     4,289
CDX Registration Activities
                                     4,289
                                       1
                                     4,289
                                     0.67
                                     2,859
   oo    CDX Registration
                                     4,289
                                       1
                                     4,289
                                     0.23
                                      983
   oo    ESA
                                     4,289
                                       1
                                     4,289
                                     0.44
                                     1,876
Prepare Part I, Form U
                                     4,289
                                       1
                                     4,289
                                     0.47
                                     2,024
Prepare and Submit Report, and Maintain Records  -  Partial Report
                                     4,289
                                     0.15
                                      648
                                     4.33
                                     2,808
   oo Part II, Form U
                                     4,289
                                     0.15
                                      648
                                     3.58
                                     2,322
   oo Recordkeeping
                                     4,289
                                     0.15
                                      648
                                     0.75
                                      486
Prepare and Submit Report, and Maintain Records - Full Report
                                     4,289
                                     7.06
                                    30,287
                                     20.74
                                    628,162
   oo Parts II and III, Form U
                                     4,289
                                     7.06
                                    30,287
                                     19.99
                                    605,447
   oo Recordkeeping
                                     4,289
                                     7.06
                                    30,287
                                     0.75
                                    22,715
 Some burden estimate subtotals may not calculate due to rounding of unit burden estimates 

      Table 13 presents the total burden hours for the ICR period (2012  - 2015), organized by information collection, for CDR respondents. 

Table 13: Total Information Collection Tally for ICR Reporting Period (2012- 2015)

                            Information Collection
                                    No. of 
                                  Respondents
                         No. of Responses / Respondent
                              Responses Subtotal
                        Total Burden Hours per Response
                          Total Burden Hours Subtotal
Compliance Determination
                                     4,289
                                       1
                                     4,289
                                     1.88
                                     8,042
Rule Familiarization
                                     4,289
                                       1
                                     4,289
                                     3.00
                                    12,867
CDX Registration Activities
                                     4,289
                                       1
                                     4,289
                                     2.00
                                     8,578
   oo    CDX Registration
                                     4,289
                                       1
                                     4,289
                                     0.69
                                     2,949
   oo    ESA
                                     4,289
                                       1
                                     4,289
                                     1.31
                                     5,629
Prepare Part I, Form U
                                     4,289
                                       1
                                     4,289
                                     1.42
                                     6,073
Prepare and Submit Report, and Maintain Records  -  Partial Report
                                     4,289
                                     0.15
                                      648
                                     13.00
                                     8,423
   oo Part II, Form U
                                     4,289
                                     0.15
                                      648
                                     10.75
                                     6,965
   oo Recordkeeping
                                     4,289
                                     0.15
                                      648
                                     2.25
                                     1,458
Prepare and Submit Report, and Maintain Records - Full Report
                                     4,289
                                     7.06
                                    30,287
                                     62.22
                                   1,884,485
   oo Parts II and III, Form U
                                     4,289
                                     7.06
                                    30,287
                                     59.97
                                   1,816,340
   oo Recordkeeping
                                     4,289
                                     7.06
                                    30,287
                                     2.25
                                    68,146
 Some burden estimate subtotals may not calculate due to rounding of unit burden estimates 

      Agency Tally

	Table 14 presents the Agency costs associated with the CDR rule. EPA multiplied the costs per report by the total number of Parts I, II, and III to calculate the total burden and cost associated with the number of reports EPA expects to be submitted. The burden is 0.193 FTE and the cost is $42,881 for variable cost activities. The burden and cost of the fixed cost activities remains unchanged by the number of reports submitted; the total fixed burden is one FTE per reporting cycle and the cost is $262,701. The total Agency burden is 1.19 FTEs. The estimated total cost incurred by the Agency, $305,582, was calculated by summing the Agency staff and contractor activities. 

Table14: Total Cost and Burden of Agency Activities 

                                   Activity
                                     Staff
                                Form U Section
                        Total Burden per Activity (FTE)
                             Total Number of Units
                            Total Cost per Activity
                                    (2010$)
                              Total Burden (FTE)
                              Total Cost (2010$)
Variable Burdens and Costs
                  Document receipt, tracking, and data entry
                                       
                                  Contractor
                                    Part I
                                      N/A
                                  4,289 Sites
                                    $0.10 
                                      N/A
                                     $419 
                                       
                                       
                                    Part II
                                      N/A
                                30,935 Part IIs
                                    $0.26 
                                      N/A
                                    $7,930 
                                       
                                       
                                   Part III
                                      N/A
                               30,287 Part IIIs
                                    $0.30 
                                      N/A
                                    $9,430 
                            Quality Control of Data
                                 EPA Employee
                                (GS-12 Step 3)
                                    Part I
                                   0.0000048
                                  4,289 Sites
                                    $0.62 
                                     0.021
                                    $2,646 
                                       
                                       
                                    Part II
                                   0.0000026
                                30,935 Part IIs
                                    $0.34 
                                     0.081
                                   $10,258 
                                       
                                       
                                   Part III
                                   0.0000030
                               30,287 Part IIIs
                                    $0.39 
                                     0.092
                                   $12,198 
                                                 Total Variable Cost and Burden
                                     0.193
                                   $42,881 
Fixed Burdens and Costs
  Data Processing, Systems Development, and Contract Oversight and Management
                                 EPA Employee
                                (GS-13 Step 3)
                                      N/A
                                      N/A
                                      N/A
                                      N/A
                                     1.000
                                   $150,051
                   Maintaining and Operating Back Up Systems
                                  Contractor
                                      N/A
                                      N/A
                                      N/A
                                      N/A
                                      N/A
                                    $60,921
                  Printing and Publishing Forms and Materials
                                  Contractor
                                      N/A
                                      N/A
                                      N/A
                                      N/A
                                      N/A
                                    $5,691
                           Managing the TSCA Hotline
                                  Contractor
                                      N/A
                                      N/A
                                      N/A
                                      N/A
                                      N/A
                                    $46,037
                                                    Total Fixed Cost and Burden
                                       1
                                   $262,701
Total Agency Cost and Burden
                                     1.19
                                   $305,582

	6(e)	Reasons for Change in Burden

      There is a decrease of 16,920 hours (from 659,743 hours to 642,823 hours) in the total estimated respondent burden compared with that identified in the ICR currently approved by OMB. This decrease reflects changes resulting from updates to the number of affected sites and the number of responses per site, and adjusting burden estimates to capture burden reductions resulting from experiences with past reporting, as summarized in Table 15. More details on the changes are outlined below. The decrease is an adjustment.

Changes

      The previous currently approved ICR (EPA ICR No. 1884.05) covered two reporting cycles; 2012 and 2016, and used a weighted average to estimate the number of sites and the number reports per site. The current request covers only the 2016 reporting cycle and therefore uses only the number of sites and reports per site for 2016, as derived in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a).
      
      Because the previous ICR covered two reporting cycles, a weighted average of first-year burden estimates and future-year burden estimates was used. However, because this ICR only covers the 2016 cycle, only the lower future-year burden estimates as derived in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a) were used. EPA expects the majority of sites to be familiar with CDR reporting requirements and have some data readily available from previous reporting, thus reducing the per-report burden of reporting.
      
      All costs were inflated from 2008$ to 2010$, which slightly increased the costs associated with the rule. EPA estimates that approximately $1.31 million of the total cost increase of $11.66 million is attributed to inflation.
      
Table 15: Total Estimate of Annual Burden Hours and Annualized Cost Comparisons

                                       
                              Annual Burden Hours
                                  Annual Cost
Current OMB Inventory
                                    659,743
                                  $40,254,393
Change in Burden due to Adjustments
                                    -16,920
                                   $542,228
Change in Burden due to Program Changes
                                       0
                                      $0
Total Change in Burden
                                    -16,920
                                   $542,228
Total Burden
                                    642,823
                                  $40,796,621

	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 about 40.1 hours per response. Burden is defined in 5 CFR 1320.3(b). 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 public docket for this ICR under Docket ID No. EPA-HQ-OPPT-2011-0709. 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 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-2011-0709 and OMB control number 2070-0162 in any correspondence.




Sources
   
BLS 2009. U.S. Bureau of Labor Statistics. Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006  -  December 2008. (March12, 2009) http://www.bls.gov/ncs/ect/sp/ecsuphst.pdf.

EPA, 2002a. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA-HQ-OPPT-2002-0054-0260). August 2002.

EPA, 2002b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Wage Rates for Economic Analysis of the Toxics Release Inventory Program. June 10, 2002.

EPA, 2005. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Economic Analysis of IUR Modifications Final Rule (EPA-HQ OPPT 2004-0106-0055). July 2005. 

EPA, 2006. US EPA, Office of Pollution Prevention and Toxics, Instructions for Reporting for the 2006 Partial Updating of the TSCA Chemical Inventory Database. Nov. 2006. Available at http://www.epa.gov/iur/pubs/2006_inst_tsca_cheminv.pdf.

EPA, 2007. U.S. EPA, Office of Environmental Information. A Business Case Analysis of EPA's Central Data Exchange. March, 2007. 
EPA, 2008a. ICR No. 1884.04. [Information Collection Request for] Partial Update of the TSCA Section 8(b) Inventory Data Base, Production and Site Report Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act. September 5, 2008. EPA-HQ-OPPT-2008-0504-0002.

EPA, 2008b. U.S. EPA, Office of Pollution Prevention and Toxics, Information Management Division, 2006 IUR Database Statistics for IUR Modifications Rule. Washington, DC. December 17, 2008. 

EPA, 2009a. U.S. EPA, Office of Pollution Prevention and Toxics. TSCA Section 4 Federal Register Enforceable Consent Agreements. http://www.epa.gov/oppt/chemtest/pubs/4eca.html. Washington, DC. Updated October 1, 2009.
EPA, 2009b. U.S. EPA, Office of Pollution Prevention and Toxics, Sunset Dates of Chemicals Subject to Final TSCA Section 4 and Related 12(b) Actions, Modified on September 1, 2009. http://www.epa.gov/oppt/chemtest/pubs/sunset.html. Washington, DC. Updated September 1, 2009.
EPA, 2010. TSCA Section 5 Premanufacture and Significant New Use Notification Electronic Reporting; Revisions to Notification Regulations; Final rule. Federal Register (75 FR 773-790), January 6, 2010) 

EPA, 2011a. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule. June, 2011. EPA-HQ-OPPT-2009-0817.

EPA, 2011b. ICR No. 1884.05. [Information Collection Request for] Partial Update of the TSCA Section 8(b) Inventory Data Base, Production and Site Report Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act. June, 2011. EPA-HQ-OPPT-2009-0817.

OPM, 2008. Office of Personnel Management, Salary Table 2008-DCB, Washington Baltimore-Northern Virginia, DC-MD-PA-VA-WV. Accessed from http://www.opm.gov/oca/08tables/pdf/DCB.pdf.
                    ATTACHMENTS TO THE SUPPORTING STATEMENT
                                       
These attachments are available in the electronic docket at www.regulations.gov, under Docket ID No. EPA-HQ-OPPT-2011-0709.  

Attachment 1		Toxic Substances Control Act Section 8(b) (15 USC 2607(b))

Attachment 2		40 CFR 711 - TSCA Chemical Data Reporting Requirements

Attachment 3		EPA Form 7740-8, IUR Form U



