              Supporting Statement for a Request for OMB Review 
                       under the Paperwork Reduction Act


 IDENTIFICATION OF THE INFORMATION COLLECTION

	1(a)	Title and Number of the Information Collection

      Title:	Use of Mercury and Mercury Compounds in Products and Processes
	
      EPA ICR No. 2532.01	OMB Control No.: 2070-NEW

      1(b)	Short Characterization/Abstract

      The U.S. Environmental Protection Agency's (EPA's) Office of Chemical Safety and Pollution Prevention is working to further reduce the use of mercury and mercury compounds in products and certain manufacturing processes to prevent future releases of mercury to the environment. After negotiating and joining a global agreement called the Minamata Convention on Mercury (Minamata Convention, see Attachment 2), EPA continues to pursue measures to reduce the use of mercury in various media. EPA investigated current information on the use of mercury and mercury compounds in products and certain manufacturing processes in the United States and found significant data gaps that prevent the Agency from taking systematic, strategic, and effective actions to reduce the use of mercury and mercury compounds in order to prevent potential releases to the environment.

      To close such data gaps, EPA will collect information from persons who process mercury or mercury compounds for use in the production of mercury-added products, import mercury for use in the production of mercury-added products, import mercury-added products, and/or export mercury-added products. In addition, EPA will request information from persons who process mercury or mercury compounds for use in certain industrial processes. EPA is particularly interested in the amount of mercury or mercury compounds used in mercury-added products as a whole and among various categories of products, including mercury or mercury compounds that are added during domestic manufacture, as well as contained in imported and exported products.

      Initially, this will be a one-time information collection request (ICR), but EPA may request subsequent renewals, as necessary. EPA first will invite companies that manufacture, import, or export a product (or products) containing mercury or mercury compounds or companies that use mercury or mercury compounds in a manufacturing process (or processes) to voluntarily submit responses to a questionnaire (see Attachment 4) for a period of 60 days after the proposed ICR is approved by the Office of Management and Budget. Thereafter, EPA will issue more formal measures under section 11 of the Toxic Substances Control Act (TSCA) to obtain the information. For all information received after the ICR is in place, the Agency anticipates some form of follow-up with respondents (e.g., emails or telephone calls) to clarify information received from respondents. Examples of such follow-up correspondence include, but are not limited to questions regarding reported amounts of mercury or mercury compounds that deviate from currently observed trends, disproportionately large or small volumes reported, or other discrepancies in reported information (e.g., reported volumes in sections of the questionnaire expected to match or be consistent appear to be incorrect per human error). In other instances, EPA anticipates that respondents might reach out to the Agency prior to submitting information for assistance in interpreting questions or in preparation of responses.

      EPA anticipates that the information collection activity will involve approximately 250 private entities that either manufacture, import, or export mercury-added products, or use mercury or mercury compounds in manufacturing processes, although the number of entities may be as high as 646. Respondents will answer set of questions about the amounts of mercury or mercury compounds the entities use and in which products. The years of interest are 2010, 2013, and 2016.

      EPA will use the collected information to determine if and what type of actions, including voluntary and/or mandatory measures, are needed to reduce the use of mercury or mercury compounds. The Agency will also use such information to prioritize where and how measures are applied in order to help prevent potential risks of mercury exposure to human health and the environment. In addition, this information also will be used to facilitate compliance with obligations of the United States under the Minamata Convention to continue to reduce the use of mercury in products and processes, and to report on actions taken to do so.


2.	NEED FOR AND USE OF THE COLLECTION

      2(a)	Need/Authority for the Collection

      Background

      Mercury is known to cause adverse health effects on humans and wildlife. Domestically, the most prevalent human and wildlife exposure to mercury results from ingesting fish contaminated with methylmercury, which forms when mercury in the air is deposited to water. Methylmercury is a highly toxic substance that affects nervous systems, particularly during an organism's development. The federal government and all fifty states have issued advisories concerning ingestion of mercury in fish.

      In addition to methylmercury, exposure to mercury can also pose health risks. Mercury primarily causes health effects when it is inhaled as a vapor that can be absorbed through the lungs. These exposures can occur when mercury is spilled or products that contain mercury break, resulting in release of mercury to the air, particularly in warm or poorly-ventilated indoor spaces. 
      Mercury and mercury compounds are used in the manufacture of mercury-added products and certain manufacturing processes. The typical lifecycle of products includes manufacture, distribution in commerce, use, disposal, or recycling. At any point in the lifecycle, there is potential for mercury to be released.

      Trends of Mercury Use in Products

      Over the past three decades, the United States has seen a strong downward trend in the domestic use of mercury in products. Nonetheless, more than 50 tons of mercury continues to be used or imported every year in products, many of which have cost-effective, non-mercury substitutes. In 2015, to collect information on domestic mercury supply and trade, the Agency collected domestic sales information for the years 2010 and 2013 from five companies identified as the primary recyclers and distributors of mercury in the United States. Comparing totals for mercury in products sold and the amount of bulk mercury sold in the United States in 2013 revealed a significant gap. EPA believes mercury may be used in manufacturing processes as a reactant or formulation component, including the production of polyurethane elastomers, which may not be reflected in the amount of mercury reported as sold in products. In addition, EPA is interested in finding out the amount of mercury in products manufactured in the United States and sold overseas, which would not be reported in domestic sales. The Agency is committed to continue working to explain such data gaps and to reduce the use of mercury in products and processes, where feasible.

   Minamata Convention on Mercury and EPA Strategy

   In 2013, the United States joined the Minamata Convention, an international environmental agreement with multiple obligations to governments aimed at reducing the production and use of mercury worldwide. Articles 4 and 5 of the Minamata Convention contain required actions by all Parties related to mercury-added products and manufacturing processes in which mercury or mercury compounds are used, including, but not limited to:
   
 Implement measures and strategies to reduce or prohibit the use of mercury in listed products;
 Report to the Conference of Parties to the Convention on the measures or strategies implemented, including a quantification of the reductions achieved;
 Consider additional measures to achieve further reductions of listed products;
 Take measures to prevent the listed products from being incorporated into assembled products;
 Discourage the manufacture and sale of mercury‑added products not covered by any known use of mercury-added products prior to the date of entry into force of the Convention; 
 Take appropriate measures to restrict or prohibit the use of mercury or mercury compounds in manufacturing processes;
 Collect and maintain information on processes that use mercury or mercury compounds and their alternatives; and
 Discourage the development of any facility using any other manufacturing process in which mercury or mercury compounds are intentionally used that did not exist prior to the date of entry into force of the Convention.

      In order to carry out its work on mercury-added products and manufacturing processes, and to facilitate compliance with the U.S. obligations under the Minamata Convention, EPA wrote and published a plan called the "EPA Strategy to Address Mercury‐Containing Products" (EPA Strategy; see Attachment 3). The EPA Strategy is divided into five phases, the first of which is to update EPA's information on mercury-added products and manufacturing processes. In later phases, EPA will use the improved information to inform voluntary or regulatory actions, as appropriate, to reduce the unnecessary use of mercury or mercury compounds.

      Purpose of the ICR

      The purpose of this ICR is to enable EPA to obtain the information necessary to achieve its goal to further reduce the use of mercury and mercury compounds in products and certain manufacturing processes in order to prevent future releases to the environment, as well as assist the United States in its implementation of its obligations under the Minamata Convention. EPA seeks to enhance its current information on how much mercury is used and in which products, and whether those products are manufactured domestically, imported, or exported.

      Overview of Existing Information on Mercury-added Products

      EPA has investigated federal and state reports and databases, among other sources, in order to accumulate as complete a collection of available information on mercury products as possible. The Agency found that its current collection lacks the specificity and level of detail that would allow EPA to target its use reduction efforts efficiently for both the government and private sectors. Internet research resulted in mostly anecdotal information. Proprietary databases and that of the U.S. Census Bureau do not distinguish between mercury products and non-mercury products. EPA's Chemical Data Reporting (CDR) rule collects quantity information on chemical substances manufactured or processed in the United States, but not on individual or categories of products containing those substances. Although the CDR rule asks manufacturers and importers for information on end-uses of their chemical substances, the required information is too general to be useful to implement the mercury-added products strategy. The EPA Toxics Release Inventory (TRI) program requires manufacturers and processors to report whether mercury is used in, among other things, manufacturing or processing, as well as whether it is used in an article, but not the amount of mercury or which articles it is used in.

      States collect useful information on the amount of mercury in mercury-added products sold in the United States. Laws in eight states (Connecticut, Louisiana, Maine, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont) require manufacturers and importers to identify the mercury products they sell and the volume of mercury in them. The volume information is reported at a national level, although only companies selling mercury products within those eight states need to report. These data are reported online in the Interstate Mercury Education and Reduction Clearinghouse (IMERC), which is managed by the Northeast Waste Management Officials' Association (NEWMOA). States also collect information on mercury in products as part of separate programs. For example, EPA reviewed data reported under Washington's Children's Safe Product Act, which requires manufacturers of children's products sold in Washington to report if their product contains a Chemical of High Concern to Children, including mercury. Most states, however, do not collect information about mercury products.

   Limitations on Existing Information

   In the past, the IMERC database has been a key source of national data on mercury used in products. The database houses information that states require the private sector to report to them on a triennial basis. The database provides a detailed picture of some aspects of the mercury product market. However, as reported by IMERC, there are limitations of the use of such data for EPA's implementation of the Minamata Convention and targeting use reduction. For example:
      
 The data may underestimate the amount of mercury sold in products in the United States. The manufacturers, importers, and distributors in eight "IMERC Notification" states must report on mercury-added products sold in the United States, so the information is national in scale. However, if a mercury product is only sold in states other than the IMERC Notification states, then the product manufacturer, importer, or distributor is not required to report to IMERC. In addition, IMERC no longer collects data on a significant category of mercury-added products, specifically switches and relays, because these products are banned from sale in each of the eight IMERC Notification States.
   
 In other instances, the data may overestimate the total amount of mercury sold in products. In some cases, manufacturers supplied data for earlier reporting years, but are out of compliance for one or more years. Rather than assuming that this non-reporting is a result of a company having phased-out its mercury-added product, IMERC takes a more conservative approach and assumes that the mercury total for non-reporters for the current reporting period is the same as its most recently reported year.
      
 IMERC does not cover mercury compounds manufactured or imported for use in manufacturing processes or mercury-added products, with the exception of formulated products. And companies report the amount of mercury in products they sell in the United States, but not the amount in products they manufacture, import, or export.
   
      Such shortcomings also were noted in 2013 by the Quicksilver Caucus, a coalition of state environmental association leaders dedicated to reducing mercury in the environment.

      In sum, without the ICR information, EPA's future ability to analyze the use of mercury and mercury compounds in products and certain manufacturing processes in the United States would need to rely on incomplete databases, assumptions, professional judgment, and anecdotal information.

   Priority Data to be Collected and Statutory Authorities

   Using the available sources described above, EPA has compiled estimates of the amount of mercury used by some manufacturers and importers in some products. EPA does not need estimates for each individual mercury-added product or manufacturing process, given that some products are almost completely phased out of the U.S. market and others are essential products without adequate substitutes (e.g., replacement components in larger equipment). However, in order to better implement the Minamata Convention and fulfill its mercury products strategy to reduce non-essential mercury uses, the Agency needs reliable estimates of:
   
 The amount of mercury used in:
 Batteries
 Cosmetics (including skin lightening soaps and creams)
 Dental amalgam
 Formulated products (e.g., commercial chemical products, including catalysts, reactants, reagents, preservatives)
 Lighting, lamps, bulbs (including neon lighting and backlighting displays)
 Pesticides, biocides, and topical antiseptics (including paint)
 Pumps
 Measuring instruments (e.g., barometers, thermometers)
 Switches, relays, sensors, valves (including thermostats)
 Miscellaneous mercury-added products
 Products derived from the use of mercury or mercury compounds in a manufacturing process
            
 The amount of mercury and mercury compounds used in manufacturing processes; and
 
 The amount of mercury imported and exported in mercury-added products.
      EPA's authority for this information collection is TSCA sections 2(b)(1) and 11(c) (see Attachment 1). More detail on information the Agency intends to collect is described in Section 4(b) of this supporting statement.

	2(b)	Practical Utility/Users of the Data

      EPA will use the collected information to fill gaps in existing data, enabling the Agency to more accurately estimate the amount of mercury used in manufactured, imported, and exported products in priority product categories. The Agency will use the results to decide whether actions are necessary to reduce specific mercury uses and to plan voluntary and regulatory action to achieve its goal to further reduce mercury use in products and certain processes in order to prevent future releases to the environment. The information will also assist the United States in its sustained implementation of its obligations under the Minamata Convention. For example, the Agency intends to use the results to determine whether and how much the United States continues to manufacture products that are not essential (i.e., those that have already been successfully phased out in some states and/or readily can be replaced by non-mercury substitutes).

Similarly, EPA is interested in determining whether certain mercury-added products are manufactured solely for replacement parts or for uses for civil protection and military purposes, as well as research, calibration of instrumentation, or reference standards. The Agency believes that the totality of such information will not only lead to a more complete understanding of if and how mercury is currently used in mercury-added products and manufacturing processes, but also the degree to which such uses may be considered essential. Based on such analysis, EPA would be able to opt for voluntary or regulatory options best suited for a particular product or category of products, as well as the companies that manufacture, sell, or use such products.

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

	3(a)	Non-Duplication

      To the best of EPA's knowledge, the data to be collected through this questionnaire are not publically available. As described in Section 2(a), EPA has devoted significant resources to investigate available data on mercury use, including federal and state reports and databases.

	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

	Initially, this will be a one-time information collection. EPA may collect the information in multiple years if it should prove necessary and would renew this ICR accordingly.

	3(e)	General Guidelines

      This ICR complies with the guidelines in 5 CFR 1320.5(d)(2). 

	3(f)	Confidentiality
      
      The questionnaire will contain information for respondents on how to make a claim to EPA that all or part of their information is Confidential Business Information.  

      3(g)   Sensitive Questions

      Not applicable. The information requested is not sensitive in nature.


4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

      Based on the described investigation of available data, EPA determined that the best way to acquire the needed information is to collect it directly from the entities that use mercury or mercury compounds to manufacture mercury-added products or in manufacturing processes, or that import or export mercury-added products. The existing databases were useful in helping to identify product categories, individual products, and NAICS codes to include in the information collection to ensure that the scope is sufficient without being overly broad.

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

      Respondents affected by this collection activity primarily include those businesses that fall under the NAICS Codes in the table below.

                      Primary NAICS Codes and Definitions
                                     Code
                                           Definition
                   Primary Product Manufacturing Industries
                                    314110
Carpet and rug mills
                                    322121
Paper (except newsprint) mills
                                    322130
Paperboard mills
                                    324122
Asphalt shingle and coating materials manufacturing
                                    325180
Other basic inorganic chemical manufacturing
                                    325199
All other basic organic chemical manufacturing
                                    325211
Plastics material and resin manufacturing
                                    325312
Phosphatic fertilizer manufacturing
                                    325320
Pesticide and other agricultural chemical manufacturing
                                    325411
Medicinal and botanical manufacturing
                                    325412
Pharmaceutical preparation manufacturing
                                    325413
In-vitro diagnostic substance manufacturing
                                    325414
Biological product (except diagnostic) manufacturing
                                    325510
Paint and coating manufacturing
                                    325520
Adhesive manufacturing
                                    325991
Custom compounding of purchased resins
                                    325992
Photographic film, paper, plate, and chemical manufacturing
                                    325998
All other miscellaneous chemical product and preparation manufacturing
                                    326113
Unlaminated plastics film and sheet (except packaging) manufacturing
                                    326150
Urethane and other foam product (except polystyrene) manufacturing
                                    326199
All other plastics product manufacturing
                                    326299
All other rubber product manufacturing
                                    327215
Glass product manufacturing made of purchased glass
                                    332911
Industrial valve manufacturing
                                    332993
Ammunition except small arms manufacturing
                                    332994
Small arms, ordnance, and ordnance accessories manufacturing
                                    334413
Semiconductor and related device manufacturing
                                    334419
Other electronic component manufacturing
                                    334511
Search, detection, navigation, guidance, aeronautical, and nautical system and instrument manufacturing
                                    334512
Automatic environmental control manufacturing for residential, commercial, and appliance use
                                    334513
Instruments and related products manufacturing for measuring, displaying, and controlling industrial process variables
                                    334515
Instrument manufacturing for measuring and testing electricity and electrical signals
                                    334516
Analytical laboratory instrument manufacturing
                                    334519
Other measuring and controlling device manufacturing
                                    335110
Electric lamp bulb and part manufacturing
                                    335122
Commercial, industrial, and institutional electric lighting fixture manufacturing
                                    335314
Relay and industrial control manufacturing
                                    335912
Primary battery manufacturing
                                    335931
Current-carrying wiring device manufacturing
                                    335999
All other miscellaneous electrical equipment and component manufacturing
                                    336413
Other aircraft parts and auxiliary equipment manufacturing
                                    336612
Boat building
                                    339914
Costume jewelry and novelty manufacturing
                                    339950
Sign manufacturing
                                    541712
Research and development in the physical, engineering, and life sciences (except biotechnology)
                                    928110
National security
                  Secondary Product Manufacturing Industries
                                    333294
Food product machinery manufacturing
                                    333313
Office machinery manufacturing
                                    333319
Other commercial and service industry machinery manufacturing
                                    333414
Heating equipment (except warm air furnaces) manufacturing
                                    333415
Air-conditioning and warm air heating equipment and commercial and industrial refrigeration equipment manufacturing
                                    334412
Bare printed circuit board manufacturing
                                    334413
Semiconductor and related device manufacturing
                                    334510
Electromedical and electrotherapeutic apparatus manufacturing
                                    334514
Totalizing fluid meter and counting device manufacturing
                                    334515
Instrument manufacturing for measuring and testing electricity and electrical signals
                                    334518
Watch, clock, and part manufacturing
                                    334519
Other measuring and controlling device manufacturing
                                    335129
Other lighting equipment manufacturing
                                    335211
Electric house wares and household fan manufacturing
                                    335212
Household vacuum cleaner manufacturing
                                    335221
Household cooking appliance manufacturing
                                    335222
Household refrigerator and home freezer manufacturing
                                    335224
Household laundry equipment manufacturing
                                    335228
Other major household appliance manufacturing
                                    335313
Switchgear and switchboard apparatus manufacturing
                                    336112
Light truck and utility vehicle manufacturing
                                    336120
Heavy duty truck manufacturing
                                    336213
Motor home manufacturing
                                    336214
Travel trailer and camper manufacturing
                                    339112
Surgical and medical instrument manufacturing
                                    339932
Game, toy, and children's vehicle manufacturing
                                    424690
Other chemical and allied products merchant wholesalers

      4(b) 	Information Requested

 Data items

      The questionnaire "Collection of Information on Use of Mercury and Mercury Compounds in Products and Processes" is Attachment 4. Generally, the questionnaire seeks to collect information on whether a company manufactures, imports, or exports products containing mercury or mercury compounds, or uses mercury or mercury compounds in a manufacturing process. For ease of responding, the questionnaire is divided into three primary sections requiring varying degrees of detail. However, the sections are divided such that a respondent may not be required to proceed past the first section or may not need to answer all of the questions in the two subsequent sections. Where feasible, questions are posed to provide boxes to check off instead of written responses and so that respondents are able to skip further questions within a section or skip sections altogether.

      Section 1. The first section poses two "yes/no" questions for the years 2010, 2013, and/or 2016: "Did your company manufacture, import, or export products containing mercury or mercury compounds;" and "Did your company use mercury or mercury compounds in a manufacturing process?" These inquiries serve as the threshold certifications that a company currently manufactures, imports, or exports products with mercury or uses mercury or mercury compounds in a manufacturing process of interest to EPA.

      Respondents answering "yes" to one of the questions would proceed to the second section. Two "no" answers would complete the questionnaire. However, the Agency will also ask respondents providing two "no" answers, if possible, to report the calendar year when their use of mercury or mercury compounds ceased.

      Section 2. The second section will present a table of eleven product and process categories. Respondents are only required to mark a box or boxes for general categories corresponding to products or processes for which a respondent's company manufactured, imported, or exported a product or products in the years 2010, 2013, and/or 2016. If a respondent cannot identify a product or process among the general categories, he/she is instructed to check a miscellaneous category. The respondent is then directed to specific subsections of Section 3 per marked general category. This inquiry serves to determine the kinds of products particular companies manufactured, imported, or exported. Based on experience with the domestic mercury market, the Agency believes that a respondent will likely only check one general category. In addition, this section provides respondents with check boxes that correspond to exclusions from reporting under the Minamata Convention where a product or process: (1) is essential for civil protection or military uses; (2) is only used for research, calibration of instruments, as a reference standard, or as a vaccine; or (3) contains only trace contaminants of mercury.

      Section 3. The third section poses questions to elicit information for each category a respondent checked in Section 2.There are approximately five multi-part questions per category, which are designed to be nearly identical. However, they are structured so that subsequent parts of a question or an entire question could be skipped. For each category, the questions are limited to the years 2010, 2013, and/or 2016 and the respondents are allowed to use either metric or U.S. customary units. There is also a space allowed for respondents to provide additional comments should they so choose. The five multi-part questions include:

       Asking if a respondent's company manufactured a product that contained mercury or mercury compounds. If the respondent answers "no," then he/she skips to the fourth question. If the respondent answers "yes," then he/she is asked to report the total amount of mercury or mercury compounds per product  A list of specific varieties of products or processes, as well as an "other" option is presented to assist respondents.
       Asking if a respondent's company purchases in the United States mercury or mercury compounds to be used in the production a product. If the respondent answers "no," then he/she skips to the fourth question. If the respondent answers "yes," then he/she is asked to report the total amount of mercury or mercury compounds purchased in the United States. This question does not ask for amounts reported to be broken out among specific varieties of products or processes.
       Asking if a respondent's company imported mercury or mercury compounds to be used in the production of a specific product. If the respondent answers "no," then he/she skips to the fourth question. If the respondent answers "yes," then he/she is asked to report the total amount of mercury or mercury compounds imported.
       Asking if a respondent's company imported a product containing mercury or mercury compounds. If the respondent answers "no," then he/she skips to the fifth question. If the respondent answers "yes," then he/she is asked to report the total amount of mercury or mercury compounds per product. A list of specific varieties of products or processes, as well as an "other" option is presented to assist respondents.
       Asking if a respondent's company exported a product containing mercury or mercury compounds. If the respondent answers "no," then he/she may choose to provide any additional comments and then skips to the next category for which the respondent checked in Section 2. If the respondent answers "yes," then he/she is asked to report the amount of mercury or mercury compounds per product. A list of specific varieties of products or processes, as well as an "other" option is presented to assist respondents.
      Certain subsections will contain additional questions that correspond to provisions of the Minamata Convention, such as whether a specific product exceeds mercury or mercury compound content limits. These types of questions are posed as "yes/no" questions. Such inquiries are intended to inform more specific reporting requirements and, in some cases, exemptions from reporting obligations under the Minamata Convention.

      EPA welcomes public comment on how to enhance the quality, utility, and clarity of the information to be collected. In particular, EPA seeks comment on these aspects of the questionnaire:

       Are there additional products or product categories that should be included in the questionnaire?
       Are there additional products or product categories that should be eliminated from the questionnaire?
       Should the questionnaire ask respondents to identify which products are intended solely as replacement parts?

 	Respondent Activities
      Individuals who are contacted to participate in this information collection activity could potentially perform each of the following tasks:

       Read the Federal Register notice or information collection letter;
       Read the questionnaire and instructions;
       Gather, organize, and compile records;
       Respond to questions; and
       Email or mail the completed questionnaire to EPA.

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

	5(a)	Agency Activities

      The Agency will conduct the following activities to complete the information collection:
   
 Request responses to the questionnaire via second Federal Register notice, to be provided by respondents after the ICR is approved;
       Send letters/formal measures to non-respondents;
       Follow up with non-responders, as needed;
       Review data;
       Follow up with respondents, if clarifications are needed; and
       Report findings.
	5(b) 	Collection Methodology and Management

      The Agency will initially publish and request comment on the efficacy of the questionnaire in the first Federal Register notice for the proposed ICR. After revisions, as appropriate, EPA in the second Federal Register notice for the proposed ICR will invite appropriate members of the general public to voluntarily provide information as set forth in a questionnaire for a period of 60 days after the proposed ICR is approved. Thereafter, EPA will issue subpoenas containing the same questionnaire under TSCA section 11 to obtain the information. For all information received after the ICR is in place, the Agency anticipates that some form of follow-up with respondents (e.g., emails or telephone calls), to clarify information received from respondents or to assist respondent in the preparation of responses.

      EPA will then compile the responses to produce an understanding of mercury use across product categories, a list of individual products containing the most mercury, and other tools to help the Agency identify the best opportunities for use reduction and to construct reports to the Conference of Parties of the Minamata Convention.

	5(c)	Small Entity Flexibility

      The majority of respondents will be small entities. The instrument has been developed to minimize the burden on all respondents while obtaining sufficient and accurate information.

	5(d)	Collection Schedule

      Exhibit 5.1 provides the schedule of the various tasks involved in conducting the proposed information collection activity. As shown in the schedule, data collection would start within one week of OMB approval of the ICR and would end 14 weeks later.


Exhibit 5.1: Information Collection Schedule





Task


  Week (from receipt of OMB approval)




 1
 2
 3
 4
 5
 6
 7
 8
 9
10
 11
 12
 13
 14
Send subpoenas to respondents requiring completion of the questionnaire














30 days (4 weeks) for respondents to respond














Preliminary data review 














Follow up with non-responders as needed














Follow up with respondents if clarifications are needed 














Compile responses
















6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

	This section presents the burden and cost estimates incurred by all potentially affected entities as a result of the data collection. All costs are presented in 2014 dollars. The proposed information collection requires reporting at the company level. EPA estimates that up to 646 companies in the United States manufacture, import, or export mercury-added products, or use mercury or mercury compounds in manufacturing processes. The following burden and cost estimate is based on this number; however, the Agency initially intends to narrow the scope of this ICR to up to 250 facilities. While the EPA expects to require information from approximately 250 entities, the Agency may need to request submissions from as many as 646 respondents. While the EPA expects to require information from approximately 250 entities, it may need to request submittals from as many as 646. The requested burden for this collection represents the burden associated with the maximum number of respondents, i.e., 646. All respondents will respond to Section 1 of this information collection; in addition, companies that use mercury or mercury compounds for the purposes described in Section 1 will respond to one or more categories in Section 2 and sets of questions in Sections 3 responding to one or more sections of the questionnaire.

      Respondents are comprised of firms that are currently required under state law to report data to IMERC and firms that are not required to do so. EPA believes that firms that have reported data to IMERC will have a reduced burden compared with firms that have not submitted IMERC data, because they keep, manage, and report data on their products that contain mercury.

      6(a) 	Estimating Respondent Burden

      This section details the estimated burden to respondents participating in this ICR. For purposes of the ICR, a company that processes mercury or mercury compounds for use in the production of mercury-added products, imports mercury for use in the production of mercury-added products, imports mercury-added products, exports mercury-added products, and/or processes mercury or mercury compounds for use in certain industrial processes is equivalent to one respondent. The questionnaire contains 13 separate sections; Section 1 contains company information and yes/no screening questions which determine whether the company should complete the rest of the questionnaire, Section 2 contains check boxes to indicate the types of products manufactured, imported, or exported by the company, and Sections 3 through 13 ask specific questions about each product type.

Unit Burden Estimates

Section 1

      Section 1 of the form asks the respondent for basic company information as well as initial questions to indicate if a company manufactured, imported, or exported any products containing mercury or if mercury was used in a manufacturing process in the years 2010, 2013, and/or 2016.

      Company Information

      The first part of Section 1 requires the respondent to provide their company name, address, the name(s) and title(s) of the responding and certifying official(s), and the contact information for the certifying official. EPA assumes providing this information will take approximately 6 minutes, based on data in the 2011 Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule. EPA expects this burden to be identical regardless of a particular respondent's experience with IMERC reporting.

   Table 1: Hourly Unit Burden for Providing Company and Contact Information
                                   Questions
                              Unit Burden (Hours)
                                       
                                   Clerical
                                   Technical
                                  Managerial
                                     Total
               Responders that Have not Submitted Data to IMERC
Company Information
                                     0.04
                                     0.04
                                     0.02
                                     0.10
                             IMERC Data Submitters
Company Information
                                     0.04
                                     0.04
                                     0.02
                                     0.10
Source(s): U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule. June 30, 2011.   Burden for submitters provide company and technical contact information. 

      Questions 1(a) and 1(b)

      The second part of Section 1 asks respondents to indicate whether they manufactured, imported, or exported any products containing mercury or whether mercury was used in a manufacturing process in the years 2010, 2013, and/or 2016. EPA estimated the burden for reviewing their records to determine this information is 2.5 hours.

Table 2: Hourly Unit Burden for Determining Whether the Respondent Manufactures, Imports, or Exports Products Containing Mercury or uses Mercury in a Manufacturing Process
                                   Questions
                              Unit Burden (Hours)
                                       
                                   Clerical
                                   Technical
                                  Managerial
                                     Total
               Responders that Have not Submitted Data to IMERC
                                 1(a) and 1(b)
                                     0.00
                                     2.50
                                     0.00
                                     2.50
                             IMERC Data Submitters
                                 1(a) and 1(b)
                                     0.00
                                     2.50
                                     0.00
                                     2.50
Source(s): U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule. June 30, 2011. Burden for compliance determination.

      Total Industry Unit Burden Estimates for Section 1

      Table 3 presents the total unit burden estimates for all submitters to complete Section 1 of the document. To calculate the total burden, the estimates derived above are weighted by the percentage of respondents completing a given section, that are expected to respond to a given question and the number of responses per respondent, in this case all respondents completing Section 1 are expected to respond to all questions in Section 1, with one response per respondent.

       Table 3: Total Burden to Complete Section One for All Submitters
                                   Question
                             Total per Unit Burden
                                    (Hours)
Percentage of Respondents who Complete the Section that Respond to the Question
                           Responses per Respondent
                                 Total Burden
                                    (Hours)
Company Information
                                     0.10
                                     100%
                                       1
                                     0.10
1(a) and 1(b)
                                     2.50
                                     100%
                                       1
                                     2.50
                                     Total
                                     2.60

Section 2 

      Section 2 of the form requires respondents to indicate the mercury added-product(s) they manufacture, import, or export and whether their products are used within certain end use categories, such as military products or only for research and development purposes. EPA believes that the burden to check the box indicating the product category is negligible, and the burden to indicate certain end use categories is approximately 1.23 hours per respondent for firms that have not submitted IMERC data and 0.98 hours per respondent for IMERC data submitters, based on the burden to indicate consumer/commercial product categories in IUR reporting. See Table 4. EPA believes that 100 percent of respondents will complete this section.

          Table 4: Hourly Unit Burden for Indicating Certain End Uses
                                   Questions
                              Unit Burden (Hours)
                                       
                                   Clerical
                                   Technical
                                  Managerial
                                     Total
               Responders that Have not Submitted Data to IMERC
Information on Certain Uses 
                                     0.14
                                     0.84
                                     0.25
                                     1.23
                             IMERC Data Submitters
Information on Certain Uses
                                     0.12
                                     0.75
                                     0.20
                                     0.98
Source(s): US Environmental Protection Agency, Office of Pollution Prevention and Toxics. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule. June 30, 2011. Burden for submitters provide commercial and consumer end use categories. 

Sections 3 to 13

	Sections 3 to 13 of the form ask for information on the use of mercury and mercury compounds in specific end products. The sections below present the burden estimates for each question in these sections.

	Questions 1, 2, 3, 4, and 5.

	Questions 1, 2, 3, 4, and 5 are yes/no questions that require the respondent to indicate whether the company manufactured, imported, or exported a product containing elemental mercury or mercury compounds, or whether the company purchased or imported elemental mercury or mercury compounds to manufacture a product, in 2010, 2013, or 2016. EPA assumed the burden for responding to these questions to be negligible, as it is likely the submitter would have reviewed this information when responding to questions 1.a. and 1.b. in Section 1 of the questionnaire.

      Questions 1(a), 2(a), 3(a), and 5(a).

	Questions 1(a), 2(a), 3(a), and 5(a) require the respondent to provide the total amount of mercury or mercury compounds manufactured in products manufactured or exported by the company or the amount of elemental mercury or mercury compounds domestically purchased or imported by the company to be used to products. EPA estimates that the burden associated with each one of these questions is similar to reporting product volumes on the paper Inventory Update Rule (IUR) form and is 1.51 hours for firms that have not submitted IMERC data and 1.21 hour for IMERC data submitters.

     Table 5: Hourly Unit Burden for Questions 1(a), 2(a), 3(a), and 5(a)
                                   Questions
                              Unit Burden (Hours)
                                       
                                   Clerical
                                   Technical
                                  Managerial
                                     Total
               Responders that Have not Submitted Data to IMERC
                          1(a), 2(a), 3(a), and 5(a)
                                     0.23
                                     1.03
                                     0.25
                                     1.51
                             IMERC Data Submitters
                          1(a), 2(a), 3(a), and 5(a)
                                     0.19
                                     0.82
                                     0.20
                                     1.21
Source(s): U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule. June 30, 2011. Burden for submitters to report production volumes, EPA assumes that Non-IMEC submitters have the same burden as a firm that reports CDR data for the first time and IMERC data submitters have the burden of a recurring CDR submitter.  

      Question 4(a)

	Question 4(a) requires the respondent to indicate the total amount of mercury or mercury compounds in manufactured products imported by the respondent. EPA believes that identifying the amount of mercury in imported products may be more burdensome that in domestically manufactured products or exports. Therefore, EPA uses the burden estimate for importers to collect information on the chemicals contained in imported articles from their suppliers as presented in the white paper Understanding the Costs Associated with Eliminating Exemptions for Articles in SNURs. The white paper estimates that this task will take between 0.08 and 8 hours, therefore, for the purposes of this ICR, EPA used the midpoint estimate of 4.04 hours. For IMERC data submitters EPA used the 20% burden reduction estimates for the IUR form and estimated a unit burden of 3.23 hours.

                Table 6: Hourly Unit Burden for Question 4 (a)
                                   Question
                              Unit Burden (Hours)
                                       
                                   Clerical
                                   Technical
                                  Managerial
                                     Total
               Responders that Have not Submitted Data to IMERC
                                     4(a)
                                     0.00
                                     4.04
                                     0.00
                                     4.04
                             IMERC Data Submitters
                                     4(a)
                                     0.00
                                     3.23
                                     0.00
                                     3.23
Source(s): Based on the average burden to collect information from suppliers on the chemicals in imported products in Understanding the Costs Associated with Eliminating Exemptions for Articles in SNURs. IMERC data submitters are assumed to have a 20% burden reduction based on the IUR EA, burden savings estimates for repeat submitters.

      Questions 1(b) and 5(b) [Sections 3 and 4 Only].

	Questions 1(b) and 5(b) are only found in Section 3 of the form, which requires the respondent to indicate whether the company has manufactured or exported cosmetics with a mercury concentration greater than 1 ppm or batteries with mercury content of 2% or greater. EPA estimates this burden to be similar to reporting chemical concentrations in a consumer or commercial product under the paper IUR form; 1.46 hours for IMERC data submitters and 1.81 hours for firms that have not submitted IMERC data.

            Table 7: Hourly Unit Burden for Questions 1(b) and 5(b)
                                   Questions
                              Unit Burden (Hours)
                                       
                                   Clerical
                                   Technical
                                  Managerial
                                     Total
               Responders that Have not Submitted Data to IMERC
                                 1(b) and 5(b)
                                     0.11
                                     1.36
                                     0.34
                                     1.81
                             IMERC Data Submitters
                                 1(b) and 5(b)
                                     0.09
                                     1.09
                                     0.28
                                     1.46
Source(s): US Environmental Protection Agency, Office of Pollution Prevention and Toxics. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule. June 30, 2011. Burden for submitters to report chemical concentrations in a consumer or commercial product, EPA assumes that Non-IMEC submitters have the same burden as a firm that reports CDR data for the first time and IMERC data submitters have the burden of a recurring CDR submitter.

      Question 4(b) [Sections 3 and 4 Only].

	Similar to question 4(a), EPA believes that importers may have a larger burden than domestic manufacturers or exporters, when reporting whether they imported any cosmetics with a mercury concentration greater than 1 ppm or batteries with mercury content of 2% or greater. EPA estimates the burden to respond to this question to be half of the burden for question 4(a), or 2.02 hours for firms that have not submitted IMERC data and 1.62 hours for IMERC data submitters.

                Table 8: Hourly Unit Burden for Questions 4(b)
                                   Question
                              Unit Burden (Hours)
                                       
                                   Clerical
                                   Technical
                                  Managerial
                                     Total
               Responders that Have not Submitted Data to IMERC
                                     4(b)
                                     0.00
                                     2.02
                                     0.00
                                     2.02
                             IMERC Data Submitters
                                     4(b)
                                     0.00
                                     1.62
                                     0.00
                                     1.62
Source(s): Assumed to be half of the burden to collect information from suppliers on the chemicals in imported products from the Article Importation white paper, as submitters will already be looking at this information for the question above. IMERC data submitters are assumed to have a 20% burden reduction based on the IUR EA, burden savings estimates for repeat submitters.

      Questions 1(c), 4(c) and 5(c) [Sections 3 and 4 Only].

      Questions 1(c), 4(c), and 5(c) require submitters to provide the percentage of the total number of cosmetics with greater than 1 ppm of mercury content or lower or batteries with mercury content of 2% or greater that they manufactured, imported, or exported. EPA believes submitters will calculate this total using information gathered to answer previously answered on the form, and therefore assumes this burden to be similar to calculating the volume of a chemical that is recycled or disposed of off-site on the TRI Form R, as this information is calculated using other information supplied on Form R (EPA, 2011b). EPA estimates the time to calculate these numbers to be 5 minutes of technical time and approximately 3.5 minutes of managerial review time per field (EPA, 2011b). For this ICR EPA multiplied these totals by three, to account for the three years' worth of data, for a total burden of 0.44 hours for firms that have not submitted IMERC data. EPA assumes that IMERC data submitters will have a 20% burden reduction based on the IUR EA (EPA, 2011a) and a burden of 0.35 hours per question.

      Table 9: Unit Per Question Burden for Questions1(c), 4(c) and 5(c)
                                   Questions
                              Unit Burden (Hours)
                                       
                                   Clerical
                                   Technical
                                  Managerial
                                     Total
               Responders that Have not Submitted Data to IMERC
                              1(c), 4(c) and 5(c)
                                     0.19
                                     0.25
                                     0.00
                                     0.44
                             IMERC Data Submitters
                              1(c), 4(c) and 5(c)
                                     0.15
                                     0.20
                                     0.00
                                     0.35
Source(s): Based on TRI (EPA, 2011b) burden estimate for calculating the volume of a chemical that is recycled or disposed of off-site. This is assumed to be 5 minutes of technical time to calculate a single value based other data in the form, plus managerial review time. The five minute total is multiplied by 3 for 3 years of data. IMERC data submitters are assumed to have a 20% burden reduction based on the IUR EA, burden savings estimates for repeat submitters.

	Question 6.

	Question 6 is an optional open ended question asking for additional comments, therefore this question has no burden by convention.

               Table 10: Unit Per Question Burden for Question 6
                                   Question
                              Unit Burden (Hours)
                                       
                                   Clerical
                                   Technical
                                  Managerial
                                     Total
               Responders that Have not Submitted Data to IMERC
                                       6
                                     0.00
                                     0.00
                                     0.00
                                     0.00
                             IMERC Data Submitters
                                       6
                                     0.00
                                     0.00
                                     0.00
                                     0.00
Source(s): EPA, 2011b

Total Industry Unit Burden Estimates for Sections 3 to 13

	Table 11 presents the burden estimates for non-IMERC data submitting firms to complete one product specific section. Table 12 presents the burden estimates for IMERC data submitting firms to complete one product specific section. To calculate the burden, the estimates derived in Tables 11 and 12 are weighted by the percentage of respondents completing a given section that are expected to respond to a given question and the number of responses per respondent. EPA estimated the number of respondents who domestically manufacture products (85%), import products (21%), and export products (28%) by assuming the proportions are similar to the proportions reported by the U.S. Census Bureau data on the number of importing and exporting manufacturing and wholesale firms. EPA estimated the number of manufacturers domestically purchasing mercury (59% of all companies) or importing mercury (26% of all companies) by multiplying the number of domestic manufacturers with the percentage of mercury imported or domestically manufactured from EPA's CDR database. The estimated number of product types per respondent (1.77) and the number of respondents answering the de minimis value questions in Sections 3 and 4 is based on data samples from the IMERC database.
Table 11: Total Burden to Complete One Product Specific Section (Sections 3 - 13) for Responders that Have not Submitted Data to IMERC
                                   Question
                          Burden for 100% of Section
Percentage of Respondents who Complete the Section that Respond to the Question
                           Responses per Respondent
                                 Total Burden
1. Did your company manufacture [product] that contain mercury or mercury compounds in 2010, 2013 or 2016?
                                     0.00
                                     100%
                                       1
                                     0.00
 1.a. If yes, then provide the total amount of mercury or mercury compounds in each of the following types of [product] per year(s)
                                     1.51
                                    85%[1]
                                    1.77[2]
                                     2.28
 1.b. Did your company manufacture any [product] with more than a de minimis level of mercury content?
                                     1.81
                                    85%[1]
                                       1
                                     1.54
 1.c. If yes, then provide the approximate number (or percentage) of the number provided for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                     0.44
                                    10%[3]
                                       1
                                     0.04
2. Did your company purchase in the United States elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016?
                                     0.00
                                     100%
                                       1
                                     0.00
 2.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company purchased in the United States for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016
                                     1.51
                                    59%[4]
                                    1.77[2]
                                     1.57
3. Did your company import elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016?
                                     0.00
                                     100%
                                       1
                                     0.00
 3.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company imported for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016
                                     1.51
                                    26%[5]
                                    1.77[2]
                                     0.70
4. Did your company import [product] containing elemental mercury or mercury compounds in 2010, 2013, or 2016?
                                     0.00
                                     100%
                                       1
                                     0.00
 4.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed types of [product] per year(s)
                                     4.04
                                    21%[6]
                                    1.77[2]
                                     1.50
 4.b. Did your company import any [product] more than a de minimis level of mercury content?
                                     2.02
                                    21%[6]
                                       1
                                     0.42
 4.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                     0.44
                                    2.5%[7]
                                     1.00
                                     0.01
5. Did your company export [product] containing mercury or mercury compounds in 2010, 2013, or 2016?
                                     0.00
                                     100%
                                       1
                                     0.00
 5.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed types of [product] per year(s)
                                     1.51
                                    28%[8]
                                    1.77[2]
                                     0.75
 5.b. Did your company export any [product] with more than a de minimis level of mercury content?
                                     1.81
                                    28%[8]
                                       1
                                     0.51
 5.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                     0.44
                                    3.4%[9]
                                       1
                                     0.01
6. Additional comments question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                     0.00
                                       -
                                       -
                                     0.00
Total for Section 3 and 4 (Batteries and Cosmetics
                                       -
                                       -
                                       -
                                     9.35
Total for Sections 5-13 (All Other Products; Excluded Questions 1.b, 1.c, 4.b, 4.c, 5.b, and 5.c)
                                       -
                                       -
                                       -
                                     6.81
Notes: Totals may not sum due to rounding
1 Estimated percentage (85%) of manufacturing and wholesale firms, that domestically manufacture or purchase products based on U.S. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012-2013. Released April 7, 2015).
2 Each firm makes an average of 1.77 types of each product based on a sample of 30 IMERC firms
[3] The percentage of firms that domestically manufacture products (85%) times the times the percentage of firms that have a product above a de minimis level (12% based on (IMERC, Mercury Added Products Database. Modified December 19, 2014)) = 10%.
[4] The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compounds that are domestically manufactured (69% (EPA. 2012 Chemical Data Reporting (CDR) Database. Updated April 3, 2014)) = 59%.
[5] The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compounds that are imported (31% (EPA. 2012 Chemical Data Reporting (CDR) Database. Updated April 3, 2014)) = 26%.
[6] Estimated percentage (21%) of manufacturing and wholesale firms, that import products based on U.S. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012-2013. Released April 7, 2015).
[7] The percentage of firms that import products (21%) times the times the percentage of firms that have a product above a de minimis level (12% (IMERC, Mercury Added Products Database. Modified December 19, 2014)) = 2.5%.
[8] The percentage of firms that export products (28%) based on U.S. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012-2013. Released April 7, 2015).
[9] The percentage of firms that export products (28%) times the times the percentage of firms that have a product above a de minimis level (12% (IMERC, Mercury Added Products Database. Modified December 19, 2014)) = 3.4%.



Table 12: Total Hourly Burden to Complete One Product Specific Section (Sections 3 - 13) for IMERC Data Submitters
                                   Question
                           Total per Question Burden
Percentage of Respondents who Complete the Section that Respond to the Question
                           Responses per Respondent
                                 Total Burden
1. Did your company manufacture [product] that contain mercury or mercury compounds in 2010, 2013 or 2016?
                                     0.00
                                     100%
                                       1
                                     0.00
  1.a. If yes, then provide the total amount of mercury or mercury compounds in each of the following types of [product] per year(s)
                                     1.21
                                    85%[1]
                                    1.77[2]
                                     1.82
  1.b. Did your company manufacture any [product] with mercury content of 2% or greater?
                                     1.46
                                    85%[1]
                                       1
                                     1.24
  1.c. If yes, then provide the approximate number (or percentage) of the number provided for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                     0.35
                                    10%[3]
                                       1
                                     0.04
2. Did your company purchase in the United States elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016?
                                     0.00
                                     100%
                                       1
                                     0.00
  2.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company purchased in the United States for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016
                                     1.21
                                    59%[4]
                                    1.77[2]
                                     1.26
3. Did your company import elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016?
                                     0.00
                                     100%
                                       1
                                     0.00
  3.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company imported for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016
                                     1.21
                                    26%[5]
                                    1.77[2]
                                     0.56
4. Did your company import [product] containing elemental mercury or mercury compounds in 2010, 2013, or 2016?
                                     0.00
                                     100%
                                       1
                                     0.00
  4.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed types of [product] per year(s)
                                     3.23
                                    21%[6]
                                     1.77
                                     1.20
  4.b. Did your company import any [product] with mercury content of 2% or greater?
                                     1.62
                                    21%[6]
                                       1
                                     0.34
  4.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                     0.35
                                    2.5%[7]
                                       1
                                     0.01
5. Did your company export [product] containing mercury or mercury compounds in 2010, 2013, or 2016?
                                     1.21
                                    28%[8]
                                     1.77
                                     0.60
  5.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed types of [product] per year(s)
                                     1.46
                                    28%[8]
                                       1
                                     0.41
  5.b. Did your company export any [product] with mercury content of 2% or greater mercury?
                                     0.35
                                    3.4%[9]
                                       1
                                     0.01
  5.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                     0.35
                                    2.8%[9]
                                       1
                                     0.01
6. Additional comments question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                     0.00
                                       -
                                       -
                                     0.00
Total for Section 3 and 4 (Batteries and Cosmetics)
                                       -
                                       -
                                       -
                                     7.49
Total for Sections 5-13 (All Other Products; Excluded Questions 1.b, 1.c, 4.b, 4.c, 5.b, and 5.c)
                                       -
                                       -
                                       -
                                     5.45
Notes: Totals may not sum due to rounding
1 Estimated percentage (85%) of manufacturing and wholesale firms, that domestically manufacture or purchase products based on U.S. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012-2013. Released April 7, 2015).
2 Each firm makes an average of 1.77 types of each product based on a sample of 30 IMERC firms
[3] The percentage of firms that domestically manufacture products (85%) times the times the percentage of firms that have a product above a de minimis level (12% based on (IMERC, Mercury Added Products Database. Modified December 19, 2014)) = 10%.
[4] The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compounds that are domestically manufactured (69% (EPA. 2012 Chemical Data Reporting (CDR) Database. Updated April 3, 2014)) = 59%.
[5] The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compounds that are imported (31% (EPA. 2012 Chemical Data Reporting (CDR) Database. Updated April 3, 2014)) = 26%.
[6] Estimated percentage (21%) of manufacturing and wholesale firms, that import products based on U.S. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012-2013. Released April 7, 20155).
[7] The percentage of firms that import products (21%) times the times the percentage of firms that have a product above a de minimis level (12% (IMERC, Mercury Added Products Database. Modified December 19, 2014)) = 2.5%.
[8] The percentage of firms that export products (28%) based on U.S. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012-2013. Released April 7, 2015).
[9] The percentage of firms that export products (28%) times the times the percentage of firms that have a product above a de minimis level (12% (IMERC, Mercury Added Products Database. Modified December 19, 2014)) = 3.4%.





      6(b) 	Estimating Respondent Costs 

      This section presents estimates of the cost expected to be incurred as a result of the information collection activity. This estimate is based on the cost of the burden estimates provided above, and includes other costs associated with this ICR.
Labor costs in this report have been updated using the most recently available, revised wage rates and information on cost of benefits. These wage rates are taken from the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation Supplemental Tables, December 2014 (released on March 11, 2015), with the information extracted from Table 2, Private industry workers in manufacturing industries, by occupational group. This table is available online at http://www.bls.gov/news.release/pdf/ecec.pdf in PDF format. The clerical wages are taken from the BLS data for "office and administrative support." The technical wages are taken from the BLS data for "professional and related." The managerial wages are taken from the BLS data for "management, business and financial." Labor wage rates and hourly cost of benefits taken from those sources have been used to calculate the labor cost for respondents, as shown below. The hourly overhead is calculated as 17 percent of the base wage. This approach is used for consistency with Office of Pollution Prevention and Toxics economic analyses practices, and is based on the analysis in Wage Rates for Economic Analyses of the Toxics Release Inventory Program. Table 13 presents $2014 hourly industry wages.

                          Table 13: Loaded Wage Rates
                                Labor Category
                                     Date
                                    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)
                                  Managerial
                                    Dec '14
                                    $47.90
                                    $24.18
                                      50%
                                      17%
                                     1.67
                                    $80.22
                                   Technical
                                    Dec '14
                                    $42.19
                                    $22.85
                                      54%
                                      17%
                                     1.71
                                    $72.21
                                   Clerical
                                    Dec '14
                                    $18.68
                                     $9.40
                                      50%
                                      17%
                                     1.67
                                    $31.26
Source(s): 
[1]Employer Costs for Employee Compensation Supplementary Tables: December 2006-September 2015, U.S. Bureau of Labor Statistics, December 9, 2015 (pp. 31,33,37) (http://www.bls.gov/ncs/ect/sp/ecsuphst.pdf, accessed January 25, 2016
[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  and Wage Rates for Economic Analyses of the Toxics Release Inventory Program.

      To estimate costs, EPA multiplied the per-hour loaded labor rates found in column (f) of Table 13 with the hourly labor estimates in Section 6(a). Table 14 presents the total per unit cost to complete Section 1 as $186 for all submitters. Table 15 presents the total cost for completing Section 2 as $85 for respondents that have not submitted IMERC data and $73 for IMERC data submitters, and Table 16 and Table 17 present the cost associated with completing one product specific section (Sections 3 to 13). EPA estimates the cost for completing Section 3 or 4 to be $645 for respondents that have not submitted IMERC data and $517 for IMERC data submitters. The cost of completing a single section in Sections 5 through 13 is estimated to be $465 for respondents that have not submitted IMERC data and $372 for IMERC data submitters.


        Table 14: Total Cost to Complete Section One for All Submitters
                                   Question
                              Total per Unit Cost
                                    ($2014)
Percentage of Respondents who Complete the Section that Respond to the Question
                           Responses per Respondent
                                  Total Cost
                                    ($2014)
Company Information
                                     $5.59
                                     100%
                                     1.00
                                     $5.59
1(a) and 1(b)
                                     $181
                                     100%
                                     1.00
                                     $181
                                     Total
                                     $186


                 Table 15: Total Cost to Complete Section Two 
                                   Question
                              Total per Unit Cost
                                    ($2014)
Percentage of Respondents who Complete the Section that Respond to the Question
                           Responses per Respondent
                                  Total Cost
                                    ($2014)
                  Firms that Have not Submitted Data to IMERC
Total for All of Section 2
                                    $85.09
                                     100%
                                     1.00
                                    $85.09
                             IMERC Data Submitters
Total for All of Section 2
                                    $73.95
                                     100%
                                     1.00
                                    $73.95



Table 16: Total Cost to Complete One Product Specific Section (Sections 3 - 13) for Responders that Have not Submitted Data to IMERC
                                   Question
                              Total per Unit Cost
                                    ($2014)
Percentage of Respondents who Complete the Section that Respond to the Question
                           Responses per Respondent
                                  Total Cost
                                    ($2014)
1. Did your company manufacture [product] that contain mercury or mercury compounds in 2010, 2013 or 2016?
                                     $0.00
                                     100%
                                       1
                                     $0.00
 1.a. If yes, then provide the total amount of mercury or mercury compounds in each of the following types of [product] per year(s)
                                     $102
                                    85%[1]
                                    1.77[2]
                                     $153
 1.b. Did your company manufacture any [product] with more than a de minimis level of mercury content?
                                     $129
                                    85%[1]
                                       1
                                     $110
 1.c. If yes, then provide the approximate number (or percentage) of the number provided for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                    $23.93
                                    10%[3]
                                       1
                                     $2.44
2. Did your company purchase in the United States elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016?
                                     $0.00
                                     100%
                                       1
                                     $0.00
 2.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company purchased in the United States for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016
                                     $102
                                    59%[4]
                                    1.77[2]
                                     $106
3. Did your company import elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016?
                                     $0.00
                                     100%
                                       1
                                     $0.00
 3.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company imported for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016
                                     $102
                                    26%[5]
                                    1.77[2]
                                    $47.32
4. Did your company import [product] containing elemental mercury or mercury compounds in 2010, 2013, or 2016?
                                     $0.00
                                     100%
                                       1
                                     $0.00
 4.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed types of [product] per year(s)
                                     $292
                                    21%[6]
                                    1.77[2]
                                     $109
 4.b. Did your company import any [product] more than a de minimis level of mercury content?
                                     $146
                                    21%[6]
                                       1
                                    $30.63
 4.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                    $23.93
                                    2.5%[7]
                                     1.00
                                     $0.60
5. Did your company export [product] containing mercury or mercury compounds in 2010, 2013, or 2016?
                                     $0.00
                                     100%
                                       1
                                     $0.00
 5.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed types of [product] per year(s)
                                     $102
                                    28%[8]
                                    1.77[2]
                                    $50.40
 5.b. Did your company export any [product] with more than a de minimis level of mercury content?
                                     $129
                                    28%[8]
                                       1
                                    $36.10
 5.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                    $23.93
                                    3.4%[9]
                                       1
                                     $0.80
6. Additional comments question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                     $0.00
                                       -
                                       -
                                     $0.00
Total for Section 3 and 4 (Batteries and Cosmetics)
                                       -
                                       -
                                       -
                                     $645
Total for Sections 5-13 (All Other Products; Excluded Questions 1.b, 1.c, 4.b, 4.c, 5.b, and 5.c)
                                       -
                                       -
                                       -
                                     $465
Notes: Totals may not sum due to rounding
1 Estimated percentage (85%) of manufacturing and wholesale firms, that domestically manufacture or purchase products based on U.S. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012-2013. Released April 7, 2015).
2 Each firm makes an average of 1.77 types of each product based on a sample of 30 IMERC firms
[3] The percentage of firms that domestically manufacture products (85%) times the times the percentage of firms that have a product above a de minimis level (12% based on (IMERC, Mercury Added Products Database. Modified December 19, 2014)) = 10%.
[4] The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compounds that are domestically manufactured (69% (EPA. 2012 Chemical Data Reporting (CDR) Database. Updated April 3, 2014)) = 59%.
[5] The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compounds that are imported (31% (EPA. 2012 Chemical Data Reporting (CDR) Database. Updated April 3, 2014)) = 26%.
[6] Estimated percentage (21%) of manufacturing and wholesale firms, that import products based on U.S. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012-2013. Released April 7, 2015).
[7] The percentage of firms that import products (21%) times the times the percentage of firms that have a product above a de minimis level (12% (IMERC, Mercury Added Products Database. Modified December 19, 2014)) = 2.5%.
[8] The percentage of firms that export products (28%) based on U.S. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012-2013. Released April 7, 2015).
[9] The percentage of firms that export products (28%) times the times the percentage of firms that have a product above a de minimis level (12% (IMERC, Mercury Added Products Database. Modified December 19, 2014)) = 3.4%.



Table 17: Total Cost to Complete One Product Specific Section (Sections 3 - 13) for IMERC Data Submitters
                                   Question
                              Total per Unit Cost
                                    ($2014)
Percentage of Respondents who Complete the Section that Respond to the Question
                           Responses per Respondent
                                  Total Cost
                                    ($2014)
1. Did your company manufacture [product] that contain mercury or mercury compounds in 2010, 2013 or 2016?
                                     $0.00
                                     100%
                                       1
                                     $0.00
  1.a. If yes, then provide the total amount of mercury or mercury compounds in each of the following types of [product] per year(s)
                                    $81.29
                                    85%[1]
                                    1.77[2]
                                     $122
  1.b. Did your company manufacture any [product] with mercury content 2% or greater?
                                     $104
                                    85%[1]
                                       1
                                    $88.39
  1.c. If yes, then provide the approximate number (or percentage) of the number provided for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                    $19.14
                                    10%[3]
                                       1
                                     $1.95
2. Did your company purchase in the United States elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016?
                                     $0.00
                                     100%
                                       1
                                     $0.00
  2.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company purchased in the United States for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016
                                    $81.29
                                    59%[4]
                                    1.77[2]
                                    $84.55
3. Did your company import elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016?
                                     $0.00
                                     100%
                                       1
                                     $0.00
  3.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company imported for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016
                                    $81.29
                                    26%[5]
                                    1.77[2]
                                    $37.86
4. Did your company import [product] containing elemental mercury or mercury compounds in 2010, 2013, or 2016?
                                     $0.00
                                     100%
                                       1
                                     $0.00
  4.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed types of [product] per year(s)
                                     $233
                                    21%[6]
                                     1.77
                                    $86.82
  4.b. Did your company import any [product] with mercury content 2% or greater?
                                     $117
                                    21%[6]
                                       1
                                    $24.51
  4.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                    $19.14
                                    2.5%[7]
                                       1
                                     $0.48
5. Did your company export [product] containing mercury or mercury compounds in 2010, 2013, or 2016?
                                     $0.00
                                    28%[8]
                                     1.77
                                     $0.00
  5.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed types of [product] per year(s)
                                    $81.29
                                    28%[8]
                                       1
                                    $40.32
  5.b. Did your company export any [product] with mercury content 2% or greater?
                                     $104
                                    3.4%[9]
                                       1
                                    $29.12
  5.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                    $19.14
                                    2.8%[9]
                                       1
                                     $0.64
6. Additional comments question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016
                                     $0.00
                                       -
                                       -
                                     $0.00
Total for Section 3 and 4 (Batteries and Cosmetics)
                                       -
                                       -
                                       -
                                     $517
Total for Sections 5-13 (All Other Products; Excluded Questions 1.b, 1.c, 4.b, 4.c, 5.b, and 5.c)
                                       -
                                       -
                                       -
                                     $372
Notes: Totals may not sum due to rounding
1 Estimated percentage (85%) of manufacturing and wholesale firms, that domestically manufacture or purchase products based on U.S. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012-2013. Released April 7, 2015).
2 Each firm makes an average of 1.77 types of each product based on a sample of 30 IMERC firms
[3] The percentage of firms that domestically manufacture products (85%) times the times the percentage of firms that have a product above a de minimis level (12% based on (IMERC, Mercury Added Products Database. Modified December 19, 2014)) = 10%.
[4] The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compounds that are domestically manufactured (69% (EPA. 2012 Chemical Data Reporting (CDR) Database. Updated April 3, 2014)) = 59%.
[5] The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compounds that are imported (31% EPA. 2012 Chemical Data Reporting (CDR) Database. Updated April 3, 2014)) = 26%.
[6] Estimated percentage (21%) of manufacturing and wholesale firms, that import products based on U.S. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012-2013. Released April 7, 2015).
[7] The percentage of firms that import products (21%) times the times the percentage of firms that have a product above a de minimis level (12% (IMERC, Mercury Added Products Database. Modified December 19, 2014)) = 2.5%.
[8] The percentage of firms that export products (28%) based on U.S. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012-2013. Released April 7, 2015).
[9] The percentage of firms that export products (28%) times the times the percentage of firms that have a product above a de minimis level (12% (IMERC, Mercury Added Products Database. Modified December 19, 2014)) = 3.4%.



      6(c) 	Estimating Agency Burden and Cost

      EPA estimates that the Agency cost for administering and mailing out the survey is $24,726, and includes both labor and materials costs. Labor costs are 1/7th of a full-time employee (FTE) 13, Step 5 employee in the Washington-Baltimore locality, with a total annual wage of $101,914 (OPM, 2014). EPA applied a government overhead factor of 1.6 to account for fringe benefits and overhead, for a total EPA staff cost of approximately $23,295 in $2014 (($101,914 x 1.6)/7=$23,295). EPA's cost for sending 646 questionnaires with stamped return envelopes is $2.22 each ($0.98 in postage and $1.24 in materials and processing cost). Both labor and material costs estimates are based on data from EPA ICR No. 249.10 OMB Control No. 2070-NEW [Information Collection Request for] Survey of Public and Commercial Buildings. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act. Stamps cost estimates are based on current U.S. postage rates for first class mail.

                        Table 18: Agency Costs ($2014)
                                   Activity
                                  Agency Cost
                    EPA Staff Time (1/7 of a GS 13-Step 5)
                                    $23,295
                             Mailing Questionnaire
                                    $1,432
                                     Total
                                    $24,726

      6(d) 	Bottom-Line Industry Burden and Cost Estimates

      Respondent tally

      EPA used various data sources including IMERC, TRI data, March 2015 subpoenas, and Internet research to identify companies to that may manufacture, import, or export mercury in a product, or use mercury in a manufacturing process. EPA identified up to 646 facilities in the United States that manufacture, import, or export mercury-added products, or use mercury or mercury compounds in manufacturing processes; 515 companies that have not previously submitted data to IMERC and 131 companies that have submitted IMERC data. If all 646 companies received a questionnaire, EPA expects that each would complete Sections 1 and 2 of the questionnaire. However some of these companies may not be using mercury in any products of interest to EPA, such as mercury present in fuel sources for coal-fired boilers or other industrial furnaces, and these firms will not complete Sections 3 to 13. Based on company data, EPA estimates that a total of 27 companies would respond to Sections 3 or 4 and 528 would respond to Sections 5 through 13. EPAs research indicates that no firms manufacture both batteries and cosmetics (Section 3 and 4), however for Sections 5-13 the average of 1.09 products categories per respondent was calculated from an IMERC sample of 30 active companies. Table 19 presents the total number of responders and responses for each section.

              Table 19: Total Number of Responders and Responses
                                    Section
                            Number of Responders[1]
                            Sections per Respondent
                              Number of Responses
                                       
                                   Non-IMERC
                                   IMERC[2]
                                     Total
                                       
                                   Non-IMERC
                                     IMERC
                                     Total
                                   Section 1
                                      515
                                      131
                                      646
                                       1
                                      515
                                      131
                                      646
                                   Section 2
                                      515
                                      131
                                      646
                                       1
                                      515
                                      131
                                      646
                              Sections 3 or 4[3]
                                       2
                                      25
                                      27
                                       1
                                       2
                                      25
                                      27
                                 Sections 5-13
                                      416
                                      112
                                      528
                                     1.09
                                      454
                                      122
                                      576

      Total Industry Burden and Cost for All Submitters

      Table 20 contains the total burden and cost for all potential respondents. EPA estimates the total industry burden to be 6,399 hours and $444,430.

              Table 20: Total Burden and Cost for All Submitters
                                   Activity
                           Total Number of Companies
                             Responses per Company
                           Total Number of Responses
                       Total Burden per Activity (hours)
                        Total Cost per Activity ($2014)
                             Total Burden (hours)
                              Total Cost ($2014)
               Responders that Have not Submitted Data to IMERC
                             Section 1 Completion
                                      515
                                       1
                                      515
                                     2.60
                                     $186
                                     1,337
                                    $95,889
                             Section 2 Completion
                                      515
                                       1
                                      515
                                     1.23
                                      $85
                                      634
                                    $43,839
                            Section 3-4 Completion
                                       2
                                       1
                                       2
                                     9.35
                                     $645
                                      19
                                    $1,290
                           Sections 5-13 Completion
                                      416
                                     1.09
                                      454
                                     6.81
                                     $465
                                     3,090
                                   $211,107
                                     Total
                                     5,080
                                   $352,125
                             IMERC Data Submitters
                             Section 1 Completion
                                      131
                                       1
                                      131
                                     2.60
                                     $186
                                      339
                                    $24,343
                             Section 2 Completion
                                      131
                                       1
                                      131
                                     0.98
                                      $74
                                      128
                                    $9,673
                            Section 3-4 Completion
                                      25
                                       1
                                      25
                                     7.49
                                     $517
                                      187
                                    $12,926
                           Sections 5-13 Completion
                                      112
                                     1.09
                                      122
                                     5.45
                                     $372
                                      664
                                    $45,363
                                     Total
                                     1,319
                                    $92,305
                          Summary for All Submitters
                             Section 1 Completion
                                      646
                                       1
                                      646
                                     2.60
                                     $186
                                     1,676
                                   $120,232
                             Section 2 Completion
                                      646
                                       1
                                      646
                                     1.18
                                      $83
                                      762
                                    $53,512
                            Section 3-4 Completion
                                      27
                                       1
                                      27
                                     7.63
                                     $527
                                      206
                                    $14,216
                           Sections 5-13 Completion
                                      528
                                     1.09
                                      576
                                     6.52
                                     $445
                                     3,755
                                   $256,470
                                     Total
                                     6,399
                                   $444,430
      
      For comparison, the Agency used the above approach to generate a total burden and cost for a narrowed scope of up to 250 respondents. As set forth in Table 20a, EPA estimates the total industry burden to be 2,566 hours and $178,961.

       Table 20a: Total Burden and Cost for all Submitters  -  250 Firms
                                   Activity
                           Total Number of Companies
                             Responses per Company
                           Total Number of Responses
                       Total Burden per Activity (hours)
                        Total Cost per Activity ($2014)
                             Total Burden (hours)
                              Total Cost ($2014)
               Responders that Have not Submitted Data to IMERC
                             Section 1 Completion
                                      65
                                       1
                                      65
                                     2.60
                                     $186
                                      169
                                    $12,094
                             Section 2 Completion
                                      65
                                       1
                                      65
                                     1.23
                                      $85
                                      80
                                    $5,529
                            Section 3-4 Completion
                                       3
                                       1
                                       3
                                     9.35
                                     $645
                                      28
                                    $1,935
                           Sections 5-13 Completion
                                      62
                                     1.09
                                      68
                                     6.81
                                     $465
                                      460
                                    $31,436
                                     Total
                                      737
                                    $50,994
                             IMERC Data Submitters
                             Section 1 Completion
                                      185
                                       1
                                      185
                                     2.60
                                     $186
                                      480
                                    $34,436
                             Section 2 Completion
                                      185
                                       1
                                      185
                                     0.98
                                      $74
                                      181
                                    $13,683
                            Section 3-4 Completion
                                      21
                                       1
                                      21
                                     7.49
                                     $517
                                      157
                                    $10,858
                           Sections 5-13 Completion
                                      170
                                     1.09
                                      185
                                     5.45
                                     $372
                                     1,010
                                    $68,990
                                     Total
                                     1,829
                                   $127,967
                          Summary for All Submitters
                             Section 1 Completion
                                      250
                                       1
                                      250
                                     2.60
                                     $186
                                      649
                                    $46,529
                             Section 2 Completion
                                      250
                                       1
                                      250
                                     1.04
                                      $77
                                      261
                                    $19,212
                            Section 3-4 Completion
                                      24
                                       1
                                      24
                                     7.73
                                     $533
                                      185
                                    $12,793
                           Sections 5-13 Completion
                                      232
                                     1.09
                                      253
                                     5.81
                                     $397
                                     1,471
                                   $100,426
                                     Total
                                     2,566
                                   $178,961



      Average Burden and Cost per Respondent

      Table 21 presents the average total burden per respondent; 9.37 hours for companies that have not submitted IMERC data and 10.18 hours for companies that have submitted IMERC data. Table 22 presents the average cost per submitter, which EPA estimates to be $683 for companies that have not submitted IMERC data and $706 for companies that have.

                    Table 21: Average Burden per Respondent
                                   Activity
                                     Hours
                         Responses per Average Company
                            Average Burden (hours)
                                       
                                   Clerical
                                   Technical
                                  Managerial
                                     Total
                                       
                                       
               Responders that Have not Submitted Data to IMERC
                             Section 1 Completion
                                     0.04
                                     2.54
                                     0.02
                                     2.60
                                       1
                                     2.60
                             Section 2 Completion
                                     0.14
                                     0.84
                                     0.25
                                     1.23
                                       1
                                     1.23
                            Section 3-4 Completion
                                     1.01
                                     6.69
                                     1.15
                                     8.85
                                     0.004
                                     0.03
                           Sections 5-13 Completion
                                     0.80
                                     4.69
                                     0.77
                                     6.25
                                     0.88
                                     5.51
                                     Total
                                     9.37
                             IMERC Data Submitters
                             Section 1 Completion
                                     0.04
                                     2.54
                                     0.02
                                     2.60
                                       1
                                     2.60
                             Section 2 Completion
                                     0.12
                                     0.75
                                     0.20
                                     1.07
                                       1
                                     1.07
                            Section 3-4 Completion
                                     0.79
                                     5.68
                                     1.03
                                     7.49
                                     0.19
                                     1.43
                           Sections 5-13 Completion
                                     0.66
                                     4.07
                                     0.71
                                     5.45
                                     0.93
                                     5.08
                                     Total
                                     10.18
Notes: Totals may not sum due to rounding
The average number of responses per company is calculated by dividing the total number of responses for each section by the total number of companies. For example the average number of Section 3-4s per company for firms that have not submitted IMERC data is calculated as 2 responses/565 companies = .004.

                     Table 22: Average Cost per Respondent
                                   Activity
                                 Cost ($2014)
                         Responses per Average Company
                             Average Cost ($2014)
                                       
                                   Clerical
                                   Technical
                                  Managerial
                                     Total
                                       
                                       
               Responders that Have not Submitted Data to IMERC
                             Section 1 Completion
                                     $1.09
                                    $183.42
                                     $1.60
                                    $186.12
                                     1.00
                                     $186
                             Section 2 Completion
                                     $4.38
                                    $60.66
                                    $20.06
                                    $85.09
                                     1.00
                                      $85
                            Section 3-4 Completion
                                    $30.48
                                    $512.90
                                    $101.73
                                    $645.11
                                     0.004
                                     $2.50
                           Sections 5-13 Completion
                                    $25.65
                                    $368.39
                                    $70.91
                                    $464.95
                                     0.88
                                     $410
                                     Total
                                     $683
                                     IMERC
                             Section 1 Completion
                                     $1.09
                                    $183.42
                                     $1.60
                                    $186.12
                                     1.00
                                     $186
                             Section 2 Completion
                                     $3.75
                                    $54.16
                                    $16.04
                                    $73.95
                                     1.00
                                      $74
                            Section 3-4 Completion
                                    $24.65
                                    $410.03
                                    $82.36
                                    $517.04
                                     0.19
                                      $99
                           Sections 5-13 Completion
                                    $20.72
                                    $294.26
                                    $56.98
                                    $371.96
                                     0.93
                                     $347
                                     Total
                                     $706
Notes: Totals may not sum due to rounding
The average number of responses per company is calculated by dividing the total number of responses for each section by the total number of companies. For example the average number of Section 3-4s per company for firms that have not submitted IMERC data is calculated as 2 responses/565 companies = .004

      6(e)	Bottom Line Burden Hours and Cost Tables

	Table 23 contains the bottom line burden and cost estimate for all potential respondents. EPA estimates the total burden to be 6,399 hours and $469,156, including Agency costs.

           Table 23: Bottom Line Burden and Costs for all Submitters
                                 Cost Category
                                  Labor Hours
                                     Cost
                               Respondent Labor
                                     6,399
                                   $444,430
                                   EPA Labor
                                     N.A.
                                    $23,295
                            Other Direct EPA Costs
                                     N.A.
                                    $1,432
                                     Total
                                     6,399
                                   $469,156

      For comparison, the Agency used the above approach to generate a total burden and cost for a narrowed scope of up to 250 respondents. As set forth in Table 23a, EPA estimates the total industry burden to be 2,566 hours and $202,810, including Agency costs.


             Table 23a: Bottom Line Burden and Costs  -  250 Firms
                                 Cost Category
                                  Labor Hours
                                     Cost
Respondent Labor
                                     2,566
                                   $178,961
EPA Labor
                                     N.A.
                                    $23,295
Other Direct EPA Costs
                                     N.A.
                                     $554
Total
                                     2,566
                                   $202,810

      6(f)	Reasons for Change in Burden

      Not applicable because this request is for a new collection of information.

      6(g)	Burden Statement

      The annual public burden for this collection of information is estimated to average 9.9 hours per response (response in this context meaning submission by a respondent of a completed questionnaire). 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 current and valid OMB control number. The OMB control numbers for EPA's regulations in title 40 of the CFR, after appearing in the Federal Register, are listed in 40 CFR part 9 and included on the related collection instrument or form, if applicable.

	The Agency has established a public docket for this ICR under Docket ID No. EPA-HQ-OPPT-2016-0125, which is available for online viewing at www.regulations.gov, or in person 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.

	You may submit comments regarding 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. Submit your comments, referencing Docket ID No. EPA-HQ-OPPT-2016-0125 and OMB Control No. 2070-NEW, to (1) EPA online using www.regulations.gov (our preferred method), or by mail to: Pollution Prevention and Toxics Docket, Environmental Protection Agency Docket Center (EPA/DC), Mailcode: 28221T, 1200 Pennsylvania Ave., NW., Washington, DC 20460, and (2) OMB by mail to: Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, NW, Washington, DC 20503.
                LIST OF ATTACHMENTS TO THE SUPPORTING STATEMENT
Attachment 1  -  Toxic Substances Control Act, section 2(b)(1) [15 U.S.C. 2601] and section 11(c) [15 U.S.C. 2610]

Attachment 2  -  Minamata Convention on Mercury

Attachment 3  -  EPA Strategy to Address Mercury‐Containing Products

Attachment 4  -  Questionnaire: Collection of Information on Use of Mercury and Mercury Compounds in Products and Processes
