       Supporting Statement for an Information Collection Request (ICR)
                    Under the Paperwork Reduction Act (PRA)
	
 EXECUTIVE SUMMARY
 Identification of the Information Collection  -  Title and Numbers 
      Title: User Fees for the Administration of the Toxic Substances Control Act (TSCA)
      ICR Numbers: EPA ICR No.: 2569.02; OMB Control No.: 2070-0208.
      EPA Form Numbers:  EPA Form No. 9600-008: Notice of TSCA Fee Action Participation (will be incorporated into online reporting tool).  
	Docket ID Number: EPA-HQ-OPPT-2020-0616.

 Docket Information
This information collection request (ICR), which explains the information collection activities and the related burden and cost estimates, as well as other supporting documents related to the ICR are available in the docket. The docket can be viewed online at http://www.regulations.gov. For additional information about EPA's public docket, visit http://www.epa.gov/dockets. 

 ICR Status 
This is a renewal of the existing ICR that addresses the information collection activities issued by the Environmental Protection Agency (EPA) on September 27, 2018 (See Attachment 1). 

 Abstract
The Frank R. Lautenberg Chemical Safety for the 21st Century Act of 2016 made transformative changes to the Toxic Substances Control Act (TSCA), including an amendment that provides EPA with authority to collect fees to defray 25% of the costs associated with administering sections 4, 5, and 6 of TSCA, as well as the costs of collecting, processing, reviewing and providing access to and protecting CBI from disclosure as appropriate under TSCA section 14. Payments are required from manufacturers (defined by statute to include importers) of a chemical substance who: are required to submit information to EPA under TSCA section 4, who submit certain notices and exemption requests to EPA under TSCA section 5, who manufacture a chemical substance that is subject to a risk evaluation under TSCA section 6(b)(4), and who process a chemical substance that is the subject of a Significant New Use Notice (SNUN) or Test Market Exemption (TME) under TSCA section 5 and who are required to submit information to EPA under TSCA section 4 related to a SNUN submission. These fees are intended to achieve the goals articulated by Congress to provide a sustainable source of funds for EPA to fulfill its legal obligations to conduct the activities required under TSCA sections 4, 5 and 6 (such as risk-based screenings, designation of applicable substances as High- and Low-Priority, conducting risk evaluations to determine whether a chemical substance presents an unreasonable risk of injury to health or the environment, requiring testing of chemical substances and mixtures, and evaluating and reviewing manufacturing and processing notices), as well as the activities under TSCA section 14 (i.e., collecting, processing, reviewing, and providing access to and protecting information about chemical substances from disclosure as appropriate.

 NECESSITY OF THE INFORMATION COLLECTION
 Related Legal and/or Administrative Requirements
As amended in 2016, TSCA section 26(b) provides EPA with authority to establish fees to defray 25% the costs associated with administering TSCA sections 4, 5, 6 and of collecting, processing, reviewing, and providing access to and protecting information about chemical substances from disclosure as appropriate under TSCA section 14. 

Fee payments are required from chemical manufactures (including importers) who make submissions under TSCA section 5, are required to submit information under TSCA section 4 or are subject to a risk evaluation under TSCA section 6. EPA is not collecting a fee for submissions of Confidential Business Information (CBI) submitted under TSCA section 14. 

Persons subject to fees are required to make fee payments electronically using the Department of Treasury's Pay.gov electronic collection payment services. Once the payment is made, Federal agencies may access the payment and associated information. The information submitted to EPA during the payment process includes company contact information, information about the payment amount and method. Once submitted via Pay.gov, the payment information is sent to EPA. 

Certain manufactures (including importers) are also required to make a submission to EPA's Central Data Exchange (CDX) and to inform EPA if they choose to associate as a consortium. Notification must be provided to EPA via the CDX when a consortium is formed. This includes the name, address, telephone number and signature of the principle sponsor and the names and contact information for each manufacturer and/or processor associating with the consortium.  Under TSCA, a consortium is an association of manufacturers (including importers) and/or processors who have made an agreement to jointly split the cost of applicable fees. Manufacturers (including importers) and processors are also required to certify if they qualify as a small business and are subject to reduced fees.

All manufacturers (and importers) who have manufactured or imported the chemical substance in the 5 years prior to a TSCA section 4 Test Rules and TSCA section 6 EPA-initiated risk evaluations must submit notice to EPA electronically via CDX, the Agency's electronic reporting portal, using the Chemical Information Submission System (CISS) reporting tool. Manufactures are required to provide the following information:

      Contact Information. The name and address of the submitting company, the name and address of the authorized official for the submitting company, and the name and telephone number of a person who will serve as technical contact for the submitting company and who will be able to answer questions about the information submitted by the company to EPA.
      
      Certification of Cessation. If a manufacturer has manufactured in the five-year period preceding publication of the preliminary list, but has ceased manufacturer prior to the certification cutoff dates identified and will not manufacture the substance again in the successive five years, the manufacturer may submit a certification statement attesting to these facts. If EPA receives such a certification statement from a manufacturer, the manufacturer will not be obligated to pay the fee.
      
      Certification of No Manufacture. If a manufacturer is identified on the preliminary list, but has not manufactured the chemical in the five-year period preceding publication of the preliminary list, the manufacturer may submit a certification statement attesting to these facts. If EPA receives such a certification statement from a manufacturer, the manufacturer will not be obligated to pay the fee.  

 Necessity of the Information Collection
The information collection activities covered by this ICR are necessary to collect and process fees as required by TSCA section 26(b). The fees collected are designed to defray a portion of the costs of administering TSCA sections 4, 5, 6 and of collecting, processing, reviewing, and providing access to and protecting information about chemical substances from disclosure as appropriate under TSCA section 14. 

 Uses, Users, and Purpose of the Information Collection
When manufactures (including importers) and importers pay a fee, they must submit information that includes company contact information, and payment information. The information will be used by the Agency to calculate the revenue generated by the TSCA fee programs and ensure that the required fees have been paid by each respondent. 

Manufactures, importers and processors are required to inform EPA if they choose to associate as a consortium for submissions under TSCA sections 4 and 6. EPA will use this information to determine the fee assessed to the consortium based on a formula established in the regulation. Once the fee is assessed by the Agency, the consortium can determine how the fees will be split among its members. However, if the consortium is unable to come to terms on how the fees will be split among its members, EPA will determine the portion of the fee to be paid by each member.   

 NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
 Non-Duplication
 EPA's collection under this ICR does not duplicate any other collection. There is no other Federal program that require the information collection activities related to the fees collected under TSCA section 26(b). 

 Public Notice Required Prior to ICR Submission to OMB
   As part of the renewal process, EPA will publish a notice in the Federal Register prior to submitting the ICR to OMB. Pursuant to 5 CFR 1320.8(d), any public comments received will be placed in the EPA docket, EPA-HQ-OPP-2020-0616, for this action. 
   
   3(c).	Consultations
Under 5 CFR 1320.8(d)(1), agencies are required 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 consult with representative stakeholders during the public comment period, see attachment 3 for an example of the questions. 

   3(d).	Effects of Less Frequent Collection
 Due to the nature of the triggering events that initiate information collection activities, less frequent collection is not feasible. There is no set collection schedule for the payment information associated with fee payments (e.g. payment method). CDX Submission and payment information is collected each time a fee payment is made via Pay.gov with the frequency of collection depending entirely on the frequency with which applicants submit information to EPA and that EPA initiates activities under TSCA sections 4, 5 and 6. Therefore, less frequent collection is not an option.
 
   3(e).	Small Entity Flexibility
 EPA believes that the regulatory requirements do not unduly burden small businesses. Although small businesses are required to submit the same information, they pay a reduced fee. EPA estimates that, of the 429 small businesses paying fees every year, all firms may have annual cost-revenue impacts of less than 1%. 

   3(f).	General PRA Related Guidelines
 This ICR is consistent with OMB's general guidelines do not exceed any of the Paperwork Reduction Act guidelines at 5 CFR 1320.5. 

   3(g).	Confidentiality
Since the information collected under this ICR involves only information related to payments, EPA does not believe that respondents will submit any confidential information collected under this ICR. However, to the extent information submitted by respondents is business confidential, procedures are in place to protect the information from improper disclosure consistent with section 14 of TSCA.

   3(h).	Sensitive Questions
 The information collection activities do not include questions of a sensitive nature.

 AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT
 Agency Activities
Agency activities include data management of the fee information. 

 Estimated Agency Costs
EPA estimates that managing the information that is submitted at the time of the fee payment would require one 80-hour week of labor per year for a GS-13, Step 5 employee in the Washington D.C. area, which will amount to an annual Agency cost of $6,740.48 ($84.26 x 80 = $6,740.48). To calculate the loaded wage rate, EPA uses the wage rate for a GS-13, Step 5 employee in the Washington D.C. area, loaded with a combined fringe and overhead factor of 60% to obtain a loaded wage rate of $175,252 per year. Dividing this wage rate over 2,080 hours  -  the annual labor hours of a full-time employee  -  results in an hourly wage rate of $84.26.
 Collection Schedule
This information collection activity does not have a calendar-based schedule. Fee payments are generally required when a manufacturer (including importer) makes a submission under TSCA section 5, is required to submit information under TSCA section 4 or is subject to a risk evaluation under TSCA section 6(b)(4).  EPA is required to have 20 EPA-initiated risk evaluations under way at all times starting in December 2019 and each risk evaluation is expected to conclude in 3 years with the option for an up to 6-month extension.  Therefore, TSCA section 6 fees for EPA-initiated risk evaluations will generally be predictable.  TSCA section 6 manufacturer-requested risk evaluations timing and frequency will depend on requests received.  EPA is required to have between 5-10 manufacturer-requested risk evaluations underway if sufficient applications have been received.  However, EPA is unsure how many such requests will be received.  Section 5 actions are entirely reliant on industry submissions.  Historical data is used for cost estimation purposes  TSCA section 4 activities will be primarily driven by EPA's data needs as the new statutory requirements continue to be implemented.  Because these activities occur on an as-needed, on-occasion basis, often initiated by the respondents, considerations for less frequent collection are not relevant. 

 Use of Technology to Facilitate Collection Activities
EPA will make use of existing technology to collect the information subject to this ICR. Fee payments will be made electronically via Pay.gov. The collection of the identifying number and payment identity number will be made through CDX, EPA's portal for submitting information electronically. 

 The RESPONDENTS AND INFORMATION COLLECTION (IC) ACTIVITIES
For each respondent category, this section of the ICR describes the respondents, the information collection activities and related estimates for burden and costs associated with those activities. 

 Methodology for Estimating Respondent Burden and Costs
The collection specifies fee payment requirements that apply to manufacturers (including importers) who are required to submit information under TSCA section 4, who submit certain notices and exemption requests to EPA under TSCA section 5, who manufacture a chemical substance that is subject to a risk evaluation under TSCA section 6(b)(4), and who process a chemical substance that is the subject of a Significant New Use Notice (SNUN) or Test Market Exemption (TME) under TSCA section 5 and who are required to submit information under TSCA section 4 related to a SNUN submission. The following list of NAICS codes is not intended to be exhaustive, but rather provides a guide to help readers determine whether this document applies to them. Potentially affected entities may include companies found in major NAICS code groups:

 324	Petroleum and Coal Products
 325	Chemical Manufacturing
 424	Chemical, Petroleum and Merchant Wholesalers

Each firm subject to a fee is required to pay the fee via Pay.gov. Firms also need to determine if they qualify as an eligible small business for reduced fees and indicate if they plan to be or are already part of a consortium.  Reduced fees apply to small business with a number of employees below the thresholds list in section §700.43 "Definitions applicable to this subpart" fewer than 500 employees if the firm is not in an industry sector that appears in the table. 

Firms subject to fees under TSCA section 4 and fees for Risk Evaluations under TSCA section 6 may form a consortium for paying the specified fees and are required to notify EPA through a principal sponsor that the consortium was formed, detailing the members of the consortium and their contact information. This notification must be submitted to EPA electronically via CDX. 

Firms subject to Test Rules under TSCA section 4 and EPA-initiated Risk Evaluations under TSCA section 6 also need to review a preliminary list published by EPA of companies to which the action applies so that they can determine whether their company is listed and certify via CDX accordingly.

Number of Entities Affected
EPA relied on past experience with 20 Test Cost actions under TSCA section 4, submitter data for new chemical notices under TSCA section 5, and work to date on the 20 high priority chemicals currently undergoing Risk Evaluation under TSCA section 6 to inform its estimates of average number of firms impacted per action. Each TSCA section 4 action is expected to cover an average of one chemical and an average of 15 manufacturers per chemical, resulting in an estimate of 15 firms impacted per TSCA section 4 action. TSCA section 5 actions are expected to impact one firm per action. Risk Evaluations initiated by EPA under TSCA section 6 are expected to impact an average of one chemical and 15 manufacturers per Risk Evaluation. Manufacturer requests for Risk Evaluations submitted to EPA are difficult to predict, but EPA expects that a single manufacturer will submit each request.

The total number of firms affected per year is the product of the number of firms affected per action and the estimated number of actions per year. EPA estimates the number of TSCA section 4 actions based on previous experience and expected work under the Frank R. Lautenberg Chemical Safety for the 21st Century Act of 2016, for a total of 13 actions per year. TSCA section 5 actions are estimated to total 1,003 submissions per year, and this estimate is based on the average number of section 5 notice submissions and exemption requests received by EPA in 2018, 2019, and 2020. The Agency expects to have between 20 and 30 Risk Evaluations ongoing in any given year at different stages in the review process, including manufacturer-requested evaluations, for an average of 10 Risk Evaluations initiated per year. Combined with the number of firms affected per action, the total number of firms impacted per year is 1,348 firms; 195 firms from TSCA section 4 actions, 1,003 firms from TSCA section 5 actions, and 150 firms from TSCA section 6 actions.

Rule Familiarization
EPA assumes that each firm subject to a fee will spend 0.5 hours becoming familiar with the requirements and developing an understanding of what actions are necessary to comply with the fee payment requirements. This is estimated as a one-time burden. The burden is estimated to occur the first time a firm is affected by the requirements. For analytical purposes, EPA assumes that no firm will be subject to any of the fee-triggering actions under TSCA sections 4, 5, or 6 more than once over the three-year period of this ICR. Therefore, the average burden per respondent for each of the three years of analysis is calculated as 0.5/3 = 0.167 hours/year.

Reduced Fee Eligibility Determination
 The regulation establishes reduced fees for firms with a number of employees below the thresholds listed in 40 CFR 700.43 "Definitions applicable to this subpart" or fewer than 500 employees if the firm is not in an industry sector that appears in that table. EPA estimates 0.5 hours of managerial burden to review the employee-based threshold established for firms eligible for a reduced fee and compare that threshold to the firm's number of employees to determine eligibility for the reduced fee. EPA assumes that the proportion of firms that will incur this burden is roughly equivalent to the proportion of affected firms that are small businesses, as defined by the Small Business Administration (SBA). EPA estimates that SBA-defined small businesses account for four in 15 firms for TSCA section 4 actions, about 35% of affected firms for TSCA section 5 actions, and 27 of the 150 total firms for TSCA section 6 actions. This may be an overestimate as some small businesses will already know their size status under SBA size standards and will, therefore, not spend the time to confirm eligibility for the reduced fee. This burden is assumed to occur once for each affected firm over the three-year period of this ICR. Since EPA assumes that no firm will be subject to any of the TSCA section 4, 5, or 6 actions more than once over the three-year period of this ICR, the average burden per respondent is calculated as 0.5/3 = 0.167 hours/year.
CDX Registration
Firms subject to fee payments are required to submit information to EPA using CDX. Since companies submitting new chemical notices under TSCA section 5 are already required through existing regulations to submit these notices using CDX, burden associated with new CDX registrants under TSCA section 5 is already accounted for elsewhere in an existing ICR. Similarly, firms subject to fee-triggering activities under TSCA section 4 are already required to submit testing and other related information to EPA using CDX, so burden associated with new CDX registrants under TSCA section 4 is already accounted for elsewhere in an existing ICR. Manufacturers requesting Risk Evaluations are required to provide the submission package to EPA via CDX, so burden associated with new CDX registrants requesting Risk Evaluations is also already accounted for elsewhere in an existing ICR. While some manufacturers subject to Risk Evaluations initiated by EPA under TSCA section 6 may already be familiar with the CDX system and may be registered CDX users from prior experience with TSCA submissions, there is no way to estimate which manufacturers are familiar with CDX and which are new to the system. Therefore, EPA assumes that all 100 manufacturers subject to EPA-initiated Risk Evaluations under TSCA section 6 each year are new CDX users and, therefore, are experiencing this burden for the first time. This burden is assumed to occur once for each affected firm over the three-year period of this ICR. Since EPA assumes that no firm will be subject to any action more than once over the three-year period of this ICR, the average burden per respondent is calculated as 0.5/3 = 0.167 hours/year.

Notification of Participation in Consortium
The principal sponsor for the firms subject to TSCA section 4 or 6 actions who decide to join consortium, must notify EPA via CDX of the formation about the consortium and provide the following information: the name, address, telephone number and signature of the principle sponsor and the names and contact information for each manufacturer and/or processor associating with the consortium. For analytical purposes, EPA assumes that all firms will opt to join a consortium when possible, such that only one firm per TSCA section 4 and TSCA section 6 action will identify themselves as the principal sponsor of the consortium and experience this burden. EPA estimates that this will require 0.25 hours per year of technical burden to submit the information to EPA. EPA estimates this burden to occur once over the three-year period of this ICR. Thus, the average annual burden is calculated as 0.25/3 = 0.083 hours/year.

Self-identification and Certification
Firms that are either subject to fees or have been identified by EPA as being subject to fees under TSCA section 4 Test Rules and TSCA section 6 EPA-initiated Risk Evaluations must submit notice to EPA, identifying whether they (1) manufacture the identified chemical, (2) have already ceased manufacturing prior to the defined cutoff dates and will not manufacture for five years into the future, or (3) have not ever manufactured the chemical substance. Firms are required to provide certain basic contact information and certify their statements of Cessation and/or No Manufacture. EPA estimates that 15 firms will report this information to EPA as a result of one Test Rule per year. Similarly, 100 firms are expected to report this information to EPA as a result of approximately seven EPA-initiated Risk Evaluations per year. EPA estimates this burden to occur once per respondent over the three-year period of this ICR. Thus, the average annual burden is calculated as 2.5/3 = 0.833 hours/year.

Fee Payment via Pay.gov
Firms are required to make fee payments electronically using the secure, web-based collection portal, Pay.gov. Firms are expected to create payment accounts in Pay.gov and use one of the electronic payment methods currently supported by Pay.gov (e.g., Automated Clearing House debits (ACH) from bank accounts, credit card payments, debit card payments, PayPal or Dwolla). EPA estimates a burden of 0.5 hours per year of technical burden to collect the required information, create a Pay.gov account, and submit the fee payment. In cases where a consortium is formed, EPA expects that the principal sponsor for the consortium to be the one responsible for submitting the fee payment. For each firm submitting a fee payment through Pay.gov, the burden is estimated to occur once over the three-year period of this ICR. Since EPA assumes that no firm will be subject to any of the TSCA section 4, 5, or 6 actions more than once over the three-year period of this ICR, the average burden per respondent is calculated as 0.5/3 = 0.167 hours/year.

Reporting Costs
Labor costs are based on fully loaded wage rates. EPA obtained wage rates from the Employer Costs for Employee Compensation (ECEC) Supplementary Tables (BLS, 2020). EPA used the wage rate for Professional/Technical workers, Managers, and Office and Administrative Support in private manufacturing industries. Fringe benefits are calculated based on the ratio of benefits to total compensation from the 2020 BLS Employer Costs for Employee Compensation data series (BLS, 2020). An overhead rate of 17 percent is used based on assumptions in Wage Rates for Economic Analysis of the Toxics Release Inventory Program (Rice, 2002) and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2001). The estimated fully loaded hourly wage rate for a technical worker in this industry is $77.78. The estimated fully loaded hourly wage rate for a manager in this industry is $83.28. The estimated fully loaded hourly wage rate for clerical staff in this industry is $33.57.

Table 1: Industry Wage Rates
                                  Labor Type
                                     Wage
                               Fringes as % Wage
                             Over-head % wage [a]
                         Fringe + Overhead Factor [b]
                               Loaded Wages [c]

                                      (a)
                                      (b)
                                      (c)
                                 (d)=(b)+(c)+1
                                   (a)x(d)
Professional / Technical
                                                                        $46.65 
                                                                            50%
                                                                            17%
                                                                           1.67
                                                                        $77.78 
Managerial
                                                                        $51.65 
                                                                            44%
                                                                            17%
                                                                           1.61
                                                                        $83.28 
Clerical
                                                                        $20.54 
                                                                            46%
                                                                            17%
                                                                           1.63
                                                                        $33.57 
Footnotes:

[a] An overhead rate of 17% is used based on assumptions in Wage Rates for Economic Analysis of the Toxics Release Inventory Program (Rice, 2002), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (U.S. EPA, 2001).
[b] The inflation factor of "1" in the formula for calculating the fringe + overhead factor means wage data are not escalated to reflect inflation.
[c] Wage data are rounded to the closest cent in this analysis.

Consortia Non-Reporting Administrative Costs
The regulation allows the formation of, and payment by, consortia for firms subject to actions under TSCA sections 4 and 6. Administrative costs associated with managing a testing consortia are estimated to total 15 percent of the total laboratory costs, which could be as high as approximately $1.7 million for a "standard" testing battery. While EPA recognizes that there may be significant administrative costs associated with forming and managing consortia, for firms subject to testing requirements under TSCA section 4 actions, EPA expects that testing consortia will be formed for purposes of coordinating the required testing and will, therefore, not incur significant additional costs for coordination of the fee payment. 

For firms subject to Risk Evaluations initiated by EPA under TSCA section 6, however, the ability to form consortia for coordination of fee payment is new under TSCA and the estimated administrative costs associated with forming consortia are, therefore, accounted for in this ICR. EPA estimates the cost per consortium to form and coordinate the fee payment for an EPA-initiated Risk Evaluation as five percent of the fee for EPA-initiated Risk Evaluations (5% x $2.05 million fee/3), for a total of $34,167 in administrative costs per TSCA section 6 consortium per year. EPA estimates that one consortium will form for each Risk Evaluation initiated by EPA each year, for a total of approximately seven consortia and approximately $228,000  in non-reporting administrative consortium costs each year. 

 Information Collections
Respondent NAICS codes associated with industries most likely affected by the paperwork requirements are listed in section 5(a) of this ICR.
   
Information Collection (IC) Activities
Table 2 presents the estimated average annual burden for each IC activity described in section 5(a) of this ICR.

Table 2: Total Average Annual Burden and Costs[1]
                              Activity/Respondent
                             Number of Respondents
                              Burden per Response
                                    (hours)
                             Total Burden (hours)
                              Cost per Respondent
                                  Total Cost
                          IC 1: Rule Familiarization
Section 4 Actions
                                                                            195
                                                                          0.167
                                                                             33
                                                                        $12.96 
                                                                        $2,528 
Section 5 Actions
                                                                          1,003
                                                                          0.167
                                                                            167
                                                                        $12.96 
                                                                       $13,002 
Section 6 Actions
                                                                            150
                                                                          0.167
                                                                             25
                                                                        $12.96 
                                                                        $1,945 
               IC 2: Notification of Participation in Consortia
Section 4 Actions
                                                                             13
                                                                          0.083
                                                                              1
                                                                         $6.48 
                                                                           $84 
Section 6 Actions
                                                                              7
                                                                          0.083
                                                                           0.58
                                                                         $6.48 
                                                                           $45 
                            IC 3: CDX Registration
Section 6 Actions
                                                                            100
                                                                          0.167
                                                                          16.67
                                                                        $12.96 
                                                                        $1,296 
                  IC 4: Reduced Fee Eligibility Determination
Section 4 Actions
                                                                             52
                                                                          0.167
                                                                              9
                                                                        $13.88 
                                                                          $722 
Section 5 Actions
                                                                            350
                                                                          0.167
                                                                             58
                                                                        $13.88 
                                                                        $4,858 
Section 6 Actions
                                                                             27
                                                                          0.167
                                                                              5
                                                                        $13.88 
                                                                          $375 
                      ICS 5: Fee Payment through Pay.gov
Section 4 Actions
                                                                             13
                                                                          0.167
                                                                              2
                                                                        $12.96 
                                                                          $169 
Section 5 Actions
                                                                          1,003
                                                                          0.167
                                                                            167
                                                                        $12.96 
                                                                       $13,002 
Section 6 Actions
                                                                             10
                                                                          0.167
                                                                              2
                                                                        $12.96 
                                                                          $130 
                  IC 6: Self-Identification and Certification
Section 4 Actions
                                                                             15
                                                                          0.833
                                                                             13
                                                                        $64.82 
                                                                          $972 
Section 6 Actions
                                                                            100
                                                                          0.833
                                                                             83
                                                                        $64.82 
                                                                        $6,482 
                        Total Burden for all Activities
Section 4 Actions
                                                                            195
 
                                                                             57
                                                                        $22.95 
                                                                        $4,475 
Section 5 Actions
                                                                           1003
 
                                                                            393
                                                                        $30.77 
                                                                       $30,863 
Section 6 Actions
                                                                            150
 
                                                                            132
                                                                        $68.48 
                                                                       $10,272 
Total PRA
                                                                          1,348
 
                                                                            581
 
                                                                       $45,610 
                Included in IC 2: Consortia Non-Reporting Costs
Section 6 Actions
                                                                              7
 
 
                                                                        $34,167
                                                                      $227,778 
Total Costs
                                                                          1,348
 
                                                                            581
 
                                                                      $273,388 
[1] Values may not calculate exactly due to rounding. Total burden and cost may be overestimated due to assumptions on the number of firms in consortia and first-time users of CDX.

 Changes in the Burden Estimates from the Last Approval
There is an increase in the total estimated respondent burden compared with that identified in the ICR currently approved by OMB due to the increase in the number of entities potentially affected by this ICR and an increase in the number of information collection activities. The change in potentially affected entities reflects the number of submissions received under TSCA sections 5 and 6. EPA's burden estimates for this collection based upon historical information on the number of chemicals per premanufacture notices (PMNs), significant new use notifications (SNUNs), microbial commercial activity notices (MCANs), and exemption notices and applications  including low-volume exemptions (LVEs), test-marketing exemptions (TMEs), low exposure/low release exemptions (LoREXs), TSCA experimental release applications (TERAs), certain new microorganism (Tier II) exemptions, and film article exemptions., and actions under TSCA section 6. This change is an adjustment.

In addition, OMB has requested that EPA move towards using the 18-question format for ICR Supporting Statements used by other federal agencies and departments and is based on the submission instructions established by OMB in 1995, replacing the alternate format developed by EPA and OMB prior to 1995. EPA intends to update this Supporting Statement during the comment period to reflect the 18-question format, and has included the questions in attachment 4 to this Supporting Statement. In doing so, the Agency does not expect the change in format to result in substantive changes to the information collection activities or related estimated burden and costs.

6. PRA Burden Statement
Under the PRA, burden is defined at 5 CFR 1320.3(b). There is an increase in the number of entities (from 1,118 to 1,384) compared with that identified in the ICR currently approved by OMB.  This increase reflects EPA's estimate of actions under TSCA sections 4, 5, and 6. This change is an adjustment.

You may submit comments regarding the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden, including the use of automated collection techniques. Comments, referencing Docket ID No. EPA-HQ-OPPT-2016-0401 and OMB Control No. 2070-0208 (EPA ICR No. 2569.02), may be submitted to EPA electronically through http://www.regulations.gov. You may also send your ICR-related comments to OMB's Office of Information and Regulatory Affairs via email to OIRA_submission@omb.eop.gov, Attention: Desk Officer for the EPA. 

7. References
Rice, C. (2002). Wage Rates for Economic Analysis of The Toxics Release Inventory Program. Office of Environmental Information: U.S. Environmental Protection Agency.

U.S. Bureau of Labor Statistics (2018). Employer Costs for Employee Compensation (ECEC) Supplementary Tables: December 2006  -  March 2018. 2018.

U.S. Environmental Protection Agency (EPA). (2001) "Revised Economic Analysis for the Amended Inventory Update Rule (IUR)." Research Triangle Park. 

8. Attachments
All of the attachments listed below can be found in the docket for this ICR or using the hyperlink that is provided for the source documentation. The docket for this ICR is accessible electronically through http://www.regulations.gov using Docket ID Number: EPA-HQ-OPPT-2020-0616.

Attachments:
                                                                             1.
EPA Form No. 9600-008: Notice of TSCA Fee Action Participation. (Form is available to respondents in CDX for online submissions in CDX.) 
                                                                             2.
CDX Screen Shots & Instructions. Revised Modules for TSCA Section 5 and Section 6 Submissions.
A: Section 5 Notices and Supports User Guide  -  Primary Authorized Official 
B: Risk Evaluation Rule User Guide  -  Primary Authorized Official
                                                                            3. 
Sample Consultations Questions 
                                                                             4.
List of 18-Question Format for Future ICR Supporting Statement

