**ATTACHMENT 3**

**Premanufacture Notice (PMN) Form and Instructions**

**EPA Form 7710-25**

\[For electronic copies of the PMN Form and Instructions, see
<http://www.epa.gov/opptintr/newchems/pubs/pmnforms.htm> and follow the
appropriate links.\]

**ATTACHMENT 4**

**Calculation of Hourly Wage Rates**

**(Excerpt from Economic Impact Analysis)**

**APPENDIX A: INFLATORS AND WAGE RATES**

This appendix provides a brief discussion of the wage rates, inflators,
and methods that were used to derive the final Afully loaded@ wages used
in the calculation of quantified costs. Base hourly wages for relevant
labor categories were loaded with factors for benefits and overhead to
derive a loaded hourly rate. If the loaded hourly rate was not already
in year 2007 dollars, it was then inflated to year 2007 dollars by
multiplying by the appropriate inflation factor. The derivation of fully
loaded wages in year 2007 dollars, for each of the labor categories used
in the report, is discussed in Section A.1 and is summarized in Table
A.1. The derivation of the different inflation factors used to inflate
wages to year 2007 dollars is discussed in Section A.2 and is summarized
in Table A.2.

**A.1. Derivation of Loaded Wage Rates**

> **A.1.1 Technical, Managerial, and Clerical Labor**[^1]

The basic method used to derive loaded wage rates for technical,
managerial, and clerical personnel is described more fully in *Wage
Rates for Economic Analysis of the Toxics Release Inventory Program*
(Rice, 2002).

December 2007 average wages for technical, managerial, and clerical
labor were taken from the Employer Costs for Employee Compensation
(ECEC) report from the Bureau of Labor Statistics for all
goods-producing, private industries (BLS, 2008).[^2]

The additional cost of benefits, such as paid leave and insurance
(Afringe benefits@), specific to each labor category, are also taken
from the same BLS series. Fringe benefit as a percentage of wage is then
calculated separately for each labor category. For example, the average
wage rate in December 2007 for technical labor was \$33.25; the average
fringe benefit

was \$16.54. So fringe benefit as a percentage of wage rate for
technical labor was 16.54/33.25, or approximately 49.7%.

An additional loading factor of 17 percent is applied to wages for
overhead.[^3] This overhead loading factor is added to the benefits
loading factor, and the total is then applied to the base wage to derive
the fully loaded wage. The fully loaded wage for technical labor, for
example, is \$33.25\*(1+0.497 + 0.17) = \$33.25\*(1.667) = \$55.44.

Fully loaded costs for managerial and clerical labor were calculated in
a similar manner.

**Table A.1 Derivation of Loaded Wage Rates**

<table>
<colgroup>
<col style="width: 10%" />
<col style="width: 24%" />
<col style="width: 5%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 8%" />
</colgroup>
<thead>
<tr class="header">
<th rowspan="2"><strong>Labor Category</strong></th>
<th rowspan="2"><strong>Data Sources</strong></th>
<th colspan="3"><strong>Uninflated wages and fringes /
hour</strong></th>
<th rowspan="2"><strong>Fringe benefits as % of wage</strong></th>
<th rowspan="2"><p><strong>Over-</strong></p>
<p><strong>head as % of wage*</strong></p></th>
<th rowspan="2"><strong>Fringe + Overhead factor</strong></th>
<th rowspan="2"><p><strong>Loaded Wage Rate</strong></p>
<p><strong>before inflation</strong></p></th>
<th rowspan="2"><strong>Inflation factor</strong></th>
<th rowspan="2"><p><strong>Loaded Wage Rate</strong></p>
<p><strong>(2003 dollars)</strong></p></th>
</tr>
<tr class="odd">
<th><strong>Date</strong></th>
<th><p><strong>Wages</strong></p>
<p><strong>$</strong></p></th>
<th><p><strong>Fringe benefits</strong></p>
<p><strong>$</strong></p></th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td>Technical</td>
<td><em>BLS Employer Costs for Employee Compensation</em>. Private
industry, goods-producing industries, Profess. specialty &amp;
<strong>technical</strong>. Dec 03. [BLS, 2008]</td>
<td><p>Dec</p>
<p>2007</p></td>
<td>$33.25</td>
<td>$16.54</td>
<td>49.7%</td>
<td>17%</td>
<td>1.667</td>
<td>$55.44</td>
<td>1</td>
<td>$55.44</td>
</tr>
<tr class="even">
<td>Managerial</td>
<td><em>BLS Employer Costs for Employee Compensation</em>. Private
industry, goods-producing industries, Exec, admin, &amp;
<strong>managerial</strong>. Dec 03. [BLS, 2008]</td>
<td>Dec 2007</td>
<td>$41.40</td>
<td>$19.74</td>
<td>47.7%</td>
<td>17%</td>
<td>1.647</td>
<td>$68.18</td>
<td>1</td>
<td>$68.18</td>
</tr>
<tr class="odd">
<td>Clerical</td>
<td><em>BLS Employer Costs for Employee Compensation</em>. Private
industry, goods-producing industries, Admin support, incl.
<strong>clerical.</strong> Dec 03. [BLS, 2008]</td>
<td><p>Dec</p>
<p>2007</p></td>
<td>$16.40</td>
<td>$8.28</td>
<td>50.5%</td>
<td>17%</td>
<td>1.675</td>
<td>$27.47</td>
<td>1</td>
<td>$27.47</td>
</tr>
</tbody>
</table>

\*An overhead rate of 17 percent applied to wages is used for
consistency with recent EPAB economic analyses for two major
rulemakings: *Wage Rates for Economic Analyses of the Toxics Release
Inventory Program*, June 10, 2002, and the *Revised Economic Analysis
for the Amended Inventory Update Rule: Final Report*, August 2002.

Note: Calculations are based on unrounded values, so the total may not
equal the product of the rounded factors.

> **A.2. Derivation of Inflation Factors**

In general, wages were inflated using the appropriate Employment Cost
Index (ECI), seasonally adjusted. Complete information on the derivation
of the inflation factors used is given in Table A.2 below.

**Table A.2 Derivation of Inflation Factors**

+--------+--------+------------------+------+-------+-------+-------+
| **     | **     | **Inflator data  | **   | **Inf | **Inf | *     |
| Report | Item** | source**         | Star | lator | lator | *Infl |
| sec    |        |                  | ting | for   | for   | ation |
| tion** |        |                  | ye   | sta   | 2003  | fac   |
|        |        |                  | ar** | rting | (B)** | tor** |
|        |        |                  |      | year  |       |       |
|        |        |                  |      | (A)** |       | **(B) |
|        |        |                  |      |       |       | /     |
|        |        |                  |      |       |       | (A)** |
+--------+--------+------------------+------+-------+-------+-------+
| S      | Export | BLS Employ. Cost | 1992 | 63.2  | 103.6 | 1.639 |
| ection | notifi | Index, Seas.     |      |       |       |       |
| 3      | cation | Adj., White      |      |       |       |       |
|        |        | Collar           |      |       |       |       |
|        |        | Occupations      |      |       |       |       |
|        |        | Series           |      |       |       |       |
|        |        | ECS11102I,       |      |       |       |       |
|        |        | Fourth Q, 1992   |      |       |       |       |
+--------+--------+------------------+------+-------+-------+-------+
| Ap     | Agency | BLS Employ. Cost | 1993 | 65.5  | 103.6 | 163.1 |
| pendix | Extr   | Index, Seas.     |      |       |       |       |
| C      | amural | Adj., White      |      |       |       |       |
|        | costs  | Collar           |      |       |       |       |
|        |        | Occupations      |      |       |       |       |
|        |        | Series           |      |       |       |       |
|        |        | ECS11102I,       |      |       |       |       |
|        |        | Fourth Q, 1993   |      |       |       |       |
+--------+--------+------------------+------+-------+-------+-------+

**APPENDIX B: AGENCY COSTS**

EPA's costs to review and process industry submissions (SNUNs, requests
to modify SNUR, and requests for equivalency determination) are assumed
to be the same as EPA costs to review PMNs. EPA's costs associated with
SNUR submissions are presented in Table B.1. The EPA staff level
(GS-12), staff-year full-time equivalents (FTEs) and extramural costs
such as costs for contractor support are derived from the costs
estimated for processing PMN submissions (RIB, 1994). The percent of
cases are from RIB 1994 and from a 1999 SNUR economic analysis (EPAB,
1999). FTE costs have been calculated using 2007 GS-12 salary data (OPM,
2008) and a loading factor of 1.6 to reflect fringe benefits and
overhead (OPPE, 1992).

The original PMN cost estimates were presented as low and high
estimates, based on the most junior (Step 1) and the most senior (Step
10) GS-12 pay rates, respectively. For simplicity, this analysis uses
the average of the two pay rates.

The GS-12 costs in the table below are calculated by multiplying the
number of FTEs (in the first column) by the fully loaded average salary,
\$122,854. This shows EPA staff cost for those chemicals requiring this
review step. The Extramural Cost column shows costs for contractor
support and other outside purchases for those chemicals requiring this
review step, inflated from 1993 prices to 2007 using the Employment Cost
Index, Total Compensation for White-Collar Occupations (BLS, 2008a)*.*
The Weighted Cost column is calculated by multiplying GS-12 staff cost
plus extramural costs (Unweighted Cost) by the percentage of cases
requiring this review step. This calculation yields total Agency costs
for submission review and processing of \$4,203 per case.

+------------------+-----+------+-----+------+-------+----+---------+---+
| **Table B.1      |     |      |     |      |       |    |         |   |
| Agency Costs for |     |      |     |      |       |    |         |   |
| SNUN and Other   |     |      |     |      |       |    |         |   |
| Submission       |     |      |     |      |       |    |         |   |
| Review and       |     |      |     |      |       |    |         |   |
| Processing**     |     |      |     |      |       |    |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| **Review Step**  | *   | *    | *   |      | **    | ** | **W     |   |
|                  | *EP | *EPA | *Ex |      | Unwei | Pc | eighted |   |
|                  | A** | s    | tra |      | ghted | t. | Cost**  |   |
|                  |     | taff | -mu |      | C     | ** |         |   |
|                  | *   | (    | ral |      | ost** |    |         |   |
|                  | *FT | GS-1 | Cos |      |       | ** |         |   |
|                  | E** | 2)** | t** |      |       | of |         |   |
|                  |     | (a)  |     |      |       | C  |         |   |
|                  |     |      |     |      |       | as |         |   |
|                  |     |      |     |      |       | es |         |   |
|                  |     |      |     |      |       | ** |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
|                  |     |      | **1 | **   |       |    |         |   |
|                  |     |      | 993 | 2007 |       |    |         |   |
|                  |     |      | dol | d    |       |    |         |   |
|                  |     |      | lar | olla |       |    |         |   |
|                  |     |      | s** | rs** |       |    |         |   |
|                  |     |      |     | (b)  |       |    |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
|                  | \(  | \    | \(  | \    | (     | \  | (7)=(   |   |
|                  | 1\) | (2\) | 3\) | (4\) | 5)=(2 | (6 | 5)\*(6) |   |
|                  |     |      |     |      | )+(4) | \) |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| Prenotice        | 0.0 | \$29 | 4   | \$   | \$3   | 4  | \       |   |
| consultation     | 024 | 4.85 |     | 6.32 | 01.17 | 1% | $123.48 |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| Administrative   | 0.0 | \$29 | 92  | \$14 | \$4   | 10 | \       |   |
| prescreen/notice | 024 | 4.85 |     | 5.54 | 40.39 | 0% | $440.39 |   |
|                  |     |      |     |      |       |    |         |   |
| receipt/user fee |     |      |     |      |       |    |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| CRSS (Chemical   | 0.0 | \$30 | 268 | \$42 | \$7   | 10 | \$      |   |
| Review and       | 025 | 7.14 |     | 3.98 | 31.12 | 0% | 731.127 |   |
| Search Strategy) |     |      |     |      |       |    |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| SAT (Structure   | 0.0 | \$7  | 14  | \$2  | \$    | 10 | \$95.86 |   |
| Activity Team)   | 006 | 3.71 |     | 2.15 | 95.86 | 0% |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| Engi             | 0.0 | \$18 | 56  | \$8  | \$2   | 10 | \       |   |
| neering/Exposure | 015 | 4.28 |     | 8.59 | 72.87 | 0% | $272.87 |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| Exposure/Fate    | 0.0 | \$9  | 0   | \$   | \$    | 10 | \$98.28 |   |
|                  | 008 | 8.28 |     | 0.00 | 98.28 | 0% |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| Focus            | 0.0 | \$9  | 23  | \$3  | \$1   | 10 | \       |   |
|                  | 009 | 8.28 |     | 6.39 | 34.67 | 0% | $134.67 |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| Standard Review  | 0.0 | \$   | 511 | \$80 | \$3,4 | 2  | \$1,0   |   |
| Functions        | 219 | 2,69 |     | 8.40 | 98.90 | 9% | 14.6896 |   |
|                  |     | 0.50 |     |      |       |    |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| Division         | 0.0 | \$   | 113 | \$17 | \$1,7 | 1  | \$      |   |
| Directors        | 129 | 1,58 |     | 9.22 | 64.04 | 5% | 264.614 |   |
| Meeting          |     | 4.82 |     |      |       |    |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| Order            | 0.0 | \$   | 22  | \$3  | \$2,1 | 3% | \$64.07 |   |
| Develop          | 171 | 2,10 |     | 4.80 | 35.60 |    |         |   |
| ment/Negotiation |     | 0.80 |     |      |       |    |         |   |
| Review           |     |      |     |      |       |    |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| Post Order Data  | 0.0 | \$1  | 0   | \$   | \     | 3% | \       |   |
| Review           | 886 | 0,88 |     | 0.00 | $10,8 |    | $326.55 |   |
|                  |     | 4.86 |     |      | 44.86 |    |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| Order            | 0.2 | 2    | 0   | \$   | \     | 3% | \       |   |
| Modification     | 167 | 6,62 |     | 0.00 | $26,6 |    | $798.67 |   |
|                  |     | 2.46 |     |      | 22.46 |    |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| New Chemical     | 0.0 | \$   | 85  | \$13 | \$3,5 | 7% | \$      |   |
| SNUR Development | 277 | 3,40 |     | 4.67 | 37.53 |    | 247.671 |   |
|                  |     | 3.06 |     |      |       |    |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| Notices of       | 0.0 | \$14 | 40  | \$6  | \$2   | 3  | \$65.32 |   |
| Commencement     | 012 | 7.42 |     | 3.28 | 10.70 | 1% |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| FOIA (Freedom of | 0.0 | \$   | 287 | \$45 | \$4,5 | 1% | \$45.45 |   |
| Information Act) | 333 | 4,09 |     | 4.03 | 45.07 |    |         |   |
| Requests         |     | 1.04 |     |      |       |    |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| CBI              | 0.0 | \$4  | 3   | \$   | \$    | 10 | \$53.89 |   |
| (Confidential    | 004 | 9.14 |     | 4.75 | 47.04 | 0% |         |   |
| Business         |     |      |     |      |       |    |         |   |
| Information)     |     |      |     |      |       |    |         |   |
| Substantiation   |     |      |     |      |       |    |         |   |
+------------------+-----+------+-----+------+-------+----+---------+---+
| **TOTAL**        |     |      |     |      |       |    | **\$    |   |
|                  |     |      |     |      |       |    | 4,778** |   |
+------------------+-----+------+-----+------+-------+----+---------+---+

Sources: FTEs per review step and 1993 extramural costs are from RIB
1994. Percents of cases are from RIB, 1994 and EPAB, 1999. GS-12
salaries are from OPM, 2008.

\(a\) The average of GS-12 Step 1 and GS-12 Step 10 salaries for 2007
was (\$66,767 + \$86,801) / 2 = \$76,784. This was multiplied by an
assumed loading factor of 1.6 to reflect fringe benefits and overhead,
resulting in a fully loaded cost per FTE of 1.6 X \$76,784 = \$122,854.

\(b\) Extramural costs consist of contracting support and other
purchases directly attributable to the PMN review process. They were
inflated from 1993 prices to 2007 prices using a factor of 1.433 (see
Appendix A).

**ATTACHMENT 5**

**Selection Criteria \-- TSCA Section 8(a) Rule vs. SNUR**

SELECTION CRITERIA: These criteria serve as guidelines and not as rigid
standards for the regulatory selection process.

[SECTION 8(a) Rules -- REQUIREMENTS, TYPES OF DATA, USES]{.underline}:

-- [Statutory prerequisites]{.underline}: None (i.e., no required risk
findings) other than a legitimate Agency need for such data "as the
Administrator may reasonably require" and the use of notice and comment
rulemaking for the establishment of reporting requirements.

-\_\_[Scope]{.underline}: EPA can require reporting by manufacturers,
importers, and processors of both new (PMN) and existing (initial
Inventory) chemical substances.

-\_\_[Types of data]{.underline}: EPA may use section 8(a) rules to
obtain a variety of health and environmental data, including data on
chemical identity and structure, uses, volume of
production/importation/processing, byproducts, health and environmental
effects, exposure, and disposal.

-\_\_[Data support functions]{.underline}: Section 8(a) rules provide
background exposure-related data to support chemical risk assessment;
e.g., data support for section 4 testing decisions, voluntary testing
decisions, section 6 rulemaking, section 9 referral actions, follow-up
SNURs, and chemical advisories.

-\_\_[Follow-up monitoring function]{.underline}: Section 8(a) rules can
be used to monitor certain chemical activities which may cause
significant new or ongoing exposures to the subject chemicals (i.e.,
section 8(a) reporting rules can be triggered by the commencement of
certain prescribed chemical activities or by prescribed changes in
chemical activities); this type of section 8(a) rule ensures that EPA
will receive notification and information concerning the chemical
activities described in the rule; however, the Agency can only take
follow-up action through lengthy rulemaking (via section 4, 5(a)(2), or
6) or by civil action in cases of extreme and imminent hazard (via
section 7).

[CRITERIA THAT FAVOR DEVELOPMENT OF A SECTION 8(a) RULE]{.underline}

-\_\_[A need to gather data for chemical risk assessment, with no
perceived need for immediate short-term control action]{.underline}: The
basic data support function described above is the primary function of
section 8(a) rules.

-\_\_[Lesser health and environmental concerns]{.underline}: If EPA
intends to develop a follow-up/monitoring rule for a particular chemical
substance, the Agency would favor a section 8(a) rule when the level of
OPPTS concern regarding health and environmental effects of the chemical
is not sufficient to require that follow-up action be immediately
available (under section 5(e) or 5(f)) once the reporting requirement is
triggered and notification is received by EPA (e.g., the substances is
an eye or skin irritant; EPA lacks sufficient data on health and
environmental effects for purposes of risk assessment; the substance may
cause transient neurotoxic effects; the substances has moderate acute
toxicity; the substance may persist in the environment; the substance
may cause organ damage or reduced sperm counts; chronic exposure to the
substance may result in health effects that generally are reversible).

-\_\_[Activities are ongoing]{.underline}: If EPA intends to develop a
follow-up/monitoring rule for a particular chemical substance, the
Agency would favor a section 8(a) rule when the chemical activities in
question are ongoing at the time of rulemaking (i.e., currently taking
place or recently ceased and likely to resume) or are likely to be
ongoing when the rule is proposed. By definition, a SNUR would not be
possible under such circumstances.

-\_\_[A need for long-term monitoring]{.underline}: A section 8(a) rule
is favored if OPPTS needs to monitor industry-wide production and
exposure trends on a long-term basis, as in the following examples:

> \(1\) The rule may be triggered by a number of different firms over
> time, and the activity eventually may be considered ongoing (thereby
> preventing a SNUR);
>
> \(2\) The rule may be triggered a number of times by the same firm,
> and the activity may be considered ongoing;
>
> \(3\) Potential increases in exposure are expected to occur gradually
> over time and/or at a number of independent sites, making it necessary
> for the Agency to gather, aggregate, and analyze exposure-related data
> before making a decision about the potential for unreasonable risk.

[SECTION 5(a)(2) SNURS -- REQUIREMENTS, TYPES OF DATA,
USES]{.underline}:

-\_\_[Statutory prerequisites]{.underline}: TSCA does not require a risk
finding for SNURs. The only statutory requirements are (1) that EPA
consider "all relevant factors" (including the four exposure-related
factors in section 5(a)(2)) before designating a significant new use,
and (2) that the use not be ongoing at the time the SNUR is promulgated
(i.e., not currently taking place or recently ceased and likely to
resume).

-\_\_[Scope]{.underline}: SNURs may be applicable to manufacturers,
importers, and processors of both new and existing chemical substances.

-\_\_[Types of data]{.underline}: EPA is authorized to require SNUR
notice submitters to report the same types of data as may be required
under section 8(a), plus certain types of test data in certain limited
cases (note that health and environmental data must already be in the
"possession or control" of the person submitting the notice (other
health and environmental data which are known to or reasonably
ascertainable by the person submitting the notice, which need only be
described)); EPA generally requires SNUR respondents to complete the PMN
reporting form.

-\_\_[Follow-up monitoring function]{.underline}: SNURs can serve
largely the same monitoring/notification/ information function as
section 8(a) rules, with three important differences:

> \(1\) A significant new use must be an activity that is not ongoing at
> the time the SNUR is promulgated;
>
> \(2\) A SNUR respondent cannot commence the significant new use while
> EPA is evaluating the data in the SNUR notice;
>
> \(3\) TSCA authorizes EPA to take immediate follow-up control action
> under either section 5(e) (the Agency lacks data but determines that
> the activity may present an unreasonable risk) or section 5(f) (the
> activity will present an unreasonable risk and section 6 action is
> necessary).

[CRITERIA THAT FAVOR DEVELOPMENT OF A SECTION 5(a)(2) SNUR]{.underline}:

-- [Greater health and environmental concerns]{.underline}: If the
potential health and environmental hazards posed by a chemical substance
are of sufficient concern to OPPTS that the Agency wants to be able to
do the following:

> \(1\) Monitor potential exposure/risk which may be caused by
> non-ongoing activities involving the subject chemical;
>
> \(2\) Prevent these activities from occurring until OPPTS has
> completed its assessment of the activities and has determined the
> potential for release and exposure;
>
> \(3\) Take immediately effective control action (if necessary) via
> section 5(e) or 5(f) to prevent the activities from occurring (at
> least on an interim basis) after the completion of Agency review
> (e.g., the substance is a possible or probably human carcinogen; the
> substance may cause human teratogenic or reproductive effects; the
> substance has high acute toxicity; the substance tends to
> bioaccumulate in living tissue and is slow to biodegrade; chronic
> exposure to the substance may result in health effects that generally
> are irreversible).

-- [Likely that small businesses engage in the activities]{.underline}:
Section 8(a) exempts small manufacturers, importers, and processors (as
defined by EPA) from reporting requirements under that section. The
Agency therefore may not receive adequate data from a section 8(a) rule
in some cases if a substantial number of the firms subject to the rule
qualify as "small." If EPA can determine prior to rulemaking that there
is a likelihood that respondents will be small firms, the Agency may
wish to ensure that it will have access to information from these key
potential respondents by developing a SNUR for data-gathering purposes.

[OTHER CRITERIA THAT MAY AFFECT THE REGULATORY SELECTION
PROCESS]{.underline} (examined in every case):

-\_\_[Federal regulatory action and state statutory/regulatory action
involving the subject chemical]{.underline}: Relevant to the current
need for OPPTS regulatory action, the likelihood of ongoing or future
activities, and past experiences involving the subject chemical.

-\_\_[Know past and present activities and projected future activities
involving the subject chemical]{.underline} (including the size of the
firms involved, the volume of production/importation/ processing,
potential releases and exposures, etc.): If available, this information
is a relevant supplement to all of the section 8(a)/SNUR criteria listed
above.

-\_\_[Concerns and objective of EPA and the technical staff responsible
for the subject chemical]{.underline}: CCD regulatory staff relies
heavily on continuing input from management (with regard to long-term
regulatory objectives for the subject chemical) and technical staff
(with regard to health and environmental concerns and short-term
regulatory objectives).

**ATTACHMENT 6**

**Selected SNUR Case History Abstracts**

HEXACHLORONORBORNADIENE (CAS \# 2432-99-7)

> also known as HEX-BCH.

# TOXICITY

• Extremely persistent compound with a great tendency to bioaccumulate.

-   Slow biodegradation.

> Very toxic to fish.
>
> Possible analogue to known carcinogens.

II\. REFERRING OFFICE'S CONCERNS/NEEDS

> • Monitor: its manufacture, importation, and processing; intended end
> uses, and potential worker exposure and environmental releases.
>
> Once production levels reach a certain point, EPA will reconsider its
> decision not to text HEX-BCH.

III\. USES

A. [Past and Ongoing]{.underline}

> Commercial batch manufacture and processing.
>
> Intermediate in the production of isodrin which is an intermediate in
> the production of
>
> endrin (both pesticides).

B. [Small Business]{.underline}

> Capable of production by a small firm.

IV\. REGULATORY BACKGROUND

-   Listed on the Preliminary Assessment Information Rule. (One-time
    reporting only).

-   Listed on the section 8(d) model health and safety data reporting
    rule (40 CFR Part 716).

-   Local limit on its discharge in a public treatment system. Limit
    based on plant's treatment capacity and not on human health or
    environmental risk.

V. RECOMMENDATION/RATIONALE: Section 8(a) rule for ongoing uses and
significant new use rule for non-ongoing uses.

> Well documented high toxicity concern.
>
> Small businesses potential.
>
> Satisfies referring office's needs.
>
> No federal regulation exists to provide a governmental entity with an
> opportunity to
>
> evaluate potential human and environmental exposures to HEX-BCH from
> its
>
> manufacture, importation, processing, and intended end use; and to
> protect human beings
>
> and the environment from potentially adverse exposures before they
> occur.

METHYL N-BUTYL KETONE (CAS \# 591-78-6)

> also known as MBK.

# TOXICITY

• Causes central and peripheral neuropathy in humans. Nerve damage is
irreversible at concentrations as low as 50 ppm.

-   Absorbed readily through the skin.

> Eye and skin irritant.
>
> Limited evidence suggests testicular atrophy.

II\. REFERRING OFFICE'S CONCERNS/NEEDS

> • Monitor: its resumption of commercial manufacture, importation, and
> processing; intended end uses, and potential worker and consumer
> exposure.

III\. USES

A. [Past]{.underline}

> Commercial manufacture, importation and processing.
>
> Solvent in lacquers, sealers, varnish removers, oils, fats, and waxes.
> (i.e., consumer products).

B. [Ongoing]{.underline}

> Importation for toxicological research and development.

C. [Small Business]{.underline}

> Capable of production by a small firm.

IV\. REGULATORY BACKGROUND

-   Occupational Safety and Health Administration standard (8 hour Time
    Weighted Average (TWA) 100 ppm).

-   American Conference of Governmental Industrial Hygienists TWA 5 ppm.
    No binding effect.

-   National Institute of Occupational Safety and Health TWA 5 ppm. No
    binding effect.

V. RECOMMENDATION/RATIONALE: Significant new use rule.

> Well documented high toxicity concern.
>
> Small businesses potential.
>
> Satisfies referring office's needs.
>
> No federal regulation exists to provide a governmental entity with an
> opportunity to
>
> evaluate potential human and environmental exposures to MBK from its
> manufacture,
>
> importation, processing, and intended end use; and to protect human
> beings and the
>
> environment from potentially adverse exposures before they occur.

URETHANE (CAS \# 51-79-6)

> Urethane is a name commonly but improperly applied to high molecular
> weight polyurethanes used as foams, elastomers, and coatings. These
> products are not made from the urethane, and do not generate urethane
> upon decomposition.

# TOXICITY

• Urethane is well established as a carcinogen. Malignant tumors have
occurred in many species of animals following the administration of
urethane by the oral, inhalation, topical, subcutaneous, and
intraperitoneal routes. Urethane is also a transplacental carcinogen
that readily traverses the placenta and affects the fetus.

-   Toxic fumes when heated; liver toxin; bone marrow depressant.

II\. REFERRING OFFICE'S CONCERNS/NEEDS

> • Monitor: its resumption of manufacture, importation, and processing;
> intended end uses, and potential worker and consumer exposure.

III\. USES

A. [Past]{.underline}

> Commercial manufacture, importation and processing.
>
> Intermediate in the production of N-hydroxymethyl derivatives, which
> are useful as cross-linking agents for imparting wash-and-wear
> properties to fabrics.
>
> Human medicine: sclerosing agent for varicose veins and hemorrhoids,
> anti-neoplastic agent, hypnotic, treatment of chronic leukemia, and
> multiple myeloma.
>
> Pharmaceutical intermediate.

B. [Ongoing]{.underline}

> Toxicological research.

C. [Small Business]{.underline}

> Capable of production by a small firm.

IV\. REGULATORY BACKGROUND

> Banned by the Food and Drug Administration as an active and inactive
> ingredient in drugs. FDA also prohibited the use of a food
> preservative that produces urethane when it is used tin acidic
> beverages.
>
> Designated by EPA as a Toxic Hazardous Waste #238.

-   Listed as a Hazardous material under the Hazardous Materials
    Transportation Act.

V. RECOMMENDATION/RATIONALE: Significant new use rule.

> Well documented high toxicity concern.
>
> Small businesses potential.
>
> Satisfies referring office's needs.
>
> No federal regulation exists to provide a governmental entity with an
> opportunity to
>
> evaluate potential human and environmental exposures from urethane's
> manufacture,
>
> importation, processing, and intended end use; and to protect human
> beings and the
>
> environment from potentially adverse exposures before they occur.

The consequences of not collecting this information is to allow, without
EPA review, human and environmental exposures to toxic chemical
substances.

PENTABROMOETHYLBENZENE (CAS \# 85-22-3)

> also known as PEB.

# TOXICITY

• Carcinogenicity observed in other structurally related compounds
having a

polyhalogenated aromatic moiety.

-   Persistent compound with a great tendency to bioaccumulate.

> Slow biodegradation.

II\. REFERRING OFFICE'S CONCERNS/NEEDS

> • Monitor: its resumption of commercial manufacture, importation, and
> processing; intended end uses, and potential worker exposure and
> environmental release.
>
> If production is to be reinstated, EPA will reconsider its decision
> not to test HEX-BCH.

III\. USES

A. [Past and Ongoing]{.underline}

> Has been used in the past as an additive-type flame retardant.
>
> No known ongoing uses.

B. [Small Business]{.underline}

> Capable of production by a small firm.

V. REGULATORY BACKGROUND

> The Interagency Testing Committee designed PEB for priority
> consideration in its 15th report.
>
> Listed on the section 8(d) model health and safety data reporting rule
> (40 CFR Part 716).

-   Listed on the Preliminary Assessment Information Rule. (40 CFR Part
    712).

-   Proposed, pursuant to section 4(a)(1)(A) findings, that chemical
    fate and environmental effects testing be performed.

-   Proposed Test Rule withdrawn due to termination of all known
    manufacture and processing operations.

V. RECOMMENDATION/RATIONALE: Significant new use rule.

> Structurally analogous to substances of carcinogenic concern.
>
> Small businesses potential.
>
> Satisfies referring office's needs.
>
> No federal regulation exists to provide a governmental entity with an
> opportunity to
>
> evaluate potential human and environmental exposures to PEB from its
> manufacture, importation, processing, and intended end use; and to
> protect human beings and the environment from potentially adverse
> exposures before they occur.

[^1]: ^9^ Many Labor hourly rates in this analysis are lower than hourly
    rates for the same labor categories in an earlier SNUR economic
    analysis (EPAB, 1999). EPA does not mean to suggest that actual
    hourly rates declined. Rather, the apparent decline is due to a
    changed method of calculating hourly costs for the same labor
    categories. There were three changes: (1) Previously, the 17%
    overhead was applied to wages-plus-fringe benefits. Now it is
    applied only to wages. This change reduces calculated overhead. (2)
    Before, most wage rates were based on older data and then inflated
    to current dollars. Here, most wage rates are based on recent data.
    (3) Finally, fringe benefits were based on an assumed percent of
    wages. Here, private industry fringe benefits are based on actual
    fringe benefits taken from recent BLS data.

    Employer Costs for Employee Compensation, Private industry workers,
    Goods-producing industries, white-collar occupations, as published
    by the U.S. Department of Labor, Bureau of Labor Statistics. The
    December 2007 values for these series were extracted onFebruary 29,
    2008.

[^2]: .

[^3]: ^10^ An overhead rate of 17 percent applied to wages is used for
    consistency with recent EPAB economic analyses for two major
    rulemakings: *Wage Rates for Economic Analyses of the Toxics Release
    Inventory Program*, June 10, 2002, and the *Revised Economic
    Analysis for the Amended Inventory Update Rule: Final Report*,
    August 2002. In reports for an earlier SNUR (EPAB, 1999), the 17%
    was applied to wages-plus-fringe benefits. Applying it only to wages
    reduces calculated overhead.