**Supporting Statement for a Request for OMB Review under**

**The Paperwork Reduction Act**

**1. IDENTIFICATION OF THE INFORMATION COLLECTION**

**1(a) Title and Number of the Information Collection**

**Title: Partial Update of the TSCA Section 8(b) Inventory Data Base,
Production and Site Reports**

> **EPA ICR No.: 1884.04 OMB Control No.: 2070-0162**

**1(b) Short Characterization**

This document provides the estimated burden hours and costs associated
with the information collection activities of the Inventory Update
Reporting (IUR) program under the Toxic Substances Control Act (TSCA)
(40 CFR part 710). Approved under OMB Control No. 2070-0162, the
previous ICR (EPA ICR No. 1884.02) covered the information collection
activities contained in the IUR as amended in 2003.

Under TSCA section 8(b) (15 USC 2607), the Environmental Protection
Agency (EPA) is required to compile and keep current, via periodic
inquiry, the Inventory of Chemical Substances in Commerce (TSCA
Inventory). The TSCA Inventory is a listing of chemical substances
manufactured, imported and processed for commercial purposes in the
United States. The Office of Prevention, Pesticides and Toxic Substances
(OPPTS) has used the IUR to update the basic chemical production
information for selected larger volume chemicals in the TCSA Inventory
six times (every four years), beginning in 1986. Prior to the 2006
collection, EPA implemented various amendments[^1] to the IUR, including
the requirement to report manufacturing, processing, and use
exposure-related information; changes to the chemical substances subject
to reporting, such as the addition of inorganic chemical substance to
the reporting requirement and the addition of partially-exempted
chemical substance lists; changes to the reporting frequency and the
records retention period; revisions to certain CBI requirements; and
changes to the reporting threshold. The next collection, in 2011, will
also include the manufacturing, processing, and use exposure-related
data elements.

OPPTS will use the updated IUR data in its risk-management efforts.
Individual plant or factory sites producing or importing chemicals will
submit the required information. The information will be stored and used
in both hard-copy and electronic forms for reference by EPA staff and
others. Further discussion of how the information is used, stored, and
collected is included in this document.

EPA maintains databases containing the IUR data. Information submitted
prior to the 2006 IUR is maintained in a series of databases called the
Chemical Update System (CUS). The 2006 IUR and future submissions are
maintained in an IUR database in the Manage Toxic Substances (MTS)
system. Respondents either mail or electronically submit a completed
Form U, the IUR reporting form, to EPA during the reporting cycle that
now occurs every five years.

The collection is expected to involve about 4,200 respondents at an
annual cost of \$20 million. The details of the paperwork burden cost
estimates are discussed in this document.

**2. NEED FOR AND USE OF THE COLLECTION**

> **2(a) Need/Authority for the Collection**

Under TSCA, EPA is required to identify, assess, and control risks of
injury to human health and the environment posed by commercial
chemicals. Under TSCA section 8(b), EPA is required to compile and keep
current a complete list of chemical substances manufactured or processed
in the United States. Under TSCA section 8(a) the Administrator shall
promulgate rules to provide for the maintenance and collection of
records from manufacturers, importers and processors of commercial
chemicals. The Inventory Update Reporting (IUR) rule is codified at 40
CFR 710. Copies of the relevant sections of TSCA and of the Code of
Federal Regulations (CFR) are attached [(see Attachments 1 and
2).]{.underline}

Sections 8(a)(1) and (2) of TSCA authorize the Agency to collect
information on the chemical manufacturing and importing industry. Table
1 contains examples of the type of information TSCA authorizes EPA to
collect, although it is not all currently being collected. EPA possesses
broad discretion in determining the information to be reported under
TSCA section 8(a).

**Table 1. Examples of Chemical-specific Information EPA is Authorized
to Collect**

**Under Section 8(a) of the Toxic Substances Control Act**

+-----------------------------------------------------------------------+
| 1.  Common or trade name, chemical identity, and molecular structure  |
|     of each chemical substance or mixture for which reports are       |
|     required.                                                         |
+-----------------------------------------------------------------------+
| 2.  Categories or proposed categories of use for each substance or    |
|     mixture reported.                                                 |
+-----------------------------------------------------------------------+
| 3.  The total amount of each substance and mixture manufactured or    |
|     processed and each of its categories of use; reasonable estimates |
|     of the total amount to be manufactured or processed and each of   |
|     its categories of use.                                            |
+-----------------------------------------------------------------------+
| 4.  A description of the byproducts resulting from the manufacture,   |
|     processing, use, or disposal of each such substance or mixture.   |
+-----------------------------------------------------------------------+
| 5.  All existing data concerning the environmental and health effects |
|     of such substances or mixtures.                                   |
+-----------------------------------------------------------------------+
| 6.  The number of individuals exposed, and reasonable estimates of    |
|     the number who will be exposed, to such substances or mixtures in |
|     their places of employment and the duration of such exposure.     |
+-----------------------------------------------------------------------+
| 7.  The manner or method of disposal, and in any subsequent report on |
|     such substance or mixture, any change in the manner or method.    |
+-----------------------------------------------------------------------+

EPA collected basic production and site identification information under
the original IUR. The basic production information included chemical
name, chemical identification number, annual production volume, and
chemical site-limited status. Site identification information included
manufacturer or importer and site name and address and the name,
address, and phone number of a technical contact. EPA will continue to
collect this information.

Beginning with the 2006 IUR, the Agency collected basic exposure-related
manufacturing, processing and use information in addition to the
production and site identification information. These data are used to
augment and expand databases of exposure-related information that the
Agency uses in everyday, basic decision-making. Because exposure is a
key component of risk, the IUR exposure-related information allows OPPT
to screen chemicals based on the potential for risk in order to protect
human health and the environment, as required by TSCA. The
exposure-related data on manufacturing, processing, and use allow the
Agency and others to potentially avoid more burdensome requirements.
These data allow a more effective and efficient screening level review
of chemicals to identify candidates for further evaluation. By providing
the means for better prioritization of limited resources on the basis of
risk, the 2006 IUR greatly enhances the Agency's efforts to achieve
better public health, sustainable development, environmental justice,
pollution prevention, sound science, partnerships, and ecosystem
protection. The success of the New Chemicals Program---where over 47,000
chemicals have been screened using data similar to the IUR
data---demonstrates the value of having sufficient information to screen
chemicals based on an adequate representation of potential risk. These
improvements will continue with the information from the 2011 IUR.

> **2(b) Practical Utility/Users of the Data**

The IUR information collection enables EPA to collect basic information
on TSCA commercial chemicals, including current production volume,
site-related data, and manufacturing, processing, and use
exposure-related data. This information collection is necessary because
it is the only mechanism through which EPA's need for basic information
on chemicals manufactured, produced, or imported can be fully and
effectively satisfied. The information collected is utilized in the
following ways:

> \(1\) Parent company and technical contact identification information:
> These data are collected to identify the parent company responsible
> for the data.
>
> \(2\) Plant site identification information: Collected to identify the
> physical site where the manufacturing and import takes place, these
> data can assist EPA in estimating human and environmental exposure and
> to identify specific plant site operators in order to be able to
> communicate with them. As such, this information is sought for
> purposes related to regulatory activities under TSCA sections 4, 6 and
> 8.
>
> \(3\) Chemical identification information: This information is
> necessary for EPA to properly identify the chemical.
>
> \(4\) Manufacturing-related information for each chemical, including
> whether the chemical is manufactured or imported, its reporting year
> production volume, whether it is site-limited, the number of workers
> reasonably likely to be exposed to the chemical, its maximum
> concentration, and its physical form(s) and related percent production
> volume: This information is used in chemical exposure and risk
> screening, testing and/or review priority setting and exposure
> estimation required by the Interagency Testing Committee (ITC) under
> TSCA section 4; for EPA monitoring activities of newly manufactured
> substances that have completed PMN review under TSCA section 5(a); to
> support the development of TSCA regulations under section 6; and to
> measure potential of human and environmental exposure under TSCA
> section 8(e). Each data element corresponds to a data point necessary
> for basic risk-screening \-- for example, a site-limited intermediate
> chemical is presumed to have lower exposure potential because it is
> not distributed outside the manufacturing plant for commercial
> purposes.

Some respondents must also report for chemicals produced in excess of
300,000 pounds on a per-site basis:

> \(5\) Industrial processing and use data, including types of
> industrial use and associated industry NAICS codes, industrial
> function, estimated number of sites, and estimated numbers of workers
> reasonably likely to be exposed: These data are used to determine
> exposure potential based on industrial processing and use, including
> related environmental releases.
>
> \(6\) Commercial and consumer end-use exposure data, including
> categories of products, the maximum concentration in each category,
> and whether the chemical is used in products intended for children:
> These data are used to determine exposure potential based on consumer
> and commercial use, including related environmental releases.

Information secured through the IUR collections is increasingly used by
a wide variety of governmental and non-governmental users. Consistent
with Congress's intent that TSCA data be used to facilitate any
government public health and environment efforts, IUR data have been
used by EPA's Office of Water, Office of Solid Waste and Emergency
Response, and Office of Air and Radiation to identify and characterize
particular chemical substances. Non-confidential IUR data are
incorporated into a number of databases and products maintained by
organizations including Right-To-Know-Net and INFORM[^2]. IUR data were
used to identify chemicals of particular concern for the National
Institutes of Health. Non-confidential IUR data were also released to
selected states to help them identify facilities manufacturing suspected
endocrine disrupters.

Under TSCA, EPA has an obligation to protect human health and the
environment from unreasonable risks associated with chemicals under its
jurisdiction. In order to evaluate potential chemical risks, EPA has
determined that a portion of the chemicals (both organic and inorganic)
on the TSCA Inventory currently warrant the continued collection of
manufacturing information, and that a subset of those chemicals (i.e.,
those produced in quantities of 300,000 pounds or more at a site)
currently warrant the collection of supplementary processing and use
information. The IUR provides an accurate and readily available source
of basic manufacturing information for about 7,600 of the 83,000
substances listed on the Inventory and basic processing and use
information for a subset of about 4,500 substances, thus significantly
limiting industry's reporting burden while providing EPA with
information necessary to conduct screening level assessments for risks
to human health and the environment.

Improving the Agency's ability to set priorities results in a variety of
benefits. Agency resources will be more efficiently and effectively
directed to high priority chemicals of concern. Industry efforts to
address chemicals of concern will also be better targeted. Overall,
public and private resources will be maximized and public health and the
environment will be better protected.

EPA uses the information submitted through this collection to update the
Agency's comprehensive chemical manufacturing, exposure, and use
database, maintained as part of the Manage Toxic Substances (MTS)
system. IUR data prior to the 2006 collection are maintained in a series
of databases known as the Chemical Update System (CUS). The MTS IUR
data, combined with CUS and the Chemicals in Commerce Information System
(CICIS) database, serves as a primary source of information for EPA, as
well as other Federal Agencies, about the chemical industry - the
chemicals used, where they are produced, how much is produced or
imported, and how they are processed and used. The chemical industry is
dynamic, therefore continual updating of the database is necessary.

EPA collects readily obtainable (to the manufacturer or importer)
exposure-related data that can be used to better establish priorities
for EPA's Existing Chemical Assessment program. The IUR data elements
are related to or are indicative of three components of exposure. These
components are: (1) the size of human populations potentially exposed,
(2) the potential routes of exposures experienced by the environment or
humans, and (3) the frequency and duration of potential exposures.
Examples of data elements of interest for each component are:

-   The size of human populations potentially exposed can be estimated
    based on several factors: production volume, number of workers
    reasonably likely to be exposed, downstream industrial and
    commercial uses, and types of industries using the chemical
    substance.

-   The potential routes, magnitudes, and concentrations of exposures
    can be estimated based on the physical state of the chemical, how it
    is used, and the concentration of the chemical.

-   The frequency and duration of potential exposures can be estimated
    based on the type of industrial or commercial and consumer use and
    the type of population.

EPA has demonstrated the usability of the 2006 IUR data by making
public, less than a year after the close of the 2006 IUR submission
period, risk-based prioritization documents providing screening-level
exposure and risk assessments for a number of chemicals in the Agency's
HPV Challenge program. These screening-level assessments rely on the IUR
manufacturing, processing, and use exposure-related information.

EPA's careful design of the IUR data collection facilitated efficient
data management and use. Data collected through the 2006 IUR are placed
into a relational database in the Agency's Manage Toxic Chemicals (MTS)
system, which can be easily searched, compared, and used. The collection
of specific data, organized by codes, instead of textual information
presented in an unstructured manner, lends itself to such a database
format. In addition, electronic IUR submissions allow data to be entered
into the database more accurately and expeditiously, resulting in a
quick turnaround between the submission of the data to the Agency and
the availability of the data for use. More than half of all reports were
submitted electronically for the 2006 IUR, and the Agency expects that
figure to increase in subsequent years.

[Data Uses]{.underline}

Data generated by the IUR are used in a wide variety of programs
fundamental to fulfilling the Agency's TSCA statutory mandate. EPA's
primary use of these data is to identify priority TSCA chemicals for
more detailed information gathering, risk assessment, and risk
management, and to develop targeted programs to protect human health and
the environment. Since screening chemical risks generally requires a
combination of both hazard and exposure information, the absence of
exposure-related data beyond production volume data in the previous
collection cycles severely limited the utility of the IUR data for risk
screening. This lack of exposure-related data made it difficult for EPA
and others to identify chemicals of concern, or resulted in generating
overly conservative exposure assessments based on incomplete
information. The IUR manufacturing, processing, and use exposure-related
data, compiled into a searchable database format, enable EPA and others
to more readily screen chemicals for potential exposure and risk. These
reviews allow EPA and others to better prioritize chemicals to identify
those warranting more detailed assessments, and to reprioritize
chemicals of lower concern for review. Current and potential uses of
these data by EPA and others are discussed below. Note that these
examples are illustrative, not exhaustive. Programs using the IUR data
range from the more traditional existing chemicals risk screening
efforts, such as the Chemical Assessment and Management Program (ChAMP),
to voluntary programs, such as Design for the Environment (DfE), to
individual requests for analysis of chemicals not specifically
associated with a particular program. The Agency anticipates that, as
was true even for the basic production data reported under previous
collections, new uses of current IUR data by EPA and by others will
continually emerge and cannot be predicted at this time.

The New Chemicals Program's PMN review process provides an excellent
example of how IUR data can assist EPA in protecting human health and
the natural environment. EPA uses exposure-related data from PMNs to
generate screening-level risk assessments for regulatory decision making
under TSCA section 5. Using this information in combination with
technical references and other research, EPA is able to estimate the
number of manufacturers who may use a new substance. EPA also is able to
estimate releases of the new substance from processing and from product
manufacturing, resulting in estimated environmental concentrations of
the new substance due to its release and estimated general population
exposures to a new substance. EPA also uses the information on
processing and use in combination with data and modeling to estimate the
numbers of workers and consumers who may be exposed to a new substance,
and their estimated exposures to a new substance. Based on the estimated
hazards of a new substance, it is determined whether the exposures to
the new substance estimated for potentially-exposed workers, general
population, consumers, and aquatic species fall below levels of concern.
A similar process for existing chemicals is now possible with the IUR
data.

[Current Uses of the 2006 IUR Data]{.underline}

-   The Security and Prosperity Partnership of North America (SPP)
    program is a collaboration among the United States, Canada, and
    Mexico to accelerate and improve effectiveness of actions to
    safeguard the health and environment, provide cost-effectiveness for
    businesses and governments, and strengthen regulatory authority.

-   EPA initiated the Chemical Assessment and Management Program (ChAMP)
    to fulfill commitments made under SPP. The Agency is developing
    screening-level Risk-based Prioritization (RBP) documents that
    summarize basic hazard and exposure information on HPV Challenge
    program chemicals, identify potential risks, note scientific issues
    and uncertainties, and indicate the initial priority being assigned
    by the Agency for potential future appropriate action. The 2006 IUR
    data is essential to the development of these RBP documents,
    providing the screening level exposure-related data necessary for
    the initial priority determination.

-   The IUR data provides EPA with the ability to access and initiate
    appropriate action on over 6,750 existing chemicals which have
    production volumes of 25,000 pounds per year by 2012. The Agency is
    using the 2006 IUR data to develop screening-level assessments for
    Medium Production Volume (MPV) Chemicals.

-   The TSCA Interagency Testing Committee (ITC) has requested IUR data
    to identify chemicals as candidates to recommend for further testing
    or information reporting. In this process, the ITC eliminates many
    chemicals for which the ITC does not recommend further testing. The
    ITC has fourteen (14) U.S. Government member organizations**:** the
    Agency for Toxic Substances and Disease Registry (ATSDR), Council on
    Environmental Quality (CEQ), Consumer Product Safety Commission
    (CPSC), Department of Agriculture (USDA), Department of Defense
    (DOD), Food and Drug Administration (FDA), Department of the
    Interior (DOI), EPA, Department of Commerce (DOC), National Cancer
    Institute (NCI), National Institute of Environmental Health Sciences
    (NIEHS), National Institute for Occupational Safety and Health
    (NIOSH), National Science Foundation (NSF), and Occupational Safety
    and Health Administration (OSHA). The ITC will use the IUR
    information to refine its selection of chemicals for testing,
    information reporting, or another recommendation. In the past, the
    primary exposure information the ITC used is production volume from
    the IUR; the addition of use and exposure information allows ITC to
    refine its recommendations. For instance, in 1991, OSHA asked ITC to
    review a list of chemicals to recommend for dermal absorption
    testing - ITC recommended 80 chemicals for testing. With the
    additional IUR information, ITC could have screened those 80
    chemicals and provided a more accurate, targeted recommendation.

-   The U.S. Geological Survey (USGS) has requested IUR information to
    help prioritize chemicals in their National Water Quality Assessment
    Program.

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

**3(a) Non-Duplication**

The data included in this information collection (i.e., production
volume, chemical manufacture, exposure, and use data) are not
comprehensively or systematically collected at the national level. There
are a variety of sources for pieces of the information, but the sources
are either incomplete or incompatible. For instance, information
currently available at both the federal and state levels is collected to
support specific federal and state programs, initiatives, or regulatory
actions. As an example, under EPCRA sections 311 and 312, states collect
data on the maximum and average amount of a chemical onsite for the
purposes of emergency response planning. This information does not
substitute for the annual volume of a chemical and is not available for
use in a national-level screening program.

In the past, EPA explored a wide variety of public data sources, as
demonstrated by the following three documents: *Inventory Update
Reporting Rule (IUR) Amendments Technical Support Document:
Exposure-Related Data Useful for Chemical Risk Screening* (EPA 1996a),
*Revised Economic Analysis of the Amended Inventory Update Reporting
Rule* (EPA 2002a), and *A Review of Existing Exposure-Related Data
Sources and Approaches to Screening Chemicals: A Response to CMA* (EPA
1999). These documents contain extensive discussions of chemical
information collections and conclude that the information collected in
the IUR program is not available elsewhere. EPA has spent considerable
effort and resources evaluating other data sources that could
potentially provide the accurate and up-to-date information that the
Agency needs. A primary consideration, as mandated by TSCA, was to not
subject industry to unnecessary or duplicative reporting. The
information sought under the IUR is not accessible to EPA through other
means. Although some useful data exist in some sources, the data are
insufficient due to a lack of scope, currency, and detail. Without the
IUR, EPA can not update the TSCA Inventory as required by law, and
remains unable to efficiently screen potential risks posed by a large
number of chemicals on the TSCA Inventory.

One mechanism in particular received scrutiny from EPA as an alternative
to the current IUR: the TSCA Preliminary Assessment Information
Reporting (PAIR) rule (40 CFR part 712). EPA does not feel that PAIR
would be an efficient or cost-effective way to compile a database to
allow the large-scale risk screening of chemicals on the TSCA Inventory.
PAIR is a useful data collection tool when one or a small group of
chemicals is targeted for risk assessment; however, PAIR is limited when
collecting information on a large number of chemicals. Additionally, the
PAIR rule has fewer, less definitive data elements than the IUR, is a
one-time collection versus the five year collection cycle of the IUR,
and will not provide data sufficient to meet the goals of the IUR. Use
of PAIR only implies that EPA should continue to set risk-screening
priorities based on hazard and production volume alone, or in response
to requests from others. This approach greatly hinders EPA's ability to
make effective and efficient risk management decisions.

EPA continues to use existing data sources and information sets.
However, the existing sources are generally best used when conducting a
more detailed risk assessment of a specific chemical of concern, rather
than preliminary risk screening of a large set of chemicals. The 2006
and later IUR submissions provide a consistent set of screening-level
exposure data that allow EPA to better identify on a relative basis the
chemicals of highest priority for further risk evaluation. EPA uses the
IUR data to identify those specific chemicals that are of potential
concern and need follow up assessment. For instance, the IUR
exposure-related data coupled with the HPV Challenge Program hazard data
provide the input needed to effectively develop risk-based priorities
for more detailed assessment of chemicals. Once EPA has determined that
a specific chemical (or group of chemicals) has sufficient potential for
exposure to warrant further assessment, the Agency will utilize the
other information sources and data gathering tools as appropriate.

The IUR focuses on information specific to the manufacture and use of
chemicals, including exposure potentials during various activities; this
information is not available elsewhere. One past source of data, NIOSH's
National Occupational Exposure Survey (NOES), represented a valuable
source of data concerning the number of exposed workers. NOES was
completed in 1981 and is now recognized as being significantly dated.
Furthermore, information regarding chemical use has never been collected
in a systematic manner.

**3(b) Public Notice Required Prior to ICR Submission to OMB**

Prior to submission to OMB, this ICR will be made available to the
public for comment through a Federal Register notice. The public will
have 60 days to provide comments. Any comments received will be given
consideration when completing the supporting statement that is submitted
to OMB.

**3(c) Consultations**

Consultations will occur after publication in the Federal Register.

**3(d) Effects of Less Frequent Collection**

The Agency needs to be able to make accurate chemical regulatory
decisions in a timely and cost effective manner, especially since
alternative data sources do not exist for these data. The effect of less
frequent collection of these data is to significantly diminish the
Agency's ability to understand the chemical industry and monitor the
production levels of chemicals produced or imported in the United
States. Based on IUR data, the statistics show that chemical industry
product lines and manufacturing in the United States change rapidly from
one reporting period to the next. This demonstrates that the IUR
collection needs to be undertaken on an ongoing basis in order for the
Agency to fulfill its mandate to keep the TSCA Inventory current under
section 8(b) of TSCA.

Despite these issues, EPA decreased the frequency of collection from
every four years to every five years when promulgating the 2003
Amendment (*see* 68 FR 848, January 7, 2003). Any further decrease in
the reporting frequency would jeopardize the utility of the data in
decision making. Experience with the past IUR collections illustrates
that from one collection to the next collection, there was a turnover in
chemicals reported of about 25-30%; that is, twenty-five to thirty
percent of the chemicals reported in one collection year were not
reported in the next collection year. Less frequent collection is
expected to increase this turnover, reducing the utility of the
database.

Other dynamic aspects of the chemical industry are less easy to measure.
Production volumes or chemical uses can change from one year to the
next, due to activities such as changing market conditions, batch
processing, or the development of new uses for the chemical. Production
sites switch owners and the products produced at a site can change. Less
frequent collection would mean the EPA could be using outdated
information, making decisions that reflect a situation no longer in
existence.

**3(e) General Guidelines**

This collection does not exceed any of the Paperwork Reduction Act
guidelines at 5 CFR 1320.6, with the exceptions listed below.

The record retention period of this collection is five years, exceeding
the PRA maximum of three years. This is necessary to ensure companies
retain records long enough to facilitate completion of Form U (EPA Form
7740-8) in the next collection, which is in five years, and to allow
EPA's enforcement activities to cover two IUR reporting cycles.

Confidential Business Information (CBI) claims limit access to the IUR
data, especially by the general public. EPA recognizes that some
information submitted to the Agency is legitimately business
confidential; because of this, EPA's review of CBI data is an inherently
governmental function that EPA must perform to protect human health and
the environment.

**3(f) Confidentiality**

Respondents may claim information submitted to EPA under this rule as
confidential if such information would reveal the submitters' trade
secrets or proprietary information as defined by TSCA section 14 and
existing TSCA regulations. EPA has long-established procedures for
handling, storing, processing and disposing of TSCA confidential
information. Transfers of this information to other governmental
agencies can only be accomplished if the other agency agrees to adhere
to all TSCA confidentiality provisions. EPA will maintain standard CBI
procedures to protect any confidential, trade secret, or proprietary
information from disclosure in accordance with EPA's confidentiality
regulation, 40 CFR Part 2, Subpart B.

**3(g) Sensitive Questions**

This collection does not include questions of a sensitive nature.

**4. THE RESPONDENTS AND THE INFORMATION REQUESTED**

**4(a) Respondent NAICS Codes**

The regulated community consists of companies manufacturing or importing
chemicals listed on the TSCA Inventory and regulated under TSCA section
8. In general, the industry segments that compose the regulated
community for the rule are those that produce or import organic and
inorganic chemicals. Most respondents previously reported information
under the IUR. Due to the past experience the Agency has had with
respondents to the IUR, it is anticipated that the majority of the
respondents affected by this collection activity are from the following
North American Industrial Classification System (NAICS) code categories:

325 - Chemical Manufacturing (including importing)

324 - Petroleum and Coal Product Manufacturing (including importing)

The subsectors identified above represent the designation of sites that
would likely be subject to IUR reporting. However, many factors relate
to the nature of these sites, making identification of the regulated
community more difficult. For example, NAICS codes reflect a site's
*primary* activity, omitting substantial participation a company may
have in other industry activities. Secondly, NAICS codes assigned to
parent companies reflect the parent company's primary activity, although
many parent companies are primarily holding companies with small
subsidiaries. Each of these small subsidiaries may belong in a
completely different industry classification based on its own primary
activity. Information on parent company NAICS codes does not provide a
very accurate characterization of the types of sites subject to
reporting, and facilities that do not fall under these categories must
still report if they meet the reporting criteria.

Generally, TSCA section 8 excludes small manufacturers (including
importers) from reporting. EPA defines small manufacturers (including
importers) for purposes of IUR and certain other reporting in 40 CFR
704.3.

**4(b) Information Requested**

***(i) Data items***

The IUR data elements are primarily related to or indicative of three
components of exposure. These components are: (1) the number of
ecosystems or size of human populations potentially exposed, (2) the
potential exposures or concentrations experienced by the environment or
humans, and (3) the frequency and duration of potential exposures. The
data enhances EPA's ability to evaluate each of these components of
exposure. Respondents are required to submit certain known or reasonably
ascertainable manufacturing exposure- related information and readily
obtainable processing and use exposure-related information.

Using Form U (EPA Form 7740-8; see Attachment 4), respondents report on
data items as follows:

-   *Certification.* Company Official must certify by signature and date
    that to the best of their knowledge and belief 1) all information
    entered on Form U has been completed in compliance with the
    regulatory requirements; and 2) that the confidentiality statements
    on Form U are true and correct.

-   *Parent Company and Technical Contact Information.* Company name and
    Dun and Bradstreet number; Technical Contact name, phone number,
    mailing address, and email address.

-   *Plant Site Identification.* Plant Site name, Dun and Bradstreet
    number, and street address (including county).

-   *Chemical Identification (for chemicals with reporting year,
    site-specific production volume of 25,000 pounds or more).* Specific
    chemical name and CAS registry or accession number, as applicable.

-   *Manufacturing Information.* Whether chemical is site-limited or
    not, whether chemical is manufactured or imported, manufactured
    production volume, imported production volume, number of workers
    reasonably likely to be exposed (in ranges), maximum concentration
    of chemical (in ranges), and physical form of chemical with
    associated percent production volume.

-   *Industrial Processing and Use Data (only for chemicals with
    reporting year, site-specific production volumes greater than or
    equal to 300,000 pounds).*[^3] Up to 10 unique combinations of type
    of process or use (code), North American Industrial Classification
    System (NAICS) code associated with specific combination, and
    industrial function category. For each unique combination, the
    percentage of respondent's production volume, number of processing
    and use sites (in ranges), and number of reasonably likely to be
    exposed workers (in ranges).

-   *Commercial and Consumer End-use Exposure Data (only for chemicals
    with reporting year, site-specific production volumes greater than
    or equal to 300,000 pounds).*[^4] Commercial/consumer use category
    whether a chemical is intended for use in children's products,
    percentages of respondent's production volume in each
    commercial/consumer use category, and maximum concentration of
    chemical in each commercial/consumer use category (in ranges).

***(ii) Respondent Activities***

A representative respondent would engage in the following activities:

(i) *Compliance Determination* \-- determine whether reporting is
    required for a chemical manufactured at a particular site, based on
    the production volume thresholds and the applicability of certain
    reporting exemptions;

(ii) *Rule Familiarization* \-- become familiar with the full
     requirements of the rule, which entails reading the rule,
     understanding the various reporting and administrative
     requirements, and determining the manner in which reporting
     requirements will be met for each chemical;

(iii) *Preparation and Submission of Reports* \-- compile the required
      information and complete a reporting form, including determining
      the CBI status of information and fulfilling appropriate
      substantiation measures. Respondents use a software program (eIUR)
      to complete EPA Form U (No. 7740-8), and either complete only
      Parts I and II for chemicals produced in quantities less than
      300,000 pounds or complete the full form for chemicals produced in
      quantities of 300,000 pounds or greater. Respondents must complete
      the form as applicable; and

(iv) *Recordkeeping* \-- retain records for five years following a
     submission period.

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

**5(a) Agency Activities**

The activities routinely conducted by EPA related to the processing,
analysis and storage of the information collected under this rule
include the following:

-   review and verify forms as they are received

-   answer respondent's questions and provide any necessary assistance

-   process submissions for inclusion in IUR database

-   review requests for confidentiality in the submissions

-   maintain the database

-   distribute the data

**5(b) Collection Methodology and Management**

The information collection activity under this rule includes an initial
reporting period in 1986 and subsequent reporting periods every four
years to 2006. The 2003 Amendments to the IUR extended the reporting
cycle to five years, therefore the next reporting will occur in 2011.
For each reporting period, all manufacturers (including importers),
except for those defined as "small manufacturers," are required to
submit information on every substance required under this rule that they
manufacture, including import, in sufficient quantities.

***(i) Collection Methodology***

All manufacturers (including importers) of subject chemicals are
required to report under the IUR rule. Potential reporters are notified
of the need to report in three ways: (1) EPA publishes a Federal
Register notice, (2) letters are sent to previous IUR submitters, and
(3) articles are published in the trade press. Reporting materials,
including the eIUR reporting software and a variety of guidance
documents (Instruction Manual, Q&As, Case Studies), are available on the
EPA's IUR website. In addition, respondents can obtain the reporting
materials from the TSCA Hotline.

To aid persons subject to this information collection, the Agency's TSCA
Hotline is also available to answer questions regarding the IUR
requirements or submission process. When Hotline staff are unable to
answer questions, the submitter is referred to OPPT's Information
Management Division (IMD) or Chemical Control Division (CCD), as
appropriate. Other Divisions within OPPT are used as necessary.

Respondents can submit information associated with this data collection
either through the Internet, as a file on a CD, or as a printed paper
copy. Initial data receipt and processing activities (data entry,
quality assurance, CBI claim reviews, etc.) will be expedited by the
receipt of the data electronically. Internet submissions require the use
of the eIUR software and the Agency's Central Data Exchange (CDX).
Reporting via the Internet is the most efficient of the choices, as the
respondent receives almost immediate feedback of the receipt of their
submission and EPA is able to directly load the information into the IUR
database. Information submitted on a CD involves different levels of
human intervention, depending upon the format of the file -- those
prepared with the eIUR software as encrypted files simply needed to be
uploaded to the IUR database, which those submitted as PDFs have to be
printed out and handled as paper submissions. Paper submissions are
scanned using Optical Character Recognition (OCR) technology and hand
checked for accuracy. Those that were handwritten or scanned poorly were
key-entered.

> ***(ii) Data Management***

This section describes the Agency tasks required for efficiently
processing submissions under the IUR. The tasks for which the Agency is
responsible are presented under four main categories: database systems
development, guidance document development, Form U processing, and
additional tasks. The task descriptions presented below generally do not
change.

IUR data are used to update and augment the Chemical Update System (CUS)
database. Once updated, the database is then available to EPA technical
reviewers for export into their various analytical modeling systems and
databases. The IUR database is also available for quick screening and
other direct uses. Non-CBI information is publicly available.

-   [Database Systems Development and Maintenance]{.underline} \-- The
    Agency is responsible for having adequate information systems in
    place to support the CUS database that serves as the primary data
    storage medium for IUR collections. File servers with appropriate
    backup are used to contain the IUR databases. Following the 2006 IUR
    collection, EPA updated the technology used to store the IUR data,
    storing it in a larger Manage Toxic Substances (MTS) database. In
    addition, IUR data are tracked via the correspondence tracking
    system utilized by the Confidential Business Information Tracking
    System (CBITS) located within the Confidential Business Information
    Center (CBIC).

-   [Guidance Document Development]{.underline} \-- The Agency is
    responsible for developing guidance to assist reporters in complying
    with IUR requirements. The guidance documents usually are developed
    by a contractor with oversight by Agency personnel.

-   [Form U Processing]{.underline} \-- The Agency is responsible for
    handling processing of IUR submissions. This includes developing
    standard operating procedures and documentation for all stages in
    the IUR document life cycle, document receipt and tracking, data
    input, quality control, file and database maintenance, information
    security, CBI aggregation policy, data dissemination, and staff
    training. For the 2006 IUR submission period, EPA developed new
    processes to receive IUR submissions over the Internet, using the
    Agency's Central Data Exchange (CDX) system.

-   [Additional Activities]{.underline} \-- The Agency develops
    reporting software and makes it available on the Internet, along
    with various supporting documents. In addition, the Agency is
    responsible for providing the TSCA Hotline with standardized
    responses for frequently asked questions; preparing mailings,
    mailing lists, and labels; and developing outgoing information
    materials.

**5(c) Small Entity Flexibility**

Ample flexibility is provided. This regulation affects only businesses
\-- governmental jurisdictions and not-for-profit organizations are not
required to take any action. Small manufacturers (including importers),
in accordance with TSCA section 8(b) (40 CFR Sections 710.29 and
710.28), are exempt and therefore are generally not subject to any of
the reporting or recordkeeping requirements. A manufacturer (including
importer) is considered a small business if (1) the firm's total annual
sales when combined with those of its parent company (if any) are less
than \$40 million for the reporting period and (2) its total production
and/or importation of the chemical substances, mixture or category, for
the reporting period, does not exceed 100,000 pounds (45,000 kilograms)
at an individual site owned and controlled by the firm. The *Revised*
*Economic Analysis for the Amended Inventory Update Final Rule*
determined that the impact on these companies is significantly less than
1% of revenues (EPA 2002a). EPA has determined that there is not a
significant economic impact on a significant number of small entities.

**5(d) Collection Schedule**

The reporting period shall be from June 1, 2011 to September 30, 2011.
This reporting period/schedule follows the requirements of 40 CFR
710.53.

Federal Register Notice February 2011

Send out letter to 2006 IUR mailing list March 2011

with instructions describing how to obtain

the reporting documents

Going Public efforts: articles in industry March 2011

press, meetings with regulated community,

and information on the IUR website

Open period for filing 2011 IUR Forms June 1, 2011 - September 30, 2011

**6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION**

**6(a) Estimating Respondent Burden**

This ICR estimates burden for an information collection effort that
includes the additional requirements of the 2003 Amendments to the IUR
rule. The previous ICR, which covered one collection from 2003 to 2008
(occurring in 2006), required chemical manufacturers (including
importers) to collect, maintain, and submit location and production
volume information for chemicals with annual production volumes of
25,000 pounds or higher. In addition, sites with production volumes of
300,000 pounds or higher of a reportable chemical were required to
collect, maintain, and submit information regarding chemical processing
and use. In the 2006 collection, manufacturers (including importers) of
inorganic chemicals, regardless of production volume, were partially
exempt (i.e., submitters did not report processing and use information
for inorganic chemicals). For the reporting period covered by this ICR,
the partial exemption for inorganic chemical manufacturers (including
importers) is no longer applicable and submitters are required to fully
report information on inorganic chemical substances when production
volumes at a site are 300,000 pounds or higher. However, petroleum
process streams and other chemical substances specifically listed
continue to be partially exempt from the information collection.
Manufacturers (including importers) of such substances are not required
to report processing and use information.

For this ICR, the burden estimates for report preparation and submission
were derived from a survey conducted by EPA in 1996 (under OMB Control
No. 2070-0034) to assess the potential burden associated with the
current IUR. The survey was distributed to previous IUR reporters
selected from the IUR database. Burden estimates are developed for the
compliance activities and then multiplied by the number of facilities or
reports (as appropriate) to estimate the total burden to respondents.
Estimates of facilities and reports are taken from the October 2007
version of the IUR database which includes data from the most recent
(2006) IUR collection.[^5] The amount of effort (and therefore cost)
required for each of these steps varies depending on the type of
chemical, company size, and the variety of uses of the chemical. The
tasks associated with IUR reporting during the period of this ICR are
those listed in Section 4(b)(ii). To complete the collection, the
respondent would:

-   Determine compliance;

-   Become familiar with rule;

-   Prepare and submit report; and

-   Keep records.

Worksheet 1 illustrates the respondents' burden of collection on a
per-collection basis. All burden hour estimates are based on the "high"
scenarios in the *Revised Economic Analysis of the Amended Inventory
Update Reporting Rule, Final Report* (EPA 2002a) (IUR EA). Estimates for
numbers of reporters and reports come directly from 2006 reported data.
This analysis estimates that a total of 4,190 Form U's will be received
with a total of 28,398 reports where reports represent a unique
site/chemical combination. Of the 28,398 reports, 51% are estimated to
be full reports and 49% are estimated to be partial reports. The total
number of chemicals with reports is 7,641.

[]{.mark}

The IUR requires reporting on a "per site" basis rather than a "per
company" basis; therefore, each site is considered a respondent. A total
of 4,190 respondents are estimated to report to this information
collection. The Agency estimates the typical annual respondent burden
for this information collection activity to be 339 hours. This burden
estimate assumes that each of the respondents will report IUR
information for an average of 2.0 full reports and 3.3 partial reports.
There are no third party burdens associated with these activities.

**6(b) Estimating Respondent Cost**

Worksheet 1 provides the respondents' cost of reporting on a
per-collection basis. The costs in worksheet 1 have been updated to
reflect wages rates in 2007 dollars.

Worksheet 1: Respondent Burden and Cost Estimates, Per Activity (2007\$)

  ----------------- --------- ------------ ------------ ---------- ---------- ------------ ---------- ------------- --------
  Activity                    Burden Hours                         Total      Cost per     Units per  Total Cost    Total
                                                                   Hours per  Unit         Site       per Activity  Burden
                                                                   Activity                                         Hours
                                                                                                                    per site

                              Managerial   Technical    Clerical                                                    
                              @\$68.18     @\$55.44     @\$27.47                                                    

  Compliance                  0.00         4.00         0.00       4.00       \$221.76     1 (4,190   \$221.76      4.00
  Determination                                                                            sites)                   
  (per site)                                                                                                        

  Rule                        2.00         2.00         0.00       4.00       \$247.24     1 (4,190   \$247.24      4.00
  Familiarization                                                                          sites)                   
  (per site)                                                                                                        

  Report            Partial   5.73         11.36        2.56       19.65      \$1,090.79   3.3        \$3,599.61    64.85
  Preparation and   Form                                                                   (13,989                  
  Submission (per                                                                          partial                  
  report)                                                                                  reports)                 

                    Full Form 25.98        66.75        12.54      105.27     \$5,816.41   3.4        \$19,775.79   357.92
                                                                                           (14,409                  
                                                                                           full                     
                                                                                           reports                  

  Recordkeeping               2.00         4.00         2.00       8.00       \$413.06     6.8        \$2,850.11    54.4
  (per Report)                                                                             (28,398                  
                                                                                           reports)                 

  Total Hours                 35.71        88.11        17.1       140.92                                           485

  Total Costs                 \$2,434.71   \$4,884.82   \$469.74              \$7,789.27                            
  ----------------- --------- ------------ ------------ ---------- ---------- ------------ ---------- ------------- --------

**6(c) Estimating Agency Burden and Cost**

Annual costs and burden to the Agency under the IUR have been estimated
by calculating the number of full-time equivalents (FTEs) required to
undertake certain prescribed tasks. These tasks are outlined in the IUR
EA. FTE requirements have been reduced from four FTE's in the EA to two
because many activities in the EA were estimated to be one-time costs.
One time costs, associated with the requirements of the IUR amendments,
are not considered in this ICR. FTEs are converted to dollars by
multiplying estimated FTE yearly earnings for the appropriate staff
level (GS level) by the number of FTEs for each staff level, and then
summing the products. Yearly earnings have been calculated to include
fringe benefits of 41 percent of the base salary and overhead costs of
17 percent of the base salary plus the fringe benefits.

EPA costs also include payment for extramural task completed by
contractors. These costs were estimated at \$84,960 for document receipt
and tracking entry and \$53,100 for backup systems operation in the
previous ICR (2005). Costs were inflated from 2005 to 2007 dollars using
the Employment Cost Index (ECI), seasonally adjusted, for white-collar
occupations in private industry (BLS 2008). The ECI for 4^th^ quarter
2005 was 100.2 and 106.8 for 4^th^ quarter 2007. Using these indices,
the costs for document receipt and tracking entry and systems operation
are estimated at \$90,737 and \$56,711, respectively.

Additional Agency costs have been estimated based on the budget that is
appropriated for the IUR and found in the previous ICR.

Worksheet 2 presents the per-cycle Agency costs of the IUR information
collection. The Agency expects only one collection to occur during the
time period that this ICR is effective. Therefore, the estimated total
annualized cost incurred by the Agency is calculated by summing the
recurring costs and the one-time costs, and dividing by the five years
of the reporting cycle, which yields \$88,077.

Worksheet 2. Estimated Per-Cycle Agency Costs for the IUR (recurring
every five years)

+-----------------------------------------+----------------------------+
| Task                                    | IUR Costs (2007 \$)        |
+-----------------------------------------+----------------------------+
| Tasks Performed by Agency Personnel     | \$111,622 (1 FTE, GS-12,   |
|                                         | Step 1)                    |
| Quality Control of Data Entry           |                            |
|                                         | \$132,737 (1 FTE, GS-13,   |
| Data Processing, Systems Development,   | Step 1)                    |
| and Contract                            |                            |
|                                         |                            |
| Oversight and Management                |                            |
+-----------------------------------------+----------------------------+
| Subtotal                                | \$244,359                  |
+-----------------------------------------+----------------------------+
| Extramural Tasks (contractor)           | \$90,737                   |
|                                         |                            |
| Document Receipt and Tracking and Data  | \$56,711                   |
| Entry                                   |                            |
|                                         |                            |
| Backup Systems Operation                |                            |
+-----------------------------------------+----------------------------+
| Subtotal                                | \$147,448                  |
+-----------------------------------------+----------------------------+
| Additional Tasks                        | \$5,298                    |
|                                         |                            |
| Publication and Printing Forms and      | \$42,855                   |
| Materials                               |                            |
|                                         | \$426                      |
| Hotline                                 |                            |
|                                         |                            |
| Mailing                                 |                            |
+-----------------------------------------+----------------------------+
| Subtotal                                | \$48,579                   |
+-----------------------------------------+----------------------------+
| Total Cost per Collection               | \$440,386                  |
+-----------------------------------------+----------------------------+
| Total Annual Cost (one collection per 5 | \$88,077                   |
| years)                                  |                            |
+-----------------------------------------+----------------------------+
| Note: All costs associated with FTEs    |                            |
| include 41 percent fringe benefits and  |                            |
| 17 percent overhead. For example, the   |                            |
| GS-12 Step 1 salary for 2007 was        |                            |
| \$69,764. This was multiplied by an     |                            |
| assumed loading factor of 1.6 (rounded) |                            |
| to reflect fringe benefits and          |                            |
| overhead, resulting in a fully loaded   |                            |
| cost per FTE of 1.6 X \$69,764 =        |                            |
| \$111,622.                              |                            |
+-----------------------------------------+----------------------------+
| Sources:                                |                            |
|                                         |                            |
| > Office of Personnel Management, 2007. |                            |
| > "2007 General Schedule Locality Notes |                            |
| > of Pay for Washington-Baltimore,      |                            |
| > DC-MD-VA-WV."                         |                            |
| > \<http://www.opm.gov                  |                            |
| /oca/2008tbls/GSannual/html/GSDCB.HTM\> |                            |
| > As obtained on April 16, 2008.        |                            |
| >                                       |                            |
| > Information Management Division,      |                            |
| > 1996. Questions for Branches within   |                            |
| > OPPT with Responsibility for IUR Data |                            |
| > Collection, Processing, and Storage.  |                            |
| > Information Management Division,      |                            |
| > Office of Pollution Prevention and    |                            |
| > Toxics, U.S. Environmental Protection |                            |
| > Agency, Washington, DC.               |                            |
| >                                       |                            |
| > EPA, 1996b. Transcribed Telephone     |                            |
| > Conversation with Ruth Heikkinen on   |                            |
| > Hotline and Mailing Costs, Office of  |                            |
| > Pollution Prevention and Toxics, U.S. |                            |
| > Environmental Protection Agency,      |                            |
| > Washington, DC.                       |                            |
| >                                       |                            |
| > EPA, 1996c. IUR Amendments---Agency   |                            |
| > Costs Question. Memorandum from Ward  |                            |
| > Penberthy to Susan Krueger, Office of |                            |
| > Pollution Prevention and Toxics, U.S. |                            |
| > Environmental Protection Agency.,     |                            |
| > Washington, DC.                       |                            |
+-----------------------------------------+----------------------------+

**6(d) Bottom Line Burden Hours and Cost: Master Table**

The total burden per reporting cycle collection is estimated to be
2,161,362 hours. Given that there is only one collection every 5 years,
the annual burden is estimated to be 432,274 hours. The total cost per
reporting cycle collection is estimated to be \$97.3 million. The cost
per year is estimated to be \$19.4 million. Details are provided in
Worksheet 4.

EPA estimates that Agency costs will be \$886,607 for the collection, or
\$221,652 annually.

Worksheet 4: Total Estimated Burden Hours and Costs (2007 \$)

  -------------------------------------------------------------------------------------------------
  Activity                    Unit of    Total                 Number   Totals per   
                              Analysis   per Unit              of Units Collection   
  ----------------- --------- ---------- -------- ------------ -------- ------------ --------------
                                         Hours    Cost                  Hours        Cost

  Compliance                  Site       4.00     \$221.76     4,190    16,760       \$929,174
  Determination                                                                      

  Rule                        Site       30.00    \$247.24     4,190    125,700      \$1,035,936
  Familiarization                                                                    

  Report            Partial   Report     19.65    \$1,090.79   13,989   274,883      \$15,259,061
  Preparation and   Form                                                             
  Submission                                                                         

                    Full Form Report     105.27   \$5,842.66   14,409   1,516,835    \$84,186,888

  Recordkeeping               Report     8.00     \$413.06     28,398   227,184      \$9,664,778

  Subtotal Per                                                          2,161,362    \$97,345,837
  Collection                                                                         

  Subtotal                                                              432,272      \$19,469,167
  Annually1                                                                          
  -------------------------------------------------------------------------------------------------

> ^1^ This collection occurs every five years, therefore total annually
> is equal to the total for the collection divided by five.

The IUR EA estimated that there would be 3,036 respondents of which 758,
or 25%, would be small. Applying the 25% to the 4,190 estimated
respondents for this ICR results in an estimated 1,048 small
respondents. It is important to note that this is very likely an
overestimate. The IUR exempts small businesses from reporting. However,
there are some cases where a small business does report (e.g., the
company may report a chemical subject to certain sections of TSCA that
require reporting) so an estimate is presented in this ICR. Worksheet 5
includes summary burden estimates.

Worksheet 5. Summary Burden Estimates

+----------------+----------------+----------------+-----------------+
| Number of      | Number of      | Responses per  | Burden per      |
| Small          | Respondents    | Respondent     | Response        |
| Respondents    |                |                |                 |
|                |                |                | (hours)         |
+----------------+----------------+----------------+-----------------+
| 1,048          | 4,190          | 6.8            | 485             |
+----------------+----------------+----------------+-----------------+

**6(e) Reasons for Change in Burden**

There is an increase of 18,699 hours (from 413,575 hours to 432,274
hours) in the total annual estimated respondent burden compared with
that identified in the ICR most recently approved by OMB. This is
expected to be due to both a program change and an adjustment. In the
2006 IUR collection covered by the previous ICR, inorganic chemicals
were partially exempt and therefore, manufacturers (including importers)
of inorganic chemicals completed only partial reports. However, in
subsequent reporting periods, including the period covered by this ICR,
manufacturers (including importers) of inorganic chemicals must complete
full reports when the site-specific production volume is 300,000 pounds
or more. Full reports are estimated to take an additional 85 hours to
complete. This represents a program change.

EPA used data reported to the 2006 IUR collection to estimate numbers of
respondents. Total sites reporting were estimated to be 4,190 for this
collection. In the previous ICR, the number of sites responding was
estimated to be 3,026 sites. This adjustment in estimates is another
reason for the change in burden hours. Other, less significant changes
in estimates of reports will also affect the change in burden estimates.

**6(f) Burden Statement**

The annual public burden for this collection of information, which is
approved under OMB Control No. 2070-0162, is estimated to average 485
hours. According to the Paperwork Reduction Act, "burden" means the
total time, effort, or financial resources expended by persons to
generate, maintain, retain, or disclose or provide information to or for
a Federal agency. For this collection it includes the time needed to
review instructions; develop, acquire, install, and utilize technology
and systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information. An agency may not conduct or
sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number. The
OMB control number for this information collection appears above. The
OMB control numbers for EPA\'s regulations in title 40 of the CFR, after
appearing in the Federal Register when approved, are listed in 40 CFR
part 9, are displayed either by publication in the Federal Register or
by other appropriate means, such as on the related collection instrument
or form, if applicable. The display of OMB control numbers in certain
EPA regulations is consolidated in 40 CFR part 9.

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a docket for this ICR under Docket ID No.
EPA-HQ-OPPT-2008-0504, which is available for public viewing at the
Pollution Prevention and Toxics Docket in the EPA Docket Center
(EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, Washington,
DC. The EPA Docket Center 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 Reading Room is (202) 566-1544 and the
telephone number for the Pollution Prevention and Toxics Docket is (202)
566-0280.

An electronic version of this docket is available at
[[http://www.regulations.gov/]{.underline}](http://www.regulations.gov/).
Use the federal government wide electronic docket and comment system at
[[www.regulations.gov]{.underline}](http://www.regulations.gov/) to
submit or view public comments, access the index listing of the docket
contents, and to access those documents in the docket that are available
electronically. Once in the system, select "advance search," then key in
the docket ID number identified above. Also, you can send comments to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Office for EPA. Please include the EPA Docket ID No.
EPA-HQ-OPPT-2008-0504 and OMB control number 2070-0162 in any
correspondence.

**SOURCES**

BLS, 2008. Employment Cost Index, Seasonally Adjusted, Total
compensation, private industry, White-collar occupation, Series ID
CIS2010000W00000I (B,D). Years 1998-2007. Extracted April 29, 2008.

EPA, 2002a. *Revised Economic Analysis of the Amended Inventory Update
Rule*. Economics, Exposure and Technology Division, Office of Pollution
Prevention and Toxics, U.S. Environmental Protection Agency, Washington,
DC.

EPA, 2002b. *EPA's IURA Data Use Plan*. Economics, Exposure and
Technology Division, Office of Pollution Prevention and Toxics, U.S.
Environmental Protection Agency, Washington, DC.

EPA, 1999. *A Review of Existing Exposure-Related Data Sources and
Approaches to Screening Chemicals: A Response to CMA*. Economics,
Exposure and Technology Division, Office of Pollution Prevention and
Toxics, U.S. Environmental Protection Agency, Washington, DC.

EPA, 1997. *Economic Analysis of the Final Rule to Add Certain Industry
Groups to EPCRA Section 313*. Economics, Exposure and Technology
Division, Office of Pollution Prevention and Toxics, U.S. Environmental
Protection Agency, Washington, DC.

EPA, 1996a. *Inventory Update Rule (IUR) Amendment Technical Support
Document: Exposure-Related Data Useful for Chemical Risk Screening*.
Economics, Exposure and Technology Division, Office of Pollution
Prevention and Toxics, U.S. Environmental Protection Agency, Washington,
DC.

EPA, 1996b. Transcribed Telephone Conversation with Ruth Heikkinen on
Hotline and Mailing Costs, Office of Pollution Prevention and Toxics,
U.S. Environmental Protection Agency, Washington, D.C.

EPA, 1996c. IUR Amendments---Agency Costs Question. Memorandum from Ward
Penberthy to Susan Krueger, Office of Pollution Prevention and Toxics,
U.S. Environmental Protection Agency, Washington, D.C.

Information Management Division, 1996. *Questions for Branches within
OPPT with Responsibility for IUR Data Collection, Processing, and
Storage*. Information Management Division, Office of Pollution
Prevention and Toxics, U.S. Environmental Protection Agency, Washington,
DC.

Office of Personnel Management, 2007. "2007 General Schedule Locality
Notes of Pay for Washington-Baltimore, DC-MD-VA-WV."
\<http://www.opm.gov/oca/2000tbls/GSannual/html/GSDCB.HTM\> As obtained
on April 16, 2008.

**ATTACHMENTS TO THE SUPPORTING STATEMENT**

These attachments are available in the electronic docket at
[[www.regulations.gov]{.underline}](http://www.regulations.gov/), under
Docket ID No. EPA-HQ-OPPT-2008-0504.

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

Attachment 2 40 CFR 710 - TSCA Inventory Update Reporting Rule

Attachment 3 IUR ICR Calculations

Attachment 4 Form U - EPA Form 7740-8

[^1]: The 2003 Amendments were published on January 7, 2003. See 68 FR
    848.

[^2]:
    > INFORM is a nonprofit environmental research organization.

[^3]: Certain chemicals, specifically listed in the IUR regulation at 40
    CFR 710.46(b), are partially exempt and only report Parts I and II
    of Form U, regardless of their production volume.

[^4]: Ibid.

[^5]: Quality control reviews had not been completed for the October
    2007 version of the IUR database. Future versions may result in
    slightly different numbers of chemicals and/or reports.