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Supporting Statement for a Request for OMB Review under

The Paperwork Reduction Act

1. IDENTIFICATION OF THE INFORMATION COLLECTION

l(a) Title of the Information Collection

TITLE: Chemical-Specific Rules, TSCA Section 8(a)

EPA ICR No.: 1198.10 OMB Control No: 2070-0067

1(b) Short Characterization

This information collection request requires OMB’s approval for the continued collection 

of chemical-specific information under section 8(a) of the Toxic Substance Control Act (TSCA, 

15 U.S.C. 2607); see Attachment 1. TSCA section 8(a) authorizes the Administrator of the EPA 

to promulgate rules that require persons who manufacture, import or process chemical 

substances and mixtures, or who propose to manufacture, import, or process chemical substances 

and mixtures, to maintain such records and submit such reports to EPA as may be reasonably 

required. Information that may be collected under TSCA section 8(a) includes, but is not limited 

to, chemical names, categories of use, production volume, byproducts of chemical production, 

existing data on deaths and environmental effects, exposure data, and disposal information. 

These data are collected by the Office of Pollution Prevention and Toxics (OPPT) and may be 

used by other EPA offices and/or Federal agencies to ensure knowledge of specific practices that 

may affect human health and the environment.

There may be circumstances when EPA may require different information than is readily 

available or information that is different from that available through existing regulatory

information collection tools, like the TSCA section 8(a) Preliminary Assessment Information 

Rule (PAIR) which is discussed in another ICR under a different OMB control number. EPA 

promulgated PAIR on June 22, 1982 (see 40 CFR Part 712). Whenever a substance is added to 

the PAIR, manufacturers and importers of the substance are required to complete a PAIR report 

form. The PAIR report requests a very limited amount of information on listed chemicals 

regarding activities occurring over a specific time period.

Any chemical covered by TSCA for which OPPT, other EPA Offices or another Federal 

agency has a reasonable need for information, and which cannot be satisfied via readily available 

sources or by use of PAIR, is a proper potential subject for a chemical-specific TSCA section 

8(a) rulemaking. For instance EPA may wish to ask detailed questions in regard to how industry

oversees the use and production of a chemical. These specific monitoring capabilities could 

allow EPA to react to change in market conditions that may warrant a change in EPA’s 

regulatory strategy. Therefore, EPA could promulgate a TSCA section 8(a) rule to gather this 
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information by requesting that current or potential manufacturers, importers or processors of the 

substance provide chemical-specific information.

EPA’s OPPT, other EPA Offices and/or other Federal agencies will generally be the 

primary groups for which information will be collected. However, to the extent that reported 

information is not considered to be confidential business information (CBI), environmental 

groups, environmental justice advocates, state and local government entities and other members 

of the public will have access to this information for their own use.

Rather than requiring respondents to submit information on reporting forms such as those 

used for PAIR, EPA has in the past allowed individual firms to choose the reporting means and 

format that is best suited to their recordkeeping resources. EPA believes that for TSCA section 

8(a) chemical-specific rules, this allowance keeps reporting costs low.

Total annual cost of a rule varies depending upon the number of chemicals per rule and 

the number of respondents per chemical. Based on the recent past usage of chemical-specific 

TSCA section 8(a) rules and expected future usage, EPA assumes that it will promulgate one 

TSCA section 8(a) chemical-specific rule with four respondents (notices) per year for the threeyear duration of the ICR (see Section 6(b), below). The maximum total annual number of burden 

hours for respondents range from 67 hours to 275 hours per TSCA section 8(a) chemical-specific 

rule. The maximum cost associated with the promulgation of a TSCA section 8(a) chemicalspecific rule is $3,711 to $16,551. However, the cost per respondent varies with the type of 

chemical-specific information requested, and subsequently, the tasks required to comply with a 

TSCA section 8(a) chemical-specific rule. Because all respondents may not have to provide 

information on all data items listed (see Sections 3 and 6(b), below), the ranges presented above 

are maximums. Assuming that all respondents do not have to complete all tasks identified to 

comply with a TSCA section 8(a) chemical-specific rule, total annual reporting costs to all 

respondents range from $8,104 to $36,316 per rule.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Generally, EPA may need chemical-specific information under TSCA section 8(a) to 

evaluate the potential for adverse human health and environmental effects caused by the 

manufacture, importation, processing, use or disposal of identified chemical substances and 

mixtures. Additionally, EPA may use TSCA section 8(a) information to assess the need or set 

priorities for testing and/or further regulatory action.

The information required in TSCA section 8(a) chemical-specific rules can be customtailored to aid in achieving EPA’s goals of protecting human health and the environment. 

Information collected may vary depending on the substance, its current and potential uses and 

EPA’s concerns about potential human or environmental risks caused by exposures to the 
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substance. Promulgated TSCA section 8(a) rules may require persons manufacturing, importing 

or processing the chemical substance to report to EPA on specific information such as: a 

chemical’s composition, byproducts, quantity produced, employee exposure and environmental 

release. Persons have in the past also been required to notify EPA of a management decision to 

initiate the manufacturing, importing, or processing of a chemical substance or mixture.

The legal authority for this information collection is TSCA section 8(a), U.S.C. 2607(a). 

TSCA section 8(a) chemical-specific rules have been codified at 40 CFR 704, subpart B; see 

Attachment 2.

2(b) Use/Users of the Data

EPA will use the information obtained through the TSCA section 8(a) reporting rules to 

satisfy specifically identified data needs. The information collected will be relevant to risk 

identification, all stages of risk assessment, and/or control action functions. Receipt of TSCA 

section 8(a) information may also give the Agency an opportunity to work with the respondent, if 

necessary, to minimize exposure risks associated with specific uses. Generally, a specific 

information collection request would be made by the Chemical Control Division or another 

division in OPPT. However, other regulatory agencies and departments, such as Occupational 

Safety and Health Administration (OSHA), the Food and Drug Administration (FDA), and other 

members of the Interagency Testing Committee (ITC) may also present a need for and 

subsequently use TSCA section 8(a) data to, for example, assess worker or consumer exposures.

An example of a use of a TSCA section 8(a) chemical-specific rule that was key in 

affecting a benefit to human health was 1,1-aminoundecanoic acid (1,1-AA). From submitted 

TSCA section 8(e) “substantial risk” reports, EPA discovered that 1,1-AA is a carcinogen in one 

sex of one rodent species (male rat), and that exposure is limited to workers producing the nylon 

in which the chemical is an ingredient. The manufacturer was contacted to obtain exposure data 

for this chemical. From this contact EPA learned: (1) 1,1-AA was imported and converted into 

nylon by one company and there was no domestic manufacture; (2) 1,1-AA was handled and 

transferred in a closed system and all 1,1-AA was converted during the reaction to produce 

nylon. Consequently, because of limited exposure potential, 1,1-AA was dropped from further 

review. However, concern would arise if 1,1-AA were to be manufactured domestically because 

of the greater likelihood for worker exposure. To alert EPA to domestic manufacture, on May 28, 

1987, OPPT promulgated a TSCA section 8(a)/5 (SNUR) rule for 1,1-AA (52 FR 19860). Users 

of TSCA section 8(a) chemical-specific data rarely make a judgment based solely on the content 

of the TSCA section 8(a) information received but rather use the TSCA section 8(a) chemicalspecific information as part of the larger risk management strategy. 1,1-AA TSCA section 8(a) 

information would be instrumental in affecting a benefit to human health if a company were to 

begin to manufacture the substance.
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3. NON-DUPLICATION, CONSULTATION, AND OTHER COLLECTION CRITERIA

3(a) Non-Duplication

Section 8(a)(2) of TSCA states, “To the extent feasible, the Administrator shall not 

require any reporting which is unnecessary or duplicative.” The reporting requirements of TSCA 

section 8(a) rules only require information that EPA believes will assist in a reasoned evaluation 

of the human health and environmental effects of chemical substances and mixtures. This 

information is unlikely to be duplicative since, (1) EPA estimates that each rule will generate 

only a few notices, (2) the information required by the TSCA section 8(a) rule is unique to the 

manufacturer, importer or processor (e.g., the proposed date of production or importation, the 

amount produced or imported, the chemical composition, and uses of the chemical substance or 

mixture), and (3) EPA thoroughly checks other public and unpublished sources to see if the 

required data may already be available. Finally, once EPA became aware of a source of 

substantially similar information, for example via comments on a proposed rule, EPA would not 

continue with the information collection.

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

EPA has not published a proposed or final TSCA section 8(a) chemical-specific 

information gathering rule for more than twenty-five years and has, therefore, not received any 

comments since that time. EPA has received comments on the use of TSCA section 8(a) 

reporting rules through published Federal Register notices. Various organizations responded to 

EPA’s request for comments during the 1985 to 1988 ICR period. For example, the Agency

originally proposed a SNUR for 4,4,1-methylenebis (2-chloroaniline) (MBOCA) but public 

comments received in July and August of 1986 on the proposed SNUR suggested that a TSCA 

section 8(a) rule would be more appropriate. This suggestion was followed, reducing the burden 

on the public since the TSCA section 8(a) rule exempted small manufacturers, whereas the 

proposed SNUR would not have had this exemption. Also, after receiving public comment on the 

proposed SNUR/8(a) rule for 1,1- aminoundecanoic acid (July 22, 1986), the proposed definition 

of the term “enclosed process” was modified to account for possible releases through emergency

pressure relief, thus expanding the number of processes that would be considered “enclosed” and 

lessening compliance costs. The Natural Resources Defense Council (NRDC) has also responded 

to several TSCA section 8(a) chemical-specific rules. The NRDC is a national nonprofit 

environmental organization dedicated to the protection of human health and the environment. 

The NRDC generally urges EPA to adopt a more extensive, detailed set of information 

requirements.
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Under 5 CFR 1320.8(d)(1) OMB requires agencies to consult with potential ICR 

respondents and data users about specific aspects of ICRs before submitting an original or 

renewal ICR to OMB for review and approval. In accordance with this regulation, EPA will 

pursue additional consultations with interested parties during the development of the renewal of 

this collection.

3(d) Effects of Less Frequent Collection

Generally companies are required to report only once under a TSCA section 8(a) 

reporting rule. EPA may consider requiring reporting on an annual, semiannual, monthly or other 

basis if the Administrator deems this necessary to protect human health and the environment. 

EPA tailors each rule to meet chemical-specific data requirements, thus reducing the potential for 

too frequent data collections.

3(e) General Guidelines

This information collection activity is necessary to implement the statutory requirements 

of section 8(a) of TSCA and is consistent with the requirements of 5 CFR 1320.6.

3(f) Confidentiality

Submitters may designate information as confidential, trade secret or proprietary. EPA 

has implemented procedures to protect any confidential, trade secret or proprietary information 

from disclosure. These procedures comply with EPA’s confidentiality regulation, 40 CFR Part 2, 

Subpart B.

3(g) Sensitive Questions

This section is not applicable. TSCA section 8(a) reporting rules do not include any 

questions of a sensitive nature.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/North American Industrial Classification System (NAICS) 

Codes

Respondents affected by this collection activity primarily include those businesses that 

fall under NAICS codes 325, Chemical Manufacturers and Processors, and 324110, Petroleum 

Refineries.

4(b) Information Requested

4(b)(i) Data Items
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Section 8(a) of TSCA specifically lists a wide range of data items that may be required by 

EPA, including information on use, production volume, exposure, and health and safety. Data 

items requested of manufacturers, importers, or processors of certain chemicals vary with each 

collection request, but will not repeat information previously requested in the PAIR or other 

information gathering tools. Some data items requested under TSCA section 8(a) chemicalspecific rules in the past include: notification and description of changes in the end use of 

identified substances and mixtures, information on planned manufacturing and on-site 

processing, and notification of changes to the method of manufacturing the substance (see 40 

CFR subpart B).

An example of a past TSCA section 8(a) chemical-specific rule is one issued on 4,4,1-

methylenebis (2-chloroaniline) (MBOCA). It required persons who propose to manufacture 

MBOCA to notify EPA of that intent and to submit information on their planned manufacturing 

and on-site processing activities. The rule also required persons who are manufacturing MBOCA 

to notify the Agency if they propose to alter their manner or method of manufacturing the 

substance.

4(b)(ii) Respondent Activities

Activities a respondent may be required to perform as a result of TSCA section 8(a) 

chemical-specific rule are as follows:

9 to 29.5 Hours of Managerial Labor

- Identify listed chemicals;

- Assign principal technical contact person;

- Identify by-product;

- Review marketing data;

- Research the date of the initiation of manufacture or importation of the chemical;

- Research occupational exposure, environmental release, health and environmental data, 

disposal methods; and

- Process, compile, and review information for accuracy, substantiate a claim of 

confidential business information.

17.5 to 98 Hours of Technical Labor

- Identify chemical and trade name and chemical composition;

- Identify by-product;

- Describe use of chemical;

- Report quantity manufactured or imported;

- Research workplace exposures, environmental releases, health and environmental data, 

and disposal methods; and

- Provide occupational description.
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7 to 21 Hours of Clerical Labor

- Format research on occupational exposures, environmental releases, health and 

environmental data;

- Format attachments; and

- Prepare notice.

Recordkeeping Estimate

TSCA section 8(a) chemical-specific rules may contain recordkeeping requirements. The 

recordkeeping estimate is rough, but it is reasonably related to the maximum reporting burden. 

EPA estimates that recordkeeping will account for approximately four percent of the reporting 

burden, or a maximum of 3 hours (see Table 2.)

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY AND INFORMATION MANAGEMENT

5(a) Agency Activities Inventory

For any TSCA section 8(a) chemical-specific rule the Agency would have to perform a 

number of tasks. They are:

o Industry/Public Assistance (answering questions regarding rule)

o Data Processing and System Support Personnel

o Storage and Distribution

o Compliance Monitoring

5(b) Collection Methodology and Management

An improved information technology to minimize burden of a TSCA section 8(a) 

chemical-specific rule has not been found. EPA has not been able to identify a more efficient, 

less expensive, or more flexible means of obtaining the required data than the one currently 

being used. To the extent data are not CBI, all information collected is made available to the 

public through the public docket office. At the present time, EPA is not requiring firms to submit 

this information on any one standard reporting form. Reporting facilities will be able to choose 

the format that best suits their reporting resources. TSCA section 8(a) chemical-specific rules 

typically require one-time reporting. As future data needs arise, EPA will consider the use of 

electronic or other types of reporting methods. EPA believes the flexibility already allowed in 

the reporting structure significantly eases burden.
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5(c) Small Entity Flexibility

Section 8(a) of TSCA generally exempts small manufacturers and processors. However, 

under TSCA section 8(a)(3), EPA may require small manufacturers and processors to report or 

keep records if the substance or mixture is subject to a rule proposed or promulgated under 

TSCA sections 4, 5(b)(4), or 6 or with respect to which relief has been granted pursuant to a civil 

action brought under sections 5 or 7 of TSCA. All respondents to TSCA section 8(a) chemicalspecific rules, including small businesses, are granted flexibility in their reporting methods.

5(d) Collection Schedule

TSCA section 8(a) chemical-specific rules are generally one-time collections of specific 

information, usually regarding one chemical substance. Proposed TSCA section 8(a) chemicalspecific rules request comments. The comments are then addressed and incorporated as 

appropriate in the final rule, which specifies the reporting deadline. Generally, EPA requires that 

information be reported no sooner than 30 days after the effective date of a final rule.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

Wage rates, including fringe benefits and overhead, for three broad categories of labor 

(managerial, technical, and clerical) were used in this analysis. The basis for estimating wage 

rates for the purposes of this analysis is the Bureau of Labor Statistics (BLS) Employer Costs for 

Employee Compensation (ECEC) data, for December 2012, for manufacturing industries. Based 

on the BLS data, the average hourly wage rates (as of December 2012) are $43.95 for managerial 

personnel, $38.53 for technical personnel and $17.64 for clerical personnel.

The cost of fringe benefits such as paid leave and insurance, specific to each labor 

category, are taken from the same ECEC series and an additional loading factor of 17 percent is 

applied to wages to account for overhead. The overhead factor of 17 percent is used in 

accordance with Office of Pollution Prevention and Toxics economic analyses for two major 

rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory Program 

(EPA, 2002b), and the Revised Economic Analysis for the Amended Inventory Update Rule: 

Final Report (EPA, 2002a). 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 loaded hourly 

wage rates are $72.87 for managerial personnel, $64.38 for technical personnel and $29.51 for 

clerical personnel, as shown in Table 1.
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Table 1: Loaded Hourly Wage Rates by Labor Category.

Labor Category Average Wages1 Benefits and Overhead

Loading Factor2 Loaded Hourly Rate3

Managerial $43.95 1.66 $72.87

Technical $38.53 1.67 $64.38

Clerical $17.64 1.67 $29.51

Notes:

1 Employer Costs for Employee Compensation Supplementary Tables December 2012, U.S. Bureau of Labor Statistics, March 

18, 2013 (BLS, 2013).

2 An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory 

Program (EPA, 2002b), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a).

3 Wage data are rounded to the closest penny in this table; however, in calculations using these numbers for this report, 

unrounded values were used.

This ICR maintains the assumption of the previous ICR that, on average, four notices per 

year are submitted in response to one section 8(a) chemical-specific rule per year. Current labor 

rates and burden hours used to calculate the cost to respondents are listed below.

Labor Category Burden Hours Hourly Rate

Managerial 9.0 – 29.5 $72.87

Technical 17.5 – 98.0 $64.38

Clerical 7.0 – 21.0 $29.51

6(b) Estimating Respondent Costs

The following are the tasks that managers, technical, and clerical personnel are expected 

to perform when preparing to submit a notice in response to an 8(a) chemical-specific rule. 

However, as discussed at the end of this section, not all respondents are likely to be required to 

perform all tasks under each labor category. Therefore, the ranges of labor hours presented below 

for each labor category (e.g., 9 to 29.5 hours for managers) are the maximums and are based on 

the assumption that all tasks are performed for each notice.

Managerial Labor

- Manufacturer identifies listed chemicals;

- Assign principal technical contact person;

- Identify by-product;

- Review marketing data;

- Research the date of the initiation of manufacture or importation of the chemical;

- Research occupational exposure, environmental release, health and environmental data, 

disposal methods;

- Process, compile, and review information for accuracy, substantiate a claim of 

confidential business information.

In performing these tasks, managerial labor hours have been estimated to range from 9.5 

to 29.5 hours per TSCA section 8(a) chemical-specific rule. At $72.87 per hour for management 
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labor times, the range of hours predicted [$72.87 x (9.5 to 29.5)], the range of cost for 

management work is $692 to $2,150 per notice resulting from a TSCA section 8(a) chemicalspecific rule. With an average of four notices per year for the three-year ICR period, the range of 

costs per year for managerial labor is [4 x ($692 to $2,150)] = $2,768 to $8,600.

Technical Labor

- Identify chemical and trade name and chemical composition;

- Identify by-product;

- Describe use of chemical;

- Report quantity manufactured or imported;

- Research occupational exposures, environmental releases, health and environmental data, 

and disposal methods; 

- Provide occupational description.

In performing these tasks, technical labor hours have been estimated to range from 17.5 

to 98 hours per notice resulting from a TSCA section 8(a) chemical-specific rule. At $64.38 per 

hour for technical labor, times the range of hours predicted [$64.38 x (17.5 to 98)], a range of 

cost for technical work is estimated to be $1,127 to $6,309 per notice resulting from a TSCA 

section 8(a) chemical-specific rule. With four notices per year for a three-year period, the range 

of annual costs for technical labor is [4 x ($1,127 to $6,309)] = $4,508 to $25,236.

Clerical Labor

- Format research on occupational exposure, environmental releases, health and 

environmental data;

- Format attachments;

- Prepare notice.

In performing these tasks, clerical labor has been estimated to range from 7 to 21 hours 

per notice resulting from a TSCA section 8(a) chemical-specific rule. At $29.51 per hour for 

clerical labor, times the range of hours predicted [$29.51 x (7 to 21)], the range of cost for 

clerical work is estimated to be $207 to $620 per notice resulting from a TSCA section 8(a) 

chemical-specific rule. With four notices per TSCA section 8(a) chemical-specific rule, the range 

of costs per year for clerical labor is [4 x ($207 to $620)] = $828 to $2,480.

The cost to a respondent for filing a TSCA section 8(a) notice depends upon the various 

tasks performed. These tasks could include gathering the required data, preparing and submitting 

the TSCA section 8(a) notice, and possibly keeping records. Based on promulgated TSCA 

section 8(a) rules, EPA estimates that each respondent will submit one notice per TSCA section 

8(a) chemical-specific rule. EPA anticipates issuing one TSCA section 8(a) rule per year and 

expects to receive an average of four notices per year.

The cost to a respondent for submitting a TSCA section 8(a) notice is a function of the 

number of hours and the hourly labor costs for the individuals developing and preparing the 
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notice. The annual estimated range of cost to the respondent is $2,026 ($692 + $1,127 + $207) to 

$9,079 ($2,150 + $6,309 + $620) per notice, and $8,104 to $36,316 per TSCA section 8(a) 

chemical-specific rule [4 notices per rule x ($2,026 to $9,079 per notice)]. However, as 

mentioned above, these figures are likely to overstate the true cost because not all respondents 

may be required to supply information regarding each activity. Thus, the average actual cost to 

the respondent will be lower than the $2,026 to $9,079 per notice estimate calculated above. The 

estimated frequency of each activity, along with total respondent cost and burden calculations, is 

presented in Table 2. The total cost to all respondents reporting under a TSCA section 8(a) 

chemical-specific rule is estimated to range from $3,711 to $16,551 per year.

Table 2. Total Annual Respondent Burden and Costs Associated with Preparing and Filing a TSCA 

Section 8(a) Notice.

Activity

Managerial 

Hours 

$72.87/hr

Technical 

Hours 

$64.38/hr

Clerical 

Hours 

$29.51/hr

Notices 

per 

Year

Annual 

Burden 

Hours

Annual 

Costs

Manufacturer ID

and Principal 

Technical Contact

1 - 4 4 4 - 16 $291-

$1,166

Chemical and

Trade Name 1 - 4 3 3 - 12 $193-$773

Chemical

Composition 0.5 - 2 4 2 - 8

$129-

$515

Byproduct ID 1 1 - 4 2 4 - 10 $275-

$661

Use Description 1 - 4 4 4 - 16 $258-

$1,030

Quantity 

Manufactured

or Imported

1 - 4 4 4 - 16 $258-

$1,030

Marketing Data 1 - 2 2 2 - 4

$146-

$292

Date of Initiation

of Manufacture or 

Importation

0.5 4 2 $146

Occupational 

Exposure 1 - 4 2 - 16 1 - 3 2 8 - 46 $462-$2,820

Environmental 

Release 1 - 4 1 - 8 1 - 3 2 6 - 30 $334-$1,790

Occupational 

Description 1 - 10 1 1 - 10 $64-$644
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Health and 

Environmental Data 2 - 8 8 - 40 1 - 3 1 11 - 51 $690-$3,247

Disposal Methods 1 - 2 1 - 6 1 2 - 8

$137-

$532

Attachments 2 - 6 1 2 - 6

$59-

$177

Preparation of

Notice 1 - 3 4 4 - 12 $118-$354

Managerial/Legal 

Review of 

Submission

1 - 4 4 4 - 16 $291-

$1,166

Recordkeeping 1 - 3 4 4 - 12 $118-

$354

TOTAL 9.5 - 29.5 17.5 - 98 7 - 21 67 - 275 $3,711 -

$16,551

6(c) Estimating Agency Burden and Cost

The Agency has developed the following burden hour estimates for activities related to 

promulgating a section 8(a) Chemical Specific rule.

Activity Burden

Industry/Public Assistance (answering 

questions regarding the rule)

0.1 FTE

Data processing and systems support 

personnel

0.2 FTE

Storage and Distribution 0.1 FTE

Compliance monitoring 0.1 FTE

TOTAL FTEs 0.5 FTE

The Office of Pollution Prevention and Toxics bases its burden hour and labor cost 

estimates on prior experience in gathering and processing information associated with other 

information collections. Because these activities involve a team approach, the Agency has used a 

composite burden hour estimate containing workers at various GS levels and calculated hourly

costs based upon the wage rate for a GS-12 Step 1 employee. The 2013 annual salary for a GS12 Step 1 employee in the Washington DC area is $74,872. The cost for 0.5 FTE is $37,436. 

Incorporation of an overhead and benefits factor of 1.6 yields a fully loaded cost of $59,898 to 

the Agency for promulgating and supporting a TSCA section 8(a) chemical-specific rule. The 

full-time work year is considered to be 2,080, so that there are 1,040 burden hours associated 

with 0.5 FTE.
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6(d) Bottom Line Burden Hours and Costs

The following table displays the annual burden and costs borne by respondents and EPA 

associated with preparing, filing and reviewing a notice resulting from a TSCA section 8(a) 

chemical-specific rule.

Table 3. Annual Burden and Cost of a TSCA Section 8(a) Chemical-Specific Rule.

Annual Burden Hours Annual Costs

Industry 67 to 275 $3,711 to $16,551

Agency 1,040 $59,898

6(e) Reasons for Change in Burden

The current request for renewal estimates a total annual burden to respondents of 275 

hours, which is unchanged from the previous ICR renewal. EPA anticipates issuing one TSCA 

section 8(a) chemical-specific rule per year with an average of four respondents submitting 

notices per rule. EPA may promulgate more than one TSCA section 8(a) chemical-specific rule 

per year over the next three years. If EPA does this, the Agency will submit a technical 

amendment to OMB to reflect the change in estimated burden to the regulated industry and the 

government.

6(f) Burden Statement

The public burden for this collection of information is estimated to average 68.8 hours 

per response (one-quarter of maximum annual burden of 275 hours for four notices). Of the 68.8 

hours, 65.8 hours are associated with reporting tasks such as reviewing instructions, gathering 

the data needed, and completing and reviewing the collection of information. The remaining 

three hours are associated with recordkeeping. Burden is defined in 5 CFR 1320.3(b). An 

Agency may not conduct or sponsor such a request and a person or facility is not required to 

respond to a collection of information unless it displays a currently valid OMB control number. 

The OMB control numbers for EPA’s regulations in title 40 of the CFR, after appearing in the 

Federal Register, are listed in 40 CFR part 9 and included on the related collection instrument or 

form, if applicable.

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQOPPT-2013-0458, which is available for online viewing at www.regulations.gov, or in-person 

viewing at the Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). 

The EPA/DC Public Reading Room is located in the EPA West Building, Room 3334, 1301 

Constitution Ave., N.W., Washington, DC. The EPA/DC Public Reading Room is open from 

8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number 

for the EPA/DC Public Reading Room is (202) 566-1744, and the telephone number for the 

Pollution Prevention and Toxics Docket is (202) 566-0280.
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You may submit comments regarding the Agency's need for this information, the 

accuracy of the provided burden estimates and any suggested methods for minimizing 

respondent burden, including the use of automated collection techniques. Submit your 

comments, referencing Docket ID No. EPA-HQ-OPPT-2013-0458 and OMB Control No. 2070-

0067, to (1) EPA online using www.regulations.gov (our preferred method), or by mail to: 

Pollution Prevention and Toxics Docket, Environmental Protection Agency Docket Center 

(EPA/DC), Mailcode: 28221T, 1200 Pennsylvania Ave., N.W., Washington, DC 20460, and (2) 

OMB by mail to: Office of Information and Regulatory Affairs, Office of Management and 

Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, N.W., Washington, DC 

20503.