## Economic Analysis of t he Pro posed Significant New Use Rule f or Di

- **n**
- pentyl Phthalate (DnPP)

FINAL
(EPA Docket EPA

- HQ

- OPPT

- 2010

- 0573

RIN 2070

- AJ 73 )



## — Does not contain TSCA CBI

—

Prepared by:

Economic and Policy Analysis Branch Economics, Exposure and Technology Division

Office of Chemical Safety and Pollution Prevention U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460Economic Analysis of Proposed SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) i Economic and Policy Analysis Branch CONTRIBUTORS

The EPA analyst responsible for this report was Lynne Blake

- Hedges

. Analytical and draft preparation support was provided by Abt Associ ates Inc. under EPA Contract No. EP

- W_08_010.Economic Analysis of Proposed SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) ii Economic and Policy Analysis Branch ABSTRACT

This report estimates the costs of the U.S. Environmental Protection Agency (EPA)’s proposed Significant New Use Rule (SNUR) for Di

- n

- pentyl phthalate (DnPP) ( 1,2

- Benzenedicarboxylic acid, 1,2

- dipentyl ester ) Chemical Abstracts Serv ice Registry Number (CASRN) 131

- 18

- 0

.
The proposed SNUR applies to all manufacturing, import, and processing of DnPP, exclud ing when the substance is used or sold for use as a chemical standard in phthalate testing

- the sole ongoing use of the

chemical

. 1 Asid e from the exempt use, EPA found no evidence of any manufactur ing or importation into

the United States. N o data for DnPP w ere reported in the 2006 Toxic Substances Control Act (TSCA ) Inventory Update Reporting (IUR) database (EPA 2006 a )

. 2 In additio n, the Agency received no

comments after the publication of the Phthalates Action Plan to indicate current production of the chemical for any uses besides use a chemical standard in phthalate testing

. 3

The proposed SNUR would require persons to notify EPA at least 90 da ys befo re commencing the

manufacture

, import, or processing of DnPP for any significant new use as defined in the SNUR

. A firm

inte nding to engage in these activities would be required to submit a Significant New Use Notice (SNUN)

. EPA is proposing the SNUR because of concerns regarding the adverse health effects presented by DnPP in humans and wildlife, as well as its environmental fate and exposure pathways. Although DnPP is no longer used in the United States, EPA is concerned that the manufacturing or processing of

DnPP could be reinitiated in the future. The required notification provided by a SNUN will provide EPA with the opportunity to evaluate activities associated with a significant new use and an opportunity to protect against unreasonable ris ks, if any, from exposure to DnPP. Because the domestic manufacture, import and processing of DnPP for the uses subject to the SNUR have been phased out, there is expected to be n o economic impact from the proposed SNUR.

When submitting a SNUN, a firm incurs a modest submission cost of $ 8, 112 and potentially other minor

costs . However, since no firms have been identified which import

, manufacture

, or process DnPP for any significant new u ses, EPA believes it is highly unlikely that any firm will incur this cost. EPA does not require the development of test data for submission of a SNUN, although a firm may submit test d ata already in its possession or describe any other available data. Because EPA does not requir e the development of test data , EPA assumes that no firms will incur testing costs as a result of the proposed

SNUR.

In addition to the firms that make a SNUN submission, the proposed SNUR may also impact firms that do

not make a submission. By avoiding a significant new use , a firm can avo id submission and testing costs but may incur other compliance costs. However, this may not be a concern given th at the domestic manufacture, import and processing of DnPP for the uses subject t o the SNUR have been phased out

.

C osts are estimated at the firm level and reflect the burden of a SNUR on the firms that would make a

submission.

1 Both Cambridge Isotope Laboratories, Inc. and Accustandard.com sell DnPP as a standard for phthalate testing (CIL 2010a, Accustandard 2010). Columbia Analytical Services, Inc. does not sell DnPP but uses DnPP for on

- site phthalate testing (CAS 2010a).

2 The IUR compiles production data from manufacturers and importers of certai n chemical substances (including DnPP) listed on the TSCA Chemical Substance Inventory. Sites are only required to submit IUR data if they manufacture or import more that 25,000 lbs of a chemical during the reporting year. 2006 was the most recent year

wi th data availability.

3 The docket for the phthalates action plan ( EPA

- HQ

- OPPT

- 2010

- 0342) is accessible at http://www.regulations.gov/search/Regs/home. html#docketDetail?R=EPA

- HQ

- OPPT

- 2010

- 0342Economic Analysis of Proposed SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) iii Economic and Policy Analysis Branch TABLE OF CONTENTS

CONTRIBUTORS

................................ ................................ ................................ ................................ ......... i

ABSTRACT

................................ ................................ ................................ ................................ .................. ii

LIST OF TABLES

................................ ................................ ................................ ................................ ....... iv

1. INTRODUCTION

................................ ................................ ................................ ................................ 1

1.1 Background

................................ ................................ ................................ ................................ . 1

Uses and Substitutes

................................ ................................ ................................ ................... 1

Health Effects

................................ ................................ ................................ ............................. 2 Environmental Expo sure

................................ ................................ ................................ ............ 2 Current Manufacturing

................................ ................................ ................................ ............... 2

1.2 Statutory Authority

................................ ................................ ................................ ..................... 3

1.3 Summary of Methodology

................................ ................................ ................................ .......... 3

1.4 Organization of this Report

................................ ................................ ................................ ........ 3

2. INDUSTRY COMPLIANCE COSTS

................................ ................................ ................................ .. 4

2.1 Wage Rates

................................ ................................ ................................ ................................ . 5

2.2 Unit Industry Compliance Costs

................................ ................................ ................................ . 5

2.2.1 Rule Familiarization

................................ ................................ ................................ ...... 5

2.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup

................ 6

2.2.3 Form Completion and Submission Fee

................................ ................................ .......... 7

2.2.4 Recordkeeping

................................ ................................ ................................ ............... 8

2.2.5 Import Certification

................................ ................................ ................................ ....... 9

2.2.6 Export Notification

................................ ................................ ................................ ........ 9

2.3 Industry Costs of SNUR, by Option

................................ ................................ ......................... 11

2.4 Likelihood of a SNUN Submission

................................ ................................ .......................... 12

2.5 Potential for Subsequent Regulatory Action

................................ ................................ ............ 12

3. AGENCY COSTS

................................ ................................ ................................ ............................... 14

3.1 Labor Rates for EPA Staff

................................ ................................ ................................ ........ 14

3.2 SNUN Processing Costs

................................ ................................ ................................ ........... 15

3.3 Export Notification Cost

................................ ................................ ................................ ........... 18

4. ADDITIONAL ANALYSES

................................ ................................ ................................ .............. 19

4.1 Regula tory Flexibility Act

................................ ................................ ................................ ........ 19

4.2 Unfunded Mandates Reform Act

................................ ................................ .............................. 19

4.3 Paperwork Reduction Act

................................ ................................ ................................ ......... 19

4.4 National Technology Transfer and Advancement Act

................................ ............................. 19

4.5 Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Populations and Low

- Income Populati ons

................................ ................................ ............... 20

4.6 Executive Order 13045: Protection of Children from Environmental Health Risks and Safety

Risks

................................ ................................ ................................ ................................ ......... 20

4.7 Executive Order 13132: Federalism

................................ ................................ ......................... 20

4.8 Executive Order 13175: Consultation and Coordination with Indian Tribal Governments

.... 20

4.9 Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

................................ ................................ ................................ ................................ .................. 20

5. BENEFITS

................................ ................................ ................................ ................................ .......... 21

A. INFLATORS AND WAG E RATES

................................ ................................ ................................ .... 1

6. REFERENCES

................................ ................................ ................................ ................................ ...... 6Economic Analysis of Proposed SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) iv Economic and Policy Analysis Branch LIST OF TABLES

Table 1: Loaded Industry Wage Rates, December 2009

................................ ................................ ............... 5

Table 2: Rule Fami liarization Burden and Cost for SNUR Submitters

................................ ........................ 6 Table 3: CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup Bur den and Cost for

First

- Time Submitters

................................ ................................ ................................ ................................ ... 7 Table 4: Industry Cost Estimate to Complete the SNUN Form

................................ ................................ .... 8 Table 5: Industry Cost Estimate to Complete and Submit the SNUN Form

................................ ................. 8 Table 6: Derivation of Total Mailing Cost for 12 Notices

................................ ................................ .......... 10

Table 7 : TSCA 12(b) Export Notificat ion Cost per Notification

................................ ................................ 11

Table 8 : Compliance Options and Associated Costs Incurred by a Firm Due to the Proposed SNUR

...... 12 Table 9: Derivation of Loaded Agency Wage Rates

................................ ................................ .................. 15 Table 10: Derivation of Inflation Factors for Agency Extramural Costs

................................ .................... 1 6

Table 11: Agency Costs for SNUN and Other Submission Review and Processing

................................ .. 17 Table 12: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2009$)

........................... 18

Table A

- 1: Derivation of Loaded Wage Rates

................................ ................................ .............................. 3

Table A

- 2: Derivation of Inflation Factors

................................ ................................ ................................ ... 5Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) 1 Economic and Policy Analysis Branch 

### 1. INTRODUCTION

This report presents the U.S. Environmental Protection Age ncy (EPA), Office of Chemical Safety and Pollution Prevention’s (OCSSP’s ) analysis of the potential costs incurred as a result of a proposed Significant New Use Rule (SNUR) for Di

- n

- pentyl phthalate (DnPP) ( 1,2

- Benzenedicarboxylic acid, 1,2

- dipentyl ester ) CAS RN 131

- 18

- 0. SNURs are proposed by EPA under the authority granted by Section 5(a)(2) of TSCA. The proposed SNUR would require persons to notify EPA at least 90 days before commencing the manufacture, import, or pr ocessing of DnPP

, excluding when the s ubstance is used or sold for use as a chemical standard in phthalate testing

– the sole ongoing use of the chemical

. Additionally, persons who manufacture or process DnPP solely for export would be exempt from the notification requirements of the proposed SNUR, if when distributing the substance in commerce, it is labeled in accordance with TSCA section 12(a)(1)(B). EPA promulgates a SNUR for a substance when potential uses c o uld result in increased exposure to

, or releases of

, the substance which in turn, could
present an unr easonable risk to health or the e nvironment

.

1.1 Background

As part of EPA’s efforts to enhance the existing chemicals program under TSCA , the Agency identified an initial list of widely recognized chemicals for the development of an Action P lan Phthalates were selected because of their toxicity and the evidence of pervasive human and environmental e xposure

. The Action Plan summarized readily available use, exposure, and hazard i nformation for eight phthalate esters ( including DnPP ); 4 considered which authorities provided under TSCA and other statutes could be used to address potential concerns; and described various courses of actions available to EPA to address the

concerns (EPA 2009d)

. 5

Uses and Substitutes It is important to note that, unless specified , the following sections describe all phthalates, not just DnPP.

The major use of phthalates is as plasticizers , additives incorporated into plastics and elastomers used to impart flexibility and other desirable properties into the ma terial (Austr alian Government 2008a

- h; HSDB

2009 ; Krauskopf and Godwin 2005 ). Phthalate esters make up 92 percent of the plasticizers produced worldwide, while di (2

- ethylhexyl) phthalate (DEHP) makes up 51 percent of those phthalates (Rahman 2004a). It is not clear what portion, if any, DnPP historically contributed to these totals. A major application of plasticizers is in poly vinyl chloride (PVC), which is used in a variety of industrial and commercial products, as well as specialized medical and dental applications. The particular phthalate or combination of phthalates used in a particular product’s formulation depends on the properties the phthalates impart, as well as their cost.

Phthalates can often substitute for each other in specific applications. Furthermore, a lthough phthalates are still the main PVC plasticizers, numerous other substances can serve as substitutes. These include other phthalates, trimellitates, and monomeric plasticizers such as epoxidized soybean oil. Many of these

substit utes h ave specialized uses, and are fr equently more expensive than phthalates

, but some exhibit properties that make them particularly suited to certain applications.

4 The list of eight phthalates was assembled by combining phthalates identified by the Consumer Product Safety Improvement Act of 2008 (CPSIA) and those being evaluated by the EPA for the Integrated Risk Informatio n System (IRIS), based on advice from the National Academy of Sciences (NAS 2008).

5 Accessible at: http://www.epa.gov/opptintr/existingchemicals/pubs/actionplans/phthalates_ap_2009_1230_final.pdfEconomic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) 2 Economic and Policy Analysis Branch Health Effects

A comparison of toxicity information from laboratory animal studies for phthalates as a chemical group allows generalizations to be drawn with respect to certain health endpoints. For example, acute toxicity, skin and eye irritation, and sensitization pote ntial are low for all phthalates tested, and the majority of the phthalates were not genotoxic. The most sensitive health outcomes from phthalate exposure shown in laboratory animals are phthalate syndrome effects, which consist of changes in the fetal dev elopment of the reproductive system (NAS 2008; NTP

- CERHR 2003a

- e, 2006; EC 2003a

- b, 2008a

- b; Australian

Government 2008a

- h). The phthalates that are the most potent at causing phthalate syndrome effects are generally those with linear ester side chains ha ving 4

- 6 carbons (NAS, 2008). DnPP has a linear carbon chain length of 5 carbons.

There are no known human studies of exposure to DnPP. However, s everal human studies have reported associations of exposure of some phthalates with adverse reproductive out comes and developmental effects similar to those in the rat, although no causal link has been established (Swan et al 2005; Huang et al 2009). The reproductive developmental effects observed in humans include shortened anogenital

distance observed in newbo rn boys; and shorted pregnancy, lower sex and thyroid hormones, and reduced sperm quality observed in adults. Recent scientific attention has focused on evaluating the cumulative effects of mixtures of phthalates on testosterone production, fetal mortality , and male and female reproductive development later in life , and shown all mixtures were cumulative for all endpoints (Rider et al. 2008, 2009; Howdeshell et al. 2007, 2008a, 2008b; Gray et al. 2006; Hotchkiss et al. 2004). 6

Based on data discussed in th is section and DnPP’s general structure and categorization as a phthalate, EPA is concerned that human health effect of DnPP exposure may be similar to that observed for some other phthalates.

Environmental Exposure

Phthalates are released in to the environ ment from multiple sources, including: industrial releases; the disposal of manufacturing, processing and industrial wastes; municipal solid waste; land application of sewage sludge; and release from products containing phthalates. Due to their pervasive u se and release, as well their propensity for global transport, various phthalates may be found in most environmental media, including ambient air, surface water, soil, sediment (Babich et al

. 2004; Clausen et al

. 2004; EC 2003 a

- b,

2003

- 04, 2008a

- b; CPSC 2 001

, 2002). Exposures due to environmental releases from the phthalate plasticized PVC material in the environment indicate a potential for bioavailability and bioaccumulation in aquatic and terrestrial food webs. 7

Current Manufacturing

EPA analyzed the most recent data from the TSCA IUR database (2006 reporting) and found no evidence of production of DnPP . Additionally, following publication of the Action Plan, there were no comments provided during the comment period that would provide any indication of ongoing production of DnPP

. 8

6 A major cumulative hazard assessment of phthalates is sch eduled to be conducted by the Consumer Product Safety Commission’s (CPSC’s) Chronic Hazard Advisory Panel (CHAP) as directed by CPSIA, with an anticipated completion date of 2012. However, subsequent internet queries identified several companies which either use or sell DnPP as a

7 Data from the National Health and Nutrition Examination survey (NHANES) in dicates widespread exposure of the general population to phthalates. Biomonitoring data have demonstrated that humans are exposed to phthalates in

utero , as infants, during puberty, and in adult life, and that people are exposed to several phthalates at on ce (CDC 2009).

8 The last year of reported DnPP production in the IUR database was 1990, in which between 100 million and 500 million pounds of DnPP were produced.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) 3 Economic and Policy Analysis Branch chemical standard for use in phthalate testing. 9

1.2 Statutory Authority As a result, EPA is proposing a SNUR for DnPP, excluding use of the substance as a chemical standard in phthalate testing.

Section 5(a)(2) of TSCA (15 U.S.C. 2604(a)(2)) authorizes EPA to determine that a use of a chemical substance is a “significant new use.” EPA must make this determination by rule after considering all relevant factors, including those listed in TSCA section 5(a)(2). Once EPA determines that a use of a chemical substance is a significant new use, TSCA section 5(a)(1)(B) requires persons to su bmit a Significant New Use Notice ( SNUN ) to EPA at least 90 days before manufacturing, importing, or processing the chemical substance for that use (15 U.S.C. 2604(a)(1)(B)).

The general SNUR provisions are found at 40 CFR Part 721, Subpart A.

1.3 Summary of Methodology

This analysis quantifies, to the extent possible, the costs to society of the proposed rule by identifying the costs to industry associated with performing the required reporting and recordkeeping, and the costs to EPA of administering the ru le. Industry costs may consist of rule familiarization; registration with the Central Data Exchange (CDX) electronic reporting tool; collection, compilation, and submission of required information for significant new uses of the subject chemicals; export n otification; and recordkeeping. Agency costs include reviewing and processing the data received as a result of the rule. Data sources for this analysis include burden estimates derived from previous information collection requests and economic analyses for related rules, compensation data acquired from government publications, and supplementary market research.

1.4 Organization of this Report

The remainder of this report provides EPA’s economic analysis in support of the proposed rule. Section 2 presents estimates of the costs incurred by manufacturers

, importers, and/or processors under the SNUR options. Section 3 shows estimates of the government costs associated with the administration of the proposed rule. Chapter 4 pre sents an analysis of other impacts, as required by various statutes and

executive orders

.

Note that all dollar amounts in this analysis are reported in December 2009 dollars

, which is the latest

year for whic h complete data are available.

9 Both Cambridge Isotope Laboratories, Inc. and Accustandard.com sell DnPP as a standard for phthalate testing (CIL 2010a; Accustandard 2010). Columbia Analytical Services, Inc. does not sell DnPP but uses DnPP for on

- site phthalate testing (CAS 2010a). It is not known what proportion of the market these three companies represent, nor how larg e the market is; however, given the IUR data and the lack of public comments received following the Action Plan, it is likely that this ongoing market is small.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) 4 Economic and Policy Analysis Branch 

### 2. INDUSTRY COMPLIANCE COSTS

The proposed SNUR discussed in this report specifies that significant new use s of DnPP that require reporting under section 5(a)( 2 )(A) of TSCA include the manufactur e , import, or pr oce ssing of DnPP,
except when used or sold for use as a chemical standard in phthalate testing

. Th erefore

, a firm intending to manufacture, import, and/or process DnPP for any use other than as a chemical standard in phthalate testing m ust submit a SNUN. Alternativel y, a firm can decide not to manufacture, import, and/or process

th e chemical for a significant new use

. The firm

, therefore

, has two options:

**•** Option 1: Submit a SNUN

. A SNUN indicates to EPA that the firm would like to manufacture, import, and/or process the chemical for a significant new use , which, in this case, means any manufacture, importing, and/or processing of this chemical or articles containing the chemicals

, except use as a chemical standard in phthalate testing

. 10

. 11

2.2.6 The firm must submit the SNUN to EPA at least 90 days before it plans to commence the manufacture, import, and/or processing of the substance; the SNUN provides EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs. If EPA allows the manufacture, import, or processing of DnPP for the intended use

, then the costs associated with this option are the costs of submitting the SNUN (in cluding a user fee) plus

, if there is any export of these products

, the export notification costs that result from TSCA Section 12(b) requirements that are automatically triggered for chemicals regulated under TSCA Section 5 (see Section for details)

. Because the domestic manufacture, import and processing of DnPP for the uses subject to the SNUR have been phased out

, EPA expect s that no firms will choose this option.

**•** Option 2: Decide not to manu facture, import, and/or process the chemical

. The firm may decide simply not to proceed to manufacture, import, and/or process the chemical. While this option avoids

the costs of submitt ing a SNUN, it entails the ‘hidden’ cost of the profit that will be foregone as a result of not engaging in the commercial activity originally planned. Similarly, if the firm would have used a given amount of DnPP in the production of another product, and must substitute to a more costly substance, it will incur those additional “ hidden ” costs of production. However, these hidden costs are expected to be minimal , if not zero, because DnPP is not currently manufactured in the United States except as a chemic al standard for use in phthalate testing

. If the firm elects to produce

DnPP for research and development (R&D) purposes only ( an exemption for R&D purposes is provided in 40 CFR §721.47), it may have costs associated with R&D recordkeeping.

Because the domestic manufacture, import and processing of DnPP for the uses subject to the SNUR have been phased out

, EPA does not expect there to be compliance cost associated for either of the options. The remainder of this chapter estimates the quantified portio n of costs as sociated with the proposed

SNUR . Section 2.1 summarizes the wage rates used in this chapter. Section 2.2 provides the unit industry compliance costs, including the costs of rule familiarization, registration with the Central Data Exchange

10 EPA notes that, in accordance with TSCA section 12(a) and 40 CFR 721.45(g), persons who manuf acture or process DnPP solely for export would be exempt from the notification requirements of 40 CFR 721.25, if when distributing the substance in commerce, it is labeled in accordance with TSCA section 12(a)(1)(B). Further, EPA notes that the exemption f rom the TSCA section 12(b) notification requirements for exported articles ( see 40 CFR 707.60(b)) would remain in force. Thus, persons who export DnPP as part of an article would not be required to provide export notification.

11 Section 5(h)(3) of TSCA, 15 USC 2604(h) exempts substances that are manufactured in small quantities solely for

research and development (R&D) from the section 5(a) notice requirements. No application is require d for the exemption for R&D und er section 5(h)(3) (U.S. EPA 1986)

.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) 5 Economic and Policy Analysis Branch ( CDX ) electronic reporting tool, completing the SNUN form, submission fee, import certification, and export notification. Total costs under each option are presented in Section 2.3

.

2.1 Wage Rates

The proposed rule involves activities that may require efforts by employees in three labor classifications: managerial, technical, and clerical. Costs for each activity are calculated by estimating the labor hours required in each labor category and multiplying those burdens by the wage rate for each labor category. This section presents the estimated wage rate in each labor category.

Loaded wage rates for managerial, technical, and clerical personnel are derived by combining data on wages and fringe benefits with estimates of over head rates, following the methodology described in “Wage Rates for Economic Analysis of the Toxics Release Inventory Program” ( EPA 2002b ). Wage data for each labor category in December 2009 are provided by the Employer Costs for Employee Compensation (ECEC ) Supplemental Tables available on the BLS website ( BLS 2010 a ). The loaded wage rate for managerial labor is $68.24; for technical labor, $59.49; and for clerical labor, $28.31. Table

1 presents the basic data used to calculate the loaded wage rates for all three categories of labor.

Table 1 : Loaded Industry Wage Rates, December 2009

Labor Category Data Sources Wage (2009$) Fringe

Benefit (2009$) Fringes

as %

wage Over

head %

wage 2 Fringe +

overhead

factor Loaded Wages 1
(2009$)

(a) (b) (c) =(b)/(a) (d) (e)=(c)+ (d)+1 (f)=(a) x (e)

Managerial BLS ECEC , Private Manufacturing industries

, “Mgt, Business, and Financial” 3 $42.36 $18.68 44.10% 17% 1.61 $68.24

Professional/

Technical BLS ECEC , Private Manufacturing industries

, “Professional and related“ 3 $35.96 $17.42 48.44% 17% 1.65 $59.49

Clerical BLS ECEC , Private Manufacturing industries,

“Office and Administrative Support” 3 $17.21 $ 8.17 47.47% 17% 1.64 $28.31

1 Wage data are rounded to the closest pennies in this table.

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 Employer Costs for Employee Compensation Supplementary Tables: December 200 9

. US Bureau of Labor Statistics, March 1 0

, 20 1

- (BLS 20 10a ).

2.2 Unit Industry Compliance Costs



### 2.2.1 Rule Familiarization

The proposed rule requires submitters and their staff to become familiar with the SNUR and its various requirements. The per company burden associated with r ule familiarization is approximately 0.55 hours of technical labor and 0.27 hours of managerial labor, as described in the Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule ( EPA 2009a )

. As shown in Table 2 the total labor cost associated with rule familiarization by a first

- time reporter is $50.92.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) 6 Economic and Policy Analysis Branch Table 2 : Rule Familiarization Burden and Cost for SNUR Submitters

Reporting Activity Clerical Labor (at $28.31/hour) Technical Labor (at $59.49/hour) Managerial Labor (at $68.24/hour) Total Labor Cost

Burden (hours) Cost (2009$) Burden (hours) Cost (2009$) Burden (hours) Cost (2009$) Burden (hours) Cost (2009$)

Rule Familiarization 0.00 $0.00 0.55 $32.72 0.27 $18.20 0.82 $50.92

Total 0.00 $0.00 0.55 $32.72 0.27 $18.20 0.82 $50.92

Source : BLS 2010 a (labor rates) ; EPA 2009a (burden hours)



### 2.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup

The proposed SNUR requires first

- time submitters (that is, those companies who have not submitted information to EPA through CDX before) to register their company and key users with the CDX reporting tool, deliver a CDX electronic signature to EPA, and establish and use a Pay.gov E

- payment account

. 12

**•** CDX registration: EPA estimates that companies will spend approximately 0.18 hours per employee to register with CDX, and that an average of four technical staff members and one manager will need to register for each company, totaling approximately 0.92 hours of burden per

company. Thes e activities are only required of first

- time submitters (companies already registered with CDX would

not need to re

- register for the purposes of complying with the proposed SNUR) . The burdens associated

with these activities were estimated in the Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule ( EPA, 2009a ) and are described in more detail below :

**•** CDX electronic signature: EPA estimates that companies will spend 0.25 hours preparing, submitting, and filing an electronic signature agreement (Authentication of Identity) form to EPA per employee

. This burden will apply to four technical staf f members and one manager per company, totaling to 1.25 hours of burden per company

. In addition, EPA estimates that a manager will spend an additional 0.50 hours accessing, preparing, and submitting verification forms (Verification of Authorization) for a ll authorized submitters to EPA

. The total burden incurred by companies submitting and then verifying electronic signature agreements is 1.75

hours

. Note that this burden does not include any additional time required to contact EPA’s CDX help desk to notif y a change of submitter status, should one occur.

Filing the electronic signature agreement requires an additional mailing cost of $2.30 per company (including five $0.44 stamps and five $0.02 business envelopes) (USPS 2010)

.

**•** Payment via Pay.gov account : EPA estimates that one manager per company will spend approximately 0.13 hours setting up a Pay.gov ID account, logging into the system, finding the appropriate form, and filling it out

. This burden does not include the time required to click

‘submit’ on the form and wait for payment processing.

As shown in Table 3

, the cost associated with CDX registration, CDX electronic signature, and Pay.gov account setup is $17 8

. 2 1 , and this cost is only incurred by a first

- time submitter.

12 Alt hough the proposed rule does not specifically require submitters to establish and use a Pay.gov account, the burden estimates in this analysis are conservative insofar as to include the use of Pay.gov as a required activity

.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) 7 Economic and Policy Analysis Branch Table 3 : CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup Burden

and Cost for First

- Time Submitters

Reporting Activity Clerical Labor (at $28.31/hour) Technical Labor (at $59.49/hour) Managerial Labor (at $68.24/hour) Total Cost

Burden (hours) Cost (2009$) Burden (hours) Cost (2009$) Burden (hours) Cost (2009$) Burden (hours) Cost (2009$) CDX Registration 0.00 $0.00 0.73 $43.63 0.18 $12.51 0.92 $56.13

CDX Electronic Signature 0.00 $0.00 1.00 $59.49 0.75 $51.18 1.75 $110.67 Mailing Cost $2.30

E

- Payment ( Pay.gov ID) 0.00 $0.00 0.00 $0.00 0.13 $9.10 0.13 $9.10

Total 0.00 $0.00 1.73 $103 1.07 $72.79 2.80 $17 8

Source : BLS, 2010a (labor rates) ; EPA, 2009a (burden hours); USPS, 2010 (mailing cost)



### 2.2.3 Form Completion and Submission Fee

Respondents are required to gather and submit information regarding the data elements identified in the applicable SNUN reporting form

. The methodology and calculations used in this analysis assume that the employee responsible for collecting, filling out, and submitting the requested information has a

reasonable level of fam iliarity with the company and knowledge of operations at the site

. It is assumed that for most entities these tasks are similar to other employee duties that require familiarity with EPA, State, and other Federal agency requests for chemical information an d do not require additional familiarization or training beyond the basic rule familiarization described above

. In addition, this analysis focuses on the marginal costs of submitting information for the proposed rule and not the total costs for the company to comply with a range of other Federal and State environmental, health, and safety regulations or accounting requirements that rely on this type of information.

Estimates of the costs of completing a Significant New Use Notice (SNUN) form are based on the costs of completing a Premanufacture Notification ( PMN ) submission, since the data requirements are the same

and the same form is used for both

. The PMN submission costs are based on EPA's 1994 Regulatory Impact Analysis of Amendments to Regulations for T SCA Section 5 Premanufacture Notifications and the updates to this estimates in 2009 ( EPA 2009a ). The original 1994 estimates relied on industry estimates of the effort needed to collect and compile all data required for a PMN submission, prepare the form, submit the form and data to EPA, and mainta in a file of the submission (EPA 1994 )

. 13 The 1994 estimates were based on a survey conducted by the Chemical Manufacturers Association ( CMA 1991 ), which became the American Chemistry Council

. These burdens “ include the time spent reading and becoming familiar with the form, gathering the required information and preparing the report, producing sanitized responses for

items claimed as confidential business informatio n, and maintaining a file of the submission” ( EPA,

1994 )

. 14 The burden associated with SNUN submission and preparation has been adjusted to reflect burden reductions resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that requires the

electr onic submission of all TSCA section 5 notices

. Electronic submission of SNUN forms is expected to remove all clerical burden associated with preparing a SNUN ( EPA 2009a ) 15

13 Table III

- 2 and pages III

- 11,

- 12, and

- 13

. . In addition, electronic

14 p. III 11

- 13

15 The Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009 a )

estimates a 0.5 hour clerical burden and a 0.5 hour technical burden associated with recordkeeping in addition to the

burd en estimates from the 1994 RIA, which include the burden for recordkeeping ( EPA, 1994 , p. III

- 14) . T hese

burden estimates are based on the recordkeeping burden for polymer exceptions and not the recordkeeping burdenEconomic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

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- pentyl Phthalate (DnPP) 8 Economic and Policy Analysis Branch su bmission is expected to generate and an additional 0.18 ho urs of technical burden, for the completion of the User Fee Payment Identification Number and e mail a ddress data elements on the electronic SNUN

form.

SNUN form completion and electronic submission is estimated to require 7 3

. 68 hours of technical labor

an d 18.00 hours of managerial labor

. Table 4 combines the estimated reporting burden and loaded wage rates for all three labor categories to estimate the per

- SNUN cost of form completion

. The labor cost incurred by a SNUN submission for both large and small business submitters is $5, 6 12

.

Table 4 : Industry Cost Estimate to Complete the SNUN Form

Reporting Activity Clerical Labor (at $28.31/hour) Technical Labor (at $59.49/hour) Managerial Labor (at $68.24/hour) Total Labor Cost

Burden (hours) Cost (2009$) Burden (hours) Cost (2009$) Burden (hours) Cost (2009$) Burden (hours) Cost (2009$) Form Completion 0.00 $0.00 73.68 $4,414 18.00 $1,228 9 1.68 $5, 6 12

Source :

1 Loaded wages include fringe benefits and overhead. See Appendix A of this report for derivation. Wage rates presented in this table are rounded values; however, unrounded values are used to calculate total labor costs. For this reason, total labo r costs may not equal the product of rounded values.

2 The estimate of no c lerical burden is taken from the Economic Analysis of the Premanufacture Notice Electronic Reporting Final Rule (EPA, 2009a, page 7)

3 T echnical and managerial labor burden is from the PMN Amendments RIA (EPA, 1994, Table III

- 2). An additional eleven

minut es (0.18 hours) of technical burden is estimated to complete the User Fee Payment Identification Number and Email Address data elements on the Electronic SNUN form (EPA, 2009a page 15).

In addition, each submitting large business must pay a $2,500 per

- SNUN submission fee, and each submitting small business must pay a $100 per

- SNUN submission fee

. Table 5 adds the labor cost and

submission fee to estimate the total cost of a SNUN submission

. The total cost of a SNUN submission is $8,14 3 for large business submitters and $5,74 3 for small business submitters.

Table 5 : Industry Cost Estimate to Complete and Submit the SNUN Fo rm

Reporting Population Labor Cost Submission Fee Total Cost (2009 $ ) Large Business Submitters $5, 6 12 $2,500 $8, 1 12

Small Business Submitters $5, 6 12 $100 $5, 7 12

Source : EPA, 2009a

.



### 2.2.4 Recordkeeping

Companies submitting a SNUN must keep records under 40 CFR §721.40. Some EPA reports have assumed that SNUN recordkeeping hours would be five percent of SNUN submission hours, or about five

to six hours

. For this report, the SNUN recordkeeping hours were included in the SNUN submission hours (see Section 2.2.3 ) and were not separately estimated

. 16

associated with PMN submissions. Therefo re
, for this analysis we assume that any reduction in recordkeeping burden is captured in the reduction of the clerical burden, and we do not consider the one hour recordkeeping burden

from the ePMN EA in order to avoid double counting

. 16 SNUN submission c osts estimated in Section 2.2.3 of this report were based on PMN submission costs from a 1994 report, Regulatory Impact Analysis of Amendments to Regulations for T SC Section 5 PremanufactureEconomic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

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- pentyl Phthalate (DnPP) 9 Economic and Policy Analysis Branch 

### 2.2.5 Import Certification

In general, promulgation of a final SNUR triggers a TSCA Section 13 import certification requir ement and the corresponding regulations at 19 CFR 12.118 to 12.127 and 19 CFR 127.28 for all imports of the

relevant chemical substances

. Thus, any U.S. manufacturer, importer, or processor receiving an imported shipment of chemicals subject to the propose d SNUR would have to certify that all chemical substances in the shipment either comply with all applicable rules and orders under TSCA or that all chemical substances in the shipment are not subject to TSCA. 17

In practice, import certification is fulfilled by checking a box on an invoice or entry document and generally imposes no additional burden or cost on the importer ( EPA 2009b )

. Any potent ial burden associated with a submitter’s familiarization with this requirement is assumed to be included in the more general SNUR familiarization burden discussed above. The statement must be on or attached to a

comm ercial invoice or entry document belonging to the imported shipment.



### 2.2.6 Export Notification

Under Section 12(b) of TSCA, exporters must notify EPA if they export or intend to export a chemical or an article subject to various TSCA sections ( 40 CFR §707.60 through 75 )

. 18 For TSCA 5(a)(2) (the section under which EPA promulgates significant new use rules) and certain other TSCA sections, this is

a one

- time notification requirement per destination country for each exporter of a chemical substance

. 19

Exporter Costs After receiving a notification from a firm, EPA notifies the importing country and the United States St ate Department ( 40 CFR §707.70 )

. To calculate the burden associated with making export notifications, EPA first estimated the average annual number of export notifications made by an exporter

. EPA then derived the annual and per notification burden associa ted with preparing and submitting an export notification.

20

The 2009 TSCA Section 12(b) ICR estimated the annual export notification cost for an exporter under the

one

- time export notification requirement ( EPA 2009b). 21

Notifications ( EPA , 1994)

. Page III

- 14 of the 1994 report refers to “the normal records kept with a PMN submission which are included in the estimates for submission costs.” Page III

- 12 identifies “maintaining a file of the

subm ission” as part of the labor hours for the PMN reporting form. These statements imply that the 95 to 114 total hours for a PMN submission (page III

- 10 of EPA 1994) included recordkeeping hours. These costs include the cost to the exporter of compiling a list of their products that are subject to TSCA Section 12(b) requirements, writing or revising

17 The exact statements are as follows: For imports of chemical substances subject to TSCA, “I certify that all chemical substances in this shipment comply with all applicable rules or orders under TSCA and that I am not offering a chemical substance for entry in violation of TSCA or any applicable rule or order under TSCA.” For imports of chemical substances not subject to TSCA (e.g., pesticides), “I certify that all chemicals in this shipment are not subject to TSCA.” ( 40 CFR 707.20 )

18 While companies which manufacture or process DnPP solely for export are exempt from the notification requirements of 40 CFR 721.25 if the DnPP is labeled in accordance with TSCA section 12(a)(1)(B), they are required to submit export notifications under s ection 12(b).

19 On November 14, 2006, EPA revised the export notification requirement for chemicals subject to TSCA §5(a)(2), 5(b), 5(e)(1) and 5(e)(2) from an annual to a one

- time requirement per destination country for each exporter ( November 14, 2006, 7 1 FR 66234 ).

20 Most underlying data in this section come from the 2009 TSCA Section 12(b) ICR, ICR No.: 0795.13 [Information Collection Request for] Notification of Chemical Exports

- TSCA Section 12(b) Supporting Statement for Request for OMB Review unde r the Paperwork Reduction Act (EPA 2009b), with updating for inflation.

21 page 11, Table 3Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

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- pentyl Phthalate (DnPP) 10 Economic and Policy Analysis Branch an export notification letter to EPA, checking the outgoing shipments, and sending the notification letters with the associated shipping costs

.



### The per

- notification cost was calculated based on the assumption that the average exporter mak es 12 notifications per year

. 22

Estimated Submission (Mailing) Costs

. Regulated companies will incur mailing costs for export

notifications delivered to EPA

. Notifications are assum ed shipped via the U.S. Postal Service (USPS) as

first

- class registered mail with a return receipt ( USPS 2010)

. The estimated per

- shipment and annual mailing costs incurred by individual submitters are detailed in Exporters making more notifications per year may benefit from economies of

scale and h ave lower costs per notification; those making fewer notifications may have higher costs per

notification.

Table 6

.

Table 6 : Derivation of Total Mailing Cost for 12 Notices

Dates that the rates were verified on United States Postal Service web site: April 2010

Postal services costs
Registered mail, regular, with $0 declared value $10.60

Return receipt, requested at time of mailing (receive by mail) $2.30

Postage, regular First Class, up to 1 ounce $0.44

Cost per export notice

– Subtotal $13.34

Source : Mailing rates are from the US Postal Service web site as of April 2010 ( http://www.usps.com/prices/)

. The mailing

method comes from the Economic Analysis of the Proposed Change to TSCA Section 12(b) Export Notification Requirements , November 2005 ( EPA, 2005), as clarified in a later SNUR economic analysis ( EPA, 2007 a , Table 8 ).

Compile and Maintain the List of Products

. Since TSCA §12(b) information collection activity has been in place for twenty yea rs, most respondents will have already developed a list of th eir products subject to TSCA §12(b) export notification. Respondents need only check for new regulations promulgated and any new products exported by the company. Updating the list is estimated to take an average of one hour of technical time, which may al so include some proportion of legal time ( EPA 2009b ). The total burden can vary from two hours per year up to two hours per mont h, depending on the number of products exported by the company and the number of their products subject to TSCA §12(b) ( EPA 2009b ).

Write or Revise Export Notification

. Companies that export chemicals subject to TSCA §12(b) reporting must prepare an export notification to send to EPA when export shipments are made Those that manufacture or process DnPP solely for export are ex empt from SNUN requirements, but will be required to submit export notifications. Time for initial preparation of the export notice may vary depending on whether the company has prior experience with this requirement

. This step is estimated to take an aver age of one hour of technical time (which may also include some proportion of legal time) per firm per year , or 0.08 hours per notification, assuming that an average facility submits 12 notifications per year

, ( EPA

2009b ). EPA currently has no evidence tha t companies export DnPP

.
Check Orders and Send Notifications

. Companies that export chemicals subject to TSCA §12(b) reporting must check outgoing shipments against the list of their products described above

. A form letter notifying

22 EPA calculated the average number of export notifications per exporter in the 2009 TSCA Section 12(b) ICR ( EPA 2009b) by dividing the estimated number of submitte d notifications (3,500) by the estimated number of exporters (300 ).Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

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- pentyl Phthalate (DnPP) 11 Economic and Policy Analysis Branch EPA and providing the r equired data must be printed and mailed within the required time period

. This process is estimated to take an average one half hour of clerical time per export notification ( EPA 2009b ).

The burdens and associated costs for each notification activity are p rovided in Table 7 below.

Table 7 : TSCA 12(b) Export Notification Cost per Notification

Technical Clerical Total

$/Hr Hours 2009$ $/Hr Hours 2009$ Hours 2009$
Compile list $59.49 0.78 $46.08

-- -- -- 0.78 $46.08

Write letter $59.49 0.08 $4.96

-- -- -- 0.08 $4.96

Check order and send

notice -- -- -- $28.31 0.50 $14.17 0.50 $14.17

Mailing cost 1

-- -- -- - $13.34
Total per n otification 0.86 $51.04 0.50 $14.15 1.36 $78.5 4

Notes:

1 Mailing costs reflect April 20 10 USPS rates and can be found in Table 6

. 2 Per notification costs are based on a n average facility submitting 12 export notifications per year.

Source: ICR No.: 0795.13 [Information Collection Request for] Notification of Chemical E xports

- TSCA Section 12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction Act ( EPA 2009b , p.10)

, and are updated to 2009 dollars.

2.3 Industry Costs of SNUR, by Option

The number of firms affected by not making submissions to EPA is not known; therefore, costs are not aggregated across the affected entities. Table 8 summarizes the co sts to comply with the proposed rule, as

described in more detail in section 2.2 above.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

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- pentyl Phthalate (DnPP) 12 Economic and Policy Analysis Branch Table 8 : Compliance Options and Associated Costs Inc urred by a Firm Due to the Proposed SNUR

Option 1 Costs Quantified Costs per Chemical (2008$) 2

1. Electronic submission of a Significant New Use Notice (SNUN), indicating to EPA that

the firm would like to manufacture, import, or process the

chemical for a Significant New Use

as defined in the

SNUR

. Costs of e lectronically submitting a SNUN, including rule familiarization, CDX registration (for companies that are first

- time submitters), form completion, user fee, export notification cost ( if

relevant )

. Rar ely, a firm may choose to conduct toxicity or fate testing to support the SNUN, but such testing is not required by law

. $50.92 rule familiarization cost; $8, 112 submission cost (including SNUN recordkeeping and $2,500 fee). EPA usually

receives well unde r ten SNUNs per year. Based on review of recent SNUNs, it appears that firms rarely conduct toxicity or fate testing to support a SNUN (such testing would be voluntary). 3 Export notifications costs are estimated at $78.56 per notification; total cost

per company will vary based on the number of countries of export

. Those submitting information electronically through CDX for the

first time w ould incur $178 for CDX registration and associated activities.

2. Decide not to manufacture, import, or process the chemical for any non

exempt uses. Cost of the profit foregone as a result of not engaging in the commercial activity originally planned (opportunity costs)

. Other

costs include rule familiarization

, and exp ort notification costs. Opportunity costs are not quantified. Other

costs including rule familiarization ($50.92), and export notification costs ($78.56 p e r notification if the chemical is exported only ) would apply.

Notes:

1 Firms may experience costs related to both options at once since submission of a SNUN results in profits foregone as a result of not manufacturing, importing, or processing the chemical. Additionally, export notification costs are somewhat independent of the option because the produ ction of DnPP for export purposes only is not subject to the proposed SNUR notification requirements under 40 CFR 721.25.

2 Quantified costs are attributable to the SNUR only if a firm would not otherwise follow the specified practices.

Costs are detaile d in Section 2.2

. 3 EPA does not require the development of test data for submission of a SNUN, although a firm may submit test data already in its possession and/or describe any other available data. Because EPA does not require the development of test data, EPA assumes that no firms will incur testing costs as a result of the proposed SNUR.

2.4 Likelihood of a SNUN Submission

Because the domestic manufacture, import and processing of DnPP for the uses subject to the SNUR have been phased out (see section 1.1 ), very few, if any, entities are expected to submit a SNUN.

2.5 Potential for Subsequent Regulatory Action

EPA recognizes that if submission of a SNUN does result from the proposed SNUR, the Ag ency may take a dditional regulatory actions under TSCA. These additional regulatory actions might be necessary to further evaluate an intended new use and associated activities, or to prohibit or limit that activity before it occurs to prevent unreasonable risk of injury to human health or the environment. It is not known what specific subsequent regulatory actions, if any, the Agency may determine are necessary after reviewing a SNUN. Any such actions are highly dependent on the circumstances surrounding t he individual SNU N (e.g., available information and scientific understanding of the chemical and its risks at the time the SNUN is being reviewed).

Should EPA’s review of the SNUN result in further regulatory actions, the Agency will initiate and

follow t he appropriate procedures for taking those actions

. Included in those procedures would be an

assessment of the costs and benefits of those actions.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

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- pentyl Phthalate (DnPP) 13 Economic and Policy Analysis BranchEconomic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

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### 3. AGENCY COSTS

As described in the following sections, EPA’s costs to review and process SNUN submissions are

assumed to be the same as EPA costs to review PMNs.

3.1 Labor Rates for EPA Staff

Agency labor costs are calculated based on annual Federal salaries for the Washington

- Baltimore area published by the Office of Personnel Management effective January 200 9 (OPM 200 9 ) . EPA assumes that, on average, a federal GS

- 13, Step 5 full

- time equivalent (FTE) will conduct its collection and administrative activities under the proposed rule. 23

Table 9 The average salary for a GS

- 13 Step 5 employee was $ 98,518 in 200 9 without fringe benefits and overhead costs

. In order to derive the fully loaded salary, EPA multiplied the annual salary by an assumed loading factor of 1.6 to reflect federal fringe benefits and overhead, which results in a fully loaded annual salary o f $157,629 (see ). Divi ding the fully loaded annual salary by 2,080 hours (i.e., the number of hours in a work year) yields an hourly FTE compensation wage rate of $ 75.78.

The Agency loading factor of 1.6 is from an EPA guide entitled Instructions for Preparing Information Collection Requests (ICRs) ( EPA 1992 ). 24

The annual costs per FTE are derived by multiplying the annual pay rate by 1.6 (the benefits

mu ltiplication factor)

. The multiplication fa ctor used is recommended in EPA’ s Office of Policy, Planning, and Evaluation’s Instructions for Preparing Information Collection Requests (ICRs) (June 1, 1992)

. An EPA internal phone call between Carol Rawie (OPPT /EETD/RIB) and Carl Koch (OPPE/RMD/IMB) on May 3, 1994, indicated that the 1.6 factor included not only benefits

but also overhead

. The 60 percent assumption was labeled “the benefits multiplication factor” in the EPA guide, but has been used in many EPA OPPT ICRs to reflect both f ringe benefits and overhead for federal staff. For example, it was used in a document supporting EPA ICR No. 1139.06 ( EPA 2000 ), with the following explanation:

Fully loaded costs for Agency labor are shown in Table 9

.

23 The GS

- 13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007) (EPA, 2007b), which covers PMN SNURs. Use of this grade level follows the approach introduced in EPA, 2007b. That report represented a change from an earlier PMN SNUR economic analysis (EPA, 2003), which used an average of GS

- 12 Step 1 and GS

- 12 Step 10

salaries.

24 page 30, footnote 9.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

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- pentyl Phthalate (DnPP) 15 Economic and Policy Analysis Branch Table 9 : Derivation of Loaded Agency Wage Rates

Labor Category Data Source for Wage

Information Date Wage Fringe

Benefit Fringes as % wage Overhead as % wage Fringe +

overhead

factor Loaded Wages (a) (b) (c)=(b)/(a) (d) (e)=(c)+(d)+1 (f)=(a) * (e)

EPA staff

FTE Annual federal staff cost: OPM Washington

Baltimore

- Northern Virginia, DC

- MD

- PA

VA

- WV, area, GS

- 13 Step 1 pay rates a Dec

09 $98,518 (annual)

-- [Included

in 60% overhead] 60% b 1.60 $157,629 (annual)

$47.36 (hourly) $75.78 (hourly)

Notes :

a The Agency salary is the unloaded federal GS

- 13 Step 5 salary ($98,518 for 2009), from the OPM salary table for the Washington

- Baltimore

- Northern Virginia Locality Pay Area ( OPM 2009 )

. Hourly rates are based on annual salary divided by 2,080 hours.

b The 60% fringes

- and

- overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) ( EPA 1992 , page 30, footnote 9).

3.2 SNUN Processing Costs

The list of review steps, estimates of extramural costs, and the percent of chemicals requiring a particular review step are derived from the costs for processing PMN submissions in a1994 EPA report entitled, Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications ( EPA 1994 ). 25 The Agency burden associated with processing a PMN has been adjusted to reflect burden reductions resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that requires the electronic submission of all TSCA section 5 notices . Electronic submission of SNUN forms is expected reduce Agency burden by 16.5 percent ( EPA, 2009a )

. 26

For each review step, the “EPA staff” cost is calculated by multiplying the number o f FTEs (in the first column) by the fully loaded hourly salary. This shows EPA staff cost for chemicals requiring the selected review step.

The Extramural Cost column shows costs for contractor support and other outside purchases for chemicals requiring t he selected review step is inflated from 1993 prices using the Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) data (BLS 2010b). T he not seasonally adjusted E CI for total compensation of private industry professional and related workers (Serie s ID CIU2010000120000I )

is used because it is the only series with continuous data since 1985 , and that includes professional and technical labor, which perform the majority of Agency extramural activities. Table 10 , below contains the derivation of inflation factors for Agency extramural costs.

25 Table VII

- 1.

26 p. 28.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

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- pentyl Phthalate (DnPP) 16 Economic and Policy Analysis Branch Table 10 : Derivation of Inflation Factors for Agency Extramural Costs

Item Inflation index source Starting

year Index for starting

year

(a) Index

for

2009

(b) Inflation

factor (b)/(a) 2

Agency Extramural costs White collar labor; equipment; supplies BLS ECI, Total comp, Private industry, Professional and related

, 4 th Q [BLS 2010d] 4 1993 67.0 111.4 1.663

Source:

Bureau of Labor Statistics

. Employment Cost Index

– Total Compensation: Professional and Related Private Industry, Not Seasonally Adjusted. (Series ID: CIU2010000120000I) , extracted April 12, 2010 (BLS 2010b).

The Percent of Cases column in Table 11 is a weighting factor applied to reflect the fact that not all chemicals require each review step. For example, in the PMN process, all chemicals require Administrative Prescreening, but not all chemicals requi re the intensive scrutiny of “Standard Review.” The three types of submissions resulting from a SNUR may have weighting factors that differ from each

other a nd from the weighting factors for PMNs. Changes in weighting factors could cause actual review costs to be higher or lo wer than calculated here. For example, some SNUNs require little review because they are determined to be “invalid”

– i.e. not required i n the first place. However, often a SNUN may take more Agency time than a typical PMN because of factors such as the need to retrieve old PMN records from archives, and the likelihood that more data requiring EPA review is submitted with a SNUN than

would be submitted

, on average
, with a PMN. Resources were not available to update the review hours to reflect the current review process or to tailor the cost estimates to SNUNs. Therefore, for this analysis, the review steps and weighting factors are assumed to be the same as those de rived in 1994 for PMNs.

The Weighted Cost column is calculated by multiplying the u n

- weighted Costs (EPA staff cost plus extramural costs) by the percentage of cases requiring this review step. Weighted c osts are then multiplied by the burden reduction of 16.5 percent to account for burden savings generated electronic submission.

A s shown in Table 11

, t h is calculation yields total Agency costs of $4,934, per SNUN, for submission review and processing

.Economic Analysis of SNUR for 17 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) Economic and Policy Analysis Branch Table 11 : Agency Costs for SNUN and Other Submission Review and Processing

Review Steps EPA staff (FTE) Cost Extramural Cost 2 Unweighted

Cost Pct. of

Cases Weighted

Cost 3 ePMN

Burden

Reduction 4 Weighted Cost

with ePMN

Burden Reduction FTE

fraction Cost per

FTE 1 FTE Total ($2009) 1993

dollars 2009

dollars (a) (b) (c)=(a)*(b) (d) (e) (f)=(c)+(e) (g) (h)=(f)*(g) (i) (j)=(h)*(1

- (i))

Pre

- notice consultation 0.0024 $157,629 $378 $4.00 $6.65 $385 41% $158 0.165 $132
Administrative prescreen/ notice receipt/user fee 0.0024 $157,629 $378 $92.00 $152.97 $531 100% $531 0.165 $444

CRSS (Chemical Review and Search Strategy) 0.0025 $157,629 $394 $268.00 $445.60 $840 100% $840 0.165 $701

SAT (Structure Activity Team) 0.0006 $157,629 $94.58 $14.00 $23.28 $118 100% $118 0.165 $98.41

Engineering/Exposure 0.0015 $157,629 $236 $56.00 $93.11 $330 100% $330 0.165 $275
Exposure/Fate 0.0008 $157,629 $126 $0.00 $0.00 $126 100% $126 0.165 $105

Focus 0.0009 $157,629 $142 $23.00 $38.24 $180 100% $180 0.165 $150

Standard Review Functions 0.0219 $157,629 $3,452 $511.00 $849.63 $4,302 29% $1,247 0.165 $1,042 Division Directors Meeting 0.0129 $157,629 $2,033 $113.00 $187.88 $2,221 15% $333 0.165 $278

Order Development/Negotiation

Review 0.0171 $157,629 $2,695 $22.00 $36.58 $2,732 3% $81.96 0.165 $68.44

Post Order Data Review 0.0886 $157,629 $13,966 $0.00 $0.00 $13,966 3% $419 0.165 $350

Order Modification 0.2167 $157,629 $34,158 $0.00 $0.00 $34,158 3% $1,025 0.165 $856

New Chemical SNUR Development 0.0277 $157,629 $4,366 $85.00 $141.33 $4,508 7% $316 0.165 $263

Notices of Commencement 0.0012 $157,629 $189 $40.00 $66.51 $256 31% $79 0.165 $66.18
FOIA (Freedom of Information Act) Requests 0.0333 $157,629 $5,249 $287.00 $477.19 $5,726 1% $57 0.165 $47.81

CBI (Confidential Business Information) Substantiation 0.0004 $157,629 $63.05 $3.00 $4.99 $68.04 100% $68.04 0.165 $56.81

TOTAL $5,909 0.165 $4,934

Notes:

1 GS

- 13 Step 5 salaries loaded with benefits and overhead. See Table 9 for derivation.

2 Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated fr om 1993 prices using the factors presented in Table 10

. 3 Weighted costs were calculated using unrounded unit cost estimates, so results may differ f rom calculations using the rounded values shown in this table.

4 Electronic submission is expected to generate a cost savings of 16.5% to the Agency (EPA 2009 b , p. 28).

Sources: FTEs per review step, 1993 extramural costs, and percents of cases are from EPA, 1994 Table VII

- 1, GS

- 13 salaries are from OPM

, 2009.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) 18 Economic and Policy Analysis Branch 3.3 Export Notification Cost The Agency burden and cost due to TSCA §12(b) export notification result from three tasks. In the fir st task, EPA receives export notifications from companies that inten d to export one of the chemicals subject to TSCA §12(b) ( EPA 2009b ). In the second task, EPA staff prepares separate notification letters that are subsequently reviewed and delivered to im porting countries, their embassies, or representatives, and to the importing country’s US embassies ( EPA 2009b ). 27

Because the domestic manufacture, import and processing of DnPP for the uses subject to the SNUR have been phased out , EPA does not expect to receive or send any export notifications. Nevertheless, should

t here be any notifications as a result of the current rulemaking, the costs to the Agency are presented per activity. The burden for the first two Agency activities is provided in The third task is comprised of EPA staff responses to public inquiries and other TSCA 12(b) activities. The work of responding to non

- routine requests for information and clarification from industry and importing countries, and of handling other tasks

ass ociated with the TSCA §12(b) program, was esti mated to require roughly 400 hours per year ( EPA

2009b ). Since the current rulemaking covers only one chemical subject to TSCA 12(b) reporting for a

minimal number of uses , a very small percent of such activity will be attributable to the current rulemaking.

Table 12 below. To estimate the Agency cost, hourly burdens are multiplied by the loaded wage rate of a GS

- 13, Step 5 (see Table 9 )

.

Table 12 : TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2009$)

Agency Activity Hours per Activity FTE per Activity 1 Loaded Mailing

Cost Total Agency Cost per Activity GS

- 13, Step 5 FTE Wage Rate (a) (b) = (a)/2,080 (c) (d) (e) = ((b)*(c))+(d)

Process an incoming

notification from an exporting compan y 0.1 0 0.000048 $157,629 $0.00 $7.58

P repare and mail a

notification to an importing countr y 0.5 0 0.000240 $157,629 $13.34 $ 51.23

Notes :

1 The burden associated with an Agency activity is the burden for the Agency to process one incoming notification, or to prepar e and mail an outgoing notification

Source: Table 9 of this report derives Agency labor costs. Mailing costs are from Table 6 of this report

. Other burdens a re from

EPA 2009 b , updated for inflation.

27 See Table 6 for the cost of mailing one notification

.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) 19 Economic and Policy Analysis Branch 

### 4. ADDITIONAL ANALYSES

This section presents additional analysis of other potential impacts of this rulemaking, as required under

various statutes and executive orders.

4.1 Regulatory Flexibility Act

The Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et. seq.), as amended by the Small Business Regulatory Enforcement Fairness Act, requires regulators to consider the impac t of regulations on small entities, in particular small businesses

. EPA ’ s experience to date is that, in response to the promulgation

of SNUR s covering over 1,000 chemicals, the Agency receives only a handful of notices per year

. For example, the number of SNUNs was 4 in Federal fiscal yea r (FY) 2005, 8 in FY2006, 6 in FY2007, 8 in FY2008, and seven in FY2009. 28 During this five

- year period, three small entities submitted a SNUN, using t he criteria for ‘ small business ’ was that the company checked the box on the PMN form, page 2,

statin g that it was a small business for the purpose of paying the $100 fee instead of the normal fee

. 29

, 30

4.2 Unfunded Mandates Reform Act Because DnPP is not currently produced in (other than as a chemical standard) or expor ted from the U.S., and because the Agency receives so few SNURs, EPA anticipates that few, if any, small business would be adversely impacted by the proposed rule.

Based on EPA's experience with proposing and finalizing SNURs , State, local, and Tribal governments have not been impacted by these rulemakings, and EPA does not expect that any State, local, or Tribal government would be impacted by this rulemaking.

4.3 Paperwork Reduction Act

According to the Paperwork Reduction Act (PRA), 44 U.S.C. 3501 et seq., an Agency may not conduct or sponsor, and a person is not required to respond to a collection of information that requires OMB approval under the PRA, unless it has been approved by OM B and 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 information collection requirements related to this action have already been approved by OMB pursuant to the PRA under OMB control number 2070

- 0038 (EPA ICR No. 1188).

If an entity were to submit a SNUN to the Agency, the annual burden is estimated to averag e 97 hours per

response

– 0.82 hours for rule familiarization (Section 2.2.1 ), 2.80 hours for CDX registration, CDX electronic signature, and pay.gov account setup (Section 2.2.2 ), 91.68 hours for form completion and submission ( 2.2.3 ), and 1.36 hours for export notification ( Section 2.2.5 )

,

4.4 National Technology Transfer and Advancement Act

28 February 5, 2009 email from Carol Rawie, EPA Office of Pollution Prevention and Toxics, to Tulika Narayan and Kimberly Wilson, Abt Associates. The counts include both “valid” and “invalid” SNUNs. SNUN numbering is according to Federal fiscal year, ending September 30.

29 February 5, 2009 email from Carol Rawie, EPA Office of Pollution Prevention and Toxics to Tulika Narayan and Kimberly Wilson, Abt A ssociates.

30 In order to submit SNUN as a “small business” a company needs to be classified as small using the TSCA based definition of annual revenue of less than $4,000,000 per year. This definition is not consistent with the definition of

a small busin ess using Small Business Administration (SBA) NAICs based definitions.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) 20 Economic and Policy Analysis Branch The proposed SNUR does not invol ve any technical standards; therefore

, section 12(d) of the National Technology Transfer and Advancement Act of 1995 (NTTAA), Public Law 104

– 113, section 12(d) (15 U.S.C. 272 note), does not apply.

4.5 Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Populations and Low

- Income Populations

The proposed SNUR does not involve special consider ations of environmental justice

- related issues as required by Executive Order 12898, Federal Actions to Address Environmental Justi ce in Minority Populations and Low

- Income Populations (59 FR 7629, February 16, 1994).

4.6 Executive Order 13045: Protection of Children from Environmental Health Risks and Safety

Risks

Th e proposed SNUR does not address environmental health or safety risks dispropo rtionately affecting

children.

4.7 Executive Order 13132: Federalism

Th e proposed SNUR is not expected to have a substantial direct effect on States, on the relationship between the national government and the States, or on the distribution of powe r and responsibilities among the various levels of government

. as specified in Executive Order 13132, entitled Federalism (64 FR 43255, August 10, 1999).

4.8 Executive Order 13175: Consultation and Coordination with Indian Tribal Governments

This proposed SNUR would not have Tribal implications because it is not expected to have substantial direct effects on Indian Tribes. This proposed rule would not significantly or uniquely affect the communities of Indian Tribal governments, nor would it involve or impo se any requirements that affect

Indian Tribes.

4.9 Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

This proposed SNUR is not expected to affect energy supply, distribution, or use.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) 21 Economic and Policy Analysis Branch 

### 5. BENEFITS

EPA requires additional information to fulfill its mandate under TSCA to fully assess the risks posed by the production, sale, and use of DnPP in the United States. A SNUN submission provides EPA with the opportunity to evaluate the intended use and, if ne cessary, to prohibit or limit that activity before it

occurs. It allows the Agency to take immediate action to mitigate an activity that the Agency deems harmful to the environment or human health. The proposed SNUR allows EPA to evaluate the use of, or

ex posure to th is chemicals and allow the Agency to take preventive action to limit or prohibit any Significant New Use. EPA also expects the proposed rule may restrict future uses or exposure to the chemicals, as a company may choose modify planned uses, and worker exposures the chemical is such a way that does not trigger a SNUR, as opposed to submitting a SNUN. Therefore, the proposed SNUR may limit future exposure to the chemicals

.

Quantification of the benefits of the proposed rule would require more sp ecific information about each user’s use patterns and preferences as well as the changes in these patterns and preferences that would result from the additional information made available under the proposed r ule. These data are not readily

available and co llecting such data would be cost

- prohibitive.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) 1 Economic and Policy Analysis Branch APPENDIX A

INFLATORS AND WAGE RATESEconomic Analysis of SNUR for 1 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) Economic and Policy Analysis Branch 

### A. INFLATORS AND WAGE R ATES

This appendix describes the derivation of the fully loaded labor rates and inflation factors used in calculating costs of labor, materials, and other inpu ts. Costs for this report are for year

- end 200 8

.

A.1 Derivation of Loaded Wage Rates

Unit labor costs are calculated by adding fringe benefits and overhead to the wage or salary to derive a fully loaded labor cost. The basic method is described in Wage Rates for Economic Analysis of the Toxics Release Inventory Program (EPA, 2002b). The resulting loaded labor rates are given in Table A

- 1 . Costs are calculated for several labor categories: Managerial, Professional/Technical, Clerical, and EPA staff.

In March 2004, BLS began using the North American Industry Classification System (NAICS) codes

instead of the Standard Industrial Classificat ion (SIC) System, and the Standard Occupational Classification (SOC) system instead of the Occupational Classification System (OCS). The following table shows the crosswalk between old and new occupational titles.

EPAB Reports Labor Category BLS Old Title (OCS) BLS New Title (SOC)

Managerial Executive, administrative, and managerial Management, business, and

financial

Professional/Technical Professional specialty and technical Professional and related

Clerical Administrative support, including

clerical Office and administrative support

Source: Employer Costs for Employee Compensation: Changes to NAICS and SOC, Table 2 . ECEC Occupational Comparability between SOC and OCS (BLS, 2006a and Weinstein, 2004 )

.

A.1.1 Derivation of Labor Rates for Managerial, Professional/Technical, Clerical, and Production

Labor

Wages and fringe benefits for managerial, professional/technical, clerical and production labor were taken from the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation (ECEC) data, 31

for December, for manufacturing industries. 32

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

from the same ECEC series. Fringe benefits as a percent of wages are calculated separately for each labor category. For example, for December 200 8 , the average wage rate for professional/technical 33

An additional loading factor of 17 percent is applied to wages to account for overhead. This approach is used for consistency with Office of Pollution Prevention and Toxics economic analyses for two major labor was $35.29 ; the average fringe benefit w as $17.55 . Fringe benefits as a percent of wages were $ 17.55 /$3 5.29

,

o r approximately 49.7 percent.

31 This follows the approach introduced in Economic Analysis of Expedited Significant New Use Rules for 65 Chemical

Substances: EPA Docket OPPT

- 2003

- 0063 (EPAB, 2007a).

32 Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006

– December 2008. (BLS, 2009a). This follows the approach introduced in EPAB, 2007a. Earlier PMN SNUR economic analyses, such as EPA,

2003 a , used ECEC data for “All Goods Pr oducing” sectors (manufacturing, mining, and construction). However, the manufacturing sector data seem more relevant since the SNURs mainly affect the chemicals industry.

33 This follows terminology introduced in EPAB, 2007a. Earlier SNUR economic analyse s used the term “technical” labor. Here the category is called “professional/technical” labor, to make clear how it relates to BLS categories. In 2004, BLS changed from the Occupational Classification System, OCS, to the Standard Occupational Classificatio n system, SOC. In the process, the “Professional specialty and technical” category became the “Professional and related” category. However, the coverage of

the old and new occupational groups is approximately the same. See the BLS article, C omparing Curr ent and Former Industry

and Occupation ECEC Series (Weinstein, 2004).Economic Analysis of SNUR for 2 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) Economic and Policy Analysis Branch rulemakings: Wage Rat es 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, 2002 a ). 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. For example, the December 2008 fully loaded wage for professional/technical labor is $3 5.29 × (1+0. 4973 +0.17) = $5 8.84

.
Fully loaded costs for managerial, clerical, and production lab or are calculated in a similar manner, as

shown in Table A

- 1

.

A.1.3 Derivation of Labor Rates for EPA Staff

Agency labor costs are calculated based on annual Federal salaries for the Washington

- Baltimore area published by the Office of Personnel Management effective January 2008 (OPM, 2008). The average salary for one FTE staff member is estimated as the salary for a GS

- 13 Step 5 employee

. 34

Multiplying the annual pay by an assumed loading factor of 1.6 to reflect Federal fringe benefits and overhead, the loaded annual salary of EPA staff was calculated to be $150,440.

The Agency loading factor is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (EPA, 1992a, page 30, footnote 9). The 60 percent assumption was labeled “the benefits multiplication factor” in the EPA Guide, but has been used in many EPA Office of Pollution Prevention

and Toxics ICRs to reflect both fringe benefits and overhead for Federal staff. For example, it was used in an August 2000 document supporting ICR No. 1139.06 (EPA, 2000), with the following explanation:

“The annual costs per FTE are derived by multiplying the annual pay rate by 1.6 (the benefits multiplication factor). The multiplication factor used is recommended in EPA’s Office of Policy, Planning, and Evaluation’s Instructions for Preparing Information Collection Requests (ICRs) (June 1, 1992). An EPA internal phone call between Carol Rawie (OPPT/EETD/RIB) and Carl Koch (OPPE/RMD/IMB) on May 3, 1994, indicated that the 1.6 factor included not only benefits but also overhead.” (ICR No.1139.06)

34 The GS

- 13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007), which covers PMN SNURs. Use of this grade level follows the approach introduced in EPAB, 2007a. That report represen ted a change from the earlier PMN SNUR economic analysis (EPA, 2003a), which used an average of GS

- 12 Step 1 and GS

- 12 Step 10 salaries.Economic Analysis of SNUR for 3 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) Economic and Policy Analysis Branch Table A

- 1 : Derivation of Loaded Wage Rates

EPAB Labor

Category Data Sources Date Wage Fringe

Benefit Fringes as

% W age Over

head %

W age 2 Fringe +

Overhead

Factor Loaded Wages 1

(a) (b) (c) =(b)/(a) (d) (e)=(c)+(d)+1 (f)=(a) x (e)

Managerial BLS ECEC , Private Manufacturing

industries

, “Mgt, Business, and

Financial” 3 Dec

- 08 $43.22 $19.46 45.03% 17% 1.62 $70.03

Professional/

Technical BLS ECEC , Private Manufacturing

industries , “Professional and

related“ 3 Dec

- 08 $35.29 $17.55 49.73% 17% 1.67 $58.84

Clerical BLS ECEC , Private Manufacturing industries, “Office and Administrative Support” 3 Dec

- 08 $17.22 $8.33 48.37% 17% 1.65 $28.48

EPA staff

FTE Annual Federal staff cost: OPM Washington

- Baltimore

- Northern Virginia, DC

- MD

- PA

- VA

- WV, area,

GS

- 13 Step 5 pay rates, with 60%

overhead. 3 Dec

- 08 $94,025(annual)

-- [Included in

60% overhead] 60% 1.6 $150,440 (annual)

Notes:

1 Wage data ar e rounded to the closest penny in this table; however, in calculations using these numbers for this report, unrounded values were used.

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, 2002 a ).

3 The salary is unloaded Federal GS

- 13 Step 5 salary for calendar 200 8 , from the Office of Personnel Management salary table for Washington

- Baltimore

- Northern Virginia (OPM, 200 8 ). The 60% fringes

- and

- overhead rate is from an EPA guide, Instructions for Preparing Inf ormation Collection Requests (ICRs) ( EPA, 1992a , page 30, footnote 9).Economic Analysis of SNUR for 4 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) Economic and Policy Analysis Branch A.2 Derivation of Inflation Factors

Complete information on the derivation of the inflation factors used is given in Table A

- 2

. In 2006, the Bureau of Labor Statistics (BLS) made several changes to the Employment Cost Index. The changes are described on a BLS web page, “Change has come to the ECI,” (BLS, 2006c) and i n several April 2006 Monthly Labor Review articles posted on the BLS web site: “Changes affecting the Employment Cost Index: an overview” (Caroll 2006); “Employment Cost Index P ublication P lans” (Sleemi, 2006); and “Seasonal adjustment in the ECI and the c onversion to NAICS and SOC” (Branch, 2006).

Under a mandate from OMB, BLS changed its classification of industries and occupations from the Standard Industrial Classification (SIC) and Occupational Classification System (OCS) to the North American Industry Classification System (NAICS) and Standard Occupational Classification (SOC)
system. In 2006, BLS adjusted all ECI series to reflect this change.

In addition to changing the industry and occupational classification systems, in 2006, BLS rebased the

ECI from June 1989 = 100 to December 2005 = 100 for all current and historical non

- seasonally adjusted series, including the NAICS and SIC based series. (Seasonally adjusted ind ices, including those in Table

A

- 2 of this report, may not exactly equal 100 for December 2005 as a result of the seasonal adjustment. Seasonal adjustments are explained in Branch, 2006.)

According to BLS, the official ECI for the years 1975

- 2005 i s the SIC

- OCS based series, and for subsequent years, the official ECI is the NAICS

- SOC based series (Sleemi, 2006, p.8). 35

“Starting year” indices in Table A

- 2 conti nue to be SIC

- SOC based. Current year indices are NAICS

SOC based. We use indices from both the NAICS

- SOC and the SIC

- OCS based ECI series because neither series spans the entire period over which testing and other costs need to be inflated.

35 BLS has been publishing the NIACS

- SOC based ECI series since March 2001 and it became official in March 2006. The

SIC

- OCS based series and NAICS

- SOC series have different series ID numbers, even when they describe essentially the same population. For example the series ID for seasonally adjusted total compensation for all private industry workers is

ECS10002I for the SIC

- OCS series and CIS2010000000000I for the NAICS

- SOC series

.Economic Analysis of SNUR for 5 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) Economic and Policy Analysis Branch Table A

- 2 : Derivation of Inflation Factors

Item Inflation Index Source 1 Starting

Y ear Index for Starting Year (a) Index for

2008

(b) Inflation

F actor (b)/(a) 2

Export notification BLS ECI, not SA, Total comp, Private industry, White Collar

. ECS11102I, 4 th Q [BLS, 2008a] 1992 63.2 109.4 1.731

Agency Extramural costs White collar labor; equipment; supplies BLS ECI, not SA, Total comp, Private industry, White Collar

. ECS11102I, 4 th Q [BLS, 2008a] 1993 65.5 109.4 1.670

Labels, placards etc. BLS CPI, inflation calculator, not SA. Annual [BLS, 2008b] 1997 160.5 215.303 1.341

File cabinet

Photocopies BLS CPI, inflation calculator, Annual [BLS, 2008b] 1988 118.3 215.303 1.820 Record keeping materials

Key: BLS = Bureau of Labor Statistics. CPI = Consumer Price Index. ECI = Employment Cost Index. SA = Seasonally Adjusted. Total Comp = Total Compensation (wages/salaries and benefits). 4th Q = Fourth Quarter. “ECS10002I” etc. refer to BLS series Ids.

Notes:

1 In 2006, Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) series “were rebased to December 2005 = 100 from June

1989 = 100.” The change is reflected in the indices in this table and explained on the BLS website, Employment Cost Index News Release Text: Employment Cost Index, March 2006 (BLS, 2006b). The Consumer Price Index (CPI) was not rebased.

“Starting year” ECI indices ar e SIC

- OCS based: ECS10002I for private industry All Workers, and ECS11102I for private industry

White Collar Workers. The indices are Seasonally Adjusted (SA).

After 2006, ECI indices are NAICS

- SOC based: CIS2010000000000I for private industry All Worker s, and CIS2010000W00000I for private industry White Collar Workers. The indices are Seasonally Adjusted

.

2 Inflation factors are rounded to three decimal places in this table, but calculations in this report use the unrounded values

. BLS CPI

values were published with one decimal place through 2006 and with three decimal places after that.Economic Analysis of SNUR for 6 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

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- pentyl Phthalate (DnPP) Economic and Policy Analysis Branch 

### 6. REFERENCES

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.

40 CFR 707, Chemical Imports and Exports , Code of Federal Regulations

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6 4 FR 43255, Federalism , Federal Register, Volume 65, August 10, 1999.

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Use , Federal Register, Volume 66, May 22, 2001.

71 FR 66234

, Export Notification; Change to Reporting Requirements, Final Rule, Federal Register

, Volume 71, November 14, 2006. Available in docket EPA

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.

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Australian Government. 2008c. Existing Chemical Hazard Assessment Report for Diethylhexyl Phthalate

.Economic Analysis of SNUR for 7 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di

- n

- pentyl Phthalate (DnPP) Economic and Policy Analysis Branch Department of Health and Ageing, National Industrial Chemicals Notification and Assessment Scheme (NICNAS): Sydney, Australia, 20 08 http://www.nicnas.gov.au/Publications/CAR/Other/Phthalates.asp

. Accessed Aug 13, 2009.

Australian Government. 2008d. Existing Chemical Hazard Assessment Report for Diisobutyl Phthalate

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. Accessed Aug 13, 2009.

Australian Government. 2008f. Existin g Chemical Hazard Assessment Report for Diisonoyl Phthalate

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Australian Government. 2008g. Existing Chemical Hazard Assessment Report for Di

- n

- octyl Phthalate

. Department of Health and Ageing, National Industrial Chemicals Notification and Assessment Scheme (NICNAS): Sydney, Australia, 2008

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Australian Government. 2008h. Phthalates Hazard Compendium. A Summary of Physicochemical and Human Health Hazard Data for 24 Ortho

- Phthalate Chemicals . Department of Health and Ageing, National Industrial Chemicals Notification and Assessment Scheme (NICNAS): Sydney, Australia, 2008. www.nicnas.gov.au/Publications/CAR/Other/Phthalates.asp

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2009.

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– 167.

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R elated Private Industry, Not Seasonally Adjusted. (Series ID: CIU2010000120000I ) , extracted April 12, 2010.

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- pentyl Phthalate.” Available at: http://www.caslab.com/Di

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- pentyl Phthalate.” Available at: http://www.isotope.com/cil/product s/displayproduct.cfm?prod_id=9076&cat_id=107

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Di

- n

- pentyl Phthalate (DnPP) Economic and Policy Analysis Branch Clausen, P. A.; Hansen, V.; Gunnarsen, L.; Afshari, A. 2004. Emission of Di

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– 2537.

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PMN Submissions

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Phthalate (DINP). Directorate of Health Sciences: Bethesda, MD 20814.

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Chen. Screening of Toys for PVC and Phthalates Migration.

EPA, 1992. U.S. EPA, Office of Policy, Planning, and Evaluation. Instructions for Preparing Information Collection Requests (ICRs). Washington, DC, June 1, 1992.

EC. 2003a. European Commissio n. European Union Risk Assessment Report: 1,2

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68515

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