**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

Rin2070-AJ36_EO12866_3-Chemical -SNUR-NPRM_EA-DnPP_2011-06-15



## Economic Analysis of the Proposed Significant New Use Rule for Di- n -pentyl Phthalate (DnPP)

FINAL

(EPA Docket EPA-HQ-OPPT-2010-0573)

EO 12866 REVIEW DRAFT – 06/15/2011



## —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U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di -n- 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preparation support was provided by Abt Associates Inc. under EPA Contract No. EP-W_08_010.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

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

This report estimates the costs of the U.S. Envi ronmental 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 Servi ce Registry Number (CASRN) 131-18-0.

The proposed SNUR applies to all manufacturing, import, and processing of DnPP, excluding when the

substance is used or sold for use as a chemical standard in phthalate testing - the sole ongoing use of the

chemical. 1 Aside from the exempt use, EPA found no evidence of any manufacturing or importation into the United States. No data for DnPP were reported in the 2006 Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) database (EPA 2006a). 2 In addition, the Agency received no comments after the publication of the Phthalates Action Plan to indicate current production of the chemical for any uses besi des use a chemical standard in phthalate testing. 3 Because the domestic manufacture, import and processing of DnPP for the u ses subject to the SNUR have been phased out, there is expected to be no economic impact from the proposed SNUR.

The proposed SNUR would require persons to notif y EPA at least 90 days before commencing the manufacture, import, or processing of DnPP for any si gnificant new use as defined in the SNUR. A firm intending 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 e nvironmental 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 require d notification provided by a SNUN will provide EPA with the opportunity to evaluate activities associated with a significan t new use and an opportunity to protect against unreasonable risks, if any, from exposure to DnPP.

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 uses, EPA believes it is highly unlikely that any firm will incur this cost. EPA does not require the development of test data for submissi on of a SNUN, although a firm may submit test data already in its possession or describe any other av ailable 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.

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 avoid submission and testing costs but may incur other compliance costs. However, th is may not be a concern given that the domestic manufacture, import and processing of DnPP for the u ses subject to the SNUR have been phased out.

Costs 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 Accustanda rd.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 certain 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 with 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#docke tDetail?R=EPA-HQ -OPPT-2010-0342**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di -n- 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 Su bstitutes .......................................................................................................... ......... 1

Health Effects ................................................................................................................ ............. 2 Environmental Exposure ........................................................................................................ .... 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 Signat ure, 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 fo r EPA Staff ..................................................................................................... ... 14

3.2 SNUN Processi ng Costs ......................................................................................................... .. 15

3.3 Export Notification Cost ...................................................................................................... ..... 18

4. ADDITIONAL ANALYSES ........................................................................................................... ... 19

4.1 Regulatory Flexibility Act .................................................................................................... .... 19

4.2 Unfunded Mandates Reform Act .............................................................................................. 19

4.3 Paperwork Reduction Act ....................................................................................................... .. 19

4.4 National Technology Transfer and Advancement Act ............................................................. 20

4.5 Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Populations and Low-In come Populations ............................................................................... 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 Coordi nation 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 W AGE RATES .................................................................................................... 1

6. REFERENCES .................................................................................................................... .................. 6**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

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

Table 1: Loaded Industry Wa ge Rates, December 2009 ............................................................................ ... 5

Table 2: Rule Familiarization Burden and Cost for SNUR Submitters ........................................................ 6 Table 3: CDX Registration, CDX Electronic Signature , and Pay.gov Account Setup Burden 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 Notif ication 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 .................................................... 16 Table 11: Agency Costs for SNUN and Ot her Submission Review and Processing .................................. 17 Table 12: TSCA 12(b) Export Notification Co st: Agency Burden per Activity (2009$) ........................... 18 Table A-1: Derivation of Loaded Wage Rates .................................................................................... .......... 3

Table A-2: Derivation of Inflation Factors .................................................................................... ............... 5**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

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

### 1. INTRODUCTION

This report presents the U.S. Environmental Protecti on Agency (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) CASRN 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 processing of DnPP, excluding when the substance 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 Dn PP 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 could result in increased exposure to, or releases of, the substance which in turn, could present an unreasonable risk to health or the environment.

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 th e development of an Action Plan Phthalates were selected because of their toxicity and the evidence of pervasive human and environmental exposure. The Action Plan summarized readily available use, exposur e, and hazard information for eight phthalate esters (including DnPP); 4 considered which authorities provided under TS CA and other statutes could be used to address potential concerns; and described various co urses of actions available to EPA to address the concerns (EPA 2009d). 5 It is important to note that, unless spec ified, the following sections describe all phthalates, not just DnPP.

Uses and Substitutes

The major use of phthalates is as plasticizers, additiv es incorporated into plastics and elastomers used to impart flexibility and other desirable properties into the material (Australian 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 (DEH P) 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 polyvinyl chloride (P VC), which is used in a variety of industrial and commercial products, as well as specialized medical and de ntal 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 speci fic applications. Furthermore, although phthalates are still the main PVC plasticizers, numerous othe r substances can serve as substitutes. These include other phthalates, trimellitates, and monomeric plastici zers such as epoxidized s oybean oil. Many of these substitutes have specialized uses, and are frequently more expensive than phthalates, but some exhibit properties that make them particular ly 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 Information System (IRIS), based on advice from the National Academy of Sciences (NAS 2008).

5 Accessible at: http://www.epa.gov/opptintr/existingchemicals/pub s/actionplans/phthalates_ap_2009_1230_final.pdf**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -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 potential are lo w 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, whic h consist of changes in the fetal development of the reproductive system (NAS 2008; NTP-CERH R 2003a-e, 2006; EC 2003a-b, 2008a-b; Australian Government 2008a-h). The phthalates that are the mo st potent at causing phthalate syndrome effects are generally those with linear ester side chains having 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, several human studies have reported associations of exposure of some phthalates with adverse reproductive outcomes 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 ob served in humans include shortened anogenital distance observed in newborn boys; and shorted pregna ncy, 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 pr oduction, 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 this 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 into the environment from mu ltiple 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 phthala tes. Due to their pervasive use and release, as well their propensity for global transport, various phth alates may be found in most environmental media, including ambient air, surface water, soil, sediment (B abich et al. 2004; Clausen et al. 2004; EC 2003 a-b, 2003-04, 2008a-b; CPSC 2001, 2002). Exposures due to environmental releases from the phthalate plasticized PVC material in the environment indicat e a potential for bioavailab ility 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 pub lication of the Action Plan, there were no comments provided during the comment period that would provi de any indication of ongoing production of DnPP. 8

6 A major cumulative hazard assessment of phthalates is sche duled to be conducted by th e Consumer Product Safety Commission’s (CPSC’s) Chronic Hazard Advisory Panel (C HAP) as directed by CPSI A, with an anticipated completion date of 2012.

7 Data from the National Health and Nutrition Examination survey (NHANES) indicates 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 once (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.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -pentyl Phthalate (DnPP) 3 Economic and Policy Analysis Branch However, subsequent internet queries identified sev eral companies which either use or sell DnPP as a chemical standard for use in phthalate testing. 9 As a result, EPA is proposing a SNUR for DnPP, excluding use of the substance as a chemical standard in phthalate testing.

1.2 Statutory Authority

Section 5(a)(2) of TSCA (15 U.S.C. 2604(a)(2)) author izes 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 se ction 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 submit 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 co sts to society of the propo sed rule by identifying the costs to industry associated with performing the requi red reporting and recordkeeping, and the costs to EPA of administering the rule. Industry costs may cons ist 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 notification; and recordkeeping. Agency costs include reviewing and processing the data received as a result of the rule. Data sources for this analysis include burden est imates derived from previ ous information collection requests and economic analyses for related rul es, 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 presents an analysis of ot her impacts, as required by various statutes and

executive orders.

Note that all dollar amounts in this analysis are re ported in December 2009 dollars, which is the latest year for which complete data are available.

9 Both Cambridge Isotope Laboratories, Inc. and Accustanda rd.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 propo rtion of the market these th ree companies represent, nor how large the market is; however, given the IUR data an d the lack of public comments received following the Action Plan, it is likely that this ongoing market is small.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

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

### 2. INDUSTRY COMPLIANCE COSTS

The proposed SNUR discussed in this report specifies that significant new uses of DnPP that require reporting under section 5(a)(2)(A) of TSCA include the manufacture, import, or processing of DnPP, except when used or sold fo r use as a chemical standard in phthalat e testing. Therefore, a firm intending to manufacture, import, and/or process DnPP for any u se other than as a chemical standard in phthalate testing must submit a SNUN. Alternatively, a firm can decide not to manufacture, import, and/or process the 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 signifi cant 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 sta ndard in phthalate testing. 10.11 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 opportu nity 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 co sts associated with this option are the costs of submitting the SNUN (including 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 2.2.6 for details). Because the domestic manufacture, import and processing of DnPP for the u ses subject to the SNUR have been phased out, EPA expects that no firms will choose this option.

• Option 2: Decide not to manufacture, 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 submitting a SNUN, it entails the ‘hidde n’ cost of the profit that will be foregone as a result of not engaging in the commercial activity origin ally 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 “h idden” 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 chemical standard for use in phthalate testing. If the firm elects to produce DnPP for research and development (R&D) pur poses 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 comp liance cost associated for either of the options. The remainder of this chapter estimates the quantif ied portion of costs associated 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, registrati on with the Central Data Exchange

10 EPA notes that, in accordance with TSCA section 12(a) and 40 CFR 721.45(g), persons who manufacture 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 from 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 substan ces that are manufactured in small quantities solely for research and development (R&D) from the section 5(a) notice requirements. No application is required for the exemption for R&D under section 5(h)(3) (U.S. EPA 1986).**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -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 act ivity 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 wa ge 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 overh ead 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 availabl e on the BLS website (BLS 2010a). The loaded wage rate for managerial labor is $68.24; for techni cal labor, $59.49; and for clerical labor, $28.31. Table 1 presents the basic data used to calculate the lo aded 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 Overhead %

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 cl osest 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 Amen ded Inventory Update Rule: Final Report (EPA, 2002a).

3 Employer Costs for Employee Compensa tion Supplementary Tables: December 2009. US Bureau of Labor Statistics, March 10, 201- (BLS 2010a).

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 rule familiarization is approximately 0.55 hours

of technical labor and 0.27 hours of managerial labor, as described in the Economic Analysis of the**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -pentyl Phthalate (DnPP) 6 Economic and Policy Analysis Branch Premanufacture Notification Electronic Reporting Final Rule (EPA 2009a). As shown in Table 2 the total

labor cost associated with rule familiari zation by a first-time reporter is $50.92.

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 2010a (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, a nd establish and use a Pay.gov E-payment account. 12
These activities are only required of first-time submitters (companies already registered with CDX would not need to re-register for the purposes of complyi ng 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 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.

• CDX electronic signature: EPA estimates that companies will spend 0.25 hours preparing, submitting, and filing an electronic signature agreem ent (Authentication of Identity) form to EPA per employee. This burden will apply to four technical staff 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 additiona l 0.50 hours accessing, preparing, and submitting verification forms (Verification of Authorization) for all authorized submitters to EPA. The total burden incurred by companies submitting and then verify ing electronic signature agreements is 1.75

hours. Note that this burden does not include an y additional time required to contact EPA’s CDX help desk to notify 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 a nd 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 burde n does not include the time required to click ‘submit’ on the form and wait for payment processing.

12 Although 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.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -pentyl Phthalate (DnPP) 7 Economic and Policy Analysis Branch As shown in Table 3, the cost associated with C DX registration, CDX electronic signature, and Pay.gov account setup is $178.21, and this cost is only incurred by a first-time submitter.

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 $178

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



### 2.2.3 Form Completion and Submission Fee

Respondents are required to gather and submit informa tion regarding the data elements identified in the applicable SNUN reporting form. The methodology and calcu lations used in this analysis assume that the employee responsible for collecting, filling out, and submitting the requested information has a reasonable level of familiarity with the company a nd knowledge of operations at the site. It is assumed

that for most entities these tasks are similar to othe r employee duties that require familiarity with EPA, State, and other Federal agency requests for chem ical information and do not require additional familiarization or training beyond the basic rule familia rization described above. In addition, this analysis focuses on the marginal costs of submitting information for the proposed rule an d not the total costs for the company to comply with a range of other Fe deral 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) s ubmission, 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 TSCA Section 5 Premanufacture Notifications and the updates to this estimates in 2009 (EPA 2009a). The or iginal 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 maintain a file of the submission (EPA 1994). 13 The 1994 estimates were based on a survey conducted by the Chemical Manufac turers 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 pr eparing the report, producing sanitized responses for items claimed as confidential business information, a nd maintaining a file of the submission” (EPA, 1994). 14 The burden associated with SNUN submission a nd preparation has been adjusted to reflect burden reductions resulting from the 2009 final PMN Elect ronic Reporting (ePMN) Rule that requires the electronic submission of all TSCA section 5 notices. Electronic submission of SNUN forms is expected to

13 Table III-2 and pages III-11, -12, and -13.

14 p. III 11-13**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -pentyl Phthalate (DnPP) 8 Economic and Policy Analysis Branch remove all clerical burden associated with preparing a SNUN (EPA 2009a) 15 . In addition, electronic submission is expected to generate and an additional 0.18 hours of tec hnical burden, for the completion of the User Fee Payment Identification Number and email address data elements on the electronic SNUN

form.

SNUN form completion and electronic submission is estimated to require 73.68 hours of technical labor and 18.00 hours of managerial labor. Table 4 combin es 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 larg e and small business s ubmitters is $5,612.

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 91.68 $5,612

Source :
1 Loaded wages include fringe benefits and ov erhead. See Appendix A of this report for derivation. Wage rates presented in this table are rounded values; however, unr ounded values are used to calc ulate total labor costs. For this reason, total labor costs may not equal the product of rounded values.

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

3 Technical and managerial labor burden is from the PMN Amendments RIA (EPA, 1994, Table III-2). An additional eleven minutes (0.18 hours) of technical burden is estimated to complete the User Fee Payment Identification Number and Email

Address data elements on the Electr onic 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 subm ission 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 $8,143 for large business submitters and $5,743 for small business submitters.

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

Reporting Population Labor Cost Submission Fee Total Cost (2009$) Large Business Submitters $5,612 $2,500 $8,112 Small Business Submitters $5,612 $100 $5,712

Source : EPA, 2009a.



### 2.2.4 Recordkeeping

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

estimates a 0.5 hour clerical burden and a 0.5 hour technica l burden associated with recordkeeping in addition to the burden estimates from the 1994 RIA, which include the burden for recordk eeping (EPA, 1994, p. III-14). These

burden estimates are based on the reco rdkeeping burden for polymer exceptions and not the recordkeeping burden associated with PMN submissions. Therefore, for this an alysis we assume that any reduction in recordkeeping burden is captured in the reduction of th e clerical burden, and we do not consid er the one hour r ecordkeeping burden from the ePMN EA in order to avoid double counting.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -pentyl Phthalate (DnPP) 9 Economic and Policy Analysis Branch 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 recor dkeeping hours were included in the SNUN submission hours (see Section 2.2.3) and were not separately estimated. 16



### 2.2.5 Import Certification

In general, promulgation of a final SNUR trigge rs a TSCA Section 13 import certification requirement 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. manuf acturer, importer, or processor receiving an imported shipment of chemicals subject to the proposed 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 The statement must be on or attached to a commercial invoice or entry document belonging to the imported shipment.

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 potential burden

associated with a submitter’s familiarization with this requirement is assumed to be included in the more general SNUR familiarization burden discussed above.



### 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
After receiving a notification from a firm, EPA notifies the importing country and the United States State Department (40 CFR §707.70). To calculate the bur den associated with making export notifications, EPA first estimated the average annual number of export no tifications made by an exporter. EPA then derived the annual and per notification burden associated wi th preparing and submitting an export notification.

16 SNUN submission costs 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 TSC Section 5 Premanufacture 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 fo r submission costs.” Page III-12 iden tifies “maintaining a file of the submission” 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.

17 The exact statements are as follows: Fo r imports of chemical substances su bject 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 labele d in accordance with TSCA s ection 12(a)(1)(B), they are required to submit export notifications under section 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, 71 FR 66234).**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -pentyl Phthalate (DnPP) 10 Economic and Policy Analysis Branch Exporter Costs 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 These costs include the co st to the exporter of compiling a list of their products that are subject to TSCA Section 12(b) requirements, writing or revising an export notification letter to EPA, checking the outgo ing shipments, and sending the notification letters with the associated shipping costs.



### The per-notification cost was calculated based on th e assumption that the average exporter makes 12 notifications per year

. 22 Exporters making more notifications per year may benefit from economies of scale and have lower costs per notification; those ma king fewer notifications may have higher costs per

notification.

Estimated Submission (Mailing) Costs . Regulated companies will incur mailing costs for export

notifications delivered to EPA. Notifications are ass umed 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 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 late r SNUR economic analysis (EPA, 2007a, Table 8).

Compile and Maintain the List of Products. Since TSCA §12(b) information collection activity has been in place for twenty years, most respondents will have al ready developed a list of their 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 also include some propor tion of legal time (EPA 2009b). The total burden can vary from two hours per year up to two hours per m onth, depending on the numbe r 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

20 Most underlying data in this section come from th e 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 under the Paperwork Reduction Act (EPA 2009b), with updating for inflation.

21 page 11, Table 3

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 submitted notifications (3,500) by the estimated number of exporters (300).**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -pentyl Phthalate (DnPP) 11 Economic and Policy Analysis Branch manufacture or process DnPP solely for export are exempt from SNUN requirements, but will be required to submit export notifications. Time for initial prepar ation of the export notice may vary depending on whether the company has prior experien ce with this requirement. This step is estimated to take an average 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 evid ence that 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 th eir products described above. A form letter notifying EPA and providing the required data must be printe d 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 notifica tion activity are provided 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 notification 0.86 $51.04 0.50 $14.15 1.36 $78.54

Notes:

1 Mailing costs reflect April 2010 USPS rates and can be found in Table 6.

2 Per notification costs are based on an average f acility submitting 12 export notifications per year.

Source: ICR No.: 0795.13 [Information Collection Request for] Notification of Chemical Exports - 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 entiti es. Table 8 summarizes the costs to co mply with the proposed rule, as

described in more detail in section 2.2 above.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -pentyl Phthalate (DnPP) 12 Economic and Policy Analysis Branch Table 8: Compliance Options and Associated Costs Incurred 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 electroni cally submitting a SNUN, including rule familiarization, CDX registration (for companies that are first-time submitters), form completion, user fee, export notification cost (if relevant). Rarely, 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 under 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 would incur $178 for CDX registration and associated activities.

2. Decide not to manufacture, import, or process thechemical for any nonexempt 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 export notification costs. Opportunity costs are not quantified. Other costs including rule familiarization ($50.92), and export notification costs ($78.56 per 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 production 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 detailed 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 descri be 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 Agency may take additional regulatory actions under TSCA. These a dditional regulatory actions might be necessary to

further evaluate an intended new use and associated activ ities, or to prohibit or li mit 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 surroundi ng the individual SNUN (e.g., available information and sci entific understanding of the chemical and its risks at the time the SNUN is being reviewed).**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -pentyl Phthalate (DnPP) 13 Economic and Policy Analysis Branch Should EPA’s review of the SNUN result in furthe r regulatory actions, the Agency will initiate and follow the appropriate procedures for taking those ac tions. Included in those procedures would be an

assessment of the costs and benefits of those actions.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -pentyl Phthalate (DnPP) 14 Economic and Policy Analysis Branch 

### 3. AGENCY COSTS

As described in the following sections, EPA’s co sts 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 annua l Federal salaries for the Washington-Baltimore area published by the Office of Personnel Management effective January 2009 (OPM 2009). EPA assumes that, on average, a federal GS-13, Step 5 full-tim e equivalent (FTE) will conduct its collection and administrative activities under the proposed rule. 23 The average salary for a GS-13 Step 5 employee was $98,518 in 2009 without fringe benefits and overhead cost s. In order to derive the fully loaded salary, EPA multiplied the annual salary by an assumed loading f actor of 1.6 to reflect federal fringe benefits and overhead, which results in a fully loaded annual sal ary of $157,629 (see Table 9). Dividing the fully loaded annual salary by 2,080 hours (i.e., the num ber 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 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 fringe benefits and overhead for federal staff. For exampl e, it was used in a document supporting EPA 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.

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.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -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 WashingtonBaltimore-NorthernVirginia, DC-MD-PAVA-WV, area, GS-13 Step 1 pay rates a Dec09 $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 Lo cality Pay Area (OPM 2009). Hourly rate s are based on annual salary divided by 2,080 hours.

b The 60% fringes-and-overhead rate is fro m an EPA guide, Instructions for Prepari ng Information Collect ion 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 pro cessing 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 pr ocessing a PMN has been adjusted to reflect burden reductions resulting from the 2009 fi nal 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 calcu lated by multiplying the number of FTEs (in the first column) by the fully loaded hourly salary. This s hows 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 the selected review step is inflated from 1993 prices using the Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) da ta (BLS 2010b). The not seasonally adjusted ECI for total compensation of private industry professional and related workers (Series 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.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**

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

Di- n -pentyl Phthalate (DnPP) 16 Economic and Policy Analysis Branch Table 10: Derivation of Inflation Fa ctors 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 weighti ng factor applied to reflect the fact that not all chemicals require each review step. For exampl e, in the PMN process, all chemicals require Administrative Prescreening, but not all chemicals requ ire the intensive scrutiny of “Standard Review.” The three types of submissions resulting from a SNUR may have weighting factors that differ from each other and from the weighting factors for PMNs. Cha nges in weighting factors could cause actual review costs to be higher or lower than calculated here. For example, some SNUNs require little review because they are determined to be “invalid” – i.e. not require d in the first place. However, often a SNUN may take more Agency time than a typical PMN because of fact ors such as the need to retrieve old PMN records from archives, and the likelihood that more data re quiring EPA review is submitted with a SNUN than would be submitted, on average, with a PMN. Resour ces 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 derived in 1994 for PMNs.

The Weighted Cost column is calculated by multiply ing the un-weighted Costs (EPA staff cost plus extramural costs) by the percentage of cases requiring this review step. Weighted costs are then multiplied by the burden reduction of 16.5 percent to account for burden savings generated electronic submission. As shown in Table 11, this calculation yields tota l Agency costs of $4,934, per SNUN, for submission review and processing.**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review**Economic Analysis of SNUR for 17U.S. EPA Office of Chemical Safety and Pollution PreventionDi-n-pentyl Phthalate (DnPP)Economic and Policy Analysis BranchTable 11: Agency Costs for SNUN and Other Submission Review and ProcessingReview StepsEPA staff (FTE) CostExtramural Cost2UnweightedCostPct. ofCasesWeightedCost3ePMNBurdenReduction4Weighted Costwith ePMNBurden ReductionFTEfractionCost perFTE1FTE Total($2009)1993dollars2009dollars(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 $132Administrative prescreen/notice receipt/user fee0.0024 $157,629 $378 $92.00 $152.97 $531 100% $531 0.165 $444CRSS (Chemical Review andSearch Strategy)0.0025 $157,629 $394 $268.00 $445.60 $840 100% $840 0.165 $701SAT (Structure ActivityTeam)0.0006 $157,629 $94.58 $14.00 $23.28 $118 100% $118 0.165 $98.41Engineering/Exposure 0.0015 $157,629 $236 $56.00 $93.11 $330 100% $330 0.165 $275Exposure/Fate 0.0008 $157,629 $126 $0.00 $0.00 $126 100% $126 0.165 $105Focus 0.0009 $157,629 $142 $23.00 $38.24 $180 100% $180 0.165 $150Standard Review Functions 0.0219 $157,629 $3,452 $511.00 $849.63 $4,302 29% $1,247 0.165 $1,042Division Directors Meeting 0.0129 $157,629 $2,033 $113.00 $187.88 $2,221 15% $333 0.165 $278OrderDevelopment/NegotiationReview0.0171 $157,629 $2,695 $22.00 $36.58 $2,732 3% $81.96 0.165 $68.44Post Order Data Review 0.0886 $157,629 $13,966 $0.00 $0.00 $13,966 3% $419 0.165 $350Order Modification 0.2167 $157,629 $34,158 $0.00 $0.00 $34,158 3% $1,025 0.165 $856New Chemical SNURDevelopment0.0277 $157,629 $4,366 $85.00 $141.33 $4,508 7% $316 0.165 $263Notices of Commencement 0.0012 $157,629 $189 $40.00 $66.51 $256 31% $79 0.165 $66.18FOIA (Freedom ofInformation Act) Requests0.0333 $157,629 $5,249 $287.00 $477.19 $5,726 1% $57 0.165 $47.81CBI (Confidential BusinessInformation) Substantiation0.0004 $157,629 $63.05 $3.00 $4.99 $68.04 100% $68.04 0.165 $56.81TOTAL$5,909 0.165$4,934Notes:1GS-13 Step 5 salaries loaded with benefits and overhead. See Table 9 for derivation.2Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated from 1993 prices using the factors presented in Table 10.3Weighted costs were calculated using unrounded unit cost estimates, soresults may differ from calculations using the rounded values shown in this table.4Electronic submission is expected togenerate a cost savings of 16.5% to the Agency (EPA 2009b, 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- n -pentyl Phthalate (DnPP) 18 Economic and Policy Analysis Branch 3.3 Export Notification Cost The Agency burden and cost due to TSCA §12(b) expor t notification result from three tasks. In the first task, EPA receives export notifications from companies that intend to export one of the chemicals subject to TSCA §12(b) (EPA 2009b). In the second task, EPA st aff prepares separate notification letters that are subsequently reviewed and delivered to importing c ountries, their embassies, or representatives, and to the importing country’s US embassies (EPA 2009b). 27 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 im porting countries, and of handling other tasks associated with the TSCA §12(b) program, was estimated 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.

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 there 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 activitie s is provided in 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 Co st: 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 company 0.10 0.000048 $157,629 $0.00 $7.58

Prepare and mail a

notification to an importing country 0.50 0.000240 $157,629 $13.34 $51.23

Notes :
1 The burden associated with an Agency acti vity is the burden for the Agency to process one incoming notification, or to prepare and mail an outgoing notification

Source: Table 9 of this report derives Agency labor costs. Mailing cost s are from Table 6 of this report. Other burdens are from EPA 2009b, 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- n -pentyl Phthalate (DnPP) 19 Economic and Policy Analysis Branch 

### 4. ADDITIONAL ANALYSES

This section presents additional analysis of other po tential 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 regulator s to consider the impact of regulations on small entities, in particular small businesses. EPA’s experience to date is that, in response to the promulgation of SNURs 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 fi scal year (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 the criteria for ‘small business’ was that the company checked the box on the PMN form, page 2, stating that it was a small business for the purpose of paying the $100 fee instead of the normal fee. 29,30
Because DnPP is not currently produced in (other th an as a chemical standard) or exported 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.

4.2 Unfunded Mandates Reform Act

Based on EPA's experience with pr oposing 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 requi red to respond to a collection of information that requires OMB approval under the PRA, unless it has been approve d by OMB and displays a currently valid OMB

control number. The OMB control numbers for EPA's re gulations in title 40 of the CFR, after appearing

in the Federal Register , are listed in 40 CFR, part 9, and include d on the related collection instrument, or form, if applicable. The information collection requi rements 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, th e annual burden is estimated to average 97 hours per response – 0.82 hours for rule familiarization (Sec tion 2.2.1), 2.80 hours for CDX registration, CDX electronic signature, and pay.gov account setup (Secti on 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),

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 bo th “valid” and “invalid” SN UNs. SNUN numbering is according to Federal fiscal y ear, 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 Associates.

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

Di- n -pentyl Phthalate (DnPP) 20 Economic and Policy Analysis Branch 4.4 National Technology Transfer and Advancement Act

The proposed SNUR does not involve any technical standards; therefore, section 12(d) of the National Technology Transfer and Advancem ent 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 Justice 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

The proposed SNUR does not address environmental hea lth or safety risks disproportionately affecting

children.

4.7 Executive Order 13132: Federalism

The proposed SNUR is not expected to have a subs tantial direct effect on States, on the relationship between the national government and the States, or on the distribution of power 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 Coordi nation with Indian Tribal Governments

This proposed SNUR would not have Tribal implicat ions because it is not expect ed 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 impose any requirements that affect

Indian Tribes.

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

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

Di- n -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 n ecessary, to prohibit or limit that activity before it occurs. It allows the Agency to take immediate ac tion to mitigate an activity that the Agency deems harmful to the environment or human health. The pro posed SNUR allows EPA to evaluate the use of, or exposure to this chemicals and allow the Agency to take preventive action to limit or prohibit any Significant New Use. EPA also expect s the proposed rule may restrict future uses or exposure to the chemicals, as a company may choose modify planned u ses, 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 specific information about each user’s use patterns and preferences as well as the ch anges in these patterns and preferences that would

result from the additional information made available under the proposed rule. These data are not readily available and collecting such da ta would be cost-prohibitive.Economic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di- n -pentyl Phthalate (DnPP) 22 Economic and Policy Analysis BranchEconomic Analysis of SNUR for U.S. EPA Office of Chemical Safety and Pollution Prevention

Di- n -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-n-pentyl Phthalate (DnPP) Economic and Policy Analysis Branch 

### A. INFLATORS AND WAGE RATES

This appendix describes the derivation of the fully lo aded labor rates and inflation factors used in calculating costs of labor, materials, and other in puts. Costs for this report are for year-end 2008.

A.1 Derivation of Loaded Wage Rates

Unit labor costs are calculated by adding fringe benef its 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 Classificati on (SIC) System, and the Standard Occupational Classification (SOC) system instead of the Occupa tional Classification System (OCS). The following table shows the crosswalk between old and new occupational titles.

EPAB Reports Labor Category BLS Ol d 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, professiona l/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 pe rcent of wages are calculated separately for each labor category. For example, for December 2008, th e average wage rate for professional/technical 33 labor was $35.29; the average fringe benefit was $17.55. Fringe benefits as a percent of wages were $17.55/$35.29, or approximately 49.7 percent.

An additional loading factor of 17 percent is applie d to wages to account for overhead. This approach is used for consistency with Office of Pollution Prev ention and Toxics economic analyses for two major

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

Substances: EPA Do cket 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 S NUR economic analyses, such as EPA, 2003a, used ECEC data for “A ll Goods Producing” 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 analyses used the term “technical” labor. Here the category is called “professi onal/technical” labor, to make clear how it relates to BLS categories. In 2004, BLS changed from the Occupational Classificati on System, OCS, to the Standard Occupational Cl assification system, SOC. In the process, the “Professional specialty and te chnical” category became the “Professional and related” catego ry. However, the coverage of the old and new occupational groups is appr oximately the same. See the BLS article, C omparing Current and Former Industry

and Occ upation ECEC Series (Weinstein, 2004).Economic Analysis of SNUR for 2 U.S. EPA Office of Chemical Safety and Pollution Prevention Di-n-pentyl Phthalate (DnPP) Economic and Policy Analysis Branch rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b),

and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a). This overhead loading factor is added to the benefits loading factor, and the total is then applied to the base wage to derive the fully loaded wage. For example, the December 2008 fully loaded wage for professional/technical labor is $35. 29 × (1+0.4973+0.17) = $58.84.

Fully loaded costs for managerial, clerical, and pr oduction labor 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 annua l 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 pe rcent 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 overh ead 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 multiplyin g the annual pay rate by 1.6 (the benefits multiplication factor). The multiplication factor u sed is recommended in EPA’s Office of Policy, Planning, and Evaluation’s Instructions for Pr eparing 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 represented a chan ge 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 for3U.S. EPA Office of Chemical Safety and Pollution PreventionDi-n-pentyl Phthalate (DnPP) Economic and Policy Analysis BranchTable A-1: Derivation of Loaded Wage RatesEPAB LaborCategoryData SourcesDateWageFringeBenefitFringes as% WageOver-head %Wage2Fringe +OverheadFactorLoaded Wages1(a) (b) (c) =(b)/(a) (d) (e)=(c)+(d)+1 (f)=(a) x (e)ManagerialBLSECEC, PrivateManufacturingindustries,“Mgt, Business, andFinancial”3Dec-08 $43.22 $19.46 45.03% 17% 1.62 $70.03Professional/TechnicalBLSECEC, PrivateManufacturingindustries, “Professional andrelated“3Dec-08 $35.29 $17.55 49.73% 17% 1.67 $58.84ClericalBLSECEC, PrivateManufacturingindustries,“Office andAdministrative Support”3Dec-08 $17.22 $8.33 48.37% 17% 1.65 $28.48EPA staffFTEAnnual Federal staff cost: OPMWashington-Baltimore-NorthernVirginia, DC-MD-PA-VA-WV, area,GS-13 Step 5 pay rates, with 60%overhead.3Dec-08$94,025(annual)--[Included in60%overhead]60%1.6$150,440(annual)Notes:1Wage data are rounded to the closest pennyin this table; however, in calculationsusing these numbers for this report, unrounded values were used.2An overhead rate of 17% was used based on assumptions inWage Rates for Economic Analyses of the Toxics Release Inventory Program(EPA, 2002b), and theRevised Economic Analysisfor the Amended Inventory Update Rule: Final Report(EPA, 2002a).3The salary is unloaded Federal GS-13 Step5 salary for calendar 2008, from the Officeof Personnel Management salary table forWashington-Baltimore-Northern Virginia (OPM, 2008).The 60% fringes-and-overhead rate is from an EPA guide,Instructions for Preparing Information 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-n-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 change s to the Employment Cost Index. The changes are described on a BLS web page, “Change has come to the ECI,” (BLS, 2006c) and in 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 Publication Plans” (Sleemi, 2006); and “Seasonal adjustment in the ECI and the conve rsion to NAICS and SOC” (Branch, 2006).

Under a mandate from OMB, BLS changed its classif ication of industries and occupations from the Standard Industrial Classification (SIC) and Occ upational 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 industr y and occupational classification syst ems, 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. (Seas onally adjusted indices, including those in Table A-2 of this report, may not exactly equal 100 for D ecember 2005 as a result of the seasonal adjustment. Seasonal adjustments are explained in Branch, 2006.)

According to BLS, the official ECI for the year s 1975-2005 is the SIC-OCS based series, and for subsequent years, the official ECI is th e NAICS-SOC based series (Sleemi, 2006, p.8). 35

“Starting year” indices in Table A-2 continue to be SIC-SOC based. Current year indices are NAICSSOC based. We use indices from both the NAICS-S OC and the SIC-OCS based ECI series because neither series spans the entire period over which t esting and other costs need to be inflated.

35 BLS has been publishing the NIACS-SOC based ECI series si nce 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 compensa tion 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-n-pentyl Phthalate (DnPP) Economic and Policy Analysis Branch Table A-2: Derivation of Inflation Factors

Item Inflation Index Source 1 Startin g Year Index for Starting Year (a) Index for

2008

(b) Inflation

Factor (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 Co st Index. SA = Seasonally Adjusted. Total Comp = Total Compensation (wages/salaries an d benefits). 4th Q = Fourth Quarter. “E CS10002I” etc. refer to BLS series Ids.

Notes:

1 In 2006, Bureau of Labor Statistics (BLS) Employment Cost Inde x (ECI) series “were rebased to December 2005 = 100 from June 1989 = 100.” The change is reflected in the indice s in this table and expl ained 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 are SIC-OCS based: ECS10002I for pr ivate 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 fo r private industry All Workers, and CIS2010000W00000I for private industry White Collar Workers. The indices are Seasonally Adjusted.

2 Inflation factors are rounded to three decimal places in this ta ble, but calculations in this report use the unrounded values. BLS CPI values were published with one decimal place through 2006 and with th ree decimal places after that.Economic Analysis of SNUR for 6 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di- n -pentyl Phthalate (DnPP) Economic and Policy Analysis Branch 

### 6. REFERENCES

15 U.S.C. 272, National Technology Transfer and Advancement Act of 1995 (NTTAA), Public Law 104– 113, Section 12(d).

19 CFR 12, Customs Duties: Special Classes of Merchandise, Code of Federal Regulations

, Part 12, Title 19, August 1, 1983.

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

, Part 707, Title 40, July 1,

2003.

40 CFR 720, Premanufacture Notification , Code of Federal Regulations

, Part 720, Title 40 , July 1, 2003.

40 CFR 721, Significant New Use of Chemical Substances , Code of Federal Regulations

, Part 721, Title 40, July 1, 2003.

59 FR 7629, Federal Actions to Address Environmental Jus tice in Minority Populations and Low-Income Populations , Federal Register, Volume 59, February 16, 1994.

59 FR 22951, Consultation and Coordination with Indian Tribal Governments , Federal Register, Volume 59, November 6, 2000.

62 FR 19885, Protection of Children from Environmental Health Risks and Safety Risks, Federal Register, Volume 62, April 23, 1997.

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

66 FR 28355, Actions Concerning Regulations that Significantly Affect Energy Supply, Distribution, or

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. Avai lable in docket EPA-HQ-OPPT-2005-0058 at http://www.regulations.gov.

Accustandard, 2010. “Phthalates Standards.” Available at: http://www.accustandard.com/asi/np_phthal ates.php3 Accessed Aug. 12, 2010.

Australian Government. 2008a. Existing Chemical Hazard Assessment Report for Butylbenzyl Phthalate

. Department of Health and Ageing, National Indust rial Chemicals Notification and Assessment Scheme (NICNAS): Sydney, Australia, 2008. http://www.nicnas.gov.au/Publications/CAR/Other /Phthalates.asp. Accessed Aug 13, 2009.

Australian Government. 2008b. Existing Chemical Hazard Assessment Report for Dibutyl Phthalate

. Department of Health and Ageing, National Industrial Chemicals Notification and Assessment Scheme (NICNAS): Sydney, Australia, 2008. http://www.nicnas.gov.au/Publications/CAR/Other /Phthalates.asp. Accessed Aug 13, 2009.

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, 2008 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

. Department of Health and Ageing, National Industrial Chemicals Notification and Assessment Scheme (NICNAS): Sydney, Australia, 2008. http://www.nicnas.gov.au/Publications/CAR/Other /Phthalates.asp. Accessed Aug 13, 2009.

Australian Government. 2008e. Existing Chemical Hazard Assessment Report for Diisodecyl Phthalate

. Department of Health and Ageing, National Industrial Chemicals Notification and Assessment Scheme (NICNAS): Sydney, Australia, 2008. http://www.nicnas.gov.au/Publications/CAR/Other /Phthalates.asp. Accessed Aug 13, 2009.

Australian Government. 2008f. Existing Chemical Hazard Assessme nt Report for Diisonoyl Phthalate

. Department of Health and Ageing, National Industrial Chemicals Notification and Assessment Scheme (NICNAS): Sydney, Australia, 2008. http://www.nicnas.gov.au/Publications/CAR/Other /Phthalates.asp. Accessed Aug 13, 2009.

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. http://www.nicnas.gov.au/Publications/CAR/Other /Phthalates.asp. Accessed Aug 13, 2009.

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 Notifica tion and Assessment Scheme (NICNAS): Sydney, Australia, 2008. www.nicnas.gov.au/Publications/CAR /Other/Phthalates.asp. Accessed Aug 13,

2009.

Babich, M.; Chen, S.; Greene, M.; Kiss, C.; et al. 2004. Risk Assessment of Oral Exposure to Diisononyl Phthalate from Children’s Products . Regul. Toxicol. Pharmacol. 2004, 40 (2), 151–167.

BLS, 2010a. U.S. Bureau of Labor Statistics. “Employer Costs for Employee Compensation Supplementary Tables December 2009.” (March 10, 2010) at http://www.bls.gov/ncs/ect/sp/ecsuptc13.pdf. (Note: The BLS report title and content is updated periodically to include more recent data, on the same website.)

BLS, 2010b. Bureau of Labor Statistics. Employment Cost Index – Total Compensation: Professional and Related Private Industry, Not Seasonally Adjusted. (Series ID: CIU2010000120000I) , extracted April 12, 2010.

CAS, 2010a. Columbia Analytical Services, Inc. “Di-n-pentyl Phthalate.” Available at: http://www.caslab.com/Di-n-pentyl-Phthalate.php5

CDC, 2009a. Centers for Disease Control and Preven tion. Third National Report on Human Exposure to Environmental Chemicals. http://www.cdc. gov/exposurereport/. Accessed July 2005.

CIL, 2010a. Cambridge Isotope Laboratories, Inc. “Di-n-pentyl Phthalate.” Available at: http://www.isotope.com/cil/products/dis playproduct.cfm? prod_id=9076&cat_id=107 . Accessed Aug. 12, 2010.Economic Analysis of SNUR for 8 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di- n -pentyl Phthalate (DnPP) Economic and Policy Analysis Branch Clausen, P. A.; Hansen, V.; Gunnarsen, L.; Afshari, A. 2004. Emission of Di-2-ethylhexyl Phthalate from PVC Flooring into Air and Uptake in Dust: Em ission and Sorption Experiments in FLEC and CLIMPQA . Environ. Sci. Technol. 2004, 38, 2531–2537.

CMA, 1991. Chemical Manufacturers Association. Responses to Questions on Burden Associated with

PMN Submissions . Distributed by the Chemical Manufacturers Association, Washington, DC.

CPSC. 2001. U.S. Consumer Product Safety Commissi on. Chronic Hazard Adviso ry Panel on Diisononyl Phthalate (DINP). Directorate of Health Sciences: Bethesda, MD 20814.

CPSC. 2002. U.S. Consumer Product Safety Commissi on. Memorandum to Marilyn L. Wind from S.B. Chen. Screening of Toys for PVC and Phthalates Migration.

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

EC. 2003a. European Commission. European Union Risk Assessment Re port: 1,2-Benzenedicarboxylic Acid, Di-C8-10-Branched Alkyl Esters, C9-Rich And Di-“Isononyl” Phthalate (DINP), CAS-Nos. 68515-48-0, 28553-12-0. Vol. 35; EUR 20784EN; Office for Official Publications of the European Communities: Luxembourg, 2003.

EC. 2003b. European Commission. European Union Risk Assessment Re port: 1,2-Benzenedicarboxylic Acid, Di-C9-11-Branched Alkyl Esters, C10-Rich And Di-“Isodecyl” Phthalate (DIDP), CAS-Nos

68515-49-1 and 26761-40-0 . Vol. 36; EUR 20785EN; Office for Official Publications of the European Communities: Luxembourg, 2003.

EC. 2003-04. European Commission. European Union Risk Assessment Report: Dibutyl Phthalate, CASNo. 84-74-2 . Vol. 29; EUR 19840EN; Office for Official Publications of the European Communities: Luxembourg, 2003-04.

EC. 2008a. European Commission. European Union Risk Assessment Report Bis(2-Ethylhexyl) Phthalate (DEHP),CAS-No. 117-81-7 . Vol. 80; EUR 23384EN; Office for Official Publications of the European Communities: Luxembourg, 2008.

EC. 2008b. European Commission. European Union Risk Assessment Report Benzyl Butyl Phthalate (BBP), CASNo. 85-68-7. Vol. 76; EUR 22773EN; Luxembourg: Office for Official Publications of the European Communities, 2008.

EPA, 1986. U.S. EPA, Office of Toxic Substances. New Chemical Information Bulletin: Exemptions for Research and Development and Test Marketing . Washington, D.C. November, 1986. Available

at: http://www.epa.gov/oppt/newchems/pubs/tmeranddbulletin.pdf

EPA, 1994. U.S. EPA, Office of Toxic Substances, Regulatory Impacts Branch. Regulatory Impact Analysis of Amendments to Regulations fo r TSCA Section 5 Premanufacture Notifications

. Washington, DC: U.S. EPA/OPPT/EETD/RIB, Sept ember 9, 1994. (OTS/RIB later became OPPTS/EPAB.)

EPA, 2000. U.S. EPA, Office of Pollution Prevention and Toxics, ICR No. 1139.06. [Information Collection Request for] TSCA Existing Chemical Test Rules, Consent Orders, Test Rule Exemptions, and Voluntary Test Data Submissions: Supporting Statement for Request for OMBEconomic Analysis of SNUR for 9 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di- n -pentyl Phthalate (DnPP) Economic and Policy Analysis Branch Review under the Paperwork Reduction Act . Attachment 5, Wage Rates Estimation, August 29,

2000.

EPA, 2002a U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Revised Economic Analysis for the Amended Inventory Update Rule: Final Report. Washington, DC. August 2002.

EPA, 2002b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis

Branch. Wage Rates for Economic Analysis of the Toxics Release Inventory Program. Washington, DC, June 10, 2002.

EPA, 2003. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Economic Analysis of Expedited Significant New Use Rules for 65 Chemical Substances

. Washington, DC, 2003. Available in docket EPA-HQ-OPPTS-2002-0078 at http://www.regulations.gov.

EPA, 2005. Office of Pollution Prevention and To xics, Economic and Policy Analysis Branch. Economic Analysis of the Proposed Change to TSCA Section 12(b) Export Notification Requirements,November 2005, available from the Federal Docket Management System as EPA-HQ-OPPT2005- 005 8-0017 at http://www.regulations.gov.

EPA, 2006a. Inventory Update Reporting (IUR): Non-C onfidential 2006 TSCA Inventory Update Rule (IUR) Records. Availa ble at: http://cfpub.epa.gov/iursea rch/index.cfm?s=c hem. (Accessed 9 April 2009).

EPA, 2007a. U.S. EPA, Office of Pollution Preven tion and Toxics, Economic and Policy Analysis

Branch. Economic Analysis of Expedited Significant New Use Rules for 38 Chemical Substances (EPA Docket OPPT- 2006-0898 ), August 17, 2007.

EPA, 2007b. U.S. EPA, Office of Pollution Prevention and Toxics , ICR No. 0574.14. [Information Collection Request for] Pre-Manufacture Review Reporting and Exemption Requirements for New Chemical Substances and Significant New Use Reporting Requirements for Chemical Substances: Supporting Statement fo r a Request for OMB Review under The Paperwork

Reduction Act , December 6, 2007.

EPA, 2009a. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis

Branch . Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule

. (EPA-HQ-OPPT-2008-0296). July 13, 2009.

EPA, 2009b. U.S. EPA, Office of Pollution Prevention and Toxics. ICR No.: 0795.13 [Information Collection Request for] Notification of Chemic al Exports - TSCA S ection 12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction Act . March 6, 2009 at http://www.regulations.gov

.

EPA, 2009c. U.S. EPA, Office of Chemical Safety and Pollution Prevention. Phthalates Action Plan.

Available at: http://www.epa.gov/opptintr/existingchemicals/ pubs/actionplans/phthalates_ap_2009_1230_final. pdf.Economic Analysis of SNUR for 10 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di- n -pentyl Phthalate (DnPP) Economic and Policy Analysis Branch Gray L.E. Jr, Wilson V.S., Stoker T., Lambright C., Furr J., Noriega N., Howdeshell K., Ankley GT,

Guillette L. 2006. Adverse effects of environmental antiandrogens a nd androgens on reproductive development in mammals . Int J Androl. Feb; 29(1): 96-104; discussion 105-8.

Review.

Hotchkiss A.K., Parks-Saldutti L.G., Ostby J.S., Lambri ght C., Furr J., Vandenbergh J.G., Gray L.E. Jr.

2004. A mixture of the "antiandrogens" linuron and butyl benzyl phthalate alters sexual differentiation of the male ra t in acumulative fashion . Biol Reprod. 71(6):1852-61.

Howdeshell K.L., Furr J., Lambright C.R., Rider C.V., Wilson V.S., Gray L.E. Jr. 2007. Cumulative effects of dibutyl phthalate and diethylhexyl phthalate on male rat reproductive tract development: altered fetal steroid hormones and genes . Toxicol Sci. Sep; 99(1): 190-202.

Howdeshell K.L., Rider C.V., Wilson V.S., Gray L.E. Jr. 2008a. Mechanisms of action of phthalate esters, individually and in combination, to induce abnormal reproductive development in male laboratory rats . Environ Res. Oct;108(2):168-76. Review.

Howdeshell K.L., Wilson V.S., Furr J., Lambright C.R., Rider C.V., Blystone C.R., Hotchkiss A.K., Gray

L.E. Jr. 2008b. A mixture of five phthalate esters inhibits fetal testicular testosterone production in the sprague-dawley rat in a cumulative, dose-additive manner . Toxicol Sci. Sep; 105(1): 153-

65.

HSDB. 2009. Hazardous Substance Data Bank. U.S. National Library of Medicine TOXNET System. http://toxnet.nlm.nih.gov/cgi-bin/sis/html gen?HSDB (accessed Aug 13, 2009).

Huang, P. C.; Kuo, P. L.; Chou, Y. Y.; Lin, S. J.; Lee, C. C. 2009. Association between prenatal exposure to phthalates and the health outcome of newborns. Environ. Int. 2009, 35(1), 14–20.

Krauskopf, L.G., and Godwin, A. 2005. Plasticizers. In C. Wilkes, J. Summers, and C. Daniels (Eds.),

PVC Handbook (pp. 173-201). Cincinnati: Han ser Gardner Publications, Inc.

NAS. 2008. National Academy of Sciences. Phthal ates and Cumulative Risk Assessment; The Tasks Ahead. Dec 2008. http://dels.nas.edu/dels/rpt_brie fs/phthalates_final.pdf. Accessed Dec 9, 2009.

NTP-CERHR. 2003a. National Toxicology Program - Center for the Evaluation of Risks to Human Reproduction. Monograph on the Potential Human Repr oductive and Developmental Effects of Di-n-Octyl Phthalate (DnOP); NIH Pub. No. 03-4488; U.S. Department of Health and Human Services, May 2003.

NTP-CERHR. 2003b. National Toxicology Program - Center for the Evaluation of Risks to Human Reproduction. Monograph on the Potential Human Repr oductive and Developmental Effects of Di-n-Hexyl Phthalate (DnHP); NIH Pub. No. 03-4489; U.S. Department of Health and Human Services, May 2003.

NTP-CERHR. 2003c. National Toxicology Program - Center for the Evaluation of Risks to Human Reproduction. Monograph on the Potential Human Repr oductive and Developmental Effects of Di-Isodecyl Phthalate (DIDP); NIH Pub. No. 03-4485; U.S. Department of Health and Human Services, April 2003.Economic Analysis of SNUR for 11 U.S. EPA Office of Chemical Safety and Pollution Prevention

Di- n -pentyl Phthalate (DnPP) Economic and Policy Analysis Branch NTP-CERHR. 2003d. National Toxicology Program - Center for the Evaluation of Risks to Human Reproduction. Monograph on the Potential Human Repr oductive and Developmental Effects of Di-Isodecyl Phthalate (DIDP); NIH Pub. No. 03-4485; U.S. Department of Health and Human Services, April 2003.

NTP-CERHR. 2003e. National Toxicology Program - Center for the Evaluation of Risks to Human Reproduction. Monograph on the Potential Human Repr oductive and Developmental Effects of Butyl Benzyl Phthalate (BBP); NIH Pub. No. 03-4487; U.S. Department of Health and Human Services, March 2003.

NTP-CERHR. 2006. National Toxicology Program - Center for the Evaluation of Risks to Human Reproduction. Monograph on the Potential Human Repr oductive and Developmental Effects of Di-(2-ethylhexyl) Phthalate (DEHP); NIH Pub. No. 06-4476; U.S. Department of Health and Human Services, March 2006.

OPM, 2009. Office of Personnel Management, Salary Table 2009-DCB, Washington-Baltimore/Northern Virginia, DC-MD-PA-VA-WV. Accessed from http://www.opm.gov/oca/09tables/pdf/DCB.pdf

Swan, S. H.; Main, K. M.; Stewart, S. L.; Kruse, R. L.; Calafat, A. M.; Mao, C. S.; Redmon, J. B.; Ternand, C. L.; Sullivan, S.; Teague. J. L. 2005. Study for Future Families Research Team. Decrease in Anogenital Distance among Male Infants with Prenatal Phthalate Exposure. Environ. Health Perspect. Aug 2005, 113(8), 1056–61.

Rahman, Mustafizur, and Brazel, Christopher S. The plasticizer market: an assessment of traditional plasticizers and research trends to meet new challenges . Progress in Polymer Science, Volume 29, Issue 12, December 2004, pp. 1223-1248.

Rawie, Carol. 2009. EPA Office of Pollution Preven tion and Toxics. Personal communication with Tulika Narayan and Kimberly Wilson of Abt Associates via e-mail. February 5, 2009.

Rider C.V., Furr J., Wilson V.S., Gray L.E. Jr. 2008. A mixture of seven antiandrogens induces reproductive malformations in rats . Int J Androl. Apr;31(2):249-62.

Rider C.V., Wilson V.S., Howdeshell K.L., Hotchkiss A.K., Furr J.R., Lambright C.R., Gray L.E. Jr.

2009. Cumulative effects of in utero administration of mixtures of "antiandrogens" on male rat reproductive development . Toxicol Pathol. 37(1):100-13.

U.S. SBA. 2010. United States Small Business Administration. Table of Small Business Size Standards Matched to North American Industry Classification System Codes. Available at: http://www.sba.gov/idc/groups/public/documen ts/sba_homepage/serv_sstd_tablepdf.pdf

USPS, 2010. U.S. Postal Service Mailing and postag e rates. <http://www.usps.c om/prices>. Accessed 16 August 2010.