ECONOMIC ANALYSIS 

OF THE PROPOSED 

SIGNIFICANT NEW USE RULE FOR MERCURY-CONTAINING FLOW METERS, 

NATURAL GAS MANOMETERS, AND PYROMETERS 

Prepared by: 

Economic and Policy Analysis Branch 

Economics, Exposure and Technology Division 

Office of Pollution Prevention and Toxics 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

1200 PENNSYLVANIA AVENUE, N.W. 

WASHINGTON, DC 20460 

October 10, 2008
Economic Analysis of SNUR i U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

CONTRIBUTORS 

The EPA analyst responsible for this report was Timothy Lehman. Analytical and draft 

preparation support was provided by Abt Associates Inc. under EPA Contract No. EP-W-08-010. 
Economic Analysis of SNUR ii U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

ABSTRACT 

 This report estimates the costs of the proposed Significant New Use Rule (SNUR) for 

elemental mercury used in the following products: flow meters, natural gas manometers, and 

pyrometers. Historically, elemental mercury has been used in many industrial and consumer 

products, due to its unique properties. Use of elemental mercury in products can lead to releases 

to the environment during manufacturing, recycling, or disposal. Under certain conditions, 

mercury in the environment can cause adverse effects in humans and wildlife. Some State 

governments have restricted mercury use in products and have requested federal action to bolster 

these efforts. In 2006, EPA committed to pursue reductions in mercury used in switches, relays, 

and measuring devices. In 2007, EPA issued a Significant New Use Rule (SNUR) for elemental 

mercury used in certain switches previously installed in motor vehicles. EPA has now identified 

three more mercury-containing products that have cost-effective substitutes and are no longer 

manufactured. The products are flow meters, natural gas manometers, and pyrometers. 

The SNUR would require persons to notify EPA at least 90 days before commencing the 

manufacture, import, or processing of elemental mercury for use in any of the three products. 

To submit this SNUN, a firm incurs a modest submission cost, since EPA does not require the 

development of test data for submission of a SNUN, although a firm may submit test data 

already in its possession and/or describe any other available data. Because mercury-containing 

flow meters, natural gas manometers, and pyrometers are an older, established technology, EPA 

assumes that a firm will submit only pre-existing test data. Thus, it is assumed that no testing 

costs will occur as a result of this SNUR. 

 

 By avoiding a Significant New Use, a firm can avoid submission and testing costs, but 

may incur other compliance costs. The firm may also incur “hidden” costs, not quantified here, 

for example if it foregoes profitable opportunities to use the chemical in an application that 

would be a Significant New Use or limits production volume to avoid a Significant New Use. 

 Costs are estimated for mercury at one representative site, and reflect SNUR restrictions 

specific to this chemical. EPA receives only a handful of notices per year due to SNURs. The 

number of firms affected but not making submissions to EPA is not known, and costs are not 

aggregated. 
Economic Analysis of SNUR iii U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

TABLE OF CONTENTS

CONTRIBUTORS........................................................................................................................... i 

ABSTRACT ............................................................................................................................. ii 

LIST OF TABLES......................................................................................................................... iv 

1.0 INTRODUCTION .......................................................................................................... 1 

1.1 Products Covered by this SNUR..................................................................................... 3 

1.1.1 Flow Meters .................................................................................................................... 3 

1.1.2 Natural Gas Manometers ................................................................................................ 4 

1.1.3 Pyrometers ...................................................................................................................... 7 

1.2 Impact of a SNUR........................................................................................................... 8 

2.0 COSTS OF A SIGNIFICANT NEW USE RULE (SNUR), BY OPTION .................... 9 

2.1 Submit SNUN (Option 1) ............................................................................................... 9 

2.1.1 Costs for Submitting a SNUN....................................................................................... 10 

2.2 Decide Not to Produce Chemical (Option 2)................................................................ 11 

2.3 Likelihood of a SNUN Submission .............................................................................. 11 

2.4 Potential for Subsequent Regulatory Actions............................................................... 11 

3.0 EXPORT NOTIFICATION COSTS ............................................................................ 12 

4.0 AGENCY COSTS ........................................................................................................ 12 

5.0 ADDITIONAL ANALYSES........................................................................................ 13 

5.1 Regulatory Flexibility Act (RFA)................................................................................. 13 

5.2 Unfunded Mandates Reform Act (UMRA) .................................................................. 14 

5.3 Paperwork Reduction Act (PRA).................................................................................. 14 

5.4 National Technology Transfer and Advancement Act ................................................. 14 

5.5 Executive Order 12630: Governmental Actions and Interference with Constitutionally 

Protected Property Rights ................................................................................. 14 

5.6 Executive Order 12866: Regulatory Planning and Review .......................................... 14 

5.7 Executive Order 12898: Environmental Justice ........................................................... 15 

5.8 Executive Order 12988: Civil Justice Reform.............................................................. 15 

5.9 Executive Order 13045: Protection of Children ........................................................... 15 

5.10 Executive Order 13132: Federalism ............................................................................. 15 

5.11 Executive Order 13175: Tribal Governments............................................................... 15 

5.12 Executive Order 13211: Energy Supply, Distribution, or Use ..................................... 15 

APPENDIX A INFLATORS AND WAGE RATES .............................................................. A-1 

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

A.2 Derivation of Inflation Factors.................................................................................... A-5 

APPENDIX B COSTS FOR SNUN ....................................................................................... B-1 

APPENDIX C AGENCY COSTS .......................................................................................... C-1 

APPENDIX D REFERENCES ............................................................................................... D-1 
Economic Analysis of SNUR iv U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

LIST OF TABLES 

Table 1: Mercury Content in Products affected by the Proposed SNUR ...................................... 1 

Table 2: Industries potentially affected by the SNUR, by NAICS Code........................................ 2 

Table 3: CAS Number and Synonyms for Mercury ....................................................................... 3 

Table 4: Manometer Regulation Information, by State .................................................................. 6 

Table 5: Compliance Options and Associated Costs Incurred by a Firm due to SNUR ................ 9 

Table 6: Cost of Requirement to Submit a SNUN ($2007)1......................................................... 11 

Table A-1: Derivation of Loaded Wage Rates.........................................................A-4 

Table A-2: Weighted Average Wages for Industrial Hygienists – Manufacturing................A-5 

Table A-3: Derivation of Inflation Factors..............................................................A-6 

Table B-1: Industry Costs for SNUN.....................................................................B-1 

Table C-1: Agency Costs for SNUN and Other Submission Review and Processing.............C-2 
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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1.0 INTRODUCTION 

 This report presents the U.S. Environmental Protection Agency (EPA), Office of 

Pollution Prevention and Toxics’ (OPPT’s) analysis of the potential costs incurred as a result of a 

Significant New Use Rule (SNUR) being proposed for elemental mercury used in the following 

products: flow meters, natural gas manometers, and pyrometers. EPA promulgates a SNUR for a 

substance when potential uses could result in increased exposure to or releases of the substance 

and in turn, could present an unreasonable risk to health or the environment. In contrast to PreManufacture Notification (PMN) requirements, which apply mainly to manufacturers and 

importers (40 CFR §720.22), the SNUR applies to processors as well as to manufacturers and 

importers (40 CFR §721.5). Table 1 presents summary information on the products regulated 

under this proposed SNUR, including the relevant applications and ranges of the amount of 

mercury used in each product type. 

Table 1: Mercury Content in Products affected by the Proposed SNUR 

Mercury-Containing 

Product Applications Hg per Unit (g) Hg per unit (lbs) 

Flow Meter All up to 5,000 up to 11 

Manometer Natural Gas Pipelines 3,175 to 4,536 7 to 10 

Pyrometer All 5 to 10 .01 - .02 

Source: IMERC 2004; Piehler 2007; Environment Canada 2004
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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Table 2 provides summary information on the industries potentially affected by this SNUR. 

Note that the table is not intended to be entirely comprehensive; it provides a sample of the 

potentially affected industries for illustration purposes. 

Table 2: Industries potentially affected by the SNUR, by NAICS Code 

NAICS Name Description 

2211 

Electric Power Generation, 

Transmission and 

Distribution 

This industry group comprises establishments primarily engaged in 

generating, transmitting, and/or distributing electric power. Establishments in 

this industry group may perform one or more of the following activities: (1) 

operate generation facilities that produce electric energy; (2) operate 

transmission systems that convey the electricity from the generation facility 

to the distribution system; and (3) operate distribution systems that convey 

electric power received from the generation facility or the transmission 

system to the final consumer. 

221310 Water Supply and 

Irrigation Systems 

This industry comprises establishments primarily engaged in operating water 

treatment plants and/or operating water supply systems. The water supply 

system may include pumping stations, aqueducts, and/or distribution mains. 

The water may be used for drinking, irrigation, or other uses. 

237120 

Oil and Gas Pipeline and 

Related Structures 

Construction 

This industry comprises establishments primarily engaged in the construction 

of oil and gas lines, mains, refineries, and storage tanks. The work performed 

may include new work, reconstruction, rehabilitation, and repairs. Specialty 

trade contractors are included in this group if they are engaged in activities 

primarily related to oil and gas pipeline and related structures construction. 

All structures (including buildings) that are integral parts of oil and gas 

networks (e.g., storage tanks, pumping stations, and refineries) are included 

in this industry. 

3315 Foundries 

This industry group comprises establishments primarily engaged in pouring 

molten metal into molds or dies to form castings. Establishments making 

castings and further manufacturing, such as machining or assembling, a 

specific manufactured product are classified in the industry of the finished 

product. Foundries may perform operations, such as cleaning and deburring, 

on the castings they manufacture. More involved processes, such as tapping, 

threading, milling, or machining to tight tolerances, that transform castings 

into more finished products are classified elsewhere in the manufacturing 

sector based on the product being made. 

334513 

Instruments and Related 

Products Manufacturing 

for Measuring, Displaying, 

and Controlling Industrial 

Process Variables 

This U.S. industry comprises establishments primarily engaged in 

manufacturing instruments and related devices for measuring, displaying, 

indicating, recording, transmitting, and controlling industrial process 

variables. These instruments measure, display or control (monitor, analyze, 

and so forth) industrial process variables, such as temperature, humidity, 

pressure, vacuum, combustion, flow, level, viscosity, density, acidity, 

concentration, and rotation. 

486110 Pipeline Transportation of 

Crude Oil 

This industry comprises establishments primarily engaged in the pipeline 

transportation of crude oil. 

486210 Pipeline Transportation of 

Natural Gas 

This industry comprises establishments primarily engaged in the pipeline 

transportation of natural gas from processing plants to local distribution 

systems. 

Sources: U.S. Census Bureau 2001; U.S. Census Bureau 2003a, U.S. Census Bureau 2007a-e 
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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Elemental mercury has many unique properties that make it extremely useful across a 

number of industries and applications. It is non-reactive over a wide-range of temperatures 

(Leopold, 2002) but conducts electricity. It is a dense metal and expands or contracts at a 

relatively constant rate across a variety of temperatures. Furthermore, it easily bonds with many 

other metals to form a variety of amalgams, themselves with different characteristics (Lenntech). 

As a result of these unparalleled characteristics, mercury can be found in thermometers, 

thermostats, barometers, manometers, sphygmomanometers, hydrometers, hygrometers, 

batteries, medical instruments, dental amalgams, switches, relays, and many more products and 

components. 

Table 3 lists the generic or specific chemical name and CAS number for the chemical 

covered under this SNUR. 

Table 3: CAS Number and Synonyms for Mercury 

CAS Number Synonyms 

7439-97-6 Mercury (Hg) 

1.1 Products Covered by this SNUR 

Since the proposed SNUR applies to three distinct products (each possessing its own 

unique market trends, regulatory history, exposure risk, etc.), the introduction discusses each 

product individually. 

1.1.1 Flow Meters 

Flow meters measure the flow rate of liquids or gases. Historically, they have been used 

in civil service applications (e.g., water treatment plants, sewage plants, power stations, and 

other industrial applications) (Galligan et al. 2003). Environment Canada’s 2004 report entitled 

“Sources of Mercury: Mercury-containing Products” indicates that mercury-containing flow 

meters can contain up to 5,000 grams of mercury (Environment Canada 2004). In recent years, 

many states have banned mercury-containing flow meters, including California, Maine, 

Massachusetts, New York, and Vermont. Research undertaken in preparation of the proposed 

SNUR found no data indicating that mercury-containing flow meters are still produced. 

Furthermore, many mercury-free alternatives exist, including differential pressure devices, 

positive displacement meters, velocity meters, and mass meters. Figure 1 shows a turbine flow 

meter. 
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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At the outset of the research into flow meters, an exhaustive Internet search was conducted of 

both foreign and domestic instrument manufacturers as well as major auction houses for 

mercury-containing flow meters; the Interstate Mercury Education and Reduction Clearinghouse 

(IMERC)1

 was also searched. These initial online searches were later supplemented by phone 

conversations with several flow meter manufacturers and distributors.2

 In all cases, none of the 

contacted companies made, sold, imported, or knew of any other companies that made, sold or 

imported mercury-containing flow meters. Also during the course of this research, no special 

uses (e.g. flow meter calibration devices that contain mercury) or exceptions were identified. 

Based on the availability of newer and more accurate alternatives, it is likely that there are few 

remaining in use; however a definitive count of mercury-containing flow meters could not be 

determined or estimated. 

1.1.2 Natural Gas Manometers 

Manometers are used in numerous applications to measure air, gas and liquid pressure. 

Manometers used in the natural gas industry contain between 7 to 10 pounds of mercury (Piehler 

2007). As with other types of manometers, breakage poses one risk of exposure; in addition, 

mercury sometimes spills when these manometers are removed from the pipelines. In the last ten 

years, several natural gas and pipeline companies have been named in settlements or lawsuits 

citing mercury contamination around metering stations (Schliefstein 2007; U.S. DOJ 2002). 

Given the large quantity of mercury per unit in natural gas manometers and the risks posed by 

 

1

 IMERC requires that all companies in its member states that are planning to sell mercury-containing products in 

their jurisdictions submit a notification to the Clearinghouse every three years with information on the amount of 

mercury in each unit of the product, and in all of the products put on the market in the United States. 

2

 The following flow meter manufacturers and distributors were contacted: Omega Engineering, Inc., Utility Supply 

of America, and Lake Monitors, Inc. 

Figure 1: Turbine Flow Meter (Omega Engineering 

Inc. 2008)
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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maintenance, it is likely that natural gas manometer repair and maintenance create further spill 

and atmospheric exposure risks. 

 The 2005 Standard Handbook of Petroleum and Natural Gas Engineering describes how 

pressure differentials have historically been measured in natural gas pipelines. This is done with 

the use of a liquid in a U-shaped tube and “mercury is generally used in commercial orifice 

meters of this type” (Lyons, 2005). In a U-shaped tube manometer, one end is left open to the 

atmosphere; the other is exposed or connected to the source being measured. If the pressure 

measured is higher than atmospheric pressure, the liquid (mercury or otherwise) moves toward 

the open end of the tube. If the pressure measured is lower than atmospheric pressure, the liquid 

moves away from the open end. The difference between the liquid levels on either side of the 

tube provides a reading relative to atmospheric pressure. Figure 2 provides a visual depiction of a 

typical mercury-containing U-Tube manometer. 

In a report entitled “Fundamentals of Orifice Recorders”, the American School of Gas 

Measurement and Technology (ASGMT) describes mercury-containing orifice meters as the 

earliest meters used to measure pressure differences in the natural gas industry. The author writes 

that there are currently “several manufacturers and configurations of mercury meters” (Reynolds, 

2007). However, he follows this sentence by noting that health and environmental concerns due 

to the mercury content within the devices have lead to their decreased use in industry. The 

Colorado Engineering Experiment Station Inc.’s (CEESI’s) Technical Library includes several 

articles from the International School of Hydrocarbon Measurement Publications reiterating the 

historical and declined use of mercury orifice meters used in natural gas measurement. An article 

entitled “Operation and Maintenance of Single Bellows Meters” states that “the bellows orifice 

meter was developed to replace the mercury meter which has been the industry standard for 

measuring differential pressure” (Beall 1979). Another article in this publication entitled 

“Bellows-Type Orifice Meters” notes how the bellows-type meter has found “widespread 

application and increasing popularity in orifice metering” (Crabtree 1979). It is important to note 

that the articles in this publication were written in 1979, indicating that the shift from mercury to 

bellows-type orifice meters was apparently underway nearly 30 years ago. 

Figure 2: Typical Mercury-Containing U-Tube 

Manometer (FAO 1989)
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for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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Historically, the decreased demand for mercury-containing manometers may partially be 

attributed to programs that have encouraged the replacement of these instruments. Furthermore, 

several states, including California, New York and Massachusetts have banned the sale of 

several types of (and in some cases, all) mercury-containing manometers. Table 4 summarizes 

state regulation data gathered from queries within each individual States’ Department of 

Environmental Protection (or the equivalent) websites. 

Table 4: Manometer Regulation Information, by State

State Application Regulation Date Effective

CA 

All mercury-containing manometers except 

those required by federal law or when the 

mercury added product is a button cell battery 

May not be offered for final 

sale, or distributed 7/1/2006 

LA Dairy and natural gas manometers May not be offered for final 

sale, used or distributed 7/1/2007 

ME 

All mercury-containing manometers except 

those required by federal law or if the mercury 

is a button cell battery 

May not be sold 7/1/2006 

MA 

All mercury-containing manometers except 

those required by federal law or are medically 

necessary or ordered by prescription 

May not be sold, offered for 

sale, or distributed 5/1/2008 

NY 

All mercury-containing manometers except if 

the manometer is in a product to replace a 

product that is a component in a larger product 

May not be sold, offered for 

sale, or distributed 1/1/2007 

VT 

All mercury-containing manometers except 

dairy manometers when used for calibration of 

equipment 

May not be sold, offered for 

sale, or distributed 1/1/2007 

WA 

All mercury containing manometers except 

those sold or distributed to a hospital or healthcare facility and those used for the calibration of

other equipment. 

May not be sold 1/1/2006 

Sources: IMERC 2006, Legislature of Louisiana 2006, Maine DEP 2007, Vermont Statutes Online. 

In preparation for the SNUR, an exhaustive internet query was undertaken to determine if 

any manufacturers still produced mercury-containing natural gas manometers. Furthermore, a 

review of the 27 mercury-containing manometers listed in the EPA Mercury-Added Products and 

Alternatives database was undertaken to determine if any were specifically advertised or 

described as intended for use in pipeline monitoring. Lastly, known historical mercurycontaining manometer manufacturers, natural gas pipeline manufacturers, and service companies 

were contacted.3

 All of the contacted companies reported that they no longer manufactured, sold, 

or imported mercury-containing manometers used for pipeline applications. While none were 

able to make broader claims regarding the entire industry, they stated that the industry was 

‘going digital’ (i.e. mercury-free). Moreover, most of the mercury-containing manometers in the 

EPA database appear to be for laboratory or medical use, and those that appear to be intended for 

industrial use generally are smaller, handheld, or portable devices and would not be suitable for 

pipelines. 

 

3 The following manometer-related companies were contacted: Reynolds Equipment Manufacturing, Weatherford 

International Ltd., Baker Hughes Incorporated, Meriam Process Technologies, and Princo Instruments, Inc. 
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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IMERC provides information indicating that there may be a market for mercurycontaining replacement parts for manometers. One of the manufacturers listed in the IMERC 

database, Meriam Instruments, reported that (as of 2004) it sold both mercury-containing 

replacement tubes for manometers, and liquid mercury for use as an indicating fluid. 

Conversations with Meriam Instruments technical support staff revealed that the sale of 

elemental mercury ended in 2007. However, it is unclear where the mercury-containing 

replacement tubes end up. Thus, it is difficult to determine the extent of the replacement 

part/mercury fluid market. A search for manufacturers/distributors of these parts did not find any 

additional companies, suggesting that the market, if existent, is very thin. 

1.1.3 Pyrometers 

 

Pyrometers are essentially thermometers that can measure extremely high temperatures. 

They are found in use today in industrial foundry processes, pottery and ceramic kiln work, and 

some automotive applications. Historically, pyrometers contained mercury in their sensing units. 

Environment Canada’s 2004 report entitled “Sources of Mercury: Mercury-containing Products” 

indicates that mercury-containing pyrometers typically contain between 5 to 10 grams of 

mercury (Environment Canada 2004). In recent years, however, many states have banned the 

sale of mercury-containing pyrometers, including California, Maine, Massachusetts, New York, 

and Vermont. Furthermore, three mercury-free alternatives were identified: optical pyrometers, 

infrared pyrometers, and digital/analog pyrometers. Figure 3 shows a typical analog pyrometer. 

In preparation for the proposed SNUR, an exhaustive Internet search was conducted of 

both foreign and domestic instrument manufacturers as well as of major auction houses for 

mercury-containing pyrometers; IMERC was also searched. These online queries were 

supplemented by phone conversations with several manufacturers of instrumentation equipment 

for high temperature applications.4

 Again, in all cases, none of the contacted companies made, 

sold, imported, or knew of any other companies that made, sold, or imported mercury-containing 

 

4 The following manufacturers of instrumentation equipment for high temperature applications were contacted: 

Bartlett Instrument Company, Cress Manufacturing Company, and Omega Engineering, Inc. 

Figure 3: Analog Pyrometer (Evenheat Kiln Inc. 2008)
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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pyrometers. Also, there were no special uses or exceptions identified, such as pyrometer 

calibration devices where mercury is still currently used. Based on the availability of newer and 

more accurate alternatives, it is likely that there are few remaining in use; however a definitive 

count of mercury-containing pyrometers could not be determined or estimated. 

1.2 Impact of a SNUR 

The SNUR discussed in this report specifies that any manufacture, importation or 

processing of mercury for use in flow meters, natural gas manometers, or pyrometers would be 

considered a new use and require reporting under section 5(a)(1)(A) of TSCA. This requires that 

a firm intending to manufacture, import, and/or process this chemical for these applications must 

submit a Significant New Use Notification (SNUN). Alternatively, a firm can decide not to 

manufacture, import, and/or process this chemical. The firm therefore has two options: 

3⁄4 Option 1: Submit a SNUN. If the firm intends to manufacture, import, and/or process 

elemental mercury for these purposes, it must submit a SNUN. A SNUN indicates to 

EPA that the firm would like to manufacture, import, and/or process the chemical for a 

Significant New Use, which, in this case, means any manufacture, importing, and/or 

processing of this chemical for flow meters, natural gas manometers, or pyrometers. The 

SNUN must be provided to EPA at least 90 days before the firm plans to commence the 

manufacture, import, and/or processing of the substance; it provides EPA with the 

opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity 

before it occurs. If EPA allows the manufacture, importation, and/or processing of 

elemental mercury for any of these three products, then the costs associated with this 

option are the costs of submitting the SNUN (including a user fee) plus the possible costs 

of following Option 2 during EPA review of the SNUN. 

3⁄4 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 elemental mercury 

for flow meters, natural gas manometers, or pyrometers. While this option avoids the 

costs of submitting a SNUN, it entails the ‘hidden’ cost of the profit that will be foregone 

as a result of not engaging in the commercial activity originally planned. Similarly, if the 

firm would have used a given amount of mercury in the production of another product 

and must substitute to a more costly substance, it will incur those additional ‘hidden’ 

costs of production. If the firm elects to produce for research and development (R&D) 

purposes only (exemption is covered in 40 CFR §721.47), it may have costs associated 

with R&D recordkeeping. 
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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Table 5 summarizes the costs associated with each option. 

Table 5: Compliance Options and Associated Costs Incurred by a Firm due to SNUR 

Option1 Costs Quantified Costs per 

Chemical ($2007)2

1. Submit a Significant New 

Use Notice (SNUN). 

Costs of submitting a SNUN, including testing 

costs, associated recordkeeping, and user fee. 

$8,222 submission cost 

(including $2,500 fee) plus 

any testing costs.3

2. 

Decide not to manufacture, 

import, or process, the 

chemical. 

Cost of the profit foregone as a result of not 

engaging in the commercial activity originally 

planned, and recordkeeping costs only if 

manufacturing for research and development. 

Costs not quantified. 

1

 Firms may be subject 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. 

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

Costs are detailed in B-1 and Appendix B. 

3 EPA does not require the development of test data for submission of a SNUN, although a firm may submit test data 

already in its possession and/or describe any other available data. Because mercury-containing flow meters, natural 

gas manometers, and pyrometers are an older, established technology, EPA assumes that a firm will submit only preexisting test data. Thus, it is assumed that no testing costs would occur as a result of this SNUR. 

 The remainder of this report estimates the quantified portion of costs associated with the 

SNUR being promulgated for these uses of mercury. Section 2 presents estimates of the costs 

incurred by manufacturers, importers, and/or processors under the SNUR options. Section 3 

addresses one-time export notification costs. Section 4 addresses costs to EPA of administering 

the SNUR, while Section 5 presents an analysis of other impacts, as required by various statutes 

and executive orders. The appendices provide cost estimation details. 

2.0 COSTS OF A SIGNIFICANT NEW USE RULE (SNUR), BY OPTION 

 A SNUR specifies requirements a firm must meet if it chooses to manufacture, import, 

and/or process a PMN chemical. A firm may choose to follow only one of the options 

previously described: submit a SNUN, or decide not to manufacture, import, and/or process, the 

chemical. These options are described below. Appendix A provides the wage rates and inflators 

used in this analysis. 

2.1 Submit SNUN (Option 1) 

 Under 40 CFR §721.5, manufacturers, importers, and/or processors who would like to 

undertake a Significant New Use of a PMN substance listed in a SNUR are required to submit a 

Significant New Use Notice (SNUN) at least 90 days before the firm plans to commence the 

manufacture, import, and/or processing of the substance. For example, they could submit a 

SNUN if they wish to produce above the volume limit listed in the SNUR for a given chemical, 

because any production beyond that volume would be defined as a Significant New Use. 
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for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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Because the SNUR discussed in this report specifies that any manufacture, importation, and/or 

processing of elemental mercury for the three prescribed products constitutes a Significant New 

Use, a firm wishing to manufacture, import, and/or process any volume of elemental mercury for 

these products would have to submit a SNUN. 

 The SNUN provides EPA with the opportunity to evaluate the intended use and, if 

necessary, to prohibit or limit that activity before it occurs. The notice form used to submit a 

SNUN is the same as that for a PMN, and the costs of submitting a SNUN are estimated based 

on the costs incurred to submit a PMN. 

 This option could have the following costs: 

• Costs of preparing the SNUN and of the $2,500 user fee. 

• Costs of avoiding production while the SNUN is being processed; costs of recordkeeping 

and of complying with any restrictions resulting from the SNUN review. 

• EPA does not require the development of test data for submission of a SNUN, although a 

firm may submit test data already in its possession and/or describe any other available 

data. Because mercury-containing flow meters, natural gas manometers, and pyrometers 

are an older, established technology, EPA assumes that a firm will submit only preexisting test data. Thus, it is assumed that no testing costs would occur as a result of this 

SNUR. 

Advance Compliance Exemption

 Another option available to firms before the SNUR is promulgated is to seek an advance 

compliance exemption under 40 CFR §721.45(h). The submission cost for this option is the 

same as that for a SNUN, but by negotiating an advance compliance agreement with EPA a firm 

can diminish the loss of profits due to delay. This option is not available after the SNUR is 

promulgated. 

2.1.1 Costs for Submitting a SNUN 

 The costs for submitting a SNUN are estimated to be equivalent to the costs of 

completing a PMN submission. In addition, as was mentioned above, there could be testing 

costs, delay costs, or other costs not included here. Table 6 shows the costs of preparing a 

SNUN; details are presented in Appendix B. 
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

11

Table 6: Cost of Requirement to Submit a SNUN ($2007)1

Cost Element Cost 

($2007) 

Costs of preparing submission (110 labor hours) $5,722 

User fees $2,5002

TOTAL $8,222 

Notes:

1

Figures are rounded to whole dollars (see Appendix B for derivation). 

2

Small businesses with annual sales of less than $40 million when 

combined with those of the parent company (if any) are subject to a 

reduced user fee of $100. 

2.2 Decide Not to Produce Chemical (Option 2) 

 Some firms may find that the costs of preparing a SNUN are financially unattractive. In 

this case, the firm could choose not to manufacture, import, and/or process the PMN substance. 

 While this option avoids the costs of meeting the specifications in the SNUR or 

submitting a request for some alternative, it entails the "hidden" cost of the profit that will be 

foregone as a result of not engaging in the commercial activity originally planned. For example, 

if the firm does not produce the PMN substance, then it will forego the profit it would have 

achieved by producing it. That foregone profit is a potential "hidden" cost of Option 2. 

Similarly, if the firm would have used the PMN substance in the production of another product 

and must substitute to a more costly substance, it will incur those additional costs of production. 

If the firm elects to produce for R&D purposes only, it may have costs associated with R&D 

recordkeeping attributable to the SNUR. 

2.3 Likelihood of a SNUN Submission 

 As of 2008, EPA has not identified any current manufacturer, importer, and/or processor, 

and therefore believes that there is no current import or domestic manufacture or processing of 

elemental mercury for use in flow meters, natural gas manometers, or pyrometers. For this 

reason, EPA thinks that submission of a SNUN for these elemental mercury uses is unlikely due 

to the history of the chemical. 

2.4 Potential for Subsequent Regulatory Actions 

 The Agency recognizes that if submission of a SNUN does result from this SNUR, the 

Agency may take additional regulatory actions under TSCA. These additional regulatory actions 

might be necessary to further evaluate an intended new use and associated activities, or to 

prohibit or limit that activity before it occurs to prevent unreasonable risk of injury to human 

health or the environment. It is not known what specific subsequent regulatory actions, if any, 

the Agency may determine are necessary after reviewing a SNUN. Any such actions are highly 
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

12

dependent on the circumstances surrounding the individual SNUN (e.g., available information 

and scientific understanding about the chemical and its risks at the time the SNUN is being 

reviewed). 

 Should the Agency’s review of the SNUN result in further regulatory actions, the Agency 

will initiate and follow the appropriate procedures for taking those actions. Included in those 

procedures would be an assessment of the costs and benefits of those actions. 

3.0 EXPORT NOTIFICATION COSTS 

Under Section 12(b) of TSCA, exporters must notify EPA if they export or intend to 

export a chemical identified in a SNUR (40 CFR §707.60 through 75). After receiving a 

notification from a firm, EPA notifies the importing country and the United States State 

Department (40 CFR §707.70). 

On November 14, 2006, EPA revised the export notification requirement from an annual 

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

subject to TSCA sections 5(a)(2), 5(b), 5(e)(1), and 5(e)(2) (November 14, 2006, 71 FR 66234).5 

Notifications must include the exporter's name and address, the chemical name, the date(s) of 

export or intended export, the importing country (or countries), and the section of TSCA under 

which EPA has taken action. 

 However, as noted in 40 CFR 707.60(b), the exemption from notification requirements for 

exported articles remains in force. Thus, persons who export elemental mercury as part of an 

article are not required to provide export notice (although they remain subject to any other 

applicable requirements of TSCA section 12(b)). Furthermore, elemental mercury is already 

subject to Section 12(b) of TSCA under the 2007 SNUR for certain automotive switches. 

Therefore, there are no expected export notification costs associated with this SNUR. 

4.0 AGENCY COSTS 

EPA’s costs to review and process industry submissions such as SNUNs are assumed to 

be the same as EPA costs to review PMNs. These costs are estimated at $5,668 per case. The 

required Agency steps, full-time equivalent (FTE) staff needs, and extramural costs such as for 

contractor support are derived in Appendix F from EPA's analysis of the Agency costs of 

processing PMN submissions (RIB, 1994), with adjustments to reflect inflation and changes in 

Agency staff levels. The original EPA analysis used a range of salaries, but this analysis uses 

one typical salary. 

The PMN costs reflect estimates made in 1994, in Regulatory Impact Analysis of 

Amendments to Regulations for TSCA Section 5 Premanufacture Notifications (RIB, 1994). The 

average cost to review a SNUN may be different from that estimated for PMNs, both because of 

differences between PMNs and SNUNs, and because the PMN review hours may have changed 

 

5 Under the previous rule, exporters were required to submit a notice the first time in the calendar year they exported 

a particular chemical to a particular country. 
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

13

since 1994. Resources were not available to re-estimate costs for SNUNs. See Appendix C for 

details. 

5.0 ADDITIONAL ANALYSES 

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

required under various statutes and executive orders. 

 5.1 Regulatory Flexibility Act (RFA) 

 The Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et. seq.), as amended by the Small 

Business Regulatory Enforcement Fairness Act, requires regulators to consider the 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. Of those SNUNs submitted, none appear to be from small 

entities in response to any SNUR. In fact, EPA expects to receive few, if any, SNUNs from 

either large or small entities in response to any SNUR. 

 This leaves open the question of how many small businesses are affected but do not

submit SNUNs. For example, businesses may change their behavior in order to use a chemical 

in a manner that avoids triggering Significant New Use notification requirements, and make no 

submission to EPA. 

Data and resources were not available to estimate the number of small businesses 

affected by the current rule. However, a 1989 analysis suggested that few small businesses 

would be affected by SNURs for chemicals that have undergone PMN review. The 1989 report 

estimated that 9% of firms subject to SNURs would be small businesses, based on the portion of 

PMN submitters who were small businesses (RIB, 1989). The threshold to be considered a 

“small business” was $40 million in sales, which is consistent with the definition used at 40 CFR 

§700.43 to set PMN fees. 

 Past bona fide submissions also suggest that few firms other than possibly some PMN 

submitters will be affected.6

 EPA has received few bona fides indicating interest in 

manufacturing or importing chemicals subject to past SNURs. EPA also has received few public 

comments during rulemaking on SNURs covering PMN chemicals. For example, a SNUR 

published in the spring of 2003 covering 62 chemicals resulted in industry comments on only 

three PMNs, none from small businesses (EPA Docket No. OPPT-2002-0060; EPA, 2003). 

 It remains possible that some small businesses are affected by SNURs without EPA being 

aware, for example if the firms have made no submissions or comments to EPA. However, even 

if a small business were interested in supplying a SNUR chemical, the SNUR's impact on profits 

is generally expected to be minor. For example, the firm may have a small expense of keeping 

records and/or of changing workplace practices to comply with restrictions. If modifying 

production practices would be overly costly, or if the firm wishes to engage in a Significant New 

 

6 Bona fides are submitted to EPA by manufacturers and importers to determine a chemical's TSCA Chemical 

Inventory and regulatory status. 
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

14

Use but believes that expensive testing is needed to support a submission to EPA, it may instead 

forego production, thus sacrificing profits. The amounts of lost profits, if any, were not 

quantified for this report, but usually should be low. This is because SNUR chemicals are 

relatively new and few compared to the many thousands of chemicals on the TSCA Inventory, 

and so are unlikely to be central to a firm’s business. 

 Based on these considerations and on the limited data available, EPA expects that any 

compliance with a SNUR will not have a significant economic impact on a substantial number of 

small entities. 

5.2 Unfunded Mandates Reform Act (UMRA) 

 EPA has determined that this regulatory action does not impose any enforceable duty, 

contain any unfunded mandate, or otherwise have any effect on small governments subject to the 

requirements of sections 202, 203, 204, or 205 of the Unfunded Mandates Reform Act of 1995 

(Public Law 104-4). 

 

5.3 Paperwork Reduction Act (PRA) 

 

 According to the Paperwork Reduction Act (PRA), 44 USC 3501 et seq., an agency may 

not conduct or sponsor, and a person is not required to respond, to a collection of information 

that requires Office of Management and Budget (OMB) approval under the PRA, unless it has 

been approved by OMB and displays a currently valid OMB control number. The information 

collection requirements related to this action have already been approved by OMB pursuant to 

the PRA under OMB control number 2070-0012 (EPA ICR No. 574). This action does not 

impose any additional burden requiring OMB approval. 

 5.4 National Technology Transfer and Advancement Act 

This action does not involve any technical standards, therefore section 12(d) of the 

National Technology Transfer and Advancement Act of 1995 (NTTAA), Public Law 104–113, 

section 12(d) (15 U.S.C. 272 note), does not apply to this action. 

 5.5 Executive Order 12630: Governmental Actions and Interference with 

Constitutionally Protected Property Rights 

 EPA has complied with Executive Order 12630, Governmental Actions and Interference 

with Constitutionally Protected Property Rights, by examining the takings implications of this 

rule in accordance with the “Attorney General's Supplemental Guidelines for the Evaluation of 

Risk and Avoidance of Unanticipated Takings” issued under the Executive order. 

5.6 Executive Order 12866: Regulatory Planning and Review 

 Executive Order 12866, Regulatory Planning and Review, requires OMB review for rules 

with an impact on the economy of $100 million or more, or with any other potential significant 
Economic Analysis of SNUR U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

15

impact. OMB has previously determined that these types of SNURs are not a “significant 

regulatory action” that would require OMB review under this Executive Order. 

5.7 Executive Order 12898: Environmental Justice 

 This action does not involve special considerations 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). 

5.8 Executive Order 12988: Civil Justice Reform 

In issuing this rule, EPA has taken the necessary steps to eliminate drafting errors and 

ambiguity, minimize potential litigation, and provide a clear legal standard for affected conduct, 

as required by Section 3 of Executive Order 12988, Civil Justice Reform. 

5.9 Executive Order 13045: Protection of Children 

 Executive Order 13045, Protection of Children from Environmental Health Risks and 

Safety Risks (62 FR 19885, April 23, 1997), requires EPA to identify and assess environmental 

health and safety risks that may disproportionately affect children. This type of analysis is 

required for rules that will have an impact of $100 million or more only. The impact of this 

SNUR will be less than $100 million and therefore no analysis of such impacts on children is 

required. 

5.10 Executive Order 13132: Federalism 

 

 Executive Order 13132, Federalism (64 FR 43255, August 10, 1999), requires EPA to 

develop an accountable process to ensure “meaningful and timely input by State and local 

officials in the development of regulatory policies that have federalism implications.” This 

action will not have a substantial 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). 

5.11 Executive Order 13175: Tribal Governments 

 Executive Order 13175 is Consultation and Coordination with Indian Tribal 

Governments (59 FR 22951, November 6, 2000). This rule does not have Tribal implications 

because it is not expected to have substantial direct effects on Indian Tribes. 

5.12 Executive Order 13211: Energy Supply, Distribution, or Use 

 This rule is not subject to Executive Order 13211, entitled Actions Concerning 

Regulations That Significantly Affect Energy Supply, Distribution, or Use (66 FR 28355, May 

22, 2001), because this action is not expected to affect energy supply, distribution, or use. 
APPENDIX A 

INFLATORS AND WAGE RATES 
Economic Analysis of SNUR A-1 U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

APPENDIX A INFLATORS AND WAGE RATES 

This appendix describes the derivation of the fully loaded labor rates and inflation factors 

used in calculating costs of labor, materials, and other inputs. The costs shown here were 

initially calculated for the Economic Analysis of the SNUR for Chloranil for year-end 2005; for 

this analysis, they have been inflated to year-end 2007 values. 

A.1 Derivation of Loaded Wage Rates 

Unit labor costs are calculated by adding fringe benefits and overhead to the wage or 

salary to derive a fully loaded labor cost. The basic method is described in Wage Rates for 

Economic Analysis of the Toxics Release Inventory Program (Rice, 2002). The resulting loaded 

labor rates are given in Table A-1. Costs are calculated for several labor categories: Managerial, 

Professional/Technical, Clerical, Production Workers, Industrial Hygienists, and EPA staff. 

In March 2004, BLS began using the North American Industry Classification System 

(NAICS) codes instead of the Standard Industrial Classification (SIC) System, and the Standard 

Occupational Classification (SOC) system instead of the Occupational Classification System 

(OCS). The following table shows the crosswalk between old and new occupational titles. 

Source: Employer Costs for Employee Compensation: Changes to NAICS and SOC, Table 2. ECEC Occupational 

Comparability between SOC and OCS (BLS, 2006a); and Weinstein, 2004. 

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

and Production Labor 

Wages and fringe benefits for managerial, professional/technical, clerical and production 

labor were taken from the Bureau of Labor Statistics (BLS) Employer Costs for Employee 

Compensation (ECEC) data,7

 for December, for manufacturing industries.8 

 

7

 This is a change from the method used in a 2003 report, Economic Analysis of Expedited Significant New Use Rules For 65 

Chemical Substances (EPAB, 2003; EPA docket number OPPT-2002-0078). Previously, wage rates for production workers 

came from the BLS National Employment, Hours, and Earnings, Average Hourly Earnings of Production Workers, while fringe 

benefits were taken from the ECEC data. Here, both wages and fringes for production workers come from ECEC data, for better 

consistency with the method of estimating labor costs for other labor categories. 

8 Employer Costs for Employee Compensation, Private Manufacturing Industry by Occupation, unpublished BLS data (BLS, 

2006a). Past SNUR economic analyses, such as EPAB, 2003, used ECEC data for “All Goods Producing” sectors 

(manufacturing, mining, and construction). However, the manufacturing sector data seems more relevant since the SNUR mainly 

affects the chemicals industry. 

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

Managerial Executive, administrative, and 

managerial 

Management, business, and 

financial 

Professional/Technical Professional specialty and technical Professional and related 

Clerical Administrative support, including 

clerical Office and administrative support 
Economic Analysis of SNUR A-2 U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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

category, are taken from the same ECEC series. Fringe benefits as a percent of wages are 

calculated separately for each labor category. For example, for December 2005, the average 

wage rate for professional/technical9

 labor was $31.02; the average fringe benefit was $16.73. 

Fringe benefits as a percent of wages were $16.73/$31.02, or approximately 53.9 percent. 

An additional loading factor of 17 percent is applied to wages to account for overhead. 

This approach is used for consistency with Office of Pollution Prevention and Toxics economic 

analyses for two major rulemakings: Wage Rates for Economic Analyses of the Toxics Release 

Inventory Program (Rice, 2002), and the Revised Economic Analysis for the Amended Inventory 

Update Rule: Final Report (EPAB, 2002). 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 2005 fully loaded wage for professional/technical labor is $31.02 × 

(1+0.539329 + 0.17) = $53.02. 

 The Bureau of Labor Statistics’ Table 5: Compensation: Employment Cost Index for 

Total Compensation, for Private Industry Workers, by Occupational Group and Industry was 

used to inflate the fully loaded wage rates from December 2005 values to December 2007 values. 

While all the inflators were chosen from the manufacturing sector, different values were used to 

inflate the costs based on the nature of the occupation. For example, managerial costs were 

inflated using the “management, professional, and related” index, while production labor used 

the “production, transportation, and material moving” index. A more detailed explanation can be 

found in the notes to Table A-1. 

Fully loaded December 2007 costs for managerial, clerical, and production labor are 

calculated in a similar manner, as shown in Table A-1. 

A.1.2 Derivation of Labor Rates for Industrial Hygienists 

For industrial hygienists, wages were based on another BLS data series, Occupational 

Employment Statistics [OES], National Industry-Specific Occupational Employment and Wage 

Estimates. OES data were used because ECEC data were not available for very specific 

occupations. However, the OES data covers only wages, not fringe benefits. Therefore, the 

Industrial Hygienist fringe benefits continue to be based on ECEC data.10

The wage rate for Industrial Hygienists is a weighted average of the hourly mean wage 

for Occupational Health and Safety Specialists, Standard Occupational Classification (SOC) 29-

9011, and Occupational Health and Safety Technicians, SOC 29-9012, in Manufacturing. The 

wage rate for each occupation was weighted by employment for the occupation. The North 

 

9

 Past SNUR economic analyses have used the term “technical” labor. Here the category is called “professional/technical” labor, 

to make clear how it relates to BLS categories. In 2004, BLS changed from the Occupational Classification System, OCS, to the 

Standard Occupational Classification system, SOC. In the process, the “Professional specialty and technical” category became 

the “Professional and related” category. However, the coverage of the old and new occupational groups is approximately the 

same. See the BLS article, Comparing Current and Former Industry and Occupation ECEC Series (Weinstein, 2004). 

10 This represents a change in data sources for Industrial Hygienist wages as compared to the prior PMN SNUR economic 

analysis, which used data from a 1997 professional journal salary survey (EPAB, 2003). 
Economic Analysis of SNUR A-3 U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

American Industry Classification System (NAICS) codes for Manufacturing are 31, 32, and 33 

(BLS, 2005). The calculations are shown in Table A-2. 

As with other labor categories, the fringe benefits factor came from the BLS Employer 

Costs for Employee Compensation: Private Manufacturing Industry by Occupation (BLS, 

2006c). Benefits for “professional specialty and technical” occupations were used, and loaded 

wages were calculated as for other types of labor. An additional loading factor of 17 percent of 

wages was applied for overhead. Costs were inflated to 2007 values using the “management, 

professional, and related” values in the same manner as discussed in the section describing the 

derivation of labor rates for managerial, professional/technical, clerical and production labor. 

Calculations are shown in Table A-1. 

A.1.3 Derivation of Labor Rates for EPA Staff 

Agency labor costs are calculated based on annual Federal salaries for the WashingtonBaltimore area published by the Office of Personnel Management effective January 2008 (OPM, 

2008). The average salary for one Full Time Equivalent (FTE) staff is estimated as the salary for 

a GS-13 Step 5 employee.

11 

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) (OPPE, 1992, page 30, footnote 9). The 60 percent assumption was 

labeled “the benefits multiplication factor” in the EPA Guide, but has been used in many EPA 

Office of Pollution Prevention and Toxics ICRs to reflect both fringe benefits and overhead for 

Federal staff. For example, it was used in an August 2000 document supporting ICR No. 

1139.06, with the following explanation: 

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

benefits multiplication factor). The multiplication factor used is recommended in EPA's 

Office of Policy, Planning, and Evaluation's Instructions for Preparing Information 

Collection Requests (ICRs) (June 1, 1992). An EPA internal phone call between Carol 

Rawie (OPPT/EETD/RIB) and Carl Koch (OPPE/RMD/IMB) on May 3, 1994, indicated 

that the 1.6 factor included not only benefits but also overhead.” (ICR No.1139.06) 

 

11 The GS-13 Step 5 is consistent with ICR No. 0574.12 (12/22/2004) which covers PMN SNURs. This grade level represents a 

change from the earlier PMN SNUR economic analysis (EPAB, 2003), which used an average of GS-12 Step 1 and GS-12 Step 

10 salaries. The change is based on the judgment of EPA staff familiar with the SNUN process that a GS-13 (or higher) grade 

level is more typical for PMN and SNUN reviewers (Carol Rawie conversation with Karen Chu, EPA OPPT/Chemical Control 

Division, 5/1/06). 
Economic Analysis of SNUR A-4 U.S. EPA Econom

for Mercury-Containing Flow Meters, Manometers on Oil and Gas Pipelines, and Pyrometers 

Table A-1 Derivation of Loaded Wage Rates1

Wage Fringe Benefit Fringes as % wage* Over- head % wage2 Fringe + overhead factor* Loaded Wages* In

Fa

EPAB Labor 

Category Data Sources 

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

Managerial 

BLS ECEC, Private Manufacturing 

industries, “Mgt, Business, and Financial”4 $38.22 $18.89 49.42% 17% 1.66 $63.61 1

Professional/ 

Technical 

BLS ECEC, Private Manufacturing 

industries, “Professional and related“4 $31.02 $16.73 53.93% 17% 1.71 $53.02 1

Clerical 

BLS ECEC, Private Manufacturing industries, “Office and Administrative Support”4

$15.73 $7.97 50.67% 17% 1.68 $26.37 1

Production 

Worker 

BLS ECEC, Private Manufacturing industries, “Production.”4 $15.34 $8.93 58.21% 17% 1.75 $26.88 1

Wage: BLS OES Occupat. Employ. and Wages, for Manufacturing (NAICS 31, 32, 33), average of wages for Occup. Health/ Safety Specialists (SOC 29-9011) and Occup. Health/Safety Technicians(SOC 29-9012), weighted by employment.5

$26.10 1

Industrial 

Hygienist 

Fringes: BLS ECEC, Private Manufacturing industries, “Professional and related”4

-- -- 53.93% 17% 1.71 $44.61 1

EPA staff 

FTE 

Annual Federal staff cost: OPM Washington-Baltimore-Northern Virginia, DC-MD-PA-VA-WV, area, GS-13 Step 5 pay rates, with 60% overhead.6

$94,025 

(annual) -- 

[Included 

in 60% 

overhead] 

60% 1.6 $150,440 (annual) 

Notes: 1Wage data are rounded to the closest dollar figure in this table; however, in calculations using these numbers for this report, unrounded values were used. 2An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory Program (Rice, 2002), and 

the Amended Inventory Update Rule: Final Report (EPAB, 2002). 

3The inflation indexes come from the Bureau of Labor Statistics' Employment Cost Index for total compensation, for private industry workers, by occupation

http://www.bls.gov/news.release/eci.t05.htm). The index used to inflate "Managerial", "Professional", and "Industrial Hygienist" is the Manufacturing "mana

value; for "Clerical" staff the inflator is the Manufacturing "Sales and office" value; for "Production Workers" the inflator is the "Production, transportation, 

4Unpublished Employer Costs for Employee Compensation: Private Manufacturing Industry by Occupation, December 2005. Data received by Carol Rawie

US Bureau of Labor Statistics, May 10, 2006 (BLS, 2006c). The data is not seasonally adjusted (email from Raphael Branch to Carol Rawie, November 17, 

5Employment and unweighted wages are from BLS Occupational Employment Statistics (National Industry-Specific Employment and Wage Estimates), May 6 The Federal salary is the unloaded Federal GS-13 Step 5 ($94,025) for 2008, from the Office of Personnel Management salary table for Washington-Baltim

fringes-and-overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (OPPE, 1992, page 30, footnote 9). 
Economic Analysis of SNUR A-5 U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

Table A-2 Weighted Average Wages for Industrial Hygienists – Manufacturing (NAICS 31, 32, 33)1

Occupation Title (SOC code) 

Employment

(a)

Mean hourly wage

(b)

Weight 

(c)

Weighted 

Wage 

($2005) 

(d)=(c) x (b)

Occupational Health & Safety Specialists (29-9011) 5,630 $27.27 0.811 $22.12 

Occupational Health & Safety Technicians (29-9012) 1,310 $21.08 0.189 $3.98 

Industrial Hygienist (weighted average) 6,940 -- 1 $26.10 

Notes: 

1

Wage data are rounded to the closest dollar figure in this table; however, in calculations using these numbers for this report, unrounded 

values were used. 

Source: Employment and unweighted wages are from BLS Occupational Employment Statistics (Occupational Employment and 

Wages), for May 2005 (BLS, 2005). 

A.2 Derivation of Inflation Factors 

 Costs of equipment and supplies were inflated to year 2007 dollars using the Consumer 

Price Index -- All Urban Consumers; wages were inflated using the appropriate Employment 

Cost Index (ECI). Where both labor and equipment/supplies were involved, we used the inflation 

factor corresponding to the dominant cost category. For example, test costs include a mix of 

labor, equipment, and supplies. Assuming that the largest component of test costs comes from 

labor, we used the ECI for private industry, all workers. Complete information on the derivation 

of the inflation factors used is given in Table A-3 below. 
Economic Analysis of SNUR A-6 U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

Table A-3 Derivation of Inflation Factors 

Item Inflation index source Starting 

year 

Index for 

starting year 

(a) 

Index for 

Dec. 2007 

(b) 

Inflation 

factor 

(b)/(a)3

Chemical testing (toxicity, 

ecological effects etc.) 

BLS ECI, not SA, total comp, 

private industry, All Workers. 

ECS10002I, 4th Q [BLS, 2008a] 

varies varies (b) varies 

White collar/other labor mix; 

equipment; supplies. Example for test costed in 1993 1993 66.5 106.3 varies 

Tests were first costed out in 

various years, depending on the 

test; inflation factors vary 

depending original cost date. 

Example for test costed in 2000 2000 83.8 106.3 1.598 

Impermeability testing of 

gloves and other gear1

BLS ECI, not SA, total comp, 

private industry, All Workers. 

ECS10002I, 4th Q [BLS, 2008a]

1997 74.9 106.3 1.268 

Export notification 

BLS ECI, not SA, Total comp, 

Private industry, White Collar. 

ECS11102I, 4th Q [BLS, 2008a] 

1992 63.2 106.8 1.690 

Agency Extramural costs 

White collar labor; 

equipment; supplies

BLS ECI, not SA, Total comp, 

Private industry, White Collar. 

ECS11102I, 4th Q [BLS, 2008a]

1993 65.5 106.8 1.631 

Labels, placards, gloves, 

eyewear, clothing, respirators 

File cabinet 

 

BLS CPI, inflation calculator, not 

SA. Annual [BLS, 2008b] 1997 160.5 207.3 1.292 

Photocopies 

Record keeping materials 

 

BLS CPI, inflation calculator, 

Annual [BLS, 2008b] 1988 118.3 207.3 1.752 

Key: BLS = Bureau of Labor Statistics. CPI = Consumer Price Index. ECI = Employment Cost Index. SA = Seasonally Adjusted. 

Total Comp = Total Compensation (wages/salaries and benefits). 4th Q = Fourth Quarter. “ECS10002I” etc. refer to BLS series Ids. 

Notes: 

1 The index selected represents a change from a prior PMN SNUR economic analysis (EPAB, 2003). The prior report used a series 

(ECS11102I) for private industry White Collar workers; this report uses the series (ECS10002I) for all private industry workers. The 

change better reflects the mix of labor likely to be involved in impermeability testing. 2

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

June 1989 = 100.” The change is reflected in the index factors in this table and explained on the BLS website, Employment Cost Index 

News Release Text: Employment Cost Index, March 2006 (BLS, 2006b). The SIC-based series (as opposed to NAICS-based) are used 

here because they contain historical data. The CPI was not rebased. 3 While indexes for the starting year and 2007 are rounded to one decimal place in this table, unrounded indexes were used to calculate 

the inflation factor. 
APPENDIX B 

COSTS FOR SNUN 
Economic Analysis of SNUR B-1 U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

APPENDIX B COSTS FOR SNUN 

Estimates of the costs of completing a Significant New Use Notice (SNUN) form are 

based on the costs of completing a PMN submission, since the data requirements are the same 

and the same form is used for both. EPA's 1994 Regulatory Impact Analysis (RIA) for 

amendments to the PMN regulations relied on industry estimates of the effort needed to collect 

and compile all data required for a PMN submission, prepare the form, and submit the form and 

data to EPA (RIB, 1994). These estimates were based on a survey conducted by the Chemical 

Manufacturers Association (CMA, 1991), which became the American Chemistry Council. 

In the 1994 EPA report, the average effort required to prepare and submit a PMN was 95 

to 114 hours. This included recordkeeping for the submission, but the recordkeeping cost was 

not broken out. For this analysis, the costs of a preparing a SNUN were derived using the 

averages of the hours for each type of labor from the 1994 report. The method of calculating 

hourly loaded labor costs is described in Appendix A. In addition to preparing and submitting a 

SNUN, manufacturers must maintain records on the submission for five years. Thus, this 

analysis includes a recordkeeping burden assumed to be 5% of the preparation and submission 

burden (5.3 hours); this is assumed to be performed with clerical labor. Thus, the total time 

burden for SNUN preparation, submission, and recordkeeping is estimated to be between 100 

and 119 hours.

Table B-1 details the cost of submitting a SNUN, including the $2,500 EPA notification 

user fee. 

Table B-1. Industry Costs for SNUN 

Labor 

Category 

Hours 

Range1

Average 

Hours 

Loaded Wage 

Rate2 ($2007) SNUN (Option 1) 

Clerical 17.3 – 19.3 18.3 $27.50 $503 

Technical 67 - 80 73.5 $54.88 $4,034 

Managerial 16 - 20 18 $65.84 $1,185 

Subtotal 100.3 – 119.3 109.8 $5,722 

User fee (SNUN only) $2,500 

TOTAL $8,222 

Notes: 

1 Hours range for each labor category are from the PMN Amendments RIA (RIB, 1994) 2

 Loaded wages include fringe benefits and overhead. See Appendix A for derivation. Wage 

rates presented in this table are rounded values; however, unrounded values are used to 

calculate total labor costs. For this reason, total labor costs may not equal the product of 

rounded values. 
APPENDIX C 

AGENCY COSTS 
Economic Analysis of SNUR C-1 U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

APPENDIX C AGENCY COSTS 

EPA submission review costs are presented in Table C-1. Costs to review and process 

SNUNs are assumed to be similar to EPA costs to review PMNs.12 

The list of review steps, estimates of staff-year full-time equivalents (FTEs), and estimates of 

extramural costs are derived from the costs for processing PMN submissions in a 1994 EPA report, 

Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture 

Notifications (RIB, 1994). The percent of chemicals requiring a particular review step are from RIB, 

1994. 

The GS levels used for Agency staff reflect the judgment of Agency staff familiar with the 

PMN/SNUN review process. The salary of a Full Time Equivalent EPA staff was calculated using 

GS-13 Step 5 salary data (OPM, 2008). The original PMN cost estimates were for GS-12 and were 

presented as low and high estimates, based on the most junior (Step 1) and the most senior (Step 10) 

GS-12 pay rates, respectively. However, this analysis uses the higher GS-13 staff level and, for 

simplicity, a single intermediate pay rate (Step 5) within that GS level. A loading factor of 1.6 was 

applied to the salary to reflect fringe benefits and overhead (OPPE, 1992). The loaded salary 

calculations are described in Appendix A. 

For each review step, the “EPA staff” cost is calculated by multiplying the number of FTEs 

(in the first column) by the fully loaded average salary. This shows EPA staff cost for chemicals 

requiring the selected review step. 

The Extramural Cost column shows costs for contractor support and other outside purchases 

for chemicals requiring the selected review step, inflated from 1993 prices, as explained in Appendix 

A. 

The Percent of Cases is a weighting factor applied to reflect the fact that not all chemicals 

require each review step. For example, in the PMN process, all chemicals require Administrative 

Prescreening, but not all chemicals require 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. Changes 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 required in the first place. However, often a 

SNUN may take more Agency time than a typical PMN because of factors such as the need to 

retrieve old PMN records from archives, and the likelihood that more data requiring EPA review is 

submitted with a SNUN than would be submitted on average with a PMN. Resources were not 

available to update the review hours to reflect the current review process or to tailor the cost 

estimates to SNUNs. Therefore, for this analysis, the review steps and weighting factors are 

assumed to be the same as those derived in 1994 for PMNs. 

 

12 For an overview of the PMN review process, see the Chemistry Assistance Manual for Premanufacture 

Notification Submitters, EPA, 1997.
Economic Analysis of SNUR C-2 U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

The Weighted Cost column is calculated by multiplying the Unweighted Costs (EPA staff 

cost plus extramural costs) by the percentage of cases requiring this review step. This calculation 

yields total Agency costs for submission review and processing shown in Table C-1. 

Table C-1 Agency Costs for SNUN and Other Submission Review and Processing 

EPA staff (FTE) Cost Extramural Cost2

FTE

fraction 

Cost per 

FTE 1

FTE Total 

($2007) 

1993 

dollars 

2007 

dollars 

Unweighted 

Cost 

Pct. of 

Cases 

Weighted 

Review Steps Cost 

(1) (2) (3)=(1)*(2) (4) (5) (6)=(3)+(5) (7) (8)=(6)*(7)

Prenotice consultation 0.0024 $150,440 $361 $4 $7 $368 41% $151 

Administrative prescreen/ 

notice receipt/user fee 0.0024 $150,440 $361 $92 $150 $511 100% $511 

CRSS (Chemical Review and 

Search Strategy) 0.0025 $150,440 $376 $268 $437 $813 100% $813 

SAT (Structure Activity 

Team) 0.0006 $150,440 $90 $14 $23 $113 100% $113 

Engineering/Exposure 0.0015 $150,440 $226 $56 $91 $317 100% $317 

Exposure/Fate 0.0008 $150,440 $120 $0 $0 $120 100% $120 

Focus 0.0009 $150,440 $135 $23 $38 $173 100% $173 

Standard Review Functions 0.0219 $150,440 $3,295 $511 $833 $4,128 29% $1,197 

Division Directors Meeting 0.0129 $150,440 $1,941 $113 $184 $2,125 15% $319 

Order Development/ 

Negotiation Review 0.0171 $150,440 $2,573 $22 $36 $2,608 3% $78 

Post Order Data Review 0.0886 $150,440 $13,329 $0 $0 $13,329 3% $400 

Order Modification 0.2167 $150,440 $32,600 $0 $0 $32,600 3% $978 

New Chemical SNUR 

Development 0.0277 $150,440 $4,167 $85 $139 $4,306 7% $301 

Notices of Commencement 0.0012 $150,440 $181 $40 $65 $246 31% $76 

FOIA (Freedom of 

Information Act) Requests 0.0333 $150,440 $5,010 $287 $468 $5,478 1% $55 

CBI (Confidential Business 

Information) Substantiation 0.0004 $150,440 $60 $3 $5 $65 100% $65 

TOTAL $5,668 

Notes:

1

 GS-13 Step 5 salaries loaded with benefits and overhead. See Appendix B derivation.

2

 Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated 

from 1993 prices as described in Appendix A. 

3

Weighted costs were calculated using unrounded unit cost estimates, so results may differ from calculations using the rounded 

values shown in this table. 

Sources: FTEs per review step and 1993 extramural costs are from RIB, 1994. Percents of cases are from RIB, 1994. GS-13 

salaries are from OPM, 2008. 
APPENDIX D 

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Economic Analysis of SNUR D-1 U.S. EPA Economic and Policy Analysis Branch 

for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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and Pyrometers 

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2 

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and Pyrometers 

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for Mercury-Containing Flow Meters, 

Manometers on Oil and Gas Pipelines, 

and Pyrometers 

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