gysn;r 3

Economic Analysis of Expedited Significant New Use Rules

for 17

(EPA DOCKET EPA

f Expedited Significant New Use Rules

Chemical Substances

(EPA DOCKET EPA-HQ- OPPT-2011-0942)

January 25, 2012

—Does not contain TSCA CBI

Prepared by:

Economic and Policy Analysis Branch

Economics, Exposure and Technology Division

Office of Pollution Prevention and Toxics

Office of Chemical Safety and Pollution Prevention

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

f Expedited Significant New Use Rules

Does not contain TSCA CBI—

Economic and Policy Analysis Branch

Economics, Exposure and Technology Division

Pollution Prevention and Toxics

Office of Chemical Safety and Pollution Prevention

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

EPA SANITIZED Page 1 of 80
Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 i January 2012

Contributors

The EPA analyst responsible for this report was Stephanie Suazo of the Economic and Policy

Analysis Branch; Economics, Exposure and Technology Division; Office of Pollution Prevention 

and Toxics. Analytical and draft preparation support was provided by Abt Associates Inc. under 

EPA Contract No. EP-W08-010.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 ii January 2012

Executive Summary

This Economic Analysis estimates the potential costs of Significant New Use Rules (SNURs) covering 

17 chemicals that have been the subject of TSCA premanufacture notices (PMNs). Appendix A lists each 

regulated chemical’s generic or specific chemical name and Chemical Abstract Service Registry Number 

(CASRN) (if non-confidential). The SNURs are being published under the rulemaking docket number 

EPA-HQ- OPPT-2011-0942 as direct final rules. The SNURs define “Significant New Uses” that trigger 

EPA notification requirements. To submit a Significant New Use Notice or request a SNUR 

modification, a firm incurs a modest submission cost, plus costs of any additional data generated to 

support the submission. By avoiding a Significant New Use, a firm can avoid submission costs, but may 

incur other compliance costs. For example, it may incur costs associated with restricting chemical 

releases to water or preventing worker exposure. The options available to a firm considering the 

manufacture, import, and/or processing of a chemical covered under a SNUR, and the types of associated 

costs to the firm, are summarized in Table ES-1. 

It should be noted that the costs listed in Table ES-1 may be incurred for reasons other than the SNUR. 

The costs of avoiding a Significant New Use are attributable to the SNUR only if, in the absence of the 

SNUR, the firm would have adopted a different approach. For example, a SNUR may define any use 

other than that described in the PMN as a Significant New Use. If the PMN submitter would have 

conformed to the uses described in the PMN even without the SNUR, then any associated costs of 

adhering to the PMN uses would not be due to the SNUR. Costs to a PMN submitter of practices 

required by a TSCA Section 5(e) Consent Order would be attributable to the Consent Order, not the 

SNUR. If a processor would have workers wear gloves even without SNUR requirements, then the 

gloves costs would not be attributable to the SNUR. The costs in Table ES-1are attributable to the SNUR 

only if the firm adopts a different approach due to the Significant New Use Rule. 

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 iii January 2012

Table ES-1. Compliance Options and Associated Costs Incurred by a Firm due to SNUR

Option1 Costs Quantified Costs per Chemical 

(2010$)2

1 Manufacture, import, or process 

in a way that avoids a 

Significant New Use, such as 

limiting water releases, 

engaging in PMN uses only, 

importing only, limiting 

volumes, providing workplace 

protection, or providing hazard 

communications. 

All SNUR chemicals require ongoing 

recordkeeping. In addition, many 

SNUR chemicals may involve costs of 

complying with water release 

restrictions and foregoing non-PMN 

uses; these costs were not quantified 

for this report. Costs for worker 

protection and hazard communication 

apply to relatively few chemicals, but 

are quantified. 

Typically, annual costs for 

recordkeeping are under $1,155. For 

the few SNUR chemicals where 

these apply, annual costs for worker 

protection may be $36,283 or more 

and for haz-comm is $1,056. 

2 Submit a request for 

modification or revocation of 

the SNUR (§721.185). 

Costs of submitting a request for 

modification or revocation, including 

costs of developing supporting data 

(e.g., testing, if needed).

$5,802 submission cost plus any 

testing costs.3 EPA receives very 

few such requests, typically 0-3 per 

year

3 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 electronically submitting a 

SNUN (including SNUN 

recordkeeping and user fee4) plus 

ongoing recordkeeping. Rarely, a firm 

may choose to conduct toxicity or fate 

testing to support the SNUN, but such 

testing is not required by law. 

$8,302 submission cost (including 

SNUN recordkeeping and $2,500 

fee)4,5 plus ongoing recordkeeping 

costs of under $1,155. EPA usually 

receives well under ten SNUNs in a 

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).

4 Petition EPA for an equivalency 

determination to consider 

alternative controls to prevent 

release or exposure that are 

equivalent to those identified in 

the SNUR (§721.30).

Costs of submitting an electronic 

request for equivalency determination. 

$5,802 one-time submission cost.

5 Do not manufacture, import, or 

process the substance except for 

R&D (the R&D exemption is 

covered in 40 CFR §721.47). 

Cost of profits foregone due to 

delaying or avoiding commercial 

activity that would otherwise be 

pursued. R&D recordkeeping costs if 

manufacture for R&D.

Costs not quantified.

Notes: Section numbers refer to 40 CFR §721 (in the Code of Federal Regulations). Costs come from Table 3

through Table 8. 

1

Firms may follow multiple Options simultaneously

2 Quantified costs are attributable to the SNUR Significant New Use definition only if a firm would not otherwise 

follow the specified practices. $36,283 is the annual cost for dermal protection selection; impermeability testing, 

heavy-duty gloves, and a lower-cost respirator (see Table 5). Some firms may have export notification costs (see 

Chapter 3 of this report).

3

See Appendix D for costs of individual tests recommended in current and recent SNURs.

4 EPA charges a nominal flat fee of $2,500 for a PMN or SNUN submission. 

5

SNUR chemicals not on the TSCA Inventory are “new” chemicals requiring a PMN, so some firms may need to 

make a submission before commercial production or import, even in the absence of a SNUR (see Section 2.3 of this 

report).

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 iv January 2012

Table of Contents

1 Introduction............................................................................................................................. 1

1.1 Statutory Authority and Significant New Uses under the Proposed SNURs.................. 1

1.2 Summary of Methodology .............................................................................................. 2

1.3 Organization of this Report............................................................................................. 2

2 Costs of a Significant New Use Rule (SNUR), by Option ..................................................... 3

2.1 Comply with SNUR Limits (Option 1)........................................................................... 4

2.2 Request Modification or Revocation of a SNUR (Option 2)........................................ 10

2.3 Submit SNUN (Option 3) ............................................................................................. 13

2.4 Request Equivalency Determination (Option 4)........................................................... 15

2.5 Decide Not to Produce Chemical (Option 5)................................................................ 16

2.6 Summary of Costs for Each Option.............................................................................. 16

3 Export Notification Costs ..................................................................................................... 18

3.1 Estimated Number of Annual Export Notifications per Exporter ................................ 18

3.2 Exporter Costs............................................................................................................... 18

4 Agency Costs........................................................................................................................ 21

4.1 SNUN Processing Costs ............................................................................................... 21

4.2 Export Notification Processing Burden ........................................................................ 24

5 Additional Analyses.............................................................................................................. 25

5.1 Regulatory Flexibility Act (RFA)................................................................................. 25

5.2 Unfunded Mandates Reform Act (UMRA) .................................................................. 26

5.3 Paperwork Reduction Act (PRA).................................................................................. 26

5.4 Executive Order 12866, Regulatory Planning and Review .......................................... 26

5.5 Executive Order 13132, Federalism ............................................................................. 26

5.6 Executive Order 12898, Environmental Justice............................................................ 26

5.7 Executive Order 13045, Protection of Children ........................................................... 26

5.8 Executive Order 13175, Tribal Governments............................................................... 27

5.9 Executive Order 13211, Energy Supply, Distribution, or Use ..................................... 27

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 v January 2012

List of Tables

Table ES-1. Compliance Options and Associated Costs Incurred by a Firm due to SNUR..........iii

Table 1. Summary of Compliance Options and Associated Costs Potentially due to a SNUR...... 3

Table 2. Production and Use Restrictions/Requirements ............................................................... 4

Table 3. Annual Costs of Hazard Communication Requirements.................................................. 5

Table 5 Sample Costs of Workplace Protection ............................................................................. 8

Table 6. Annual Costs of Recordkeeping Requirements (40 CFR §721.125).............................. 10

Table 7. Sample Costs of Recommended Testing ........................................................................ 11

Table 8. Costs of Requirement to Modify/Revoke SNUR or Submit SNUN............................... 13

Table 9. Derivation of Total Mailing Cost for 12 Notices............................................................ 19

Table 10. TSCA 12(b) Export Notification Cost per Notification................................................ 20

Table 11. Agency Costs for SNUN and Other Submission Review and Processing.................... 23

Table 12: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2010$)............. 24

Table A-1 PMNs and Chemical Names Referenced in this Economic Analysis ........................... 1

Table B-1 Derivation of Loaded Wage Rates................................................................................. 4

Table B-2 Derivation of Industrial Hygienist Wage Rate (NAICS 31, 32, 33).............................. 5

Table B-3 Derivation of Inflation Factors ...................................................................................... 7

Table C-1 Annual Costs of Labeling for Distribution in Commerce [40 CFR §721.72(b)(2)]...... 3

Table C-3 Annual Costs for Material Safety Data Sheets (MSDSs) [40 CFR §721.72(c)]............ 4

Table C-4 Annual Costs for Employee Training, Per Chemical [40 CFR §721.72(d)].................. 5

Table C-5 Annual Costs for Dermal Protection Selection [40 CFR §721.63(a)(1)] ...................... 5

Table C-6 Annual Costs of Impermeability Testing [40 CFR §721.63(a)(3)] ............................... 7

Table C-7 Annual Cost of Gloves [40 CFR §721.63(a)(2)(i)]........................................................ 7

Table C-8 Annual Cost of Protective Eyewear [40 CFR §721.63(a)(2)(iii)] ................................. 8

Table C-9 Annual Cost of Protective Clothing [40 CFR §721.63(a)(2)] ....................................... 9

Table C-10 Crosswalk Between SNUR Text and Respirator Types at 40 CFR §721.63(a)(5).... 10

Table C-12 Respirator Prices and Average Costs in 1997, by NIOSH Type ............................... 14

Table C-13 Recordkeeping Estimates from Kearney 1988a and 1988b....................................... 19

Table C-14 Annual Per-Chemical Costs of Recordkeeping Requirement [40 CFR 721.125] ..... 20

Table D-1 Cost Estimates for Test Guidelines Cited in SNURs .................................................... 3

Table D-2 Default Parameters for Species, Route, and Study Type............................................ 12

Table D-3 Persistent Bioaccumulative Toxic (PBT) Tiered Testing Requirements..................... 14

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 1 January 2012

1 Introduction

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

Pollution Prevention’s (OCSPP)’s analysis of the potential costs incurred as a result of direct final 

Significant New Use Rules (SNURs) being promulgated for 17 chemical substances which have gone 

through premanufacture notice (PMN) review.1 The SNURs are being published under the rulemaking 

docket number OPPT-2011-0942. Appendix A lists the generic or specific chemical name and Chemical 

Abstract Service Registry Number (CASRN) (if non-confidential) for each PMN.

1.1 Statutory Authority and Significant New Uses under the Proposed SNURs

EPA may promulgate a SNUR for a substance when (1) the substance is the subject of a section 5(e) 

Consent Order (40 CFR §721.160), or (2) the Agency determines that activities other than those 

described in the PMN may result in significant changes in human exposure or environmental release 

levels and/or that concern exists about the substance’s health or environmental effects (40 CFR 

§721.170). In contrast to PMN requirements, which apply mainly to manufacturers and importers (TSCA 

§ 5(a)(1)(A), 40 CFR §720.22), the SNUR applies to processors as well as to manufacturers and 

importers (TSCA § 5(a)(1)(B), 40 CFR §721.5).

Each substance analyzed here was the subject of at least one premanufacture notice submitted under the 

Toxic Substances Control Act (TSCA), and is now being regulated as a result of PMN review. For the 

current rulemaking, 10 of the 17 chemicals have commenced commercial manufacture or import and so 

are listed on the TSCA Inventory; they are no longer “new” chemicals. For chemicals in this type of 

rulemaking, SNUR requirements are sometimes based on past Consent Orders entered into with a PMN 

or SNUN submitter under TSCA Section 5(e). For the current rulemaking, SNUR requirements for 2 of 

the 17 substances are based on prior Consent Orders.

EPA promulgates a SNUR to designate specific activities involving the chemical substance that EPA has 

determined constitute a “significant new use.” No person may manufacture or process a chemical substance 

for a significant new use, unless they submit a significant new use notice (SNUN) to EPA at least 90 days 

in advance. Examples of typical “significant new uses” that can trigger the requirement to submit a SNUN 

(if EPA has promulgated a SNUR applying these requirements to a specific chemical) include:

 Domestic manufacture in the United States

 Manufacture of a particular aggregate or annual volume

 Use other than that specified in the PMN

 Releases to water resulting in a surface water concentration exceeding a specified amount

 Handling the chemical without employing specified personal protective equipment (e.g., gloves, 

goggles, respirators) or hazard communication (haz-comm) measures (e.g., label, MSDS, worker 

training)

If EPA does not promulgate a SNUR for a given chemical, then these requirements would not apply 

(unless they apply to a PMN submitter via a §5(e) Consent Order). If EPA has promulgated a SNUR 

containing these types of significant new use designations, as long as the person does not engage (nor 

intend to engage) in any activities defined by the SNUR as a significant new use, then that person may 

proceed to handle the chemical without submitting a SNUN.

 

1 This report covers chemicals that went through PMN review and are part of an expedited rulemaking. The relevant 

Office of Management and Budget Information Collection Request number is ICR No. 0574 (OMB Control Number 

2070-0012). EPA also promulgates SNURs through conventional rulemaking that are covered by ICR No. 1188 

(OMB Control Number 2070-0038). 

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 2 January 2012

1.2 Summary of Methodology

This analysis quantifies, to the extent possible, the costs to society of the proposed rule by identifying the 

costs to industry associated with complying with the rule, and the costs to EPA of administering the rule. 

Types of industry costs analyzed include those for worker protection, hazard communication, testing, 

submission of required information, 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 estimates derived from previous information collection requests and economic analyses for related 

rules, compensation data acquired from government publications, and supplementary market research to 

produce an estimate of the universe of affected entities and measure the impact of the proposed rule on 

small entities.

In previous economic analyses of SNURs, EPA identified those requirements under Subparts A, B, C, and 

D of 40 CFR §721 that may indirectly impose costs on manufacturers, importers, and processors of PMN 

substances (e.g., EPA, 1989). Some of these costs, such as providing personal protective equipment under 

§721.63, were estimated in earlier SNUR economic analyses and are presented as part of this analysis. 

Resources were not available to quantify other costs, such as for limiting releases to water, avoiding uses 

not listed in the PMN, or keeping production below a specified level; they are described only 

qualitatively.

It was not feasible within available resources to aggregate costs, or to estimate how often costs are 

actually incurred as a result of SNURs, except for costs of SNUN submissions.

1.3 Organization of this Report

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

such as those included in this rulemaking. Chapter 2 presents estimates of the costs that could be incurred 

by manufacturers, importers, and/or processors under the various SNUR options. Chapter 3 addresses 

export notification costs. Chapter 4 addresses costs to EPA of administering the SNURs, while Chapter 5 

presents an analysis of other impacts, as required by various statutes and executive orders. Appendix A lists 

the chemicals that are subject to the proposed SNURs. Appendix B provides the wage rates and inflators 

used in this analysis. Other appendices give cost estimation details and references.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 3 January 2012

2 Costs of a Significant New Use Rule (SNUR), by Option

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

PMN chemical without engaging in a Significant New Use that would trigger notification to EPA. A 

SNUR also requires recordkeeping for anyone manufacturing, importing, or processing the SNUR 

chemical. A SNUR recommends testing, but does not require testing. EPA rarely receives results of tests 

performed specifically to support a SNUN. Table 1 sets forth possible responses to a SNUR. A firm may 

select more than one course of action. For example, it may produce a chemical in a way that avoids a 

Significant New Use, while simultaneously submitting a Significant New Use Notice for a proposed new 

use. These options are described below along with their costs.

Table 1. Summary of Compliance Options and Associated Costs Potentially due to a SNUR

Option1 Description of Costs

1 Manufacture, import, or process in a way that 

avoids a Significant New Use, such as limiting 

water releases, engaging in PMN uses only, 

importing only, limiting volumes, providing 

workplace protection, or providing hazard 

communications. 

All SNUR chemicals require ongoing recordkeeping. In 

addition, many SNUR chemicals may involve costs of 

complying with water release restrictions and foregoing 

non-PMN uses; these costs were not quantified for this 

report. Costs for worker protection and hazard 

communication apply to relatively few chemicals, but are 

quantified. 

2 Submit a request for modification or revocation 

of the SNUR (§721.185). 

Costs of submitting a request for modification or 

revocation, including costs of developing supporting data 

(e.g., testing, if needed).

3 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 electronically submitting a SNUN (including 

SNUN recordkeeping and user fee4) plus ongoing 

recordkeeping. Rarely, a firm may choose to conduct 

toxicity or fate testing to support the SNUN, but such 

testing is not required by law. 

4 Petition EPA for an equivalency determination to 

consider alternative controls to prevent release or 

exposure that are equivalent to those identified in 

the SNUR (§721.30).

Costs of submitting an electronic request for equivalency 

determination. 

5 Do not manufacture, import, or process the 

substance except for R&D (the R&D exemption 

is covered in 40 CFR §721.47). 

Cost of profits foregone due to delaying or avoiding 

commercial activity that would otherwise be pursued. R&D 

recordkeeping costs if manufacture for R&D.

Notes: Section numbers refer to 40 CFR §721 (in the Code of Federal Regulations). Costs come from Table 3

through Table 8. 

1

Firms may follow multiple Options simultaneously

2 Quantified costs are attributable to the SNUR Significant New Use definition only if a firm would not otherwise 

follow the specified practices. $36,283 is the annual cost for dermal protection selection; impermeability testing, 

heavy-duty gloves, and a lower-cost respirator (see Table 5). Some firms may have export notification costs (see 

Chapter 3 of this report).

3

See Appendix D for costs of individual tests recommended in current and recent SNURs.

4 EPA charges a nominal flat fee of $2,500 for a PMN or SNUN submission. 

5

SNUR chemicals not on the TSCA Inventory are “new” chemicals requiring a PMN, so some firms may need to 

make a submission before commercial production or import, even in the absence of a SNUR (see Section 2.3 of this 

report).

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 4 January 2012

2.1 Comply with SNUR Limits (Option 1)

A firm can avoid engaging in a Significant New Use and submitting a SNUN by meeting all applicable 

SNUR requirements. The firm may also pursue this option temporarily by complying with SNUR 

restrictions while also pursuing other options such as making a submission to EPA. If it does avoid 

engaging in a Significant New Use (and if the chemical is on the TSCA Inventory or if the firm has 

already submitted a PMN), no notice to EPA is required.2 Table 2 shows the types of requirements a firm 

must meet to avoid engaging in a Significant New Use. 

The Significant New Use designation in a SNUR for a specific chemical reflects either the use scenario 

described in the PMN for that chemical (what the submitter was already planning to do) or the 

requirements in the 5(e) Consent Order resulting from the PMN submission. Thus, it is likely that the 

typical PMN submitter will incur no added costs of complying with the SNUR requirements so as to 

avoid a Significant New Use. However, if there is any export of these chemicals, there will be export 

notification costs that result from the TSCA Section 12 (b) requirements that are automatically triggered 

for chemicals regulated under TSCA Section 5 (see Chapter 3 for details).

Table 2. Production and Use Restrictions/Requirements

40 CFR Reference 

(Code of Federal 

Regulations)

Restriction/Requirement

Number of 

Chemicals 

Affected1

Sample Costs Per 

Chemical

(2010$)

§721.63 Workplace protection 0

$12,061 to 

$36,2832

§721.72 Hazard communication 2 $1,056 

Industrial Commercial, and Consumer Activities (§721.80)

§721.80(a, b, c) Enclosed use only 0 Not quantified

§721.80(d, e) Use at site only 0 Not quantified

§721.80(f) Import only (do not manufacture) 1 Not quantified

§721.80(g, h, i) Use only as intermediate 1 Not quantified

§721.80(j, k) Engage only in uses listed in PMN or Consent 

Order 4 Not quantified

§721.80(l, m, n, o) Limits non-industrial uses 3 Not quantified

§721.80(p, q, s, t) Limit production volume 3 Not quantified

§721.80(r, u) Volume-triggered testing 0 Not quantified

§721.80(v, w, x, y) Restricts physical form of chemical 0 Not quantified

Disposal, water release, recordkeeping

§721.85 Disposal 2 Not quantified

§721.90 Limit releases to water 10 Not quantified

§721.1253 Recordkeeping for all manufacturers, 

importers, and processors 17 Up to $1,155

Notes: 1Some chemicals have more than one type of restriction.

2 $12,061, is the annual cost for dermal protection selection and heavy duty gloves. $36,283 is the annual cost for 

dermal protection selection; heavy duty gloves, impermeability testing/evaluation of manufacturer specifications, 

and a lower-cost respirator (see Table 5).

3 This excludes SNUN recordkeeping under §721.40. See the recordkeeping discussion in Appendix C.

Source: Costs are summarized in Table 3, Table 4, and Table 6, and derived in Appendix C.

 

2 Under the Toxic Substances Control Act § 3(9), if a chemical is not on the TSCA Inventory, it is a “new chemical.” 

Prior to manufacture or import of a new chemical for general commercial use, a notice must be filed with EPA under 

Section 5(a)(1)(A) of TSCA (40 CFR §720.3 and 40 CFR §720.22).

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 5 January 2012

The costs of meeting the haz-comm, protective equipment, and recordkeeping requirements are quantified 

for this report. Appendix C presents a more detailed derivation of these costs. The export notification 

costs are summarized in Chapter 3. Complying with requirements to avoid a Significant New Use also 

may result in additional costs that affect a significant number of the chemicals, such as costs associated 

with limiting releases to water, that were not quantified for this report; these costs are also summarized 

below.

2.1.1 Hazard Communication

Requirements. Each SNUR may require firms that manufacture, import, or process one of the PMN 

substances to implement a haz-comm program for the applicable chemical, or else submit a SNUN. For 

purposes of the economic analysis, it is assumed that each facility has in place a haz-comm program 

consistent with that required by OSHA’s Hazard Communication standard (29 CFR 1910; November 25, 

1983). Much of the haz-comm cost methodology used in this analysis came from a 1989 EPA report, 

Economic Analysis of Final Significant New Use Rules: General Provisions for New Chemical Followup 

(EPA, 1989). The cost estimates provided here are for one chemical produced at one site, assumed to have 

25 exposed workers and roughly a 10,000 kilogram annual shipment volume. Higher volumes would 

increase costs, although not necessarily proportionately. The major elements of a haz-comm program that 

could apply to a SNUR chemical, based on the requirements in §721.72, are:

 Revision of the existing written haz-comm program to incorporate information about the 

chemical [§721.72(a)];

 Creation of labels and application of labels to containers used for distributing the 

chemical in commerce [§721.72(b)];

 Creation of labels or signage and posting of hazard data in areas of the facility where the 

chemical is used or stored [§721.72(b)];

 Creation and distribution of material safety data sheets (MSDSs) [§721.72(c)]; and

 Employee awareness training on where and how the chemical is used, the hazards associated and 

availability of hazard information about the chemical, and protective equipment and other 

measures in place to reduce and minimize exposure to the chemical [§721.72(d)].

Costs. The annual costs of compliance with the haz-comm requirements for PMN substances subject to 

haz-comm requirements appear in Table 3. Further, the costs are for substances with full haz-comm 

requirements, and may overstate haz-comm costs for substances with partial requirements. 

Appendix C gives the detailed cost derivation.

Table 3. Annual Costs of Hazard Communication Requirements

Requirement Cost

(2010$)1,2 Hours

Update written program $205 4

Labeling Distribution in commerce $135 0.5

Use in the workplace $372 1.5

MSDS preparation $134 2.25

Employee training $210 6.75

TOTAL $1,056 15

Notes: 1Figures are rounded to whole dollars. Substances not subject to all of these requirements may have lower 

costs. See Table C-1 through Table C-4, and section C.1.1 for derivations.

2 Hourly labor costs are derived in Table B-1.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 6 January 2012

2.1.2 Protection in the Workplace

Requirements. Under 40 CFR §721.63, manufacturers, importers, or processors must comply with 

worker protection requirements as specified in the SNUR on the regulated chemical, or else submit a 

SNUN. The core components of the worker protection requirements include provision of personal 

protective equipment (PPE) such as gloves, goggles, protective clothing, and respirators.

In some cases, EPA specifies the type of PPE required. In other cases, EPA requires adequate dermal 

protection but does not specify particular PPE. Instead, it requires the employer to evaluate worker 

exposure conditions and hazards, and select appropriate PPE. Generally the employer is also required to 

determine that dermal PPE is impervious to the PMN substance by one or both of the following methods: 

(1) perform impermeability testing on the PPE under the expected conditions of exposure, and/or (2) rely 

on equipment manufacturers' specifications. Employers not already providing adequate dermal protection 

would need to do so.

Costs. Annual costs for worker protection items are shown in Table 4 below. The derivation of the sample 

minimum and maximum annual costs for worker protection is found in Table 5. The costs of worker 

protection were originally estimated in a 1989 EPA report, Economic Analysis of Final Significant New 

Use Rules: General Provisions for New Chemical Follow-Up (EPA, 1989), as a range of costs, depending 

on the assumed number of worker-days of exposure. This report uses the high end of the assumptions 

about worker-day exposure, updated to adjust for inflation. The estimates are for one chemical at one site 

with 25 exposed workers; actual costs would vary with the number of workers. Appendix C gives the 

detailed cost derivation.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 7 January 2012

Table 4 Annual Costs of Workplace Protection Requirement

Personal Protective Equipment and Requirement Citation at 40 CFR Unit Cost 

(2010$)1

Quantity 

Required1

Total Annual 

Cost2(2010$)

Dermal Protection Selection §721.63(a)(1)

 10 hours industrial hygienist (IH) time $51.24 10 $512

Impermeability Testing §721.63(a)(3)

 Impermeability Test $1,306 1 $1,306

 Evaluation of Manufacturer's Specifications $205 1 $205

Gloves §721.63(a)(2)(i)

 Standard (disposable) $0.58 6,250 $3,651

 Heavy-duty butyl $46.19 250 $11,548

Protective clothing §721.63(a)(2)

 [ii] - Full-body (coverall with hood) $83.15 75 $6,236

 [iv] - Coverall (no hood) $49.25 75 $3,694

Eyewear §721.63(a)(2)(iii)

 Standard goggles $5.50 75 $413

 Heavy-duty goggles $8.22 75 $616

Respirator Types3 

Supplied-air respirator operated in pressure demand or continuous flow mode 

and equipped with a tight-fitting full facepiece. [similar to §721.63(a)(5)(ii)] $1,092 25 $27,309

Supplied-air respirator operated in pressure demand or continuous flow mode 

and equipped with a hood or helmet or tight-fitting facepiece (either half- or 

full-face). [similar to §721.63(a)(5)(iii)]

$1,266 25 $31,661

Air-purifying respirator equipped with a tight-fitting full facepiece and High 

Efficiency Particulate Air (HEPA) filters.[similar to §721.63(a)(5)(iv)] $908 25 $22,711

Air-purifying, tight-fitting respirator (either half- or full-face) equipped with 

N100 (if aerosols absent), R100, or P100 filters. [similar to 

§721.63(a)(5)(iv)]

$908 25 $22,711

Powered air-purifying, tight-fitting full-face respirator equipped with N100 

(if oil aerosols absent), R100, or P100 filters. [similar to §721.63(a)(5)(v)] $3,264 25 $81,599

Powered air-purifying respirator equipped with a tight-fitting facepiece 

(either half- or full-face) and HEPA filters. [similar to §721.63(a)(5)(v)] $3,264 25 $81,599

Powered air-purifying respirator equipped with a loose-fitting hood or helmet 

and High Efficiency Particulate Air (HEPA) filters. [similar to 

§721.63(a)(5)(vi)] 

$2,540 25 $63,512

Notes:

1 Quantities assume: 1) 25 workers exposed 250 days per year; 2) standard gloves replaced daily and heavy-duty gloves 

replaced every 25 days; 3) respirator units replaced annually and cartridge sets replaced every five days (50 cartridges sets

per year); 4) goggles and protective clothing replaced three times yearly. 

2 Total annual costs were calculated using unrounded unit cost estimates, and may not equal the product of the rounded 

estimates shown in this table.

3 This table lists respirator choices that typically would satisfy SNUR requirements for a particular chemical, for current 

and recent SNURs. Future SNURs may list different choices. The citations in brackets refer to respirator types listed at 40 

CFR. While the SNURs no longer reference the §721.63(a)(5) categories, costs in this analysis are based on costs 

estimated in 1997 for the §721.63(a)(5) categories. See Table C-10 for the crosswalk between respirator types in SNURs 

and in this table. The respirator “unit cost” is per worker. Total respirator costs include costs of the respirator plus the costs 

of any add-on items such as hoods, helmets, cartridges, filters, and caps, if these items are required for a particular 

respirator. 

Source: Appendix C, Tables Table C-5 through Table C-11. 

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The costs of purchasing protective equipment are derived in Appendix C, and have been annualized 

based on the assumptions listed above regarding their use and lifetime in the workplace. Costs for 

evaluating hazards when PPE is not specified in the SNUR are based on estimates of the reasonable time 

required for a safety professional to perform such evaluations. Costs for conducting impermeability 

testing are based on consultation with PPE vendors, as described in Appendix C. Table 4 summarizes the 

annual costs associated with protection in the workplace, including the PPE itself, as well as selecting 

required dermal protection, and performing impermeability testing and/or evaluating manufacturer's 

information.

Table 5 shows a sample of the minimum and maximum annual cost of workplace protection, assuming 

25 workers who are exposed for 250 hours per year. The minimum cost includes the cost of heavy-duty 

butyl gloves, and 10 hours of an industrial hygienist’s time for dermal protection selection. The 

maximum cost is includes the cost of gloves, dermal protection, impermeability testing, and the annual 

cost of the least expensive respirator and filters for 25 workers. 

Table 5 Sample Costs of Workplace Protection 

Cost Element Annual Cost

(2010$)

Example #1: Gloves and Dermal Protection Selection

 Heavy-duty butyl Gloves $11,548 

 Dermal Protection Selection $512 

Total per site with 25 workers $12,061 

Example #2: Gloves , Testing, and Respirator

 Heavy-duty butyl Gloves $11,548 

 Dermal Protection Selection $512 

 Impermeability Test $1,306 

 Evaluation of Manufacturer's Specifications $205 

 Least Cost Respirator $22,711 

Total per site with 25 workers $36,283 

Source: Table 4

In cases where the SNUR specifies the type of protective gear, the estimates assume workers would not 

otherwise wear adequate protective equipment. To the extent that workers would otherwise be 

adequately protected (as a result of the company’s own safety program related to other chemical hazards, 

or to comply with OSHA’s PPE standards), these costs may be an overestimate of the actual costs.

In some cases, the SNUR requires dermal protection but does not specify any particular gear, allowing 

regulated companies to make that determination. Table 4 shows costs of assessing needs and 

demonstrating impermeability. These cost estimates would reflect a situation where the dermal protection 

is already in place but the manufacturer must demonstrate that it is adequate. If companies also have to 

purchase additional protective gear, incremental costs attributable to the SNUR would include the added 

items. For example, if a firm already providing gloves and goggles determined that it would have to add

protective clothing to avoid engaging in a Significant New Use, this would increase costs even if 

particular protective clothing is not specified in the SNUR.

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2.1.3 Recordkeeping

Requirements. Under 40 CFR §721.40, recordkeeping is required for SNUN submitters. This 

recordkeeping cost was included in the SNUN submission cost and is not separately estimated here.3

In addition, the SNURs specify recordkeeping requirements for manufacturers, importers, and processors, 

by identifying paragraphs selected from 40 CFR §721.125(a) through (k). These recordkeeping 

requirements apply even if the firm does not engage in a reportable New Use or make a submission to 

EPA, so long as it manufactures, imports, or processes the chemical. The recordkeeping requirements 

vary by chemical. For example, only chemicals that must establish a Hazard Communications program to 

avoid a Significant New Use would be required to keep records documenting their haz-comm program. 

(For firms producing under the R&D exemption, R&D recordkeeping would be needed. R&D 

recordkeeping costs were not estimated for this report.)

SNUR recordkeeping requirements essentially involve copying and filing relevant records, including 

those related to manufacturing, importing, or processing volumes; shipment amounts and customer 

information; clothing impermeability determinations; the hazard communication program including labels 

and MSDS copies; compliance with disposal and water discharge limitations; and/or compliance with 

restrictions on volumes, nature of manufacture or use, or on the chemical’s physical form (powder, liquid 

etc.).

Costs. Annual costs for compliance with 40 CFR §721.125 recordkeeping requirements are low, but do 

potentially apply to all SNUR chemicals, and the recordkeeping could continue for years. Costs are 

presented in Table 6 and derived in Appendix C. They are estimated for one chemical at one site, and 

include technical and clerical labor time, photocopying charges, and costs for records storage.

Table 6 summarizes recordkeeping costs by requirement at 40 CFR §721.125. The totals in Table 6

provide the cost if all recordkeeping requirements in paragraphs §721.125 (a) through (k) were required; 

this would seldom, if ever, be the case for a single chemical.

 

3

For example, OPPT’s Information Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules for 

Existing Chemicals (Renewal), October 11, 2005, estimated SNUN recordkeeping costs at 5.67 hours (EPA, 2005, 

page 12).

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Table 6. Annual Costs of Recordkeeping Requirements (40 CFR §721.125)

40CFR §721.125 Cost Element Cost (2010$)1 Hours

(a)(b)(c) Volumes & sales/transfer data $327 7.11

(d)(e) Protective clothing [§721.63] and 

impermeability [§721.63(a)(3)] $13.47 0.29

(f) Haz com program [§721.72] $168 3.67

(g) Label copies [§721.72(b)] $3.37 0.07

(h) MSDS copies [§721.72(c)] $3.37 0.07

(i) Use limitations compliance [§721.80] $168 3.67

(j) Disposal compliance [§721.80] $404 8.80

(k) Water discharge compliance [§721.90] $67.37 1.47

TOTAL $1,155 25.15

Notes:

1 Recordkeeping applies to all SNUR chemicals. This table does not cover recordkeeping for SNUN submissions. 

See Appendix C Table C-14 for derivations.

2.1.4 Hidden Costs: production volume limits, limiting releases to water, PMN uses, import-only, 

and disposal

Several types of costs that may be incurred by complying with the significant new use designations are 

not quantified in this report, including .production volume limits, releases to water, disposal, and other 

use restrictions. For example:

 Keeping production volume below specified limits to avoid a Significant New Use could result 

in a decrease in profits; a potential “hidden” cost. A firm producing for sale may have to restrict 

its sales of the chemical. If the chemical is for internal use, it may have to substitute to a less 

cost-effective chemical.

 A producer could incur costs of determining whether discharges to water would constitute a 

Significant New Use and of limiting releases in order to avoid the Significant New Use.

 Similarly, avoiding uses not listed in the original PMN could result in “hidden” costs of 

foregone profits if the firm cannot market the chemical for certain applications. If the firm 

wants to use the chemical for internal use, it may have to substitute to other chemicals or 

technologies that cost more or have lesser performance resulting in higher production costs.

 Importing could be costlier than manufacturing a PMN substance in the United 

States.

2.2 Request Modification or Revocation of a SNUR (Option 2)

Under 40 CFR §721.185, EPA may modify or revoke a SNUR upon review of a submittal from a 

manufacturer, importer, or processor. Consequently, the second option for a firm is to request 

modification or revocation of the SNUR. According to New Chemical Program records EPA receives 

few modify/revoke requests (typically up to three per year) due to SNURs. 

This option may have some or all of the following associated costs:

 One-time costs of testing to develop health and environmental effects data for a chemical subject 

to the SNUR; 

 One-time costs of submitting a request for modification or revocation;

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 11 January 2012

 Ongoing costs of complying with SNUR restrictions (Option 1 in this report) or of avoiding 

production while the modification request is being processed (Option 5). The firm may also 

incur costs of complying with any SNUR restrictions that are not ultimately revoked or may 

incur hidden costs of avoiding production altogether.

These costs are discussed below.

2.2.1 Costs of Developing and Submitting Testing Data

40 CFR §721.185(b)(1) requires that a modification request include “information sufficient to support 

the request.” For each PMN substance, the SNUR identifies health, ecological, and/or 

fate/transport/transformation testing that would help characterize the risks associated with the substance. 

However, there is no requirement for a requester to perform the recommended tests or even to perform 

testing at all. It is possible that some of the recommended tests, or other tests, would be performed by the 

submitter to support a request for modification and revocation of a SNUR. For informational purposes, 

costs for various tests recommended in SNURs over the years are listed in Appendix D. If no additional 

testing is performed to support a modification request, costs may be similar to costs of a SNUN – discussed

later in this section – minus the user fee.

Table 7 below provides an example of potential costs if a firm were to perform a standard set of 

basic ecotoxicity tests to support a request to modify or revoke a SNUR. 

Table 7. Sample Costs of Recommended Testing 

Test Guideline Test description Estimated Cost

(2010$)

Ecotoxicity Base Set

OPPTS 850.5400 Algal Toxicity, Tiers I and II $18,480 

OPPTS 850.1010 Daphnid Acute Toxicity $15,293 

OPPTS 850.1075 Fish Acute Toxicity $21,076 

Sample TOTAL Testing Cost: $54,848

Source: Costs are from Table D-1

2.2.2 Costs for Submitting a Request for Modification or Revocation of a SNUR

The costs associated with submitting a request for modification and revocation of a SNUR (or of 

submitting a SNUN) are estimated to be similar to the costs for preparing a PMN submission, except 

that there is no user fee for the modify/revoke request. The PMN submission costs came from EPA’s 

1994 Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture 

Notifications, which 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, Table III-2 and pages III-11, -12, and -13). The 1994 estimates were 

based on a survey conducted by the Chemical Manufacturers Association (CMA, 1991), which became 

the American Chemistry Council. The burden associated with PMN submission and preparation has 

been adjusted to reflect burden reductions resulting from the 2009 final PMN Electronic Reporting 

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(ePMN) Rule that requires the electronic submission of all TSCA section 5 notices.4 Electronic 

submission of SNUN forms is expected to remove all clerical burden associated with preparing a SNUN 

(EPA, 2009a, p.7). In addition, electronic submission is expected reduce all recordkeeping burden 

associated with SNUN submissions by fifty percent. Because, the recordkeeping burden for PMNs was 

not estimated separately, for the purposes of this report we assume this burden reduction is captured in 

the removal of all clerical burden.5

In the 1994 EPA report, the average effort required to prepare and submit a PMN was 95 to 114 hours. 

This burden is reduced to 83 to 100 hours after accounting for the ePMN savings (EPA, 2009a). 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, after adjusting for the ePMN savings. The method of calculating hourly 

loaded labor costs is described in Appendix B.

2.2.3 Other Costs

EPA’s review of the submitter’s request may cause delays in the start of manufacturing or processing 

activities. Such delays could cause the company to forego opportunities to earn profits for the duration of 

the review period. Alternatively, the submitter may elect to produce under the constraints of the SNUR 

during the review period, so as to avoid a Significant New Use. EPA may not revoke all SNUR 

provisions as a result of the request. If the company is allowed to continue production and chooses to do 

so, it would bear costs of complying with any SNUR restrictions that are not revoked. Costs of complying 

with SNUR restrictions pending EPA modification or revocation were discussed under Option 1.

 

4 Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: EPA Docket OPPT-2009-

0922, was the first report to consider the burden reductions resulting from electronic submission of SNUN forms 

and requests for equivalency determination. Previously, all burdens were based upon 1994 paper submission 

estimates. 

5The Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009a) 

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

estimates from the 1994 RIA, which include the burden for recordkeeping (EPA, 1994, p. III-14). These burden 

estimates are based on the recordkeeping burden for polymer exceptions and not the recordkeeping burden 

associated with PMN submissions. Therefore, for this analysis we assume that any reduction in recordkeeping 

burden is captured in the reduction of the clerical burden, and we do not consider the one hour recordkeeping burden 

from the ePMN EA to avoid double counting.

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Table 8. Costs of Requirement to Modify/Revoke SNUR or Submit SNUN 

Labor Category Hours 

Range

Average 

Hours

Loaded 

Wage 

Rate1

(2010$)

Total Labor Cost (loaded wage X hours)

Request to 

Modify 

SNUR 

(Option 2)

SNUN 

(Option 3)

Equivalency 

Determination (Option 4)

Clerical20 0 $28.98 $0 $0 $0

Technical367 - 80 73.68 $61.71 $4,547 $4,547 $4,547

Managerial316 - 20 18 $69.74 $1,255 $1,255 $1,255

Subtotal 83 - 100 91.68 -- $5,802 $5,802 $5,802

User fees (SNUN only) $0 $2,500 $0

TOTAL $5,802 $8,302 $5,802 

Test Costs Sometimes Rarely

Notes:

1 Loaded wages include fringe benefits and overhead. See Appendix B of this report for derivation. Wage rates presented in 

this table are rounded values; however, unrounded values are used to calculate total labor costs. For this reason, total 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 Hours range for each technical and managerial labor is from the PMN Amendments RIA (EPA, 1994, Table III-2)

2.2.4 Total Costs for Option 2

The total costs associated with requesting a modification or revocation of a SNUR include the costs of 

generating new supporting data plus the administrative cost of preparing the submission.

2.3 Submit SNUN (Option 3)

Under 40 CFR §721.5, manufacturers, importers, or processors who would like to undertake a Significant 

New Use of a 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, 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, since any production beyond that volume would be defined as a Significant 

New Use.

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:

 One-time costs of the SNUN and $2,500 user fee. (However, in some cases, a notification may be 

needed for reasons other than the SNUR; see Section 2.3.1 below.)

 Ongoing costs of complying with SNUR restrictions to avoid engaging in a Significant New 

Use (Option 1 in this report) or of avoiding production while the SNUN is being processed 

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(Option 5); costs of recordkeeping, and of complying with any restrictions resulting from the 

SNUN review.

 Rarely, the SNUN submitter may elect to perform some of the testing recommended in the 

SNUR as a way to characterize effects of a chemical. These tests are not mandatory, and firms 

do not usually conduct testing to support a SNUN, so any such costs are likely to be zero or 

low. 

The assumption regarding testing is based on an analysis of the 18 SNUNs submitted over a three-year 

period, from 2005 through 2007. A list of human health tests submitted to EPA with PMNs and 

SNUNs was also available from a confidential database maintained by EPA’s Office of Pollution 

Prevention and Toxics Risk Assessment Division. Only one SNUN described toxicity or environmental 

fate testing that seemed reasonably likely to have been performed to support a SNUN. In that case, two 

relatively low-cost tests (fish acute toxicity and daphnid acute toxicity) may have been conducted to 

support a SNUN, although it is also possible that the testing was done for some other reason not 

apparent in the SNUN itself. A substantial portion of the SNUNs did provide or reference test results. 

However, in almost all cases, the testing appeared to have been conducted for reasons other than a 

SNUR. For example, the SNUN might include laboratory reports that had already been submitted for a 

PMN for the same chemical.

2.3.1 SNUR “New” Chemicals

If a SNUR chemical is not on the TSCA Inventory and a potential manufacturer or importer has not 

yet filed a PMN, submission costs may be incurred but are not attributable to the SNUR.

All SNUR chemicals in this rulemaking were the subject of at least one PMN. For PMN chemicals to be 

added to the TSCA Inventory, manufacturing (or import) must have commenced, with notification to 

EPA through a Notice of Commencement, or NOC. Thus, SNUR chemicals not yet in commercial 

manufacture (or import) are not on the TSCA Inventory. They legally remain “new” chemicals subject to 

PMN requirements.

For “new” chemicals, firms who have not yet submitted a PMN must notify EPA 90 days before 

manufacturing/importing the chemical for commercial purposes. This submission is still designated a 

PMN but may contain information demonstrating the submitter intends to engage in a significant new use. 

Either way, the firm uses the same submission form and provides the data listed at 40 CFR §720.45. 

Consequently, for this special situation, the submission cost is incurred due to PMN requirements, not 

due to the SNUR. (See EPA’s 1997 Chemistry Assistance Manual for Premanufacture Notification 

Submitters for an overview of New Chemicals requirements [EPA, 1997]).

2.3.2 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 might diminish any loss of profits 

due to delay. This option is not available after the SNUR is promulgated.

2.3.3 Costs for Submitting a SNUN

As with Option 2 above (Request Modification or Revocation of a SNUR), the costs for submitting a 

SNUN are estimated to be equivalent to the costs of completing a PMN submission. If the SNUN is 

submitted at the same time as a request to modify a SNUR (Option 2), the added cost would be less than 

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shown here due to overlap in information in the two submissions. Table 8 shows the costs of preparing a 

SNUN.

2.3.4 Potential for Subsequent Regulatory Actions

The Agency recognizes that if submission of a SNUN does result from a 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 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. 

Subsequent regulatory action may be a Consent Order under TSCA Section 5(e). Assessments of costs 

and benefits for a Consent Order would be limited, similar to those supporting PMN reviews leading to 

Consent Orders, in contrast to the in-depth benefit-cost analyses prepared under some other TSCA 

Sections. 

The description above was adapted from text in Economic Analysis of the Significant New Use Rule for 

Chloranil, January 8, 2008, Section 2.4; and Economic Analysis of the Final Significant New Use Rule for 

183 Perfluoroalkyl Sulfonates, August 20, 2007, Section 3.4. Both reports are from the U.S. EPA Office 

of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. The nature of the follow-up 

regulatory action and benefit/cost analysis may differ between SNUNs for newer chemicals submitted as 

a result of a direct final rulemaking such as this one, and SNUNs for older chemicals such as chloranil 

and most perfluoroalkyl sulfonates.

2.4 Request Equivalency Determination (Option 4)

Under 40 CFR §721.30, EPA may review applications from facilities who propose alternative methods 

of controlling or preventing exposures or releases to those specified in the SNUR. In these cases, EPA 

evaluates the alternatives using an abbreviated review process. As shown in Table 8, the costs of 

submitting an equivalency determination request are expected to be the same as those for submitting a 

SNUN except that no user fee is required.

For this option the EPA review period is 45 days compared to 90 days for a SNUN, therefore any 

potential loss of profits due to delays may be less than for a SNUN under Option 3.

In addition to the costs of submitting the equivalency determination request, each submitter will also incur 

costs to develop data to support the request. However, total costs of the equivalency option should be no 

more than the costs of complying with controls in the SNUR to avoid a significant new use -- for 

example, controls related to workplace protection or environmental release. Otherwise, presumably there 

would be no incentive for the submitter to choose this alternative. Finally, to produce the chemical 

following EPA review, the submitter would incur costs from recordkeeping and from any restrictions not 

waived (see Option 1).

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2.5 Decide Not to Produce Chemical (Option 5)

Some firms may find that the costs of meeting the SNUR requirements and/or restrictions (Option 1) or 

preparing a SNUN or other submission (Options 2, 3, or 4) are financially unattractive. In these cases, the 

firm could choose not to manufacture, import, 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 SNUR 

substance, then it will forego the profit it would have achieved by producing it. That foregone profit is a 

potential “hidden” cost of Option 5. Similarly, if the firm would have used the SNUR 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.

Firms that exercise Option 5 may still incur export notification costs, if they export any existing 

stockpiles of the product. This cost is quantified in Chapter 3 below.

2.6 Summary of Costs for Each Option

Table 1, above, gave an overview of compliance options. Table 3 through Table 6 summarized the 

quantified portion of potential costs of either following restrictions to avoid engaging in a Significant 

New Use, or of making a submission to EPA. Table 7 presented sample testing costs. Costs are for one 

chemical at one site, and – where volume is relevant – are based on standard assumptions that include 25 

exposed workers per site and, for haz-comm costs, annual shipments of about 10,000 kilograms per site. 

Costs are not otherwise adjusted for the nature of the chemical or process, volume, location, or other firmspecific or chemical-specific factors.

As mentioned above, costs are estimated for one chemical at one site, not for aggregate production. 

Resources were not available to estimate aggregate costs. Among other things, it is not known how many 

firms are affected by the SNURs. EPA receives a handful of Significant New Use Notices per year due to 

SNURs. However, if a SNUR chemical is on the TSCA Inventory, a firm may use the chemical in a way 

that avoids a Significant New Use (Option 1), and never make a submission. It is not known how many 

firms are affected but do not make a submission. Also, it is not known whether firms avoid the chemical 

altogether specifically due to the SNUR. However, at least for the years immediately following SNUR 

promulgation, these numbers are likely to be small. This is because the chemicals in this type of SNUR

rulemaking are still relatively new – as Appendix A indicates, most were submitted to EPA as PMNs in the 

past four Federal fiscal years – and, in addition, often have confidential chemical identities. 

 For firms manufacturing, importing, or processing within SNUR restrictions to avoid a 

Significant New Use (Option 1), quantifiable costs can range from about one thousand dollars (if 

the only added cost is for recordkeeping) to over $35,000 per chemical if the firm must add 

worker protection measures such as gloves, protective clothing, and respirators that it would not 

otherwise use. Most chemicals are also subject to costs that could be significant but are not 

quantified in this report, such as restrictions on releases to water or on other aspects of use.

 For submissions to EPA (Options 2, 3, and 4), the basic one-time submission cost is estimated at 

$5,802, including recordkeeping for the submission. For the SNUN (Option 3), EPA also 

collects a $2,500 fee. 

 One objective of the rule is that EPA will be able to regulate prospective manufacturers, 

importers, or processors of a listed chemical substance before the described significant new use 

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of that chemical substance occurs, provided that regulation is warranted pursuant to TSCA 

sections 5(e), 5(f), 6 or 7. Consequently, after submitting a SNUN, the firm may need to comply 

with restrictions as a result of the SNUN review process, possibly leading to further costs similar 

to those in Option 1.

 Rarely, firms may choose to perform toxicity and/or environmental fate testing to support a 

SNUN (Option 3). Such testing is not mandatory. Costs for such testing are expected to be zero 

for most SNUNs and expected to be low for the few SNUNs for which a submitter might 

voluntarily perform such testing.

 Companies that might have manufactured, imported, or processed a chemical in the absence of 

the SNUR may incur “hidden” costs, such as loss of profits from delayed or foregone sales, if 

they avoid the chemical altogether (Option 5). These costs were not quantified.

 Companies may incur costs from more than one Option, for example if they temporarily produce 

in conformance with SNUR restrictions while submitting a SNUN and waiting the required 90 

days plus any extensions.

For some firms, costs may be attributable to EPA’s New Chemicals review process, but not to the SNUR 

itself. For example, a firm may already be bound by a TSCA Section 5(e) Consent Order following 

review of its PMN, so that the SNUR based on the 5(e) order imposes no added costs for that firm. As 

another example, in rulemakings where a SNUR chemical is not on the TSCA Inventory, firms that have 

not yet submitted a PMN must submit one to EPA before commercial production/import, with or without 

the SNUR (see Section 2.3, SNUR “New” Chemicals). 

If the SNUR reflects the PMN use scenario, and the PMN submitter would stick to the PMN uses even in 

the absence of a SNUR, then there would be no added costs for the PMN submitter attributable to the 

SNUR. Also, firms may also incur worker protection, haz-comm and other costs for reasons other than 

the SNUR, so that SNUR requirements may impose no added costs.6

 

6 Earlier SNUR economic analyses calculated possible haz-comm, worker protection, testing, and other costs for 

each PMN chemical (EPA, 2007b, Tables 9, 10, D-4). The chemical-specific tables were dropped from a later 

SNUR economic analysis (EPA, 2007c). They reflected SNUR requirements and “recommended” testing, but were 

not otherwise tailored to the particular situation, and so were unreliable predictors of actual SNUR costs.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 18 January 2012

3 Export Notification Costs

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

subject to various TSCA sections (40 CFR §707.60 through 75). 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 requirement7per destination country for each exporter of a chemical substance. 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 burden associated with making export notifications, 

EPA first estimated the average annual number of export notifications made by an exporter, in Section 

3.1. EPA then derived the annual and per notification burden associated with preparing and submitting 

an export notification, in Section 3.2.8

EPA estimated the average burden associated with making a single notification, but did not estimate 

either the total number of exporters of a SNUR chemical or the number of notifications per SNUR 

chemical. This is because the SNURs apply to a variety of different chemicals with a variety of 

unrelated uses, manufactures, and processors, making it impractical within the resources available for 

this report to assess the potential number of exporters and importing countries per chemical. 

Most underlying data in this section come from the 2009 TSCA Section 12(b) ICR, ICR No.: 0795.13

[Information Collection Request for] Notification of Chemical Exports - TSCA Section 12(b) Supporting 

Statement for Request for OMB Review under the Paperwork Reduction Act (EPA, 2009b), with 

updating for inflation. 

3.1 Estimated Number of Annual Export Notifications per Exporter

EPA’s 2009 TSCA Section 12(b) ICR estimated that the average exporter making notifications will make 

12 notifications per year.

9 This includes notifications resulting from SNURs and notifications resulting 

from other TSCA activities. A notification is typically no more than one page per chemical/country 

combination, and one notification mailing often includes multiple chemicals and/or destination 

countries.10

The percent of notifications due to PMN SNURs is unknown, and it is also unknown how many 

notifications may result from this rulemaking, as not all manufacturers may choose to export a chemical, 

or they may make several notifications for a single chemical.

3.2 Exporter Costs

The 2009 TSCA Section 12(b) ICR (EPA, 2009b, page 11, Table 3), estimated the annual export 

notification cost for an exporter under the one-time export notification requirement. These costs include 

 

7 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). 

8 Beginning with this report (Economic Analysis of Expedited Significant New Use Rules for 25 Chemical 

Substances: EPA Docket OPPT-2009-0922), the cost per notification is presented as well as the cost for the average 

submitter making export notifications. 

9EPA 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).

10 Based on review by an EPA economist of notifications received under TSCA Sections 4, 5 and 6 over 

approximately three weeks in early 2010.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 19 January 2012

the cost 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 outgoing shipments, 

and sending the notification letters with the associated shipping costs.

The per-notification cost was calculated based on the average burden per firm making notifications. 

Exporters making more notifications per year may benefit from economies of scale and have lower costs 

per notification; those making fewer notifications may have higher costs per notification.

3.2.1 Estimated Submission (Mailing) Costs

Regulated companies will incur mailing costs for export notifications delivered to EPA. Notifications are 

assumed shipped via the U.S. Postal Service (USPS) as first-class registered mail with a return receipt

(USPS, 2009). The estimated per-shipment and annual mailing costs incurred by individual submitters are 

detailed in Table 9.

Table 9. Derivation of Total Mailing Cost for 12 Notices

Postal Service Cost

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

× 12

Total Mailing Cost for 12 Notices $160.08

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, 2005a), as clarified in a later SNUR economic analysis (EPA, 2007c, Table 8). 

3.2.2 Compile and Maintain the List of Products

Since TSCA §12(b) information collection activity has been in place for over twenty years, most 

respondents will have already 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 proportion of legal time (EPA, 2009b). The total burden can vary from two 

hours per year up to two hours per month, depending on the number of products exported by the company 

and the number of their products subject to TSCA §12(b) (EPA, 2009b).

The number of submitters per year who report under TSCA §12(b) has varied over time, rising from 

around 160 in 1991 to over 460 in 2000, and declining since. In the most recent TSCA §12(b) ICR, EPA 

estimated there would be approximately 300 submitters per year in near-future years (EPA, 2009b). Of 

these 300 submitters, EPA estimated that 200 companies were near the lower burden estimate of 2 hours 

per year, and 100 companies were near the upper estimate of 24 hours per year. Compiling the list for all 

respondents was therefore estimated to take 2,800 hours (2 hours × 200 firms plus 24 hours × 100 firms), 

or an average of about 9.3 hours of technical time per firm per year for 12 notifications per year (EPA, 

2009b).

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 20 January 2012

3.2.3 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. Time for initial preparation of the export notice may vary 

depending on whether the company has prior experience with this requirement. This step is estimated to 

take an average of one hour of technical time (which may also include some proportion of legal time) per 

firm per year for 12 notifications per year (EPA, 2009b).

3.2.4 Check Orders and Send Notifications

Companies that export chemicals subject to TSCA §12(b) reporting must check outgoing shipments 

against the list of their products described above. A form letter notifying EPA and providing the required 

data must be printed and mailed within the required time period. This process is estimated to take an 

average one half hour of clerical time per export notification or 6 hours for 12 notifications (EPA, 2009b). 

The burdens and associated costs for each notification activity are provided in Table 10 below. 

Table 10. TSCA 12(b) Export Notification Cost per Notification

Technical Clerical Total

$/Hr Hours 2010$ $/Hr Hours 2010$ 2010$ Hours

Compile list $61.71 9.3 $574 -- -- -- $574 9.3

Write letter $61.71 1 $61.71 -- -- -- $62 1

Check order and send 

notice -- -- -- $28.98 6 $174 $174 6

Mailing cost1-- -- -- -- -- -- $160 -

Total per facility2` 10.3 $636 6 $174 $970 16.3

Total per Notification 0.86 $52.97 0.50 $14.49 $80.80 1.36

Notes:

1 Mailing costs reflect April 2010 USPS rates and can be found in Table 9.

2An average facility submitting notifications is assumed to submit 12 export notifications per year.

Source: Appendix B of this report derives technical and clerical hourly labor costs. Other costs are from 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 

2010 dollars. 

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 21 January 2012

4 Agency Costs

This SNUR is expected to generate Agency costs for both SNUN review and processing, and export 

notification processing. Because it is unknown how many SNUNs and export notifications will be 

submitted as a result of this rulemaking, all Agency costs are estimated at the per-case level and are not 

aggregated to estimate the total Agency burden. Section 4.1 describes the burden to the Agency of 

reviewing and processing a single SNUN submission. Section 4.2 derives the Agency burden of 

processing and reviewing export notifications.

4.1 SNUN Processing Costs

EPA’s costs to review and process industry submissions (SNUNs, requests to modify or revoke the 

SNUR, and requests for equivalency determinations) are assumed to be the same as EPA costs to review 

PMNs and are presented in Table 11. Costs to review and process industry submissions – SNUNs, 

requests to modify a SNUR, and requests for equivalency determination – are assumed to be similar to 

EPA costs to review PMNs.11

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

costs, and the percent of chemicals requiring a particular review step are derived from the costs for 

processing PMN submissions in Table VII-1 of a 1994 EPA report, Regulatory Impact Analysis of 

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

burden associated with processing a SNUN has been adjusted to reflect burden reductions resulting from 

the 2009 final PMN Electronic Reporting (ePMN) Rule that requires the electronic submission of all 

TSCA section 5 notices.12 The ePMN rule affects SNUN submissions and requests for equivalency 

determination, but not requests to modify or revoke a SNUR. However, for simplicity, this analysis 

continues to assume that Agency per-submission costs are the same for all three types of submissions. 

Electronic submission of SNUN forms is expected to reduce Agency burden by 16.5 percent (EPA, 

2009a, p.28).

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, 2010). 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 (EPA, 1992). The loaded salary calculations are described in Appendix B. 

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. 

 

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

Notification Submitters, EPA, 1997.

12Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: EPA Docket OPPT2009-0922, was the first report to consider the burden reductions resulting from electronic submission of SNUN 

forms and requests for equivalency determination. Previously, all burdens were based upon 1994 paper submission 

estimates. 

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 22 January 2012

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 B. 

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.

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. Weighted costs are then multiplied 

by the burden reduction of 16.5 percent to account for burden savings generated electronic submission. 

This calculation yields total Agency costs for submission review and processing shown in Table 11.

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Draft Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 23 January 2012

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

Review Steps

EPA staff (FTE) Cost Extramural Cost 2

Unweighted 

Cost

Pct. of 

Cases

Weighted 

Cost3

ePMN 

Burden 

Reduction4

Weighted Cost 

with ePMN 

Burden Reduction

FTE

fraction

Cost per 

FTE 1

FTE Total 

($2010)

1993 

dollars

2010

dollars

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

Pre-notice consultation 0.0024 $161,446 $387 $4.00 $6.78 $394 41% $162 0.165 $135

Administrative prescreen/ 

notice receipt/user fee 0.0024 $161,446 $387 $92.00 $156 $543 100% $543 0.165 $454

CRSS (Chemical Review and 

Search Strategy) 0.0025 $161,446 $404 $268 $454 $858 100% $858 0.165 $716

SAT (Structure Activity Team) 0.0006 $161,446 $96.87 $14.00 $23.72 $121 100% $121 0.165 $100.69

Engineering/Exposure 0.0015 $161,446 $242 $56.00 $94.87 $337 100% $337 0.165 $281

Exposure/Fate 0.0008 $161,446 $129 $0.00 $0.00 $129 100% $129 0.165 $108

Focus 0.0009 $161,446 $145 $23.00 $38.96 $184 100% $184 0.165 $154

Standard Review Functions 0.0219 $161,446 $3,536 $511 $866 $4,401 29% $1,276 0.165 $1,066

Division Directors Meeting 0.0129 $161,446 $2,083 $113 $191 $2,274 15% $341 0.165 $285

Order 

Development/Negotiation 

Review

0.0171 $161,446 $2,761 $22.00 $37.27 $2,798 3% $83.94 0.165 $70.09

Post Order Data Review 0.0886 $161,446 $14,304 $0.00 $0.00 $14,304 3% $429 0.165 $358

Order Modification 0.2167 $161,446 $34,985 $0.00 $0.00 $34,985 3% $1,050 0.165 $876

New Chemical SNUR 

Development 0.0277 $161,446 $4,472 $85.00 $144 $4,616 7% $323 0.165 $270

Notices of Commencement 0.0012 $161,446 $194 $40.00 $67.76 $261 31% $81.06 0.165 $67.69

FOIA (Freedom of Information 

Act) Requests 0.0333 $161,446 $5,376 $287 $486 $5,862 1% $58.62 0.165 $48.95

CBI (Confidential Business 

Information) Substantiation 0.0004 $161,446 $64.58 $3.00 $5.08 $69.66 100% $69.66 0.165 $58.17

TOTAL $6,046 0.165 $5,049 

Notes:

1 GS-13 Step 5 salaries loaded with benefits and overhead. See Table B-1 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 B. 

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

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

Sources: FTEs per review step, 1993 extramural costs, and percent of cases are from EPA, 1994 Table VII-1, GS-13 salaries are from OPM, 2010.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 24 January 2012

4.2 Export Notification Processing Burden

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

SNURs, as described in Chapter 3 above. The Agency burden and cost due to TSCA §12(b) export 

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 

staff prepares separate notification letters that are subsequently reviewed and delivered to importing 

countries, their embassies, or representatives, and to the importing country’s US embassies (EPA, 2009b). 

(See Table 9 for the cost of mailing one notification). The third task is comprised of EPA staff responses

to public inquiries and other TSCA 12(b) activities. The work of responding to non-routine requests for 

information and clarification from industry and importing countries, and of handling other tasks 

associated with the TSCA §12(b) program, was estimated to require roughly 400 hours per year (EPA, 

2009b). Since the current rulemaking covers only a very small percent of the chemicals subject to TSCA 

12(b) reporting, a very small percent of such activity will be attributable to the current rulemaking. 

Because it is unknown how many, if any, notifications EPA will receive or send as a result of the current 

rulemaking, the costs to the Agency are presented per activity.

13

 The burden for the first two Agency 

activities 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, which is derived in Appendix B. 

Table 12: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2010$)

Agency Activity

Hours per 

Activity

FTE per 

Activity1

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

0.1 0.000048 $161,446 $7.76

Prepare and mail a 

notification to an 

importing country

0.5 0.000240 $161,446 $13.34 $52.15

Notes:

1 The burden associated with an Agency activity is the burden for the Agency to process one incoming notification, or 

to prepare and mail an outgoing notification 

Source: Appendix A of this report derives Agency labor costs. Mailing costs are from Table 9 of this report. Other 

burdens are from 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), 

updated for inflation..

 

13 Beginning with the reportEconomic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: 

EPA Docket OPPT-2009-0922, the Agency cost per activity is presented, and not the entire Agency costs resulting 

from export notifications. 

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5 Additional Analyses

This chapter 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. For 

example, the number of SNUNs was four in Federal fiscal year in 2005, eight in FY2006, six in FY2007, 

eight in FY2008, seven in FY2009, and one in FY2010.

14

,

15 During this six-year period, three small 

entities submitted a SNUN.

16 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. 

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 such 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 percent of firms subject 

to SNURs would be small businesses, based on the portion of PMN submitters who were small 

businesses (EPA, 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.17 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, 2003b).

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 practices would be overly costly, the small business 

may instead forego production, thus sacrificing profits. The lost profits, if any, were not quantified for this 

report, but EPA expects them to be low. This is because SNUR chemicals are unlikely to be central to a 

 

14 FY2005 – FY2009 counts are from a February 5, 2009 email from Carol Rawie, EPA Office of Pollution Prevention and 

Toxics, to Tulika Narayan and Kimberly Wilson, Abt Associates, and counts of SNUN submissions that had been assigned an 

identifying number by EPA. The counts include both “valid” and “invalid” SNUNs. SNUN numbering is according to Federal 

fiscal year, ending September 30. 

15 FY 2010 count is from a July 20, 2011 email from Stephanie Suazo, EPA Office of Pollution Prevention and Toxics, to 

Kimberly Wilson, Abt Associates.

16 February 5, 2009 email from Carol Rawie, EPA Office of Pollution Prevention and Toxics to Tulika Narayan and Kimberly 

Wilson, Abt Associates and reviews of SNUN submissions on April 8, 2010 by Abt staff.

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

regulatory status

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 26 January 2012

firm’s business because they are relatively new and few compared to the many thousands of chemicals on 

the TSCA Inventory.

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, 2007a). This action does not impose any additional burden requiring OMB approval.

5.4 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 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.

5.5 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).

5.6 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).

5.7 Executive Order 13045, Protection of Children

Executive Order 13045, Protection of Children from Environmental Health Risks and Safety Risks (62 

FR 19885, April 27, 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 these SNURs will be less than $100 million and 

therefore no analysis of such impacts on children is required.

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5.8 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.

5.9 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.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 1 January 2012

List of PMNs and their Chemical Names

Table A-1 PMNs and Chemical Names Referenced in this Economic Analysis

No PMN1

CAS RN2Name

2

1 P09-0248 N/A Ethyleneamine polyphosphates (generic)

2 P10-0486 958238-81-8 Poly[oxy(methyl-1,2-ethanediyl)], .alpha.-sulfo-.omega.-hydroxy-, C12-

13-branched and linear alkyl ethers, sodium salts

3 P10-0487 958238-82-9 Poly[oxy(methyl-1,2-ethanediyl)],.alpha. -sulfo-.omega.-hydroxy-, C14-

15-branched and linear alkyl ethers, sodium salts

4 P11-0033 1191244-16-2 Formaldehyde, polymer with 4-(1,1-dimethylethyl)phenol, reaction 

products with 1-piperazineethanamine.

5 P11-0034 1192146-78-3

Formaldehyde, polymer with .alpha.-(2-aminomethylethyl)-.omega.-(2-

aminomethylethoxy)poly[oxy(methyl-1,2-ethanediyl)] and 4-(1,1-

dimethylethyl)phenol.

6 P11-0188 N/A Infused carbon nanostructures (generic)

7 P11-0316 1014979-92-0 Cyclohexane, oxidized, by-products from, distn. residues

8 P11-0333 N/A Hexanedioic acid polymer with aliphatic polyol dihydrogen phosphate 

aromatic ester (generic)

9 P11-0424 N/A Alkenoyloxy arylphenone (generic)

10 P11-0511 N/A C15 olefins (generic)

11 P11-0546 16923-87-8 Silicate (2-) hexafluoro-, cesium (1:2)

12 P11-0578 43100-38-5 Benzoic acid, 4-(1-1-dimethylethyl)-, hydrazide

13 P11-0580 163119-16-2 Cyclohexanol, 2,6-bis(1,1-dimethylethyl)-4-methyl14 P11-0591 N/A IPDI modified isophthalic acid, neopentyl glycol and adipic acid (generic)

15 P11-0608 1313999-39-1 1,3-Benzenediol, 4-[1-[[3-(1H-imidazol-1-yl)propyl]imino]ethyl]-

16 P11-0637 1315588-63-6 Tin, C16-18 and C18-unsatd. fatty acids castor-oil fatty acids complexes

17 P11-0662 N/A MDI terminated polyester polyurethane polymer (generic)

Key: PMN = Premanufacture Notice. CAS RN = Chemical Abstract Service Registry Number.

Notes: 

1The PMN number reflects the Federal Fiscal Year and sequence of submission. For example, those starting “P-07” were 

submitted in the twelve months ending September 31, 2007. 

2

If a CAS RN is identified as “N/A” meaning “Not available” and/or the chemical name is indicated to be “generic” then the 

chemical identity is indicated to be confidential. 

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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. Costs for this report are for year-end 2010.

Derivation of Loaded Wage Rates

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

fully loaded labor cost. The basic method is described in Wage Rates for Economic Analysis of the 

Toxics Release Inventory Program (EPA, 2002b). The resulting loaded labor rates are given in Table 

B-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.

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

Managerial Executive, administrative, and

managerial

Management, business, and

financial

Professional/Technical Professional specialty and technical Professional and related

Clerical Administrative support, including

clerical Office and administrative support

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

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

2.0.1 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,18 for December, for manufacturing industries.19

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 

 

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

Chemical Substances: EPA Docket OPPT-2003-0063 (EPA, 2007b). In earlier PMN SNUR economic analyses, such 

as EPA, 2003a, 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, as in 

EPA, 2007b, 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.

19 Employer Costs for Employee Compensation Supplementary Tables December 2010. (BLS, 2011a). This follows 

the approach introduced in EPA, 2007b. Earlier PMN SNUR economic analyses, such as EPA, 2003a, used ECEC 

data for “All Goods Producing” sectors (manufacturing, mining, and construction). However, the manufacturing 

sector data seem more relevant since the SNURs mainly affect the chemicals industry.

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Draft Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 B-2 January 2012

labor category. For example, for December 2010, the average wage rate for professional/technical20

labor was $36.93; the average fringe benefit was $18.50. Fringe benefits as a percent of wages were 

$18.50/$36.93, or approximately 50.09%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 (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 2010 fully loaded wage for 

professional/technical labor is $36.93× (1+0.5009 + 0.17) = $61.71.

Fully loaded costs for managerial, clerical, and production labor are calculated in a similar manner, 

as shown in Table B-1.

2.0.2 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.21

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 American Industry Classification System 

(NAICS) codes for Manufacturing are 31, 32, and 33 (BLS, 2005). The calculations are shown in Table 

B-2.

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

Employee Compensation Supplementary Tables December 2010 (BLS, 2011a). 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. 

Calculations are shown in Table B-1.

 

20 This follows terminology introduced in EPA, 2007b. Earlier SNUR economic analyses 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).

21 This follows the approach for calculating Industry Hygienist wages introduced in EPA, 2007b and is a change 

from the method used in earlier PMN SNUR economic reports such as EPA, 2003a, which used data from a 1997 

professional journal salary survey.

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Draft Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 B-3 January 2012

2.0.3 Derivation of Labor Rates for EPA Staff

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

published by the Office of Personnel Management effective January 2010 (OPM, 2010). The average 

salary for one Full Time Equivalent (FTE) staff is estimated as the salary for a GS-13 Step 5 employee.22

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$161,446.

The Agency loading factor is from an EPA guide, Instructions for Preparing Information Collection 

Requests (ICRs) (EPA, 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 (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.” (EPA, 2000)

 

22 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007) (EPA, 2007a), 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, 2003a), which used an average of GS-12 Step 1 and GS-12 Step 10 salaries.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 B-4 January 2012

Table B-1 Derivation of Loaded Wage Rates

EPAB Labor 

Category Data Sources Date Wage Fringe 

Benefit

Fringes as 

% wage

Overhead % 

wage2

Fringe + 

overhead 

factor

Loaded 

Wages1

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

Managerial

BLS ECEC, Private Manufacturing 

industries, “Mgt, Business, and 

Financial”3

Dec-10 $42.82 $19.64 45.87% 17% 1.63 $69.74

Professional/

Technical

BLS ECEC, Private Manufacturing 

industries, “Professional and 

related“3

Dec-10 $36.93 $18.50 50.09% 17% 1.67 $61.71

Clerical

BLS ECEC, Private Manufacturing 

industries, “Office and 

Administrative Support” 3

Dec-10 $17.36 $8.67 49.94% 17% 1.67 $28.98

Production 

Worker

BLS ECEC, Private Manufacturing 

industries, “Production, transport, 

and material moving.” 3

Dec-10 $16.72 $9.05 54.13% 17% 1.71 $28.61

Industrial 

Hygienist

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. 4

Fringes: BLS ECEC, Private 

Manufacturing industries, 

“Professional and related” 3

Wage: 

May-10

Fringe: 

Dec-10

$30.67 -- 50.09% 17% 1.67 $51.24

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. 5

Dec-10 $100,904 

(annual) --

[Included 

in 60% 

overhead]

60% 1.6 $161,446

(annual)

Notes:

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

2 An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b), and the Revised 

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

3 Employer Costs for Employee Compensation Supplementary Tables December 2010, US Bureau of Labor Statistics, March 9, 2011 (BLS, 2011a).

4 Employment and unweighted wages are from BLS Occupational Employment Statistics (National Industry-Specific Employment and Wage Estimates), May 2010.

5 The salary is unloaded Federal GS-13 Step 5 salary for calendar 2010, from the Office of Personnel Management salary table for Washington-Baltimore-Northern Virginia 

(OPM, 2010). The 60% fringes-and-overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (EPA, 1992, page 30, footnote 9).

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 B-5 January 2012

Table B-2 Derivation of Industrial Hygienist Wage Rate (NAICS 31, 32, 33)

Occupation Title (SOC code)

Employment Mean hourly wage Weight

Weighted 

Wage1

(a) (b) (c) (d)=(c) × (b)

Occupational Health & Safety Specialists 

(29-9011) 8,520 $31.91 0.861 $27.49

Occupational Health & Safety 

Technicians (29-9012) 1,370 $22.94 0.139 $3.18

Industrial Hygienist (weighted average) 9,890 -- 1 $30.67

Notes:

1 Wage data are rounded to the closest pennies in this table; however, in calculations using these numbers for this 

report, unrounded values were used.

Source: Employment and unweighted wages are for manufacturing (NAICS 31, 32, 33) from BLS Occupational 

Employment Statistics (Occupational Employment and Wages), for May 2010 (BLS, 2011). 

Derivation of Inflation Factors

Costs of equipment and supplies were inflated 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 category23. 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 B-3 below.

In 2006, the Bureau of Labor Statistics (BLS) made several changes to the Employment Cost 

Index. The changes are described on a BLS web page, “Change has come to the ECI,” (BLS, 

2006c) and 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 conversion 

to NAICS and SOC” (Branch, 2006).

Under a mandate from OMB, BLS changed its classification of industries and occupations from the 

Standard Industrial Classification (SIC) and Occupational Classification System (OCS) to the North 

American Industry Classification System (NAICS) and Standard Occupational Classification (SOC) 

system. In 2006, BLS adjusted all ECI series to reflect this change. 

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

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

series, including the NAICS and SIC based series. (Seasonally adjusted indices, including those in Table 

 

23 Prior SNUR economic analyses used the seasonally adjusted ECI for the total compensation, private industry 

white collar workers (Series ID CIS2010000W00000I) to inflate export notification and Agency extramural cost. 

However, in 2008 BLS retired both the “white-collar” and “blue-collar” series (BLS, 2008, p. BLS-45). Therefore,

beginning with the report, Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: 

EPA Docket OPPT-2009-0922, the “white-collar” series was replaced with the not seasonally adjusted ECI for total 

compensation of private industry professional and related workers (Series ID CIU2010000120000I). The 

“professional and related workers” series was chosen because it is the only series with continuous data since 1985,

and the majority of export notification and Agency extramural activities are performed by professional and technical 

labor.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 B-6 January 2012

B-3 of this report, may not exactly equal 100 for December 2005 as a result of the seasonal adjustment. 

Seasonal adjustments are explained in Branch, 2006.) 

According to BLS, the official ECI for the years 1975-2005 is the SIC-OCS based series, and for 

subsequent years, the official ECI is the NAICS-SOC based series (Sleemi, 2006, p.8).24 

“Starting year” indices in Table B-3 continue to be SIC-SOC based. Current year indices are NAICS-SOC 

based. We use indices from both the NAICS-SOC and the SIC-OCS based ECI series because neither 

series spans the entire period over which testing and other costs need to be inflated. 

 

24 BLS has been publishing the NAICS-SOC based ECI series since March 2001 and it became official in March 2006. The SICOCS based series and NAICS-SOC series have different series ID numbers, even when they describe essentially the same 

population. For example the series ID for seasonally adjusted total compensation for all private industry workers is ECS10002I 

for the SIC-OCS series and CIS2010000000000I for the NAICS-SOC series. 

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 B-7 January 2012

Table B-3 Derivation of Inflation Factors

Item Inflation index source1 Starting 

year

Index for 

starting 

year

(a)

Index 

for 

2010

(b)

Inflation 

factor

(b)/(a) 2

Chemical testing (toxicity, 

ecological effects etc.)

BLS ECI, SA, Total comp, Private 

industry, All Workers, 4th Q [BLS 

2006d and 2010c]

varies varies 112.7 varies

White collar/other labor mix; 

equipment; supplies. 

Example for test costed in 1993 1993 66.5 112.7 1.695

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 83.8 112.7 1.345

Impermeability testing of 

gloves and other gear3

BLS ECI, SA, Total comp, Private 

industry, All Workers, 4th Q [BLS 

2006d and 2010c]

1997 74.9 112.7 1.505

Export notification

BLS ECI, ,Total comp, Private 

industry, Professional and related, 4th

Q [BLS 2010d] 4

1992 64.9 113.5 1.749

Agency Extramural costs 

White collar labor; 

equipment; supplies

BLS ECI, Total comp, Private industry, 

Professional and related, 4th Q [BLS 

2010d] 4

1993 67.0 113.5 1.694

Labels, placards, gloves, 

eyewear, clothing, 

respirators, file cabinet

BLS CPI, All urban consumers, not 

SA. CUUR0000SA0, Annual [BLS 

2010b]

1997 160.5 218.056 1.359

Photocopies

Record keeping materials

BLS CPI, All urban consumers, not 

SA. CUUR0000SA0, Annual [BLS 

2010b]

1988 118.3 218.056 1.843

Notes:

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

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

Release Text: Employment Cost Index, March 2006 (BLS, 2006b). The Consumer Price Index (CPI) was not rebased. 

“Starting year” ECI indices are SIC-OCS based: Seasonally Adjusted (SA) ECS10002I for private industry All Workers, and not SA 

ECU11122I for private industry Professional and Related Workers. 

After 2006, ECI indices are NAICS-SOC based: Seasonally Adjusted (SA) CIS2010000000000I for private industry All Workers, 

and not SA CIU2010000120000I (B) for private industry Professional, and Related workers. 

.

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

values were published with one decimal place through 2006 and with three decimal places after that.

3 We began using the ECI for Private Industry All Workers in EPA, 2007b, to better reflect the labor mix for impermeability testing. 

Earlier PMN SNUR economic analyses used the ECI for Private Industry White Collar Workers.

4 Beginning with the report ,Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: EPA Docket 

OPPT-2009-0922, we began to use the not-seasonally adjusted CIU2010000120000I for private industry Professional, and Related 

workers, instead of SA CIS2010000W00000I for private industry white collar workers because BLS retired the “white-collar” series. 

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-1 January 2012

Costs of Hazard Communication, Protection in the Workplace, 

and Recordkeeping Requirements

Section 2.1 of the main text of this report discusses costs of worker protection, hazard communication 

(haz-comm), and recordkeeping for SNURs. This appendix presents dollar costs and labor hours of these 

requirements, for one chemical at one site. Some requirements listed here may not be cited in the current 

rulemaking, but have been cited in past SNUR rulemakings.

The haz-comm costs reflect the annual costs of updating the written program, labeling for chemical 

distribution and storage, creating and distributing material safety data sheets (MSDS), and employee 

training. The personal protective equipment (PPE) costs reflect the annualized costs of providing required 

equipment (i.e., gloves, goggles, clothing, or respirators), assessing dermal protection needs associated 

with the chemical, and performing required impermeability testing, and/or evaluating manufacturer’s 

information. Finally, the annual recordkeeping costs include labor, photocopying, and record storage 

costs.

To estimate the costs of haz-comm, worker protection, and recordkeeping requirements, a number of 

assumptions were made, based on the original EPA analysis for generic SNUR provisions, Economic 

Analysis of Final Significant New Use Rule: General Provisions for New Chemical Followup (EPA, 

1989). In that report, EPA estimated that the number of workers exposed to any one substance would 

range from 10 to 25, and that a worker potentially would be exposed to a substance for a minimum of 50 

days per year to a maximum of 250 days per year. The current analysis uses the high ends of those two 

ranges. Thus, each site is assumed to have 25 chemically-exposed workers requiring training and/or 

protective equipment, with each of them assumed to be exposed for 250 days per year.

Labor costs are derived from the United States Bureau of Labor Statistics sources as described in 

Appendix B. Material costs were primarily obtained from a national safety equipment supply house 

catalog (LSS, 1997) and are inflated as described in Appendix B.

Costs of haz-comm, workplace protection, and recordkeeping are discussed in Sections C.1, C.2, and C.3, 

respectively. Table 4 and Table 6 in the main text summarize these costs by SNUR requirement.

Modifying the Hazard Communication Program

As mentioned in Section 2.1, it is assumed that each facility has in place a haz-comm program consistent 

with that required by OSHA’s Hazard Communication standard (29 CFR 1910; November 25, 1983), so 

that costs attributable to the SNUR are costs of adding one chemical to the program. Much of the hazcomm methodology and assumptions came from the EPA report, Economic Analysis of Final Significant 

New Use Rules: General Provisions for New Chemical Followup (EPA, 1989), which in turn relied partly 

on the 1983 OSHA study, Final Regulatory Impact and Regulatory Flexibility Analyses of the Hazard 

Communication Standard OSHA, 1983).

It was assumed that the haz-comm costs would be incurred each year. For example, there would be 

worker turnover and need for refresher training, the MSDS would need revision due to changing 

information, placards would wear out (EPA, 1989). To the extent that some steps would not need 

repeating each year, costs could be lower than estimated here. The hazard communication costs 

summarized in Table 3 above are detailed here.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-2 January 2012

3.0.1 Updating the Written Program

If the SNUR cites 40 CFR §721.72(a), then to avoid engaging in a Significant New Use, which would 

trigger other SNUR requirements, manufacturers must update their written haz-comm program to 

incorporate information about the chemical. The written part of the program includes data and 

information about hazardous chemicals present in the workplace, the hazards associated with such 

chemicals, procedures for employees who routinely work with or around such chemicals, procedures for 

non-routine tasks that may involve exposure (e.g., tank cleaning), and personal protective equipment 

requirements when working with or around such chemicals.

While material safety data sheets may provide much of the information needed to update the written hazcomm program, many employers may perform a more detailed assessment of exposure risks associated 

with the chemical and develop more site-specific procedures for workers potentially exposed to such 

chemicals. For purposes of the economic analysis, EPA assumes that each employer will engage the 

services of a professional industrial hygienist (IH), either in-house or on a consulting basis, for four hours 

to perform such an assessment. Loaded hourly rates for IH services were calculated based on Bureau of 

Labor Statistics data, as described in tables B-1 and B-2. Costs for the written haz-comm program, in 

2010 dollars, are as follows25

4 hours Industrial Hygienist time × $51.24 per hour = $205

The estimates of IH hours to update the program come from a 1998 EPA report (EPA, 1998).

3.0.2 Labeling

If the SNUR cites 40 CFR §721.72(b), then to avoid engaging in a Significant New Use, manufacturers 

must ensure that containers used to distribute the PMN substance in commerce are labeled with the 

necessary hazardous substance warnings and procedures. In addition, containers used in the workplace 

must bear similar labels or, alternatively, the employer must provide equivalent signage, operating 

procedures, or other written material to communicate hazard information to workers. The cost of 

providing such labeling was estimated in a 1989 EPA report (EPA, 1989) and has been updated here 

using more recent cost information.

Standard formats are assumed to be used for creating labels or other signage, and the information 

required for the labels is assumed to be already available from the MSDS for the chemical (see below).

Chemicals Distributed in Commerce. For chemicals distributed in commerce, the labeling process is 

assumed to require 0.5 hours of technical labor time per chemical to compile label information. It is 

assumed to require 480 labels per chemical. The assumption of 480 labels per chemical is from a 1989 

EPA report (EPA, 1989), and is based on the assumption that, on average, each chemical is shipped twice 

monthly to 20 customers. This is consistent with roughly 10,000 kilograms of chemical per year shipped 

in 40 five-gallon containers per month (EPA, 1989).26

 

25 Figures presented here are rounded.

26 Data on PMN notices suggest that some PMN submitters expected to produce less than 10,000 kilograms per year of the 

SNUR chemicals, but many expected to produce much more. It is not known whether volumes listed in the PMNs were 

realized in practice. Production volumes of secondary suppliers affected by the SNUR are also unknown. Annual volumes 

significantly greater than 10,000 kg could lead to higher haz-comm costs than those estimated here.

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Technical labor is fully loaded with fringe benefits and overhead, as described in Appendix B. Labeling 

materials costs were obtained from a national safety equipment supply house catalog (LSS, 1997) and 

were inflated as described in Appendix B. The resulting costs of labeling for chemicals distributed in 

commerce, per chemical substance at one site, are shown in Table C-1.

Table C-1 Annual Costs of Labeling for Distribution in Commerce [40 CFR §721.72(b)(2)] 

Cost Element Unit Cost

(1997 Dollars) Inflation Factor Unit Cost(2010 Dollars)

Hours Total 

Cost

0.5 hours technical time -- -- $61.71 per hour 0.5 $31 

480 labels $0.16 per label 1.359 $0.22 per label -- $104 

TOTAL 0.5 $135 

Note: 

Total costs were calculated using unrounded unit cost values and inflation factors (see Appendix B), so results may 

differ from calculations using the rounded values shown in this table.

Source: 1997 label cost, EPAB 1998, LSS 1997; cost elements, quantities, RIB 1989; inflators, labor, Table B-1 and 

Table B-3.

Chemicals Used in the Workplace. Workplace labeling requirements are costed by assuming the facility 

purchases six large (14" × 10") signs, priced at $38.30 each in 1997 dollars (LSS, 1997; EPA, 1998). Costs 

of these signs were inflated as described in Appendix B. These signs will be mounted in areas where the 

chemicals are used or formulated. For example, a placard might be posted at each of six vessels: a mixing 

tank, a reactor, two separators, and two storage vessels (EPA, 1989). The labeling process is also assumed 

to require 0.5 hours of technical time to compile label information and 10 minutes of production worker 

time to post each placard. Technical labor costs include wages, fringe benefits, and overhead, as described 

in Appendix B.

The resulting per chemical, per site costs of labeling for chemicals in the workplace are shown in Table 

C-2.

Table C-2 Annual Costs of Labeling for Use in Workplace [40 CFR §721.72(b)(1)]

Cost Element Unit Cost 

(1997 Dollars)

Inflation 

Factor

Unit Cost 

(2010 Dollars) Hours Total Cost

0.5 hours technical time -- -- $61.71 per hour 0.5 $30.85 

6 labels or placards (14" x 

10") $38.30 per item 1.359 $52.03 per item -- $312

10 minutes per label/placard 

production worker time -- -- $28.61 per hour 1.0 $28.61

TOTAL 1.5 $372 

Note:

Total costs were calculated using unrounded unit cost values and inflation factors (see Appendix B), so results may 

differ from calculations using the rounded values shown in this table.

Source: 1997 placard cost, EPA, 1998, LSS, 1997; cost elements and quantities, EPA, 1989; inflators and labor unit 

costs, Table B-1 and Table B-3. 

3.0.3 Preparing Material Safety Data Sheet (MSDS) Information

If the SNUR cites 40 CFR §721.72(c), then to avoid engaging in a Significant New Use, each facility is 

required to create, post, and distribute material safety data sheets (MSDSs). Based on estimates in OSHA 

 

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-4 January 2012

1983, the 1989 EPA report (EPA, 1989) has estimated that creation of an MSDS for a chemical substance 

requires 2.0 hours of technical labor time and 0.25 hours of clerical time. Further, EPA assumes that the 

manufacturer provides 20 copies of the MSDS to customers and retains 20 copies for use onsite, for a 

total of 40 copies (EPA, 1989). The loaded hourly wage rates and the inflator used in estimating unit 

photocopy costs are derived in Appendix B. The resulting cost of MSDS preparation is shown in Table C3.

Table C-3 Annual Costs for Material Safety Data Sheets (MSDSs) [40 CFR §721.72(c)]

Cost Element Unit Cost 

(1988 Dollars)

Inflation 

Factor

Unit Cost 

(2010 Dollars) Hours Total Cost

2.0 hours technical 

time -- -- $61.71 per hour 2 $123

0.25 hours clerical 

time -- -- $28.98 per hour 0.25 $7.25

40 copies $0.05 1.843 $0.09 per copy -- $3.69

TOTAL 2.25 $134 

Note: 

Total costs were calculated using unrounded unit cost values and inflation factors (see Appendix B), so results may 

differ from calculations using the rounded values shown in this table.

Source: Cost elements, quantities, and 1988 copy cost, RIB 1989; inflators and labor unit costs, Table B-1 and 

Table B-3

Employee Training

The final required component of the haz-comm program is employee training, based on 40 CFR 

§721.72(d). The 1989 EPA report, Economic Analysis of Final Significant New Use Rules: General 

Provisions for New Chemical Follow-up (EPA, 1989), assumes that a training program currently is in 

place, but the existing program must be modified to add new information pertaining to the PMN 

substance. Subsequently, the training program must be expanded to include such material each time the 

training course is presented. Costs of modifying the program and presenting the modified program are 

mainly labor costs for the trainer and the trainees.

Inserting the new information about the PMN substance into the training program and conducting the 

revised training is assumed to require 0.5 hours of the trainer’s time. An additional 0.25 hours per 

trainee is estimated to be required, and an average of 25 affected workers is assumed per facility 

(EPA, 1989). If additional production workers needed to be trained, for example because they might 

come into contact with the chemical due to spills or leaks, training costs could be higher than 

estimated here (EPA, 1989).

Labor rates for training are based on the loaded rates derived in Appendix B for chemical technicians and 

chemical industry production workers. The total cost of the employee training requirement is shown in 

Table C-4.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-5 January 2012

Table C-4 Annual Costs for Employee Training, Per Chemical [40 CFR §721.72(d)]

Cost Element Unit Cost 

(2010 Dollars)

Hours Total Cost

0.5 hours technical time (trainer) $61.71 per hour 0.5 $30.85

0.25 hours per production employee X average of 

25 workers per plant = 6.25 hours $28.61 per hour 6.25 $179

TOTAL 6.75 $210

Note: 

Total costs were calculated using unrounded values from (see Appendix B), so results may differ from calculations 

using the rounded values shown in this table.

Source: Cost elements and quantities, EPA, 1989; labor unit costs, Table B-1.

Protection in the Workplace

The following section estimates costs of assessing needs for dermal protection and evaluating protective 

gear for impermeability, as well as the costs of gloves, goggles, protective clothing, and respirators.

3.2.1 Dermal Protection Selection

If the SNUR cites 40 CFR §721.63(a)(1), then to avoid engaging in a Significant New Use, the 

employer must ensure that each person who is likely to experience dermal exposure to a PMN chemical, 

must be provided with and is required to wear personal protective equipment (e.g., gloves) that will 

prevent dermal exposure to the substance. The equipment must be selected and used in accordance with 

29 CFR § § 1910.132 and 1910.133 (promulgated by the Occupational Safety and Health 

Administration, OSHA). The selection and administration of this dermal protection is estimated to 

require 10 hours labor by an industrial hygienist, annually (EPA, 1999). The wage rate of the hygienist 

was calculated as described in Appendix B. The cost calculations for the dermal protection selection 

requirement are given in Table C-5. This covers only costs of selecting the dermal protection needed, 

not costs of the items themselves. For costs of purchasing dermal protective items, see the sections 

below on costs of gloves, eyewear, and clothing.

Table C-5 Annual Costs for Dermal Protection Selection [40 CFR §721.63(a)(1)]

Cost Element Unit Cost

(2010 Dollars) Hours Total Cost1

10 hours industrial hygienist (IH) time $51.24 per hour 10 $512 

Notes:

Total costs were calculated using unrounded values (see Appendix B), so results may differ from calculations using 

the rounded values shown in this table.

Source: Labor rates, Table B-1; cost elements and quantities, EPA, 1999.

3.2.2 Impermeability Testing

As part of the workplace protection requirements specified under 40 CFR §721.63(a)(3), to avoid 

engaging in a Significant New Use, the SNUR may require that employers demonstrate that each item of 

protective equipment provided (e.g., gloves) provides an impervious barrier, to protect employees from 

dermal exposure. Requirements outlined in §721.63(a)(3) are provided in two parts, §721 .63(a)(3)(i) and 

(ii). The employer may use a combination of (i) testing and/or (ii) evaluating manufacturer specifications. 

The following discussion is based on the Economic Analysis of Expedited Significant New Use Rules for 

168 Chemical Substances and Background Support Document for Economic Analysis of Significant New 

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-6 January 2012

Use Rules (EPA, 1998) and assumes that the manufacturer uses both testing and evaluation of 

manufacturer specifications. The analysis assumes that costs are incurred annually.

The first step, described at 40 CFR §721.63(a)(3)(i), is to perform actual impermeability testing. To 

determine the costs of impermeability testing compliance, Best Manufacturing Company, a leading 

manufacturer and tester of chemical resistant articles, was consulted (Best, 1997).

As described in EPA, 1998, Best used one of two methodologies for impermeability testing. In the first 

method, chemical samples were submitted to Best with a specific article to be tested for impermeability. 

This method was cheaper, costing $200 (1997 dollars) per chemical, but the burden of finding an 

appropriate article of protection lay with the chemical manufacturer. In the second method, the chemical 

manufacturer simply submitted chemical samples to Best, who in turn determined the most appropriate 

product, even if a competitor manufactured the product. This method was more costly at $800 (1997 

dollars) per chemical.

The second method of impermeability testing is favored in this analysis for several reasons. First, the 

burden of finding and submitting an article of protection is shifted from the chemical manufacturer to the 

testing company, who would have greater experience in Personal Protective Equipment (PPE) selection. 

Second, should the article submitted fail the impermeability test, other articles may have to be submitted 

until satisfactory test results are obtained. Furthermore, substances subject to SNURs may include new 

and/or rare chemicals, which may have undiscovered or unknown properties. This uncertainty may 

impede chemical manufacturers’ ability to effectively submit appropriate PPE articles for testing. Finally, 

the first method is essentially a pass-fail test. If an article passes the impermeability test, then it is 

acceptable. In the second method, several articles may be tested and compared, and, while one or more 

acceptable articles may result, the most impermeable article is always determined for the chemical. To 

obtain the best article rather than merely a satisfactory article of protection, the second method of testing 

is more appropriate. For these reasons, unit costs of $800 per chemical (1997 dollars) are assumed for 

impermeability testing. The cost of the impermeability testing is assumed to be driven by labor costs of 

the company performing the testing, thus test costs were inflated with an Employment Cost Index as 

described in Appendix B. The administration of this test would also require two hours of industrial 

hygienist labor (EPA, 1999).

The second step to compliance with the workplace protection requirements at §721.63 (a)(3)(ii) is 

the evaluation of specifications from the manufacturer or supplier of the protective equipment. This 

requirement helps ensure that the protective equipment will be impervious to the PMN chemical(s). 

The evaluation of manufacturer specifications requires an estimated four hours of industrial hygienist 

labor.

Annual costs of the impermeability testing requirements are presented in Table C-6.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-7 January 2012

Table C-6 Annual Costs of Impermeability Testing [40 CFR §721.63(a)(3)]

Cost Element Unit Cost 

(1997$)

Inflation 

Factor

Unit Cost

(2010$) Hours Total Cost1

Impermeability Testing [§721.63(a)(3)(i)]

 Impermeability Test $800 per chemical 1.505 $1,204 per chemical $1,204

 Industrial Hygienist time $51.24 per hour 2 $102.49

Subtotal 2 $1,306

Evaluation of Manufacturer’s Specifications [§721.63(a)(3)(ii)] 

 Industrial Hygienist time $51.24 per hour 4 $205

Subtotal 4 $205

TOTAL 6 $1,511

Notes:

1 Total costs were calculated using unrounded unit cost values and inflation factors (see Appendix B), so results may 

differ from calculations using the rounded values shown in this table.

Source: 1997 costs, Best, 1997; cost elements and quantities, EPA, 1998 and EPA, 1999; inflators and labor rates, 

Table B-1 through Table B-3.

3.2.3 Gloves

If the SNUR cites 40 CFR §721.63(a)(2)(i), then gloves must be worn to avoid engaging in a Significant 

New Use. Gloves may also be acquired as a result of the dermal protection selection at §721.63 (a)( 1). 

If standard, disposable medical-grade gloves are used, they are assumed to be worn and discarded by the 

worker following each day of exposure. Each site is assumed to have 25 workers, each of them exposed 

250 days per year. This reflects the high-side assumptions in EPA, 1989 (page 25) for the number of 

workers and exposure days. Each pair was estimated to cost $0.43 in 1997 (LSS, 1997); the cost has 

been inflated as described in Appendix B. Total annual costs of providing disposable gloves are 

developed by applying the assumptions above regarding the number of workers exposed (25 per site) 

and frequency of replacement (one pair per worker per day of exposure H 250 days of exposure per 

year). For some chemicals, heavy-duty gloves may be used. They are generally not disposed of daily, 

but are more expensive. The estimated costs of gloves purchased in compliance with SNUR Personal

Protective Equipment requirements are presented below in Table C-7. The cost estimates for each 

chemical assume that the more expensive heavy-duty gloves are used in cases where the SNUR 

explicitly requires gloves.

Table C-7 Annual Cost of Gloves [40 CFR §721.63(a)(2)(i)]

Cost Element

Unit Cost 

($1997 per 

pair)

Inflation 

Factor

Unit Cost 

($2010 per pair)

Number 

of Pairs 

Required1

Total Cost 

($2010)

2

Disposable nitrile gloves 

(replaced daily) $0.43 1.359 $0.58 6,250 $3,651

Heavy duty butyl gloves 

(replaced every 25 work days) $34.00 1.359 $46.19 250 $11,548

Notes:

1 The analysis assumes that 25 workers who are exposed 250 days/year replace disposable gloves daily and replace 

heavy duty gloves every 25 work days.

2 Total costs were calculated using unrounded unit cost values and inflation factors (Table B-3), so results may differ 

from calculations using the rounded values shown in this table.

Source: 1997 item costs, LSS, 1997; item type and quantity, EPA, 1998; inflator, Table B-3.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-8 January 2012

3.2.4 Eyewear

If the SNUR cites 40 CFR §721.63(a)(2)(iii), then to avoid engaging in a Significant New Use, employer 

must provide eye protection. Eye protection may also be acquired as a result of the dermal protection 

selection at §721.63 (a)( 1). Protective goggles are expected to be used at a rate of one set per worker 

and replaced every four months. Each site is assumed to have 25 workers, each of them exposed 250 

days per year. The SNUR may not specify the exact type of eyewear required. OSHA guidelines in 29 

CFR § 1910.133 (b)( 1), however, state that protective eye and face devices purchased after July 5, 1994 

shall comply with ANSI Z87.1-1989. To determine the cost of goggles that meet this standard, EPA 

consulted with eyewear specialists at equipment supplier LSS. A standard pair of goggles that meets the 

ANSI Z87.1-1989 specification was priced at $4.05 per pair in 1997 (LSS, 1997; RIB, 1998). A price 

estimate for a heavy-duty pair of goggles compliant with the ANSI standard is also included in Table C8.

The cost estimates for each chemical assume that the more expensive heavy-duty goggles are used in 

cases where the SNUR explicitly requires goggles. Costs of protective eyewear were inflated as 

described in Appendix B and are presented in Table C-8 below.

Table C-8 Annual Cost of Protective Eyewear [40 CFR §721.63(a)(2)(iii)]

Cost Element Unit Cost

(1997$ per pair)

Inflation 

Factor

Unit Cost

(2010$ per pair)

Number of 

Pairs 

Required1

Total 

Cost

(2010$)

2

Standard Goggles $4.05 1.359 $5.50 75 $413

Heavy duty chemical-splash/impact 

goggles

$6.05 1.359 $8.22 75 $616

Notes:

1 The analysis assumes 25 workers replacing goggles three times per year.

2Total costs were calculated using unrounded unit cost values and inflation factors (see Appendix B), so results may 

differ from calculations using the rounded values shown in this table.

Source: 1997 item costs, LSS, 1997; item type and quantity, EPA, 1998; Inflator, Table B-3.

3.2.5 Clothing

Costs for a standard coverall clothing set, estimated at $36.25 in 1997 (LSS, 1997), were inflated as 

described in Appendix B and are shown in Table C-9 below. Costs for full-body protective clothing are 

based on the coverall clothing set with a hood (LSS, 1997) as shown in Table C-9.

If the SNUR cites 40 CFR §721.63(a)(2)(ii) or (iv), then to avoid engaging in a Significant New Use, 

employers must provide protective clothing. Protective clothing may also be acquired as a result of the 

dermal protection selection at §721.63(a)(1). Protective clothing, (a)(2)(iv), and full-body chemical 

resistant clothing, (a)(2)(ii), are assumed to last four months. Each site is assumed to have 25 workers, 

each of them exposed 250 days per year.

Table C-9 shows estimated costs, after inflating as described in Appendix B, for a standard coverall 

clothing set that cost $36.25 in 1997 (LSS, 1997) and for full-body protective clothing – the coverall 

clothing set with a hood – costing $61.20 in 1997 (LSS, 1997).

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-9 January 2012

Table C-9 Annual Cost of Protective Clothing [40 CFR §721.63(a)(2)]

Cost Element Unit Cost 

(1997$ per set)

Inflation 

Factor

Unit Cost

(2010$ per set)

Number 

Required1

Total Cost

(2010$)2

Coverall with hood [full-body 

clothing] §721.63(a)(2)(ii) $61.20 1.359 $83.15 75 $6,236

Coverall §721.63(a)(2)(iv) $36.25 1.359 $49.25 75 $3,694

Notes:

1 The analysis assumes 25 workers replacing coverall three times per year.

2 Totals were calculated using unrounded unit cost values and inflation factors (see Table B-3), so results may differ 

from calculations using the rounded values shown in this table.

Source: 1997 item costs, LSS, 1997; item type and quantity, EPA, 1998; inflation factor, Table B-3.

3.2.6 Respirators

For some PMN chemicals, to avoid engaging in a Significant New Use, the SNUR requires either the use 

of respirators or compliance with a New Chemical Exposure Limit (NCEL). Both requirements differ by 

chemical.1827For costing purposes, this analysis assumes that respirators are used. Earlier, PMN SNURs 

referenced specific paragraphs at 40 CFR §721.63 (a)(5) that identified fifteen types of NIOSH-approved 

respirator units. However, with rulemaking docket OPPT-2003-0063 (EPA, 2007b), PMN SNURs began 

to describe respirator choices directly. Costs of the SNUR respirator choices were estimated based on the 

costs of the respirator in §721.63 (a)(5) that appeared to best match the SNUR descriptions.

 

27 EPA’s website at http://www.epa.gov/oppt/newchems/pubs/ncelmain.htm explains that in Consent Orders and 

subsequent SNURs, EPA can require respirators unless workplace air measurements show that air-borne 

concentrations of the chemical are below a New Chemical Exposure Limit established by EPA to protect health. 

NCEL provisions are modeled after Occupational Safety and Health Administration Permissible Exposure Limits 

(PELs), and also cover sampling and analytical methods, monitoring, respiratory protection, and recordkeeping.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-10 January 2012

Table C-10 Crosswalk Between SNUR Text and Respirator Types at 40 CFR §721.63(a)(5)

Respirator types at 40 CFR §721.63 (a)(5) 1

Requirement Stated in SNUR

(exact SNUR wording may differ)

(ii) Category 19C Type C supplied-air respirator operated 

in pressure demand or continuous flow mode and equipped

with a tight-fitting facepiece.

Some SNURs may specify “full” facepiece

Some SNURs may specify “or other positive pressure 

mode”

Supplied-air respirator operated in pressure demand

or continuous flow mode and equipped with a tightfitting full facepiece.

Supplied-air respirator operated in pressure demand 

or other positive pressure mode and equipped with a 

tight-fitting full facepiece

(iii) Category 19C Type C supplied-air respirator operated

in pressure demand or continuous flow mode and equipped

with a hood or helmet or tight-fitting facepiece.

Some SNURs may specify “half” or “full” facepiece.

Supplied-air respirator operated in pressure demand

or continuous flow mode and equipped with a hood

or helmet or tight-fitting facepiece (either half- or

full-face).

(iv) Category 21C air-purifying respirator equipped with a

full facepiece and high efficiency particulate filters.

Some SNURs may specify a “half" or "full" facepiece.

Some SNURs may specify “if oil aerosols absent” or other 

restrictions related to oil aerosols.

Air-purifying respirator equipped with a tight-fitting

full facepiece and High Efficiency Particulate Air

(HEPA) filters.

Air-purifying, tight-fitting respirator equipped with 

N100 (if oil aerosols absent), R100, or P100 filters 

(either half- or full-face).

Air-purifying, tight-fitting respirator (either half- or

full-face) equipped with N100 (if oil aerosols 

absent), R100 (restricted use when oil aerosols 

present), or P100 (appropriate when oil aerosols 

present) filters.

Air purifying, tight-fitting full-face respirator 

equipped with the appropriate combination 

cartridges tested and approved for the gas/vapor 

substance (i.e., organic vapor, acid gas, or substancespecific cartridge), with a particulate filter (N100 if 

oil aerosols are absent, R100, or P100).

(v) Category 21C powered air-purifying respirator equipped

with a tight-fitting facepiece and high efficiency particulate

filters.

Some SNURs may specify a “half" or "full" facepiece.

Powered air-purifying, tight-fitting full-face

respirator equipped with N100 (if oil aerosols

absent), R100, or P100 filters.

Powered air-purifying respirator equipped with a

tight-fitting facepiece (either half- or full-face) and

HEPA filters.

(vi) Category 21C powered air-purifying respirator

equipped with a loose-fitting hood or helmet and high

efficiency particulate filters.

Powered air-purifying respirator equipped with a

loose-fitting hood or helmet and High Efficiency

Particulate Air (HEPA) filters.

Notes:

1The table specifies respirator types at 40 CFR §721.63 (a)(5) that are most similar to the equipment described in the

SNUR text for the current and recent SNUR rulemakings. Any significant differences between the specified 

respirator type at 40 CFR §721.63 (a)(5) and the SNUR text respirator type are noted in italics.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-11 January 2012

Table C-11 gives average costs of various respirator types, both as originally estimated in 1997 and 

after applying inflation factors from Table B-3. It also estimates costs per plant site for a chemical 

requiring respirators.

The respirators specified in the SNURs are typically comprised of a respirator unit and any number of 

the following: special cartridges (such as high efficiency particulate filters, organic vapor cartridges, 

and paint, lacquer, and enamel filters), hoods or helmets, and filter caps. The costs for each site of 

providing respirators to chemically-exposed workers, shown in Table 4 of Chapter 2 of the report, are 

calculated based on the assumptions stated there, that (1) there are 25 chemically-exposed workers 

requiring protective equipment, (2) respirators are replaced once a year, and (3) cartridges (and 

cartridge filters and caps) are replaced at a rate of one pair (two cartridges) every five of the 250 days 

that workers are exposed, or 50 times per year. For example, for the respirator type described at 40 

CFR §721.63(a)(5)(xv), the annual cost per worker in 1997 dollars would be as follows:

$10.83 per respirator + ($8.94 per cartridge × 50 cartridges/year) = $457.83 per worker. 

The 1997 cost was adjusted for inflation as shown in Table C-11. 

Typically a SNUR describes more than one type of respirator, but only one type of respirator is needed 

to comply with the workplace protection requirements.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-12 January 2012

Table C-11 Annual Per-Chemical Costs for Respiratory Protection [40 CFR §721.63(a)(4)]

§721.63 

(a)(5) 

par.

NIOSH approval type at 40 CFR §721.63 (a)(5)

(See Table C-10 for cross-walk to respirators in SNUR) 

Annual Average Costs 

(1997$)

Annual Average Costs 

(2010$)1

Respirator 

Unit

Cartridge 

Set

Per 

Worker2

Inflation 

Factor

Annual 

Per 

Worker

Annual Per 

Site (25 

workers)3

(i) 19C Type C Supplied-air with full facepiece $804 $0.00 $804 1.359 $1,092 $27,309

(ii) 19C Type C Supplied-air with tight-fitting facepiece $804 $0.00 $804 1.359 $1,092 $27,309

(iii)

19C Type C Supplied-air with hood or helmet or tight-fitting 

facepiece $932 $0.00 $932 1.359 $1,266 $31,661

(iv)

21C Air-purifying with full facepiece and high efficiency particulate 

filters (HEPAs) $181 $9.76 $669 1.359 $908 $22,711

(v)

21C Powered air-purifying (PAPR) with tight fitting facepiece and 

HEPAs $627 $35.50 $2,402 1.359 $3,264 $81,599

(vi) 21C PAPR with loose hood or helmet and HEPAs $525 $26.89 $1,870 1.359 $2,540 $63,512

(vii) 21C Air-purifying with HEPA and disposable respirators $12.53 $7.00 $363 1.359 $493 $12,313

(viii)

23C air-purifying with full facepiece and combination cartridges 

approved for paints, lacquers and enamels (PLE)

$192 $15.71 $978 1.359 $1,328 $33,202

(ix)

23C PAPR with tight-fitting facepiece and combination cartridges 

approved PLE $627 $35.50 $2,402 1.359 $3,264 $81,599

(x)

23C PAPR with loose-fitting hood or helmet and combination 

cartridges for PLE $525 $26.88 $1,869 1.359 $2,540 $63,495

(xi)

23C Air-purifying with combination cartridges for PLE, including 

disposable respirators $14.30 $8.90 $459 1.359 $624 $15,600

(xii)

23C Air-purifying with full-facepiece and organic gas/vapor 

cartridges $192 $10.47 $716 1.359 $972 $24,303

(xiii)

23C PAPR with tight-fitting facepiece and organic gas/vapor 

cartridges $826 $41.15 $2,884 1.359 $3,918 $97,952

(xiv)

23C PAPR with a loose-fitting hood or helmet and organic 

gas/vapor cartridges $640 $41.15 $2,697 1.359 $3,665 $91,614

(xv)

23C Air-purifying with organic gas/vapor cartridges, including 

disposable cartridges $10.83 $8.94 $458 1.359 $622 $15,550

Notes:

1 Annual average costs were inflated as described in Table B-3.

2

“Respirator unit” costs include both the respirator and any required add-ons such as hoods and helmets. A “cartridge set” includes two cartridges and any filters 

or caps required. Assumes cartridge sets are replaced every five days (50 times during 250 exposure days) so that each worker requires one respirator unit and 50 

cartridge sets per year.

3 Totals were estimated from unrounded unit costs and inflation factors, so results may differ from calculations using the rounded values shown in this table.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-13 January 2012

Table C-12 shows how the average costs per NIOSH-type respirator were calculated, based on prices of 

respirators listed in a 1997 catalog. To calculate the cost of respirators that meet the NIOSH criteria, the 

prices of all units in the supplier catalog (LSS, 1997) that meet each NIOSH criteria were averaged. Costs 

of additional items such as hoods, helmets, cartridges, and filter caps were also obtained. These are added 

to the cost of the basic respirator unit if they are required under the SNUR regulation and if the unit does 

not already include the item. For example, §721.63(a)(5)(x) requires a hood or helmet. One model in the 

catalog that satisfies the requirement already includes a hood, while another unit requires that a separate 

hood be purchased. The cost of the hood was added to the unit cost and the combined cost was then 

averaged with the model with integrated hood.

Many respirator specifications also require cartridges. The costs of the cartridges listed in LSS (1997) 

were averaged for the corresponding requirements. In some instances, certain cartridges or filters 

require a secondary cartridge to function properly (e.g., some paint, lacquer and enamel filters required 

the organic vapors cartridges and filter retainer caps). These additional items were priced and added to 

the cost for the basic cartridge before averages were taken.

Some cartridge prices were unavailable from LSS (1997). For instance, §721.63(a)(5)(ix) and (x) require 

a powered air-purifying respirator (PAPR) with a paint, lacquer and enamel cartridge. The only cartridges 

available for these models of respirators in LSS (1997) are HEPA cartridges. In these cases the costs of a 

paint, lacquer, and enamel cartridge are assumed to be the same as for a HEPA cartridge.

The 1997 purchase costs of the varying types of respiratory protective equipment are shown in Table 

C-12.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-14 January 2012

Table C-12 Respirator Prices and Average Costs in 1997, by NIOSH Type

40CFR NIOSH 

Type

Catalog 

Item

Number

Description1 1997 

Cost

1997 Average Cost2

§721.63 

(a)(5)

Respirator 

Unit

Cartridge 

Set

(i)

19C Type C Supplied-air with full facepiece $804 --

7A-24506 Allegro Economical Full-Face Airline Kits, p144 $758.95 

7A-32366 311Survivair Supplied Air Respirator Kits, p144 $849.10 

(ii)

19C Type C Supplied-air with tight-fitting facepiece $80 --

7A-24506 Allegro Economical Full-Face Airline Kits, p144 $758.95

7A-32366 Survivair Supplied Air Respirator Kits, p144 $849.10

(iii)

19C Type C Supplied-air with hood or helmet or tight-fitting facepiece $932 --

7A-29363 Allegro Hood Systems, p144 $932.15

(iv)

21C Air-purifying with full facepiece and high efficiency particulate filters (HEPAs) $181 $10

7A-9838 North Full-Face Respirator, p114 $210.10

7A-7122 North HEPA Cartridge, p115 $11.15

7A-12338 Willson Full-Face Silicone Respirator, p116 $215.10

7A-7526 Willson HEPA Cartridge, p117 $11.75

7A-10516 3M 7800 Full-Facepiece Respirator, p118 $202.10

7A-11839 3M HEPA Cartridge, p118 $7.00

7A-33446 Pro-Tech Full-Face Respirator, p122 $106.45

7A-3070-1 Pro-Tech HEPA Cartridge, p123 $9.87

7A-3195 Willson 1600/1700 Series Full-Face Respirators, 

p124

$215.10

7A-3202 Willson HEPA Cartridge, p125 $12.50

7A-23959 AO7Star Full-Face Respirator (Silicone), p126 $203.25

7A-9940 AO7Star HEPA Cartridge, p127 $9.44

7A-24158 MSA Advantage 1000 Full-Face Respirator, p134 $112.60

7A-29946 MSA HEPA Cartridge, p134 $6.60

(v)

21C Powered air-purifying (PAPR) with tight fitting facepiece and HEPAs $627 $36

7A-13599 3M Face-Mounted PAPR System, p142 $720.00

7A-13601 3M HEPA Replacement Cartridge, p142 $36.50

7A-32505 RACAL Powerflow PAPR, p142 $534.90

7A-11936 RACAL Replacement Cartridge, p142 $34.50

(vi)

21C PAPR with loose hood or helmet and HEPAs $525 $27

7A-32506 RACAL Air-Mate PAPR 12, p143 $411.05

7A-24505 RACAL HEPA Replacement Cartridge, p143 $24.65

7A-32477 RACAL Breathe-Easy HEPA Cartridges and Turbo 

Unit, p141

$548.50

7A-12838 RACAL HEPA Replacement Cartridge $29.12

7A-12840 RACAL Breathe-Easy 10 Tyvek Hood, p140 $91.30

(vii)

21C Air-purifying with HEPA and disposable respirators $13 $7

7A-15255 3M 6000 Series Low-Maintenance Respirator, p135 $10.90

7A-12518P 3M Adaptor, p135 $1.63

7A-11839 3M HEPA Cartridge, p135 $7.00

(viii)

23C air-purifying with full facepiece and combination cartridges approved for 

paints, lacquers and enamels (PLE)

$192 $16

7A-9838 North Full-Face Respirator, p114 $210.10

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-15 January 2012

40CFR

NIOSH 

Type

Catalog 

Item

Number

Description1 1997 

Cost

1997 Average Cost2

§721.63 

(a)(5)

Respirator 

Unit

Cartridge 

Set

7A-7117 North Organic Vapors Cartridge, p115 $10.50

7A-7125 North Paint Spray/Mists Prefilter, p115 $2.38

7A-7125-2 North Filter Covers, p115 $4.35

7A-12338 Willson Full-Face Silicone Respirator, p116 $215.10

7A-7527 Willson Organic Vapors Cartridge, p117 $10.25

7A-7531 Willson Dusts/Mists/Pesticides/Paint Spray Prefilter, 

p117

$2.52

7A-7532 Willson Retainer Caps, p117 $4.00

7A-10516 3M 7800 Full-Facepiece Respirator, p118 $202.10

7A-9279 3M Organic Vapors Cartridge, p119 $8.91

7A-9284 3M Paint Spray Prefilter, p119 $2.37

7A-9292 3M Retainer Caps, p119 $3.90

7A-33446 Pro-Tech Full-Face Respirator, p122 $106.45

7A-955-4 Pro-Tech Organic Vapors Cartridge, p123 $9.27

7A-9605 Pro-Tech Paint Spray Prefilter, p123 $1.95

7A-3195 Willson 1600/1700 Series Full-Face Respirators, 

p124

$215.10

7A-3197 Willson Organic Vapors Cartridge, p125 $11.22

7A-3203 Willson Pesticides/Paint Spray Prefilter, p125 $3.36

7A-3858 Willson Retainer Caps, p125 $4.27

7A-23959 AO7Star Full-Face Respirator (Silicone), p126 $203.25

7A-9935 AO7Star Organic Vapors Cartridge, p127 $8.76

7A-10043 AO7Star Dusts/Mists/Paint Spray Prefilter, p127 $3.07

7A-10044 AO7Star Retainer Clips, p 127 $3.20

(ix)

23C PAPR with tight-fitting facepiece and combination cartridges approved PLE $627 $36

7A-13599 3M Face-Mounted PAPR System, p142 $720.00

--- Paint, Lacquer, Enamel Cartridge3$36.50

7A-32505 RACAL Powerflow PAPR, p142 $534.90

--- Paint, Lacquer, Enamel Cartridge3$34.50

(x)

23C PAPR with loose-fitting hood or helmet and combination cartridges for PLE $525 $27

7A-32506 RACAL Air-Mate PAPR 12, p143 $411.05

--- Paint, Lacquer, Enamel Cartridge3$24.65

7A-32477 RACAL Breathe-Easy HEPA Cartridges and Turbo 

Unit, p141

$548.50

7A-12840 RACAL Breathe-Easy 10 Tyvek Hood, p140 $91.30

--- Paint, Lacquer, Enamel Cartridge3$29.10

(xi)

23C Air-purifying with combination cartridges for PLE, including disposable 

respirators

$14 $9

7A-12711 Willson Freedom 2000 Series Organic Vapors 

Respirator, p136

$17.85

7A-7531 Willson Dusts/Mists/Paint Spray/Pesticides Prefilter, 

p136

$2.52

7A-13509 Willson Retainer Caps, p136 $2.03

7A-33826 Moldex 8000 Series Half-Mask Respirator, p139 $10.75

7A-22751 Moldex Organic Vapors Cartridge, p139 $8.03

7A-22753 Moldex Paint Spray/Pesticides Prefilter, p139 $2.56

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-16 January 2012

40CFR

NIOSH 

Type

Catalog 

Item

Number

Description1 1997 

Cost

1997 Average Cost2

§721.63 

(a)(5)

Respirator 

Unit

Cartridge 

Set

7A-22754 Moldex Retainer Caps, p139 $2.65

(xii)

23C Air-purifying with full-facepiece and organic gas/vapor cartridges $192 $10

7A-9838 North Full-Face Respirator, p114 $210.10

7A-7117 North Organic Vapors Cartridge, p115 $10.50

7A-12338 Willson Full-Face Silicone Respirator, p116 $215.10

7A-7527 Willson Organic Vapors Cartridge, p117 $10.25

7A-10516 3M 7800 Full-Facepiece Respirator, p118 $202.10

7A-9279 3M Organic Vapors Cartridge, p119 $8.91

7A-9292 3M Retainer Caps, p119 $3.90

7A-33446 Pro-Tech Full-Face Respirator, p122 $106.45

7A-955-4 Pro-Tech Organic Vapors Cartridge, p123 $9.27

7A-3195 Willson 1600/1700 Series Full-Face Respirators, 

p124

$215.10

7A-3197 Willson Organic Vapors Cartridge, p125 $11.22

7A-23959 AO7Star Full-Face Respirator (Silicone), p126 $203.25

7A-9935 AO7Star Organic Vapors Cartridge, p127 $8.76

(xiii)

23C PAPR with tight-fitting facepiece and organic gas/vapor cartridges $826 $41

7A-32473 RACAL Breathe-Easy Organic Vapors and Turbo 

Unit, p141

$548.50

7A-12844 RACAL Breathe-Easy 7 Full Face, p140 $277.90

7A-12830 RACAL Organic Vapors Replacement Cartridges, 

p141

$41.15

(xiv)

23C PAPR with a loose-fitting hood or helmet and organic gas/vapor cartridges $640 $41

7A-32473 RACAL Breathe-Easy Organic Vapors and Turbo 

Unit, p141

$548.50

7A-12840 RACAL Breathe-Easy 10 Tyvek Hood, p140 $91.30

7A-12830 RACAL Organic Vapors Replacement Cartridges, 

p141

$41.15

(xv)

23C Air-purifying with organic gas/vapor cartridges, including disposable 

cartridges

$11 $9

7A-15255 3M 6000 Series Low-Maintenance Respirator, p135 $10.90

7A-15256 3M Organic Vapors Cartridge, p135 $9.85

7A-33826 Moldex 8000 Series Half-Mask Respirator, p139 $10.75

7A-22751 Moldex Organic Vapors Cartridge, p139 $8.03

Notes: 

1

See Table C-10 for the cross-walk between respirator types in the SNUR and in this table .

2 Average costs presented in this table are rounded to the nearest dollar figure, so results may differ from 

calculations using the rounded values shown in this table.

3

Paint, lacquer and enamel (PLE) cartridges for PAPRs were not listed in the catalog. The costs for PLE 

cartridges are assumed to be the same as HEPA cartridges.

Source: LSS 1997; EPAB 1999 

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-17 January 2012

Recordkeeping

There are two main types of recordkeeping requirements for the substances listed in the current SNURs: 

those for companies submitting a SNUN, and those for all companies that manufacture, import or process 

SNUR-regulated substances, regardless of whether they have made a submission to EPA. 

3.3.1 SNUN submitters

Companies submitting a SNUN must keep records under 40 CFR §721.40. Some EPA reports have 

assumed that SNUN recordkeeping hours would be 5 percent of SNUN submission hours, or about five to 

six hours.28 Other EPA reports have estimated that electronic submission of SNUNs is expected to reduce 

the recordkeeping burden to approximately one hour (EPA, 2009a, p. 16) For this report, the SNUN 

recordkeeping hours were included in the SNUN submission hours (see Table 8) and the SNUN 

recordkeeping cost was not separately estimated.29 

3.3.2 All manufacturers, importers, and processors 

Whether or not they submit a SNUN, firms that manufacture, import, or process the SNUR substance 

must keep records based on 40 CFR §721.125(a) through (k), to document compliance with SNUR 

conditions for avoiding a Significant New Use. (For firms producing under the R&D exemption, R&D 

recordkeeping would be needed. R&D recordkeeping costs were not estimated for this report.)

Recordkeeping requirements vary between PMN chemicals, reflecting differences in SNUR restrictions. 

For all chemicals in the current SNURs, manufacturers, importers, and processors must keep records on 

quantities supplied or purchased under 40 CFR §721.125(a), (b), and (c). For chemicals with water 

discharge restrictions, companies must keep records concerning water discharge compliance, under 

§721.125(k). For chemicals with other use restrictions, or for those few chemicals with workplace 

protection or hazard communication restrictions, companies must keep records under other 40CFR 

§721.125 paragraphs, to document compliance.

All recordkeeping requirements essentially involve copying and filing relevant records, including those 

related to: manufacturing, importing, or processing volumes; shipment amounts and customer 

information; clothing impermeability determinations; the hazard communication program including labels 

and MSDS copies; compliance with other use restrictions; and/or compliance with disposal and release to 

water limitations. Records must be maintained for five years from the date of their creation.

Costs for compliance with the recordkeeping requirements for substances subject to a SNUR are based on 

the approach in Economic Analysis of Final Significant New Use Rules: General Provisions for New 

Chemical Followup (EPA, 1989) which in turn was based on Recordkeeping Costs for a Generic SNUR, 

prepared for EPA in 1988 by Kearney/Centaur (Kearney, 1988a). These reports drew on recordkeeping 

 

28 For example, OPPT’s Information Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules 

for Existing Chemicals (Renewal), October 11, 2005, estimates SNUN recordkeeping costs at 5.67 hours (EPA 

2005, page 12).

29 SNUN submission costs estimated in Table 8 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 for submission costs.” Page III-12 identifies “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 RIB 1994) included recordkeeping hours.

EPA SANITIZED Page 58 of 80
Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-18 January 2012

costs estimated for the Comprehensive Assessment Information Rule, CAIR. Industry recordkeeping 

costs for CAIR compliance were estimated in reports Kearney prepared for EPA, including Estimated 

Cost of the Final Comprehensive Assessment Information Rule, June 1, 1988 (Kearney, 1988b, pages 63 

to 65). 

This report uses the basic Kearney (1988a and 1988b) estimates and assumptions to estimate 

recordkeeping costs for SNUR requirements.30 Unlike Kearney (1988a), this report presents costs for 

each §721.125 recordkeeping requirement separately. This report also avoids minor rounding errors by 

calculating from unrounded data. However, the underlying methodology is identical to the Kearney 

1988a/RIB 1989 reports, resulting in identical costs per chemical except for differences due to inflation 

and rounding. The paragraphs that follow describe estimates and assumptions used from Kearney (1988a 

and 1988b).

Cost per page. Recordkeeping costs are based on cost per page. Kearney (1988a) assumes that the ratios 

of labor hours to page count for each labor category, file drawer space to page count, and cost of 

miscellaneous supplies such as folders and labels to page count, are the same as the per-page ratios 

estimated for EPA’s Comprehensive Assessment and Reporting Rule. The CAIR estimates are given in 

the 1988 report, Estimated Cost of the Final Comprehensive Assessment Information Rule, June 1, 1988, 

page 65 (Kearney, 1988b). Table C-13 summarizes estimates from Kearney 1988a and the CAIR report 

(Kearney, 1988b). It also shows the derivation of costs from these estimates, after inflation. The method is 

as follows:

 Technical labor was estimated at 1 hour for 750 pages in the CAIR report (Kearney, 1988b, page 

65), or .00133 hours per page. The analysis estimates a cost per hour and per page using fully 

loaded labor rates from Table B-1.

 Clerical labor was estimated at 10 hours for 750 pages in the CAIR report (Kearney, 1988b, page 

65), or .01333 hours per page. The analysis estimates a cost per hour and per page using fully 

loaded labor rates from Table B-1.

 The photocopying cost from Kearney 1988a ($0.05 per page) was inflated using an inflation 

factor from Table B-3.

 File space for CAIR was estimated at 1⁄4 of a four-drawer file cabinet for 750 pages (Kearney, 

1988b, page 65) or 0.000333 of a cabinet per page. A standard, four-drawer, full-suspension file 

cabinet was priced from a national office products supplier at $195 in 1997 (BT Office Products, 

1997; Item #LGM-202401; EPA, 1998). This results in $0.065 per page cost for file space, before 

inflation ($195 × 0.25 file cabinet/750 pages). The cost per page was inflated using an inflation 

factor from Table B-3.

 Miscellaneous materials costs were estimated at $10.00 for 750 pages in the CAIR report 

(Kearney, 1988b, page 65), or $0.0133/page before inflation. This cost per page was inflated 

using an inflation factor from Table B-3.

 

30 This report follows the method in Economic Analysis of Expedited Significant New Use Rules for 65 Chemical 

Substances (EPA Docket OPPT-2003-0063), (EPA, 2007b), which used the Kearney data to calculate the cost 

breakdown by recordkeeping requirement.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-19 January 2012

Table C-13 Recordkeeping Estimates from Kearney 1988a and 1988b

Kearney Estimates for CAIR Rule (1988a, b) Adjusted for inflation

Per page cost - 2010$

Estimate CAIR 

Pages Cost Per Page

Cost Per 

Hour or 

Inflation 

Factor

Cost Per 

Page 

Labor Costs

Technical 1 hour 750 0.00133 hours $61.71 $0.0823

Clerical 10 hours 750 0.01333 hours $28.98 $0.3864

Total Labor 0.01467 hours $0.4687

Material Costs

Photocopying $0.05 [1988 dollars] 1 $0.050 1.843 $0.0922

File Cabinet

1/4 of cabinet priced 

at $195 [1997 dollars] 750 $0.065 1.359 $0.0883

Misc. Materials

$10 total [1988 

dollars] 750 $0.013 1.843 $0.0246

Total Materials $0.128 $0.2050

Total Cost per Page (Labor & Materials) $0.6737

Notes: 

Per-page labor hours and materials costs were originally estimated in Kearney 1988b for the CAIR rule. The 

CAIR per-page costs were then used to estimate SNUR recordkeeping per-page costs in Kearney 1988a. This 

clarifies the method by which the original CAIR per-page costs and hours were calculated. It also adjusts costs for 

inflation using labor rates from Table B-1 and inflation factors from Table B-3. 

Pages per chemical at one site. In order to estimate recordkeeping costs, the analysis multiplies the costs 

per page for each recordkeeping element estimated in Table C-13 by the number of pages required for 

each SNUR recordkeeping requirement at 40 CFR §721.125 as estimated by Kearney (1998a). The 

Kearney data was used by EPA in its original expedited-SNUR economic analysis (EPA, 1989). For 

example, maintaining MSDS copies as required at §721.125(h) would require 5 pages. The following 

estimates from Kearney (1988a) are also used: 

 Manufacture and import volume, and sales and transfer data require 485 pages of records per 

year. This reflects 40 invoices per month (see haz-comm Section C.1 above), 480 for 

sales/transfer and 5 for manufacturer/import (Kearney, 1988a, p.11).

Disposal compliance records, if required, cover items such as waste production, shipping

manifests, permits, and transfer receipts. The 600 disposal compliance pages assume 50 pages per 

month (Kearney, 1988a, p.11).

(This report uses slightly different terminology from EPA, 1989: “Protective clothing” instead of 

“protective gloves,” “haz-comm” instead of “employee information and training.” Recordkeeping for 

“impermeability determination” was not separately costed out in EPA, 1989. This report assumes it is 

included under “protective clothing” recordkeeping.)

Cost per chemical. Table C-14 shows annual recordkeeping activities at one site for one SNUR chemical, 

by CFR requirement. If all recordkeeping requirements at 40 CFR §721.125 applied to a single chemical, 

there would be costs for 2.3 hours of technical time, 23 hours of clerical time, 1,715 photocopies, 

approximately one-half of a four-drawer file cabinet, and other miscellaneous materials such as folders. 

However, in reality, few if any chemicals will have all of the recordkeeping requirements listed in Table 

EPA SANITIZED Page 60 of 80
Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 C-20 January 2012

C-14. Recordkeeping costs would be lower for chemicals with relatively few SNUR restrictions because 

fewer pages would be needed to document SNUR compliance.

Table C-14 does not include costs of recordkeeping resulting from a SNUN submission; those costs were 

included in the SNUN submission cost. 

Table C-14 Annual Per-Chemical Costs of Recordkeeping Requirement [40 CFR 721.125] 

40CFR 

§721.1252 Requirement Pages3

Labor and materials cost1

(2010$) Hours 

(a)

Per Page 

(b)

Per Chemical 

(c)=(a)*(b)

Per Page

(d)

Per Chemical 

(e)=(a)*(d)

(a)(b)(c) Volumes & sales/transfer data 485 $0.6737 $327 0.01467 7.11

(d)(e) Protective clothing [§721.63] and 

impermeability [§721.63(a)(3)] 20 $0.6737 $13.47 0.01467 0.29

(f) Haz-comm program [§721.72] 250 $0.6737 $168 0.01467 3.67

(g) Label copies [§721.72(b)] 5 $0.6737 $3.37 0.01467 0.07

(h) MSDS copies [§721.72(c)] 5 $0.6737 $3.37 0.01467 0.07

(i) Use limitations compliance 

[§721.80] 250 $0.6737 $168 0.01467 3.67

(j) Disposal compliance [§721.80] 600 $0.6737 $404 0.01467 8.80

(k) Release to water compliance 

[§721.90] 100 $0.6737 $67.37 0.01467 1.47

TOTAL 1,715 $0.6737 $1,155 0.01467 25.15

Notes: 

1 This table multiplies cost per page estimates from Table C-13 by the number of pages estimated for each 

recordkeeping cost element. (This table does not include recordkeeping for SNUN submissions required by 40 

CFR §721.40.) Total costs are calculated from unrounded values and may not equal the sum and/or product of 

rounded values. 

2

40 CFR 721.125(a) through (k) list recordkeeping that may be specified in the SNUR. The recordkeeping 

specified depends on which 40 CFR §721 provisions [in brackets] were used by the SNUR to define reportable 

New Uses (§721.63, §721.72, §721.80, and/or §721.90). Few if any SNUR chemicals would require all of the 

recordkeeping costs listed above since few if any chemicals are subject to all of the requirements (a) through (k). 

3

Pages count estimates for each SNUR requirement are from Kearney, 1988a.

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 D-1 January 2012

Costs of Testing

EPA recognizes that TSCA Section 5 does not require developing any particular test data before 

submission of a Significant New Use Notice. Persons are required only to submit test data in their 

possession or control and to describe any other data known to or reasonably ascertainable by them. (Upon 

review of a SNUN, the Agency has the authority to require appropriate testing, but that is a cost of 

regulatory follow-up, not of the SNUN submission itself.) For informational purposes, the SNURs 

describe tests recommended by EPA to provide sufficient information to evaluate the chemical substance. 

However, as was explained in the discussion of SNUNs earlier in this report, it appears that firms rarely 

elect to do these recommended tests to support a SNUN, and especially not the higher-cost tests. For 

informational purposes, this appendix presents estimated costs for testing often recommended for 

chemicals that have been the subject of PMNs and are subject to Significant New Use Rules (SNURs). 

Testing Guidelines 

In the SNURs, EPA identifies a set of tests for each PMN chemical that can be used by firms making 

Significant New Use Notice or other submissions to EPA to characterize risks of the chemical. The tests 

are recommended in the SNUR, not mandatory. They are identified by guideline numbers which can be 

used to look up published test protocols. Table D-1 lists test guidelines cited in the current and recent 

SNUR rulemakings, and their associated costs, Table D-2 presents certain assumptions used in the 

analysis, and Table D-3 presents Persistent Bioaccumulative Toxic (PBT) tiered testing requirements. The 

types of guidelines are described below.

4.0.1 OPPTS Harmonized Test Guidelines

Most SNUR tests are identified by their OPPTS number from the series of OPPTS Harmonized Test 

Guidelines and OPPTS harmonized public drafts not yet promulgated as OPPTS guidelines. These 

guidelines blended testing guidance from OPPT (published in the Code of Federal Regulations), EPA's 

Office of Pesticide Programs, the Organization for Economic Cooperation and Development (OECD), 

and other sources. The harmonized guidelines fall into several categories, including the following:

 Series 835--Fate, Transport and Transformation Test Guidelines

 Series 850--Ecological Effects Test Guidelines

 Series 870--Health Effects Test Guidelines

They are available electronically on EPA’s website (EPA, 2006). Cross-references for health effects 

guidelines are listed at 63 FR 41847, August 5, 1998.

4.0.2 Code of Federal Regulations

SNUR tests may also come from the Code of Federal Regulations (CFR), identified for example as “40 

CFR 799.9370” or just “799.9370.” In addition, in costing out test guidelines, this report sometimes uses 

costs for a CFR guideline when costs have not been developed for the equivalent OPPTS harmonized 

guideline. 40 CFR parts 795 through 798 include pre-harmonization test guidelines, typically updated 

before 1990. 40 CFR part 799 includes more recent TSCA test guidelines, based on harmonized test 

guidelines. (63 FR 41845, August 5, 1998).

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 D-2 January 2012

4.0.3 OECD

A few SNUR tests are identified by their OECD number. The OECD guidelines may have OPPTS 

equivalents. For example, OECD 407 28-Day Oral Toxicity in Rats is essentially equivalent to OPPTS 

870.3050. 

4.0.4 OECD’s Guidance Manual for the Testing of Manufactured Nanomaterials

For some nanomaterials SNUR tests may refer to OECD’s Guidance Manual for the Testing of 

Manufactured Nanomaterials. Because of the newness of nanomaterial testing tests may not have 

protocol numbers, but rather refer to the guidelines described in the manual. 

4.0.5 PBT Category

For some chemicals, the SNUR cites tiered testing according to a testing strategy published in the Federal 

Register (FR), Category for Persistent, Bioaccumulative, and Toxic New Chemical Substances,

November 4, 1999 (64 FR 60194), which in turn refers to a number of tests by OPPTS or OECD 

guideline number.

4.0.6 ASTM, NTIS, and Other Sources

Test guidelines may also come from the American Society for Testing and Materials (for example, ASTM 

D2035-80 Modified Coagulation-flocculation Jar Test of Water) (www.astm.org) or other sources. The 

guideline for a neurotoxicity functional observational battery, NTIS PB 91-154617, is available from the 

National Technical Information Service (www.ntis.gov).

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 D-3 January 2012

Table D-1 Cost Estimates for Test Guidelines Cited in SNURs 

Guideline Test Species Route/Method Cost

2010$

Product Properties

830.6315 Flammability NA NA $2,252

830.7050 Absorption in Aqueous Solution: ultraviolet/visible 

spectra NA NA $2,277

830.7200 Melting Point / Melting Range NA 8-test average $1,351

830.7550 Partition Coefficient (n-Octanol/Water) NA Shake Flask Method $7,061

830.7560 Partition Coefficient (n-Oct/Water) NA Generator Column $7,506

830.7570 Partition Coefficient (n-Oct/Water) NA Liquid 

Chromatography $4,940

830.7840 Water Solubility NA Flask Method $10,205

830.7860 (796.1860)x Water Solubility: Column Generator Method NA Generator Column $22,033

Karel Vershueren Handbook, 

odor and taste test

Odor and taste test (in Handbook of Environmental 

Data on Organic Chemicals, by Karel Vershueren, 

4

th Ed,Vol. 1, Page 22)

NA NA *

Fate, Transport, Transformation

835.1110 Activated Sludge Sorption Isotherm NA NA $19,733

835.1220 Sediment and Soil Adsorption/Desorption Isotherm NA NA $30,266

835.2110 Hydrolysis as a Function of pH NA NA $59,465

835.2120 Hydrolysis test NA NA $41,938

835.2130 Hydrolysis as a Function of pH and Temperature NA NA *

835.2210 (796.3700) Photolysis in Aqueous Solution in Sunlight NA NA $118,953

835.3100 (796.3100) Aerobic Aquatic Biodegradation NA NA $16,330

835.3110 Ready Biodegradation NA Average of six 

methods $12,759

835.3120 Sealed-Vessel CO2 Production Test NA NA $7,912

835.3140 CO2 in Sealed Vessels Test NA NA *

835.3170 Shake Flask Die-Away Test NA NA $52,029

835.3180 Sediment/Water Microcosm Biodegradation NA Flow-through $136,045

835.3190 Aerobic Mineralization in Surface Water –

Simulation Biodegradation Test NA NA *

835.3200 (OECD 302B) Inherent Biodegradation: Modified Zahn-Wellens NA NA $10,339

835.3210 Modified SCAS Test NA NA $30,468

835.3220 Porous Pot Test NA NA $33,000

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 D-4 January 2012

Guideline Test Species Route/Method Cost

2010$

835.3400 Anaerobic Biodegradability of Organic Chemicals NA NA $12,560

835.5045 (OECD 302A) Inherent Biodegradability: Modified SCAS Test NA NA $14,513

835.5270 (795.7000)

Sunlight Photolysis in Waters Containing 

Dissolved Humic Substances (Indirect Photolysis 

Screening Test)

NA NA

$25,089

D2035-80 (ASTM D 2035-

80)

Standard Practice for Coagulation-Flocculation Jar 

Test of Water NA NA

$4,333

OECD 303A Simulation Test - Aerobic Sewage Treatment, with 

measurement of loss of the parent NA NA $43,640

OECD 307 Aerobic and Anaerobic Transformation in Soil NA Flow-through $286,184

OECD 307 Aerobic and Anaerobic Transformation in Soil NA Bio-meter type flasks $270,528

OECD 308 Anaerobic transformation in aquatic sediment 

systems NA NA *

OECD 309 Aerobic mineralisation in surface water NA NA *

OECD 310 Ready biodegradability-CO2 in Sealed Vessels 

(headspace test) NA NA *

OECD 311 (835.3400) Anaerobic biodegradability of organic compounds 

in digested sludge NA NA *

OECD TG 310 CO2 in Sealed Vessels – Headspace Test NA NA *

Ecological Effects

850.1000 Special Considerations for Conducting Aquatic 

Laboratory Studies NA NA *

850.1010 (797.1300) Daphnid Acute Toxicity Daphnid Flow-through $15,293

850.1010 (797.1300) Daphnid Acute Toxicity Daphnid Static $15,091

850.1075 (797.1400) Fish Acute Toxicity Fathead 

Minnow Flow-through $21,076

850.1075 (797.1400) Fish Acute Toxicity NA Static $17,069

850.1085 Fish Acute Toxicity Test mitigated by humic acid Fathead 

Minnow Flow-through *

850.1085 Fish Acute Toxicity Test mitigated by humic acid Fathead 

Minnow Static $17,793

850.1300 Daphnid Chronic Toxicity Test Daphnid Flow-through $136,977

850.1350 Mysid Chronic Toxicity Test Mysid Flow-through $44,961

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Guideline Test Species Route/Method Cost

2010$

850.1400 Fish Early Life Stage Toxicity Rainbow 

Trout Flow-through $69,853

850.1400 Fish Early Life Stage Toxicity Fathead 

Minnow Flow-through $47,223

850.1730 Fish BCF Fathead 

Minnow Flow-through $152,822

850.1925 Site-Specific Aquatic Microcosm Test NA NA *

850.1950 Field testing for Aquatic Organisms3 NA NA $679,578

OECD 218 Chironomid Sediment Toxicity NA NA $29,146

850.5400 Algal Toxicity, Tiers I and II NA NA $18,480

Health Effects

870.1100 Acute Oral Toxicity Rats Gavage $7,965

870.1300 Acute Inhalation Toxicity Rats4Inhalation $17,564

870.2500 Acute Dermal Irritation Test Rabbits Dermal $6,306

870.2600 Dermal Sensitization Test Guinea Pigs NA $12,092

870.3050 Repeated Dose 28-day Oral Toxicity Test Rodents NA *

870.3100 90-Day Oral Toxicity Rats Gavage $159,544

870.3250 Subchronic Dermal Toxicity - 90 days Rats Dermal $169,384

870.34651Subchronic Inhalation Toxicity Rats Inhalation $522,939

870.3465 (mod) Subchronic Inhalation Toxicity (w/ 60 day 

recovery group) Rats Inhalation $249,450

870.3465 (OECD 413)1 Subchronic Inhalation Toxicity (90-day

exposure/180-day retention) Rats Inhalation $435,830

870.3550 Reproductive/Developmental Toxicity Screening 

Test NA Oral *

870.3650 Combined repeated dose toxicity test with the 

reproductive/developmental screening test Rats NA *

870.3700 Prenatal Developmental Toxicity {2 species} Rats Gavage $121,107

870.3800 Reproduction/Fertility Effects (2-Generation 

Reproduction) Rats Gavage $403,152

870.4200 Carcinogenicity {2 species} (24 months) Rats Gavage $1,607,496

870.4200 Carcinogenicity {2 species} Rats Inhalation $1,275,697

870.4300 Combined Chronic Toxicity/Carcinogenicity Test Rats Gavage $1,227,788

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Economic Analysis of Expedited SNURs, Docket OPPT-2011-0942 D-6 January 2012

Guideline Test Species Route/Method Cost

2010$

870.5100 Bacterial reverse mutation test NA Direct plate $9,169

870.5265 Salmonella typhimurium Reverse Mutation Assay 

(Ames Test) NA Average of direct plate 

and Azo reduction $13,233

870.5385 Mammalian Bone Marrow Chromosomal 

Aberration Test Rats Gavage $37,836

870.5395

In Vivo Mammalian Bone Marrow Cytogenetics

Tests: Erythrocyte Micronucleus Assay (Average 

of 1 and 3 day dosings)

Mice Gavage (Average of 1 

and 3 day) $22,441

870.5395

In Vivo Mammalian Bone Marrow Cytogenetics 

Tests: Erythrocyte Micronucleus Assay (Average 

of 1 and 3 day dosings)

Mice Intravenous (Two test 

average) $22,441

870.5550 Unscheduled DNA Synthesis in Mammalian Cells 

in Culture

Rat 

Hepatocytes NA $23,174

870.6100 Delayed Neurotoxicity of Organophosphorus 

Substances (Acute) Hens Gavage (Acute) $39,621

870.6100 Delayed Neurotoxicity of Organophosphorus 

Substances (Subchronic 28-day) Hens Gavage (Subchronic) $95,818

870.6200 Neurotoxicity Screening Battery (Acute) Rats Gavage $159,654

870.7800 Immunotoxicity Rats Gavage $67,832

ASTM F739 -91 (ASTM 

F739)2

Standard Test Method for Resistance of Protective 

Clothing Materials to Permeation by Liquids or 

Gases Under Conditions of Continuous Contact

NA Average (Gases and 

Liquids) $14,829

OECD 105 Water Solubility Test NA Flask Method $7,169

OECD 112 Dissociation Constant in Water Test NA Conductometric 

Method $6,282

OECD 206 Avian Reproduction Test Bobwhite 

Quail NA $103,841 

OECD 206 Avian Reproduction Test Mallard 

Ducks NA $112,290 

OECD 303A Simulation Test - Aerobic Sewage Treatment: 

Activated Sludge Units NA NA $43,640

OECD 307 Aerobic and Anaerobic Transformation in Soil Test NA Flow Through $286,184 

OECD 307 Aerobic and Anaerobic Transformation in Soil Test NA Bio-meter Type Flasks $270,528

OECD 308 Aerobic and Anaerobic Transformation in Aquatic 

Sediment Systems Test NA NA *

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Guideline Test Species Route/Method Cost

2010$

OECD 311 Anaerobic Biodegradability of Organic 

Compounds in Digested Sludge Test NA NA *

OECD 314 Simulation Test to Assess the Biodegradability of 

Chemicals Discharged in Wastewater NA NA *

OECD 404 (870.2500) Acute Dermal Irritation Rabbits Dermal $6,306

OECD 405 (870.2400) Acute Eye Irritation Rabbits Eye $6,306

OECD 407 (870.3050) Repeated dose 28-day oral toxicity study in rodents Rats Gavage (28 Days) $58,824

OECD 412 Repeated Dose Inhalation Toxicity (28-Day Study) Rats Inhalation (28 Days) $131,703

OECD 416 Two-Generation Reproduction Toxicity Test Rats Dietary $434,048

OECD 421 (870.3550) Reproduction/developmental toxicity screening 

tests Rats Gavage $68,996

OECD 422 (870.3650) Combined Repeated Dose Study with 

Reproductive/Developmental Toxicity Screen Rats Gavage $137,531

OECD 422 (mod)

Combined Repeated Dose Study with 

Reproductive/Developmental Toxicity Screen (90 

days w/ histopathology)

Rats Gavage $258,569

OECD 425 Acute Oral toxicity: Up-and-down Procedure Rats Gavage $6,092

OECD 453 Combined Chronic Toxicity/Carcinogenicity Test Rats Inhalation $3,606,487

ASTM D6007-02

Small Scale Chamber Test to Determining 

Formaldehyde Concentration in Air from Wood 

Products 

NA NA *

Nanomaterial Specific Tests5, 6

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

Dustiness Test NA EN 15051 Method $2,570

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

Dry particle size distribution by count for each 

PMN substance in a form which has the highest 

content of particles smaller than 10 microns as 

manufactured, processed or used in the workplace 

at sites controlled by the Company

NA

STEM (scanning 

transmission electron 

microscopy) method

*

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

Surface chemistry NA Average of Three 

Methods $5617

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Guideline Test Species Route/Method Cost

2010$

ASTM D2565-99(2008) Release of MWCNTs after exposure of liquid 

polymer forms to sunlight: NA

Consult Standard 

Practice for XenonArc Exposure of 

Plastics Intended for 

Outdoor Applications

*

ASTM E1354-09 Release of MWCNTs during the burning of liquid 

polymer forms: NA

Consult Standard Test 

Method for Heat and 

Visible Smoke 

Release Rates for 

Materials and Products 

Using an Oxygen 

Consumption 

Calorimeter

*

EPA method 1320 Release of MWCNTs after landfill disposal: NA

Multiple Extraction 

Procedure to 

determine the fraction 

of MWCNTs released 

during the leaching 

that the liquid polymer 

forms will undergo 

from repetitive 

precipitation of acid 

rain

*

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

Configuration of Carbon Nanotube ends NA NA $750

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Guideline Test Species Route/Method Cost

2010$

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

Release of MWCNTs during solid polymer form 

shipping and use NA

A simple short-term

test consisting of 

placing the solid 

polymer forms in a 

standard rock tumbler 

and determining the 

amount of free 

MWCNTs after a 

period of l, 5, 15, and 

30 days to screen for 

significant release of 

MWCNTs from the 

solid polymer forms.

*

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

GRAPHISTRENGTH TM C100 (>90% 

MWCNTs. < 7% aluminia and <5% of iron oxide) NA NA *

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

GRAPHISTRENGTH TM U100 (>97% 

MWCNTs. <3% of iron oxide, 1% alumnia) NA NA *

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

GRAPHISTRENGTH TM CSI-015, a viscous 

resin (honey-like) comprised of 98.5% epoxy resin, 

1,5% GRAPHISTRENGTH TM C100

NA NA *

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

GRAPHISTRENGTH TM PEB-201, a very highly 

viscous resin (tar-like paste) comprised of 64.3% 

polyester, 31.6% styrene, remainder 

GRAPHISTRENGTH TM C100

NA NA *

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

GRAPHISTRENGTH TM CM1-20, a pellet 

comprised of 79% polyamide, 12.5% white mineral

oil, remainder GRAPHISTRENGTH TM C100

NA NA *

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

GRAPHISTRENGTH TM CM2-20 a pellet 

comprised of 78% polyamid resin, 22% 

GRAPHISTRENGTH TM C100

NA NA *

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

GRAPHISTRENGTH TM CM3-20 a pellet 

comprised of 79% polyamid 11, 21% 

GRAPHISTRENGTH TM C100

NA NA *

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Guideline Test Species Route/Method Cost

2010$

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

GRAPHISTRENGTH TM CM5-20 a pellet 

comprised of 60% polycarbonate, 20% flame 

retardant, 20% GRAPHISTRENGTH TM C100

NA NA *

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

GRAPHISTRENGTH TM CM12-30, a pellet 

comprised of cyclic butylenes trephthalate (CBT), 

30% GRAPHISTRENGTH C100

NA NA *

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

GRAPHISTRENGTH TM CM13-30, a pellet 

comprised of 65% polyacrylic-polyolefin, 15% 

acrlonitrile-butadiene copolymer, 20% 

GRAPHISTRENGTHTM C100

NA NA *

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

GRAPHISTRENGTH TM C M6-20 a granule 

comprised of 80%polyamid6, 20% 

GRAPHISTRENGTH TM C100

NA NA *

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

Workplace exposure monitoring and 

characterization testing (including byproducts) NA NA *

OECD's Guidance Manual 

for the Testing of 

Manufactured Nanomaterials

Certain material characterization data NA NA *

Notes:

* Indicates this cost has not been calculated for this report.

+

Indicates that EPA, EPAB staff estimated this test cost in fall of 2009 and it is more recent that the other EPA, OPPTS EPAB test cost estimates presented in the table, the 

majority of which were estimated prior to 1990. 1For some PMNs, recommended testing under guideline 870.3465 would involve an additional 3 month recovery group, as well 

as other evaluation beyond the standard requirements in the test guideline. These activities would raise testing cost substantially.

1 The recommended testing for some PMN chemicals may include a glove permeation test following ASTM F739 and F1194-99 guidelines. ASTM F1194-99 is a standard guide 

for documenting the results of chemical permeation tests (see www.astm.org). The additional costs of following ASTM F1194-99 (average of gases and liquids) were not estimated 

for this report.

2 Costs for field testing will be site-specific, with a wide range of actual costs. A report from EPA's Office of Pesticide Programs estimated an average test cost of $600,000 for 

guideline 850.1950, for simulated or actual field testing for aquatic organisms (EPA, 2008a, Appendix C). 

3

Performing the test on species other than rats may change the test costs. For example, testing on rabbits is likely to increase costs.

4

Fate, transport and transformation, ecological effects, and health effects testing may be required for nanomaterials, however nano-specific costs for these tests were not estimated

for this report.

5 While the Agency expects that analytical methodology validation costs may be more expensive for nanomaterials than for traditional chemicals, EPA was unable to gather any 

information on nanomaterial-specific analytical methodology validation and therefore uses the traditional chemical costs as a proxy.

6 The test cost is an average of the test costs for three methods: EELS, XPS (ESCA), and Auger electron spectroscopy.

Source: EPA OPPTS Economic and Policy Analysis Branch cost estimates. Many costs were estimated in the 1990s or earlier. All have been inflated (see Table B-1 and Table B3 for inflation index). Dollar costs include $4,054or $9,854 for analytical method validation; where applicable (see text). Species and route or method may be specified in SNURs or 

may be unspecified but assumed in this table for costing purposes.

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Test Costs by Guideline 

Table D-1 gives dollar cost for each test, based on assumptions and adjustments discussed below. This 

section describes the development of individual test costs.

EPA’s Office of Pollution Prevention and Toxics, Economic and Analysis Branch, regularly develops 

cost estimates of test guidelines to support TSCA rule development. Estimates are based on assumptions 

about species, route of administration, study duration, and other aspects of methodology. Costs are 

calculated based on costs of labor, materials, and equipment needed to perform testing, with overhead and 

fee. Many of the test costs were developed in the 1990s. Test costs have been inflated using Employment 

Cost Index inflators from the Bureau of Labor Statistics (see Appendix B). However, generally they have 

not been updated to reflect subsequent changes in laboratory technologies. 

Testing laboratories perform analytical method validation to ensure that proper dose concentrations are 

used in toxicity studies (EPA, 2005a, p. 3-9). This analysis assumes that for health effects tests (e.g. 870 

series guidelines), tests of up to 90 days in duration have method validation costs of $3,500, and longerterm tests have validation costs of $8,500 in 2004 dollars. Using the inflation rates found in Appendix B, 

validation costs are $4,054 and $9,854in 2010 dollars. For simplicity, the method validation cost for 

ecological effects tests (e.g. 850 series guidelines) was assumed to be $4,054 for each test. In addition, this 

analyses assumes that analytical method validation costs are the same for both nanomaterials and 

traditional chemcials.

In cases where costs have not been estimated for the specified guideline, EPA uses the cost from an 

approximately equivalent guideline (listed in Table D-1 and Table D-3 in parentheses). Many of these 

equivalents are listed in the Federal Register at 63 FR 41847, August 5, 1998. In some cases the test 

protocol itself states that it is essentially equivalent to another test upon which it was based. Sometimes 

judgment was needed to select the closest equivalent(s). 

In some cases, EPA has not costed out the test for the species, route, duration, and/or other method listed 

in the SNUR, or the SNUR specifies a guideline but does not specify these details. In such cases, EPA has 

made the adjustments described below. The adjustments were selected based on discussions with EPA 

scientists and on SNUR language, published test guidelines, assumptions underlying the cost estimates in 

EPAB's test cost database, EPA review and Consent Order history for specific PMNs, or other sources. 

4.1.1 Default Parameters

Costs for many of the guidelines have been estimated for different combinations of species, route, length 

of study and other aspects of methodology, but in some cases the SNUR may not specify all of these 

variables. Where this occurs, EPA has used certain default parameters, listed in Table D-2. 

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Table D-2 Default Parameters for Species, Route, and Study Type

Variable Default

Species Mammals

Fish

Invertebrates

Algae

Rats

Fathead minnow1

Daphnids

[Four species -- see text]

Route/Method Mammalian

Fish

Invertebrates

Gavage

Flow-through

Flow-through

Notes: 

1

For guideline 850.1400 tests also in PBT tier tests, rainbow trout is the default species. (See PBT discussion 

below.)

4.1.2 SNUR Testing Tiers

A SNUR may recommend tiered testing. In such cases, costs are lower if only the first-tier tests are 

performed, and higher if all tests listed for the chemical are performed. Testing is “tiered” if later tests are 

contingent on the results of earlier tests, and/or if some tests are contingent on the firm reaching a certain 

chemical volume or time limit. Some tiers are explicit in the SNUR text; others result because the SNUR 

references the tiered PBT Category testing described at 64 FR 60194. 

4.1.3 Test Cost Assumptions and Comments

This section explains treatment of certain tests listed in this or past SNUR rulemakings.

 A SNUR may recommend algal acute toxicity testing according to OPPTS Guideline 850.5400. 

This guideline has been previously costed by EPA for four separate algal species (Navicula 

pelliculosa, Skeletonema costatum, Anabaena flos-aquae, and Selenastrum capricornutum). If a 

SNUR does not specify the algal species to be used, the average costs of the four algal species 

tests are used.

 For OPPTS test guideline 835.3100 (Aerobic Aquatic Biodegradation), a SNUR may call for an 

additional analytical methodology to identify the isononyl phenol degradation product, which 

may be a substantial add-on to the basic cost. Table D-1 gives costs for 835.3100 but not for the 

extended test. 

 A SNUR may recommend a “modified” version of ASTM test guideline D2035-80 (CoagulationFlocculation Jar Test of Water). Table D-1 gives costs for D2035-80 but not for the additional 

analytical methodology. 

 For test guideline OECD 422 (Combined Repeated Dose Oral Toxicity with Reproductive/ 

Developmental Toxicity Screening), a SNUR may recommend extended histopathology. 

Although the OECD 422 protocol does include histopathology, it is possible that extending the 

histopathology would increase the cost beyond that shown in Table D-1.

 A SNUR may recommend two variations of test guideline OECD 218 (Chironomid Sediment 

Toxicity), one using the acute portion of the sediment and the other using the chronic portion. 

Costs were not determined for these two variants. The cost of the test performed on midge under 

flow through conditions was used for both.

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 A SNUR may recommend “a fish acute toxicity test, freshwater and marine (OPPTS 850.1075 

test guideline)”. “Freshwater and marine” refers to the name of the test, not the number of species 

required by EPA. The cost estimates assume only one species is used.

4.1.4 Persistent Bioaccumulative Toxic (PBT) tiered testing

A SNUR may cite tiered testing for Persistent Bioaccumulative Toxic chemical substances (PBTs) 

according to the testing strategy in EPA’s New Chemicals Program PBT Category document, published 

in the Federal Register notice, Category for Persistent, Bioaccumulative, and Toxic New Chemical 

Substances, November 4, 1999, at 64 FR 60194. 

In 64 FR 60194, there are three tiers of testing. The results of Tier 1 determine whether Tier 2 testing is 

needed and the results of Tier 2 testing determine whether Tier 3 testing is needed. Table D-3 lists the 

tests in the PBT category document. These tests are also listed in Table D-1.

To obtain a cost estimate for SNURs that cite PBT Category testing (64 FR 60194), costs of individual 

tests from 64 FR 60194 would have to be added up as appropriate, depending on the specific SNUR 

language. The test list would also need to be adjusted to avoid double counting tests listed in the SNUR 

both explicitly by guideline number, and implicitly due to their inclusion in PBT Category tiers. 

Other assumptions related to PBT testing are described below:

 The PBT category tests at 64 FR 60194 specify rainbow trout as the species for the chronic fish 

toxicity test, 850.1400. For SNURs that recommend PBT Category testing, 850.1400 costs would 

be based on using rainbow trout. If 850.1400 is recommended without PBT testing, costs would 

be based on using fathead minnows.

 For PBT Tier 1 ready biodegradability tests, firms may either choose among six methods in test 

guideline 835.3110 or follow test guideline 835.3120. The cost of 835.3110 is calculated as the 

average cost of its six possible methods. The cost estimates assume an equal chance of using 

either 835.3110 or 835.3120. 

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Table D-3 Persistent Bioaccumulative Toxic (PBT) Tiered Testing Requirements

PBT 

Tier Guideline Test Cost2010$

1

OPPTS 830.7560*

-orOPPTS 830.7570*

Partition Coefficient (n-Oct/Water), Generator Column method

-orPartition Coefficient (n-Oct/Water), Liquid Chromatography method

Average

$7,506

$4,940

$6,223

1 OPPTS 835.2110 Hydrolysis as a Function of pH $59,465

1

OPPTS 835.3110

-orOPPTS 835.3120

Ready Biodegradability (choose one of 6 methods; cost is average of the 6)

-or-

[Ready biodegradability] Sealed-vessel CO2 Production Test

Average

$12,759

$7,912

$10,336

2 OPPTS 835.3170 Shake-flask Die-away Test [measures biodegradability] $52,029

2 OPPTS 850.1730 Fish Bioconcentration $152,822

3 OPPTS 835.3180 Sediment/Water Microcosm Biodegradation $136,045

3

40CFR 797.1330 

or 850.1300** Daphnid Chronic Toxicity Test $136,977

3

40CFR 797.1600 

or 850.1400** Fish Early Life Stage Toxicity (in rainbow trout) $69,853

3 OECD 422 Combined Repeated Dose Oral Toxicity with Reproductive/ Developmental 

Toxicity Screening (in rats)

$137,531

Total cost, all tiers (assuming all tests are conducted) $761,280

Source: 64 FR 60194, Category for Persistent, Bioaccumulative, and Toxic New Chemical Substances, November 

4, 1999, at http://www.epa.gov/EPA-TOX/1999/November/Day-04/t28888.htm. Tests costs are from Table D-1. 

* The PBT FR notice cites 830.7560 and 830.7570. This table used costs for similar tests 796.1720 and 796.1570, 

respectively. Tests 830.7550 (Partition Coefficient using Shake Flask method) and “the new ‘slow-stir’ method 

currently under development by the OECD” are also mentioned as options for determining the Oct/Water partition 

coefficient, in the PBT FR notice Response to Comments but not in the main Testing Strategy discussion. 

** PBT FR notice cites both tests as equivalents. This table uses costs for 850.1300 and 850.1400 since they were 

costed out more recently by EPA.

Testing Costs by Chemical 

Test costs attributable to a SNUN are likely to be much lower than the costs that would be implied by 

adding up costs of all of the testing recommended in the SNUR for that chemical, and usually are zero.31

See the main text of this report for a discussion of testing. 

 

31 A prior SNUR economic analysis calculated chemical-specific test costs (EPA, 2007b, Table D-4). The 

chemical-specific table was dropped from a later SNUR economic analysis (EPA, 2007c). 

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29, November 25, 1983.

63 FR 41847. Test Guidelines; Notice of Availability, Federal Register, Volume 63, August 5, 1998.

64 FR 60914. Category for Persistent, Bioaccumulative, and Toxic New Chemical Substances, Federal 

Register, Volume 64, November 8, 1999. 

71 FR 6733. Export Notification; Proposed Change to Reporting Requirements, Federal Register, 

Volume 71, February 9, 2006. Available from the Federal Docket Management System as 

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75 FR 773. TSCA Section 5 Premanufacture and Significant New Use Notification Electronic Reporting; 

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