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Economic Analysis of the Final Significant New Use Rule for MercuryContaining Barometers, Manometers, Hygrometers, and Psychrometers 

(EPA Docket EPA-HQ-OPPT-2010-0630)

Final - March 26, 2012

—Does not contain TSCA CBI—

RIN 2070-AJ71

Prepared by:

Economic and Policy Analysis Branch

Economics, Exposure and Technology Division

Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460
This Page was Intentionally Left Blank.
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products i Economic and Policy Analysis Branch

CONTRIBUTORS

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

support was provided by Abt Associates Inc. under EPA Contract No. EP-W-08-010.
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products ii Economic and Policy Analysis Branch

ABSTRACT

This report estimates the costs of the U.S. Environmental Protection Agency (EPA)‟s final Significant 

New Use Rule (SNUR) that applies to the significant new use of elemental mercury (CAS 7439-97-6) in 

three mercury-containing products: 1) barometers; 2) hygrometers/psychrometers, except batterypowered, motor-aspirated psychrometers containing less than 7 grams of elemental mercury;

1

and 3) 

manometers.2

The final SNUR applies to all manufacturing, import, and processing of elemental mercury for use in

these three mercury-containing products (excluding the specified psychrometers). The three mercurycontaining products subject to the SNUR are believed to no longer be manufactured in or imported into

the United States and are considered “legacy products” by the Interstate Mercury Education and 

Reduction Clearinghouse (IMERC), with the exception of battery-powered, motor-aspirated 

psychrometers containing less than 7 grams of elemental mercury, which are still manufactured in the 

United States. Legacy products are defined by IMERC as products that are not sold as new, but may still 

be in use, resold as used or antique, or stored in homes or businesses.3 All three products currently have 

viable and cost-effective mercury-free substitutes. Because the three mercury-containing products subject 

to the SNUR are not manufactured, and feasible mercury-free alternatives are widely available, the final 

SNUR is not expected to have any economic impact.

The three mercury-containing products subject to the final SNUR are all applications of barometers,

manometers and hygrometers/psychrometers (excluding the specified psychrometers). All three products

subject to the SNUR currently have effective and economically feasible mercury-free substitutes, and are 

no longer manufactured in United States.

4 Manometers are used to measure air, gas, and liquid pressure, 

in the automotive, dairy, and heating, ventilating, and air conditioning (HVAC) industries. There are 

viable mercury-free alternatives for almost all uses of manometers, including digital manometers, 

bourdon tube manometers, aneroid manometers, and hydrostatic gauges. Barometers are instruments used 

to measure atmospheric pressure. Current mercury-free alternatives for barometers include aneroid 

barometers, electronic barometers, and other liquid-based barometers. Hygrometers/psychrometers are 

used to measure the moisture content, or humidity, of air or gas. There are two available and widely used 

alternatives to mercury-filled hygrometers/psychrometers: spirit-filled products and digital products. 

The final SNUR requires persons to notify EPA at least 90 days before commencing the manufacture,

import, or processing of elemental mercury for any significant new use as described in the SNUR. A firm 

intending to engage in these activities is required to submit a Significant New Use Notice (SNUN). EPA 

is promulgating the SNUR because of health and environmental concerns about mercury use. Because the

three specified mercury-containing products subject to the SNUR are not currently manufactured in the 

United States, it is important that EPA is notified if a company chooses to produce, import, or process 

elemental mercury for use in any of these products. The SNUN provides EPA with the opportunity to 

evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs.

To submit this SNUN, a firm incurs a modest submission cost of $8,334 and potentially other minor 

costs. However, because no firms are currently importing, manufacturing, or processing elemental

 

1

Psychrometers are the most common type of hygrometer; while they function similarly, they have historically been 

used in different applications and so have different naming conventions. See Section 2 for more details.

2 Because EPA cannot regulate articles containing a chemical under TSCA Section 5, the SNUR applies to 

elemental mercury used in these products. EPA will not be notified if there is import of mercury-containing 

barometers, hygrometers, or manometers.

3 These devices may still be in use, resold in the aftermarket, or stored in homes and businesses. 

4

Portable, battery-powered, motor-aspirated psychrometers containing less than 7 grams of elemental mercury

continue to be manufactured in the United States, and are not subject to the SNUR.
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products iii Economic and Policy Analysis Branch

mercury for any significant new uses, it is highly unlikely that any firm will incur this cost. EPA does not 

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

already in its possession or describe any other available data. Because EPA does not require the 

development of test data, EPA assumes that no firms will incur testing costs as a result of the SNUR.

In addition to the firms that make a SNUN submission, the final SNUR may also impact firms that do not 

make a submission. By avoiding a significant new use, a firm can avoid submission costs but may incur 

other compliance costs. However, this may not be a concern given that there are no current manufacturers 

of these three products.

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

submission. 
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products iv Economic and Policy Analysis Branch

TABLE OF CONTENTS

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

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

LIST OF TABLES........................................................................................................................................v

1. INTRODUCTION ................................................................................................................................1

1.1 Statutory Authority.....................................................................................................................1

1.2 Summary of Methodology..........................................................................................................1

1.3 Organization of this Report ........................................................................................................1

2. POTENTIALLY AFFECTED ENTITIES............................................................................................2

2.1 Historic Uses of and Alternatives to Mercury-Containing Barometers, 

Hygrometers/Psychrometers, and Manometers..........................................................................2

Barometers..................................................................................................................................2

Hygrometers/Psychrometers.......................................................................................................2

Manometers................................................................................................................................3

2.2 Potentially Affected Entities.......................................................................................................3

Barometers..................................................................................................................................3

Hygrometers/Psychrometers.......................................................................................................4

Manometers................................................................................................................................4

3. INDUSTRY COMPLIANCE COSTS ..................................................................................................5

3.1 Wage Rates.................................................................................................................................6

3.2 Unit Industry Compliance Costs.................................................................................................6

3.2.1 Rule Familiarization ......................................................................................................6

3.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup................7

3.2.3 Form Completion and Submission Fee..........................................................................8

3.2.4 Import Certification .......................................................................................................9

3.2.5 Export Notification ......................................................................................................10

3.3 Industry Costs of SNUR, by Option (per Submission).............................................................12

3.4 Likelihood of a SNUN Submission ..........................................................................................13

3.5 Potential for Subsequent Regulatory Action ............................................................................13

4. AGENCY COSTS...............................................................................................................................14

4.1 Labor Rates for EPA Staff........................................................................................................14

4.2 SNUN Processing Costs...........................................................................................................15

4.3 Export Notification Cost...........................................................................................................18

5. ADDITIONAL ANALYSES..............................................................................................................19

5.1 Small Entity Impacts.................................................................................................................19

5.2 Unfunded Mandates..................................................................................................................19

5.3 Paperwork Reduction Act.........................................................................................................19

5.4 Technical Standards..................................................................................................................20

5.5 Regulatory Planning and Review .............................................................................................20

5.6 Environmental Justice...............................................................................................................20

5.7 Protection of Children...............................................................................................................20

5.8 Federalism ................................................................................................................................20

5.9 Tribal Governments..................................................................................................................20

5.10 Effect on Energy Supply, Distribution, or Use.........................................................................20

6. REFERENCES....................................................................................................................................21
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products v Economic and Policy Analysis Branch

LIST OF TABLES

Table 1: Loaded Industry Wage Rates, December 2010...............................................................................6

Table 2: Rule Familiarization Burden and Cost for SNUR Submitters........................................................7

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

First-Time Submitters...................................................................................................................................8

Table 4: Industry Cost Estimate to Complete the SNUN Form....................................................................9

Table 5: Industry Cost Estimate to Complete and Submit the SNUN Form.................................................9

Table 6: Derivation of Total Mailing Cost for 12 Notices..........................................................................11

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

Table 8: Compliance Options and Associated Costs Incurred by a Firm Due to the Final SNUR.............13

Table 9: Derivation of Loaded Agency Wage Rates ..................................................................................15

Table 10: Derivation of Inflation Factors for Agency Extramural Costs....................................................16

Table 11: Agency Costs for SNUN and Other Submission Review and Processing..................................17

Table 12: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2010$)...........................18
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 1 Economic and Policy Analysis Branch

1. INTRODUCTION

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

Toxics‟ (OPPT‟s) analysis of the potential costs incurred as a result a final Significant New Use Rule 

(SNUR) that addresses the use of elemental mercury (CAS 7439-97-6) in three products: 1) barometers,

2) hygrometers/psychrometers, and 3) manometers. Portable, battery-powered, motor-aspirated 

psychrometers containing less than 7 grams of elemental mercury continue to be manufactured in the 

United States, and are not subject to the final SNUR. SNURs are promulgated by EPA under the authority 

granted by Section 5(a)(2) of the Toxic Substances Control Act (TSCA). The final SNUR requires

persons to notify EPA at least 90 days before commencing the manufacture, import, or processing of 

elemental mercury for manometers, barometers and hygrometers/psychrometers (excluding the specified 

psychrometers). EPA promulgates a SNUR for a substance when potential uses could result in increased 

exposure to or releases of the substance and in turn, could present an unreasonable risk to health or the 

environment.

1.1 Statutory Authority 

Section 5(a)(2) of TSCA (15 U.S.C. 2604(a)(2)) authorizes EPA to determine that a use of a chemical 

substance is a “significant new use.” EPA must make this determination by rule after considering all 

relevant factors, including those listed in TSCA section 5(a)(2). Once EPA determines that a use of a 

chemical substance is a significant new use, TSCA section 5(a)(1)(B) requires persons to submit a 

Significant New Use Notice (SNUN) to EPA at least 90 days before manufacturing, importing, or 

processing the chemical substance for that use (15 U.S.C. 2604(a)(1)(B)).

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

1.2 Summary of Methodology

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

costs to industry associated with performing the required reporting and recordkeeping, and the costs to 

EPA of administering the rule. Industry costs consist of rule familiarization; registration with the Central 

Data Exchange (CDX) electronic reporting tool; collection, compilation, and submission of required 

information for significant new uses of the subject chemicals; export 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.

1.3 Organization of this Report

The remainder of this report provides EPA‟s economic analysis in support of the final rule. The chemical 

substances and industry sectors potentially affected are characterized in Chapter 2. Chapter 3 contains 

estimates of the industry cost of complying with the final rule, and Chapter 4 shows estimates of the 

government costs associated with the administration of the final rule. Chapter 5 presents additional impact 

analyses.

Note that dollar amounts in this analysis are reported in 2010 dollars for industry costs and for agency 

costs. 
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 2 Economic and Policy Analysis Branch

2. POTENTIALLY AFFECTED ENTITIES 

The final SNUR applies to all manufacturing, import, and processing of elemental mercury for use in 

mercury-containing barometers, manometers, and hygrometers/psychrometers (excluding portable, 

battery-powered, motor-aspirated psychrometers containing less than 7 grams of elemental mercury). 

None of the three mercury-containing products subject to the SNUR are believed to be manufactured,

imported, or process in the United States,

5

and are considered “legacy products” by the Interstate Mercury 

Education and Reduction Clearinghouse (IMERC).6 Legacy products are defined by IMERC as products 

that are not sold as new, but may still be in use, resold as used or antique, or stored in homes or 

businesses. 

The following sections describe the specific historic uses of each of the three specified mercurycontaining products, the substitutes for each product, and the potentially affected industry sectors. 

Because the manufacture of the three mercury-containing products subject to the SNUR has ceased in the 

United States, we assume that there is no import of elemental mercury for these uses. 

2.1 Historic Uses of and Alternatives to Mercury-Containing Barometers, 

Hygrometers/Psychrometers, and Manometers

Barometers

Barometers are instruments used to measure atmospheric pressure, and consist of a long cylindrical tube, 

typically closed at one end, with a mercury-filled reservoir at the base. The weight of mercury creates a 

vacuum at the top of the tube, and the mercury adjusts until the pressure inside the reservoir equals 

atmospheric pressure. Rising mercury indicates increasing air pressure while dropping mercury indicates 

decreasing air pressure (IMERC, 2010b, 2009b and Maine DEP, 2003). Historically, barometers have 

primarily been used in weather forecasting applications (IMERC 2008c).7 Additional uses include 

scientific demonstration in schools and non-mercury device calibration (IMERC, 2007, DEPA, 2006). A 

mercury barometer contains between 400 and 620 grams of mercury (IMERC, 2010b).

Alternatives to mercury-containing barometers include aneroid barometers, electronic barometers (which 

use vibrating cylinder air pressure transducers, electronic resistance or capacitance), and other liquidbased (water or eco-celli) barometers.8

Hygrometers/Psychrometers

Hygrometers are used to measure the moisture content, or humidity, of air or gas. A psychrometer, the 

most common type of hygrometer, uses two mercury-added thermometers, one with a wetted base, and 

 

5 However, it is possible that these three may still be in use, resold as used or antique, or stored in homes or 

businesses. 

6

IMERC requires that all companies planning to sell mercury-containing products under the jurisdiction of its 

member states (California, Connecticut, Illinois, Louisiana, Maine, Massachusetts, Minnesota, New Hampshire, 

New Jersey, New York, North Carolina, Rhode Island, Vermont, and Washington) submit a notification to the 

clearinghouse every three years. However, because IMERC does not cover all states, its totals may not represent the 

entire universe. The only exception to this finding is mercury-containing psychrometers for which we found one 

manufacturer (Belfort, 2010).

7 Electronic instruments connected are now commonly used to take barometric readings (Columbia Encyclopedia 

2010).

8

Since water is lighter than mercury, it moves a greater distance in response to a given pressure change. As a result, 

the water barometers are large, bulky, and thus, seldom used (Maine DEP, 2003). Eco-celli barometers use a nontoxic silicon-based fluid in conjunction with a gas, and leverage the compressibility of gas in relation to gravity. 

Since changes in temperature can cause the liquid to expand, a thermometer is attached so that the necessary 

adjustments can be made to the scale (IMERC, 2007).
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 3 Economic and Policy Analysis Branch

one with a dry base. Hygrometers and psychrometers function similarly but have historically been used in 

different applications: hygrometers are used for cigar and tobacco humidors, or in residential settings 

where humidity is monitored to prevent the growth of mildew or dust mites; psychrometers are used by 

atmospheric scientists and weather enthusiasts (IMERC, 2010a). Mercury-added 

hygrometers/psychrometers contain between 3 and 7 grams of mercury (Environment Canada, 2004). 

There are two types of alternatives to mercury-added hygrometers/psychrometers that are readily 

available and widely used: spirit-filled products, which use methyl alcohol or citrus oil thermometers and

provide results with comparable accuracy to mercury-added thermometers; and digital products, which 

use electronic sensors to measure humidity changes and, when calibrated properly, provide as accurate 

results as mercury products (Maine DEP, 2003, IMERC, 2010b).

EPA found sufficient information to conclude that only one type of mercury-containing 

hygrometer/psychrometer is manufactured in or imported into the United States. Portable, batterypowered, motor-aspirated psychrometers containing less than 7 grams of elemental mercury continue to 

be manufactured in the United States.9EPA is considering whether risk management or other actions 

would be appropriate for the one type of psychrometer that is still in use. 

Manometers

Manometers are used to measure air, gas, and liquid pressure. While these instruments come in a variety 

of shapes and sizes, the most common mercury manometer design is a U-shaped tube. One end is left 

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

measured is higher than atmospheric pressure, the liquid moves toward the open end of the tube. If the 

pressure measured is lower, it moves away from the open end. The difference between the levels of 

mercury provides a reading relative to atmospheric pressure. Historical manometer uses include vacuum 

pressure measurement in natural gas pipelines,10 dairy cow milking systems (“dairy manometers”), the 

automotive industry, and the heating, ventilation, and air conditioning (HVAC) industry. Depending on 

the application, the amount of mercury in a manometer may range from 30 to 525 grams (IMERC, 2010b, 

VT Agricultural Agency, 2001; WI DNR, 2007).11

There are viable mercury-free alternatives for almost all uses of manometers. There are several mercuryfree technologies in the dairy industry (digital manometers, bourdon tube manometers, and aneroid 

manometers), automobile industry (hydrostatic gauges) and the heating, ventilation and air conditioning 

(HVAC) industry (hydrostatic gauges and bourdon tube manometers).

2.2 Potentially Affected Entities

Because the three mercury-containing products subject to the SNUR are believed to no longer be 

manufactured in or imported into the United States, there are likely to be no entities affected by the final

SNUR. The following summarizes the research undertaken as part of this decision-making process.

Barometers

Princo Instruments, the sole barometer manufacturer reporting use of mercury to IMERC in 2001 and 

2004, phased-out manufacturing mercury-added measuring products in January, 2007 (IMERC, 2010b). 

 

9 A phone conversation with a customer service representative at the Belfort Instrument Company on April 27, 2010 

confirmed the manufacture of at least one model of mercury-containing psychrometer (Belfort, 2010). 

10 Based on information that use of mercury in natural gas manometers has ceased, on July 21, 2010, promulgated a

TSCA §5(a)(2) significant new use rule (SNUR) requiring persons to notify EPA 90 days prior to manufacture, 

import, or processing of elemental mercury for natural gas manometers, except when the articles are in service as of 

the effective date of the final rule. 75 FR 42330, July 21, 2010.

11 Natural gas manometers may contain several kilograms of mercury (Schleifstein, 2007).
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 4 Economic and Policy Analysis Branch

Internet queries did not identify any current manufacturer of mercury-added barometers. This research 

suggests that the manufacture of mercury-containing barometers has been phased out.12

Hygrometers/Psychrometers

IMERC reports that the quantity of mercury sold in hygrometers/psychrometers decreased from 0.0018 

metric tons in 2001 to 0.0009 metric tons in 2007; however, the 2007 value actually equals zero because 

IMERC categorizes “other measuring equipment” with hygrometers/psychrometers, and both 

manufacturers who reported sales of mercury-containing hygrometers/psychrometers to IMERC in either 

2001 or 2004 (Princo Instruments, Inc. and Taylor Precision Products L.P.) have reported that they have 

phased out the use of mercury (IMERC, 2010b).

13

Manometers

All manufacturers who had reported historical manufacture of mercury-containing manometers to IMERC

in either 2001 or 2004 have since phased out use of mercury in their products (IMERC, 2010b).14 Phone 

conversations with five additional companies (Ashcroft Inc., Dwyer Instruments, Dynisco Instruments, S 

J Electro Systems, Inc., and McMaster-Carr) identified through 1) online queries for pressure 

measurement devices, and 2) a search of Dun & Bradstreet database under the relevant NAICS code15

indicated that none made or sold mercury-containing manometers (Ashcroft Inc., 2010; Dwyer 

Instruments, 2010; Dynisco Instruments, 2010; S J Electro Systems, Inc.; and McMaster-Carr, 2010). As 

a result, EPA believes that manufacturing of mercury-containing manometers have been phased-out.

 

12 Barometers may still be found in secondary markets; in fact, some state bans provide exemptions for antique 

barometers. 

13 A phone conversation with a customer service representative at the Belfort Instrument Company on April 27, 

2010 confirmed the manufacture of at least one model of mercury-containing psychrometers, therefore these were 

excluded from the SNUR (Belfort, 2010).13

14 Scientific Glass & Instruments, which reported the sale of mercury-containing manometers to IMERC in 2001 and 

2004, reported to IMERC that they only produce the glass component and do not fill the manometer with mercury.

15 NAICS 334512: Automatic Environmental Control Manufacturing for Residential, Commercial, and Appliance 

Use.
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 5 Economic and Policy Analysis Branch

3. INDUSTRY COMPLIANCE COSTS

The final SNUR discussed in this report specifies that significant new uses of mercury that require 

reporting under section 5(a)(2)(A) of TSCA include the manufacture, import, or processing of elemental 

mercury for use in: 1) barometers, 2) manometers, and 3) hygrometers/psychrometers. Not included in 

this SNUR is mercury use in portable, battery-powered, motor-aspirated psychrometers containing less 

than 7 grams of elemental mercury because they are currently manufactured.16 Therefore, a firm intending 

to manufacture, import, and/or process elemental mercury for the previously specified products, must 

submit a SNUN. Alternatively, a firm can decide not to manufacture, import, and/or process the chemical

for a significant new use. The firm, therefore, has two options:

Option 1: Submit a SNUN. A SNUN indicates to EPA that the firm would like to manufacture, 

import, and/or process the chemical for a significant new use, which, in this case, means any 

manufacture, importing, and/or processing of this chemical or articles containing the chemicals. The 

firm must submit the SNUN to EPA at least 90 days before it plans to commence the manufacture, 

import, and/or processing of the substance; the SNUN provides EPA with the opportunity to evaluate 

the intended use and, if necessary, to prohibit or limit that activity before it occurs. If EPA allows the 

manufacture, import, or processing of mercury for use in the three products subject to the SNUR, then 

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

if there is any export of these products, the export notification costs that result from TSCA Section 

12(b) requirements that are automatically triggered for chemicals regulated under TSCA Section 5

(see Section 3.2.5 for details). Because the three products subject to the SNUR are not currently 

manufactured or imported into the United States, EPA expects that no firms will choose this option. 

Option 2: Decide not to manufacture, import, and/or process the chemical. The firm may simply 

decide to not manufacture, import, or process mercury for use in the three products subject to the final 

SNUR. While this option avoids the costs of submitting a SNUN, it entails the “hidden” cost of the 

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

the firm would have used a given amount of mercury for use in the production of one of the three 

products subject to the SNUR, it may substitute mercury with a more costly substance and will incur 

those additional “hidden” costs of production. However, these hidden costs are expected to be 

minimal, if not zero, because the manufacture of the mercury-containing products subject to the 

SNUR has phased out, and firms have begun to produce substitutes for the products prior to the 

SNUR. If the firm elects to produce mercury for use in the three products subject to the SNUR for 

research and development (R&D) purposes only (an exemption for R&D purposes is provided in 40 

CFR §721.47), it may have costs associated with R&D recordkeeping. In addition, if the firm exports 

any existing stockpiles of the specified mercury-containing products, it will incur the export 

notification costs (see Section 3.2.5 for details). 

Since the products subject to the SNUR are not currently manufactured in the United States, EPA does 

not expect there to be compliance costs associated with either of the options. The remainder of this 

chapter estimates the quantified portion of costs associated with the final SNUR for these uses of the 

elemental mercury. Section 3.1 summarizes the wage rates used in this chapter. Section 3.2 provides the 

unit industry compliance costs, including the costs of rule familiarization, registration with the Central 

Data Exchange (CDX) electronic reporting tool, completing the SNUN form, submission fee, import 

certification, and export notification. Total costs under each option are presented in Section 3.3. 

 

16 A phone conversation with a customer service representative at the Belfort Instrument Company on April 27, 2010 

confirmed the manufacture of at least one model of mercury-containing psychrometer (Belfort, 2010). 
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 6 Economic and Policy Analysis Branch

3.1 Wage Rates

The final rule involves activities that may require efforts by employees in three labor classifications: 

managerial, technical, and clerical. Costs for each activity are calculated by estimating the labor hours 

required in each labor category and multiplying those burdens by the wage rate for each labor category. 

This section presents the estimated wage rate in each labor category.

Loaded wage rates for managerial, technical, and clerical personnel are derived by combining data on 

wages and fringe benefits with estimates of overhead rates, following the methodology described in 

“Wage Rates for Economic Analysis of the Toxics Release Inventory Program” (EPA, 2002b). Wage data 

for each labor category in December 2010 are provided by the Employer Costs for Employee 

Compensation (ECEC) Supplemental Tables available on the BLS website (BLS, 2011a). The loaded 

wage rate for managerial labor is $69.74; for technical labor, $61.71; and for clerical labor, $28.98. Table 

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

Table 1: Loaded Industry Wage Rates, December 2010

Labor 

Category Data Sources Date

Wage

(2010$)

Fringe 

Benefit

(2010$)

Fringes 

as % 

wage

Overhead % 

wage2

Fringe + 

overhead 

factor

Loaded 

Wages1

(2010$)

(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

12/10 $42.82 $19.64 45.87% 17% 1.63 $69.74

Professional/

Technical

BLS ECEC, Private 

Manufacturing industries, 

“Professional and related“3

12/10 $36.93 $18.50 50.09% 17% 1.67 $61.71

Clerical

BLS ECEC, Private 

Manufacturing industries,

“Office and Administrative 

Support” 3

12/10 $17.36 $8.67 49.94% 17% 1.67 $28.98

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

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

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

2002a).

3 Employer Costs for Employee Compensation Supplementary Tables December 2010, U.S. Bureau of Labor Statistics, March 9, 

2011 (BLS, 2011a).

3.2 Unit Industry Compliance Costs

3.2.1 Rule Familiarization

The final rule requires submitters and their staff to become familiar with the SNUR and its various 

requirements. The per company burden associated with rule familiarization is approximately 0.55 hours 

of technical labor and 0.27 hours of managerial labor, as described in the Economic Analysis of the 

Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009b). As shown in Table 2 the 

total labor cost associated with rule familiarization by a first-time reporter is $52.54.
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 7 Economic and Policy Analysis Branch

Table 2: Rule Familiarization Burden and Cost for SNUR Submitters

Reporting Activity

Clerical Labor (at 

$28.98/hour)

Technical Labor (at 

$61.71/hour)

Managerial Labor 

(at $69.74/hour)

Total Labor Cost

Burden

(hours)

Cost

(2010$)

Burden

(hours)

Cost

(2010$)

Burden

(hours)

Cost

(2010$)

Burden

(hours)

Cost

(2010$)

Rule Familiarization 0.00 $0.00 0.55 $33.94 0.27 $18.60 0.82 $52.54

Total 0.00 $0.00 0.55 $33.94 0.27 $18.60 0.82 $52.54

Source: BLS, 2011a (labor rates); EPA, 2009b (burden hours)

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

The final SNUR requires first-time submitters (that is, those companies who have not submitted 

information to EPA through CDX before) to register their company and key users with the CDX reporting 

tool, deliver a CDX electronic signature to EPA, and establish and use a Pay.gov E-payment account.

17. 

These activities are only required of first-time submitters (companies already registered with CDX do not 

need to re-register for the purposes of complying with the final SNUR). The burdens associated with 

these activities were estimated in the Economic Analysis of the Premanufacture Notification Electronic 

Reporting Final Rule (EPA, 2009b) and are described in more detail below:

CDX registration: EPA estimates that companies will spend approximately 0.18 hours per 

employee to register with CDX, and that an average of four technical staff members and one 

manager will need to register for each company, totaling approximately 0.92 hours of burden per

company.

CDX electronic signature: EPA estimates that companies will spend 0.25 hours preparing, 

submitting, and filing an electronic signature agreement (Authentication of Identity) form to EPA 

per employee. This burden will apply to four technical staff members and one manager per 

company, totaling to 1.25 hours of burden per company. In addition, EPA estimates that a 

manager will spend an additional 0.50 hours accessing, preparing, and submitting verification 

forms (Verification of Authorization) for all authorized submitters to EPA. The total burden 

incurred by companies submitting and then verifying electronic signature agreements is 1.75 

hours. Note that this burden does not include any additional time required to contact EPA‟s CDX 

help desk to notify a change of submitter status, should one occur. 

Filing the electronic signature agreement requires an additional mailing cost of $2.30 per 

company (including five $0.44 stamps and five $0.02 business envelopes) (USPS, 2010).

Payment via Pay.gov account: EPA estimates that one manager per company will spend 

approximately 0.13 hours setting up a Pay.gov ID account, logging into the system, finding the 

appropriate form, and filling it out. This burden does not include the time required to click 

„submit‟ on the form and wait for payment processing.

As shown in Table 3, the cost associated with CDX registration, CDX electronic signature, and Pay.gov 

account setup is $184, and this cost is only incurred by a first-time submitter.

 

17 Although the proposed rule does not specifically require submitters to establish and use a Pay.gov account, the 

burden estimates in this analysis are conservative insofar as to include the use of Pay.gov as a required activity.
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Table 3: CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup Burden 

and Cost for First-Time Submitters

Reporting Activity

Clerical Labor (at 

$29.98/hour)

Technical Labor (at 

$61.71/hour)

Managerial Labor 

(at $69.74/hour) Total Cost

Burden

(hours)

Cost

(2010$)

Burden

(hours)

Cost

(2010$)

Burden

(hours)

Cost

(2010$)

Burden

(hours)

Cost

(2010$)

CDX Registration 0.00 $0.00 0.73 $45.25 0.18 $12.78 0.92 $58.03 

CDX Electronic 

Signature 0.00 $0.00 1.00 $61.71 0.75 $52.30 1.75 $114 

Mailing Cost $2.30

E-Payment (Pay.gov

ID) 0.00 $0.00 0.00 $0.00 0.13 $9.30 0.13 $9.30 

Total 0.00 $0.00 1.73 $107 1.07 $74.38 2.80 $184

Source: BLS, 2011a (labor rates); EPA, 2009b (burden hours); USPS, 2010 (mailing cost)

3.2.3 Form Completion and Submission Fee

Respondents are required to gather and submit information regarding the data elements identified in the 

applicable SNUN reporting form. The methodology and calculations used in this analysis assume that the 

employee responsible for collecting, filling out, and submitting the requested information has a 

reasonable level of familiarity with the company and knowledge of operations at the site. It is assumed 

that for most entities these tasks are similar to other employee duties that require familiarity with EPA, 

State, and other Federal agency requests for chemical information and do not require additional 

familiarization or training beyond the basic rule familiarization described above. In addition, this analysis 

focuses on the marginal costs of submitting information for the final rule and not the total costs for the 

company to comply with a range of other Federal and State environmental, health, and safety regulations 

or accounting requirements that rely on this type of information.

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

of completing a Premanufacture Notification (PMN) submission, since the data requirements are the same 

and the same form is used for both. The PMN submission costs are based on EPA's 1994 Regulatory 

Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications and the 

updates to these estimates in 2009 (EPA, 2009b). The original 1994 estimates relied on industry estimates 

of the effort needed to collect and compile all data required for a PMN submission, prepare the form, 

submit the form and data to EPA, and 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. These burdens 

“include the time spent reading and becoming familiar with the form, gathering the required information 

and preparing the report, producing sanitized responses for items claimed as confidential business 

information, and maintaining a file of the submission” (EPA, 1994. p. III 11-13). The burden associated 

with SNUN submission and preparation has been adjusted to reflect burden reductions resulting from the 

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

section 5 notices. Electronic submission of SNUN forms is expected to remove all clerical burden 

associated with preparing a SNUN and reduce the recordkeeping burden associated with SNUN 

submissions (EPA, 2009b, p.7). Because, the recordkeeping burden for PMNs was not estimated 
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Mercury Legacy Products 9 Economic and Policy Analysis Branch

separately, for the purposes of this report we assume this burden reduction is captured in the removal of 

all clerical burden.18

The 1994 RIA estimates that the burden to prepare, keep and maintain records, and submit a PMN is 

between 95 and 114 hours. Once the clerical burden is removed as a result of the ePMN rule, the total 

burden associated with preparing and submitting a PMN is reduced to 83 to 100 hours (EPA, 2009b). For 

this analysis, the midpoint burden is used. An additional 0.18 hours of technical time is added for the 

completion of the User Fee Payment Identification Number and email address data elements on the 

electronic SNUN form (EPA, 2009b), therefore the total burden of completing an electronic SNUN form 

is approximately 92.2 hours. Table 4 combines the estimated reporting burden and loaded wage rates for 

all three labor categories to estimate the per-SNUN cost of form completion. The labor cost incurred by a 

SNUN submission for both large and small business submitters is $5,834.

Table 4: Industry Cost Estimate to Complete the SNUN Form

Reporting Activity

Clerical Labor (at 

$28.98/hour)

Technical Labor (at 

$61.71/hour)

Managerial Labor 

(at $69.74/hour) Total Labor Cost

Burden

(hours)

Cost

(2010$)

Burden

(hours)

Cost

(2010$)

Burden

(hours)

Cost

(2010$)

Burden

(hours)

Cost

(2010$)

Form Completion 0.00 $0.00 74.2 $4,579 18.00 $1,255 92.2 $5,834 

Source: BLS, 2011a (labor rates); EPA, 2009b (burden hours)

In addition, each submitting large business must pay a $2,500 per-SNUN submission fee, and each 

submitting small business must pay a $100 per-SNUN submission fee. Table 5 adds the labor cost and 

submission fee to estimate the total cost of a SNUN submission. The total cost of a SNUN submission is 

$8,334 for large business submitters and $5,934 for small business submitters.

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

Reporting Population Labor Cost Submission Fee Total Cost 

(2010$)

Large Business Submitters $5,834 $2,500 $8,334 

Small Business Submitters $5,834 $100 $5,934 

Source: EPA, 2009b.

3.2.4 Import Certification

In general, promulgation of a final SNUR triggers a TSCA Section 13 import certification requirement 

and the corresponding regulations at 19 CFR 12.118 to 12.127 and 19 CFR 127.28 for all imports of the 

relevant chemical substances. Thus, any U.S. manufacturer, importer, or processor receiving an imported 

shipment of chemicals subject to the final SNUR will have to certify that all chemical substances in the 

shipment either comply with all applicable rules and orders under TSCA or that all chemical substances in 

 

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

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 in order to avoid double counting.
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the shipment are not subject to TSCA.19 The statement must be on or attached to a commercial invoice or 

entry document belonging to the imported shipment.

In practice, import certification is fulfilled by checking a box on an invoice or entry document and 

generally imposes no additional burden or cost on the importer (EPA, 2009c). Any potential burden 

associated with a submitter‟s familiarization with this requirement is assumed to be included in the more 

general SNUR familiarization burden discussed above.

3.2.5 Export Notification

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

an article subject to various TSCA sections (40 CFR §707.60 through 75). For TSCA 5(a)(2) (the section 

under which EPA promulgates significant new use rules) and certain other TSCA sections, this is a onetime notification requirement20 per 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. EPA then derived 

the annual and per notification burden associated with preparing and submitting an export notification. 

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

total number of exporters of elemental mercury for the uses subject to the SNUR, or the number of 

notifications per specified mercury-containing product. It is also important to note that the Mercury 

Export Ban Act of 2008 will forbid export of elemental mercury from the United States beginning in 

2013. Therefore, beyond 2013, there will be no export notification costs related to export of elemental 

mercury for these uses; the only cost will be if there is import of mercury-containing barometers, 

manometers and/or hygrometers/psychrometers. 

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, 2009c), with updating 

for inflation. 

Exporter Costs

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

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

the cost to the exporter of compiling a list of their products that are subject to TSCA Section 12(b) 

requirements, writing or revising an export notification letter to EPA, checking the outgoing shipments, 

and sending the notification letters with the associated shipping costs. 

 

19 The exact statements are as follows: For imports of chemical substances subject to TSCA, “I certify that all 

chemical substances in this shipment comply with all applicable rules or orders under TSCA and that I am not 

offering a chemical substance for entry in violation of TSCA or any applicable rule or order under TSCA.” For 

imports of chemical substances not subject to TSCA (e.g., pesticides), “I certify that all chemicals in this shipment 

are not subject to TSCA.” (40 CFR 707.20)

20 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). 
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The per-notification cost was calculated based on the assumption that the average exporter makes 12 

notifications per year.

21

 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.

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, 2010). The estimated per-shipment and annual 

mailing costs incurred by individual submitters are detailed in Table 6.

Table 6: Derivation of Total Mailing Cost for 12 Notices

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

Postal services costs

Registered mail, regular, with $0 declared value $10.60

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

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

Cost per export notice – Subtotal $13.34

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

method comes from the Economic Analysis of the Proposed Change to TSCA Section 12(b) Export Notification 

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

Compile and Maintain the List of Products. Since TSCA §12(b) information collection activity has been 

in place for twenty years, most respondents will have 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, 2009c). 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, 2009c).

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, or 0.08 hours per 

notification (EPA, 2009c).

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 (EPA, 

2009c). 

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

 

21 EPA calculated the average number of export notifications per exporter in the 2009 TSCA Section 12(b) ICR

(EPA, 2009d) by dividing the estimated number of submitted notifications (3,500) by the estimated number of 

exporters (300).
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Table 7: TSCA 12(b) Export Notification Cost per Notification

Technical Clerical Total

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

Compile list $61.71 0.78 $47.82 -- -- -- $47.82 0.78

Write letter $61.71 0.08 $5.14 -- -- -- $5.14 0.08

Check order and send 

notice -- -- -- $28.98 0.50 $14.49 $14.49 0.50

Mailing cost1-- -- -- $13.34 -

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

Notes:

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

2

Per notification costs are based on an average facility submitting notifications that is assumed to submit 12 export 

notifications per year.

Source: ICR No.: 0795.13 [Information Collection Request for] Notification of Chemical Exports - TSCA Section 

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

and are updated to 2010 dollars. 

3.3 Industry Costs of SNUR, by Option (per Submission)

The number of firms affected by not making submissions to EPA is not known; therefore, costs are not 

aggregated across the affected entities. Table 8 summarizes the costs to comply with the final rule, as 

described in more detail in section 3.2 above.
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Mercury Legacy Products 13 Economic and Policy Analysis Branch

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

Option1 Costs Quantified Costs per Chemical (2008$)2

1. Submit a 

SNUN.

Costs of submitting a SNUN, 

including rule familiarization, 

CDX registration (for 

companies that are first-time 

submitters), form completion, 

user fee, export notification, 

and any test costs, 

$52.54 rule familiarization cost; $8,334 submission cost 

(including SNUN recordkeeping and $2,500 fee). EPA 

usually receives well under ten SNUNs per year. Based on 

review of recent SNUNs, it appears that firms rarely 

conduct toxicity or fate testing to support a SNUN (such 

testing would be voluntary).3 Export notifications costs are 

estimated at $80.80 per notification; total cost per company 

will vary. First time submitters will incur $184 for CDX 

registration and associated activities.

2.

Decide not to 

manufacture, 

import, or 

process the 

chemical.

Cost of the profit foregone as 

a result of not engaging in the 

commercial activity originally 

planned, and recordkeeping 

costs only if manufacturing 

for research and development.

Costs not quantified. Rule familiarization and export 

notification costs may apply.

Notes:

1

Firms may be subject to both options at once since submission of a SNUN results in profits foregone as a result of 

not manufacturing, importing, or processing the chemical.

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

are detailed in Section 3.2.

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

already in its possession and/or describe any other available data. Because EPA does not require the development of 

test data, EPA assumes that no firms will incur testing costs as a result of the SNUR.

3.4 Likelihood of a SNUN Submission

EPA believes that the use of elemental mercury for manufacturing the specified mercury-containing 

products has been phased out in the United States (see section 2.2).

22 Therefore, very few, if any, entities

are expected to submit a SNUN. 

3.5 Potential for Subsequent Regulatory Action

EPA recognizes that if submission of a SNUN does result from the final 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 of the chemical and its risks at the time the 

SNUN is being reviewed). 

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

follow the appropriate procedures for taking those actions. Included in those procedures would be an 

assessment of the costs and benefits of those actions.

 

22 These products may still be in use, resold in the aftermarket, or stored in homes and businesses, but these 

activities are not subject to the SNUR. 
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4. AGENCY COSTS 

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

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

4.1 Labor Rates for EPA Staff

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

published by the Office of Personnel Management effective January 2010 (OPM, 2010). EPA assumes 

that, on average, a federal GS-13, Step 5 full-time equivalent (FTE) will conduct its collection and 

administrative activities under the final rule. 23 The average salary for a GS-13 Step 5 employee was 

$100,904 in 2010 without fringe benefits and overhead costs. In order to derive the fully loaded salary, 

EPA multiplied the annual salary by an assumed loading factor of 1.6 to reflect federal fringe benefits and 

overhead, which results in a fully loaded annual salary of $161,446 (see Table 9). Dividing the fully 

loaded annual salary by 2,080 hours (i.e., the number of hours in a work year) yields an hourly FTE

compensation wage rate of $77.62.

The Agency loading factor of 1.6 is from an EPA guide entitled 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 OPPT ICRs to 

reflect both fringe benefits and overhead for federal staff. For example, it was used in a document 

supporting EPA ICR No. 1139.06 (EPA, 2000), with the following explanation:

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

multiplication factor). The multiplication factor used is recommended in EPA‟s Office of Policy, 

Planning, and Evaluation‟s Instructions for Preparing Information Collection Requests (ICRs)

(June 1, 1992). An EPA internal phone call between Carol Rawie (OPPT/EETD/RIB) and Carl 

Koch (OPPE/RMD/IMB) on May 3, 1994, indicated that the 1.6 factor included not only benefits 

but also overhead.

Fully loaded costs for Agency labor are shown in Table 9.

 

23 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007) (EPA, 2007b), which covers PMN SNURs. Use of this 

grade level follows the approach introduced in EPA, 2007b. That report represented a change from an earlier PMN SNUR 

economic analysis (EPA, 2003), which used an average of GS-12 Step 1 and GS-12 Step 10 salaries.
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Mercury Legacy Products 15 Economic and Policy Analysis Branch

Table 9: Derivation of Loaded Agency Wage Rates

Labor 

Category

Data Source for Wage 

Information Date Wage Fringe 

Benefit

Fringes as 

% wage

Overhead 

as % wage

Fringe + 

overhead 

factor

Loaded 

Wages

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

EPA staff 

FTE

Annual federal staff 

cost: OPM 

WashingtonBaltimore-Northern 

Virginia, DC-MDPA-VA-WV, area, 

GS-13 Step 1 pay 

rates a

Jan2010

$100,904 

(annual)

--

[Included 

in 60% 

overhead]

60% b1.60

$161,446 

(annual)

$48.51 

(hourly)

$77.62 

(hourly)

Notes:

a The Agency salary is the unloaded federal GS-13 Step 5 salary ($100,904 for 2009), from the OPM salary table for the 

Washington-Baltimore-Northern Virginia Locality Pay Area (OPM, 2010). Hourly rates are based on annual salary divided by 

2,080 hours.

b The 60% fringes-and-overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) 

(EPA, 1992, page 30, footnote 9).

4.2 SNUN Processing Costs

The list of review steps, estimates of extramural costs, and the percent of chemicals requiring a particular 

review step are derived from the costs for processing PMN submissions in 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 PMN has been adjusted to 

reflect burden reductions resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that 

requires the electronic submission of all TSCA section 5 notices. Electronic submission of SNUN forms 

is expected reduce Agency burden by 16.5 percent (EPA, 2009b, p.28).

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

column) by the fully loaded hourly salary. This shows EPA staff cost for chemicals requiring the selected 

review step. 

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

chemicals requiring the selected review step is inflated from 1993 prices using the Bureau of Labor 

Statistics (BLS) Employment Cost Index (ECI) data (BLS, 2011b). The not seasonally adjusted ECI for 

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

is used because it is the only series with continuous data since 1985, and that includes professional and 

technical labor, which perform the majority of Agency extramural activities. Table 10, below contains the 

derivation of inflation factors for Agency extramural costs.
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Table 10: Derivation of Inflation Factors for Agency Extramural Costs

Item Inflation index source1 Starting 

year

Index for 

starting 

year

(a)

Index 

for 

2010

(b)

Inflation 

factor

(b)/(a) 2

Agency Extramural costs 

White collar labor; 

equipment; supplies

BLS ECI, Total comp, Private industry, 

Professional and related, 4th Q [BLS 

2011b]

3

1993 67.0

113 1.69

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, 2006). The Consumer Price Index (CPI) was not rebased.

2 Inflation factors are rounded; unrounded values were used in calculations. 

3 Beginning with the report Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: EPA Docket OPPT2009-0922 (EPA 2011b), 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.

Source:

(BLS 2011b) Bureau of Labor Statistics. Employment Cost Index – Total Compensation: Professional and Related Private 

Industry, Not Seasonally Adjusted. (Series ID: CIU2010000120000I (B)), extracted June 16, 2011.

The Percent of Cases column in Table 11 is a weighting factor applied to reflect the fact that not all 

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

Administrative Prescreening, but not all chemicals 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 un-weighted Costs (EPA staff cost plus 

extramural costs) by the percentage of cases requiring this review step. Weighted costs are then multiplied 

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

This calculation yields total Agency costs of $5,049, per SNUN, for submission review and processing, as

shown in Table 11.
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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 $101 

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 

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% $1,049 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 $193 $40.00 $67.76 $261 31% $81.06 0.165 $68 

FOIA (Freedom of Information 

Act) Requests 0.0333 $161,446 $5,376 $287 $486 $5,862 1% $58.62 0.165 $49 

CBI (Confidential Business 

Information) Substantiation 0.0004 $161,446 $64.58 $3.00 $5.08 $70 100% $69.66 0.165 $58 

TOTAL $6,046 0.165 $5,049 

Notes:

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

2 Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated from 1993 prices using {insert reference]. 

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 2009b, p. 28).

Sources: FTEs per review step, 1993 extramural costs, and percentages of cases are from EPA, 1994 Table VII-1, GS-13 salaries are from OPM, 2010.
Economic Analysis of SNUR for Three 18 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

4.3 Export Notification Cost

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, 2009c). 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, 2009c). (See Table 6 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, 2009c). Since the current rulemaking covers only 

one chemical subject to TSCA 12(b) reporting for a minimal number of uses, a very small percent of such 

activity will be attributable to the current rulemaking. 

Because the manufacture of mercury-containing products subject to the final SNUR is phased out, EPA 

does not expect to receive or send any export notifications. Nevertheless, should there be any notifications 

as a result of the current rulemaking, the costs to the Agency are presented per activity. The burden for 

the first two Agency 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 Table 9. 

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 $0.00 $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: Table 9 of this report derives Agency labor costs. Mailing costs are from Table 6 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 2009c), updated for inflation.
Economic Analysis of SNUR for Three 19 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

5. ADDITIONAL ANALYSES

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

various statutes and executive orders.

5.1 Small Entity Impacts

Pursuant to section 605(b) of the Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et seq.), the Agency 

hereby certifies that promulgation of this SNUR will not have a significant adverse economic impact on a 

substantial number of small entities. The rationale supporting this conclusion is as follows. A SNUR 

applies to any person (including small or large entities) who intends to engage in any activity described in 

the rule as a "significant new use." By definition of the word "new," and based on all information 

currently available to EPA, it appears that no small or large entities presently engage in such activity. 

Since this final SNUR requires a person who intends to engage in such activity in the future to first notify 

EPA by submitting a SNUN, no economic impact will occur unless someone files a SNUN to pursue a 

significant new use in the future or forgoes profits by avoiding or delaying the significant new use. 

Although some small entities may decide to conduct such activities in the future, EPA cannot presently 

determine how many, if any, there may be. However, EPA's experience to date is that, in response to the 

promulgation of over 1,000 SNURs, the Agency receives on average only 5 notices per year. Of those 

SNUNs submitted, only one appears to be from a small entity in response to any SNUR. Therefore, EPA 

believes that the potential economic impact of complying with a SNUR is not expected to be significant 

or adversely impact a substantial number of small entities. In a SNUR that published as a final rule on 

August 8, 1997 (62 FR 42690)(FRL-5735-4), the Agency presented its general determination that 

proposed and final SNURs are not expected to have a significant economic impact on a substantial 

number of small entities, which was provided to the Chief Counsel for Advocacy of the Small Business 

Administration.

5.2 Unfunded Mandates

Based on EPA's experience with proposing and finalizing SNURs, State, local, and Tribal governments 

have not been impacted by these rulemakings, and EPA does not have any reason to believe that any 

State, local, or Tribal government will be impacted by this rulemaking. As such, EPA has determined that 

this regulatory action will 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 (UMRA) (2 U.S.C. 1531-1538).

5.3 Paperwork Reduction Act

According to the Paperwork Reduction Act (PRA), 44 U.S.C. 3501 et seq., an Agency may not conduct or 

sponsor, and a person is not required to respond to a collection of information that requires OMB 

approval under the PRA, unless it has been approved by OMB and displays a currently valid OMB 

control number. The OMB control numbers for certain EPA regulations in title 40 of the CFR, after 

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

instrument, or form, if applicable. 

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

pursuant to the PRA under OMB control number 2070-0038 (EPA ICR No. 1188). This action does not 

impose any burden requiring additional OMB approval. If an entity were to submit a SNUN to the 

Agency, the annual burden is estimated to average 97 hours per response. This burden estimate includes 

the time needed to review instructions, search existing data sources, gather and maintain the data needed, 

and complete, review, and submit the required SNUN. 
Economic Analysis of SNUR for Three 20 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

5.4 Technical Standards

Because this action does not involve any technical standards; section 12(d) of the National Technology 

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

note), does not apply to this action.

5.5 Regulatory Planning and Review

Under Executive Order 12866, entitled Regulatory Planning and Review (58 FR 51735, October 4, 1993), 

the Office of Management and Budget (OMB) has determined that this action is a "significant regulatory 

action," because it may raise novel legal or policy issues arising out of legal mandates, the President‟s 

priorities, or the principles set forth in the Executive Order. Accordingly, EPA submitted this action to 

OMB for review under Executive Order 12866 and any changes made in response to OMB 

recommendations have been documented in the docket for this action as required by section 6(a)(3)(E) of 

the Executive Order. 

5.6 Environmental Justice 

This action does not entail special considerations of environmental justice related issues as delineated by 

Executive Order 12898, entitled Federal Actions to Address Environmental Justice in Minority 

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

5.7 Protection of Children

This action is not subject to Executive Order 13045, entitled Protection of Children from Environmental 

Health Risks and Safety Risks (62 FR 19885, April 23, 1997), because this is not an economically 

significant regulatory action as defined by Executive Order 12866, and this action does not address 

environmental health or safety risks disproportionately affecting children.

5.8 Federalism 

This action will not have federalism implications because it is not expected to have a substantial direct 

effect on States, on the relationship between the national government and the States, or on the distribution 

of power and responsibilities among the various levels of government, as specified in Executive Order 

13132, entitled Federalism (64 FR 43255, August 10, 1999).

5.9 Tribal Governments 

This action will not have tribal implications as specified in Executive Order 13175, entitled Consultation 

and Coordination with Indian Tribal Governments (65 FR 67249, November 9, 2000). This action is not 

expected to have substantial direct effects on Indian Tribes, will not significantly or uniquely affect the 

communities of Indian Tribal governments, and does not involve or impose any requirements that affect 

Indian Tribes. Thus, Executive Order 13175 does not apply to this action. 

5.10 Effect on Energy Supply, Distribution, or Use 

This action is not a “significant energy action” as defined in 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 likely to have a significant adverse effect on the supply, 

distribution, or use of energy.
Economic Analysis of SNUR for Three 21 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

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