1 **Supporting Statement for a Request for OMB Review under**

**The Paperwork Reduction Act**
**1. IDENTIFICATION OF THE INFORMATION COLLECTION**  **1(a) Title of the Information Collection**  **Title: Pa**  **rtial Update of the TSCA Section 8(b) Inventory Data Base, Production**  **and Site Reports (Chemical Data Reporting) EPA ICR No.: 1884.**  **0 8**  **OMB Control No.: 2070**
**- 0162**  **1(b) Short Characterization/Abstract**  The following information collection request (I C R addresses the paperwork requirements contained in a final rule (RI N 2070

- AJ43) that amended the information collection activities of the TSCA Chemical Data Reporting (CDR) rule, formerl y known as Inventory Update Rule or IUR, under the Toxic Substances Control Act (TSCA) (40 CFR Part 710 ). Under TSCA section 8(a) (15 USC 2607), the Environmental Protection Agency (EPA) is authorized to collect certain information on chemical substances manufactured (including imported) or processed in the United States. The CDR data provide chemical manufacture, processing and use information that helps EPA identify

what chemicals the public may be exposed to as consumers or in commercial and industrial settings and to better assess routes of potential exposure to those chemicals. The Office of Pollution Prevention and Toxics (OPPT) has used the C DR to collect basic chemical substance manufacturing information for selected chemical substances on the TSCA Inventory seven times beginning in 1986, and to collect additional information relating to the manufacture, processing, and use of those chemical substances, beginning in 2006. In August 2011, EPA published an amendment to the existing CDR rule, adding new requirements and thresholds, some of which were effective in the 2012 reporting cycle and others that will become effective in the 2016 reporting cycle. The changes to the CDR were characterized in the last ICR published in 2011. Between February and August 2012, chemical manufacturers (including importers) producing a chemical substance at 25,000 pounds or greater at a single site reported their 2011 manufacturing information to EPA. In addition, those that produced a chemical substance at 100,000 pounds or greater at a single

- site reported information on processing and u se of the chemical substance. The non

- confidential CDR information was made public through the Agency ’s CDR website ( http://www.epa.gov/cdr). Several benefits of the 2011 rule update were evident in this past reporting cycle:

- The requirement to use electronic reporting

. The elimination of paper

- based submissions in favor of the requirement to report CDR information electronically greatl y improved the reporting process, both for EPA and for manufacturers (including importers). The electronic reporting s ys tem (e

- CDR) cont ained improved capabilities included an enhanced validation system that alerts users when a required field on the form is either missing information or contains certain kinds of potentially incorrect information. Electronic submission ensured that2

CDR dat a could be quickly incorporated into a database and ready for immediate Agency

use, and eliminated data entry

errors which occurred with paper submissions. Also the mandatory use of electronic reporting reduced the reporting burden on industry by reducing both the cost and the time required to review, edit and transmit the data to the Agency

.

- The requirement to use of upfront substa ntiation for Confidential Business Information (CBI) claims. As a result of this requirement, fewer CBI claims have been m ade; submitters who claimed processing and use data as CBI needed to justify these claims, giving greater transparency

and making more data/ information available to the public. The 2011 amendments in the CDR contained four changes that will become effe ctive in 2016: 1) the frequency

of data collection changed from every five years to every

four years; 2) the threshold for reporting process and use information will be lowered to 25,000 pounds; 3) the total annual production volume must be reported for al l reporting years since the last reporting ye ar (for 2016, years 2012

- 2015); and 4) the threshold for reporting manufacturing, processing and use information for certain regulated chemicals will be lowered to 2,500 pounds.

- More frequent data collection : Changes to reporting frequency from every

five years to every four years will help to increase the Agency ’s ability to understand the chemical industry and monitor the production levels of chemical substances manufactured (including imported) in the United States. As chemical industry product lines and manufacturing in the United States change substantiall y from one submission period to the next, m ore current information enhances the Agency ’s ability

to make more accurate chemical substance risk assess ment and management decisions in a timely

and cost effective manner. This is especially important because there are no alternative data sets as comprehensive as CDR for the chemical manufacturing industry

.

- Lower thresholds for processing and use reporting : For 2016, the reporting threshold for processing and use information is 25,000 pounds

. In2012, the threshold was 100,000 pounds. This change provides exposure

- related processing and use information to EPA and others for moderate

- volume chemical subs tances, enabling the Agency to asse s s such chemical substances in the same manner as the higher

- volume chemical substances. The 2016 chemical data collection is expected to involve an average of approximately 4 , 991 respondents at an annual cost of $ 52 million during the IC R period

. The details of the paperwork burden and cost estimates are discussed in this document.

**2. NEED**  **F OR AND**  **U SE OF THE COLLECTION**  **2(a) Need/Authority for the Collection**  Under TSCA, EPA is charged with protecting human health and the environment from potential chemical risks. OPPT carries out its responsibilities by conducting risk assessments and, where necessary , taking risk management actions under TSCA, as well as by making non

confidential information publicly availabl e in order to promote informed decision

- making and transparency . CDR data helps the Agency to identify , assess, and control potential risks to human3

health and the environment posed by commercial chemical substances. TSCA section 8(a) authorizes the Admini strator to promulgate rules to provide for the maintenance and collection of records from manufacturers (including importers) and processors of commercial chemical substances. Sections 8(a)(1) and (2) of TSCA also authorize the Agency to collect informatio n on the chemical substance manufacturing (including importing) industry . EPA possesses broad discretion in determining the information to be reported under TSCA section 8(a). The original IUR rule was codified at 40 CFR 710. In its August 2011 amendments, EPA moved the CDR rule to a new Part at 40 CFR 711. In the CDR database, EPA collects basic exposure

- related manufacturing, processing and use information used by the Agency

and others in a wide range of activities. The 2016 CDR will provide more detailed information needed to better understand and interpret the state of U.S. chemical manufacturing and processing and use. More detailed information will further enhance the Agency ’s ability to identify , screen, and manage potential chemical substance risks. Manufacturers (including importers) will be required to report if, for any calendar year since 2011, a chemical substance was manufactured (including imported) at a site in production volumes of 25,000 pounds . or greater. The reporting threshold for processing and use information will be 25,000 pounds which is lower than the 100,000 pounds threshold for processing and use information required in the 2012 CDR. Also, the reporting threshold will be 2,500 pounds for chemical substances that are:

 Subject of a rule proposed or promulgated under TSCA section 5(a)(2), 5(b)(4), or 6
 Subject of an order issued under TSCA section 5(e) or 5(f)
 Subject of relief that has been granted under a civil action under TSCA section 5 or 7 Because exposure is a key component of risk, the CDR exposure

- related information will allow OPPT to screen chemical substances based on the potential for risk in order to protect human health and the environment, as required by TSCA. The exposure

- related data on manufacturing, processing, and use will potentially allow the Agency

and others to avoid more burdensome regulatory

requirements. These enhanced data will allow EPA to conduct a more effective and efficient screening level review of chemical substances to identify candidates for further evaluation or action. Data reported under the 2016 CDR w ill enhance the capabilities of the Agency and other f ederal agencies to ensure risk management actions are taken on chemical substances posing the most concern. More in

- depth reporting of processing and use data will better support a robust risk assessment and management program

. By enhancing the data supplied to Agency risk

- screening programs, EPA expects to more effectivel y and expeditiously identify and address potential risks posed by chemical s ubstances and provide improved access and information to the public

. **2(b) Practical Utility/Users of the Data**  The reporting methods, including the reporting tool and electronic registration, ensure the information reported to EPA is accurate and in compliance with the CDR requirements.4

e - CDRweb Reporting Tool For the 2016 submission period, EPA will continue to require electronic reporting for all CDR submissions, including joint submissions and amendments. P ersons submitting information under the CDR rule are required to use e

- CDRweb, the Agency

- provided, web

- based tool to complete Form U (the CDR reporting form). The information is submitted electronically via the Internet, through EPA’s Central Data Exchang e (CDX). Users of CDX are required to register with the sy stem, including submitting an authorized signature agreement to EPA

. CDX Registration Each CDR submission must have an associated authorized official . The authorized official sign s the certification statement and submit s the CDR report via CDX

. To register in CDX, the CDX registrant (also referred to as “ Electronic Signature Holder”) completes an electronic signature agreement ( ESA) form . For identity authentication, the registrant will complete the ESA, and either submit the form electronicall y or mail the form to EPA. Once EPA receives the form , EPA will activate the registrant’s CDX account and send a notification via email. A company may need or desire to have more than one individ ual complete an electronic signature agreement, so that more than one person can add information to an original CDR submission. Persons submitting supplemental information for a CDR submission on behalf of a company need to register with CDX by signing an ESA. The company official can authorize an unlimited number of support registrants and support registrants can work with an unlimited number of company official s . A support registrant may be an employee of the company , an outside consultant for the company , or an authorized representative agent for the company. While this individual is not able to sign the certification statement required for the initial CDR submission, he or she is able to provide additional information, if needed, using CDX. Data Elements for CDR Submissions The CDR information collection is the only mechanism through which EPA can collect basic information on commercial chemical substances listed on the TSCA Inventory , including production volume and other manufacturing (including importing), processing, and use exposure

related data. EPA will use the information it is collecting in the following way s: (1) U.S. p arent company identification information : Company identification information is collected already b y the current CDR. EPA al so requires reporting of company identification associated with the location of the company , and specifies that the company information is to be for the U.S. parent company associated with the reporting plant site. These data will help ensure the company information is consistently provided. (2) Manufacturing

- related information :

 The production volume for each of the years since the last principal reporting year : For the 2016 CDR information collection, manufacturers (including importers) need to report production volume information for calendar ye ars 2012, 2013, 2014, and 2015.5 For subsequent CDR collections, determination of the need to report will be based on whether, for any calendar ye ar since the last principal reporting ye ar, a chemical substance was manufactured (including imported) at a site in production volumes of 25,000 pounds or greater

. EPA will use these data for chemical manufacturing, and process ing and use trend analyses; and for the assessment of the effectiveness of Agency and public programs, among other uses.

 The production volume of a manufactured (including imported) chemical substance us ed at the reporting site: This data element identifi es whether a chemical substance is used by the reporting site. Either domestically manufactured or imported chemical subs tances can be reported as used at the reporting site. This information is related to potential exposures associated with the on

- site vo lumes, and provides the Agency with information for exposure assessments and other data anal ys es.

 Wh ether an imported chemical substance i s p hysically at the reporting site : This data element enables the Agency and others to better assess manufacturing

- related potential exposures, thereb y enabling information for screening

- level anal ys es and other uses of the CDR data.

 The production volume directly exported and not domestically processed or used : This data element allows EPA to identify the completeness of the reported processing and use information, by

indicating the proportion of the production volume potentially covered b y the reported processing and use information. CDR processing and use information is required only for domestic use s ituations, and is not required for any volumes directly

exported. This data element informs the exposure profile for the U.S. public.

 The number of workers exposed: This data element allows EPA to identify the number of workers reasonably likel y to be exposed to each reportable chemical substance during manufacture at each site. This e xposure - related information allows OPPT to screen chemical substances based on the potential for risk in order to protect human health.

 The maximum concentration of a ch emical: This data element provides maximum concentration measured by percentage of weight of a reportable chemical substance at the time it is reacted on

- site to produce a different chemical substance or as it leaves the site.

 Wh e ther a manufactured (inc luding imported) chemical substance, such as a byproduct, is being recycled, remanufactured, reprocessed, or reused : This data element provides valuable information for the Agency and the public. It provides a sense of exposure profiles to chemicals and ef ficiencies within the chemical manufacturing industry . The information could also be used to encourage industry to find uses for wastes rather than disposing of the wastes, such as in a landfill.

 The physical form of a chemical: This data element provides the Agency with the total6 production volume of the chemical substance for each physical form reacted onsite or sent off

- site. There are 6 physical forms. (3 ) Processing and use information: D ata element s that relate to processing and use help EPA, other agencies, and the general public to readily screen and prioritize chemicals for the purpose of identifying potential human health and environmental effects. For instance, the data are used in chemical sub stance exposure and risk screening, testing and/or priority setting, and exposure estimation required b y TSCA section 4; for EPA monitoring activities of newly manufactured substances that have completed pre

- manufacture notification (PMN) review under TSCA section 5(a); and to measure potential human and environmental exposure which helps inform various chemical risk anal ys es. Each data element corresponds to a data point necessary for basic risk

- screening. The reporting threshold for processing and use in formation will be 25,000 pounds for the 2016 CDR collection. This is lower than the 100,000 pounds threshold for processing and use information required in the 2012 CDR. Respondents who manufacture (including import) a chemical substance in volumes of 25, 000 pounds or more at a single site will be required in 2016 to report processing and use information unless the chemical substance is partially exempt. This lower threshold will enable the Agency to understand how lower

volume chemical substances are used in the U.S. economy , in the same manner as the higher

- volume chemical substances.

 Industrial processing and use data : This data element identifies the functions of the chemical substances. The industrial function categories include the ty pe of process or use operation (TPU), the industrial sector (IS) codes and the Industrial Function Category

(IFC). The I S codes reduce the number of choices available to the respondent, thus streamlining the reporting process and making the data easier to use. Processing and use information helps EPA, other agencies, and the general public to readily

screen and prioritize chemicals for the purpose of identifying potential human health and environmental effects.

 Consumer and commercial end

- use e xposure data: These data ar e reported separately and are used to determine exposure potential based on consumer or commercial populations. These two populations are very different from each other, and the ability

to distinguish uses between the two enables better exposure

- based scre ening of the chemical substance

. Additionally, within the consumer product category , submitters mus t report to the extent they know if the chemical is used in products intended for children. This information allows EPA and the public to better understand what is in children’s products and allows the Age n cy to focus in on chemical risks related to children’s health. (4 ) Special considerations for Joint Submitters : In certain situations CDR submitters are allowed to report the CDR information jointly with the supplier of the chemical substance for which the submitter is reporting

. For example, importers may not know the specific chemical identity of the imported7

TSCA chemical substance because the foreign s upplier chooses to keep the information confidential. In addition, a manufacturer may not know the specific chemical identity of the substance being manufactured because the supplier of a reactant used to manufacture the substance chooses to keep the information confiden tial. In s uch situations, the manufacturer (including importer) is still responsible for ensuring that the CDR information is submitted to EPA and may do so by submitting a joint report. For example, in the case of an imported substance, the U.S. importer, as the primary submitter, completes the majority

of the required information on Form U, and provides a trade name in Part II.2.A.4 of Form U to identify the chemical substance. The primary submitter then contacts the foreign supplier, who is the secondary submitter , to notify

them of the need to report the specific chemical identity information directly

to EPA in the joint submission section (Part IV) of Form U, using the electronic reporting tool, e

- CDRweb. EPA has added Part IV to Form U to accommodate joint submi ssions. Because signatures are required b y each party of a joint submission, they must each register with CDX , complete their own sections on Form U, and submit their own sections of the same report electronically to EPA. The secondary submitter will not b e able to access the information provided b y the primary submitter and vice versa. The electronic reporting tool will match both submissions based upon company and chemical information provided by the manufacturer (including importer), acting as a primary submitter, and by the supplier, acting as a secondary

submitter. The information provided b y the primary and secondary respondents will be saved and combined as one joint submission. EPA will process the joint submission once all F orm Us are received and m atched by the Agency

. This information collection allows EPA to connect submissions from the primary submitter and secondary

submitter and to request clarification from the secondary submitter if needed

. The data EPA will collect will be utilized in the following ways:

 Joint submission information (primary registrant only): The primary submitter provides only a trade name or other designation to identify the chemical substance being reported. Therefore, the requested data are needed by the Agency to identi f

y the chemical substance correctly and provide the company name and complete mailing address of the secondary

submitter.

 Secondary company identification information: These data identify the secondary submitter ’s company name and the complete mailing address of the company

. The information provided helps ensure that the company information is provided consistently , and is used to associate the secondary submitter’s company

with the primary submitter’s company

and site plant.

 Technical c ontact information: The company’s technical contact information provides EPA with the name and complete mailing address of the person who will be able to answer questions EPA may have about the reported chemical substance.

 Primary company information : These data provide the trade name and the unique identifier number for joint submissions . This is the number the primary submitter sent to the secondary

submitter.8

 Trade p roduct identification information : These data identify the primary

submitters’ company name, s ite name, and site address, as well as the CAS Registry Number, the appropriate specific che mical identities, and product composition. These data are needed b y EPA to combine the secondary submitters’ chemical

- specific information with the primary

submitters’ information to result in a complete CDR submission. In formation secured through the CDR collections is used increasingl y b y a wide variety of governmental and non

- governmental users. Consistent with Congress’ intent that TSCA data be used to facilitat e any government public health and environment efforts, CDR data have been used by EPA’s Office of Water, Office of Solid Waste and Emergency Response, and Office of Air and Radiation to identify and characterize particular chemical substances. Non

- confidential CDR data are incorporated into a number of publicly accessible databases and products maintained by

non - government organizations such as Right

- To

- Know

-Net 1 and INFORM

. 2 CDR data were used to identify chemical substances of particular concern for the National Institutes of Health. Non

- confidential CDR data have also been released to selected states to help them identify facilities manufacturing suspected endocrine disrupters.

**3. NON** 
**- DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION**  **CRITERIA 3(a)**  **Non**
**- duplication**  The data included in this information collection (i.e., production volume, chemical manufacture, exposure, and processing and use data) are not collected comprehensivel y or sy stematically

at the national level by

any other entity . There are a variety of sources for certain data elements, but none is as complete as CDR. **3(b) Public Notice Required Prior to ICR submission to OMB**  Prior to submission to OMB, this I CR will be made available to the public for comment through a Federal Register notice. The public will have 60 days to provide comments. Any comments received will be given consideration when completing the supporting statement that is submitted to OMB.

1 RTKNET.org is a project of the Center for Effective Government.

2 INFORM is a nonprofit environmental research organization.9

**3(c) Consultations**  In addition to the public notice and comment period, OMB regulations, at 5 CFR 1320.8(d)(1), require agencies to consult with potential I CR respondents and data users about specific aspects of an IC R before the Agency submits the I CR to OMB for review and approval. In accordance with this regulation, EPA will solicit consultation feedback from potential respondents and data users with respect to this I CR by sending letters simultaneously with this ICR. **3( d**  **) General Guidelines**  This collection does not exceed any of the Paperwork Reduction Act (PRA) guidelines at 5 CFR 1320.6, with the exceptions listed below. The record retention period of this collection is five years, as specified in 40 CFR 710.57, exceeding the PRA maximum of three ye ars. This is necessary to ensure companies retain records long enough to facilitate completion of Form U (EPA Form 7740

- 8) in the 2016 and subsequent collections , which is every four years, and to allow EPA’s enforcement activities to overlap two CDR reporting cycles. Confidential Business Information (CBI) claims limit access to the CDR data, especiall y by the public. EPA recognizes that some information submitted to the Agency is legitimatel y confidential business information; because of this, EPA’s review of CBI data is an inherently governmental function that EPA must perform to protect human health and the environment. **3(e) Confidentiality**  Submitters may

claim information reported to EPA under this rule as co nfidential if such information reveals the submitter’s trade secrets or proprietary information as defined b y TSCA section 14 and existing TSCA regulations. EPA has long

- established procedures for handling, storing, processing, and disposing of TSCA confid ential information. Transfers of this information to other governmental agencies can be made onl y if the other agency agrees to adhere to all TSCA confidentiality provisions. EPA will maintain standard CBI procedures to protect any confidential, trade secr et, or proprietary information from disclosure in accordance with EPA’s confidentiality

regulation, 40 CFR Part 2, Subpart B. **3( f**  **) Sensitive Questions** This collection does not include questions of a sensitive nature.10

**4. THE RESPONDENTS AND THE**  **INFORMATION REQUESTED 4(a)**  **Respondents /** **NAICS Codes**  The regulated community consists of companies manufacturing (including importing) chemical substances listed on the TSCA Inventory and regulated under TSCA section 8. In general, the industry

segments that compose the regulated community for the rule are those that produce or import organic and inorganic chemical substances. Most respondents previously reported information to the CDR. The Agency ’s previous experience with CDR collections has shown that the majority

of the respondents affected by this collection activity

are from the following North American Industrial Classification Sy stem (NAI CS) code categories: 325

- Chemical Manufacturing 324

- Petroleum and Coal Product Manufacturing The subs ectors identified above represent the designation of sites that likely would be subject to CDR reporting. However this list does not include all potentially affected entities. Other ty pes of entities not listed in this unit could also be subject to reporting. Generally , TSCA section 8 excludes small manufacturers (including importers) from reporting. EPA defines small manufacturers (including importers) for purposes of CDR and certain other reporting in 40 CFR 704.3. In addition to the anticipated resp ondents listed above, manufacturers (including importers) of b yproducts are required to report under the CDR rule. By product manufacturers (including importers) may be listed under a different primary activity for a site, such as NAICS codes 22, 322, 331, and 3344; e.g., utilities, paper manufacturing, primary metal manufacturing, and semiconductor and other electronic component manufacturing. For purposes of the CDR , a by product is “ a chemical substance produced without a separate commercial intent during the manufacture, processing, use or disposal of another chemical substance or mixture ” (40 CFR 704.3). Such a chemical substance, like any other manufactured chemical substance, is subject to CDR reporting if it is manufactured (including imported) , is lis ted in EPA’s TSCA Master Inventory File, is not otherwise excluded from reporting, and its manufacturer is not specifically exempted from CDR reporting requirements

. For instance, a manufacturer (including importer) that uses a chemical substance in the production of an object may produce a by

product substance that is chemically

different from the starting substance; the manufacturer (including importer) therefore may

incur reporting obligations under the CDR for that by product. **4(b) Information Requeste**  **d (i)**  **Reporting Threshold for Certain Regulated Chemicals** The threshold for reporting to CDR is a production (including import) volume of 25,000 pounds at a single site for any calendar ye ar since the previous reporting ye ar. Beginning in 2016, the reporting threshold for processing and use information will be 2,500 pounds for certain chemical substances that are:11  The subject of a rule proposed or promulgated under TSCA section 5(a)(2), 5(b)(4), or 6,
 The subject of an order issued under TSCA section 5(e), or 5(f)
 The subject of relief that has been granted under a civil action under TSCA section 5 or 7. Chemical substances that are the subject of these particular TSCA actions are of demonstrated high interest to the Agency . This change will help to ensure the availability of current information when the Agency has expressed a concern in the form of regulatory action on those chemi cal substances manufactured below 25,000 pounds. EPA will use the CDR data associated with these regulated chemical substances to monitor chemical substance production and compliance with the rules

. **(ii) Data**  **elements , including record keeping requirem**  **ents** The CDR data elements are related to or indicative of three components of exposure. These components are: (1) the number of ecos ys tems or size of human populations potentially exposed, (2) the potential human or environmental exposure concentrations, and ( 3) the frequency and duration of potential exposures. The data enhances EPA’s ability to evaluate each of these components of exposure. Respondents are required to submit certain “known or reasonabl y ascertainable ” manufacturing, processing, and use exposure - related information. Using e

- CDRweb, individuals report the data elements as follows:

 Authorized company official’s e

- mail a ddress . The e

- mail address of the company official authorized to sign and submit the CDR Form U.

 U.S. parent company name a nd address . The name and mailing address of the U. S. parent company. The requirement that the parent company reported must be the U.S. parent company.

 Manufacturing information. For the 2016 reporting cycle and subsequent reporting cycles , the production volume for each of the ye ars since the last principal reporting ye ar; the volume of the reported chemical substance used at the reporting site; whether an imported chemical substance is phys icall y at the reporting site; the production volume directly

exported and not domestically processed or used ; and whether a manufactured (including imported) chemical substance , such as a b yp roduct, is being recycled, reused, reprocessed, or remanufactured

.

 Processing and use information. The reporting thresh old for processing and use information will change from the 2012 level of 100,000 pounds to 25,000 pounds for 2016 and subsequent CDR collections. Respondents are to report this information for all reported chemical s ubstances , unless the chemical substanc e is specifically partiall y exempted.12

 Industrial p rocessing and use d ata

. Submitters must report their industrial function. They choose from a list of in dustrial function categories.

 Consumer and commercial use data . Respondents must indicate whether th e use is consumer , commercial or both, and, if commercial, the number of commercial workers reasonabl y likel y to be exposed to the chemical must be reported as a range. Joint Submissions. Joint submissions are allowed only in those instances where a supplier w ill not disclose to the respondent the specific chemical name of the imported TSCA Inventory chemical substance or of a reactant used to manufa cture the TSCA Inventory substance. This may happen , for instance, when a company is importing a mixture under a trade name, and the foreign manufacturer does not want to reveal the components in the mixture. (See Special Considerations for Joint Submitters in section 2b, above.) Electronic reporting for both the primary and the secondary portions of a joint submission make it easier for respondents to report. In addition to signing the certification statement and completing Parts I , II, and III, primary respondents will report on data elements in Part II, Blocks 2.A.5 through 2.A.12, on Form U as follows:

 Joint submission information. Trade name of the chemical substance being reported, secondary respondent name, and complete mailing address (city , state/province, zip code, and country

(if applicable)). Secondary submitters register with CDX as secondary authorized submitter or a secondary support registrant. They

will provide the primary company ’s information and the trade product name, supplied to them by the primary submitter, to gain access to the Form U containing information specific to the trade p roduct name. After the secondary submitter is granted access to the form, they

report on data elements in Part IV on Form U as follows:

 Certification. The company official must certify by signature and date that to the best of his/her knowledge and belie f: 1) all information entered on Form U has been completed in compliance with the regulatory requirements; and 2) any confidentiality

claims are true and correct as to that information for which they have been asserted.

 Secondary company information. The secondary company name and complete mailing address (city , state, zip code, and country (if applicable)).

 Secondary technical contact information. The technical contact name, phone number, complete mailing address (city /town, state/province, zip code, and country (if applicable)), and email address.

 Primary company information. Trade name and the Unique Identifier for Joint Submissions number provided by the primary

submitter and sent to the secondary submitter.

 Trade product information. The trade product name, chemical name, CAS Registry Number, ID code linking the primary and secondary

submission s , and percentage of each chemical substance component of a trade product.13

**(i i** **i) Submitter**  **Activities/Information Collections (ICs)** EPA identified the following ICs in the currentl y - approved IC R for activities that submitters would complete when compl ying with the rule:
 Compliance Determination;
 Rule Familiarization;
 CDX Registration Activities
 Report Preparation and Submission

– Partial Reports including identity and manufacturing (including import) information;
 Report Preparation and Submission

- Full Reports including identity , manufacturing(including import), processing and use information;
 Recordkeeping. **Table 1: Information Collections (ICs) for**  **CDR Reporting**  **I nformation**  **Collection Description**  Compliance Determination Determine whether reporting is required for a chemical substance

manufactured (including imported) at a particular site, based on the chemical su

bstance’s production volume and the applicability of certain reporting exemptions. For 2016 and all future reporting cycles, r eporting is required if the production volume of a chemical substance me et s or exceed s the 25,000 lb threshold (or 2,500 lb threshold, if applicable) for any calendar ye ar since the last principal reporting year . Rule Familiarization Become familiar with the full requirements of the rule, which entails

reading the rule, understanding the various reporting and administrative requirements, and determining the manner in which reporting requirements will be met for each chemical substance. CDX Registration Activities The CDR rule require s electronic reporting, and therefore require s that all

submitters complete EP A’s CDX registration process. As part of registering with CDX, each submitter w ill provide identifying information that will comprise all or most of the information requested in Part Iof Form U (EPA Form 7740

- 8). This information will then be pre

populate d whenever the submitter prepares a partial or full report. In order to submit electronically to EPA via CDX, the authorized official, who will be signing and submitting the site’s CDR Form U , must register with CDX and must submit an ESA

. Once the registration process is complete, the registered individual w ill be able to access the e

- CDRweb reporting tool

. Prepare and Submi t Report

- Partial Report Compile the required information, determine the CBI status of

information and fulfill appropriate substantiation measures, and use the e

CDRweb tool to complete and submit only Parts I and II (and Part IV, if a joint submission) of Form U (EPA Form 7740

- 8) for chemical substances specificall y listed in the regulation for which there is a partial14 reporting exemption. Prepare and Submi t Report

- Full Report Compile the required information, determine the CBI status of

information and fulfill appropriate substantiation requirements, and use the e

- CDRweb tool to complete and submit Parts I, II, III and, if a joint submission, Part IV, of Form U (EPA Form 7740

- 8). Maintain Records Retain all records related to the submission for five years after the

submission period.

**5. THE INFORMATION COLLECTED** 

**– AGENCY ACTIVITIES, COLLECTION**  **METHODOLOGY, AND INFORMATION MANAGEMENT 5(a)**  **Agency Activities** The Agency

develops and maintains the electronic tool used to collect and verify data. Other activities routinel y conducted b y EP A related to the processing, anal ysis and storage of the information collected under this rule include the following:

 Review and verify

submissions;
 Answer submitter questions and provide any necessary technical assistance;
 Process submissions for inclusion in CDR database;
 Review requests for confidentiality in the submissions;
 Maintain the database; and
 Distribute the data. **5(b) Collection Methodology and Management**  The next CDR collection will occur in 2016. All manufacturers (including impo rters), except for those defined as “small manufacturers” by EPA’s regulations, are required to submit information on every

substance subject to the 2011 rule that they manufacture (including import) in quantities that meet or exceed the CDR thresholds. Th e collection will occur every four ye ars. **(i) Collection Methodology**  Submitters are required to submit information associated with this data collection electronically

via the Internet using e

- CDRweb and CDX. Potential submitters will be notified of the need to report in three way s: (1) make available guidance describing CDR reporting requirements at chemical industry conferences and meetings, (2) send email notices to previous CDR submitters, and (3) publish articles in the trade press. Reporting materials, including a non

- submission version of the e

- CDRweb reporting tool and a variety of guidance documents (Instruction Manual, Q&As, Case Studies), are available on EPA’s CDR website. Submitters also can obtain these materials from the TSCA Hotline. S ubmitters obtain the submission version of the e

- CDRweb reporting tool as part of the CDX registration process, as described in section 4 of this document.15

EPA will receive all CDR submissions electronically . The CDX registration process, required for all submitters, will provide a user ID, which the submitter will use to access e

CDRweb. In formation quality

and validation begins with the e

- CDRweb reporting tool, which is programmed to help the submitter provide the information required, in the correct f ormat as required b y the CDR rule. To aid persons subject to this information collection, the Agency ’s TSCA and CDX Hotlines are available to answer questions regarding the CDR requirements or submission process. When Hotline staff is unable to answer questions, the submitter is referred to OPPT’s In formation Management Division (IMD) or Chemical Control Division (CCD), as appropriate. Submitters can also email their questions to the eCDRweb mail site at eCDRweb@epa .gov . Other Divisions within OPPT or OE I are used as necessary

. **(ii) Data Management**  This section describes the Agency tasks required for efficiently processing submissions under the CDR. The tasks for which the Agency is responsible are presented under four main categories: database s ys t ems development, guidance document development, Form U processing, and additional tasks. The task descriptions presented below generall y do not change from collection to collection. CDR data is stored in a database managed b y the Agency. Once updated, th e CDR database is then available to EPA technical reviewers to search or export into their various anal ytical modeling s ys tems and databases. The CDR database is also available for quick screening and other direct uses. The Agency makes publicly

available as much information as possible, within the confines of protecting CBI.

 Database S ys tems Development and Maintenance

-- The Agency develops and maintains adequate information systems in place to support the database that serves as the primary data storage medium for CDR collections. File servers with appropriate backup are used to contain the CDR databases.

 Guidance Document Development

-- The Agency develops guidance to assist submitters in submitting data and complying with CDR requirements. The guidance documents are updated for each CDR cycle.

 Form U Processing

-- The Agency is responsible for processing CDR Form U submissions. This includes deve loping standard operating procedures and documentation for all stages in the CDR life cycle, tracking submissions, implementing quality assurance and control, maintaining file and databases, information security, disseminating data, and training staff. EPA receives CDR submissions over the Internet, using CDX.

 Additional Activities

-- The Agency develops various supporting documents associated with the reporting tool and makes them available on the Internet. In addition, the Agency16

provides the TSCA Hotline with standardized responses for frequentl y asked questions; preparing mailin gs, mailing lists, and labels; and develops outgoing information materials. **5(c) Small Entity Flexibility**  The CDR regulation provides flexibility to small entities. This regulation affects onl y businesses

-- governmental jurisdictions and not

- for

-prof it organizations are not required to take any action. Small manufacturers (including importers), in accordance with TSCA section 8(b) (40 CFR Sections 710.29 and 710.28 ), are exempt and therefore are generall y not subject to any of the reporting or recordk eeping requirements. A manufacturer (including importer) is considered a small business if (1) the firm’s total annual sales when combined with those of its U.S. parent company (if any) are less than $40 million for the submission period and (2) its total production and/or importation of the chemical substances, mixture or category , for the reporting period, does not exceed 100,000 pounds (45,000 kilograms) at an individual site owned and controlled b y the firm. The Economic Analysis for the Final Inventory Update Reporting Modifications Rule determined that the impact on these companies is, on average, significantl y less than one percent of revenues (EPA, 2011). **5(d) Collection Schedule**  The submission period for the 2016 collection will be from June 1 , 2016 to September 30, 2016. For all subsequent collections, the submission period will be from June 1 to September 30. The submission period/schedule follows the requirements of 40 CFR 711.20. Federal Register Notice published Send out e

- mail to 2016 CDR e

- mailing list with instructions describing how to obtain the reporting form Earl y 2014
Public Outreach efforts: articles in industry press, meetings with regulated community , and information on the IUR website 2014

- 2016
Open period for submitting 2 01 6 CDR Forms June 1, 2016 to September 30, 2016

**6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION**  This section presents the burden and cost estimates incurred b y all affected entities

. This ICR covers the ye ars 2015, 2016, and 2017. Therefore, it provides burden and cost estimates for the information collection corresponding to the 2016 and 2020 reporting cycles. Even though reporting occurs only

once per reporting cycle, EPA expects th at rule compliance and data collection activities, and thus, costs and burdens, are incurred over the course of the reporting cycle. Therefore, for purposes of this anal ys is, the burden and cost for one reporting cycle are averaged over the number of years in the reporting cycle and are presented here as average annual figures. All costs are presented in year 2012 dollars. The CDR requires reporting on a “per site” basis rather than a “per company” basis. Therefore, each site which is subject to the CDR rul e is considered a respondent and will submit one Form U containing one or more chemical

- specific17

reports. Respondents are comprised of both first time CDR submitters and previous respondents who have submitted data under the previous CDR and IUR reporting cycles. EPA assumes that the burden for previous submitters will be reduced because of efficiencies achieved through the establishment of compliance processes; as described in the IUR EA (EPA, 2011). After a site’s first reporting cycle, the availability o f data from previous reporting cycles and the familiarity with reporting requirements will expedite future submissions

. **6(a) Estimating**  **Respondent Burden**  Beginning with the 2016 reporting cycle, manufacturers (including importers), must submit a Form U for each site (including import sites) at which 25,000 pounds or more was manufactured (including import) for a chemical substance in any calendar year since 2011. For purposes of the ICR, one manufacturing site is equivalent to one respondent. Form U co ntains four Parts. Part I contains basic site identification information and must be completed by all sites. Part II contains manufacturing (including import) data (production volumes, etc.) specific to each chemical substance , which also must be completed by all sites. Together, Part Iand Part II are considered a “partial report.” Part III contains processing and use information and will be completed for all chemical s ubstances unless the chemical substance is specificall y exempted from the requirement to do so. Part IV contains secondary company identification information and specific information identifying a chemical substance. Part IV is completed only by a secondary respondent (see Section 2(b)). For purposes of this anal ys is, burden and costs associated with P art IV are considered part of the burden and costs estimates of Part I (respondent identification) and the beginning of Part II (chemical identification) , and therefore were not separately calculated. Together, P arts I, II, and III (and Part IV, when applicable) are considered a “full report.” One report is submitted for each unique chemical substance/site combination; that is, a site must complete a separate report for each applicable chemical substance , but Part I of Form U is completed and submitted only once per site . EPA anticipates that Part Iwill be completed automaticall y when respondents register with CDX

. To comply

with the regulation, manufacturers (including importers) must complete the activities listed in Table 2. Table 2 also provides a cross

- walk of the related Information Collection that corresponds to each activity

. **Table 2: Cross**
**- Walk between Industry Activities and Related Information Collections (ICs)**  **Activity Description**  **Related IC(s) Compliance**  **Determ ination**  Site staff must determine whether reporting is

required for a chemical substance manufactured (including imported) at a particular site, based on the chemical substance’s production volume and the applicability of certain reporting exemptions. Submitters would report all data from 2015 and only production volume from 2012

- 2014. This involves determining whether the production volume of a chemical substance met or exceeded the 25 , 00 0 lb threshold in any of the calendar years since the last principal reporting year (i.e. 2012

- 2015). Com pliance Determination

**Rule Fam** **iliarization** Site staff must familiarize themselves with the

requirements of the rule. Staff from sites that reported previously must become familiar with new Rule Familiarization18 requirements, and staff from sites new to reporting must become familiar with all requirements. This entails reading the rule, understanding the various reporting and administrative requirements, and determining the manner in which the reporting requirements will be met. **CDX Registration** Before submitting Form U, all respondents must

register with CDX. In addition, respondents must complete an Electronic Signature Agreement form, which is signed, dated , and either submitted electronically or ma il ed bac k to EPA. CDX Registration Activities

**Preparation of Reports**  Site staff must collect all of the required information,

and complete partial and/or full reports using a Form U report form, for each of the reportable chemical substances at that site. The information must be reviewed, and submitted to EPA. This task involves any research necessary to identify the correct information to report, the act of completing Form U (technical and clerical burden), and managerial review. Once the Form

U is completed, com

pany staff must submit it electronically to EPA via CDX. Prepare and Submit Report, and Maintain Records

- Partial Report Prepare and Submit Report, and Maintain Records

- Full Report

**Recordkeeping** Respondents must keep records supporting their

submissions for five years. Prepare and Submit Report, and Maintain Records

- Partial Report Prepare and Submit Report, and Maintain Records

- Full Report Burden estimates were derived originall y from a survey conducted b y EPA in 1996 (under OMB Control No. 2070

- 0034) to assess the potential burden associated with the IUR, as amended at that time. The survey

was distributed to previous IUR respondents selected from the IUR database. Burden estimates were updated for a 2005 amendment to the rule as described in Economic Analysis of IUR Modifications Final Rule (EPA, 2005) 3 . Burden estimates for new reporting elements in the final rule were derived as described in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule ( EPA, 2011 )

. Table 3 and Table 4 illustrate the burden for a ty pical respondent on a per - activity basis, including time required to complete each section of Form U. The Agency expects data will be collected for two data collection s, the 2016 and 2020 repo rting cycles, during the three

- ye ar period covered b y this I CR addendum

. The section

- by

- section industry burden estimates for report preparation also include the burden of compliance determination and rule familiarization

. EPA estimates the total industry burden for completing and submitting one partial report to be 56.11 hours, and the estimated burden for completing and submitting one full report, to be 139.13 hours for new submitters. EPA considers new submitters to include both staff from sites that hav e not previously

submitted a Form U and new staff members at sites that have previousl y reported data under CDR. For old submitters (staff who have previousl y submitted Form Us), EPA estimates the total industry burden to be 25.74 hours for completing and submitting one partial report and 91.37 hours for one full report

. For the purposes of this I CR, EPA assumed that all new

3 The economic analysis for the 2005 Amendments assumed a 15 percent reduction in burden for the completion of Part III because submitters were no longer required to report use and downstream processing information for exports.19

submitters will complete CDX registration and no previous submitters will undertake any CDX registration activities. EPA calculated burden estimates for each element of Form U individuall y using the 1996 survey results, economic anal ys es for other rules with similar requirements (such as the 2010 Premanufacture Notification Electronic Reporting final rule), and EPA’s best professional judgment. More detailed information on the derivation of these estimates is found in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule ( EPA, 2011 ).20

**Table 3: Total Industry Burden, by Activity, New Submitters**  **Activity Clerical**  **Burde n**  **(hours) Technical** 

**Burden (hours)**  **Manageria**

**l Burden (hours)**  **Total Burden (hours)**  **(a) (b)**  **(c) (d) = (a)+(b)+(c)**  **PREPARATION OF REPORT (Includes rule familiarization associated with each data element) Part I.**  **Site Identification Inform ation** 

Certification 0 .00 0.85 1.01 1.86 Com pany Information (U.S. Parent Com pany Name, D&B Number, Mailing Address , Technical Contact , Technical Contact Mailing Address) 0 .00 0.04 0.02 0.06 Plant Site Identification (Site Name, D&B Number, Mailing Address ) 0 .00 0.06 0.02 0.08 Information for Joint Submissions 0.00 0.00 0.01 0.01 **Total for Part I 0.00**  **0.95 1.06**  **2.01 Part II** 

. **Manufacturing Inform ation** 

Site

- Limited , Activity, Production Volume ( lb ) (2015) 0.00 2.28 0.56 2.84 Chemical Substance Identification Upfront CBI Substantiation 0.00 1.45 0.77 2.22 Accession Number Requests 0.00 0.01 0.00 0.01 Plant Site Upfront Substantiation 0.00 0.83 0.51 1.34 Total Number of Workers 0.00 1.43 0.59 2.02 Maximum Concentration, Physical Form, Percent Volume of Production 0.00 2.79 1.07 3.86 Production Volume for Each of the Years since Last Principal Reporting Year (2012

- 2014) 0.00 3.08 0.76 3.83 Production Volume Used On

- Site 0.00 0.20 0.05 0.25 Whether Im

ported Chemical Substance is Physically at Reporting Site 0.00 0.11 0.03 0.14 Volume Exported 0.00 1.03 0.25 1.28 Whether a C hemical Substance is to be Recycled , Remanufactured, Reprocessed, or Reused. 0.00 0.11 0.03 0.14 **Total for Part II** 0.00 **13.32 4.60**  **17.93 Part III. Processing and Use Inform**  **ation** Upfront S ubstantiation for P rocessing and U se I nformation CBI Claims 0.00 0.43 0.26 0.69 Industrial Processing and Use Exposure

- Related Data

Determination of Applicability 0.00 1.01 0.28 1.29 Industrial Function Category 0.00 4.67 2.07 6.73 Sector 0.00 0.94 0.40 1.3321 **Activity Clerical**  **Burde n**  **(hours) Technical** 

**Burden (hours)**  **Manageria**

**l Burden (hours)**  **Total Burden (hours)**  **(a) (b)**  **(c) (d) = (a)+(b)+(c)**  Percent of Production Volume 0.00 10.00 5.27 15.27 Total Number of Processing and Use Sites 0.00 9.14 3.52 12.67 Total Number of Potentially Exposed Workers 0.00 15.43 3.83 19.26 Consumer and Commercial Use Exposure

- Related Data

Determination of Applicability 0.00 0.94 0.25 1.19 Identification of Production Category/Use by Children 0.00 1.68 0.25 1.92 Percent of Production Volume 0.00 1.26 0.45 1.71 Maximum Concentration by Category 0.00 1.36 0.34 1.70 Number of C ommercial W orkers Reasonably L ikely to be E xposed 0.00 15.43 3.83 19.26 **Total for Part III 0.00**  **62.26 20.76**  **83.02 COMPLIANCE DETERMINATION** 

Com pliance Determination **0.00 2.50**  **0.00 2.50**  **RULE FAMILIARIZATION**

Rule Familiarization **0.00 19.00**  **9.00 28.00**  **CDX REGISTRATION ACTIVITIES** CDX Registration 0.00 0.73 0.18 0.92 CDX Electronic Signature Agreement 0.00 1.00 0.75 1.75 **Total for CDX Registration Activities**  **0.00 1.73**  **0.93 2.67**  **RECORDKEEPING**

Recordkeeping **0.75 1.50**  **0.75 3.00**  **TOTAL BURDEN Burden for one**  **Partial Report (Parts I, II,**  **Com pliance Determ** **ination, Rule Fam** **iliarization, Recordkeeping and**  **CDX Registration Activities )**  **0.75 39.01**  **16.34 56.11**  **Burden for one Full**  **Report (Parts I, II, III, Compliance Determ** **ination, Rule Fam** **iliarization, Recordkeeping and**  **CDX Registration Activities )**  **0.75 101.27**  **37.10 139.13**  **Note:** Totals may not sum due to rounding

. **Source:** Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule ( EPA, 2011 )

.22

**Table 4: Total Industry Burden, by Activity, Old Submitters**  **Activity Clerical Burde**  **n (hours)**  **Technical Burden**

**(hours) Managerial** 

**Burden (hours)**  **Total Burden**

**(hours) (a)**  **(b) (c)**  **(d) = (a)+(b)+(c) PREPARATION OF REPORT**  **(Includes rule familiarization associated with each data element)** Part I. **Site Identification Inform ation**  Certification 0.00 0.85 1.01 1.86 Com pany Information (U.S. Parent Com pany Name, D&B Number, Mailing Address , Technical Contact , Technical Contact Mailing Address) 0.00 0.01 0.004 0.01
Plant Site Identification (Site Name, D&B Number, Mailing Address ) 0.00 0.01 0.004 0.02 **Total for Part I 0.00**  **0.87 1.02**  **1.89** Part II. **Manufacturing Information** Site

- Limited , Activity, Production Volume ( lb ) (2015) 0.00 1.82 0.45 2.27 Chemical Substance Identification Upfront CBI Substantiation 0.00 1.16 0.61 1.77 Plant Site Upfront Substantiation 0.00 0.66 0.41 1.07 Total Number of Workers 0.00 1.14 0.47 1.61 Maximum Concentration, Physical Form , Percent Volume of Production 0.00 2.23 0.86 3.09 Production Volume for Each of the Years since Last Principal Reporting Year (2012

- 2014) 0.00 2.46 0.60 3.07 Production Volume Used On

- Site 0.00 0.16 0.04 0.20 Whether Im

ported Chemical Substance is Physically at Reporting Site 0.00 0.09 0.02 0.11 Volume Exported 0.00 0.82 0.20 1.02 Whether a C hemical Substance is to be Recycled , Remanufactured, Reprocessed or Reused. 0.00 0.09 0.02 0.11 **Total for Part II 0.00**  **10.66 3.68**  **14.34 Part III. Processing and Use Inform**  **ation**

Upfront S ubstantiation for P rocessing and U se Information CBI Claims 0.00 0.43 0.21 0.64 Industrial Processing and Use Exposure

- Related Data Determination of Applicability 0.00 0.81 0.23 1.03 Industrial Function Category 0.00 3.53 1.65 5.18 Sector 0.00 0.75 0.32 1.0623 **Activity Clerical Burde**  **n (hours)**  **Technical Burden**

**(hours) Managerial** 

**Burden (hours)**  **Total Burden**

**(hours) (a)**  **(b) (c)**  **(d) = (a)+(b)+(c)** Percent of Production Volume 0.00 8.00 4.22 12.22 Total Number of Processing and Use Sites 0.00 7.31 2.82 10.13 Total Number of Potentially Exposed Workers 0.00 12.34 3.06 15.41 Consumer and Commercial Use Exposure

- Related Data Determination of Applicability 0.00 0.75 0.20 0.95 Identification of Production Category/Use by Children 0.00 0.67 0.20 0.87 Percent of Production Volume 0.00 1.01 0.36 1.37 Maximum Concentration by Category 0.00 1.09 0.28 1.36 Number of C ommercial W orkers Reasonably L ikely to be E xposed 0.00 12.34 3.06 15.41 **Total for Part III 0.00**  **49.03 16.60**  **65.63 COMPLIANCE DETERMINATION**  Com pliance Determination **0.00 2.50**  **0.00 2.50**  **RULE FAMILIARIZATION** Rule Familiarization **0.00 2.00**  **2.00 4.00**  **CDX REGISTRATION ACTIVITIES**

CDX Registration 0.00 0.00 0.00 0.00 CDX Electronic Signature Agreement 0.00 0.00 0.00 0.00 **Total for CDX Registration Activities**  **0.00** 0.00 0.00 0.00 **RECORDKEEPING** Recordkeeping **0.75 1.50**  **0.75 3.00**  **TOTAL BURDEN Burden for one**  **Partial Report (Parts I, II,**  **Recordkeeping and Submission**  **) 0.75**  **17.53 7.45**  **25.74 Burden for one**  **Full Report (Parts I, II, III,**  **Recordkeeping and Submission**  **) 0.75**  **66.56 24.05**  **91.37 Note:**  Totals may not sum due to rounding

. **Source:** Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule ( EPA, 2011).24

**6(b) Estimating**  **Submitter Cost**  EPA multiplied b urden estimates by standard wage rates for managerial, technical, and clerical levels developed from information published by the Bureau of Labor Statistics (BL S) and a method outlined in the document Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b). Wage data for the three occupational categories was gathered for manufacturing industries from Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006

– June 2013 ( BLS, 2013a). The cost of fringe benefits, such as he alth insurance and vacation, is taken for each labor category from the same ECEC series. Following the methodology outlined in (EPA, 2002b), fringe benefits are calculated as a percentage of total wages for each category

. EPA added 17 percent to the wages in each category to account for overhead, based on information provided by the chemical industry

and chemical industry

trade associations in the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EP A, 2002a). The wages for each of the three categories were then multiplied by benefits and overhead factors to estimate loaded, annual salaries in year 2012 dollars. Table 5 contains the loaded wage rates f or the managerial, technical and clerical occupati on categories.
**Table 5**  **: Derivation of Loaded Wage Rates for the Private Manufacturing Sector in 2012$** 

**Wage 1**  **Fringe**

**Benefits 1**  **Fringes as %**

**of Wage Overhead %** 

**of Wage 2**  **Fringe +**

**Overhead Factor**  **Loaded Wages (a)**  **(b) (c) = (b)/(a)**  **(d) (e)=(1)+(c)+(d)**  **(f) = (a) x (e) Managerial**  $43. 95 $ 21.45 48.81 % 17% 1.6 6 **$72.87 Technical**  $ 38.53 $ 19.31 50.12 % 17% 1.67 **$64.39 Clerical**  $17. 64 $ 8.87 50.28 % 17% 1.6 7 **$29.51** 1 Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006

– June 2013 , US Bureau of Labor Statistics, November 15, 2013 (BLS, 2013a). 2 An overhead rate of 17 percent was estimated based on industry data gathered for the Revised Economic Analysis for the Amended Inventory Update Rule : Final Report (EPA, 20 11 )

. Table 6 contains the cost per activity of completing Form U for one new respondent

. Burden hours presented in Table 3 were multiplied by the corresponding loaded wage rat e in Table 5

. EPA estimates the total cost for completing and submitting one partial report for a new submitter is $3, 725 and the cost for completing and submitting one full report is $ 9,247

. More information on the derivation of these costs is found in the IUR EA (EPA, 2011 ). Similarly, Table 7 contains the cost per activity of completing Form U for one old respondent . Burden hours presented in Table 4 were multiplied by the corresponding loaded wage rat e in Table 5

. EPA estimates the total cost for completing and subm itting one partial report for an old submitter is $1, 694 and the cost for completing and submitting one full report is $ 6,061

. More information on the derivation of these costs is found in the IUR EA ( EPA, 2011 ).25

**Table 6**  **: Total Industry**  **Cost ,**  **by Activity , New Submitters** 
**Activity Clerical Cost**  **Technical Cost Managerial**  **Cost Total Cost**  **(2012$) (2012$)**  **(2012$) (2012$)**  **(a) (b)**  **(c) (d) = (a)+(b)+(c)**  **PREPARATION OF REPORT (Includes rule familiarization associated with each data element)** Part I. **Site Identification Inform ation**  Certification $0.00 $54.73 $73.60 $128.33 Com pany Information (Company Name, Contact, Address, D&B Number, Mailing Address) $0.00 $2.58 $1.46 $4.03 Plant Site Identification Plant Name, D&B Number Address, Mailing Address $0.00 $3.86 $1.46 $5.32 Im port Joint Submissions $0.00 $0.29 $0.62 $0.91 **Total for Part I $0.00**  **$61.46 $77.13**  **$138.60** Part II. **Manufacturing Information** Site Limited, Activity, Production Volume (pounds) (2015) $0.00 $146.81 $40.81 $187.62 Chemical Identification Up

- front CBI Substantiation $0.00 $93.37 $55.75 $149.11 Acc e ss ion Number Requests $0.00 $0.85 $0.00 $0.85 Plant Site Up

- Front Substantiation $0.00 $53.44 $37.16 $90.61 Total Number of Workers $0.00 $92.08 $42.63 $134.71 Maximum Concentration, Physical Form, Percent Volume of Production $0.00 $179.65 $77.97 $257.62 Production Volume for Each of the Years since Last Principal reporting Year (2012

- 2015) $0.00 $198.19 $55.09 $253.28 Production Volume Used on Site: $0.00 $12.82 $3.56 $16.38 Whether Chemical is Physically at Reporting Site $0.00 $7.34 $2.04 $9.38 Volume Exported $0.00 $66.06 $18.36 $84.43 Whether a Chemical is to be Recycled $0.00 $7.34 $2.04 $9.38 **Total for Part II $0.00**  **$857.95 $335.42**  **$1,193.37 Part III. Processing and Use Inform**  **ation**

Upfront substantiation for Processing and Use Information CBI Claims $0.00 $27.49 $19.12 $46.6126 **Activity Clerical Cost**  **Technical Cost Managerial**  **Cost Total Cost**  **(2012$) (2012$)**  **(2012$) (2012$)**  **(a) (b)**  **(c) (d) = (a)+(b)+(c)**  Industrial Processing and Use Exposure

- Related Data

Determination of Applicability $0.00 $64.86 $20.75 $85.61 Industrial Function Category $0.00 $300.38 $150.52 $450.90 Function Code $0.00 $60.20 $28.80 $89.01 Percent of Production Volume $0.00 $643.92 $384.34 $1,028.26 Total Number of Processing and Use Sites $0.00 $588.64 $256.74 $845.38 Total Number of Potentially Exposed Workers $0.00 $993.38 $279.04 $1,272.42 Consumer and Commercial Use Exposure

- Related Data

Determination of Applicability $0.00 $60.20 $18.27 $78.48 Production Category/Use by Children $0.00 $108.05 $17.96 $126.01 Percent of Production Volume $0.00 $81.00 $32.83 $113.83 Maximum Concentration by Category $0.00 $87.57 $25.09 $112.66 Number of Commercial Workers Reasonably Likely to be Exposed $0.00 $993.38 $279.04 $1,272.42 **Total for Part III $0.00**  **$4,009.07 $1,512.51**  **$5,521.58 Compliance Determination**  Com pliance Determination $0.00 $160.98 $0.00 $160.98 **Rule Familiarization** Rule Familiarization $0.00 $1,223.41 $655.84 $1,879.26 **REPORT SUBMISSION** Submission CDX Registration $0.00 $47.22 $13.36 $60.58

CDX electronic Signature $0.00 $64.39 $54.65 $119.04 **Total Submission $47.22**  **$13.36 $179.62** 27 **Activity Clerical Cost**  **Technical Cost Managerial**  **Cost Total Cost**  **(2012$) (2012$)**  **(2012$) (2012$)**  **(a) (b)**  **(c) (d) = (a)+(b)+(c)**  **RECORDKEEPING** Recordkeeping $22.13 $96.59 $54.65 $173.37 **TOTAL Cost Burden for one**  **Partial Report (Parts I, II,**  **Com pliance Determ** **ination, Rule Familiarization,**  **Recordkeeping and CDX Registration Activities**  **) $22.13**  **$2,447.61 $1,136.41**  **$3,725.19 Burden for one**  **Full Report (Parts I, II, III,**  **Compliance Determ** **ination, Rule Familiarization, Recordkeeping and**  **CDX Registration Activities**  **) $22.13**  **$6,456.68 $2,648.92**  **$9,246.78 Note:**  Totals may not sum due to rounding. **Source:** Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA 2011)28

**Table 7**  **: Total Industry**  **Cost ,**  **by Activity , Old Submitters** 
**Activity Clerical Costs**  **Technical Costs Managerial Costs**  **Total Costs (a)**  **(b) (c)**  **(d) = (a)+(b)+(c) PREPARATION OF REPORT (Includes rule familiarization associated with each data element)**  Part I. **Site Identification Inform ation**  Certification $0.00 $54.73 $73.60 $128.33 Com pany Information (U.S. Parent Company Name, D&B Number, Mailing Address, Technical Contact, Technical Contact Mailing Address) $0.00 $0.52 $0.29 $0.81 Plant Site Identification (Site Name, D&B Number, Mailing Address) $0.00 $0.64 $0.29 $0.94 **Total for Part I $0.00**  **$55.89 $74.18**  **$130.07** Part II. **Manufacturing Information** Site

- Limited, Activity, Production Volume (lb) (2015) $0.00 $117.45 $32.65 $150.09 Chemical Substance Identification Upfront CBI Substantiation $0.00 $74.69 $44.60 $119.29 Accession Number Requests $0.00 $0.85 $0.00 $0.85 Plant Site Upfront Substantiation $0.00 $42.76 $29.73 $72.49 Total Number of Workers $0.00 $73.66 $34.10 $107.77 Maximum Concentration, Physical Form, Percent Volume of Production $0.00 $143.72 $62.38 $206.10 Production Volume for Each of the Years since Last Principal Reporting Year (2012

- 2014) $0.00 $158.55 $44.07 $202.63 Production Volume Used On

- Site $0.00 $10.25 $2.85 $13.10 Whether Imported Chemical Substance is Physically at Reporting Site $0.00 $5.87 $1.63 $7.50 Volume Exported $0.00 $52.85 $14.69 $67.54 Whether a Chemical Substance is to be Recycled, Remanufactured, Reprocessed or Reused. $0.00 $5.87 $1.63 $7.50 **Total for Part II $0.00**  **$686.53 $268.34**  **$954.87 Part III. Processing and Use Inform**  **ation** Upfront substantiation for Processing and Use Information CBI Claims $0.00 $27.49 $15.29 $42.7929 **Activity Clerical Costs**  **Technical Costs Managerial Costs**  **Total Costs (a)**  **(b) (c)**  **(d) = (a)+(b)+(c)** Industrial Processing and Use Exposure

- Related Data Determination of Applicability $0.00 $51.89 $16.60 $68.49 Industrial Function Category $0.00 $227.43 $120.41 $347.84 Function Code $0.00 $48.16 $23.04 $71.21 Percent of Production Volume $0.00 $515.13 $307.47 $822.61 Total Number of Processing and Use Sites $0.00 $470.91 $205.40 $676.31 Total Number of Potentially Exposed Workers $0.00 $794.70 $223.23 $1,017.94 Consumer and Commercial Use Exposure

- Related Data Determination of Applicability $0.00 $48.16 $14.62 $62.78 Production Category/Use by Children $0.00 $43.31 $14.37 $57.68 Percent of Production Volume $0.00 $64.80 $26.26 $91.07 Maximum Concentration by Category $0.00 $70.06 $20.07 $90.13 Number of Commercial Workers Reasonably Likely to be Exposed $0.00 $794.70 $223.23 $1,017.94 **Total for Part III $0.00**  **$3,156.75 $1,210.01**  **$4,366.76 COMPLIANCE DETERMINATION**  Com pliance Determination $0.00 $160.98 $0.00 $160.98 **RULE FAMILIARIZATION** Rule Familiarization $0.00 $128.78 $145.74 $274.52 **REPORT SUBMISSION** Submission CDX Registration $0.00 $0.00 $0.00 $ 0.00 CDX Electronic Signature $0.00 $0.00 $0.00 $ 0.00 **Total Submission $0.00**  **$0.00 $0.00**  **$0.00**30 **Activity Clerical Costs**  **Technical Costs Managerial Costs**  **Total Costs (a)**  **(b) (c)**  **(d) = (a)+(b)+(c) RECORDKEEPING**  Recordkeeping $22.13 $96.59 $54.65 $ 151.24 **TOTAL BURDEN Burden for one**  **Partial Report (Parts I, II, Recordkeeping and**  **Submission) $22.13**  **$1,128.76 $542.92**  **$1,693.81 Burden for one**  **Full Report (Parts I, II, III, Recordkeeping and**  **Submission) $22.13**  **$4,285.52 $1,752.92**  **$6,060.57 Note:**  Totals may not sum due to rounding. **Source:** Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA 2011)**Page 31**  **of** 50

**6(c) Estimating Agency Burden and Cost**  EPA is responsible for the following activities associated with administering the CDR rule:

 Document receipt and tracking;
 Q uality

control of data , including protection of CBI ;  Backup s ys tems operation;
 Data processing;
 Sy stems development;
 Contract oversight and management;
 Publication of materials and creating pdfs of forms ; and
 Operation of the TSCA Hotline to handle CDR

- related calls. Costs related to EPA activities that involve using the data are not included. **(i) EPA Staff Activities**  Of the tasks listed above, Agency personnel are responsible for 1) quality control of data ; and 2) data processing, sy stems development, and contract oversight and management. Contractors perform the other activities, as described below. EPA estimates the total burden of completing Agency tasks to be one full

- time equivalent at the GS 13 level for data processing, s ys tems development, and contract oversight and management, per
- reporting cycle. Q u ality control of data will be completed by GS 12 level employees. Calculations of the Agency burden are presented in Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule ( EPA, 2011 ). EPA labor costs are based on annual fed eral wage rates published b y the Office of Personnel Management for the Washington

- Baltimore

-Northern Virginia, DC

- MD

- PA

- VA

- WV locality pay area for 2012 ( OPM, 201 3 ). Wages are presented in terms of GS

- level and step. Based on previous IUR economics anal ys es, a Step 3 is assumed for all FTEs (EPA, 2002a and EPA, 2005). Following the methodology outlined in Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a), EPA added 58 percent to the wage rate to account for fringe benefits and overhead costs. Table 8 shows the loaded wage rates for Agency staff at the GS

- 12 Step 3, and GS

- 13 Step 3 levels.**Page 32**  **of** 50

**Table 8**  **: D**  **erivatio n of Loaded Agency Wage Rates**  **(2010$) Pay Grade**  **Annual**

**Salary Overhead and Fringe** 

**Benefits (**  **% of w**  **ages )**  **Overhead and Fringe Benefit Cost**  **Total GS 12 Step 3**  $ 79,864 58% $ 46,321 $ 126,185 **GS 13 Step 3** $ 94,969 58% $ 55,082 $ 150,051 Source: The unloaded Federal salary for 20 10 is from the Office of Personnel Management salary table for Washington

- Baltimore

-Northern Virginia ( OPM, 201 3 ). Table 9 contains the burden and cost per report for all EPA staff activities in the first and future reporting cycles. The activities performed by the GS

- 13 level staff member, including sy stems development, and contract oversight and management, are fixed costs and are not dependent on the number of reports submitted to EPA. The total fixed cost burden for s ys tems development and contract oversight is one FTE at the GS

- 13 level, with a cost of $150,051. Quality control of data is performed b y the GS

- 12 level sta ff member and is dependent on the number of reports received. The burden for quality control of data is approximately 0.000007 per report with no electronic signature review and 0.00001FTE per report when there is electronic signature review. The total cos t per
- report is approximately $0.49 with electronic signature review and $1.32 without electronic signature review . The burden and cost of processing each data element in Form U are derived in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011) and is approximately 0.00008 hours per data element and 0.00081 hours for reviewing electronic signature forms, per submission. EPA multiplied these burdens by the number of data elements in each section (24 in Part I , 67 in Part II, and 78 in Part III) to estimate the total cost and burden of processing each Form U. For more detail on the derivation of these burdens , see the IUR EA ( EPA, 2011 ).
**Table 9**  **: EP**  **A Staff Burden and Cost of Processing One Report**

**Activity Agency Burden**  **per Activity (FTE)**  **Agency Burden**

**per Activity (hours)**  **Agency Cost**

**per Activity (2010$)**  **GS**
**- 12 Step**  **3 per**  **- Report Burden**  Quality Control of Data for Part I 0.0000009 0.0019 $0.12 Quality Control of Data for Part II 0.0000026 0.0054 $0.33 Quality Control of Data for Part III 0.0000030 0.0063 $0.38 Revie w of

Electronic Signatures 0.0000039 0.0081 $0.49 **Total GS**
**- 12 Burden, per report**  **without Electronic Signature 0.000007**  **0.0137 $0.83**  **Total GS**
**- 12 Burden, per report**  **with Electronic Signature 0.000010**  **0.0218 $1.32**  **GS**
**- 1**  **3 Step**  **3 Fixed Cost Burden**  Sy stems development, and contract oversight and management 1 2,080 $ 150,051 **Total GS**
**- 13 Burden, per**  **reporting cycle 1**  **2,080 $**  **150,051 Note:**  Totals may not sum due to rounding.**Page 33**  **of** 50

**(ii) Contractor Activities**  Agency costs also include pay

ment for extramural tasks completed by contractors (this category includes costs to EPA, but not burden hours). Contractor activities include document receipt, tracking, data review, maintaining backup systems, publication of materials , making pdfs of Form Us, and managing the TSCA H otline, as presented in Table 10 . With the exception of document receipt, tracking, and data review , all contractor costs are fixed and are not dependent on the number of reports received. All variable and fixed costs are taken from the last published ICR and were inflated from 200 8 to 20 12 dollars with an inflation factor calculated using the Employ ment Cost Index (ECI), seasonally adjusted, for management, professional, and related occupations in private industry ( BLS, 2013b ). **Table 10: Cost of Contractor Activities**

**Activity Annual Cost**  **2008$ Inflation** 

**Factor Annual Cost 2012$**  **Variable Costs** Document receipt, tracking, and data review for Part I $0.09 1.07 $0.10 Document receipt, tracking, and data review for Part II $0.26 1.07 $0.28 Document receipt, tracking, and data review for Part III $ 0.30 1.07 $0.3 2 **Total Cost of Docum ent receipt,**  **tracking, and data review, per full report**  **$ 0.65**  1.07 **$0. 70**  **Fixed Costs** Maintaining and Operating Back Up Sy stems $ 59,145 1.0 7 $ 63,385 Publication of materials and making a pdf of all Form U’s. $ 5,525 1.0 7 $5, 921 Managing the TSCA Hotline $ 44,694 1.0 7 $ 47,898 **Total Fixed Cost $**  **109,364** 1.07 **$ 117,204**  **6(d) Bottom** 
**- Line**  **Industry Burden and Cost**  **Estimates** This section describes the estimated social burden and cost of paperwork over the three ye ar ICR period

. The next CDR submission period will occur in 201 6 f or chemical s ubstances manufactured (including imported) during the calendar year s 201 2

- 2015

. Even though reporting occurs onl y once every

4 years, EPA expects rule compliance and data collection activities, and thus, costs and burdens , are in curred over the course of the reporting cycle. Therefore, for purposes of this anal ys is, the burden and cost for one reporting cycle are averaged over the number of ye ars in the reporting cycle and are presented here as average annual figures. This ICR supporting statement is for the three

- ye ar period of 2015 through 2017; therefore, average annual figures for each of these three years are presented below.**Page 34**  **of** 50

**Respondent T**

**ally** EPA calculated the numbers of expected sites and reports for the 2016 reporting cycle submitted based on submission information from the April 2013 version of the CDR database, which contains data from the most recent (2012) CDR collection. This database contained 32,358 reports from 4,753 sites on 7,674 chemic als. However, due to changes in reporting requirements between the 2012 and 2016 reporting cycle, EPA expects an increase in the number of sites reporting data, and the number of full and partial reports. Beginning with the 2016 EPA is lowering the reporting threshold for chemicals subject to certain TSCA orders from 25,000 pounds to 2,500 pounds and based on past data, expects that this will increase the number of chemicals with reports by 1,2 11 chemicals and the number of reports by 5, 106 reports

. 4 , 5 EPA is also requiring that sites must report on chemicals exceeding the reporting threshold in any calendar year since the last principal reporting ye ar , and not just if the threshold is exceeded in the reporting ye ar. EPA anticipates a 5 percent increase in the number of reporting sites and reports submitted as a result of this modification (EPA, 2011). Finall y , EPA is lowering the threshold for reporting downstream processing and use information from 100,000 pounds to 25,000 pounds (or 2,500 pounds for chemicals subject to certain TSCA actions ) . This means that, with the exception of reports for the 708 chemicals exempt from reporting downstream processing a use information (approximately 2,985 reports ), 6 all reports submitted will be full reports (See Appendix C of the Instructions for the 2012 TSCA Chemical Data Reporting (EPA, 2012) for a list of partial ly exempt chemicals )

. 7 After accounting for all these changes , EPA expects that 4,991 sites will submit 39, 337 reports (36, 352 full reports and 2,985 partial reports) in both the 2016 and 2020 reporting cycle. Table 11 contains a derivation of these numbers.

4 To calculate the number of chemicals subject certain TSCA orders that will report under CDR, EPA first counted 1,345 CAS and accession numbers subject to TSCA sections 5(a)(2), 5(b)(4), or 6; a consent agreement developed under the procedures of 40 CFR part 790; an order issued unde r section 5(e) or 5(f) of TSCA; or relief that has been granted under a civil action under TSCA sections 5 or 7, as listed in Appendix B of the Instructions for the 2012 TSCA Chemical Data Reporting (EPA, 2012). Then using assumptions presented in Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011) EPA assumed that 90% of these chemicals or 1,278 new

chemicals have a production volume between 2,500 and 25,000 pounds and will be reported under CDR. 5 To calculate the number of new reports resulting from the lowering of the reporting threshold for chemicals subject to certain TSCA Sections EPA multiplied the number of new chemicals that will now report under CDR, 1,278, by the average number of reports per chemical, 4.217, for a total of 5,389 new reports. 6 To calculate the number of reports submitted for the partially exempt chemicals EPA multiplied the number of new partial exempt chemicals, 708, by the average number of reports per chemical, 4.217, for a total o f 2,985 reports. 7 To calculate the number of reports submitted for the partially exempt chemicals EPA multiplied the number of new partial exempt chemicals, 708, by the average number of reports per chemical, 4.217, for a total of 2,985 reports.**Page 35**  **of** 50

**Table 11**  **: Number of Sites and Reports in the 2016 and 2020 Reporting Cycles** 

**Modification Number of Sites**  **Number of Reports Number of Full**  **Reports Baseline (2012 CDR data)**  **4,753 32,358**  **20,348 Step 1: Consider the 25,000 lb Threshold for Specific Regulated Chemical Substances to 2,500 lb**  Reduce the 25,000 lb Threshold for Specific Regulated Chemical Substances to 2,500 lb (1,278 more chemicals will report resulting in 5,389 reports) -- 5,106

--

**STEP 1 TOTAL 4,753**  **37,464**

-- **Step 2:Account for change in the method for determining whether you are subject to the CDR reporting requirements**  Method for Determining Whether you are Subject to the IUR Reporting Requirements (5% increase in the number of sites and reports) 238 1,873

--

**STEP 2 TOTAL 4,991**  **39,337**

-- **Step 3:Consider the effect of replacing the 300,000 lb threshold for processing and use reporting** Total Number of Reports from Step 2 (39,634 minus the number of reports for partially exempt chemicals, 2,985) -- -- 36,352

**TOTAL 4,991**  **39,337 36,352**  **Note:** Totals may not sum due to rounding As stated above, EPA assume s that the burden for previous submitters will be reduced because of efficiencies achieved through familiarity with the reporting process. Therefore , EPA must account for the number of “new” and “old” sites and technical contacts reporting under the 2016 and 2020 CDR reporting cycles

. Therefore , EPA used Toxics Release Inventory (TRI) data to estimate the number of new staff (either at a site new to CDR reporting or a technical contact at a site that has previously submitted data) reporting CDR data each year. EPA calculated the number of new sites reporting to TRI each ye ar between 2009 and 2012, for the Chemical Manufacturing (325) and Petroleum and Coal Products Manufacturing (324) NAICS codes and estimated that approximately 5.16 percent of all reporters are “new” submitters. EPA applied this percentage to the 2012 CDR data and estimates that there will be 258 new respondents and 4,733 old respondents will respond in the 2016 reporting cycle and 2020 reporting cycles, for a total of 4,991 submitters. EPA expects a total of 154 partial reports from new submitters and 2,831 partial reports from old submitters and 1,8 79 full reports from new submitters and 34, 473 full reports from old submitters. 8

8 To calc ulate the number of partial reports attributable to new and old submitters EPA first calculated the number of partial reports per submitter, 0.60 (2,985/4,991), and multiplied that number by the total of new and old submitters respectively. Similarly to calculate number full submitted by new and old submitters, the number of full reports per submitter, 7.34 (36,694/4,991), was multiplied that number by the total of new and old submitters.**Page 36**  **of** 50

**Table 12**  **: Number of New and Old Sites Reporting Data in the 2016 and 2020 Reporting Cycles**  **Sites Partial**  **Reports Full** 

**Reports Total Reports**  **New Submitters** 258 154 1,879 **2,033 Old Submitters**  4,733 2,831 34,473 **37,304 Total**  **4,991 2,985**  **36,352 39,337**  **Note:** Totals may not sum due to rounding Each site is expected to submit an average of 7.28 full reports and 0.60 partial reports in the 2016 and 2020 reporting cycles

. The average burden per new respondent is estimated to be 804 hours per cycle, or 201 hours annuall y. The average burden per old respondent is estimated to be 623 hours per cycle, or 156 hours annuall y. This is higher than the burden estimated for the currentl y approved ICR due to both program changes and an adjustment in reporting requirement criteria, including additional data requirements and modifications to reporting thresholds. **Total Industry Bu**  **rden/ Cost for**  **New Submitters** . EPA estimates the total industry burden per reporting cycle for new submitters to be 207,612 hours. Given that this data collection is part of a four

- year reporting cycle, EPA estimates the annual industry burden for 2015, 201 6, and 2017 to be 51,903 hours. As presented in Table 13, EPA estimates the total cost to industry of a four

- ye ar reporting cycle to be $ 13.8 million or an annual cost of $ 3.44 million.
**Table 13**  **: Estimated Respondent Burden and Cost for New Reporters** 

**Activity Total** 

**Burden per**  **Activity (hours)**  **Total**

**Number of Units**  **Total Cost**

**per Activity**  **Total**

**Burden per Reporting**  **Cycle (hours)**  **Total Cost**

**per Reporting**  **Cycle (2008$)**  **Annual**

**Burden (hours)**  **Annual**

**Cost (2012$)**  **(2012$) Compliance**  **Determ ination**  **(per Site)** 2.50 258 Sites $161 645 $41,532 **161 $10,383**  **Rule Fam** **iliarization (per Site)**  28.00 258 Sites $1,879 7,224 $484,848 **1,806 $121,212**  **CDX Registration**  **Activities (per Site)**  2.67 258 Sites $180 688 $46,343 **172 $11,586** 
**Part I Preparation**  2.01 258 Sites $139 519 $35,758 **130 $8,940**  **Partial Report Preparation**  17.93 154 Partial Reports $1,193 2,761 $183,779 **690 $45,945**  **Full Report Preparation**  100.95 1,879 Full Reports $6,715 189,676 $12,617,402 **47,419 $3,154,351**  **Recordkeeping** 3.00 2,033 Reports $173 6,099 $352,462 **1,525 $88,115**  **Total Industry Burden and Cost for New Reporters 207,612**  **$13,762,124 51,903**  **$3,440,531 Note:**  Totals may not sum due to rounding**Page 37**  **of** 50

**Total Industry Burden and**  **Cost for Old Submitters** 

. EPA estimates the total industry burden per reporting cycle for old submitters to be 2.95 million hours. Given that this data collection will occur every four years, EPA estimates the annual industry burden to be 737,300 hours. As presented in Table 14, EPA estimates the total cost to industry per reporting cycle would be $ 194 million, or an annual cost of $48.6 million
**Table 14**  **: Estimated Annual Respondent Burden and Cost for Old Reporters** 
**Activity Total** 

**Burden per**  **Activity (hours**  **) Total** 

**Number of Units**  **Total Cost**

**per Activity**  **Total**

**Burden per Reporting**  **Cycle (hours)**  **Total Cost**

**per Reporting**  **Cycle (2008$)**  **Annual**

**Burden (hours)**  **Annual**

**Cost (2012$)**  **(2012$) Compliance**  **Determ ination**  **(per Site)** 2.50 4,733 Sites $161 11,833 $761,896 **2,958 $190,474** 
**Rule Fam** **iliarization (per Site)**  4.00 4,733 Sites $275 18,932 $1,299,318 **4,733 $324,830**  **CDX Registration**  **Activities (per Site)**  0.00 4,733 Sites $0 0 $0 **0 $0** 
**Part I Preparation**  1.89 4,733 Sites $130 8,955 $615,639 **2,239 $153,910**  **Partial Report Preparation**  14.34 2,831 Partial Reports $955 40,609 $2,703,231 **10,152 $675,808**  **Full Report Preparation**  79.97 34,473 Full Reports $5,322 2,756,961 $183,452,459 **689,240 $45,863,11**  **5 Recordkeeping**  3.00 37,304 Reports $151 111,912 $5,641,811 **27,978 $1,410,453**  **Total Industry Burden and Cost for the First Reporting Cycle**  **2,949,201 $194,474,355**  **737,300 $48,618,58**  **9 Note:**  Totals may not sum due to rounding **Annual Industry Burden and Cost**  **for All Submitters**  **.** As shown in Table 1 5 , EPA calculated the estimated total annual respondent burden and cost associated with this I CR by summing the burdens and costs for new and old submitters . The total annual burden associated with this I CR renewal is 789,203 hours. The total annual cost is $52 million.**Page 38**  **of** 50

**Table 1 5**  **: Estimated Annual Average Burden and Cost Associated with this ICR** 
**Activity New**  **Old Total** 

**Annual Burden**  **(hours) Annual** 

**Cost (2012$)**  **Annual**

**Burden (hours)**  **Annual Cost**

**(2012$) Annual** 

**Burden (hours)**  **Annual Cost**

**(2012$) Compliance**  **Determ ination**  **(per Site)** 161 10,383 2,958 190,474 **3,119 $200,857** 
**Rule Fam** **iliarization (per Site)**  1,806 121,212 4,733 324,830 **6,539 $446,042**  **CDX Registration**  **Activities** 172 11,586 0 0 **172 $11,586**  **Part I Preparation**  **(per Site)**  130 8,940 2,239 153,910 **2,369 $162,849**  **Partial Report Preparation**  **(Part II)** 690 45,945 10,152 675,808 **10,842 $721,753**  **Full Report Preparation**  **(Part II and Part III)**  47,419 3,154,351 689,240 45,863,115 **736,659 $49,017,465**  **Recordkeeping (per Report)**  1,525 88,115 27,978 1,410,453 **29,503 $1,498,568**  **Total 51,903**  **$3,440,531 737,300**  **$48,618,589 789,203**  **$52,059,120**

**Average Burden and Cost**  **per Site.** As shown in Table 16, the Agency estimates the ty pical respondent burden for this in formation collection activity to be 803 hours for new submitters and 623 hours for old submitters

. Given that a collection will occur once every four ye ars, the average annual burden is 201 hours for new submitters and 156 hours for old submitters

. Th e s e burden estimate s assume each site will submit an average of 7.28 full reports and 0.60 partial reports. This is a decrease of 0.66 partial reports per site and an increase of 2

. 21 full reports per site compared to the average number of reports completed p er site presented in the currently

approved ICR.**Page 39**  **of** 50

**Table 16**  **: Average**  **Burden per Site Activity**  **Burden Hours Total**  **Hours per Activity**  **Reports**

**per Average**  **Site Total Burden** 

**(hours per average site)**  **Annual**

**Burden (hours per**  **average site) Clerical**  **Technical Managerial**  **New Rule**  **Fam iliarization,**  **Compliance Determ** **ination, CDX**  **Registration Activities and**  **Part I Preparation**  0.00 23.45 10.81 34.26 1 **34.26 8.57** 

**Partial Report Preparation**  **(Part II,** 0.00 13.32 4.60 17.93 0.60 **10.72 2.68**  **Full Report Preparation**  **(Part II and Part III,**  0.00 75.59 25.36 100.95 7.28 **735.24 183.81**  **Recordkeeping** 0.75 1.50 0.75 3.00 7.88 **23.65 5.91**  **Total Hours 803.87**  **200.97 Old**  **Rule Fam** **iliarizatio n,**  **Compliance Determ** **ination, CDX**  **Registration Activities and**  **Part I Preparation**  0.00 5.37 3.02 8.39 1.00 **8.39 2.10** 

**Partial Report Preparation**  **(Part II, per Report)**  0.00 10.66 3.68 14.34 0.60 **8.58 2.15**  **Full Report Preparation**  **(Part II and Part III, per Report)**  0.00 59.69 20.29 79.97 7.28 **582.49 145.62**  **Recordkeeping (per Report)**  0.75 1.5 0.75 3.00 7.88 **23.65 5.91**  **Total Hours 623.11**  **155.78 Page**  **40 of**  50

Table 17 presents the average cost per site, by activity , for a CDR respondent . EPA estimates the average site will submit 7.28 full reports and 0.60 partial reports in each reporting c yc le. New sites are expected to incur a total cost of $ 53,287 for Form U completion and submission and olds sites will incur a cost of $41,263per submission

. **Table 17**  **: Average Cost**  **per Site**

**Ac tivity**  **Cost ($2012) Total**  **Cost per Activity**  **Reports**

**per Average**  **Site Total** 

**Burden (Cost per**  **average site) Annual** 

**Burden (Cost per**  **average site)**  **Clerical Technical**  **Managerial New**  **Rule Familiarization ,**  **Compliance Determina** 
**** **tion, CDX Registration Activities and Part I**  **Preparation** $0 $1,510 $788 $2,298 1 **$2,298 $574** 
**Partial Report Preparation (Part II,**  $0 $858 $335 $1,193 0.60 **$714 $178**  **Full Report Preparation (Part II and Part III,**  $0 $4,867 $1,848 $6,715 7.28 **$48,908 $12,227**  **Recordkeeping** $22.13 $96.59 $54.65 $173 7.88 **$1,366 $342**  **Total Cost $53,287**  **$13,322**

**Old Rule Familiarization.**  **Compliance Determina**
  ** tion, CDX Registration** **Activities and Part I Preparation**  $0 $346 $220 $566 1 **$566 $141** 
**Partial Report Preparation (Part II,**  **per Report)**  $0 $687 $268 $955 0.60 **$571 $143**  **Full Report Preparation (Part II and Part III,**  **per Report)** $0 $3,843 $1,478 $5,322 7.28 **$38,760 $9,690**  **Recordkeeping (per Report)**  $22.13 $96.59 $54.65 $173 7.88 **$1,366 $342**  **Total Cost $41,263**  **$10,316** Table 18 presents the annual burden hours, organized by information collection, and annual averages for the ICR period (2015

- 2017), for CDR respondents. **T able 1**  **8 : Annual Information Collection Tally for**  **New and Old Submitters** **Page 41**  **of** 50

**Inform ation**  **Collection No. of** 

**Respondents No. of** 

**Responses / Respondent**  **Responses**

**Subtotal Annual Burden** 

**Hours per Response**  **Annual Burden**

**Hours Subtotal**
**New Submitters** Com pliance Determination 258.0 1.0 258.0 0.63 161 Rule Familiarization 258.0 1.0 258.0 7.00 1,806 CDX Registration Activities 258.0 1.0 258.0 0.67 172

 CDX Registration 258.0 1.0 258.0 0.23 59

 ESA 258.0 1.0 258.0 0.44 113 Prepare Part I of Form U 258.0 1.0 258.0 0.50 130 Prepare and Submit Report, and Maintain Records

– Partial Report 258.0 0.60 154.0 5.23 806

 Part II of Form U 258.0 0.60 154.0 4.48 690

 Recordkeeping 258.0 0.60 154.0 0.75 116 Prepare and Submit Report, and Maintain Records

- Full Report 258.0 7.28 1,879.0 25.99 48,828

 Part II and III of Form U 258.0 7.28 1,879.0 25.24 47,419

 Recordkeeping 258.0 7.28 1,879.0 0.75 1,409 **Old Submitters** Com pliance Determination 4,733 1 4,733 0.63 2,958 Rule Familiarization 4,733 1 4,733 1 4,733 CDX Registration Activities 4,733 0 0 0 0

 CDX Registration 4,733 0 0 0 0

 ESA 4,733 0 0 0 0 Prepare Part I of Form U 4,733 1 4,733 0.47 2,239 Prepare and Submit Report, and Maintain Records

– Partial Report 4,733 0.60 2,831 4.34 12,275**Page 42**  **of** 50

**Inform ation**  **Collection No. of** 

**Respondents No. of** 

**Responses / Respondent**  **Responses**

**Subtotal Annual Burden** 

**Hours per Response**  **Annual Burden**

**Hours Subtotal**

 Part II of Form U 4,733 0.60 2,831 3.59 10,152

 Recordkeeping 4,733 0.60 2,831 0.75 2,123 Prepare and Submit Report, and Maintain Records

- Full Report 4,733 7.28 34,473 20.74 715,095

 Part II and III of Form U 4,733 7.28 34,473 19.99 689,240

 Recordkeeping 4,733 7.28 34,473 0.75 25,855 **Average Burden for ICR Period** Com pliance Determination 4,991 1 4,991 0.63 3,119 Rule Familiarization 4,991 1 4,991 1.31 6,539 CDX Registration Activities 258 1 258 0.67 172

 CDX Registration 258 1 258 0.23 59

 ESA 258 1 258 0.44 113 Prepare Part I of Form U 4,991 1 4,991 0.47 2,369 Prepare and Submit Report, and Maintain Records

– Partial Report 4,991 0.60 2,986 4.38 13,081

 Part II of Form U 4,991 0.60 2,986 3.63 10,842

 Recordkeeping 4,991 0.60 2,986 0.75 2,239 Prepare and Submit Report, and Maintain Records

- Full Report 4,991 7.28 36,352 21.01 763,923

 Part II and III of Form U 4,991 7.28 36,352 20.26 736,659

 Recordkeeping 4,991 7.28 36,352 0.75 27,264 Some burden estimate subtotals may not calculate due to rounding of unit burden estimates Table 19 presents the total burden hours for the ICR period (2015

- 2017), organized by information collection, for CDR respondents.**Page 43**  **of** 50

**Table 19**  **: Total**  **Information Collection Tally for ICR Reporting Period ( 2015** 
**- 2017** **)**
**Inform ation Collection**  **No. of Respondent**  **s No. of** 

**Responses / Respondent**  **Responses**

**Subtotal Total Burden** 

**Hours per ICR Period**  **Annual**

**Burden Hours**  **Subtotal New Submitters**  Com pliance Determination 258 1 258 1.88 484 Rule Familiarization 258 1 258 21.00 5,418 CDX Registration Activities 258 1 258 2.00 516

 CDX Registration 258 1 258 0.69 177

 ESA 258 1 258 1.31 339 Prepare Part I of Form U 258 1 258 1.51 390 Prepare and Submit Report, and Maintain Records

– Partial Report 258 0.60 154 15.70 2,417

 Part II of Form U 258 0.60 154 13.45 2,071

 Recordkeeping 258 0.60 154 2.25 347 Prepare and Submit Report, and Maintain Records

- Full Report 258 7.28 1,879 77.96 146,485

 Part II and III of Form U 258 7.28 1,879 75.71 142,257

 Recordkeeping 258 7.28 1,879 2.25 4,228 **Old Submitters**  Com pliance Determination 4,733 1 4,733 1.88 8,874 Rule Familiarization 4,733 1 4,733 3.00 14,199 CDX Registration Activities 4,733 0 0 0.00 0

 CDX Registration 4,733 0 0 0.00 0

 ESA 4,733 0 0 0.00 0 Prepare Part I of Form U 4,733 1 4,733 1.42 6,716 Prepare and Submit Report, and Maintain Records

– Partial Report 4,733 0.60 2,831 13.01 36,826

 Part II of Form U 4,733 0.60 2,831 10.76 30,457

 Recordkeeping 4,733 0.60 2,831 2.25 6,370 Prepare and Submit Report, and Maintain Records

- Full Report 4,733 7.28 34,473 62.23 2,145,285

 Part II and III of Form U 4,733 7.28 34,473 59.98 2,067,720**Page 44**  **of** 50

**Inform ation Collection**  **No. of Respondent**  **s No. of** 

**Responses / Respondent**  **Responses**

**Subtotal Total Burden** 

**Hours per ICR Period**  **Annual**

**Burden Hours**  **Subtotal**

 Recordkeeping 4,733 7.28 34,473 2.25 77,564 **Average Burden for ICR Period** Com pliance Determination 4,991 1 4,991 1.88 9,358 Rule Familiarization 4,991 1 4,991 3.93 19,617 CDX Registration Activities 258 1 258 2.00 516

 CDX Registration 258 1 258 0.69 177

 ESA 258 1 258 1.31 339 Prepare Part I of Form U 4,991 1 4,991 1.42 7,106 Prepare and Submit Report, and Maintain Records

– Partial Report 4,991 0.60 2,986 13.14 39,244

 Part II of Form U 4,991 0.60 2,986 10.89 32,527

 Recordkeeping 4,991 0.60 2,986 2.25 6,716 Prepare and Submit Report, and Maintain Records

- Full Report 4,991 7.28 36,352 63.04 2,291,770

 Part II and III of Form U 4,991 7.28 36,352 60.79 2,209,978

 Recordkeeping 4,991 7.28 36,352 2.25 81,792 Some burden estimate subtotals may not calculate due to rounding of unit burden estimates **Agency Tally** Table 20 present s the Agency costs associated with the CDR rule. EPA multiplied the costs per report b y the total number of Parts I, II, and III to calculate the total burden and cost associated with the number of reports EPA expects to be submitted. For each reporting cyc le the total burden is 0.208 FTEs and the total cost is $ 48.152 for variable cost activities. The burden and cost of the fixed cost activities remains unchanged b y the number of reports submitted; the total fixed burden is one FTE per reporting cycle and the cost is $ 150,051 . The total Agency burden is 1. 21 FTEs and the estimated total cost incurred b y the Agency is $ 198,203. The total agency cost and burden was calculated b y summing the Agency staff and contractor activities.**Page 45**  **of** 50

**Table 20**  **: Total Cost and Burden of Agency Activities, per Reporting Cycle** 
**Activity Staff**  **Form U**  **Section Total** 

**Burden per**  **Activity (FTE)**  **Total**

**Number of Units**  **Total**

**Cost per Activity**  **( 2012$**  **) Total** 

**Burden (FTE)**  **Total Cost ( 2012$**  **)**

**Variable Burdens and Costs** Document receipt, tracking, and data review Contractor Part I N/A 4,991 Sites $0.10 N/A $493
Part II N/A 37,464 Part IIs $0.28 N/A $10,338
Part III N/A 34,479 Part IIIs $0.32 N/A $11,076

Quality Control of Data EPA

Em ployee (GS

- 12 Step 3) Part I 0.0000009 4,991 Sites $0.12 0.005 $588 Part II 0.0000026 37,464 Part IIs $0.33 0.098 $12,324 Part III 0.0000030 34,479 Part IIIs $0.38 0.105 $13,205 Electronic Signature Agreements 0.0000039 258 Sites $0.49 0.001 $127

**Total Variable Cost and Burden**  **0.208 $48,152**  **Fixed Burden s**  **and Costs** Data Processing, Sy stems Development, and Contract Oversight and Management EPA

Em ployee (GS

- 13 Step 3) N/A N/A N/A N/A 1.000 $ 150,051

Maintaining and Operating Back Up Sy stems Contractor N/A N/A N/A N/A N/A N/A Printing and Publishing Form s and Materials Contractor N/A N/A N/A N/A N/A N/A Managing the TSCA Hotline Contractor N/A N/A N/A N/A N/A N/A **Total Fixed Cost and Burden 1**  **$150,051 Total Agency Cost and Burden**  **1.21 $198,203** 

**6(e) Reasons for Change in Burden**  EPA estimates industry

will incur an increase of 315,0 8 0 hours in annual burden compared to the estimate in the information collection request most recently approved by

OMB (from 474,1 2 3 hours to 789,203 hours ). Differences in burden and costs from the previous I CR are attributed to both program and adjustments changes. Adjustments capture changes in the baseline burden not included in the currently approved IC R . These changes result from updates**Page 46**  **of** 50

to the number of affected sites and wages and the correcti on of e stimates in the previous ICR. Program changes account for changes in reporting requirements between the 2012 and 2016 reporting cycles. Adjustment Changes The previous currentl y approved used data from the 2006 IUR to estimate the number of sites and partial and full reports submitted to EPA. EPA I CR No. 1884.06 estimated that a total of 4,153 sites would submit 3,696, partial reports and 23,838 full reports over the ICR period. EPA has adjusted the number of sites and reports using data from the April 2013, 2012 CDR database where a total of 4,753 sites submitted 12,010 partial reports and 20,348 full reports. The previous ICR assumed all reporters would complete CDX registration activities; however, because CDX registration is a one

- time action, EPA assumes that after a site’s first reporting cycle, submitters will not incur any burden or cost for this IC activity

. Therefore, this ICR calculates separate costs for new submitters who incur CDX registration and electronic signature burdens and for old submitters who have already incurred these costs. The previous ICR covered parts of the 2012 and 2016 reporting cycles, therefore EPA assumed that all submitters would incur the larger “new” submitter burden in the first two years of the anal ys is and all submitters would incur the smaller “old” submitter burden in the last year of the anal ys is. For this ICR EPA assumed that approximately 95% of submitters would incur the lower “old” submitter burden for al l three ye ars. In addition, annual burden for the previous IC R partially covered portions of two reporting cycles, including two years of 2012 cycle reporting and one ye ar of 2016 cycle reporting. The burden for the previous IC R averaged the annual burden over a six year period for 2012 reporting cycle and over a four year period for the 2016 burden and included a portion of the hours for each of those cycles. Because the 2016 and 2020 reporting cycles are 4 years, EPA adjusted the baseline burden estimate s be averaged over a four ye ar period only

. All costs were inflated from 200 8 $ to 20 12 $, which slightly increased the costs associated with the rule. The total of all of the adjustments results in an increase of the baseline total burden of 2,573 hours and an increase in the annual burden of 858 hours. Program Changes Beginning with the 2016 reporting cycle, EPA is lowering the reporting threshold for chemicals subject to certain TSCA orders from 25,000 pounds to 2,500 pounds, requiring that sites must report on chemicals exceeding the reporting threshold in any calendar ye ar since the last principle reporting year, and is lowering the threshold for reporting downstream processing and use information from 100,000 pounds to 25,000 pounds. After accountin g for all these changes, EPA expects that the number of sites and full reports submitted will increase, and there will be a decrease in the number of partial reports submitted, for a total of 4,991 sites submitting 39,337 reports (36,352 full reports and 2 ,985 partial reports).**Page 47**  **of** 50

In addition, beginning with the 2016 reporting cycle, sites will be required to submit production volumes for all years in the reporting cycle, as opposed to the production volume for just the reporting ye ar. This will slightly incre ase the burden for completing Part II of Form U. The program changes results in an increase of the baseline total burden of 942,684 hours and an increase in the annual burden of 314,228 hours.
**Table 21**  **: Total Estimate of Annual Burden Hours and Annualized Cost Comparisons**  **Annual Burden Hours** Current OMB Inventory **474,122** Change in Burden due to Adjustments 852 Change in Burden due to Program Changes 314,228 Total Change in Burden 315,080 **Total Burden 789,203**  **6(f) Burden Statement**  The annual public burden for this collection of information, which is approved under OMB Control No. 2070

- 0162, is estimated to average 158 hours per respon se , which may include reporting on multiple chemicals . According to the Paperwork Reduction Act, “burden” is defined in 5 CFR 1320.3(b). An Agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control number for this information collecti on is 2070

- 0162. The OMB control numbers for EPA's regulations in title 40 of the CFR, after appearing in the Federal Register when approved, are listed in 40 CFR Part 9, and are displayed either by publication in the Federal Register or by other appropriate means, such as on the related collection instrument or form, if applicable. The Agency

has established a public docket for this I CR under Docket ID No. EPA

- HQ

OPPT

- 2013

- 0721, which is available for online viewing at www.regulations.gov, or in

-person v iewing at the Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). The EPA/DC Public Reading Room is located in the EPA West Building, Room 3334, 1301 Constitution Ave., N.W., Washington, DC. The EPA/DC Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the EPA/DC Public Reading Room is (202) 566

- 1744, and the telephone number for the Pollution Prevention and Toxics Docket is (202) 566

- 0280.**Page 48**  **of** 50

You may submit comments regarding the Agency's need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden, including the use of automated collection techniques. Submit your comments, referencing Docket ID No. EPA

- HQ

- OPPT

- 2013

- 0721 and OMB Control No. 2070

- 0162, to (1) EPA online using www.regulations.gov (our preferred method), or b y mail to: Pollution Prevention and Toxics Docket, Environmental Protection Agency Docket Center (EPA/DC) , Mailcode: 28221T, 1200 Pennsylvania Ave., N.W., Washington, DC 20460, and (2) OMB b y mail to: Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, N.W., Washington, DC 2050 3.**Page 49**  **of** 50

**7. Sources**  BL S 2013a . U.S. Bureau of Labor Statistics. Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006

– June 2013

. (November 15, 2013 )

. http://www.bls.gov/ncs/ect/sp/ecsuphst.pdf. BL S, 2013b. U.S. Bureau of Labor Statistics. Employment Cost Index. Total compensation, private industry , index number, Management, professional, and related, seasonally adjusted. (November 22, 2013). http://data.bls.gov/pdq/query tool.jsp?survey=ci

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

-HQ

- OPPT

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- 0054

- 0260). Augu st 2002

. EPA, 2002b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Wage Rates for Economic Analysis of the Toxics Release Inventory Program. June 10, 2002. EPA, 2005. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Anal ys is Branch. Economic Analysis of IUR Modifications Final Rule (EPA

-HQ OPPT 2004

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2005

. EPA, 2006. US EPA, Office of Pollution Prevention and Toxics, Instructions for Reporting for the 2006 Partial Updating of the TSCA Chemical Inventory Database . Nov. 2006. Available at http://www.epa.gov/iur/pubs/2006_inst_tsca_cheminv.pdf

. EPA, 2 007. U.S. EPA, Office of Environmental Information. A Business Case Analysis of EPA’s Central Data Exchange . March, 2007. EPA, 2008. U.S. EPA, Office of Pollution Prevention and Toxics, Information Management Division, 2006 IUR Database Statistics for IUR Modifications Rule . Washington, DC. December 17, 2008. EPA, 2009a. U.S. EPA, Office of Pollution Prevention and Toxics. TSCA Section 4 Federal Register Enforceable Consent Agreements. http://www.epa.gov/oppt/chemtest/pubs/4eca.html

. Washington, DC. Updated October 1, 2009. EPA, 2009b. U.S. EPA, Office of Pollution Prevention and Toxics, Sunset Dates of Chemicals Subject to Final TSCA Section 4 and Related 12(b) Actions, Modified on Septem ber 1, 2009. http://www.epa.gov/oppt/chemtest/pubs/sunset.html

. Washington, DC. Updated September 1, 2009. EPA, 2010

. TSCA Section 5 Premanufacture and Significant New Use Notification Electronic Reporting; Revisions to Notification Regulations; Final rule. Federal Register (7 5 FR 773

- 790 ), January

6, 2010 )**Page 50**  **of** 50

EPA, 2011 . U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Anal ys is Branch

. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule . June, 2011

. EPA, 2012

. ICR No. 1884.0 6

. [Information Collection Request for] Partial Update of the TSCA Section 8(b) Inventory

Data Base, Production and Site Report Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act

. January 27, 2012

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-DCB, Washington Baltimore

Northern Virginia, DC

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-PA

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- WV. Accessed from http://www.opm.gov/policy

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oversight/pay

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.