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: Partial Update of the TSCA Section 8(b) Inventory Data Base, 

Production and Site Reports (Chemical Data Reporting)

EPA ICR No.: 1884.08 OMB Control No.: 2070-0162

1(b) Short Characterization/Abstract

The following information collection request (ICR addresses the paperwork requirements 

contained in a final rule (RIN 2070-AJ43) that amended the information collection activities of 

the TSCA Chemical Data Reporting (CDR) rule, formerly 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 CDR 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 use 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 greatly 

improved the reporting process, both for EPA and for manufacturers (including importers). The 

electronic reporting system (e-CDR) contained 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 that 
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CDR data 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 substantiation for Confidential Business Information 

(CBI) claims. As a result of this requirement, fewer CBI claims have been made; 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 effective 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 all reporting years since the last reporting year (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 substantially from one submission period to the next, more current information enhances 

the Agency’s ability to make more accurate chemical substance risk assessment 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. In 2012, the threshold was 100,000 pounds. 

This change provides exposure-related processing and use information to EPA and others for 

moderate-volume chemical substances, enabling the Agency to assess 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 ICR period. The details of the 

paperwork burden and cost estimates are discussed in this document.

2. NEED FOR AND USE 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 nonconfidential information publicly available in order to promote informed decision-making and 

transparency. CDR data helps the Agency to identify, assess, and control potential risks to human 
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health and the environment posed by commercial chemical substances. TSCA section 8(a) 

authorizes the Administrator 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 information 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 will enhance the capabilities of the Agency and other 

federal 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 effectively and expeditiously identify and address potential risks 

posed by chemical substances 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.
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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. Persons 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 Exchange (CDX). Users of CDX are required to register

with the system, including submitting an authorized signature agreement to EPA.

CDX Registration

Each CDR submission must have an associated authorized official. The authorized official

signs the certification statement and submits 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 electronically 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 individual 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 officials. 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 exposurerelated data. EPA will use the information it is collecting in the following ways:

(1) U.S. parent company identification information: Company identification information 

is collected already by the current CDR. EPA also 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 years 2012, 2013, 2014, and 2015. 
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For subsequent CDR collections, determination of the need to report will be based on 

whether, for any calendar year since the last principal reporting year, 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 

processing 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 

used at the reporting site: This data element identifies whether a chemical substance is 

used by the reporting site. Either domestically manufactured or imported chemical 

substances can be reported as used at the reporting site. This information is related to 

potential exposures associated with the on-site volumes, and provides the Agency with 

information for exposure assessments and other data analyses. 

 Whether an imported chemical substance is physically at the reporting site: This data 

element enables the Agency and others to better assess manufacturing-related potential 

exposures, thereby enabling information for screening-level analyses 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 by the reported processing and use information. CDR processing and use 

information is required only for domestic use situations, 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 likely to be exposed to each reportable chemical 

substance during manufacture at each site. This exposure-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 chemical: 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.

 Whether a manufactured (including 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 efficiencies 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 total 
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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: Data elements 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 substance exposure and risk screening, testing and/or priority setting, 

and exposure estimation required by 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 analyses. Each data element 

corresponds to a data point necessary for basic risk-screening.

The reporting threshold for processing and use information 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 lowervolume 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 type of 

process or use operation (TPU), the industrial sector (IS) codes and the Industrial 

Function Category (IFC). The IS 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 exposure data: These data are 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 

screening of the chemical substance. Additionally, within the consumer product 

category, submitters must 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 Agency 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 imported 
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TSCA chemical substance because the foreign supplier 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 confidential. In such 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 submissions. Because signatures are 

required by 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 be able to access the information 

provided by 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 by the primary and secondary

respondents will be saved and combined as one joint submission. EPA will process the 

joint submission once all Form Us are received and matched 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 identify 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 contact 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. 
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 Trade product identification information: These data identify the primary submitters’ 

company name, site name, and site address, as well as the CAS Registry Number, the 

appropriate specific chemical identities, and product composition. These data are 

needed by EPA to combine the secondary submitters’ chemical-specific information 

with the primary submitters’ information to result in a complete CDR submission.

Information secured through the CDR collections is used increasingly by a wide variety of 

governmental and non-governmental users. Consistent with Congress’ intent that TSCA data be 

used to facilitate 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-Net1and 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 comprehensively or 

systematically 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 ICR 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.

 

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

2

INFORM is a nonprofit environmental research organization.
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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 ICR respondents and data users about 

specific aspects of an ICR before the Agency submits the ICR 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 ICR 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 years. 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, especially 

by the public. EPA recognizes that some information submitted to the Agency is legitimately 

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 confidential if such 

information reveals the submitter’s trade secrets or proprietary information as defined by TSCA 

section 14 and existing TSCA regulations. EPA has long-established procedures for handling, 

storing, processing, and disposing of TSCA confidential information. Transfers of this 

information to other governmental agencies can be made only if the other agency agrees to adhere 

to all TSCA confidentiality provisions. EPA will maintain standard CBI procedures to protect any

confidential, trade secret, 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.
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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 System (NAICS) code categories:

325 - Chemical Manufacturing

324 - Petroleum and Coal Product Manufacturing

The subsectors 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 types 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 respondents listed above, manufacturers (including 

importers) of byproducts are required to report under the CDR rule. Byproduct 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 

byproduct 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 listed 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 byproduct substance 

that is chemically different from the starting substance; the manufacturer (including importer) 

therefore may incur reporting obligations under the CDR for that byproduct. 

4(b) Information Requested

(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 year since the previous reporting year. Beginning in 2016, 

the reporting threshold for processing and use information will be 2,500 pounds for certain 

chemical substances that are:
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 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 chemical 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 requirements

The CDR data elements are related to or indicative of three components of exposure. 

These components are: (1) the number of ecosystems 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 reasonably 

ascertainable” manufacturing, processing, and use exposure-related information. 

Using e-CDRweb, individuals report the data elements as follows: 

 Authorized company official’s e-mail address. The e-mail address of the company

official authorized to sign and submit the CDR Form U.

 U.S. parent company name and 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 years since the last principal reporting 

year; the volume of the reported chemical substance used at the reporting site; whether 

an imported chemical substance is physically 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 byproduct, is being 

recycled, reused, reprocessed, or remanufactured.

 Processing and use information. The reporting threshold 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 substances, unless the chemical substance is specifically partially 

exempted.
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 Industrial processing and use data. Submitters must report their industrial function. 

They choose from a list of industrial function categories.

 Consumer and commercial use data. Respondents must indicate whether the use is 

consumer, commercial or both, and, if commercial, the number of commercial workers 

reasonably likely 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 

will not disclose to the respondent the specific chemical name of the imported TSCA Inventory

chemical substance or of a reactant used to manufacture 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 product 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 belief: 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 submissions, and percentage of each 

chemical substance component of a trade product. 
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(iii) Submitter Activities/Information Collections (ICs)

EPA identified the following ICs in the currently-approved ICR for activities that 

submitters would complete when complying 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 

Information

Collection

Description

Compliance 

Determination 

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. 

For 2016 and all future reporting cycles, reporting is required if the 

production volume of a chemical substance meets or exceeds the 25,000 

lb threshold (or 2,500 lb threshold, if applicable) for any calendar year 

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 requires electronic reporting, and therefore requires that all 

submitters complete EPA’s CDX registration process. As part of 

registering with CDX, each submitter will provide identifying 

information that will comprise all or most of the information requested in 

Part I of Form U (EPA Form 7740-8). This information will then be prepopulated 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 will be able to access the e-CDRweb 

reporting tool.

Prepare and Submit 

Report - Partial 

Report 

Compile the required information, determine the CBI status of 

information and fulfill appropriate substantiation measures, and use the eCDRweb 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 specifically listed in the regulation for which there is a partial 
14

reporting exemption. 

Prepare and Submit 

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 routinely conducted by EPA related to the processing, analysis 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 importers), 

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. The collection will occur every four years. 

(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 ways: (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. Submitters 

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 eCDRweb. 

Information quality and validation begins with the e-CDRweb reporting tool, which is 

programmed to help the submitter provide the information required, in the correct format as 

required by 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 

Information 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 OEI 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 systems development, guidance document development, Form U processing, 

and additional tasks. The task descriptions presented below generally do not change from 

collection to collection.

CDR data is stored in a database managed by the Agency. Once updated, the CDR 

database is then available to EPA technical reviewers to search or export into their various 

analytical modeling systems 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 Systems 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 developing 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 Agency
16

provides the TSCA Hotline with standardized responses for frequently asked questions; 

preparing mailings, 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 only 

businesses -- governmental jurisdictions and not-for-profit 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 generally not subject to any of the 

reporting or recordkeeping 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 by the 

firm. The Economic Analysis for the Final Inventory Update Reporting Modifications Rule

determined that the impact on these companies is, on average, significantly 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

Early 2014

Public Outreach efforts: articles in industry

press, meetings with regulated community, and 

information on the IUR website

2014-2016

Open period for submitting 2016 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 by all affected entities. This 

ICR covers the years 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 that 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 analysis, 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 rule is 

considered a respondent and will submit one Form U containing one or more chemical-specific 
17

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 of 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 contains 

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 I and Part II are 

considered a “partial report.” Part III contains processing and use information and will be 

completed for all chemical substances unless the chemical substance is specifically 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 analysis, burden and costs 

associated with Part 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, Parts 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 I will be 

completed automatically 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 

Determination

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 25,000 lb 

threshold in any of the calendar years since the last

principal reporting year (i.e. 2012-2015). 

Compliance Determination

Rule 

Familiarization

Site staff must familiarize themselves with the 

requirements of the rule. Staff from sites that 

reported previously must become familiar with new 

Rule Familiarization
18

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 mailed back 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, company

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 originally from a survey conducted by 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 typical 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 collections, the 2016 and 2020 reporting cycles, during the three-year 

period covered by this ICR 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 have 

not previously submitted a Form U and new staff members at sites that have previously reported 

data under CDR. For old submitters (staff who have previously 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 ICR, 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 individually using the 1996 

survey results, economic analyses 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 

Burden 

(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 Information

Certification 0.00 0.85 1.01 1.86

Company Information (U.S. Parent Company 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 Information

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 Imported 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 Chemical 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 Information

 Upfront Substantiation for Processing and Use Information 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 1.33
21

Activity

Clerical 

Burden 

(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 Commercial Workers Reasonably Likely to be 

Exposed 0.00 15.43 3.83 19.26

Total for Part III 0.00 62.26 20.76 83.02

COMPLIANCE DETERMINATION 

Compliance 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, Compliance Determination, Rule 

Familiarization, Recordkeeping and CDX Registration Activities)

0.75 39.01 16.34 56.11

Burden for one Full Report (Parts I, II, III, Compliance Determination, Rule 

Familiarization, 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 Burden 

(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 Information

Certification 0.00 0.85 1.01 1.86

Company Information (U.S. Parent Company 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 Imported 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 Chemical 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 Information

Upfront Substantiation for Processing and Use 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 1.06
23

Activity

Clerical Burden 

(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 Commercial Workers Reasonably Likely to be 

Exposed 0.00 12.34 3.06 15.41

Total for Part III 0.00 49.03 16.60 65.63

COMPLIANCE DETERMINATION 

Compliance 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 burden estimates by standard wage rates for managerial, technical, and 

clerical levels developed from information published by the Bureau of Labor Statistics (BLS) 

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 health 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 (EPA, 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 for the managerial, technical 

and clerical occupation categories. 

Table 5: Derivation of Loaded Wage Rates for the Private Manufacturing Sector in 2012$

Wage1

Fringe 

Benefits1

Fringes as % 

of Wage

Overhead % 

of Wage2

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% 1.66 $72.87

Technical $38.53 $19.31 50.12% 17% 1.67 $64.39

Clerical $17.64 $8.87 50.28% 17% 1.67 $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, 2011).

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 rate 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 rate in Table 5. EPA estimates the total cost for completing and submitting 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 Information

Certification $0.00 $54.73 $73.60 $128.33 

Company 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 

Import 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 

Accession 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 Information

Upfront substantiation for Processing and Use Information 

CBI Claims $0.00 $27.49 $19.12 $46.61 
26

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

Compliance 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, Compliance Determination, 

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 

Determination, 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 Information

Certification $0.00 $54.73 $73.60 $128.33 

Company 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 Information

Upfront substantiation for Processing and Use Information CBI Claims

$0.00 $27.49 $15.29 $42.79 
29

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 

Compliance 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;

 Quality control of data, including protection of CBI;

 Backup systems operation;

 Data processing;

 Systems 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, systems 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, systems development, and contract oversight and 

management, per-reporting cycle. Quality 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 federal wage rates published by the Office of 

Personnel Management for the Washington-Baltimore-Northern Virginia, DC-MD-PA-VA-WV 

locality pay area for 2012 (OPM, 2013). Wages are presented in terms of GS-level and step. 

Based on previous IUR economics analyses, 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: Derivation of Loaded Agency Wage Rates (2010$)

Pay Grade Annual 

Salary

Overhead and Fringe 

Benefits 

(% of wages)

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 2010 is from the Office of Personnel Management salary table 

for Washington-Baltimore-Northern Virginia (OPM, 2013). 

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 

systems 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 systems 

development and contract oversight is one FTE at the GS-13 level, with a cost of $150,051. 

Quality control of data is performed by the GS-12 level staff 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 cost 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: EPA 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 

Review 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-13 Step 3 Fixed Cost Burden

Systems 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 payment 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 Hotline, 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 2008 to 2012 dollars with an inflation factor calculated using the 

Employment 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 $0.32

Total Cost of Document receipt, 

tracking, and data review, per full 

report

$0.65 1.07 $0.70

Fixed Costs

Maintaining and Operating Back Up 

Systems $59,145 1.07 $63,385

Publication of materials and making a 

pdf of all Form U’s. $5,525 1.07 $5,921

Managing the TSCA Hotline $44,694 1.07 $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 

year ICR period. The next CDR submission period will occur in 2016 for chemical substances 

manufactured (including imported) during the calendar years 2012-2015. Even though reporting 

occurs only once every 4 years, EPA expects 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 analysis, 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. This 

ICR supporting statement is for the three-year period of 2015 through 2017; therefore, average 

annual figures for each of these three years are presented below.
Page 34 of 50

Respondent Tally

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 chemicals. 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 1,211 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 year, and not just if the threshold is exceeded in 

the reporting year. EPA anticipates a 5 percent increase in the number of reporting sites and 

reports submitted as a result of this modification (EPA, 2011). Finally, 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), 6all 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 partially 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 under 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 of 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 assumes 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 year 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 1,879 full reports from new submitters and 34,473 full 

reports from old submitters.8

 

8 To calculate 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 annually. The average burden per old respondent is estimated 

to be 623 hours per cycle, or 156 hours annually. This is higher than the burden estimated for the 

currently 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 Burden/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, 2016, and 2017 to be 51,903 hours. As presented in Table 13, EPA estimates the total cost 

to industry of a four-year 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 

Determination 

(per Site)

2.50 258 Sites $161 645 $41,532 161 $10,383 

Rule 

Familiarization 

(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 

Determination 

(per Site)

2.50 4,733 Sites $161 11,833 $761,896 2,958 $190,474 

Rule 

Familiarization 

(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 $48,618,589

Note: Totals may not sum due to rounding 

Annual Industry Burden and Cost for All Submitters. As shown in Table 15, EPA 

calculated the estimated total annual respondent burden and cost associated with this ICR by

summing the burdens and costs for new and old submitters. The total annual burden associated 

with this ICR renewal is 789,203 hours. The total annual cost is $52 million.
Page 38 of 50

Table 15: 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 

Determination 

(per Site)

161 10,383 2,958 190,474 3,119 $200,857

Rule 

Familiarization 

(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 

typical respondent burden for this information collection activity to be 803 hours for new 

submitters and 623 hours for old submitters. Given that a collection will occur once every four 

years, the average annual burden is 201 hours for new submitters and 156 hours for old 

submitters. These burden estimates 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 per 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 

Familiarization,

Compliance 

Determination, 

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 

Familiarization,

Compliance

Determination, 

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 

cycle. 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 

Activity

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 Determination, 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 Determination, 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. 

Table 18: Annual Information Collection Tally for New and Old Submitters
Page 41 of 50

Information 

Collection

No. of 

Respondents

No. of 

Responses / 

Respondent

Responses 

Subtotal

Annual Burden 

Hours per 

Response

Annual Burden 

Hours Subtotal

New Submitters

Compliance 

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

Compliance 

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

Information 

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

Compliance 

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)

Information Collection No. of 

Respondents

No. of 

Responses / 

Respondent

Responses 

Subtotal

Total Burden 

Hours per 

ICR Period

Annual 

Burden 

Hours 

Subtotal

New Submitters

Compliance 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

Compliance 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

Information Collection No. of 

Respondents

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

Compliance 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 presents the Agency costs associated with the CDR rule. EPA multiplied the 

costs per report by 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 cycle 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 by 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 by the Agency is $198,203. The total 

agency cost and burden was calculated by 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 

Employee

(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 Burdens and Costs

Data 

Processing, 

Systems 

Development, 

and Contract 

Oversight and 

Management

EPA 

Employee

(GS-13 

Step 3)

N/A N/A N/A N/A 1.000 $150,051

Maintaining 

and Operating 

Back Up 

Systems

Contractor N/A N/A N/A N/A N/A N/A

Printing and 

Publishing 

Forms 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 315,080 hours in annual burden 

compared to the estimate in the information collection request most recently approved by OMB 

(from 474,123 hours to 789,203 hours). Differences in burden and costs from the previous ICR 

are attributed to both program and adjustments changes. Adjustments capture changes in the 

baseline burden not included in the currently approved ICR. These changes result from updates 
Page 46 of 50

to the number of affected sites and wages and the correction of estimates in the previous ICR. 

Program changes account for changes in reporting requirements between the 2012 and 2016 

reporting cycles. 

Adjustment Changes

The previous currently approved used data from the 2006 IUR to estimate the number of 

sites and partial and full reports submitted to EPA. EPA ICR 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 analysis and all submitters would incur the smaller “old” submitter burden in the last year 

of the analysis. For this ICR EPA assumed that approximately 95% of submitters would incur the 

lower “old” submitter burden for all three years. In addition, annual burden for the previous ICR 

partially covered portions of two reporting cycles, including two years of 2012 cycle reporting 

and one year of 2016 cycle reporting. The burden for the previous ICR 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 estimates be averaged over a four 

year period only.

All costs were inflated from 2008$ to 2012$, 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 year 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 accounting 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 year. This will slightly increase 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 response, 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 collection 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 ICR under Docket ID No. EPA-HQOPPT-2013-0721, which is available for online viewing at www.regulations.gov, or in-person 

viewing 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 holidays. 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 by 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 by 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 

20503.
Page 49 of 50

7. Sources

BLS 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.

BLS, 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/querytool.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-2002-0054-0260). August 2002.

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

Analysis Branch. Wage Rates for Economic Analysis of the Toxics Release Inventory Program.

June 10, 2002.

EPA, 2005. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis 

Branch. Economic Analysis of IUR Modifications Final Rule (EPA-HQ OPPT 2004-0106-

0055). July 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, 2007. 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 September 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 (75 FR 773-

790), January 6, 2010) 
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EPA, 2011. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis 

Branch. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications 

Rule. June, 2011.

EPA, 2012. ICR No. 1884.06. [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. EPA-HQOPPT-2009-0187.

EPA, 2013. Toxics Release Inventory. 2012 National Analysis dataset. Accessed from 

http://iaspub.epa.gov/triexplorer/tri_release.chemical

OPM, 2013. Office of Personnel Management, Salary Table 2010-DCB, Washington BaltimoreNorthern Virginia, DC-MD-PA-VA-WV. Accessed from http://www.opm.gov/policy-dataoversight/pay-leave/salaries-wages/2013/general-schedule/dcb.pdf.