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# Page 1 of 118 EO12866_RIN2070-AJ92_Formaldehyde-Imp_NPRM_ICR_2013-04-11_MARKUP.docx 

# 1

2

Supporting Statement for OMB Review under 3

the Paperwork Reduction Act 4

5

1. IDENTIFICATION OF THE INFORMATION COLLECTION 6

7

l(a) Title of the Information Collection 8

9

TITLE: ICR for Proposed Rule Implem enting the Formaldehyde Emissions 10

Standards for Composite Wood Products Act [RIN 2070-AJ92] 11

12

EPA ICR No.: 2446.01 13

14

OMB Control No.: 2070-NEW 15

16

1(b) Short Characterization 17

18

The Formaldehyde Standards for Composite Wood Products Act, which established Title 19

VI of the Toxic Substances Control Act (TSCA), set forth formaldehyde emission standards for 20

hardwood plywood, particleboard and medium-densi ty fiberboard and directs EPA to promulgate 21

implementing regulations by January 2013. TSCA Title VI also directs EPA to promulgate 22

supplementary provisions to ensure compliance with the emissions standards, including testing 23

requirements, laminated product provisions, provisions for products made with no-added 24

formaldehyde (NAF) resins or ultra-low emitti ng formaldehyde (ULEF) resins, product labeling 25

requirements, chain of custody provisions for product compliance documentation, recordkeeping, 26

product inventory sell-through dates, a product st ockpiling prohibition, and product certification 27

by an accredited third party (third party certifier, or TPC). This ICR covers the recordkeeping 28

and reporting requirements for all aspects of the TSCA Title VI implementing regulations, 29

except those relating to accreditation bodies and th ird-party certifiers that wish to participate in 30

this third-party certification program. A separa te information collecti on request covers those 31

recordkeeping and reporting requirements. 32

33

Some examples of proposed reporting and third-party reporting requirements covered by 34

this information collection request include: 35

36

 Notifying EPA in the event of a failed quarterly test 37

 Reporting of the results of quality cont rol tests to third-party certifiers 38

 Notifying a third-party certifier of a change in quality control manager 39

40

Examples of proposed recordkeeping requirements include: 41

42

 Records on quarterly test results and quality assurance test results 43

 Records of quality control manuals 44

 Records on quality control managers a nd employees and their qualifications 45

 Records on the disposition of non-compliant lots 46

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# Page 2 of 118 

#  Chain of custody recordkeeping requirements for importers, fabricators, and laminated 47

products producers 48

 Labeling requirements for manufacturers (includi ng importers), fabricators, distributors, 49

and wholesalers and retailers

. 50

 Minimized requirements for non-importing distributors and retailers 51

52

The information collected under this ICR would be used by EPA’s Regional 53

Administrators, the Office of Enforcement an d Compliance Assurance (OECA), and/or the 54

Office of Chemical Safety and Pollution Prevention (OCSPP), as appropriate. Some of the 55

information would also be made available to the public via the internet. This would include the 56

names and address of companies that have products that qualified for reduced testing based on 57

the use of no-added formaldehyde-based resins. Downstream purchasers may use this 58

information in order to determine that the me rchandise is compliant and to avoid purchasing 59

products that are not legally saleable in the Unit ed States. Confidential business information 60

(CBI) submitted to EPA will be maintained by th e Agency pursuant to TSCA § 14 and 40 CFR 61

Part 2. 62

63

2. NEED FOR AND USE OF THE COLLECTION 64

65

2(a) Need/Authority for the Collection 66

67

The reporting and recordkeeping requirements of this ICR are implemented under the 68

authority of TSCA Title VI. TSCA Title VI di rects EPA to promulgate regulations to ensure 69

compliance with the emissions standards, in cluding provisions on testing requirements, 70

laminated products, products made with no-added formaldehyde resins or ultra-low emitting 71

formaldehyde resins, product labeling requirements, chain of custody for product compliance 72

documentation, recordkeeping, product inventory sell-through dates, a product stockpiling 73

prohibition, and product certification by a TPC. To meet its statutory obligations, EPA must 74

obtain sufficient information to ensure complianc e with the emissions standards; moreover, a 75

reasonable amount of reporting encourages regulated entities to fulfill thei r obligations under the 76

statute and regulations. 77

78

2(b) Use of the Data 79

80

EPA would use the information collected to evaluate manufacturer and importer 81

compliance with the emissions standards. The info rmation that is collected and required to be 82

reported to third-party certifiers is necessary to ensure th at producers of composite wood panels 83

maintain proper quality assurance and control measures. Third-party certifiers require access to 84

this information so that they can certify that products are produce in accordance with TSCA Title 85

VI requirements. TSCA Title VI also direct s EPA to include labe ling provisions. The 86

information contained in the labels accompanying composite wood panels and finished goods 87

containing such panels will allow downstream purchasers of these products to determine whether 88

the merchandise is compliant; non-compliant merchandise may not be legally sold supplied or 89

offered for sale in the United States. 90

91

92

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# Page 3 of 118 

# 93

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 94

95

3(a) Non-Duplication 96

97

TSCA Title VI assigns to the EPA Admini strator the responsibility for promulgating 98

regulations that ensure compliance with the statutory emissions standards for formaldehyde from 99

composite wood products. The information collecti on requirements addressed in this ICR are not 100

duplicative of any other Federal requirement. There are no federal regulations on formaldehyde 101

emissions from pressed wood products other than those of the Department of Housing and Urban 102

Development (HUD) that are applicable to particleboard and plywood used in manufactured 103

housing. In contrast with the HUD emission s standards which are only applicable to 104

particleboard and plywood used in manufactured housing, the emissions standards in TSCA Title 105

VI apply to hardwood plywood, medium-density fiberboard, and particleboard sold, supplied, 106

offered for sale, or manufactured (defined by st atute to include import) in the United States. 107

108

Because the proposed regulatory requirements are necessarily tailored to the unique 109

TSCA Title VI requirements, these records and reports are the sole source of information for 110

EPA to rely on to ensure complian ce with the emissions standards. 111

112

3(b) Public Notice Required Prior to ICR Submission to OMB 113

114

The proposed rulemaking serves as the public notice for this ICR. Interested parties 115

should submit comments referencing Docket ID No. EPA-HQ-OPPT-2011-0380 to the address 116

listed at the end of this document. Responses will be taken into account in developing the final 117

rulemaking. 118

119

3(c) Consultations 120

121

On numerous occasions during the course of developing the proposed regulation, the 122

Agency has consulted with the regulated community and the public. These consultations have 123

been held directly with industry officials and, on an ongoing basis, with owners and operators of 124

regulated facilities. EPA has al so consulted with the California Air Resources Board (CARB), 125

which operates a similar third-party certification program for formaldehyde standards for 126

composite wood products that are sold, supplied or offered for sale in the State of California. 127

128

Since EPA began its regulatory investigation into formaldehyde emissions from pressed 129

wood products with an Advanced Notice of Proposed Rulemaking (ANPR) published in 2008, 130

EPA has met on numerous occasions with the composite wood panel and related industries. 131

These meetings have been in the form of presen tations at trade shows and industry association 132

conferences, and meetings with the Composite Panel Association (CPA), the Hardwood Plywood 133

and Veneer Association (HPVA), the Kitchen Ca binet Manufacturing Association (KCMA), the 134

American Home Furnishings Alliance (AHFA) , the Business and Institutional Furniture 135

Manufacturer’s Association (BIFMA), and individual companies. EPA staff have, at the 136

invitation of potentially regulated manufacturers, conducted factory tours and site visits. 137

138

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# Page 4 of 118 

# EPA convened a Small Business Advocacy Review Panel and hosted two panel outreach 139

meetings with small entity representatives (SER). Prior to each meeting, EPA distributed 140

outreach materials to the SERs, and after each meeting the SERs were asked to provide written 141

feedback on how EPA might redu ce regulatory burden on small entities. The Panel received 142

written comments from the SERs in response to the discussions at the meetings and the outreach 143

materials. The Panel summarized written and oral comments from the SERs and developed Panel 144

recommendations in its Panel Report. ( See Panel Report of the Small Business Advocacy Review 145

Panel on EPA’s Planned Proposed Rule Implementing the Formaldehyde Standards for 146

Composite Wood Products Act (TSCA Title VI), April 4, 2011). 147

148

EPA intends to carry out further consultations and outreach with potentially regulated 149

entities concurrent with the public comment peri od. These comments will be used to update the 150

Supporting Statement as needed. 151

152

3(d) Effects of Less Frequent Collection 153

154

EPA has judged that the reporting and recordkeeping requirements of the ICR are the 155

minimum amount necessary to fulf ill its statutory mandate to prom ulgate regulations that ensure 156

compliance with the emissions standards. The reports and records in this ICR would allow EPA 157

carry out its statutorily-delegated roles in pr ogram design, enforcement, and oversight. EPA 158

believes that less frequent reporting and failure to require notice of significant events could result 159

in uncertified and noncompliant products being di stributed in commerce in violation of the 160

statute. For example, panel producers must pr ovide their third-party certifier with monthly 161

product data reports for each production facility, production line, and product type. These reports 162

will include production information and quality cont rol test results, and will allow the third-party 163

certifier to monitor quality control testing and en sure that production at the facility remains in 164

compliance with the statutory emission standards. 165

166

3(e) General Guidelines 167

168

In general, this information collection complies with the guidelines at 5 CFR 169

1320.5(d)(2). The exceptions to OMB’s Paperwork Reduction Act Guidelines, and the 170

explanation of why such characteristics are need ed to fulfill the statutory requirements, are 171

described below: 172

173

Record retention for 5 3 years is especially critical because these regulated products 174

(composite wood panels, component parts, and finished goods) may be in commerce for 5 3 years 175

or even longer. Composite wood products ar e regulated beginning with the manufacture 176

(including import) of panels through their incorporation into component parts and finished 177

goods, the distribution of those products, and the retail sale of those products. This is a lengthy 178

process and the amount of time composite wood panels are held in inventory and the amount of 179

time before they are incorporated into a finished good are variable. This point was illustrated by 180

the fact that the State of California had to twi ce extend its “sell-through date” when it enacted an 181

Airborne Toxic Control Measure (ATCM) estab lishing formaldehyde emissions standards for 182

composite wood products. The California Air Resources Board found that these extensions were 183

necessary because the recession increased the amount of time manufacturers needed to clear 184

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# Page 5 of 118 

# preexisting inventory. ( See, e.g., Composite Wood Products Regulation Advisory: 11-01, 185

Extension of Sell-Through Dates for: Distributor s, Importers, Fabricators, and Retailers of 186

Finished Goods Containing Phase 1 Hardwood Plyw ood- Veneer Core and Distributors of Phase 187

1 Particleboard and Medium Density Fiberboard Panels, available at 188

http://www.arb.ca.gov/toxics/compwood/outreach/11_01_advisory.pdf ). It is essential that 189

proper chain-of-custody documentation be retained for this entire period of time so that both 190

EPA and interested downstream consumers can be assured that a finished good containing 191

regulated composite wood product was made from compliant composite wood panels. 192

193

A number of provisions require reporting only upon the occurrence of a specific event. 194

For example, a panel producer must notify its third-party certifier immediately if it makes 195

production changes that are likely to have an impact on formaldehyde emissions from its 196

products. These reporting requirements are not triggered by the calendar ( i.e. , they are not 197

required quarterly or at more frequent intervals). Therefore, the Agency does not believe that 198

these provisions need special justification. Moreover, EPA believes that unless these 199

notifications are provided within the intervals prescribed in the proposed rule, a change in 200

circumstances could result in non-compliant products being distributed in commerce. Not only is 201

this a violation of the statute, but it greatly incr eases the cost associated of segregating, treating 202

and retesting these products. 203

204

3(f) Confidentiality 205

206

Regulated entities may claim all or part of an y information given to EPA as confidential 207

business information (CBI). EPA handles claims of confidentiality pursuant to established CBI 208

procedures, as found at Section 14 of TSCA , 40 CFR Part 2, and the Agency’s TSCA CBI 209

Manual. CBI is also protected under the Free dom of Information Act (5 USC Section 525). 210

Much of the information requested in the reporting requirements of these collections is not of a 211

confidential nature. 212

213

3(g) Sensitive Questions 214

215

EPA asks no questions of a sensitive nature. 216

217

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 218

219

4(a) Respondents/NAICS Codes 220

221

The primary respondents would be manufactures, distributors, importers, retailers of 222

regulated composite wood products and finished goods containing regulated composite wood 223

products. 224

225

The following NAICS codes may be affected: 226

227

 Hardwood Veneer and Plywood Manufacturing (NAICS code 321211); 228

 Reconstituted Wood Product Manufact uring (NAICS code 321219); 229

 All Other Miscellaneous Wood Product Manufacturing (NAICS code 321999); 230

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#  Furniture and Related Product Manufacturing (NAICS code 337); 231

 Miscellaneous Manufacturing (NAICS code 339); 232

 Merchant Wholesalers, Durable Goods (NAICS code 423); 233

 Merchant Wholesalers, Nondurable Goods (NAICS code 424); and 234

 Retail Trade (NAICS Sector 44 and 45). 235

236

4(b) Information Requested 237

238

(i) Data Items 239

240

The proposed recordkeeping requirements and reporting requirements include: 241

242

(A) Notifications/Reports . Respondents are required to submit information to EPA to 243

accomplish the following reporting tasks: 244

245

 Imports of regulated composite wood products and finished goods containing regulated 246

composite wood products must be accompanied by a TSCA § 13 import certification. 247

248

 Panel producers who wish to qualify for reduced testing and third-party certifier oversight 249

under the no-added formaldehyde-based resi n provisions must apply to a third-party 250

certifier and send a copy of the application to EPA. 251

252

 Third-party certifiers must notify EPA and the panel producer of a failed quarterly test I 253

in writing within 24 hours. 254

255

(B) Third-Party Notifications/Reports . Respondents are required to submit 256

information to entities ot her than EPA as follows: 257

258

 Composite wood product panel producers must apply for product certification from a 259

third-party certifier. The application must include the panel producer’s name, address, 260

telephone number, and other contact information, including name and contact 261

information for the panel producer’s quality control manager, and an identification of the 262

specific products for which certification is requested, the chemical formulation of the 263

resins, including base resins, catalysts, and other additives used in panel production, and 264

testing results. A copy of the panel producer’s quality control manual must also be 265

provided to the third-party certifier with the application. Manuals must include 266

information on the organizational structure of the quality control department, a 267

description of the sampling procedures and frequency of testing, a description of 268

procedures used to identify significant production changes, a description of the resin and 269

press time for each product type, and a description of recordkeeping procedures. Changes 270

in manuals must be submitted to and approved by an accredited third-party certifier. 271

272

 Composite wood product panel producers must provide information on the qualifications 273

of their quality control manager and quality control employees to the third-party certifier. 274

275

 Composite wood product panel producers must provide their third-party certifier with a 276

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# Page 7 of 118 

# monthly product data reports that include production information and quality control test 277

results for each production facility, production line, and product type. 278

279

 Composite wood product panel producers must notify their third-party certifiers if they 280

change quality control managers. This notifi cation must occur within 10 days of the 281

change. 282

283

 Composite wood product panel producers wishing to take advantage of reduced testing 284

and third-party certification requirements for products made with no-added formaldehyde 285

resins must apply to an accredited third-party certifier. The application must include the 286

panel producer’s name and contact information as well as an identification of the specific 287

product and the chemical formulation of the resins, including base resins, catalysts, and 288

other additives as used in manufacturing. Testing results must also be part of the 289

application. If the application is granted, every two years thereafter, the panel producer 290

must have one test performed by an accredited third-party certifier that demonstrates 291

continued compliance with the reduced formaldehyde emission standards for each 292

product type. 293

294

 Panels or bundles of regulated composite wood products must be labeled with the 295

producer’s name (or number), lot or batch number, the number of the accredited third296

party certifier, and markings indicating that the product complies with the TSCA Title VI 297

emission standards. Products that qualify for reduced testing and third-party certification 298

requirements based on the use of ultra-low formaldehyde or no-added formaldehyde 299

resins must also be marked with indications that they were produced using ultra-low 300

formaldehyde or no-added formaldehyde resins. Boards that are shipped into the United 301

States for testing purposes must also be labeled as such. 302

303

 Fabricators of finished goods containing composite wood products are required to label 304

every finished good they produce, or every box containing finished goods. The label 305

could be applied as a stamp, tag, sticker, or bar code and must include the fabricator’s 306

name, the date the finished good was produced and a marking to denote that the product 307

was made in compliance with TSCA Title VI. 308

309

(C) Records . Respondents are required to maintain records as follows: 310

311

 Panel producers must maintain th e following records for at least five three years and make 312

them available upon request to EPA, their third-party certifiers, and to purchasers of their 313

composite wood products: 314

o Records of all quarterly emission testing and all ongoing quality control testing 315

that identify the TPC condu cting or overseeing the tes ting and the laboratory or 316

quality control facility actually performing the testing. These records must also 317

include the date, the product type tested, the lot or batch number that the tested 318

material represents, the test method used, and the test results. 319

o Production records, including a description of the composite wood product(s), the 320

date of manufacture, lot or batch numbers, and tracking information allowing 321

each product to be traced to a specific lot number or batch produced. 322

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# o Records of changes in production, including changes of more than 10% in the 323

resin use percentage, changes in resin composition that result in a higher ratio of 324

formaldehyde to other resin components, and changes in the process, such as 325

changes in press time by more than 20 percent. 326

o Records demonstrating initial and contin ued eligibility for the reduced testing 327

provisions in 40 CFR § 770.17, if applicable. 328

o Purchaser information for each composite wood product, if applicable, including 329

the name, contact person, address, phone number, e-mail address if available, 330

purchase order or invoice number, and amount purchased. 331

o Transporter information for each composite wood product, if applicable, 332

including name, contact person, address, phone number, e-mail address if 333

available, and shipping invoice number. 334

o Information on the disposition of non-complying lots, including product type and 335

amount of composite wood products affected, lot or batch numbers, mitigation 336

measures used, results of retesting, and final disposition. 337

o Copies of labels used. 338

339

 Panel producers are required to maintain an up-to-date quality control manual on their 340

premises. 341

342

 Panel producers are required to maintain the credentials of their quality control managers 343

and quality control employees for as long as employees are serving in a quality control 344

capacity. 345

346

 Producers of exempt laminated products are required to maintain records demonstrating 347

that they are using compliant platforms and NAF resins. These records would include 348

records of purchases of NAF resins and of compliant, certified platforms, or, if the resins 349

or platforms are made in-house, records demonstrating that the platforms have been 350

certified by an accredited TPC and records demonstrating the production of NAF resins. 351

352

 Importers, fabricators of finished goods that incorporate composite wood products, 353

laminated product producers whose products are exempt from the definition of hardwood 354

plywood must maintain records identifying the panel producer, the date the composite 355

wood products were produced, the date the composite wood products were purchased, 356

and bills of lading or invoices that include a written affirmation from the supplier that the 357

composite wood products are compliant. 358

359

 Non-importing distributors and retailers must retain invoices and bills of lading and 360

copies of labels used. 361

362

(ii) Respondent Activities 363

364

All respondents would need to read the rule and determine which provisions would be 365

applicable to their operations; plan and modify their procedures to come into compliance with 366

the rule; provide training to appropriate staff; process, compile, and review information for 367

accuracy and appropriateness; and record, disclose, and/or report the required information. 368

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# 5. THE INFORMATION COLLECTION — AGENCY ACTIVITIES, COLLECTION 369

METHODOLOGY, AND INFORMATION MANAGEMENT 370

371

5(a) Agency Activities 372

373

EPA resources would be devoted to reviewing and analyzing import certifications, 374

auditing and inspecting facilities, producing audit and inspection reports, responding to public 375

inquiries, providing regulatory interpretations and developing rulemakings. 376

377

5(b) Collection Methodology and Management 378

379

At this time, the majority of the informat ion requirements would not require the use of a 380

specific form or format, except that failed test results must be reported in writing. By and large 381

the reporting requirements of this rule are thir d-party reporting requirements, in that panel 382

producers are required to submit information to TPCs. EPA wishes to give maximum latitude to 383

TPCs and panel producers as they choose how to most expediently structure their 384

communications. 385

386

5(c) Small Entity Flexibility 387

388

Small businesses are not exempt from the requirements of TSCA Title VI. The 389

information collections would apply to all enti ties that manufacture (including import), sell, 390

supply, or offer for sale regulated composite wood products in the United States regardless of 391

size. They would also apply to entities that manufacture regulated composite products, including 392

finished goods, for import into the U.S. and to third-party certifiers that wish to participate in the 393

program. During the Small Business Advocacy Review Panel process, the Panel recommended 394

regulatory flexibility alternativ es to alleviate burden on small business. EPA seeks to implement 395

those recommendations in its proposal. For example, EPA’s proposal would allow labeling by 396

bundle, as opposed to individual boards. EP A is also requiring quality control tests for 397

hardwood plywood based on production volume, allowing low volume producers to conduct 398

fewer tests. 399

400

5(d) Collection Schedule 401

402

Panel producers must provide their third-party certifiers with monthly product data 403

reports. The rest of the reporting activities are triggered by specific events or on an as needed 404

basis rather than by specific dates. 405

406

6. ESTIMATING BURDEN AND COST OF THE COLLECTION 407

408

This section estimates the burden and associated costs for both the respondents and the 409

Agency associated with the recordkeeping and reporting requirements of the proposed TSCA 410

Title VI Implementation Rule. This supporti ng statement provides aver age annual burden and 411

cost estimates for the next three years of the program. All costs are presented in year 2010 412

dollars. 413

414

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# This ICR presents the burden and associated costs for the activity types listed below. 415

Note that not all entities will incur burden or co sts from these activities because they may already 416

be meeting the requirements under the CARB ATCM and/or their existing recordkeeping and 417

labeling systems may already be sufficient. 418

419

 Rule Familiarization: All respondents will need to read the rule in order to understand 420

the requirements; 421

 Testing and Certification: All composite panel producers will need to perform 422

formaldehyde emission testing on their composite wood products and attain certification 423

from an accredited third-party certifier (T PC). These entities must undergo qualifying 424

tests at a TPC lab, obtain an on-site audit from a TPC, implement quality control systems, 425

and train quality control empl oyees in order to receive initial certification. Once 426

certified, a mill is required to conduct on-g oing small scale quality co ntrol testing, submit 427

monthly reports to the certifying TPC, and receive quarterly on-site audits and large 428

chamber testing to maintain its certified stat us. Mills that produce products made with 429

ULEF or NAF resins that meet more stringent emissions limits may apply for exemptions 430

from some of the on-going testing requirements; 431

 Recordkeeping : Firms that import, produce, or manufacture composite wood panels, 432

component parts, or finished goods are required to keep records showing the date of 433

purchase of the composite wood product, the supplier, and all precautions taken to ensure 434

that the product meets emissions standards. Wholesalers and retailers that do not import, 435

produce, or manufacture composite wood panels, component parts, or finished goods are 436

only required to maintain invoices and bills of lading; and 437

 Labeling: Firms Panel producers, fabricators, and wholesalers that package or repackage 438

composite wood products or finished goods containing composite wood products will 439

need to modify their labels to include their name, the date the finished good was 440

produced, and a statement of compliance. 441

442

Exhibit 6-1 summarizes the recordkeeping and reporting activities for respondents as a 443

result of the proposed rule: 444

445

446

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# Page 11 of 118 Exhibit 6-1: Summary of Recordkeeping and Reporting Activities, by Sector and Activity

Activity Com p osite Panel Producer 1



# Fabricator Wholesaler

Retailer Standard ULEF NAF Imports No

Imports

1. Rule Familiarization 1-time 1-time 1-time 1-time

2. Certification Fee Annual

- - - -

3. Initial On-site Audit 1-time

- - - - 4. Develop Quality Control

Manual 1-time

- - - -

5. Qualifying Test 1-time

- - - - 6. Qualifying Test Shipment 1-time

- - - -

7. Correlation Test 1-time

- - - - 8. Recurring On-site

Audit 1 

# Audit 2 

# Quarterly Annual

- - - -

9. Large Scale Testing Fee 2 

# Fee 3 

# Quarterly Annual

- - - - 10. Large Scale Testing

Shipment 2 

# Shipment 3 

# Quarterly Annual

- - - -

11. On-site Audit Travel 3 

# Travel 4 

# Annual

- - - -

12. Desk Audits 4 

# Audits 5 

# 8 per year

- - - - - -

13. Purchase of Small Chamber

Testing Unit 5 

# Unit 6 

# 1-time

- - - - - -

14. Quality Control

Testing 6 

# Testing 7 

# Up to Daily

- - - -

15. Lost Product 7 

# Product 8 

# Up to Daily

- - - - 16. Initial Recordkeeping

- - - 1-time

- - 17. Recurring Recordkeeping Annual Annual Annual

- - 18. Initial Labeling 1-time 1-time 1-time

-

Notes:

1. This analysis assumes that panel producers with standard (Phase 2), ULEF, or NAF certifications under the CARB ATCM will retai n those

certifications under the TSCA Title VI rule, but that product lines being newly certified as a result of the TSCA Title VI rule will receive either

standard or NAF certifications. Furthermore, some TPCs may have more stringent requirements than the regulations require. Fo r example,

HPVA requires mills to have on-site audits and large chamber tests annually for NAF-certified products, and quarterly for ULEF- certified

products, which is more frequently than the CARB ATCM requires. This analysis therefore assumes that TPCs test and audit mills with NAF or

ULEF-certified product lines more frequently than the CARB ATCM or the proposed TSCA Title VI rule require.

2. This analysis assumes that producers with new NAF certifications will incur the burden associated with one on-site audit (in a ddition to the

initial audit) in the first year. The initial on-site audit is assumed to be sufficient for producers with existing ULEF or NAF certifications. All

ULEF or NAF-certified producers will have one on-site audit annually thereafter.

2 3 . Mills are required assumed to perform large scale testing quarterly unless all products are certified as NAF. It is assumed that mills with only

NAF-certified products will perform large scale testing annually. In the first year, mills with added-formaldehyde products wi ll test those

products three times in addition to the qualifying testing, and mills with NAF products will test those once at the end of the qualifying process.

3 4 . It is assumed that travel is only necessary for the annual audits, as other intermediate audits can be performed by contracti ng inspectors closer

to the mill.

4 5 . Desk audits for standard certification are assumed to occur monthly except in months without with quarterly on-site audits. The analysis

assumes that producers with new NAF certification will incur the burden associated with two desk audits in the first year. ULEF or NAFcertified producers will not have any desk audits in subsequent years.

5 6 . This analysis assumes that mills with standard certification or a new NAF certification will choose to set up and operate a small scale testing

facility on-site; although, all particleboard and MDF mills with standard certification are assumed to already have a small sca le testing facility onsite. Mills with an existing ULEF or NAF certification only require weekly will already have been exempted from quality control testing for the

first three months of certificati on; as a result, it is assumed that these mills will outsource their testing.

6

.

7 . Particleboard and MDF mills are required to test samples at least once per eight or twelve hour shift, but the frequency is r educed to one test

per 48 hours if the plant or production line has shown consistent operations with low variability of test results. The testing frequency for

hardwood plywood producers depends on their production volume, ranging from as little as one test per hundred thousand square f eet of

production to as much as four tests per week. This analysis makes the simplifying assumption that all panel producers with standard certification

will test once per day, which results in a conservative estimate of the burden and cost of quality control testing for hardwood plywood producers.

7 8 . Mills will need to forfeit a number of panels for initial and on-going testing. Mills are expected to ship five 4’ x 8’ pane ls per product type

for qualifying testing. All producers of products with a standard certification are assumed to lose one panel per product type each day for quality

control testing, which is a conservative estimate for hardwood plywood producers. In addition, mills are required to send one panel per product

type to the TPC for large scale testing each quarter. However, product lines that are certified as NAF are exempt from routine quality control

testing after the three month qualifying period, and need only have large scale testing performed annually. Product lines that are certified as 

# Formatted Table

Inserted Cells

Formatted Table

Inserted Cells

Inserted Cells

Formatted Table

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# Page 12 of 118 ULEF are exempt from routine quality control testing after the six month qualifying period, and are assumed to have large scale testing

performed quarterly.



# 447

448

Note that the TSCA Title VI rule requires importers of articles that are composite wood 449

products, or articles that contain composite wood products, to comply with the TSCA Section 13 450

import certification regulations for “Chemical Substances in Bulk and As Part of Mixtures and 451

Articles,” as found at 19 CFR 12.118 through 12.127. Thus, any U.S. importer of composite 452

wood products or articles that contain composite wood products would have to certify that all 453

articles in the shipment either comply with all ap plicable rules and orders under TSCA or that all 454

the articles in the shipment are not subject to TS CA. The statement must be on or attached to a 455

commercial invoice or entry document belonging to the imported shipment. In practice, import 456

certification is fulfilled by checking a box on an i nvoice or entry document. It is assumed that 457

this does not generally impose a significant a dditional burden or cost on the importer. Any 458

potential burden associated with a submitter’s familiarization with this requirement is assumed to 459

be included in the more general rule familiarization burden discussed below. 460

461

Exhibit 6-2 

# summarizes the activities that have re porting and recordk eeping burden hours 462

(and thus labor costs) associated with them, and those that have non-labor costs (such as 463

purchasing equipment, shipping composite wood samples for testing, TPC fees, etc.). Burden 464

hour estimates are discussed in section 6(a), while labor and non-labor costs are discussed in 465

section 6(b). Exhibit 6-2 

# also summarizes the baseline calculations for this ICR analysis. Many 466

panel producers are already engaged in these ac tivities because their products are certified under 467

the CARB ATCM. This analysis estimates the burden and cost of the TSCA Title VI rule’s 468

requirements both with and withou t accounting for this baseline. 469

470

This analysis assumes that mills making product lines that have a standard certification 1 

# 471

or a ULEF or NAF certification under the CARB ATCM will not need to submit new data or 472

resubmit existing data to their existing TPC in order to receive the equivalent certification under 473

the TSCA Title VI regulations. Thus, this ICR does not include burdens and costs for these 474

reporting and recordkeeping activities where it is assumed the activities were already performed 475

to comply with the CARB ATCM and will not need to be performed again. This is consistent 476

with the methodology used in the Economic Analysis for the proposed rule. 477

1 

# The term standard certification is used here to describe a ce rtification other than an ultra-low-emitting formaldehyde (ULEF) or

NAF certification.

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# Page 13 of 118 

# 478

However, this ICR does include the burdens and costs of required activities that will 479

continue to be performed under the TSCA Title VI rule, even if those activities would be 480

performed regardless of the TSCA rule (i.e., to comply with the CARB ATCM). This is 481

different from the methodology in the Economic Analysis for the proposed rule, where the 482

baseline included activities performed to comp ly with the CARB ATCM. As a result, the 483

Economic Analysis excluded the costs of activities that would be performed even without the 484

TSCA rule. 485

486

Exhibit 6-2: Summary o f Recordkeeping and Reporting Activities, by Activity

Activity Labor

Costs

(see

Section

6(a)) NonLabor

Costs

(see

Section

6(b)) Burden/Cost Included for

Incremental Estimate, by firm

type Burden/Cost Included for

Total Estimate, by firm

type

Baseline CARBCompliant Not Baseline

CARBCompliant Baseline

CARBCompliant Not Baseline

CARBCompliant

1. Rule Familiarization Yes Yes Yes Yes Yes

2. Certification Fee Yes Incremental Only Yes Yes Yes

3. Initial On-site Audit Yes Yes Incremental Only Yes Yes Yes

4. Develop Quality Control

Manual Yes Yes Yes

5. Qualifying Test Yes Yes Yes

6. Qualifying Test Shipment Yes Yes Yes Yes

7. Correlation Test Yes Yes Yes Yes

8. Recurring On-site Audit Yes Yes Incremental Only Yes Yes Yes

9. Large Scale Testing Fee Yes Incremental Only Yes Yes Yes

10. Large Scale Testing

Shipment Yes Yes Incremental Only Yes Yes Yes

11. On-site Audit Travel Yes Incremental Only Yes Yes Yes

12. Desk Audits Yes Yes Incremental Only Yes Yes Yes

13. Purchase of Small Chamber

Testing Unit Yes Yes Yes

14. Quality Control Testing Yes Incremental Only Yes Yes Yes

15. Lost Product Yes Incremental Only Yes Yes Yes

16. Initial Recordkeeping Yes Yes Yes Yes

17. Recurring Recordkeeping Yes Yes Yes Yes

18. Initial Labeling Yes Yes Yes Yes Yes Yes

This ICR uses two sets of baseline calculations because it calculates both the incremental and the total burden and cost of th e

TSCA Title VI rule. The incremental burden and cost excludes fu ture activities that will be performed to comply with the CARB

ATCM in the baseline. The total burden and cost includes future activities that will be performed to comply with the CARB

ATCM in the baseline. Neither includes activities that CARB compliant firms already performed in the past to meet the ATCM

requirements and that are assumed not to be repeated in order to comply with the TSCA Title VI requirements.



# 487

6(a) Estimating Respondent Burden 488

489

(i) Number of Respondents 490

491

Since the rule applies to pr oducts imported into the U.S., the certification, testing, 492

recordkeeping, and reporting requirements also apply to entities outside the U.S. Therefore, this 493

analysis estimates both domestic and foreign entities. 2 

# The number of respondents is estimated 494

2 

# EPA’s Economic Analysis for the rulemaking ( Economic Analysis of the Formaldehyde Standards for Composite Wood

Products Act Implementing Regulations Proposed Rule ) does not estimate the number of foreign entities subject to the rule.

The number of domestic entities estimated here is the same as the number in the Economic Analysis.

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# Page 14 of 118 

# separately by sector (i.e., panel producers, fabricators, wholesalers, and retailers). 495

496

The number of domestic stock panel producers (41 stock hardwood plywood mills, 30 497

particleboard mills, and 22 MDF mills) is taken from EPA’s Economic Analysis for the 498

rulemaking, and is described in more detail there. The estimate of foreign stock panel mills 499

exporting to the U.S. is based on the number of foreign mills on the CARB list of certified mills. 3 

# 500

To remain consistent with the Economic Analysis , which estimates that the share of imports that 501

is not CARB certified is larger compared to the share of domestic production that is not certified, 502

the analysis assumes the number of foreign mills that are not currently certified under the CARB 503

ATCM but will seek certification under the Title VI rule as 20 percent of the total number of 504

foreign mills certified under the CARB ATCM. 505

506

The Economic Analysis for the rule estimated there are 7,486 to 13,875 domestic entities 507

making wood veneer laminated products. The high end estimate (13,875) is used here. Under the 508

rule, wood veneer laminated products are exempted from the definition of hardwood plywood if 509

they are made with compliant platforms and NAF resins. The Economic Analysis estimates that 510

most domestic laminators not already using NAF resi ns will switch to them so that their products 511

will be exempted from the definition of hardwo od plywood. However, two percent of wood 512

veneer laminated product producers (278 entities) are assumed to continue to use added 513

formaldehyde resins and therefore will make products defined as hardwood plywood. The 514

remaining wood veneer laminated product produ cers (13,597 entities) make products that will 515

not be defined as hardwood plywood, so these entities will be considered fabricators under the 516

rule. The process used to estimate the number of wood veneer laminated product producers is 517

described in greater detail in the Economic Analysis. 518

519

As described in the Economic Analysis for the rule, the number of domestic wholesale 520

and retail trade firms was estimated using employer and nonemployer data from the Census. 4 

# 521

These totals were adjusted to account for that fact that not all firms are expected to sell 522

composite wood products. For example, some retail stores in the Floor Covering Stores industry 523

(NAICS 442210) might only sell carpet and rugs, and therefore would not be affected by the 524

proposed TSCA Title VI rule’s requirements. Data from the 2007 Economic Census’ Product 525

Lines Subject Series were used to estimate the pe rcentage of wholesalers and retailers that sell 526

composite wood products in affected industries. 5 

# 527

528

The numbers of foreign fabricators and wholesalers were estimated by 1) calculating the 529

ratio of the total customs value of imports for th e affected fabricator NAICS to the total domestic 530

3 

# California Air Resources Board 2011.

4 

# The following NAICS are included for wholesalers: 423210, 423220, 423310, 423320, 423330, 423390, 423410, 423420,

423430, 423440, 423450, 423490, 423510, 423610, 423620, 423690, 423710, 423720, 423730, 423740, 423740, 423810,

423820, 423830, 423840, 423850, 423910, 423920, 423930, 423940, 423990, 424110, 424120, 424130, 424210, 424310,

424320, 424330, 424340, 424410, 424420, 424450, 424460, 424480, 424490, 424510, 424610, 424690, 424910, 424920,

424930, 424940, 424950, 424990.

The following NAICS are included for retailers: 441110, 441210, 441221, 441229, 441320, 442110, 442210, 442291, 442299,

443111, 443112, 443120, 443130, 444110, 444120, 444130, 444190, 444210, 444220, 445110, 445120, 445210, 445220,

445230, 445291, 445292, 445299, 445310, 446110, 446120, 446130, 446191, 446199, 447110, 447190, 448110, 448120,

448130, 448140, 448150, 448190, 448210, 448310, 448320, 451110, 451120, 451130, 451140, 451211, 451212, 451220,

452111, 452112, 452910, 452990, 453110, 453210, 453220, 453910, 453920, 453930, 453991, 453998, 454111, 454113,

454210, 454311, 454312, 454390.

5 

# U.S. Census Bureau 2010a, 2011.

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# Page 15 of 118 

# value of shipments for these NAICS and 2) applying it to the number of domestic firms in each 531

sector. In addition, the percentage of domes tic wholesalers that import composite wood products 532

or articles that contain composite wood products was estimated as ratio of the customs value of 533

imports to the sum of the customs value of imports and the total domestic value of shipments. 534

Exhibit 6-3 

# presents the customs value of imports and the domestic value of shipments for the 535

affected industries. 536

537

Exhibit 6-3: Customs Value of Imports and Dome stic Value of Shipments, by NAICS (millions,

2010$)

NAICS Description Customs

Value of

Imports Domestic

Value of

Shipments Sum of

Imports and

Domestic

Shipments

321211 Hardwood veneer and plywood manufacturing $1,516 $3,327 $4,843

321219 Reconstituted wood product manufacturing $1,502 $6,721 $8,223

321911 Wood window and door manufacturing $491 $14,161 $14,653

321918 Other millwork (including flooring) $770 $7,483 $8,254

321991 Manufactured home (mobile home) manufacturing $2 $6,086 $6,089

321992 Prefabricated wood building manufacturing $50 $4,215 $4,265

321999 All other miscellaneous wood product manufacturing $1,927 $6,058 $7,984

336213 Motor home manufacturing $117 $5,779 $5,896

336214 Travel trailer and camper manufacturing $537 $10,641 $11,178

337110 Wood kitchen cabinet and countertop manufacturing $491 $18,658 $19,149

337121 Upholstered household furniture manufacturing $2,898 $11,269 $14,166

337122 Nonupholstered wood household furniture manufacturing - - -

337124 Metal household furniture manufacturing $2,708 $2,393 $5,101

337127 Institutional furniture manufacturing $12,133 $5,799 $17,932

337129 Wood television, radio, and sewing machine cabinet manufacturing $4 $407 $411

337211 Wood office furniture manufacturing $697 $2,904 $3,601

337212 Custom architectural woodwork and millwork manufacturing - - -

337214 Office furniture (except wood) manufacturing $410 $8,978 $9,388

337215 Showcase, partition, shelving, and locker manufacturing $4,283 $7,873 $12,156

339920 Sporting and athletic goods manufacturing $6,260 $12,510 $18,770

339932 Game, toy, and children's vehicle manufacturing $21,428 $2,712 $24,140

339950 Sign manufacturing $184 $13,003 $13,187

339992 Musical instrument manufacturing $1,190 $1,796 $2,986

Total $59,598 $152,772 $212,370

Ratio of Customs Value of Imports Domestic Shipments 39%

Ratio of Customs Value of Imports to Sum of Imports and Domestic Shipments 28%

Sources: U.S. Census Bureau 2010b, U.S. International Trade Commission 2011



# 538

As indicated in Exhibit 6-3 

# . imports are 39.0 percent of the U.S. value of shipments for 539

these goods. Therefore, as shown in Exhibit 6-4, it is assumed that there are 39.0 percent as 540

many foreign fabricators that export products to the U.S. as there are domestic fabricators 541

(31,083 foreign fabricators compared to 79,701 domestic fabricators). Similarly, it is assumed 542

that there are 39 percent as many foreign wholesalers that export composite wood products or 543

goods containing composite wood products to the U. S. as there are domestic wholesalers that are 544

subject to the rule (33,368 foreign wholesalers co mpared to 85,560 domestic wholesalers). The 545

analysis assumes that composite wood products and goods containing composite wood products 546

are generally exported to the United States by panel producers, fabricators, or wholesalers. Few 547

foreign retailers are assumed to export composite wood products directly to the U.S., so the 548

analysis does not estimate that number. 549

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# Page 16 of 118 

# 550

The number of wholesalers that import composite wood products is assumed to be 551

proportional to the ratio of the value of imports of composite wood products to the sum of the 552

total import and domestic shipment values. As shown in Exhibit 6-3 imports represent 28 553

percent of the value of imports and domestic shipments. Thus, it is estimated that 28 percent of 554

wholesalers are importers of composite wood products . This results in an estimate that 23,957 of 555

the 85,560 domestic wholesalers import composite wood products. Since the number of 556

wholesalers that import products is estimated us ing the total customs value of imports (which 557

reflects imports by all sectors), to the extent that some products are imported directly by retailers, 558

the number of such retailers (and their recordkeeping burden) would be reflected in the 559

wholesaler estimate. And to the extent that some fabricators import composite wood products 560

directly, the estimated total recordkeeping burden may be overstated (since the recordkeeping 561

burden for fabricators is estimated separately). 562

563

Exhibit 6-4: Summary of Respondents, by Sector and Geographic Location

Sector Domestic

Res p ondents Foreign

Res p ondents 1 

# Total

Res p ondents

Composite Panel Producers (Mills)

Stock Panel Mills

Stock Hardwood Plywood 41 538 579

Particleboard 30 209 239

MDF 22 274 296

Wood Veneer Laminated Product Producers

(Classified as making Hardwood Plywood) 2 

# 277 108 385

Total Composite Panel Producers 370 1,129 1,499

Fabricators (Firms)

Wood Veneer Laminated Product Producers

(Classified as Fabricators) 13,598 5,303 18,901

Other Fabricators 66,103 25,780 91,883

Total Fabricators 79,701 31,083 110,784

Wholesalers (Firms)

Wholesalers that import 23,957 --- 23,957

Wholesalers that do not import 61,603 --- 61,603

Total Wholesalers 85,560 33,368 118,928

Retailers(Firms) 3 

# 759,048 0 759,048

Total 924,679 65,580 990,259

Notes: 1. The numbers of foreign fabricators and wholesaler s were estimated by 1) calculating the ratio of the total

customs value of imports for the affected fabricator NAICS to the total domestic value of shipments for these NAICS

(which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assumes that there

are foreign retailers do not typically export composite wood products or goods containing composite wood products into

the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified product

being imported into the U.S., the analysis assumes that the number of certified foreign mills as is 20 percent of the total

number of certified mills.

2. These are laminators that are assumed to continue using added formaldehyde resins after the rule is implemented. It is

also assumed that all wood veneer laminated product producers are single-establishment firms.

3. The analysis assumes that there are foreign retailers do not typically export composite wood products or goods

containing composite wood products into the United States.



# Sources: California Air Resources Board 2011, Composite Panel Association 2011, U.S. Census Bureau

2009, 2010a, b, c, d, e, f, g, h, 2011, U.S. International Trade Commission 2011



# 564

As indicated in Exhibit 6-4, there are an estimated total of 990,259 domestic and foreign 565

respondents. Domestic respondents account for an estimated 93.4 percent of the total. Retailers 566

account for the largest proportion of the total respondents (76.7 percent). Wholesalers, 567

fabricators, and composite panel producers account for approximately 12.0 percent, 11.2 percent, 568

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# Page 17 of 118 

# and 0.2 percent of the total number of respondents, respectively. 569

570

(ii) Burden Per Respondent 571

572

This section describes the per-activity recordkeeping and reporting burden for 573

respondents as a result of the proposed TSCA Title VI rule. Where some TPCs have more 574

stringent requirements than the proposed TSCA Title VI rule requires, the analysis is based on 575

the TPC requirements. For example, HPVA requ ires mills to have on-site audits and large 576

chamber tests annually for NAF-certified products , and quarterly for ULEF-certified products, 577

which is more frequently than the CARB ATCM or the proposed TSCA Title VI rule require. 578

Therefore this analysis estimates the burden and cost estimates for mills based on the 579

requirements frequently imposed by TPCs, rather than the requirements in the CARB ATCM or 580

the proposed TSCA Title VI rules. Exhibit 6- 5 summarizes the differences between how TPCs 581

are assumed to implement a standard certifica tion and a certification with an NAF or ULEF 582

exemption. 583

584

Exhibit 6- 5 : Testing and Certification Frequencies Assumed to be Implemented by TPCs

Category Standard NAF ULEF

Certification Fee Annual Annual (reduced fee after first

year) Annual (reduced fee after first

year)

Qualifying Testing One-time One-time One-time

TPC Audit Quarterly Twice initially and annually

thereafter Twice initially and annually

thereafter

TPC Audit Travel First audit each year Annual Annual

Large Chamber TPC

Testing Quarterly Once initially and annually

thereafter Once initially and quarterly

thereafter

QC Testing On-going First 3 months and exempt

thereafter First 6 months and exempt or

reduced thereafter

Desk Audit Monthly (excludes

audit months) First 2 months and exempt

thereafter First 4 months and exempt

thereafter



# 585

Respondent activities are presented separate ly for each unique combination of (1) 586

responses per respondent and (2) per-response burden that is accounted for in this analysis. For 587

example, while all composite panel producers are with a standard certification are required to 588

have an on-site audit performed quarterly, those with ULEF or NAF certification are exempt 589

from sub sequent receive two audits after three months of routine small scale testing in the first 590

year and one quarterly test. then are audited annually thereafter. 6 

# As a result, even though these 591

audits are assumed to take the same amount of time for all producers (four managerial-level 592

hours), they are presented as separate activities because they require a different number of annual 593

responses, depending on the certification type. Th e section begins with a description of activities 594

that are common to all respondents, and then separately discusses the activities by category of 595

respondents (composite panel producers, fabricators, wholesalers, and retailers). 596

6 

# This is an example where the TPC requirements are more stringent than the regulatory requirements.

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# Page 18 of 118 

# 597

This section also describes the process used to estimate the number of respondents in 598

each activity group. Note that the number of foreign respondents in each activity group is 599

estimated by 1) calculating the sector-specific ratio of domestic respondents by certification type 600

to the total domestic respondents in that sector; 2) applying the ratio to the estimated number of 601

foreign respondents in the sector; and, 3) taking the sum of the rounded estimates across all 602

affected sectors. For example, this analysis assumes that 1 7 of the 30 41 domestic 603

particleboard hardwood plywood respondents (or 3.3 17.1 percent) and 2 of the 22 domestic MDF 604

respondents (or 9.1 percent) will switch from ULEF are currently NAF certified under CARB and 605

will maintain NAF certification to standard certification as a result of the under the TSCA Title 606

VI rule. As a result, it is assumed that 6 certified 76 foreign particleboard hardwood plywood 607

respondents ( 3.3 17.1 percent of 173) and 26 the 448 foreign hardwood plywood mills with 608

current CARB certification) are currently NAF certified foreign MDF respondents (9.1 percent 609

of 228) under CARB and will switch from ULEF maintain NAF certification to standard 610

certification as a result of under the TSCA Title VI rule. 611

612

(A). All Respondents 613

614

The burden associated with rule familiarizati on is presented first because this activity is 615

common to all respondents. Composite panel producers are presented separately from the other 616

respondent types because they are subject to testing and certification requirements unique to their 617

sector. Since wood veneer laminated product pr oducers will be defined as either hardwood 618

plywood manufacturers or fabricators under the proposed rule (depending on the resin they use), 619

they are discussed within the context of these respondent types. 620

621

Rule Familiarization (Activity #1) 622

623

All entities will need to familiarize themse lves with the proposed regulation and either 624

ensure that their current systems are sufficien t for the requirements or identify necessary 625

changes. The analysis assumes that all respondents will spend an average of 4.0 managerial 626

labor hours on rule familiarization. This one- time burden is incurred during the first year. 627

628

(B). Composite Panel Producers 629

630

In addition to rule familiarization, comp osite panel producers will also spend time on 631

testing and certification, recordkeeping, and labeli ng activities. This analysis assumes that mills 632

making product lines that have a standard certification or a NAF certification are certified under 633

the CARB ATCM will not need to submit new data or resubmit existing data to their existing 634

TPC in order to receive the equivalent certifica tion under the TSCA Title VI regulations. Thus, 635

this ICR does not include burdens and costs for these reporting and recordkeeping activities 636

where it is assumed the activities were already performed to comply with the CARB ATCM and 637

will not need to be performed again. This is consistent with the methodology used in the 638

Economic Analysis for the proposed rule. However, this ICR does include the burdens and costs 639

of required activities that will continue to be pe rformed under the TSCA Title VI rule, even if 640

those activities would be performed regardless of the TSCA rule (i.e., to comply with the CARB 641

ATCM). This is different from the methodology in the Economic Analysis for the proposed rule, 642

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# Page 19 of 118 

# where the baseline included activities performed to comply with the CARB ATCM. As a result, 643

the Economic Analysis excluded the costs of activities that woul d be performed even without the 644

TSCA rule. 645

646

In addition, this analysis assumes that two percent of wood veneer laminated product 647

producers will continue to use ad ded formaldehyde resins and thus be classified as hardwood 648

plywood producers. Since laminators are not certified under the CARB ATCM, these producers 649

will incur additional costs due to the TSCA Title VI rule. 650

651

TSCA Title VI requires panel producers to perform formaldehyde emission testing on 652

their composite wood products and obtain and maintain certification from an accredited TPC. 653

Panel producers must undergo qualifying tests at a TPC lab, obtain an on-site audit from a TPC, 654

implement quality control systems, and train quality control employees in order to receive initial 655

certification. Once a TPC certifies a panel prod ucer, that producer is required to conduct on656

going small scale quality control testing, submit monthly reports to the TPC, and receive 657

quarterly on-site audits and large scale testing to maintain its certified status. Panel producers 658

that make products with ULEF or NAF resins and meet more stringent emissions limits may 659

apply for exemptions from some of the on-going testing requirements. 660

661

NAF certification can be achieved by performing three months of routine small scale 662

testing and one quarterly primary or secondary method test at the TPC. ULEF certification can 663

be achieved by performing six months of routine small scale testing and one quarterly primary or 664

secondary method test at the TPC. Product lines approved for ULEF or NAF certification are 665

regulatorily exempt from routine small scale testing and quarterly primary or secondary method 666

TPC testing for two years, after wh ich point the mill may reapply for a ULEF or NAF 667

certification by submitting the results of at least one primary or secondary method test ; however

. 668

However, because some TPC requirements are more stringent than the rule , this analysis 669

assumes that ULEF product lines will receive quarter ly TPC testing, and that ULEF and NAF670

certified mills will undertake a TPC audit annually. Where the frequency of testing is different 671

for composite panel producers with ULEF, NAF certification and standard certification, these 672

groups are presented separately. 673

674

Initial On-site Audit (Activity #3) 675

676

Prior to certification, the TPC is expected to make at least one trip to the mill to inspect 677

the mill’s quality control systems and employees. Du ring the initial visit, the TPC will assist the 678

mill in setting up quality control sy stems, including the small scale testing facility, if applicable, 679

and methods for selecting samples. Audits typically do not take more than one day of travel and 680

visitation, though if the mill requires a substantia l number of modifications or is unprepared, the 681

duration of the visit may be longer. 7 

# This analysis assumes that a managerial-level employee 682

will be present for eight hours during the initial on-site audit of mills. It is assumed that the 683

initial quality control audit (see below) is sufficien t for mills with existing CARB certifications. 684

685

Quality Control Systems Development (Activity #4) 686

687

7 

# Personal Communication with HPVA 2011.

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# Page 20 of 118 

# Mills are required to implement quality control procedures to ensure that all certified 688

products consistently meet the applicable emissions standards. In addition, mills are required to 689

designate a quality control manager and quality control employees, if needed. The quality 690

control manager must have adequate training or experience to handle all quality control 691

procedures, including on-site testing and shipping samples for TPC testing. All quality control 692

procedures and designated quality control personnel must be identified in a quality control 693

manual. Prior to the mill’s initial certificatio n, the TPC will assist mills in developing and 694

documenting appropriate quality control procedures. In some cases, the mill’s resin supplier will 695

also help to train quality control employees and develop quality control procedures. 696

697

Based on conversations with CPA, HPVA, and composite wood manufacturers, it is 698

assumed that training, implementing quality control systems, and developing the quality control 699

manual could take between one and five days to complete, depending on the mill’s existing 700

quality control systems. HPVA and CPA noted that smaller mills often do not have quality 701

control systems in place and that developing these systems can be a time-consuming process. 702

This analysis assumes that a managerial-lev el employee will spend forty hours training, 703

becoming familiarized with the testing and certifi cation requirements, writing the quality control 704

manual, and setting up quality control systems and testing procedures. It also assumes that mills 705

with existing certifications will have quality co ntrol systems in place an d so will not need to 706

spend time on these activities. 707

708

Qualifying Test (Activities #5 and #6) 709

710

Composite panel producers are required to obtain five qualifying tests for each product 711

type (e.g., veneer core hardwood plywood) and production line for which certification is sought. 712

A TPC employee must select and ma rk the panels to be tested du ring the initial mill audit, with 713

at least one panel being selected for each test. After panel selection has occurred, the mill must 714

ship the marked panels to the TPC for large scale testing. 8 

# Results from the five large chamber 715

tests must not exceed the emission standards for each product type and production line. Mills are 716

expected to ship at least five 4’ x 8’ panels for each product type via a commercial shipping 717

carrier. Panels must be dead-stacked (i.e., havi ng no layers between panels), bundled air-tight, 718

wrapped in polyethylene, and prot ected by cover sheets. The anal ysis assumes that it will take a 719

managerial-level employee half an hour to prepar e the panels for shipping. Producers that are 720

already CARB compliant and are not expected to adopt a more stringent certification type thus 721

will not incur this burden. 722

723

Quality Control Audits (Activities #8 and #11) 724

725

After certification has been granted, the TPC is obligated to perform an on-site audit at 726

least once quarterly, unless the mill obtains ULEF or NAF certification. TPCs may also conduct 727

periodic “desk audits,” which are quality control checks performed over the phone in which the 728

mill’s small scale testing procedures and data are reviewed. Desk audits are assumed to occur 729

monthly, except in months with quarterly on-s ite audits. This analysis assumes that a 730

8 

# Large scale testing can be performed using either the primar y test method or an equivalent secondary test method; however,

this analysis assumes that all qualifying testing is perform ed using the primary test method. The primary method for

formaldehyde testing is the large chamber test, as defined by ASTM International Standard E1333.

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# Page 21 of 118 

# managerial-level employee will be present for four hours for every on-site quality control audit, 731

and one hour for each desk audit. 732

733

This analysis assumes that producers with new NAF certifications will incur the burden 734

associated with one on-site audit (in addition to th e initial audit) and two desk audits in the first 735

year. The initial on-site audit is assumed to be sufficient for producers with existing ULEF and 736

NAF certifications. All ULEF and NAF-certified producers will have one on-site audit annually 737

thereafter. 738

739

Quality Control Tes ting (Activity #14) 740

741

Mills must also perform on-going quality control testing on the applicable products. 742

Quality control testing is typically performed using a small chamber test (ASTM D6007) or 743

desiccator test (ASTM D5582). These tests requir e smaller test samples and can be conducted at 744

the TPC facility or on-site at a TPC-approved lab at the composite wood mill. The TPC must 745

develop a statistical correlation between the la rge scale and small scale test methods using a 746

minimum of five data pairs. It is assumed that mills will need to obtain all five data pairs during 747

qualifying testing, though it is possible that some mi lls may be able to use previous test results or 748

data obtained from the resin manufacturer. Each large chamber test requires results from one 749

small chamber test or three desiccator tests to cal culate the correlation. This analysis assumes 750

that the TPC will perform desiccator testing for half of the mills and small chamber testing for 751

the other half during qualification when small scale testing is performed at the TPC. Thus, if the 752

TPC performs 5 large chamber tests, it would also perform either 15 desiccator tests or 5 small 753

chamber tests. 754

755

Mills have the option of constructing an on-site lab and having it approved by a TPC, or 756

contracting a certified third-party lab to perform small scale quality control testing. The decision 757

to perform on-site testing is dependent on the relative costs of building and running an on-site 758

lab, and the fees and shipping costs associated wi th hiring a third-party lab. According to CPA 759

and HPVA, particleboard and MDF mills already have their own on-site labs to test for 760

formaldehyde (because they have to test their products on a daily basis under the CARB ATCM), 761

while most smaller hardwood plywood mills pay their TPC to conduct their quality control 762

testing. (In part because hardwood plywood mills often use ULEF or NAF resins to qualify for 763

exemptions from some of the on-going testin g requirements under the CARB ATCM.) However, 764

the CARB ATCM allows mills to ship panels fr om certified product lines before test results are 765

available. By contrast, the proposed TSCA VI rule requires mills to wait until test results 766

indicate that the emissions standards have been met before shipping a lot that has been tested. It 767

is uncertain how often mills currently ship product from a lot being tested before the test results 768

are available and therefore it is uncertain how mills will choose to comply with this requirement. 769

It may be the case that some mills normally maintain a level of inventory where they would 770

typically not ship any panels before test results ha ve been determined for th at lot, but other mills 771

may ship out panels on the same day they are produ ced. This analysis assumes that all mills that 772

have not already done so will opt to set up and ope rate a quality control testing facility on-site, in 773

order to minimize the time spent waiting for test re sults, and to maximize their flexibility to ship 774

out panels shortly after they have been produced. (Assuming that mills conduct on-site testing 775

may overstate the costs of this requirement if some mills find it more cost effective to hold 776

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# Page 22 of 118 

# products in inventory until test results have been determined by an outside lab.) Producers that 777

are already CARB compliant and are not expected to adopt a more stringent certification type 778

(e.g., NAF) will not need to perform correlation testing. 779

780

The frequency of small scale testing without ULEF or NAF certification depends on the 781

product type and other factors. For hardwood plywood producers, the frequency of testing 782

depends upon the volume of hardwood plywood produced weekly at each plant. Plants 783

producing less than 100 thousand square feet (msf) per week are required to test once per 100 784

msf. Plants producing between 100 msf and 200 thousand square feet (msf) per week are 785

required to test once, plants producing between 200 msf and 400 msf per week are required to 786

test twice per week, and those producing greater than 400 msf per week are required to test four 787

times per week. Particleboard and MDF producers must test samples at least once per eight or 788

twelve hour shift, but this frequency may be reduced to one test per forty-eight hours if the plant 789

or production line has shown consistent operations and low variability of test results. This 790

analysis makes the simplifying assumption that all producers will test each production line once 791

daily. This results in a conservative estimate of the burden and cost of quality control testing for 792

hardwood plywood producers. It is assumed that the quality control manager will spend two 793

hours each day performing routine quality control testing. 794

795

As previously stated, composite panel producers need to perform 3 months of routine 796

small scale testing to become NAF certified. As a result, it is assumed that new NAF producers 797

will perform 65 daily quality control tests (assuming that the plants are in operation 5 days per 798

week). It is assumed that producers with existing ULEF or NAF certifications will not incur the 799

burden associated with initial quality control testing. ULEF and NAF certified producers will 800

not incur any additional burden associated with quality control testing in subsequent years. Note 801

that the numbers of quality control testing responses are presented at the product line level; as a 802

result, the per-response burdens have been modified accordingly. 803

804

Recurring Recordkeeping (Activity #17) 805

806

Panel producers are assumed to incur an average labor burden of one hour of managerial 807

labor per week (equivalent to $3,710.72 per year) to maintain the following records for 5 3 years: 808

809

 Records of quarterly emission testing and quality control testing that identify the 810

accredited third-party certifier conducting or overseeing the testing and the 811

laboratory or quality control facility actually performing the testing. These 812

records must also include the date, the product type tested, the lot or batch number 813

that the tested material represents, the te st method used, and the test results; 814

 Production records, including a description of the composite wood product(s), the 815

date of manufacture, lot or batch numbers, the amount of resin use by volume and 816

weight, the resin trade name, resin manufacturer and supplier contact information, 817

and tracking information allowing each product to be traced to a specific lot 818

number or batch produced; 819

 Records demonstrating initial and contin ued eligibility for the reduced testing 820

provisions for products made with ultra-low formaldehyde or no-added 821

formaldehyde-based resins, if applicable; 822

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# Page 23 of 118 

#  Records of changes in production, including changes in resin use, resin 823

composition, and changes in the process, such as changes in press time; 824

 Purchaser information for each composite wood product, if applicable, including 825

the name, contact person, address, phone number, e-mail address if available, 826

purchase order or invoice number, and amount purchased; 827

 Transporter information for each composite wood product, if applicable, 828

including name, contact person, address, phone number, e-mail address if 829

available, and shipping invoice number; 830

 Information on the disposition of non-complying lots, including product type and 831

amount of composite wood products affected, lot or batch numbers, mitigation 832

measures used, results of retesting, and final disposition; 833

 Copies of labels used; 834

 Panel producers are required to maintain an up-to-date quality control manual on 835

their premises; and 836

 Panel producers are required to maintain the credentials of their quality control 837

managers and quality control employees for as long as employees are serving in a 838

quality control capacity. 839

840

Initial Labeling (Activity #18) 841

842

It is assumed that panel producers, for whom product labeling is a customary business 843

practice, will incur the incremental costs of 6 hours of clerical labor for changing their labels 844

twice. They may need to change their labels once before the effective date of the rule (to 845

indicate that the panels were produced before that date if they are to be sold after the rule goes 846

into effect) and again after their product lines are certified. 847

848

To remain consistent with the Economic Analysis, wood veneer laminated product 849

producers defined as hardwood plywood producers are assumed to incur the same burden as the 850

fabricators who are assumed to incur more substantial initial labeling costs (an average of 100 851

hours of technical labor) (see below). 852

853

(C) Fabricators 854

855

While all fabricators will incur the burden a ssociated with rule familiarization, only a 856

fraction will incur the additional burdens associated with recordkeeping and labeling. This is 857

because 1) many fabricators are already complying with similar requirements in the CARB 858

ATCM because the products they make are sold in California, and 2) many fabricators’ existing 859

recordkeeping and labeling systems are expected to be sufficient to meet the proposed rule’s 860

requirements without any significant modifications. 861

862

All fabricators are required to label their products with their name, the date the finished 863

good was produced, and a statement of complian ce. Fabricators are also required to take 864

“reasonable precautions” to ensure that the composite wood products and finished goods they 865

acquire are in compliance with the applicable emission standards. This includes keeping records 866

showing the date of purchase, the supplier, as we ll as all precautions taken to ensure that the 867

product meets emissions standards. These records must be kept for five three years. 868

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# Page 24 of 118 

# 869

Baseline Compliance for Fabricators 870

871

The baseline level of compliance for most fabricators was determined based on 872

conversations with industry associations. 9 

# However, baseline compliance for some industries 873

was estimated simply as the number of establis hments located in Califor nia divided by the total 874

number of U.S. establishments in each industry. Exhibit 6-6 presents the estimated baseline 875

CARB compliance levels for fabricator industr ies. The baseline CARB compliance category 876

represents the percent of fabricators estimated to be selling their products in California, and thus 877

using certified panels and complying with the re cordkeeping requirements. Additional details 878

are provided in the Economic Analysis for the rulemaking. 879

880

Exhibit 6-6: Baseline CARB Compliance of Fabricator Industries

NAICS NAICS Definition Baseline CARB

Compliance a



# 321211 b 

# Hardwood Veneer and Plywood Manufacturing 100%

321219 b 

# Reconstituted Wood Product Manufacturing 100%

337110 b 

# Wood Kitchen Cabinet and Countertop Manufacturing 50%

337129 b 

# Wood Television, Radio, and Sewing Machine Cabinet Manufacturing 50%

321911 b 

# Wood Window and Door Manufacturing 100%

337121 b 

# Upholstered House Furniture Manufacturing 100%

337122 b 

# Non-upholstered Wood Household Furniture Manufacturing 100%

337124 b 

# Metal Household Furniture Manufacturing 100%

337127 b 

# Institutional Furniture Manufacturing 100%

337211 b 

# Wood Office Furniture Manufacturing 100%

337214 b 

# Office Furniture (except Wood) Manufacturing 100%

337215 b 

# Showcase, Partition, Shelving, and Locker Manufacturing 100%

321918 c 

# Other Millwork (incl uding Flooring) 9.23%

337212 c 

# Custom Architectural Woodwork and Millwork 9.83%

321999 c 

# All Other Miscellaneous Wood Product Manufacturing 7.84%

336213 c 

# Motor Home Manufacturing 100%

336214 c 

# Travel Trailer and Camper 100%

321991 c 

# Manufactured Home (Mobile Home) Manufacturing 10.90%

321992 c 

# Prefabricated Building Manufacturing 5.92%

339950 c 

# Sign Manufacturing 10.09%

Notes: a. Baseline CARB compliance represents the percent of fabricators estimated to be selling their products in California,

and thus using certified panels and complying with the recordkeeping requirements.

b. Assumptions based on conversations with industry associations.

c. Estimated as the percentage of establishments in CA.



# Sources: U.S. Census Bureau 2009, 2010i



# 881

Fabricators incurring Recordkeeping and Labeling Costs 882

883

The proposed recordkeeping and labeling requirements under the TSCA Title VI rule are 884

similar to the requirements under the CARB ATCM . As a result, firms that manufacture or sell 885

composite wood products destined for California markets have experience implementing 886

recordkeeping and labeling requirements that are si milar to the proposed TSCA Title VI rule. To 887

learn about the experiences of the firms who are complying with the CARB ATCM 888

requirements, two questionnaires (one for fabricators and one for wholesalers) were administered 889

9 

# Conversations with industry represented informed assumptions for the following fabricator NAICS codes: 321211, 321219,

337110, 337129, 321911, 337121, 337122, 337127, 337211, 337214, 337215, 336213, and 336214.

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# Page 25 of 118 

# to fewer than ten respondents per questionnaire. 10 

# These questionnaires asked respondents for 890

descriptions of the changes they made and the costs they incurred to implement any changes. 891

This information is described in detail in the Economic Analysis, and is summarized below. 892

893

Nine fabricator firms were administered telephone questionnaires that asked about the 894

changes that were made and the costs that were incurred in order to achieve compliance with the 895

CARB recordkeeping and labeling requirements. Based on the questionnaire results, most 896

fabricators are not estimated to incur initial co sts for recordkeeping, because their existing 897

recordkeeping systems are adequate and do not need to be modified to comply with the TSCA 898

Title VI requirements. It is estimated that 11 percent of the fabricators that are not currently 899

complying with the CARB ATCM because their products are not sold in California will incur 900

additional recurring recordkeeping costs. 901

902

The fabricator questionnaire respondent that reported incurring recurring recordkeeping 903

costs indicated that their recurring recordkeeping burden associated with the CARB ATCM was 904

about 10 hours per week (equivalent to 520 hours per year), which this analysis estimates to be 905

about $12,917 per year. However, the burden reported by this fabricator questionnaire 906

respondent seems unlikely to be representative for all the fabricator firms that incur a recurring 907

recordkeeping burden. This fabricator questionna ire respondent was a firm with employees, but 908

smaller firms, such as nonemployer firms, are likely to need much less time than 10 hours per 909

week (about a quarter of a 40 hour work week) to perform the necessary recordkeeping activities. 910

Since the recordkeeping requirements entail keeping track of composite wood materials 911

purchased and shipments that contain composite wood products, it is expected that the burden 912

associated with keeping records will typically incr ease with the volum e of a fabricator’s sales. 913

Thus, to estimate the recurring recordkeeping burden for nonemployer fabricators, the analysis 914

assumes that there is a fixed-cost component of the recurring recordkeeping costs associated with 915

two hours of labor and a variable cost component that is proportional to a firm’s revenue. It is 916

assumed that fabricators will use clerical staff to perform these activities. 917

918

For employer firms, the average recurri ng recordkeeping burden is estimated as 520 919

hours per year (based on 2 hours of fixed cost labor, with the remaining hours of variable cost 920

labor). For nonemployer firms, the variable cost component is calculated by subtracting the two 921

hours of fixed cost labor (at a cost of $49.68) from the total reported cost ($12,917) and then 922

dividing by the estimated average revenue for affected employer fabricators ($4,241,245). The 923

resulting variable cost component (0.30338 percent of revenue) is multiplied by average 924

nonemployer revenues ($42,690) and results in recurring recordkeeping costs of $179.19, or 925

approximately 7.21 labor hours per year. 926

927

Several of the respondents indicated that they already had labeling systems in place and 928

therefore they did not incur any significant costs associated with CARB’s labeling requirements. 929

However, this analysis assumes that these firms did in fact incur small costs associated with 930

making small changes to their labels. One of the firms that did report minor labeling costs 931

10 

# Retailers are also subject to the chain of custody and recordkeeping requirements. The California Retailers Association

indicated that retailers’ customary business practices were genera lly sufficient to meet the chain of custody requirements in t he

CARB ATCM (Personal Communication with CRA 2011), so retailers were not administered a questionnaire.

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# Page 26 of 118 

# reported that it took “a few hours” to change over to using the new labels. The analysis assumes 932

that “a few hours” is 3 hours for the purpose of estimating costs. The analysis also assumes that 933

67 percent of firms that are not already complying with the CARB ATCM, and all firms that are 934

already complying with the CARB ATCM, incu r the costs associated with 3 labor hours. 11 

# Two 935

other firms that responded to the questionnaire reported more substantial costs associated with 936

setting up their labeling systems and therefore, it is assumed that the remaining 33 percent of 937

firms that are not already complying with the CARB ATCM will incur the average burden 938

reported by these two firms (100 hours). 12 

# It is assumed that fabricators will use technical labor 939

to perform these activities. Since none of the fabricator respondents reported any recurring costs 940

for labeling, no recurring labeling costs are estimated. 941

942

(D). Wholesalers 943

944

While all wholesalers will incur the burden a ssociated with rule familiarization, only a 945

fraction will incur incremental burdens associated with recordkeeping and labeling. As with 946

fabricators, this is because 1) many wholes alers are already complying with the CARB ATCM 947

because they handle products that are ultimately sold in California, and 2) many wholesalers’ 948

existing recordkeeping systems are expected to meet the proposed rule’s requirements without 949

any significant modifications. Like fabricat ors, wholesalers who import composite wood 950

products are required to take “reasonable precautions” to ensure that the composite wood 951

products and finished goods they acquire are in compliance with the applicable emission 952

standards. These records must be kept for five three years. 953

954

Wholesalers that are defined as manufacturers under TSCA (because they import, 955

produce, or manufacture composite wood panels, component parts, or finished goods) must keep 956

records showing the date of purchase, the suppli er, and all precautions taken to ensure that the 957

product meets the emissions standards. Wholesal ers that are not defined as manufacturers under 958

TSCA (because they do not import such products) must keep invoices and bills of lading. Most 959

wholesalers are likely to keep invoices and bills of lading as part of their customary business 960

practices. 13 

# Therefore the requirement to keep invoices and bills of lading is not assumed to 961

impose any additional burden on wholesalers that do not import products. 14 

# 962

963

Baseline Compliance for Wholesalers 964

965

This analysis assumes that wholesale firms with establishments in California are 966

complying with the recordkeeping requirements of the CARB ATCM and therefore would not 967

incur the burden associated with some of the proposed rule’s requirements. Because data on the 968

number of firms with at least one establishment in California are not available, the following 969

steps must be taken to estimate baseline compliance for each affected industry: (1) use 2007 970

11 

# 67 percent is calculated as 4/6 since 4 of the 6 firms that reported labeling their products are assumed to have these costs.

12 

# 33 percent is calculated as 2/6 since 6 firms reported that they labeled their product.

13 

# For example, the Internal Revenue Service (U.S. Internal Revenue Service 2007) recommends that firms keep invoices in

order to document their assets, expenses, gross receipts, and purchases.

14 

# While wholesalers that do not import composite wood products are assumed to meet the proposed rule’s recordkeeping

requirements with documents kept as part of their customar y business practices, these firms do count toward the respondent

and response totals in Exhibit 6-9 through Exhibit 6-14.

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# Page 27 of 118 

# Economic Census data to identify the number of affected wholesale firms 15 

# (2) estimate the 971

number of single-unit firms in California; (3) esti mate the number of multi-unit firms with at 972

least one establishment in California; and (4) es timate baseline compliance as the percentage of 973

U.S. firms with at least one establishment in Califo rnia. Note that this approach may lead to an 974

understatement of the level of baseline compliance among wholesalers because they may sell 975

products in states where they do not have physical locations. In addition, two wholesale 976

industries -- Furniture Merchant Wholesaler s (423210) and Home Furnishing Merchant 977

Wholesalers (423220) -- are assumed to be fully compliant with the CARB ATCM chain of 978

custody requirements in the baseline. 16 

# Exhibit 6-7 presents a summary of the baseline 979

compliance estimates for wholesale industries. The Economic Analysis for the rule provides a 980

detailed description of the baseline calculations. 981

15 

# U.S. Census Bureau 2009, 2010d, j.

16 

# Personal Communication with AHFA 2010, Pers onal Communication with BIFMA 2010.

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 28 of 118 Exhibit 6-7: Baseline CARB Compliance of Wholesale Industries

NAICS NAICS Description Baseline

CARB Compliance a



# 423210 b 

# Furniture merchant wholesalers 100%

423220 b 

# Home furnishing merchant wholesalers 100%

423310 Lumber, plywood, millwork, and wood panel merchant wholesalers 12.3%

423320 Brick, stone, and related construction material merchant wholesalers 14.9%

423330 Roofing, siding, and insulation material merchant wholesalers 13.7%

423390 Other construction material merchant wholesalers 14.6%

423410 Photographic equipment and supplies merchant wholesalers 24.8%

423420 Office equipment merchant wholesalers 18.1%

423430 Computer and software merchant wholesalers 23.9%

423440 Other commercial equipment merchant wholesalers 13.0%

423450 Medical equipment merchant wholesalers 15.9%

423490 Other professional equipment and supplies merchant wholesalers 14.8%

423510 Metal service centers and othe r metal merchant wholesalers 15.1%

423610 Elec. equip. and wiring merchant wholesalers 19.3%

423620 Electric appliance merchant wholesalers 25.2%

423690 Other electronic parts and equipment merchant wholesalers 26.1%

423710 Hardware merchant wholesalers 19.4%

423720 Plumbing equip. merchant wholesalers 18.8%

423730 HVAC equip. merchant wholesalers 14.5%

423740 Refrigeration equipment and supplies merchant wholesalers 22.2%

423810 Construction equipment merchant wholesalers 11.4%

423820 Farm and garden machinery and equipment merchant wholesalers 9.5%

423830 Industrial machinery and equipment merchant wholesalers 12.3%

423840 Industrial supplies merchant wholesalers 16.2%

423850 Service establishment equipment and supplies merchant wholesalers 9.9%

423910 Sporting and recreational goods and supplies merchant wholesalers 21.1%

423920 Toy and hobby goods and supplies merchant wholesalers 30.5%

423930 Recyclable material merchant wholesalers 13.3%

423940 Jewelry merchant wholesalers 19.6%

423990 Other miscellaneous durable goods merchant wholesalers 17.9%

424110 Printing and writing paper merchant wholesalers 17.8%

424120 Stationery and office suppl ies merchant wholesalers 15.1%

424130 Industrial and personal service paper merchant wholesalers 17.2%

424210 Drugs and druggists' sundries merchant wholesalers 21.7%

424310 Piece goods, notions, and other dry goods merchant wholesalers 29.6%

424320 Men's and boys' clothing and furnishings merchant wholesalers 24.6%

424330 Women's and children's clothing merchant wholesalers 32.0%

424340 Footwear merchant wholesalers 33.1%

424410 General line grocery merchant wholesalers 19.7%

424420 Packaged frozen food merchant wholesalers 19.6%

424450 Confectionery merchant wholesalers 15.1%

424460 Fish and seafood merc hant wholesalers 12.3%

424480 Fresh fruit and vegetable merchant wholesalers 23.2%

424490 Other grocery and related products merchant wholesalers 18.8%

424510 Grain and field bean merchant wholesalers 5.2%

424610 Plastics materials and basic forms and shapes merchant wholesaler 18.1%

424690 Other chemical and allied products merchant wholesalers 13.6%

424910 Farm supplies merchant wholesalers 13.1%

424920 Book, periodical, and newspa per merchant wholesalers 16.4%

424930 Flower, nursery stock, & florists ' supplies merchant wholesalers 17.9%

424940 Tobacco and tobacco product merchant wholesalers 8.1%

424950 Paint, varnish, and supplies merchant wholesalers 18.0%

424990 Other miscellaneous nondurable goods merchant wholesalers 24.4%

Notes: a. Baseline CARB compliance represents the percent of wholesalers estimated to be selling their products in California,

and thus complying with the recordkeeping requirements.

b. Two wholesale industries, Furniture Merchant Wholes alers (423210) and Home Furnishing Merchant Wholesalers

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 29 of 118 Exhibit 6-7: Baseline CARB Compliance of Wholesale Industries

NAICS NAICS Description Baseline

CARB Compliance a



# (423220) are assumed to be fully compliant with the CARB ATCM chain of custody requirements in the baseline, based on

conversation with industry (Personal Communication with AHFA 2010, Personal Communication with BIFMA 2010).

Sources: U.S. Census Bureau 2010d, j



# 982

Wholesalers incurring Recordkeeping and Labeling Costs 983

984

Seven wholesale firms were administered telephone questionnaires that asked about the 985

changes that were made and the costs that were incurred in order to achieve compliance with the 986

CARB recordkeeping and labeling requirements. The questionnaire and the calculation of 987

recordkeeping costs are described in detail in the Economic Analysis, and are summarized 988

below. 989

990

Based on the questionnaire responses, this analysis assumes that 57 percent of 991

wholesalers that import composite wood products and/or articles that contain composite wood 992

products will incur initial recordkeeping costs associated with 59.15 labor hours. 17 

# As indicated 993

above, this analysis estimates that 28 percent of domestic wholesalers import composite wood 994

products and/or articles that contain composite wood products. In addition, the analysis assumes 995

that one percent of wholesalers will repackage their products and so will incur the same burden 996

as the fabricators who are assumed to incur more substantial initial labeling costs (an average of 997

100 hours). However, the recurring recordkeeping burden reported by the wholesaler 998

questionnaire respondent (forty five minutes per day) seems unlikely to be representative for all 999

the wholesaler firms that incur this type of bur den. This wholesaler questionnaire respondent 1000

was a firm with employees, but smaller firms, such as nonemployer firms, are likely to need 1001

much less time than 3.75 hours per week (nearly 10% of a 40 hour work week) to perform the 1002

necessary recordkeeping activities. Since the recordkeeping requirements entail keeping track of 1003

composite wood materials purchased and shipment s that contain composite wood products, it is 1004

expected that the burden associ ated with keeping records will typically increase with the volume 1005

of a wholesaler’s sales. Thus, to estimate the recurring recordkeeping burden for nonemployer 1006

wholesalers, the analysis assumes that there is a fixed-cost component of the recurring 1007

recordkeeping costs associated with two hours of labor and a variable cost component that is 1008

proportional to a firm’s revenue. It is assume d that wholesalers will use clerical labor for 1009

recordkeeping activities and technical labor for labeling. 1010

1011

For employer firms that import composite wood products, the recurring recordkeeping 1012

cost is estimated as 195 hours per year (based on 2 hours of fixed cost labor, with the remaining 1013

hours of variable cost labor). For nonemployer firms that import composite wood products, the 1014

variable cost component is calculated by subtrac ting two hours of fixed labor cost (at a cost of 1015

$51.08) from the total reported annual cost ($4,980) and then dividing by the estimated average 1016

revenue for affected employer wholesalers ($8,308, 417). The resulting variable cost component 1017

(0.05933 percent of revenue) is multiplied by average nonemployer revenues ($82,542) and 1018

results in costs of $100.05, or 3.92 labor hours per year. 1019

17 

# The average annual burden for wholesalers with initial recordkeeping costs was calculated as the average burden for the two

firms that quantified costs. One firm indicated that they spent $2,000 for a “small amount of labor.” This was divided by the

clerical wage rate in the wholesale trade industry ($25.54) and equals approximately 78.3 hours. The other firm indicated that

they spent 40 labor hours. As a result, the average firm incurred a labor burden of approximately 59.15 hours.

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 30 of 118 

# 1020

It is assumed that one percent of wholesalers incur labeling burden, either because they 1021

are repackaging goods that were originally labe led on the packaging instead of on the individual 1022

items, or because they are replacing an original label applied by the panel producer or fabricator 1023

with a label listing a different company name. It is also assumed that these wholesalers incur the 1024

same burden as the fabricators who are assumed to incur more substantial initial labeling burden 1025

(an average of 100 hours). 1026

1027

(E). Retailers 1028

1029

It is assumed that retailers do not import composite wood products directly (without a 1030

wholesaler), and thus are not subject to the rule’s chain of custody requirements for importers

. 18 

# 1031

Retailers that do not import composite wood products must keep invoices and bills of lading. 1032

Retailer’s customary business practices are assumed to be generally sufficient to meet the 1033

proposed rule’s recordkeeping requirements. 19 

# Therefore the recordkeeping requirements are not 1034

assumed to impose any additional burden on retailers. 20 

# In addition, assuming they do not 1035

modify the packaging of the composite wood products they purchase, retailers are not required to 1036

modify their labeling system to comply with the proposed rule. 1037

1038

Baseline Compliance for Retailers 1039

1040

Exhibit 6-8 presents a summary of the baseline compliance estimates for retail industries. 1041

Baseline CARB compliance was calculated in the same manner as described the wholesale 1042

section (i.e., by determining the number of firms w ith at least one establis hment in California). 1043

Additional detail is provided in the Ec onomic Analysis for the rulemaking. 1044

1045

18 

# Because all foreign products are assumed to be imported by wholesalers, the burden of the rule’s chain of custody

requirements for any retailers that do import products di rectly is accounted for under the wholesaler category.

19 

# Personal Communication with California Retailers Association 2011.

20 

# While retailers are assumed to meet the proposed rule’s recor dkeeping requirements with documents kept as part of their

customary business practices, these firms do count toward the respondent and response totals in Exhibit 6-9 through Exhibit 6-

14.

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 31 of 118 Exhibit 6-8: Baseline CARB Compliance of Retail Industries

NAICS NAICS Description Baseline CARB

Compliance

441110 New car dealers 11.5%

441210 Recreational vehicle dealers 11.6%

441221 Motorcycle, ATV, and personal watercraft dealers 10.7%

441229 All other motor vehicle dealers 10.6%

441320 Tire dealers 14.7%

442110 Furniture stores 15.2%

442210 Floor covering stores 11.2%

442291 Window treatment stores 15.0%

442299 All other home furnishings stores 15.4%

443111 Household appliance stores 10.5%

443112 Radio, television, and other electronics stores 16.8%

443120 Computer and software stores 15.1%

443130 Camera and photographic supplies stores 17.8%

444110 Home centers 16.2%

444120 Paint and wallpaper stores 19.0%

444130 Hardware stores 9.7%

444190 Other building material dealers 12.3%

444210 Outdoor power equipment stores 5.7%

444220 Nursery, garden center, and farm supply stores 8.7%

445110 Supermarkets and other grocery (except convenience) stores 15.3%

445120 Convenience stores 11.2%

445210 Meat markets 10.9%

445220 Fish and seafood markets 10.3%

445230 Fruit and vegetable markets 10.4%

445291 Baked goods stores 12.4%

445292 Confectionery and nut stores 13.9%

445299 All other specialty food stores 12.2%

445310 Beer, wine, and liquor stores 11.3%

446110 Pharmacies and drug stores 15.5%

446120 Cosmetics, beauty supplies, and perfume stores 12.4%

446130 Optical goods stores 16.1%

446191 Food (health) supplement stores 13.1%

446199 All other health and personal care stores 13.3%

447110 Gasoline stations with convenience stores 15.0%

447190 Other gasoline stations 13.1%

448110 Men's clothing stores 18.0%

448120 Women's clothing stores 17.0%

448130 Children's and infants' clothing stores 15.6%

448140 Family clothing stores 19.6%

448150 Clothing accessories stores 15.3%

448190 Other clothing stores 15.2%

448210 Shoe stores 19.1%

448310 Jewelry stores 14.4%

448320 Luggage and leather goods stores 16.1%

451110 Sporting goods stores 13.5%

451120 Hobby, toy, and game stores 14.2%

451130 Sewing, needlework, and piece goods stores 13.2%

451140 Musical instrument and supplies stores 12.2%

451211 Book stores 15.6%

451212 News dealers and newsstands 11.5%

451220 Prerecorded tape, compact disc, and record stores 14.5%

452111 Department stores (except di scount department stores) 70.8%

452112 Discount department stores 74.7%

452910 Warehouse clubs and supercenters 92.0%

452990 All other general merchandise stores 9.8%

453110 Florists 9.2%

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 32 of 118 Exhibit 6-8: Baseline CARB Compliance of Retail Industries

NAICS NAICS Description Baseline CARB

Compliance

453210 Office supplies and stationery stores 17.6%

453220 Gift, novelty, and souvenir stores 12.8%

453910 Pet and pet supplies stores 12.9%

453920 Art dealers 13.7%

453930 Manufactured (mobile) home dealers 7.3%

453991 Tobacco stores 12.7%

453998 All other miscellaneous store retailers (except tobacco

stores) 11.5%

454111 Electronic shopping 10.3%

454113 Mail-order houses 11.3%

454210 Vending machine operators 11.0%

454311 Heating oil dealers 11.7%

454312 Liquefied petroleum gas (bottled gas) dealers 20.4%

454390 Other direct selling establishments 11.1%

Total Retailers 13.2%

a. Baseline CARB compliance represents the percent of retailers estimated to be selling their

products in California, and therefore not expected to incur supplier notification costs.



# Sources:U.S. Census Bureau 1997, 2010g, k, l



# 1046

(F). Summary 1047

1048

Exhibit 6-9 and Exhibit 6-10 summarize the total number of respondents, total burden 1049

per respondent and total burden for each response activity over the first year, and second and 1050

third years of the ICR, respectively. Exhibit 6-11 presents the average total value for those 1051

variables over the first three years of the ru le (i.e., without accounting for the baseline 1052

compliance with the CARB ATCM). Exhibit 6-12 through Exhibit 6-14 mirror the previous 1053

three tables, except that they account for incremental burdens (excluding baseline burden and 1054

cost). Note that most respondents are incurri ng burdens for multiple activities listed in these 1055

exhibits. As indicated, the average annual burden over the first three years of the rule is 1056

estimated to be approximately 8.0 7.9 million hours, while the incremental burden over this time 1057

period is estimated at 5. 9 8 million hours. The domestic burden accounts for approximately 1058

62.8 63.3 percent and 66. 2 9 percent of the totals, respectively. 1059

1060

1061

1062*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 33 of 118Exhibit 6-9: Total (including baseline) First Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivitiesPerRespondentBurden PerActivity(Hours)Total Burden (Hours)DomesticForeign2TotalDomesticForeignTotal1. Rule FamiliarizationProducers3M3701,1291,49914.001,4804,5165,996Fabricators4M79,70131,083110,78414.00318,804124,332443,136WholesalersM85,56033,368118,92814.00342,240133,472475,712RetailersM759,048-759,04814.003,036,192-3,036,1922. Certification Fee---------3. Initial On-site AuditWith Existing CertificationsM8276484614.003283,0563,384Without Existing Certifications3,5M28836565318.002,3042,9205,2244. Develop Quality Control Manual3M288365653140.0011,52014,60026,1205. Qualifying Test6. Qualifying Test Shipment61 ProductM115129641406910.5063653270352 Products3,5M28836565320.251441833277. Correlation Test1 ProductM1151296414069101.00110501,2906401,4006902 Products3,5M288365653201.005,7607,30013,0608. Quarterly On-site Audit7Standard3,6M3393287135991,05292734.004,0683,9368,5567,18812,62411,124NAF (With New Certification)M171127621129322214.0068441,1048441,172888NAF (WithExisting Certification)M14140154-4.00---9. Large Scale Testing Fee---------10. Large Scale Testing Shipment7Standard/ULEFCertification3,5M3393457137781,05212330.505095181,0701671,578685NAF (With New Certification)M171127621129322210.5096138106147112NAF (With Existing Certification)M14140154-10.50-7-70-7711. On-site Audit Travel---------12. Desk Audits8Standard Certification3,5M3393287135991,05292781.002,7126245,7044,79287,416NAF (With New Certification)M171127621129322221.00342255242258644413. Purchase of Small Chamber Testing---------Formatted TableFormatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 34 of 118Exhibit 6-9: Total (including baseline) First Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivitiesPerRespondentBurden PerActivity(Hours)Total Burden (Hours)DomesticForeign2TotalDomesticForeignTotalUnit914. Quality Control Testing10Standard Certification3,6M3393287135991,0529272602.00176,280170,560370,760311,480547482,040New NAF CertificationM1711276211293222652.002,2101,43035,88027,43038,09028,86015. Lost Product---------16. Initial Recordkeeping11C8,57611,94520,521159.15507,270706,5471,213,81717. Recurring Recordkeeping12Producers3,5M3701,1291,49915219,24058,70877,948Fabricators with burden- Employers4C3,6301,4225,0521520.001,887,600739,4402,627,040Fabricators with burden - Nonemployers4C5,1371,9977,13417.2137,03814,39851,436Fabricators without burdenC70,93427,66498,5981----Wholesalers with burden - EmployersC4,2085,86110,0691195.00820,5601,142,8951,963,455Wholesalers with burden - NonemployersC6,0948,48714,58113.9223,88833,26957,158Wholesalers without burdenC75,25819,02094,2781----RetailersC759,048-759,0481----18. Initial Labeling13Minor Changes - Producers4,5C931,0211,11416.005586,1266,684Minor Changes - Fabricators4T64,29024,98689,27613.00192,87074,958267,828Major Changes - Producers3C2771083851100.0027,70010,80038,500Major Changes - Fabricators andWholesalers4T16,2666,34422,6101100.001,626,600634,4002,261,000Total - Year 19,048,102041,2964,137,039066,09113,185,140107,388Notes: 1. This column indicates the category of labor associated with the activity. "M", "T", and "C" stand for managerial, technical, and clerical labor, respectively.2. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value ofimports for the affected fabricatorNAICS to the totaldomestic value ofshipments for these NAICS (which is 39 percent) and 2) applying itto the number of domestic firmsin each sector. The analysis assumes that foreign retailers do not typically export composite woodproducts or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis,which assumes that there is uncertified product being imported into theU.S., the analysis estimates the number of certified foreignmills as 20 percent of the total number of certified mills.3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be definedas hardwood plywood. A similar proportion of foreign laminatorsexporting to the U.S. are also assumed to continue to use added formaldehyde resins.4. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.5. Since CARB does not certify wood veneer laminated products, allproducers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by a TPCas a result of the TSCA Title VI rule.6. Producers that are already CARB compliantand are not expected adopt a more stringent certification type (e.g., NAF certification)are not assumed to need to perform correlation testing because it isassumed that their previoustesting is sufficient.Formatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 35 of 118Exhibit 6-9: Total (including baseline) First Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivitiesPerRespondentBurden PerActivity(Hours)Total Burden (Hours)DomesticForeign2TotalDomesticForeignTotal7. On-site audits must be conducted at least once quarterly, unless the mill obtainsULEF orNAF certification. This analysis assumes that producers with new NAF certifications will incur the burdenassociated with one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existingULEF orNAF certifications under the CARB ATCM will only incur theinitial on-site audit in the first year. All producers withULEF orNAF certification will have one on-site audit annually thereafter.8. Desk audits are assumed to occur monthlyfor standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated withtwodesk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existingULEF orNAF certification.9. Although mills are likely to incur some labor burden while learning how to use the small chamber testing unit, it is not estimated in this analysis.10. This analysis assumes that composite panel producerswith a standard certification or a new NAF certificationtest each production line once daily.Composite panel producers need toperform 3months of routine small scaleProducers with an existing ULEF or NAF certification will already have been exempted from quality controltestingto become NAF certified.11. Recordkeeping costs are incurred by composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers),fabricators, and wholesalers that import composite wood products or articles that contain composite wood products. However, composite panel producers and fabricators are not expected to need to makeany initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. Inaddition, it is assumed that 57 percent of wholesalers are notalready complying with the CARB ATCM and will have initial burden to change their recordkeeping systems to comply with the TSCA TitleVI rule.12. While recordkeeping is required for all respondents, not all entities will incuradditionalrecordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existingrecordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percentof wholesalers willhave recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products andthus 43% of that 28% incur recurring recordkeeping burden. Thecustomary business practices of the remaining fabricators, wholesalers, and all retailers are assumed tobe generally sufficient to meet theproposed rule’s recordkeeping requirements. For fabricators andwholesalers with burden, the analysis assumes that there is afixed-cost component of the recurring recordkeeping costs associated withtwo hours of labor and a variable cost component that is proportional to a firm’s revenue. The variable cost factor is estimated by subtracting the fixed cost from the total reported cost and then dividingby the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the total reportedcost is $12,916.80, and the average revenue is $4,241,245. For wholesalers,the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variablecost factors are 0.30338 percent and 0.05933 percent of revenue. Therecurring recordkeeping burdens for employer fabricators andwholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring recordkeeping burden is estimated as thesum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs, whichare calculated as 0.30338 percent of average nonemployer fabricatorrevenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricatorand wholesaler nonemployer recurring recordkeeping burdens are 7.21and 3.92 hours per year, respectively.13.FirmsPanel producers, fabricators, and wholesalersthat package or repackage composite wood products or finishedgoods containing composite wood products will need to modify their labels toinclude their name, the date the finished good was produced, and a statement of compliance.Retailers are not required to modify their labeling system to comply with the proposed rule assuming they donot modify the packaging of the products they purchase.This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators thatare already complying with the CARB ATCM 33 percent of fabricators, and 1 percent of wholesalers will incur the cost associatedwith 3 hours of labor for making small changes to their labels. Theremaining fabricators and one percent of wholesalers are assumedto incur the average cost ofthe two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysisfor more details).1063*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 36 of 118Exhibit 6-10: Total (including baseline) Second and Third Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Total Burden (Hours)DomesticForeign2TotalDomesticForeignTotal1. Rule FamiliarizationProducers3M--------Fabricators4M--------WholesalersM--------RetailersM--------2. Certification Fee---------3. Initial On-site AuditWith Existing CertificationsM--------Without Existing Certifications3,5M--------4. Develop Quality Control Manual3M--------5. Qualifying Test---------6. Qualifying Test Shipment1 ProductM--------2 Products3,5M--------7. Correlation Test61 ProductM--------2 Products3,5M--------8. Quarterly On-site Audit7Standard3,6M3393287135991,05292744.005,42424811,4089,5841614,832NAF (With New Certification)M171127621129322214.0068441,1048441,172888NAF (With Existing Certification)M1414015414.00565606169. Large Scale Testing Fee---------10. Large Scale Testing Shipment7Standard/ULEFCertification3,5M3393457137781,05212340.506786901,4265562,104246NAF (With New Certification)M171127621129322210.5096138106147112NAF (With Existing Certification)M1414015410.507707711. On-site Audit Travel---------12. Desk Audits8Standard Certification3,5M3393287135991,05292781.002,7126245,7044,79287,416NAF (With New Certification)M--------13. Purchase of Small ChamberTesting Unit9---------14. Quality Control Testing10Standard Certification3,5M3393287135991,0529272602.00176,280170,370,760547482,040Formatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 37 of 118Exhibit 6-10: Total (including baseline) Second and Third Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Total Burden (Hours)DomesticForeign2TotalDomesticForeignTotal560311,480*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 38 of 118Exhibit 6-10: Total (including baseline) Second and Third Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Total Burden (Hours)DomesticForeign2TotalDomesticForeignTotalNew NAF CertificationM--------15. Lost Product16. Initial Recordkeeping11C--------17. Recurring Recordkeeping12Producers3,5M3701,1291,499152.0019,24058,70877,948Fabricators with burdenEmployers4C3,6301,4225,0521520.001,887,600739,4402,627,040Fabricators with burden -Nonemployers4C5,1371,9977,13417.2137,03814,39851,436Fabricators without burdenC70,93427,66498,5981----Wholesalers with burden -EmployersC4,2085,86110,0691195.00820,5601,142,8951,963,455Wholesalers with burden -NonemployersC6,0948,48714,58113.9223,88833,26957,158Wholesalers without burdenC75,25819,02094,2781----RetailersC759,048-759,0481----19. Initial Labeling4,13Minor Changes - Producers4,5C--------Minor Changes - Fabricators4T--------Major Changes - Producers3C--------Major Changes - Fabricators andWholesalers4T--------Total - Years 2 and 32,973,560967,5052,379,880317,1425,353,441284,648Notes: 1. This column indicates the category of labor associatedwith the activity. "M", "T",and "C" stand for managerial, technical, and clerical labor, respectively.2. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value ofimports for the affected fabricatorNAICS to the total domestic value ofshipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typically export composite woodproducts or goods containing composite wood products into the UnitedStates. To remain consistent with the Economic Analysis,which assumes that there is uncertified product being imported into theU.S., the analysis estimates the number of certified foreignmills as 20 percent of the total number of certified mills.3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be definedas hardwood plywood. A similar proportion of foreign laminatorsexporting to the U.S. are also assumed to continue to use added formaldehyde resins.4. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.5. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by aTPC as a result of the TSCA Title VI rule.6. Producers that are already CARB compliantand are not expected adopt a more stringent certification type (e.g.,NAF certification)are not assumed to need to perform correlation testing because it isassumed that their previous testing is sufficient.7. On-site audits must be conducted at least once quarterly, unless the mill obtainsULEF orNAF certification. This analysisassumes that producers with new NAFcertifications will incur the burdenassociated with one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existingULEF orNAF certifications under the CARB ATCM will only incur theFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 39 of 118Exhibit 6-10: Total (including baseline) Second and Third Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Total Burden (Hours)DomesticForeign2TotalDomesticForeignTotalinitial on-site audit in the first year. All producers withULEF orNAF certification willhave one on-site audit annually thereafter.8. Desk audits are assumed to occur monthlyfor standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated withtwodesk audits in the first year; none are required in subsequentyears. No desk audits are required for respondents with existingULEF orNAF certification.9. Although mills are likely to incur some labor burden while learning how to use the small chamber testing unit, it is not estimated in this analysis.10. This analysis assumes that composite panel producerswith s standard certification or a new NAF certificationtest each production line once daily.Composite panel producers need to perform 3months of routine small scaleProducers with an existing ULEF or NAF certification will already have been exempted from quality controltestingto become NAF certified.11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fabricators,and wholesalers that import composite wood products or articles that contain composite wood products. However, composite panelproducers and fabricators are not expected to need to make any initialchanges to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, itis assumed that 57 percent of wholesalersare not already complying with the CARB ATCMand will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule.12. While recordkeeping is required for all respondents, not all entities will incuradditionalrecordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existingrecordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers willhave recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products andthus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumedto be generally sufficient to meetthe proposed rule’s recordkeeping requirements. For fabricatorsand wholesalers with burden, the analysis assumes that there is a fixed-cost component of the recurring recordkeeping costs associatedwith two hours of labor and a variable cost component that is proportional to a firm’s revenue. The variable cost factor is estimated by subtracting the fixed cost from the total reported cost and thendividing by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the totalreported cost is $12,916.80, and the average revenue is $4,241,245. Forwholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variable cost factors are 0.30338 percent and 0.05933 percent of revenue.The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. Fornonemployers, the average recurring recordkeeping burden is estimatedas the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs,which are calculated as 0.30338 percent of average nonemployer fabricatorrevenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricatorand wholesaler nonemployer recurring recordkeeping burdens are 7.21and 3.92 hours per year, respectively.13.FirmsPanel producers, fabricators, and wholesalersthat package or repackage composite woodproducts or finished goods containing composite wood products will need to modify their labels toinclude their name, the date the finished good was produced, and a statement of compliance.Retailers are not required to modify their labeling system to comply with the proposed rule assuming theydo not modify the packaging of the products they purchaseThis analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and allfabricatorsthat are already complying with the CARB ATCM 33 percent of fabricators, and 1 percent of wholesalers will incur the cost associated with 3 hours of labor for making small changes to their labels.The remaining fabricators and one percent of wholesalers are assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the EconomicAnalysis for more details).1064*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 40 of 118Exhibit 6-11: Three Year Average Burden Hours (including baseline), by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Total Burden (Hours)DomesticForeign2TotalDomesticForeignTotal1. Rule FamiliarizationProducers3M3701,1291,4990.33334.00004931,5051,998Fabricators4M79,70131,083110,7840.33334.0000106,25741,440147,697WholesalersM85,56033,368118,9280.33334.0000114,06944,486158,555RetailersM759,048-759,0480.33334.00001,011,963-1,011,9632. Certification Fee---------3. Initial On-site AuditWith Existing CertificationsM827648460.33334.00001091,0191,128Without Existing Certifications3,5M2883656530.33338.00007689731,7414. Develop Quality Control Manual3M2883656530.333340.00003,8404,8668,7065. Qualifying Test---------6. Qualifying Test Shipment1 ProductM11512964140690.33330.500021211123122 Products3,5M2883656530.66670.250048611097. Correlation Test61 ProductM11512964140693.33331.000037174302134672302 Products3,5M2883656536.66671.00001,9202,4334,3538. Quarterly On-site Audit7Standard3,5M3393287135991,0529273.66674.00004,97281110,4578,78515,42913,596NAF (With New Certification)M17112762112932221.00004.000068441,1048441,172888NAF (With Existing Certification)M141401540.66674.0000373734119. Large Scale Testing Fee---------10. Large Scale Testing Shipment7Standard/ULEFCertification3,5M3393457137781,0521233.66670.50006226331,3074261,9292,059NAF (With New Certification)M17112762112932221.00000.500096138106147112NAF (With Existing Certification)M141401540.66671.00000.5000574770517711. On-site Audit Travel---------12. Desk Audits8Standard Certification3,5M3393287135991,0529278.00001.00002,7126245,7044,79287,416Formatted TableFormatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 41 of 118Exhibit 6-11: Three Year Average Burden Hours (including baseline), by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Total Burden (Hours)DomesticForeign2TotalDomesticForeignTotalNAF (With New Certification)M17112762112932220.66671.000011718414119514813. Purchase of Small Chamber Testing Unit9---------14. Quality Control Testing10Standard Certification3,5M3393287135991,052927260.00002.0000176,280170,560370,760311,480547482,040New NAF CertificationM171127621129322221.66672.000073747711,9609,14312,6979,62015. Lost Product---------16. Initial Recordkeeping11C8,57611,94520,5210.333359.1500169,073235,492404,56517. Recurring Recordkeeping12Producers3,5M3701,1291,4991.000052.000019,24058,70877,948Fabricators with burden- Employers4C3,6301,4225,0521.0000520.00001,887,600739,4402,627,040Fabricators with burden - Nonemployers4C5,1371,9977,1341.00007.210037,03814,39851,436Fabricators without burdenC70,93427,66498,5981.0000----Wholesalers with burden - EmployersC4,2085,86110,0691.0000195.0000820,5601,142,8951,963,455Wholesalers with burden - NonemployersC6,0948,48714,5811.00003.920023,88833,26957,158157Wholesalers without burdenC75,25819,02094,2781.0000----RetailersC759,048-759,0481.0000----18. Initial Labeling4,13Minor Changes - Producers4,5C931,0211,1140.33336.00001862,0422,228Minor Changes - Fabricators4T64,29024,98689,2760.33333.000064,28424,98489,267268Major Changes - Producers3C2771083850.3333100.00009,2323,60012,832Major Changes - Fabricators and Wholesalers4T16,2666,34422,6100.3333100.0000542,146211,446753,591592Total - Three Year Average4,998,206991,9012,965,542900,0687,963,747891,969Notes: 1. This column indicates the category of labor associatedwith the activity. "M", "T",and "C" stand for managerial, technical, and clerical labor, respectively.2. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value ofimports for the affected fabricatorNAICS to the total domestic value ofshipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typically export composite woodproducts or goods containing composite wood products into the UnitedStates. To remain consistent with the Economic Analysis,which assumes that there is uncertified product being imported into theU.S., the analysis estimates the number of certified foreignmills as 20 percent of the total number of certified mills.3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be definedas hardwood plywood. A similar proportion of foreign laminatorsexporting to the U.S. are also assumed to continue to use added formaldehyde resins.Formatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 42 of 118Exhibit 6-11: Three Year Average Burden Hours (including baseline), by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Total Burden (Hours)DomesticForeign2TotalDomesticForeignTotal4. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.5. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by aTPC as a result of the TSCA Title VI rule.6. Producers that are already CARB compliantand are not expected adopt a more stringent certification type (e.g.,NAF certification)are not assumed to need to perform correlation testing because it isassumed that their previous testing is sufficient.7. On-site audits must be conducted at least once quarterly, unless the mill obtainsULEF orNAF certification. This analysisassumes that producers with new NAFcertifications will incur the burdenassociated with one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existingULEF orNAF certifications under the CARB ATCM will only incur theinitial on-site audit in the first year. All producers withULEF orNAF certification willhave one on-site audit annually thereafter.8. Desk audits are assumed to occur monthlyfor standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated withtwodesk audits in the first year; none are required in subsequentyears. No desk audits are required for respondents with existingULEF orNAF certification.9. Although mills are likely to incur some labor burden while learning how to use the small chamber testing unit, it is not estimated in this analysis.10. This analysis assumes that composite panel producerswith a standard certification or a new NAF certificationtest each production line once daily.Composite panel producers need to perform 3months of routine small scaleProducers with an existing ULEF or NAF certification will already have been exempted from quality controltestingto become NAF certified.11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fabricators,and wholesalers that import composite wood products or articles that contain composite wood products. However, composite panelproducers and fabricators are not expected to need to make any initialchanges to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, itis assumed that 57 percent of wholesalersare not already complying with the CARB ATCMand will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule.12. While recordkeeping is required for all respondents, not all entities will incuradditionalrecordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existingrecordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers willhave recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products andthus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to be generally sufficient to meetthe proposed rule’s recordkeeping requirements. For fabricatorsand wholesalers with burden, the analysis assumes that there is a fixed-cost component of the recurring recordkeeping costs associatedwith two hours of labor and a variable cost component that is proportional to a firm’s revenue. The variable cost factor is estimated by subtracting the fixed cost from the total reported cost and thendividing by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the totalreported cost is $12,916.80, and the average revenue is $4,241,245. Forwholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variable cost factors are 0.30338 percent and 0.05933 percent of revenue.The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. Fornonemployers, the average recurring recordkeeping burden is estimatedas the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs,which are calculated as 0.30338 percent of average nonemployer fabricatorrevenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricatorand wholesaler nonemployer recurring recordkeeping burdens are 7.21and 3.92 hours per year, respectively.13.FirmsPanel producers, fabricators, and wholesalersthat package or repackage composite woodproducts or finished goods containing composite wood products will need to modify their labels toinclude their name, the date the finished good was produced, and a statement of compliance.Retailers are not required to modify their labeling system to comply with the proposed rule assuming theydo not modify the packaging of the products they purchaseThis analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and allfabricatorsthat are already complying with the CARB ATCM 33 percent of fabricators, and 1 percent of wholesalers will incur the cost associated with 3 hours of labor for making small changes to their labels.The remaining fabricators and one percent of wholesalers are assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the EconomicAnalysis for more details).1065*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 43 of 118Exhibit 6-12: Incremental First Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Incremental Burden (Hours)DomesticForeign2TotalDomesticForeignTotal1. Rule FamiliarizationProducers3M3701,1291,49914.001,4804,5165,996Fabricators4M79,70131,083110,78414.00318,804124,332443,136WholesalersM85,56033,368118,92814.00342,240133,472475,712RetailersM759,048-759,04814.003,036,192-3,036,1922. Certification Fee---------3. Initial On-site AuditWith Existing CertificationsM8276484614.003283,0563,384Without Existing Certifications3,5M28836565318.002,3042,9205,2244. Develop Quality Control Manual3M288365653140.0011,52014,60026,1205. Qualifying Test---------6. Qualifying Test Shipment1 ProductM115129641406910.5063653270352 Products3,5M28836565320.251441833277. Correlation Test61 ProductM1151296414069101.00110501,2906401,4006902 Products3,5M288365653201.005,7607,30013,0608. Quarterly On-site Audit7Uncertified to Standard3,5M27715443134.003,3241,8485,172ULEF toStandardM1111412534.001321,3681,500NAF (With New Certification)M1121122214.00448448889. Large Scale Testing Fee---------10. Large Scale Testing Shipment7Uncertified to Standard3,5M27715443130.50416231647ULEF to StandardM1111412530.5017171188NAF (With New Certification)M1121122210.50610611111211. On-site Audit Travel---------12. Desk Audits8Uncertified to Standard3,5M27715443181.002,2161,2323,448ULEF to StandardM1111412581.00889121,000NAF (With New Certification)M1121122221.002242244413. Purchase of Small Chamber TestingUnit9---------14. Quality Control Testing10---------Standard Certification3,5M2882772681545564312602.00149,760144,040139,36080,080289224,120Formatted TableFormatted TableFormatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 44 of 118Exhibit 6-12: Incremental First Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Incremental Burden (Hours)DomesticForeign2TotalDomesticForeignTotalNew NAF CertificationM1711276211293222652.002,2101,43035,88027,43038,09028,86015. Lost Product---------16. Initial Recordkeeping11C8,57611,94520,521159.15507,270706,5471,213,81717. Recurring Recordkeeping12Producers3,5M3701,1291,499152.0019,24058,70877,948Fabricators with burden- Employers4C2,1768483,0241520.001,131,520440,9601,572,480Fabricators with burden -Nonemployers4C3,0541,1914,24517.2122,0198,58730,606Fabricators without burdenC42,31016,43758,7471----Wholesalers with burden - EmployersC2,6423,6806,3221195.00515,190717,6001,232,790Wholesalers with burden -NonemployersC3,8265,3319,15713.9214,99820,89835,895Wholesalers without burdenC47,26311,94459,2071----RetailersC658,150-658,1501----18. Initial Labeling4,13Minor Changes - Producers4,5C931,0211,11416.005586,1266,684Minor Changes - Fabricators4T64,29024,98689,27613.00192,87074,958267,828Major Changes - Producers3C2771083851100.0027,70010,80038,500Major Changes - Fabricators andWholesalers4T16,2666,34422,6101100.001,626,600634,4002,261,000Total - Year 17,935,088928,2883,153,692082,82811,088,777011,115Notes: 1. This column indicates the category of labor associatedwith the activity. "M", "T",and "C" stand for managerial, technical, and clerical labor, respectively.2. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value ofimports for the affected fabricatorNAICS to the total domestic value ofshipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typically export composite woodproducts or goods containing composite wood products into the UnitedStates. To remain consistent with the Economic Analysis,which assumes that there is uncertified product being imported into theU.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be definedas hardwood plywood. A similar proportion of foreign laminatorsexporting to the U.S. are also assumed to continue to use added formaldehyde resins.4. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.5. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by aTPC as a result of the TSCA Title VI rule.6. Producers that are already CARB compliantand are not expected adopt a more stringent certification type (e.g., NAF certification)are not assumed to need to perform correlation testing because it isassumed that their previous testing is sufficient.7. On-site audits must be conducted at least once quarterly, unless the mill obtainsULEF orNAF certification. This analysisassumes that producers with new NAFcertifications will incur the burdenassociated with one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existingULEF orNAF certifications under the CARB ATCM will only incur theFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 45 of 118Exhibit 6-12: Incremental First Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Incremental Burden (Hours)DomesticForeign2TotalDomesticForeignTotalinitial on-site audit in the first year. All producers withULEF orNAF certification willhave one on-site audit annually thereafter.8. Desk audits are assumed to occur monthlyfor standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated withtwodesk audits in the first year; none are required in subsequentyears. No desk audits are required for respondents with existingULEF orNAF certification.9. Although mills are likely to incur some labor burden while learning how to use the small chamber testing unit, it is not estimated in this analysis.10. This analysis assumes that composite panel producerswith a standard certification or a new NAF certificationtest each production line once daily.Composite panel producers need to perform 3months of routine small scaleProducers with an existing ULEF or NAF certification will already have been exempted from quality controltestingto become NAF certified.11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fabricators,and wholesalers that import composite wood products or articles that contain composite wood products. However, composite panelproducers and fabricators are not expected to need to make any initialchanges to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, itis assumed that 57 percent of wholesalersare not already complying with the CARB ATCMand will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule.12. While recordkeeping is required for all respondents, not all entities will incuradditionalrecordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existingrecordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers willhave recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products andthus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumedto be generally sufficient to meetthe proposed rule’s recordkeeping requirements. For fabricatorsand wholesalers with burden, the analysis assumes that there is a fixed-cost component of the recurring recordkeeping costs associatedwith two hours of labor and a variable cost component that is proportional to a firm’s revenue. The variable cost factor is estimated by subtracting the fixed cost from the total reported cost and thendividing by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the totalreported cost is $12,916.80, and the average revenue is $4,241,245. Forwholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variable cost factors are 0.30338 percent and 0.05933 percent of revenue.The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. Fornonemployers, the average recurring recordkeeping burden is estimatedas the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs,which are calculated as 0.30338 percent of average nonemployer fabricatorrevenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricatorand wholesaler nonemployer recurring recordkeeping burdens are 7.21and 3.92 hours per year, respectively.13.FirmsPanel producers, fabricators, and wholesalersthat package or repackage composite wood products or finishedgoods containing composite wood products will need to modify their labels toinclude their name, the date the finished good was produced, and a statement of compliance.Retailers are not required to modify their labeling system to comply with the proposed rule assuming theydo not modify the packaging of the products they purchase.This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricatorsthat are already complying with the CARB ATCM will incur the cost associated with 3 hours of labor for making small changes totheir labels. The remaining fabricators and one percent of wholesalersare assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).1066*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 46 of 118Exhibit 6-13: Incremental Second and Third Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Incremental Burden (Hours)DomesticForeign2TotalDomesticForeignTotal1. Rule FamiliarizationProducers3M--------Fabricators4M--------WholesalersM--------RetailersM--------2. Certification Fee---------3. Initial On-site AuditWith Existing CertificationsM--------Without Existing Certifications3,5M--------4. Develop Quality Control Manual3M--------5. Qualifying Test---------6. Qualifying Test Shipment1 ProductM--------2 Products3,5M--------7. Correlation Test61 ProductM--------2 Products3,5M--------8. Quarterly On-site Audit7Uncertified to Standard3,5M27715443144.004,4322,4646,896ULEF to StandardM1111412534.001321,3681,500NAF (With New Certification)M11211222134.00441328442,5328882,6649. Large Scale Testing Fee---------10. Large Scale Testing Shipment7Uncertified to Standard3,5M27715443140.50554308862ULEF to StandardM1111412530.5017171188NAF (With New Certification)M1121122210.50610611111211. On-site Audit Travel---------12. Desk Audits8Uncertified to Standard3,5M27715443181.002,2161,2323,448ULEF to StandardM1111412581.00889121,000NAF (With New Certification)M---------13. Purchase of Small Chamber Testing Unit9---------14. Quality Control Testing10Standard Certification3,5M2882772681545564312602.00149,760144,040139,36080,080289224,120New NAF CertificationM--------Formatted TableFormatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 47 of 118Exhibit 6-13: Incremental Second and Third Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Incremental Burden (Hours)DomesticForeign2TotalDomesticForeignTotal15. Lost Product---------16. Initial Recordkeeping11C--------17. Recurring Recordkeeping12Producers3,5M3701,1291,499152.0019,24058,70877,948Fabricators with burden- Employers4C2,1768483,0241520.001,131,520440,9601,572,480Fabricators with burden - Nonemployers4C3,0541,1914,24517.2122,0198,58730,606Fabricators without burdenC42,31016,43758,7471----Wholesalers with burden - EmployersC2,6423,6806,3221195.00515,190717,6001,232,790Wholesalers with burden - NonemployersC3,8265,3319,15713.9214,99820,89835,895Wholesalers without burdenC47,26311,94459,2071----RetailersC658,150-658,1501----18. Initial Labeling4,13Minor Changes - Producers4,5T--------Minor Changes - Fabricators4T--------Major Changes - Producers3T--------Major Changes - Fabricators and Wholesalers4T--------Total - Years 2 and 31,860,216854,3471,393,518333,4753,253,732187,821Notes: 1. This column indicates the category of labor associated with the activity. "M", "T", and "C" stand for managerial, technical, and clerical labor, respectively.2. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value ofimports for the affected fabricatorNAICS to the total domestic value ofshipments for these NAICS (which is 39 percent) and 2) applyingit to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typically export composite woodproducts or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis,which assumes that there is uncertified product being imported into theU.S., the analysis estimates the number of certified foreignmills as 20 percent of the total number of certified mills.3. This analysis assumes that two percent of wood veneer laminated product producers (277 domesticentities) will continue to use added formaldehyde resins and therefore their products will be definedas hardwood plywood. A similar proportion of foreign laminatorsexporting to the U.S. are also assumed to continue to use added formaldehyde resins.4. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.5. Since CARB does not certify wood veneer laminated products, allproducers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by a TPCas a result of the TSCA Title VI rule.6. Producers that are already CARB compliantand are not expected adopt a more stringent certification type (e.g.,NAF certification)are not assumed to need to perform correlation testing because it isassumed that their previous testing is sufficient.7. On-site audits must be conducted at least once quarterly, unless the mill obtainsULEF orNAF certification. This analysis assumes that producers with new NAF certifications will incur the burdenassociated with one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existingULEF orNAF certifications under the CARB ATCM will only incur theinitial on-site audit in the first year. All producers withULEF orNAF certification will have one on-site audit annually thereafter.8. Desk audits are assumed to occur monthlyfor standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications willincur the costs associated withtwodesk audits in the first year; none are required in subsequentyears. No desk audits are required for respondents with existingULEF orNAF certification.9. Although mills are likely to incur some labor burden while learning how to use the small chamber testing unit, it is not estimated in this analysis.Formatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 48 of 118Exhibit 6-13: Incremental Second and Third Year Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Incremental Burden (Hours)DomesticForeign2TotalDomesticForeignTotal10. This analysis assumes that composite panel producerswith a standard certificationor a new NAF certificationtest each production line once daily.Composite panel producers need to perform 3months ofroutine small scaleProducers with an existing ULEF or NAF certification will already have been exempted from quality controltestingto become NAF certified.11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fabricators, andwholesalers that import composite wood products. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysisassumes that 28 percent of domestic wholesalers import compositewood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers are notalready complying with the CARB ATCM and will have initial burden to change their recordkeeping systems to comply with the TSCATitle VI rule.12. While recordkeeping is required for all respondents, not all entities will incuradditionalrecordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existingrecordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers willhave recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products andthus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to be generally sufficient to meet theproposed rule’s recordkeeping requirements. For fabricators andwholesalers with burden, the analysis assumes that there is afixed-cost component of the recurring recordkeeping costs associated withtwo hours of labor and a variable cost component that is proportional to a firm’s revenue. The variable cost factor is estimated by subtracting the fixed cost from the total reported cost and then dividingby the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the total reportedcost is $12,916.80, and the average revenue is $4,241,245. For wholesalers,the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variablecost factors are 0.30338 percent and 0.05933 percent of revenue. Therecurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring recordkeeping burden is estimated as thesum of the burden associated with the fixed cost (2 hours) andthe burden associated with the respective variable costs, whichare calculated as 0.30338 percent of average nonemployer fabricator revenues($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542).The resulting average fabricator and wholesaler nonemployer recurring recordkeeping burdens are 7.21 and 3.92hours per year, respectively.13.FirmsPanel producers, fabricators, and wholesalersthat package or repackage composite wood products or finishedgoods containing composite wood products will need to modify their labels toinclude their name, the date the finished good was produced, and a statement of compliance.Retailers are not required to modify their labeling system to comply with the proposed rule assuming they donot modify the packaging of the products they purchase.This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators thatare already complying with the CARB ATCM will incur the cost associated with 3 hours of labor for making small changes to theirlabels. The remaining fabricators and one percent of wholesalers areassumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).1067*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 49 of 118Exhibit 6-14: Three Year Average Incremental Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Incremental Burden (Hours)DomesticForeign2TotalDomesticForeignTotal1. Rule FamiliarizationProducers3M3701,1291,4990.33334.00004931,5051,998Fabricators4M79,70131,083110,7840.33334.0000106,25741,440147,697WholesalersM85,56033,368118,9280.33334.0000114,06944,486158,555RetailersM759,048-759,0480.33334.00001,011,963-1,011,9632. Certification Fee---------3. Initial On-site AuditWith Existing CertificationsM827648460.33334.00001091,0191,128Without Existing Certifications3,5M2883656530.33338.00007689731,7414. Develop Quality Control Manual3M2883656530.333340.00003,8404,8668,7065. Qualifying Test---------6. Qualifying Test Shipment1 ProductM11512964140690.33330.500021211123122 Products3,5M2883656530.66670.250048611097. Correlation Test61 ProductM11512964140693.33331.000037174302134672302 Products3,5M2883656536.66671.00001,9202,4334,3538. Quarterly On-site Audit7Uncertified to Standard3,5M2771544313.66674.00004,0632,2596,321322ULEF to StandardM111141253.00004.00001321,3681,500NAF (With New Certification)M112112221.00002.33334.0000441038441,9698882,0729. Large Scale Testing Fee---------10. Large Scale Testing Shipment8Uncertified to Standard3,5M2771544313.66670.5000508282790ULEF to StandardM111141253.00000.500017171188NAF (With New Certification)M112112221.00000.5000610611111211. On-site Audit Travel---------12. Desk Audits8Uncertified to Standard3,5M2771544318.00001.00002,2161,2323,448ULEF to StandardM111141258.00001.0000889121,000NAF (With New Certification)M112112220.66671.0000714114813. Purchase of Small ChamberTesting Unit9---------14. Quality Control Testing10Formatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 50 of 118Exhibit 6-14: Three Year Average Incremental Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Incremental Burden (Hours)DomesticForeign2TotalDomesticForeignTotalStandard Certification3,5M288277268154556431260.00002.0000149,760144,040139,36080,080289224,120New NAF CertificationM171127621129322221.66672.000073747711,9609,14312,6979,62015. Lost Product---------16. Initial Recordkeeping11C8,57611,94520,5210.333359.1500169,073235,492404,56517. Recurring Recordkeeping12Producers3,5M3701,1291,4991.000052.000019,24058,70877,948Fabricators with burdenEmployers4C2,1768483,0241.0000520.00001,131,520440,9601,572,480Fabricators with burden -Nonemployers4C3,0541,1914,2451.00007.210022,0198,58730,606Fabricators without burdenC42,31016,43758,7471.0000----Wholesalers with burden -EmployersC2,6423,6806,3221.0000195.0000515,190717,6001,232,790Wholesalers with burden -NonemployersC3,8265,3319,1571.00003.920014,99820,89835,895896Wholesalers without burdenC47,26311,94459,2071.0000----RetailersC658,150-658,1501.0000----18. Initial Labeling4,13Minor Changes - Producers4,5C931,0211,1140.33336.00001862,0422,228Minor Changes - Fabricators4T64,29024,98689,2760.33333.000064,28424,98489,267268Major Changes - Producers3C2771083850.3333100.00009,2323,60012,832Major Changes - Fabricators andWholesalers4T16,2666,34422,6100.3333100.0000542,146211,446753,591592Total - Three Year Average3,884,972878,7931,980,186916,5365,865,153795,329Notes: 1. This column indicates the category of labor associatedwith the activity. "M", "T",and "C" stand for managerial, technical, and clerical labor, respectively.2. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value ofimports for the affected fabricatorNAICS to the total domestic value ofshipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typically export composite woodproducts or goods containing composite wood products into the UnitedStates. To remain consistent with the Economic Analysis,which assumes that there is uncertified product being imported into theU.S., the analysis estimates the number of certified foreignmills as 20 percent of the total number of certified mills.3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be definedas hardwood plywood. A similar proportion of foreign laminatorsexporting to the U.S. are also assumed to continue to use added formaldehyde resins.4. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.5. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by aFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 51 of 118Exhibit 6-14: Three Year Average Incremental Burden Hours, by Activity and Geographic LocationActivityLaborType1Number of EntitiesNumber ofActivities PerRespondentBurden PerActivity(Hours)Incremental Burden (Hours)DomesticForeign2TotalDomesticForeignTotalTPC as a result of the TSCA Title VI rule.6. Producers that are already CARB compliantand are not expected adopt a more stringent certification type (e.g., NAF certification)are not assumed to need to perform correlation testing because it isassumed that their previous testing is sufficient.7. On-site audits must be conducted at least once quarterly, unless the mill obtainsULEF orNAF certification. This analysisassumes that producers with new NAFcertifications will incur the burdenassociated with one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existingULEF orNAF certifications under the CARB ATCM will only incur theinitial on-site audit in the first year. All producers withULEF orNAF certification willhave one on-site audit annually thereafter.8. Desk audits are assumed to occur monthlyfor standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated withtwodesk audits in the first year; none are required in subsequentyears. No desk audits are required for respondents with existingULEF orNAF certification.9. Although mills are likely to incur some labor burden while learning how to use the small chamber testing unit, it is not estimated in this analysis.10. This analysis assumes that composite panel producerswith a standard certification or a new NAF certificationtest each production line once daily.Composite panel producers need to perform 3months of routine small scaleProducers with an existing ULEF or NAF certification will already have been exempted from quality controltestingto become NAF certified.11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fabricators,and wholesalers that import composite wood products or articles that contain composite wood products. However, composite panelproducers and fabricators are not expected to need to make any initialchanges to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, itis assumed that 57 percent of wholesalersare not already complying with the CARB ATCMand will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule.12. While recordkeeping is required for all respondents, not all entities will incuradditionalrecordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existingrecordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers willhave recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products andthus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumedto be generally sufficient to meetthe proposed rule’s recordkeeping requirements. For fabricatorsand wholesalers with burden, the analysis assumes that there is a fixed-cost component of the recurring recordkeeping costs associatedwith two hours of labor and a variable cost component that is proportional to a firm’s revenue. The variable cost factor is estimated by subtracting the fixed costfrom the total reported cost and thendividing by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the totalreported cost is $12,916.80, and the average revenue is $4,241,245. Forwholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variable cost factors are 0.30338 percent and 0.05933 percent of revenue.The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. Fornonemployers, the average recurring recordkeeping burden is estimatedas the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs,which are calculated as 0.30338 percent of average nonemployer fabricatorrevenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricatorand wholesaler nonemployer recurring recordkeeping burdens are 7.21and 3.92 hours per year, respectively.13.FirmsPanel producers, fabricators, and wholesalersthat package or repackage composite wood products or finishedgoods containing composite wood products will need to modify their labels toinclude their name, the date the finished good was produced, and a statement of compliance.Retailers are not required to modify their labeling system to comply with the proposed rule assuming theydo not modify the packaging of the products they purchase.This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricatorsthat are already complying with the CARB ATCM will incur the cost associated with 3 hours of labor for making small changes totheir labels. The remaining fabricators and one percent of wholesalersare assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).1068106910701071

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# Page 52 of 118 

# 1072

6(b) Estimating Respondent Costs 1073

1074

Respondent costs are estimated by multiplying burden estimates from the previous 1075

section with loaded wage ra tes, and adding in capital/startup costs and operating and 1076

maintenance (O&M) costs. 1077

1078

(i) Wage Rates 1079

1080

The fully loaded unit labor cost for manage rial, technical, and clerical labor in the 1081

regulated industry and for EPA staff is estimated by adding fringe benefits and overhead costs to 1082

the hourly wage or annual salary for each category following the method described in Wage 1083

Rates for Economic Analysis of th e Toxics Release Inventory Program . This section describes 1084

the method employed to estimate the fully loaded unit labor costs for each labor category and 1085

presents the results of the analysis. 1086

1087

Wage data used to calculate the labor costs are from the May 2009 National Industry1088

Specific Occupational Employment and Wage Estimates estimated as part of the Bureau of 1089

Labor Statistics’(BLS’) Occupational Employment Statistics Program (OES). 21 

# The values were 1090

inflated to 2010 dollars using data from the BLS’ Employer Costs for Employee Compensation 1091

(ECEC) for all private industry for 2009 and 2010. 22 

# Thus, the analysis uses domestic wage rates 1092

to estimate the costs for burden incurred by foreign firms. 1093

1094

The costs of fringe benefits (i.e., paid leave and insurance) were estimated using the same 1095

ECEC data for all private industry in 2010, resulting in a fringe benefit rate of 42 percent. An 1096

additional loading factor of 17 percent is applied to wages to account for overhead. This 1097

overhead loading factor is added to the benefits loading factor, and the total (1.59) is then applied 1098

to the base wage to derive the fully loaded wage. 1099

1100

The derivation of the fully loaded costs for managerial, technical, and clerical labor is 1101

presented in Exhibit 6-15. Note that two types of managerial labor costs are calculated – one for 1102

rule familiarization (a general managerial labor rate for wood product manufacturing NAICS) 1103

and one for testing and certification (a more specific managerial labor rate for composite panel 1104

manufacturing NAICS). 1105

1106

21 

# U.S. Bureau of Labor Statistics (BLS) 2009

22 

# U.S. Bureau of Labor Statistics (BLS) 2011*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 53 of 118Exhibit 6-15: Derivation of Loaded Industry Wage RatesLaborCategoryEntity Type Burden Type Data Source for Wage InformationWage($2010)Fringe andOverhead FactorLoaded Wages($2010)(a) (b) (c) = (a)*(b)ManagerialComposite Panel ProducersRuleFamiliarizationBLSOES, Managerial Occupations, NAICS321000 - Wood Product Manufacturing$46.291.59$73.60FabricatorsWholesalersBLSOES, Managerial Occupations, Sector 42 -Wholesale Trade$58.67 $93.29RetailersBLSOES, Managerial Occupations, 321200 -Veneer, Plywood, and Engineered Wood ProductManufacturing$44.47 $70.71Composite Panel ProducersTesting andCertification,RecordkeepingBLSOES, Managerial Occupations, 321200 -Veneer, Plywood, and Engineered Wood ProductManufacturing$44.88 $71.36Technical Fabricators / Wholesalers LabelingBLSOES, Computer and Mathematical ScienceOccupations, 321200 - Veneer, Plywood, andEngineered Wood Product Manufacturing$27.84 $44.27ClericalComposite Panel ProducersRecordkeepingfor Fabricatorsand Wholesalers/ Labeling forProducersBLSOES, Office and Administrative SupportOccupations, NAICS 321000 - Wood ProductManufacturing$15.62 $24.84FabricatorsWholesalersBLSOES, Office and Administrative SupportOccupations, Sector 42 - Wholesale Trade$16.06 $25.54

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# Page 54 of 118 

# (ii) Costs Per Respondent 1107

1108

This section describes the recordkeeping a nd reporting costs for each respondent activity 1109

as a result of the proposed TSCA Title VI Rule. The total cost is comprised of labor costs, 1110

capital/start-up costs, and operating and mainte nance (O&M) costs. The latter two costs are 1111

classified as non-labor costs in this analysis. Labor costs are presented first since they are based 1112

directly on the labor burden and the loaded wage rates summarized above. Costs are broken out 1113

such that each unique combination of (1) the number of responses per respondent and (2) per1114

response costs is classified as a separate activity. 1115

1116

Labor Costs 1117

1118

Exhibit 6-16 and Exhibit 6-17 summarize the total per-activity recordkeeping and 1119

reporting labor costs for all respondents over the first year, and second and third years of the 1120

rule, respectively. Exhibit 6- 18 presents the average labor costs over the first three years of the 1121

rule, by activity. Exhibit 6- 19 through Exhibit 6-21 present the same information as the previous 1122

three tables, except for the incremental labor costs. These labor costs were estimated by 1123

multiplying the labor burdens summarized in Exhibit 6-9 through Exhibit 6-14 by the loaded 1124

wage rates presented in Exhibit 6-15. As indicat ed, the estimated average annual total labor cost 1125

over the first three years of the rule is approximately $ 312. 2 307 million, while the incremental 1126

labor costs are $ 246.9 242 million. The domestic labor cost accounts for approximately 66.0 67 1127

percent ($205 .9 million) and 71.6 73 percent ($176 .7 million) of these totals, respectively. 1128*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 55 of 118Exhibit 6-16: Total (including baseline) First Year Labor Costs, by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerial1. Rule FamiliarizationProducers1--$108,928--$332,378--$441,306Fabricators1--$23,463,974--$9,150,835--$32,614,810Wholesalers2--$31,927,570--$12,451,603--$44,379,172Retailers3--$214,689,136-----$214,689,1362. Certification Fee---------3. Initial On-site Audit4With Existing Certifications--$23,406--$218,076--$241,482Without Existing Certifications--$164,413--$208,371--$372,7854. Develop Quality Control Manual4--$822,067--$1,041,856--$1,863,9235. Qualifying Test---------6. Qualifying Test Shipment41 Product--$428214--$4,6382,284--$4,9952,4982 Products--$10,347276--$13,059--$23,3357. Correlation Test41 Product--$7,8503,568--$92,05445,670--$99,90449,2382 Products--$411,034--$520,928--$931,9628. Quarterly On-site Audit4Standard--$290,292280,873--$610,556512,936--$900,849793,809NAF (With New Certification)--$4,8523,140--$78,78160,228--$83,63463,368NAF (With Existing Certification)---------9. Large Scale Testing Fee---------10. Large Scale Testing Shipment4Standard/ULEFCertification--$36,322964--$76,35583,277--$112,606120,242NAF (With New Certification)--$642428--$9,8487,564--$10,4907,992NAF (With Existing Certification)---$500---$4,995---$5,49511. On-site Audit Travel4---------12. Desk Audits4Standard Certification--$193,528187,249--$407,037341,957--$600,566529,206NAF (With New Certification)--$2,4261,570--$39,39130,114--$41,81731,68413. Purchase of Small Chamber TestingUnit---------Formatted TableFormatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 56 of 118Exhibit 6-16: Total (including baseline) First Year Labor Costs, by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerial14. Quality Control Testing4Standard Certification--$12,579,341171,162--$26,457,43422,227,213--$39,036,77434,398,374New NAF Certification--$157,706102,045--$2,560,3971,957,405--$2,718,102059,45015. Lost Product---------16. Initial Recordkeeping5$12,955,676--$18,045,210--$31,000,886--17. Recurring RecordkeepingProducers4$1,372,966--$4,189,403--$5,562,369--Fabricators with costs - Employers6$46,887,984--$18,367,690--$65,255,674--Fabricators with costs -Nonemployers6$920,024--$357,646--$1,277,670--Fabricators without costs---------Wholesalers with costs - Employers5$20,957,102--$29,189,538--$50,146,641--Wholesalers with costs -Nonemployers5$610,100--$849,690--$1,459,815--Wholesalers without costs---------Retailers---------18. Initial LabelingMinor Changes - Producers6$13,861--$152,170--$166,031--Minor Changes – Fabricators7-$8,538,355--$3,318,391--$11,856,746-Major Changes – Producers6$688,068--$268,272--$956,340--Major Changes - Fabricators andWholesalers7-$72,009,582--$28,084,888--$100,094,470-Total - Year 1$84,405,781$80,547,937$284,894,191408,517$71,419,619$31,403,279$54,273,59749,210,749$155,825,426$111,951,216$339,167,648333,619,267Notes: 1. The analysis uses a loaded wage rate of$73.60 for rule familiarization for composite panel producers and fabricators.2. The analysis uses a loaded wage rate of$93.29 for rule familiarization for wholesalers.3. The analysis uses a loaded wage rateof $70.71 for rule familiarization for retailers.4. The analysis uses a loaded wage rate of $71.36 for testing and certification and recordkeeping for composite panel producers.5. The analysis uses a loaded wage rate of $25.54 for recordkeeping for wholesalers.6. The analysis uses a loaded wage rate of $24.84 for recordkeeping for fabricators, and labeling for producers.7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers.Formatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 57 of 118Exhibit 6-16:Total(including baseline)Second and Third Year Costs, by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerial1. RuleFamiliarizationProducers1---------Fabricators1---------Wholesalers2---------Retailers3---------2.Certification Fee---------3.Initial On-site Audit4With Existing Certifications---------Without Existing Certifications---------4.Develop Quality Control Manual---------5. Qualifying Test---------6.Qualifying Test Shipment71 Product---------2Products---------7. Correlation Test41 Product---------2Products---------8.Quarterly On-site Audit4Standard Certification--$387,057--$814,075--$1,201,132NAF (With New Certification)--$4,852--$78,781--$83,634NAF (With Existing Certification)--$3,996--$39,962--$43,9589. Large Scale Testing Fee---------10. Large Scale Testing Shipment4Standard Certification--$48,382--$101,759--$150,141NAF (With New Certification)--$642--$9,848--$10,490NAF (With Existing Certification)--$500--$4,995--$5,49511. On-site AuditTravel---------12. Desk Audits4Standard Certification--$193,528--$407,037--$600,566NAF (With New Certification)---------13. Purchase of Small ChamberTesting Unit---------14. Quality Control Testing4*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 58 of 118Exhibit 6-16:Total(including baseline)Second and Third Year Costs, by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerialStandard Certification--$12,579,341--$26,457,434--$39,036,774New NAF Certification---------15. Lost Product---------16. Initial Recordkeeping5---------17. Recurring RecordkeepingProducers4$1,372,966--$4,189,403--$5,562,369Fabricators with costs-Employers6$46,887,984--$18,367,690--$65,255,674--Fabricators with costsNonemployers6$920,024--$357,646--$1,277,670--Fabricators withoutcosts---------Wholesalers with costs-Employers5$20,957,102--$29,189,538--$50,146,641--Wholesalers with costs-Nonemployers5$610,100--$849,690--$1,459,815--Wholesalers without costs---------Retailers---------18. Initial LabelingMinor Changes-Producers6---------Minor Changes–Fabricators7---------Major Changes–Producers6---------Major Changes-Fabricators andWholesalers7---------Total-Years 2 and 3$70,748,176-$13,218,298$52,953,967-$27,913,891$123,702,169-$41,132,190Notes: 1. The analysis uses a loaded wage rate of $73.60 for rule familiarization for composite panel producers and fabricators.2. The analysis uses a loaded wage rate of$93.29 for rule familiarization for wholesalers.3. The analysis uses a loaded wage rateof $70.71 for rule familiarization for retailers.4. The analysis uses a loaded wage rate of $71.36 for testing and certification and recordkeeping for composite panel producers.5. The analysis uses a loaded wage rate of $25.54 for recordkeeping for wholesalers.6. The analysis uses a loaded wage rate of $24.84 forrecordkeeping for fabricators, and labeling for producers.7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 59 of 118Exhibit 6-17:Three Year Average Labor CostsTotal(including baseline),) Second and Third Year Costs,by Activity and GeographicLocation ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerial1. Rule FamiliarizationProducers1--$36,285---$110,768---$147,053-Fabricators1--$7,820,515---$3,049,984---$10,870,499-Wholesalers2--$10,641,497---$4,150,099---$14,791,596-Retailers3--$71,555,904------$71,555,904-2. Certification Fee---------3. Initial On-site Audit4With Existing Certifications--$7,778---$72,716---$80,494-Without Existing Certifications--$54,804---$69,433---$124,238-4. Develop Quality ControlManual4Manual--$274,022---$347,238---$621,260-5. Qualifying Test---------6. Qualifying TestShipment4Shipment71 Product--$143---$1,499---$1,641-2 Products--$3,425---$4,353---$7,778-7. Correlation Test41 Product--$2,640---$30,685---$33,325-2 Products--$137,011---$173,619---$310,630-8. Quarterly On-site Audit4Standard Certification--$354,802374,497--$746,212683,914--$1,101,013058,412NAF (With New Certification)--$4,8523,140--$78,78160,228--$83,63463,368NAF (With ExistingCertification)--$2,640--$26,617--$29,3299. Large Scale Testing Fee---------10. Large Scale Testing Shipment4Formatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 60 of 118Exhibit 6-17:Three Year Average Labor CostsTotal(including baseline),) Second and Third Year Costs,by Activity and GeographicLocation ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerialStandard/ULEFCertification--$44,38649,238--$93,268111,036--$137,653160,275NAF (With New Certification)--$642428--$9,8487,564--$10,4907,992NAF (With ExistingCertification)--$357500--$3,3544,995--$3,6395,49511. On-site Audit Travel---------12. Desk Audits4Standard Certification--$193,528187,249--$407,037341,957--$600,566529,206NAF (With New Certification)--$785---$13,130---$13,915-13. Purchase of Small ChamberTesting Unit---------14. Quality Control Testing4Standard Certification--$12,579,341171,162--$26,457,43422,227,213--$39,036,77434,398,374New NAF Certification--$52,592---$853,466---$906,058-15. Lost Product---------16. Initial Recordkeeping5$4,318,124---$6,014,466---$10,332,590---17. Recurring RecordkeepingProducers4$1,372,966--$4,189,403--$5,562,369Fabricators with costs -Employers6$46,887,984--$18,367,690--$65,255,674--Fabricators with costsNonemployers6$920,024--$357,646--$1,277,670--Fabricators without costs---------Wholesalers with costs -Employers5$20,957,102--$29,189,538--$50,146,641--Wholesalers with costs -Nonemployers5$610,100--$849,690--$1,459,815--Wholesalers without costs---------Formatted TableInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 61 of 118Exhibit 6-17:Three Year Average Labor CostsTotal(including baseline),) Second and Third Year Costs,by Activity and GeographicLocation ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerialRetailers---------18. Initial LabelingMinor Changes - Producers6---------Minor Changes – Fabricators7---------Major Changes – Producers6---------Major Changes - Fabricatorsand Wholesalers7---------Total - Years 2 and 3$70,748,176-$12,786,214$52,953,967-$23,436,907$123,702,169-$36,223,122Notes: 1. The analysis uses a loaded wage rate of $73.60 for rule familiarization for composite panel producers and fabricators.2. The analysis uses a loaded wage rate of$93.29 for rule familiarization for wholesalers.3. The analysis uses a loaded wage rateof $70.71 for rule familiarization for retailers.4. The analysis uses a loaded wage rate of $71.36 for testingand certification and recordkeeping for composite panel producers.5. The analysis uses a loaded wage rate of $25.54 for recordkeeping for wholesalers.6. The analysis uses a loaded wage rate of $24.84 for recordkeeping for fabricators, and labeling for producers.7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers.Formatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 62 of 118Exhibit 6-18: Three Year Average Labor Costs (including baseline), by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerial1. Rule FamiliarizationProducers1--$36,309--$110,793--$147,102Fabricators1--$7,821,325--$3,050,278--$10,871,603Wholesalers2--$10,642,523--$4,150,534--$14,793,057Retailers3--$71,563,045-----$71,563,0452. Certification Fee---------3. Initial On-site Audit4With Existing Certifications--$7,802--$72,692--$80,494Without ExistingCertifications--$54,804--$69,457--$124,2624. Develop Quality ControlManual4--$274,022--$347,285--$621,3085. Qualifying Test---------6. Qualifying Test Shipment41 Product--$71--$761--$8332 Products--$3,425--$4,353--$7,7787. Correlation Test41 Product--$1,189--$15,223--$16,4132 Products--$137,011--$173,643--$310,6548. Quarterly On-site Audit4Standard Certification--$343,289--$626,921--$970,211NAF (With NewCertification)--$3,140--$60,228--$63,3689. Large Scale Testing Fee---------10. Large Scale Testing Shipment4Standard/ULEFCertification--$45,147--$101,783--$146,931NAF (With NewCertification)--$428--$7,564--$7,992NAF (With ExistingCertification)--$500--$4,995--$5,49511. On-site Audit Travel---------12. Desk Audits4Standard Certification--$187,249--$341,957--$529,206NAF (With NewCertification)--$523--$10,038--$10,561*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 63 of 118Exhibit 6-18: Three Year Average Labor Costs (including baseline), by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerial13. Purchase of SmallChamber Testing Unit---------14. Quality Control Testing4Standard Certification--$12,171,162--$22,227,213--$34,398,374New NAF Certification--$34,015--$652,468--$686,48315. Lost Product---------16. Initial Recordkeeping5$4,318,559--$6,015,070--$10,333,629--17. Recurring RecordkeepingProducers4$1,372,966--$4,189,403--$5,562,369--Fabricators with costs -Employers6$46,887,984--$18,367,690--$65,255,674--Fabricators with costs -Nonemployers6$920,024--$357,646--$1,277,670--Fabricators without costs---------Wholesalers with costs -Employers5$20,957,102--$29,189,538--$50,146,641--Wholesalers with costs -Nonemployers5$610,100--$849,690--$1,459,815--Wholesalers without costs---------Retailers---------18. Initial LabelingMinor Changes – Producers6$4,620--$50,723--$55,344--Minor Changes –Fabricators7-$2,845,853846,118--$1,106,042130--$3,951,850952,249-Major Changes – Producers6$229,323356--$89,424--$318,747780--Major Changes - Fabricatorsand Wholesalers7-$24,000,803003,194--$9,360,714361,629--$33,361,474364,823-Total - Three Year Average$75,300,243711$26,846,656849,312$103,767,949326,979$59,108,580109,184$10,466,756467,759$36,699,54132,028,186$134,408,850409,922$37,313,324317,072$140,467,489135,355,170Notes: 1. The analysis uses a loaded wage rate of $73.60 for rule familiarization for composite panel producers and fabricators.2. The analysis uses a loaded wage rate of$93.29 for rule familiarization for wholesalers.3. The analysis uses a loaded wage rateof $70.71 for rule familiarization for retailers.4. The analysis uses a loaded wage rate of $71.36 for testingand certification and recordkeeping for composite panel producers.5. The analysis uses a loaded wage rate of $25.54 for recordkeeping for wholesalers.6. The analysis uses a loaded wage rate of $24.84 for recordkeeping for fabricators, and labeling for producers.Formatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 64 of 118Exhibit 6-18: Three Year Average Labor Costs (including baseline), by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerial7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers.Exhibit 6-18:Incremental First Year Labor Costs, by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerial1. RuleFamiliarizationProducers1--$108,928--$332,378--$441,306Fabricators1--$23,463,974--$9,150,835--$32,614,810Wholesalers2--$31,927,570--$12,451,603--$44,379,172Retailers3--$214,689,136-----$214,689,1362. Certification Fee---------3. Initial On-site Audit4With Existing Certifications--$23,406--$218,076--$241,482Without ExistingCertifications--$164,413--$208,371--$372,7854. Develop Quality ControlManual4--$822,067--$1,041,856--$1,863,9235. Qualifying Test---------6. Qualifying Test Shipment41 Product--$428--$4,638--$4,995*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 65 of 118Exhibit 6-19: Incremental First Year Labor Costs, byActivity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerial1. Rule FamiliarizationProducers1--$108,928--$332,378--$441,306Fabricators1--$23,463,974--$9,150,835--$32,614,810Wholesalers2--$31,927,570--$12,451,603--$44,379,172Retailers3--$214,689,136-----$214,689,1362. Certification Fee---------3. Initial On-site Audit4With Existing Certifications--$23,406--$218,076--$241,482Without ExistingCertifications--$164,413--$208,371--$372,7854. Develop Quality ControlManual4--$822,067--$1,041,856--$1,863,9235. Qualifying Test---------6. Qualifying Test Shipment41 Product--$214--$2,284--$2,4982 Products--$10,276--$13,059--$23,3357. Correlation Test41 Product--$7,8503,568--$92,05445,670--$99,90449,2382 Products--$411,034--$520,928--$931,9628. Quarterly On-site Audit4Uncertified to Standard--$237,201--$131,873--$369,074ULEF to Standard--$9,420--$97,620--$107,040NAF (With NewCertification)--$3,140--$60,228--$63,3689. Large Scale Testing Fee---------10. Large Scale Testing Shipment4Uncertified to Standard--$29,686--$16,484--$46,170ULEF to Standard--$1,213--$12,203--$13,416NAF (With NewCertification)--$428--$7,564--$7,92199211. On-site Audit Travel---------12. Desk Audits4Uncertified to Standard--$158,134--$87,916--$246,049Formatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 66 of 118Exhibit 6-19: Incremental First Year Labor Costs, byActivity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerialULEF to Standard--$6,280--$65,080--$71,360NAF (With NewCertification)--$1,570--$30,114--$31,68413. Purchase of Small ChamberTesting Unit---------14. Quality Control Testing4Standard Certification--$10,686,874278,694--$9,944,7305,714,509--$20,631,60315,993,203New NAF Certification--$157,706102,045--$2,560,3971,957,405--$2,718,102059,45015. Lost Product---------16. Initial Recordkeeping5$12,955,676--$18,045,210--$31,000,886--17. Recurring RecordkeepingProducers4$1,372,966--$4,189,403--$5,562,369--Fabricators with costs -Employers6$28,106,957--$10,953,446--$39,060,403--Fabricators with costs -Nonemployers6$546,952--$213,301--$760,253--Fabricators without costs---------Wholesalers with costs -Employers5$13,157,953--$18,327,504--$31,485,457--Wholesalers with costs -Nonemployers5$383,049--$533,735--$916,758--Wholesalers without costs---------Retailers---------18. Initial LabelingMinor Changes - Producers6$13,861--$152,170--$166,031--Minor Changes –Fabricators7-$8,538,355--$3,318,391--$11,856,746-Major Changes – Producers6$688,068--$268,272--$956,340--Major Changes - Fabricatorsand Wholesalers7-$72,009,582--$28,084,888--$100,094,470-Total - Year 1$57,225,482$80,547,937$282,920,734435,484$52,683,041$31,403,279$37,048,00731,991,153$109,908,497$111,951,216$319,968,597314,426,637Formatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 67 of 118Exhibit 6-19: Incremental First Year Labor Costs, byActivity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerialNotes: 1. The analysis uses a loaded wage rate of $73.60 forrule familiarization for composite panel producers and fabricators.2. The analysis uses a loaded wage rate of $93.29 for rule familiarization for wholesalers.3. The analysis uses a loaded wage rate of $70.71 for rule familiarization for retailers.4. The analysis uses a loaded wage rate of $71.36 for testing and certification and recordkeeping for composite panel producers.5. The analysis uses a loaded wage rate of $25.54 for recordkeeping for wholesalers.6. The analysis uses a loaded wage rate of $24.84 forrecordkeeping for fabricators and labeling for producers.7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 68 of 118Exhibit 6-20: Incremental Second and Third Year LaborCosts, by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerial1. Rule FamiliarizationProducers1---------Fabricators1---------Wholesalers2---------Retailers3---------2. Certification Fee---------3. Initial On-site Audit4With ExistingCertifications---------Without ExistingCertifications---------4. Develop Quality ControlManual4---------5. Qualifying Test---------6. Qualifying Test Shipment41 Product---------2 Products---------7. Correlation Test41 Product---------2 Products---------8. Quarterly On-site Audit4Uncertified to Standard--$316,268--$175,831--$492,099ULEF to Standard--$9,420--$97,620--$107,040NAF (With NewCertification)--$3,1409,420--$60,228180,684--$63,368190,1039. Large Scale Testing Fee---------10. Large Scale Testing Shipment4Uncertified to Standard--$39,533--$21,979--$61,512ULEF to Standard--$1,213--$12,203--$13,416NAF (With NewCertification)--$428--$7,564--$7,92199211. On-site Audit Travel---------12. Desk Audits4Uncertified to Standard--$158,134--$87,916--$246,049ULEF to Standard--$6,280--$65,080--$71,360NAF (With NewCertification)---$6,280---$65,080---$71,36013. Purchase of SmallChamber Testing Unit---------14. Quality Control Testing4Formatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 69 of 118Exhibit 6-20: Incremental Second and Third Year LaborCosts, by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerialStandard Certification--$10,686,874278,694--$9,944,7305,714,509--$20,631,60315,993,203New NAF Certification---------15. Lost Product---------16. Initial Recordkeeping5---------17. Recurring RecordkeepingProducers4$1,372,966--$4,189,403--$5,562,369--Fabricators with costs -Employers6$28,106,957--$10,953,446--$39,060,403--Fabricators with costs -Nonemployers6$546,952--$213,301--$760,253--Fabricators without costs---------Wholesalers with costs -Employers5$13,157,953--$18,327,504--$31,485,457--Wholesalers with costs -Nonemployers5$383,049--$533,735--$916,758--Wholesalers without costs---------Retailers---------18. Initial LabelingMinor Changes -Producers6---------Minor Changes -Fabricators7---------Major Changes -Producers6---------Major Changes -Fabricators andWholesalers7---------Total - Years 2 and 3$43,567,877-$11,221,29010,802,477$34,217,389-$10,473,1516,188,483$77,785,240-$21,694,36816,990,958Notes: 1. The analysis uses a loaded wage rate of $73.60 for rule familiarization for composite panel producers and fabricators.2. The analysis uses a loaded wage rate of$93.29 for rule familiarization for wholesalers.3. The analysis uses a loaded wage rateof $70.71 for rule familiarization for retailers.4. The analysis uses a loaded wage rate of $71.36 for testingand certification and recordkeeping for composite panel producers.5. The analysis uses a loaded wage rate of $25.54 for recordkeeping for wholesalers.6. The analysis uses a loaded wage rate of $24.84 forrecordkeeping for fabricators and labeling for producers.7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers.Formatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 70 of 118*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 71 of 118Exhibit 6-21: Three Year Average Incremental Labor Costs, by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerial1. Rule FamiliarizationProducers1--$36,285309--$110,768793--$147,053102Fabricators1--$7,820,515821,325--$3,049,984050,278--$10,870,499871,603Wholesalers2--$10,641,497642,523--$4,150,099534--$14,791,596793,057Retailers3--$71,555,904563,045-----$71,555,904563,0452. Certification Fee---------3. Initial On-site Audit4With ExistingCertifications--$7,778802--$72,716692--$80,494Without ExistingCertifications--$54,804--$69,433457--$124,2382624. Develop QualityControl Manual4--$274,022--$347,238285--$621,2603085. Qualifying Test---------6. Qualifying Test Shipment41-Product byTPC--$14371--$1,499761--$1,6418332-Product byTPC--$3,425--$4,353--$7,7787. Correlation Test41-Product byTPC--$2,6401,189--$30,68515,223--$33,32516,4132-Product byTPC--$137,011--$173,619643--$310,6306548. Quarterly On-site Audit4Uncertified toStandard--$289,936912--$161,202178--$451,067091ULEF toStandard--$9,420--$97,620--$107,040NAF (With NewCertification)--$3,1407,327--$60,228140,532--$63,368147,8589. Large ScaleTesting Fee---------10. Large Scale Testing Shipment4Formatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 72 of 118Exhibit 6-21: Three Year Average Incremental Labor Costs, by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerialUncertified toStandard--$36,251--$20,124147--$56,374398ULEF toStandard--$1,213--$12,203--$13,416NAF (With NewCertification)--$428--$7,564--$7,92199211. On-site AuditTravel---------12. Desk Audits4Uncertified toStandard--$158,134--$87,916--$246,049ULEF toStandard--$6,280--$65,080--$71,360NAF (With NewCertification)--$500523--$10,062038--$10,56113. Purchase ofSmall ChamberTesting Unit---------14. Quality Control Testing4StandardCertification--$10,686,874278,694--$9,944,7305,714,509--$20,631,60315,993,203New NAFCertification--$52,59234,015--$853,466652,468--$906,058686,48315. Lost Product---------16. InitialRecordkeeping5$4,318,124559--$6,014,466015,070--$10,332,590333,629--17. Recurring RecordkeepingProducers4$1,372,966--$4,189,403--$5,562,369--Fabricators withcosts -Employers6$28,106,957--$10,953,446--$39,060,403--Fabricators withcosts -Nonemployers6$546,952--$213,301--$760,253--Fabricatorswithout costs---------Wholesalerswith costs -Employers5$13,157,953--$18,327,504--$31,485,457--Formatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 73 of 118Exhibit 6-21: Three Year Average Incremental Labor Costs, by Activity and Geographic Location ($2010)ActivityDomesticForeignTotalClericalTechnicalManagerialClericalTechnicalManagerialClericalTechnicalManagerialWholesalerswith costs -Nonemployers5$383,049--$533,735--$916,758--Wholesalerswithout costs---------Retailers---------18. Initial LabelingMinor Changes– Producers6$4,620--$50,723--$55,344-Minor Changes– Fabricators7-$2,845,853846,118--$1,106,042130--$3,951,850952,249-Major Changes -Producers6$229,323356--$89,424--$318,747780--Major Changes -Fabricators andWholesalers7-$24,000,803003,194--$9,360,714361,629--$33,361,474364,823-Total - ThreeYear Average$48,119,944120,412$26,846,656849,312$101,778,792346,810$40,372,002606$10,466,756467,759$19,330,58914,789,371$88,491,921492,993$37,313,324317,072$121,109,235116,136,184Notes: 1. The analysis uses a loaded wage rate of $73.60 for rule familiarization for composite panel producers and fabricators.2. The analysis uses a loaded wage rate of$93.29 for rule familiarization for wholesalers.3. The analysis uses a loaded wage rate of $70.71 for rule familiarization for retailers.4. The analysis uses a loaded wage rate of $71.36 for testingand certification and recordkeeping for composite panel producers.5. The analysis uses a loaded wage rate of $25.54 for recordkeeping for wholesalers.6. The analysis uses a loaded wage rate of $24.84 forrecordkeeping for fabricators and labeling for producers.7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers.Formatted TableFormatted Table

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# Page 74 of 118 

# Non-Labor Costs 1129

1130

This subsection presents the non-labor costs associated with the recordkeeping and 1131

reporting requirements of the proposed TSCA Title VI rule. The different categories of 1132

respondents (composite panel producers, fabricators, wholesalers, and retailers) are presented 1133

separately because they engage indifferent activities. There are no activities that are common to 1134

all respondents. Exhibit 6-23 through Exhibit 6- 25 summarizes the number of respondents, per1135

respondent and total non-labor costs for each response activity over the next three years. Exhibit 1136

6-26 through Exhibit 6-28 present the corresponding incremental costs. 1137

1138

(A). Composite Panel Producers 1139

1140

Composite panel producers will incur non-la bor costs from testing and certification 1141

activities. As stated above, this an alysis assumes that product lines that have a standard 1142

certification or a NAF certification are certified under the CARB ATCM will not have to submit 1143

new data or resubmit existing data to their TPC in order to receive the equivalent certification 1144

under the TSCA Title VI regulations. In additi on, this analysis assumes that two percent of 1145

wood veneer laminated product producers will continue to use added formaldehyde resins and 1146

thus be classified as hardwood plywood produ cers. These entities are no t certified by CARB and 1147

so will incur the burdens as sociated with first time certification by a TPC. 1148

1149

Certification Fees (Activity #2) 1150

1151

CPA and HPVA charge administrative fees to mills for certifying their products. CPA 1152

charges a quarterly fee of $1,500 regardless of NAF or ULEF status, which is equivalent to 1153

$6,000 per year. HPVA charges an annual program fee of $4,500 to $5,500 (depending on 1154

membership status) to mills that are not NAF or ULEF certified. Mills with ULEF or NAF 1155

certifications are required to pay the standard annual program fee in the first year and an annual 1156

fee of $2,700 to $3,700 in all subsequent years. This analysis assumes that the annual 1157

certification fee for mills with standard certific ation is $6,000, the fees for uncertified or 1158

standard-certified mills with new NAF certifications are $6,000 in the first year and $3,700 in all 1159

subsequent years, and the annual certification fee for mills with a current NAF or ULEF 1160

certification is $3,700.

, 23 

# 1161

1162

Exhibit 6-22: Certification Fees

Cost Category Certification Type Fee

Initial Fee All $6,000

Annual Fee Standard $6,000

NAF/ULEF $3,700



# 1163

Qualifying Test (Activity #5) 1164

1165

Under TSCA Title VI, a composite panel produ cer is required to obtain five qualifying 1166

tests for each product type (e.g., hardwood plywood – veneer core) and production line from the 1167

23 

# ULEF and NAF certifications apply to product lines, and not necessarily to the entire facility. Mills with multiple product

lines could have one or more lines certified as ULEF or NAF a nd other lines that are not. The ULEF and NAF testing costs do

not apply to any product lines that are not ULEF or NAF certified.

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# Page 75 of 118 

# mill for which certification is sought. This ICR as sumes that all qualifying testing is performed 1168

using the primary test method, large chamber test , as defined by ASTM International Standard 1169

E1333. This ICR assumes a cost of $480 per large scale test based on HPVA’s 2010 fee. 24 

# This 1170

analysis assumes that mills making product line s that have a standard certification or a NAF 1171

certification under the CARB ATCM will not need to submit new data or resubmit existing data 1172

to their existing TPC in order to receive the equivalent certification under the TSCA Title VI 1173

regulations. Thus, producers that are already CARB compliant and are not expected to adopt a 1174

more stringent certification type (e.g., NAF certification) will not incur this burden. 1175

1176

Qualifying Test Shipping (Activity #6) 1177

1178

Mills are expected to ship at least five 4’ x 8’ panels for each product type via a 1179

commercial shipping carrier. Panels must be dead-stacked (i.e., having no layers between 1180

panels), bundled air-tight, wrapped in polyethylene, and protected by cover sheets. Based on 1181

conversations with CPA and with CARB-certified mills , the total shipping co st for the qualifying 1182

tests is estimated to be approximately $200 per pr oduct line. This analysis assumes that mills 1183

making product lines that have a standard certification or a NAF certification are certified under 1184

the CARB ATCM will not need to submit new data or resubmit existing data to their existing 1185

TPC in order to receive the equivalent certifica tion under the TSCA Title VI regulations. Thus, 1186

producers that are already CARB compliant and ar e not expected to adopt a more stringent 1187

certification type will not incur this burden. 1188

1189

Quarterly On-site Audit (Activity #8) 1190

1191

The TPC is responsible for conducting on-site vi sits to certified mills. Before the initial 1192

certification, the TPC is expected to make at least one trip to the mill to inspect the mill’s quality 1193

control systems and employees. During the initia l visit, the TPC will assist the mill in setting up 1194

quality control systems, including the small scale testing facility, if applicable, and methods for 1195

selecting samples. After certification has been granted, the TPC is obligated to perform an on1196

site audit at least once quarterly, unless the mill obtains a ULEF or NAF certification. Audits 1197

typically do not take more than one day of travel and visitation, though if the mill requires a 1198

substantial number of modifications or is unprepared, the duration of the visit may be longer. 25 

# 1199

1200

The cost of the audit is borne by the composite panel producer and has two components: 1201

audit fees and travel costs. Site audit fees can range from $300 to $450 for initial visits and from 1202

$400 to $450 for quarterly visits, depending on the TPC. Based on these ranges, this analysis 1203

assumes that will mills will pay a fee of $450 per visit. 1204

1205

As in the burden section, this analysis assumes that producers with new NAF 1206

certifications will incur the costs associated with on e on-site audit (in addition to the initial audit) 1207

and two desk audits in the first year. The initia l on-site audit is assumed to be sufficient for 1208

producers with existing ULEF or NAF certifications. All ULEF and NAF-certified producers 1209

will have one on-site audit annually thereafter. 1210

24 

# This is the rate charged by HPVA’s Reston Lab to non-memb ers for testing panels. This lab charges non-members $660 to

test doors, $840 to test finished engineered wood flooring, and $480 to test furniture and cabinets.

25 

# Personal Communication with HPVA 2011

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# Page 76 of 118 

# 1211

Large Scale Testing Fees (Activity #9) 1212

1213

As described above, it is assumed that each large scale test costs $480. Mills are 1214

required assumed to perform large scale testing quarterly unless all products are certified as NAF. 1215

It is assumed that mills with only NAF-certified products will perform large scale testing 1216

annually. In the first year, mills with added-fo rmaldehyde products will test those products three 1217

times in addition to the qualifying testing, and mills with NAF products will test those once at 1218

the end of the qualifying process. Note that some respondents are assumed to have both different 1219

certifications for different product lines (i.e., combinations of standard , ULEF and NAF 1220

certifications

. ). 1221

1222

Large Scale Testing Shipping (Activity #10) 1223

1224

Mills are expected to ship one 4’ x 8’ panel for each product type via a commercial 1225

shipping carrier. Panels must be dead-stacked (i.e., having no layers between panels), bundled 1226

air-tight, wrapped in polyethylene, and protected by cover sheets. Based on conversations with 1227

CPA and with CARB-certified mills, the total shippi ng cost for the quarterly tests is estimated to 1228

be approximately $50 per product line. Note that some respondents are assumed to have 1229

both different certifications for different product lines (i.e., combinations of standard , ULEF and 1230

NAF certifications

. ). 1231

1232

On-site Audit Travel (Activity #11) 1233

1234

Travel costs can vary depending on the relative location of the mill to the TPC; mills 1235

within a close proximity may not incur any travel costs, whereas a mill across the country may 1236

incur travel costs of up to $2,000 per visit. It is assumed that travel is only necessary for the 1237

annual audits, as other intermediate audits can be performed by contracting inspectors closer to 1238

the mill. Therefore, this analysis assumes that each annual audit costs $1,500 in travel costs. All 1239

composite panel producers are assumed to incur this cost. 1240

1241

Desk Audits (Activity #12) 1242

1243

TPCs may conduct periodic “desk audits,” which are quality control checks performed 1244

over the phone in which the mill’s small scale testing procedures and data are reviewed. Desk 1245

audits are assumed to occur monthly, except in months with quarterly on-site audits. Based on 1246

fees charged by CPA and HPVA, it is assumed that each desk audit costs $250. 1247

1248

As in the burden section, this analysis assumes that producers with new NAF 1249

certifications will incur the costs associated with two desk audits in the first year; none are 1250

performed in subsequent years. No additional desk audits are assumed to be performed as a 1251

result of this rule for re spondents with existing NAF or ULEF certification. 1252

1253

Small Chamber Testing Unit (Activity #13) 1254

1255

This analysis assumes that all panel manufacturers that are required to perform routine 1256

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# Page 77 of 118 

# quality control testing will use their own small chamber testing unit rather than have the TPC 1257

perform the testing. It is assumed that the unit costs $10,000 to purchase. 1258

1259

Quality Control Testing (Activities #14) 1260

1261

To maintain certification, a mill must perform small scale quality control testing for each 1262

certified product type and production line. Mills have the option of constructing an on-site lab 1263

and having it approved by a TPC, or contracting a certified third-party lab to perform small scale 1264

quality control testing. According to CPA and HPVA, particleboard and MDF mills already 1265

have their own on-site labs to test for formaldehyde (because they have to test their products on a 1266

daily basis under the CARB ATCM), while most smaller hardwood plywood mills pay their TPC 1267

to conduct their quality control testing. (In part because hardwood plywood mills often use 1268

ULEF or NAF resins to qualify for exemptions from some of the on-going testing requirements 1269

under the CARB ATCM.) However, the CARB ATCM allows mills to ship panels from 1270

certified product lines before test results are available. By contrast, the proposed TSCA rule 1271

requires mills to wait until test results indicate th at the emissions standard s have been met before 1272

shipping a lot that has been tested. It is uncerta in how often mills currently ship product from a 1273

lot being tested before the test results are available and therefore it is uncertain how mills will 1274

choose to comply with this requirement. It ma y be the case that some mills normally maintain a 1275

level of inventory where they would typically not ship any panels before test results have been 1276

determined for that lot, but other mills may ship out panels on the same day they are produced. 1277

This analysis assumes that all mills that do not already do so will opt to set up and operate a 1278

quality control testing facility on -site, in order to minimize the time spent waiting for test results, 1279

and to maximize their flexibility to ship out pa nels shortly after they have been produced. 1280

(Assuming that mills conduct on-site testing may ove rstate the costs of this requirement if some 1281

mills find it more cost effective to hold products in inventory until test results have been 1282

determined by an outside lab. Producers that are already CARB compliant and are not expected 1283

to adopt a more stringent certif ication type will not need to perform correlation testing. 1284

1285

HPVA typically uses a desiccator test for smal l scale testing, but small chamber tests may 1286

also be performed. Each instance of desiccator testing requires three small samples to be cut 1287

from a larger panel and tested. It is assumed th at mills will incur fees of $70 per desiccator test 1288

and $405 per small chamber test. The mean cost, weighted by the number of tests needed (three 1289

for desiccator testing), is $154. 1290

1291

Lost Product (Activity #15) 1292

1293

Mills will need to forfeit a number of panels for initial and on-going testing. Mills are 1294

expected to ship five 4’ x 8’ panels per product type for qualifying testing. Producers will lose 1295

one panel per product type for each day for that quality control testing

. is performed. In addition 1296

to routine small scale testing, standard certification and ULEF mills are required assumed to send 1297

one panel per product type to the TPC for large scale testing each quarter. However, product 1298

lines that are certified as NAF are exempt from routine quality control testing after the three 1299

month qualifying period, and need only have large scale testing performed annually. Note that 1300

the total respondents with lost product costs presented in the exhibits below sum to more than the 1301

total number of respondents because some respondents are assumed to have both different 1302

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# Page 78 of 118 

# certifications for different product lines (i.e., combinations of standard , ULEF and NAF 1303

certifications

. ). 1304

1305

This analysis estimated the cost of each panel using the average cost per square foot of 1306

hardwood plywood, $0.49 and particleboard, $0.28 (RISI 2010). Assuming a panel size of 32 sq. 1307

ft., each hardwood plywood panel will cost th e mill $15.68, and each particleboard panel will 1308

cost $8.96. 1309

1310

(B). Fabricators 1311

1312

Fabricators are subject to the proposed rule’s recordkeeping and labeling requirements. 1313

However, not all fabricators incur the non-labor co sts associated with proposed rule because 1) 1314

they may already complying with the CARB ATCM (Exhibit 6-6) or 2) their existing systems 1315

are sufficient to meet the requirements. As stated above, this analysis assumes that 98 percent of 1316

wood veneer laminated product producers will likely switch to NAF resins and be classified as 1317

fabricators. It is assumed that the entirety of this subset of fabricators will incur the non-labor 1318

costs associated with supplier notification. 1319

1320

As described in the Economic Analysis for the rulemaking, one respondent to the 1321

fabricator questionnaire reported that that they would incur a one-time cost of $250 for 1322

purchasing new stamps for labeling. To remain c onsistent with the labor section, this cost was 1323

averaged across the two firms that reported more significant costs. As a result, this analysis 1324

assumes that the 33 percent of fabricators that are not CARB compliant in the baseline will incur 1325

an initial non-labor cost of approximately $125.00 ($250/2) associated with the labeling 1326

requirements. There are not expected to be an y non-labor costs associated with recordkeeping 1327

for fabricators. 1328

1329

(C). Wholesalers 1330

1331

Wholesalers are subject to the proposed rule’s recordkeeping and labeling requirements. 1332

This analysis assumes that 1 percent of wholes alers will repackage their products and so will 1333

incur an initial non-labor labeling cost. It is assumed that these wholesalers incur the same costs 1334

as the fabricators described above (an average of $125.00). In addition, not all wholesalers will 1335

incur the non-labor costs associated with recordkeeping because 1) they are already complying 1336

with the CARB ATCM (Exhibit 6-7), 2) their ex isting systems are sufficient to meet the 1337

requirements, or 3) they do not import composite wood products or articles that contain 1338

composite wood products and so are only required to keep ordinary business records. 1339

1340

As described in the Economic Analysis for the rulemaking, only one respondent to the 1341

wholesaler questionnaire reported that they in curred non-labor costs (a one-time cost of $2,000 1342

for programming changes). The average non-labor cost is calculated for firms reporting 1343

quantified costs. As a result, this analysis assumes that the 57 percent of wholesalers that import 1344

composite wood products and/or articles that contain composite wood products will incur an 1345

initial non-labor cost of approximately $1,000 ($ 2,000/2) associated w ith the recordkeeping 1346

requirements (since one of two firms reporting co sts reported a non-labor cost of $2,000). As 1347

indicated above, this analysis assumes that 28 pe rcent of domestic wholesalers import composite 1348

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# Page 79 of 118 

# wood products and/or articles that contain composite wood products. There are not expected to 1349

be any non-labor costs associated wi th recurring recordkeeping costs. 1350

1351

(D). Retailers 1352

1353

As stated above, retailer’s customary business practices are assumed to be generally 1354

sufficient to meet the proposed rule’s recordkeeping requirements. 26 

# In addition, retailers are 1355

assumed not to repackage goods made with composite wood products, and thus do not incur 1356

costs to m odify labeling systems to comply with the proposed rule. 1357

1358

(E). Summary 1359

1360

Exhibit 6-23 and Exhibit 6-24 summarize the total (including baseline) per-activity non1361

labor costs for all the respondents over the first year, and second and third years of the rule, 1362

respectively. Exhibit 6-25 presents the average non-labor costs over the first three years of the 1363

rule, respectively. Exhibit 6-26 through Exhibit 6-28 mirror the previous three tables, except that 1364

they account for incremental non-labor costs (excluding baseline non-labor costs). Note that the 1365

number of respondents cannot be summed across activities because many respondents are 1366

incurring multiple burdens. As indicated, th e average total annual non-labor cost (including 1367

baseline) over the first three years of the rule is estimated at approximately $ 37.3 35 million, 1368

while the incremental non-labor costs are $ 25.6 24 million. The domestic non-labor costs 1369

account for approximately 34.5 36 percent ($ 12.9 13 million) and 46.3 49 percent ($ 11.9 12 1370

million) of these totals, respectively. 1371

26 

# Personal Communication with Califo rnia Retailers Association 2011).*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 80 of 118Exhibit 6-23: Total (including baseline) First Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCost PerResponseTotal CostDomesticForeign1TotalDomesticForeignTotal1. Rule Familiarization--------2. Certification Fee2Standard33393287135991,0529271$6,000$2,0341,968,000$4,2783,594,000$6,3125,562,000NAF (From Uncertified or Standard)112112221$6,000$66,000$1,266,000$1,332,000NAF/ULEF(From NAF orNAF/ULEF)20312053192253501$3,700$74,000114,700$758,5001,180,300$832,5001,295,0003. Initial On-site AuditWith Existing Certifications827648461$450$36,900$343,800$380,700Without Existing Certifications3,42883656531$450$129,600$164,250$293,8504. Develop Quality Control Manual--------5. Qualifying Test51 Product11512964140695$480$26,40012,000$309153,600$336,000165,6002 Products3,428836565310$480$1,382,400$1,752,000$3,134,4006. Qualifying Test Shipping51 Product11512964140691$200$2,2001,000$2512,800$28,00013,8002 Products3,42883656532$200$115,200$146,000$261,2007. Correlation Test--------8. Quarterly On-site Audit6Standard3,43393287135991,0529273$450$457,650442,800$962,550808,650$1,420,200251,450NAF (With New Certification)17112762112932221$450$7,6504,950$124,20094,950$131,85099,900NAF(With Existing Certification)14140154-$450---9. Large Scale Testing Fee71 Standard (Existing)886944$480$15,360$165,120$180,4802 Standard (New)3,42771544316$480$797,760$443,520$1,241,2802 Standard/ULEF(Existing)544735278$480$207,360$1,816,320$2,023,6801 NAF322251$480$1,440$10,560$12,0002 NAF31254163514473762$480$29,76024,000$399,360336,960$429,120360,9601 NAF and 1 ULEF665715480$14,400$156,000$170,40010. Large Scale Testing Shipment71 Standard (Existing)886944$50$1,600$17,200$18,8002 Standard (New)3,42771544316$50$83,100$46,200$129,3002 Standard (Existing)544735278$50$21,600$189,200$210,800Formatted TableFormatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 81 of 118Exhibit 6-23: Total (including baseline) First Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCost PerResponseTotal CostDomesticForeign1TotalDomesticForeignTotal1 NAF322251$50$150$1,100$1,2502 NAF31254163514473762$50$3,1002,500$41,60035,100$44,70037,6001 NAF and 1 ULEF665715$50$1,500$16,250$17,75011. On-site Audit Travel3701,1291,4991$1,500$555,000$1,693,500$2,248,50012. Desk Audits8Standard3,43393287135991,0529278$250$678656,000$1,426198,000$2,1041,854,000NAF17112762112932222$250$85,500$138,000105,500$146,500111,00013. Purchase of Small Chamber TestingUnit32952823502086454901$10,000$2,950820,000$3,5002,080,000$6,4504,900,00014. Quality Control Testing--------15. Lost Product72 Standard (HWPW - Existing)3,429510304109599119528$15.68$2,442,31782,790$2,516,828902,415$4,959,145985,2061 NAF (HWPW - New)5277551086038571536$15.68$5,5662,328,041$61,230907,684$66,7973,235,7251 NAF (HWPW - Existing)585587609518$15.68$781,004$86210,913$94111,9172 NAF (HWPW - New)555605$15.68$392$4,312$4,7042 NAF (HWPW -NewExisting)11211222142$15.68$24,492$469,804$494,2962 NAF (HWPW1 Standard(PB/MDF- Existing)776832$15.68$220$2,383$2,6031 Standard (PB/MDF-Existing)88694264$8.96$18,924$203,428$222,3512 Standard (PB/MDF - New)-346224625536265$8.96-$7,123$220,91852,237$220,91859,3602 Standard (PB/MDF - Existing)365277110313115528532$8.96$170,31223,834$1,310,454524,339$1,480,765548,1731 NAF (PB/MDF - New)133102501128371528$8.96$636156,119$6,3621,182,720$6,9981,338,8391 NAF (PB/MDF - Existing)433227363018$8.96$36215$2871,935$3232,1502 NAF (PB/MDF - Existing)764712$8.96$125$1,147$1,2721 NAF and 1 ULEF (PB/MDF -Existing)110115$8.96$45$448$493Formatted TableFormatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 82 of 118Exhibit 6-23: Total (including baseline) First Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCost PerResponseTotal CostDomesticForeign1TotalDomesticForeignTotal16. Initial Recordkeeping98,57611,94520,5211$1,000$8,576,000$11,945,000$20,521,00017. Recurring Recordkeeping--------18. Initial Labeling10Minor Changes - Producers--------Minor Changes - Fabricators--------Major Changes – Producers32771083851$125$34,625$13,500$48,125Major Changes - Fabricators andWholesalers1116,2666,34422,6101$125$2,033,250$793,000$2,826,250Total - Year 1$22,991,311749,095$37,563,58334,638,718$60,554,89457,387,813Notes: 1. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domestic value ofshipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assumes that there foreign retailers do not typically export composite woodproducts or goods containing composite wood products into the UnitedStates. To remain consistent with the Economic Analysis,which assumes that there is uncertified product being imported into the U.S., theanalysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.2. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by a TPC as aresult of the TSCA Title VI rule.3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined ashardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use added formaldehyde resins.4. This analysis assumes thatthatmills will seek standard certification for uncertifiedand ULEFproduct lines. The exceptions are1) mills that are both ULEF and NAF certified, which are assumed to switch totwo NAF product lines; and 2)uncertified hardwood plywood producers, which are assumed to switch to NAF certification.5. Producers that are already CARB compliantand are not expected adopt a more stringent certification type (e.g., NAF certification)are assumed not to need to perform qualifying or correlation testing because itis assumed that their previous testing is sufficient.6. On-site audits must be conducted at least once quarterly, unless the mill obtainsULEF orNAF certification. This analysis assumes that producers with new NAF certifications will incur the burden associatedwith one on-site audit (in addition to the initial audit) andtwo desk audits in the first year. Producers with existingULEF orNAF certifications under the CARB ATCM will only incur the initial on-site audit inthe first year. All producers withULEF orNAF certification will have one on-site audit annually thereafter.7. The respondents sum to more than the total number of respondents because some respondents are assumed to havebothmore than one certification type (i.e.,standard, ULEF,and NAFcertifications.).8. Desk audits are assumed to occur monthlyfor standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated withtwo desk auditsin the first year; none are required in subsequent years.No desk audits are required for respondents with existingULEF orNAF certification.9. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneerlaminated product producers defined as hardwood plywood producers],fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier,and all precautions taken to ensure that the product meets the emissions standards.However, composite panel producers and fabricators are not expectedto need to make any initial changes to their recordkeepingsystems. This analysis assumes that 28 percent of domestic wholesalers importcomposite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying withthe CARB ATCM will have initial burdento change their recordkeeping systems to comply withthe TSCA Title VI rule.10.FirmsPanel producers, fabricators, and wholesalersthat package or repackage composite wood products or finishedgoods containing composite wood products will need to modify their labels to include theirname, the date the finished good was produced, and a statement of compliance.Retailers are not required to modify their labeling system to comply with the proposed rule assuming they do not modify thepackaging of the products they purchase.This analysis assumes that all 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are not sold in California) will incura non-labor cost of $125.00 for purchasing stamps for labeling.Producers and wholesalers are not expected to incur any non-labor costs from initial labeling.11. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.Formatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 83 of 118Exhibit 6-24: Total (including baseline) Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCost PerResponseTotal CostDomesticForeign1TotalDomesticForeignTotal1. Rule Familiarization--------2. Certification Fee2Standard33393287135991,0529271$6,000$2,0341,968,000$4,2783,594,000$6,3125,562,000NAF (From Uncertified or Standard)112112221$3,700$40,700$780,700$821,400NAF/ULEF(From NAF orNAF/ULEF)20312053192253501$3,700$74,000114,700$758,5001,180,300$832,5001,295,0003. Initial On-site AuditWith Existing Certifications--------Without Existing Certifications3,4--------4. Develop Quality Control Manual--------5. Qualifying Test51 Product--------2 Products3,4--------6. Qualifying Test Shipping51 Product--------2 Products3,4--------7. Correlation Test5--------8. Quarterly On-site Audit6Standard3,43393287135991,0529274$450$610,200590,400$1,283,400078,200$1,893668,600NAF (With New Certification)17112762112932221$450$7,6504,950$124,20094,950$131,85099,900NAF (With Existing Certification)141401541$450$6,300$63,000$69,3009. Large Scale Testing Fee71 Standard (Existing)886944$480$15,360$165,120$180,4802 Standard (New)3,42771544316$480$797,760$443,520$1,241,2802 Standard/ULEF(Existing)544735278$480$207,360$1,816,320$2,023,6801 NAF322251$480$1,440$10,560$12,0002 NAF31254163514473762$480$29,76024,000$399,360336,960$429,120360,9601 NAF and 1 ULEF665715$480$14,400$156,000$170,40010. Large Scale Testing Shipment71 Standard (Existing)886944$50$1,600$17,200$18,8002 Standard (New)3,42771544316$50$83,100$46,200$129,3002 Standard (Existing)544735278$50$21,600$189,200$210,8001 NAF322251$50$150$1,100$1,2502 NAF31254163514473762$50$3,1002,500$41,60035,100$44,70037,60Formatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 84 of 118Exhibit 6-24: Total (including baseline) Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCost PerResponseTotal CostDomesticForeign1TotalDomesticForeignTotal0*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 85 of 118Exhibit 6-24: Total (including baseline) Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCost PerResponseTotal CostDomesticForeign1TotalDomesticForeignTotal1 NAF and 1 ULEF665715$50$1,500$16,250$17,75011. On-site Audit Travel3701,1291,4991$1,500$555,000$1,693,500$2,248,50012. Desk Audits8Standard3,43393287135991,0529278$250$678656,000$1,426198,000$2,1041,854,000NAF--------13. Purchase of Small Chamber Testing Unit3--------14. Quality Control Testing--------15. Lost Product72 Standard (HWPW - Existing)3,429510304109599119528$15.68$2,442,31782,790$2,516,828902,415$4,959,145985,2061 NAF (HWPW - New)527755108603851528$15.68$782,293,294$862894,136$9413,187,4301 NAF (HWPW - Existing)585587609518$15.68$781,004$86210,913$94111,9172 NAF (HWPW - New)555605$15.68$392$4,312$4,7042 NAF (HWPW -NewExisting)112112222$15.68$345$6,617$6,9622 NAF (HWPW1 Standard (PB/MDF- Existing)776832$15.68$220$2,383$2,6031 Standard (PB/MDF-Existing)88694264$8.96$18,924$203,428$222,3512 Standard (PB/MDF - New)-346224625536265$8.96-$7,123$220,91852,237$220,91859,3602 Standard (PB/MDF - Existing)365277110313115528$8.96$170,31223,654$1,310,454520,397$1,480,765544,0511 NAF (PB/MDF - New)13310250112831528$8.96$9156,119$901,182,720$991,338,8391 NAF (PB/MDF - Existing)433227363018$8.96$36215$2871,935$3232,1502 NAF (PB/MDF - Existing)764712$8.96$125$1,147$1,2721 NAF and 1 ULEF (PB/MDF - Existing)110115$8.96$45$448$49316. Initial Recordkeeping9--------17. Recurring Recordkeeping--------18. Initial Labeling10Minor Changes - Producers--------Minor Changes - Fabricators--------Minor Changes – Wholesalers3--------Major Changes – Fabricators11--------Total - Years 2 and 3$7,799,524665,846$17,801,35616,432,841$25,600,88024,098,688Notes: 1. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domesticvalue of shipments for these NAICS (which is 39 percent) and 2)applying it to the number of domestic firms in each sector. The analysis assumes that there foreign retailers do not typically exportFormatted TableFormatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 86 of 118Exhibit 6-24: Total (including baseline) Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCost PerResponseTotal CostDomesticForeign1TotalDomesticForeignTotalcomposite wood products or goods containing composite wood productsinto the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified product beingimported into the U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.2. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by aTPC as a result of the TSCA Title VI rule.3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be definedas hardwood plywood. A similar proportion of foreign laminatorsexporting to the U.S. are also assumed to continue to use added formaldehyde resins.4. This analysis assumes thatthatmills will seek standard certification for uncertifiedand ULEFproduct lines. The exceptions are1) mills that are both ULEF and NAFcertified, which are assumed toswitch to two NAF product lines; and 2)uncertified hardwood plywood producers, which are assumed to switch to NAF certification.5. Producers that are already CARB compliantand are not expected adopt a more stringent certification type (e.g., NAF certification)are assumed not to need to perform qualifying or correlation testingbecause it is assumed that theirprevious testing is sufficient.6. On-site audits must be conducted at least once quarterly, unless the mill obtainsULEF orNAF certification. This analysisassumes that producers with new NAFcertifications will incur the burdenassociated with one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existingULEF orNAF certifications under the CARB ATCM will only incur theinitial on-site audit in the first year. All producers withULEF orNAF certification willhave one on-site audit annually thereafter.7. The respondents sum to more than the total number of respondents because some respondents are assumed to havebothmore than one certification type (i.e.,standard, ULEF,and NAFcertifications.).8. Desk auditsfor standard certificationsare assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with twodesk audits in the first year; none are required in subsequentyears. No desk audits are required for respondents with existingULEF orNAF certification.9. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneerlaminated product producers defined as hardwood plywoodproducers], fabricators, and wholesalers that import composite woodproducts) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meetsthe emissions standards. However, composite panel producers and fabricators are not expected toneed to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percentof domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying withthe CARB ATCM will have initial burden tochange their recordkeeping systems tocomply with the TSCA Title VI rule.10.FirmsPanel producers, fabricators, and wholesalersthat package or repackage composite woodproducts or finished goods containing composite wood products will need to modify their labels toinclude their name, the date the finished good was produced, and a statement of compliance.Retailers are not required to modify their labeling system to comply with the proposed rule assuming theydo not modify the packaging of the products they purchase.This analysis assumes that all 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are notsold in California) will incur a non-labor cost of $125.00 forpurchasing stamps for labeling. Producers and wholesalers are not expected to incur any non-labor costs from initial labeling.11. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 87 of 118Exhibit 6-25: Three Year Average Non-Labor Costs (includingbaseline), by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCost PerResponseTotal CostDomesticForeign1TotalDomesticForeignTotal1. Rule Familiarization--------2. Certification Fee2Standard33393287135991,0529271.0000$6,000.00$2,0341,968,000$4,2783,594,000$6,3125,562,000NAF (From Uncertified or Standard)112112221.0000$4,466.676,000$49,133$942,467$991,601600NAF/ULEF(From NAF orNAF/ULEF)20312053192253501.0000$3,700.00$74,000114,700$758,5001,180,300$832,5001,295,0003. Initial On-site AuditWith Existing Certifications827648460.3333$450.00$12,299300$114,589600$126,887900Without Existing Certifications3,42883656530.3333$450.00$43,196200$54,745750$97,9409504. Develop Quality Control Manual--------5. Qualifying Test51 Product11512964140691.6667$480.00$8,8004,000$103,20251,200$112,00255,2002 Products3,42883656533.3333$480.00$460,795800$583,994584,000$1,044,7908006. Qualifying Test Shipping51 Product11512964140690.3333$200.00$733333$8,5994,267$9,3324,6002 Products3,42883656530.6667$200.00$38,402400$48,669667$87,0710677. Correlation Test--------8. Quarterly On-site Audit6Standard3,43393287135991,0529273.6667$450.00$559,355541,200$1,176,461988,350$1,735,816529,550NAF (With New Certification)17112762112932221.0000$450.00$7,6504,950$124,20094,950$131,85099,900NAF (With Existing Certification)141401540.6667$450.00$4,200$42,002$46,2029. Large Scale Testing Fee71 Standard (Existing)886944.0000$480.00$15,360$165,120$180,4802 Standard (New)3,42771544316.0000$480.00$797,760$443,520$1,241,2802 Standard/ULEF(Existing)544735278.0000$480.00$207,360$1,816,320$2,023,6801 NAF322251.0000$480.00$1,440$10,560$12,0002 NAF31254163514473762.0000$480.00$29,76024,000$399,360336,960$429,120360,9601 NAF and 1 ULEF665715.0000$480$14,400$156,000$170,40010. Large Scale Testing Shipment71 Standard (Existing)886944.0000$50.00$1,600$17,200$18,800Formatted TableFormatted TableFormatted TableFormatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 88 of 118Exhibit 6-25: Three Year Average Non-Labor Costs (includingbaseline), by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCost PerResponseTotal CostDomesticForeign1TotalDomesticForeignTotal2 Standard (New)3,42771544316.0000$50.00$83,100$46,200$129,3002 Standard (Existing)544735278.0000$50.00$21,600$189,200$210,8001 NAF322251.0000$50.00$150$1,100$1,2502 NAF31254163514473762.0000$50.00$3,1002,500$41,60035,100$44,70037,6001 NAF and 1 ULEF665715.0000$50$1,500$16,250$17,75011. On-site Audit Travel3701,1291,4991.0000$1,500.00$555,000$1,693,500$2,248,50012. Desk Audits8Standard3,43393287135991,0529278.0000$250.00$678656,000$1,426198,000$2,1041,854,000NAF17112762112932220.6667$250.00$21,833$46,00235,167$48,83637,00013. Purchase of Small Chamber Testing Unit32952823502086454900.3333$10,000.00$983,235940,000$1,166,550693,333$2,149,7851,633,33314. Quality Control Testing--------15. Lost Product72 Standard (HWPW - Existing)3,429510304109599119528.0000$15.68$2,442,31782,790$2,516,828902,415$4,959,145985,2061 NAF (HWPW - New)5277551086038524.3333530.6667$15.68$1,9082,304,876$20,985898,652$22,8933,203,5291 NAF (HWPW - Existing)585587609518.0000$15.68$781,004$86210,913$94111,9172 NAF (HWPW - New)555605.0000$15.68$392$4,312$4,7042 NAF (HWPW -NewExisting)1121122248.6667$15.68$8,394$161,013$169,4072 NAF (HWPW1 Standard (PB/MDF-Existing)776832.0000$15.68$220$2,383$2,60312Standard (PB/MDF -ExistingNew)8386229425264265.0000$8.96$18,9247,123$203,42852,237$222,35159,3602 Standard (PB/MDF -NewExisting)-54611046115536.0000529.3333$8.96-$23,714$220,918521,711$220,918545,4252 Standard1 NAF(PB/MDF -ExistingNew)3633277250313283528.0000$8.96$170,312156,119$1,310,454182,720$1,480,765338,8391 NAF (PB/MDF -NewExisting)131027113024.33338.0000$8.96$218215$2,1801,935$2,39815012NAF (PB/MDF - Existing)473264367112.0000$8.96$36125$2871,147$3231,27221NAFand 1 ULEF(PB/MDF - Existing)716410711125.0000$8.96$12545$1,147448$1,272493Formatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 89 of 118Exhibit 6-25: Three Year Average Non-Labor Costs (includingbaseline), by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCost PerResponseTotal CostDomesticForeign1TotalDomesticForeignTotal16. Initial Recordkeeping98,57611,94520,5210.3333$1,000.00$2,858,381667$3,981,269667$6,839,649840,33317. Recurring Recordkeeping--------18. Initial Labeling10Minor Changes - Producers--------Minor Changes - Fabricators--------Major Changes – Producers32771083850.3333$125.00$11,541542$4,500$16,040042Major Changes - Fabricators andWholesalers1116,2666,34422,6100.3333$125.00$677,682750$264,307333$941,989942,083Three-Year Average Cost$12,862,997693,595$24,388,22122,501,467$37,251,21635,195,063Notes: 1. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domesticvalue of shipments for these NAICS (which is 39 percent) and 2)applying it to the number of domestic firms in each sector. The analysis assumes that there foreign retailers do not typically exportcomposite wood products or goods containing composite wood productsinto the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified product beingimported into the U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.2. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by aTPC as a result of the TSCA Title VI rule.3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be definedas hardwood plywood. A similar proportion of foreign laminatorsexporting to the U.S. are also assumed to continue to use added formaldehyde resins.4. This analysis assumes thatthatmills will seek standard certification for uncertifiedand ULEFproduct lines. The exceptions are1) mills that are both ULEF andNAF certified, which are assumed toswitch to two NAF product lines; and 2)uncertified hardwood plywood producers, which are assumed to switch to NAF certification.5. Producers that are already CARB compliantand are not expected adopt a more stringent certification type (e.g., NAF certification)are assumed not to need to perform qualifying or correlation testingbecause it is assumed that theirprevious testing is sufficient.6. On-site audits must be conducted at least once quarterly, unless the mill obtainsULEF orNAF certification. This analysisassumes that producers with new NAFcertifications will incur the burdenassociated with one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existingULEF orNAF certifications under the CARB ATCM will only incur theinitial on-site audit in the first year. All producers withULEF orNAF certification willhave one on-site audit annually thereafter.7. The respondents sum to more than the total number of respondents because some respondents are assumed to havebothmore than one certification type (i.e.,standard, ULEF,and NAF certifications.).8. Desk audits are assumed to occur monthlyfor standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated withtwodesk audits in the first year; none are required in subsequentyears. No desk audits are required for respondents with existingULEF orNAF certification.9. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneerlaminated product producers defined as hardwood plywoodproducers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meetsthe emissions standards. However, composite panel producers and fabricators are not expected toneed to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percentof domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying withthe CARB ATCM will have initial burden tochange their recordkeeping systems tocomply with the TSCA Title VI rule.10.FirmsPanel producers, fabricators, and wholesalersthat package or repackage composite woodproducts or finished goods containing composite wood products will need to modify their labels toinclude their name, the date the finished good was produced, and a statement of compliance.Retailers are not required to modify their labeling system to comply with the proposed rule assuming theydo not modify the packaging of the products they purchase.This analysis assumes that all 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are notsold in California) will incur a non-labor cost of $125.00 forpurchasing stamps for labeling. Producers and wholesalers are not expected to incur any non-labor costs from initial labeling.11. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.Formatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 90 of 118*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 91 of 118Exhibit 6-26: Incremental First Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber ofRespondentsNumberofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal1. Rule Familiarization--------2. Certification Fee2Uncertified to Standard3,42771544311$6,000$1,662,000$924,000$2,586,000ULEF to Standard111141251$2,300$25,300$262,200$287,500NAF (With New Certification)112112221$6,000$66,000$1,266,000$1,332,0003. Initial On-site AuditWith Existing Certifications82764846-$450---Without Existing Certifications3,42883656531$450$129,600$164,250$293,8504. Develop Quality Control Manual--------5. Qualifying Test51 Product11512964140695$480$26,40012,000$309153,600$336,000165,6002 Products3,428836565310$480$1,382,400$1,752,000$3,134,4006. Qualifying Test Shipping51 Product11512964140691$200$2,2001,000$2512,800$28,00013,8002 Products3,42883656532$200$115,200$146,000$261,2007. Correlation Test5--------8. Quarterly On-site Audit6Uncertified to Standard3,42771544313$450$373,950$207,900$581,850ULEF to Standard111141253$450$14,850$153,900$168,750NAF (With New Certification)112112221$450$4,950$94,950$99,9009. Large Scale Testing Fee1 New Standard564693$480$7,200$92,160$99,360Formatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 92 of 118Exhibit 6-26: Incremental First Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber ofRespondentsNumberofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal2 New Standard3,42771544316$480$797,760$443,520$1,241,2802 ULEF to 2 Standard111141256$480$31,680$328,320$360,0001 New NAF665711$480$2,880$31,200$34,0802 New NAF1152111462221512$480$10,5604,800$202,560140,160$213,120144,9601 NAF and 1 ULEF665715$480$14,400$156,000$170,40010. Large Scale Testing Shipment1 New Standard564693$50$750$9,600$10,3502 New Standard3,42771544316$50$83,100$46,200$129,3002 ULEF to 2 Standard111141256$50$3,300$34,200$37,5001 New NAF665711$50$300$3,250$3,5502 New NAF1152111462221512$50$1,100500$21,10014,600$22,20015,10011. On-site Audit Travel1 NAF and 1 ULEF2886365656537115$1,50050$432,0001,500$547,50016,250$979,50017,75012. Desk Audits711. On-site Audit Travel2883656531$1,500$432,000$547,500$979,500Uncertified to Standard3,412. Desk Audits72771544318$250$554,000$308,000$862,000ULEFUncertifiedtoStandardStandard3,4112771141541254318$250$22554,000$228308,000$250862,000NAF (With New Certification)112112222$250$5,500$105,500$111,00013. Purchase of Small Chamber Testing Unit22952823502086454901$10,000$2,950820,000$3,5002,080,000$6,4504,900,00014. Quality Control Testing--------Formatted TableFormatted TableInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 93 of 118Exhibit 6-26: Incremental First Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber ofRespondentsNumberofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal15. Lost Product1 New2Standard-PB/MDF(HWPW – Existing)3,45106410969119268416$8.9615.68$12,00665,229$153,682710,994$165,688776,2232NewStandard-HWPW3(HWPW-New)3,4277154108431385536$15.68$2,328,041$1,294,290907,684$3,622,331235,7252 ULEF to 2 Standard-PB/MDF32730528$8.96$14,193$127,734$141,9262 ULEF to 2Standard-HWPW88795528$15.68$66,232$720,276$786,5091 ULEF to 1 NAF-PB/MDF1101167$8.96$600$6,003$6,6041 ULEF to 1 NAF–HWPW5556067$15.68$5,253$57,781$63,0342NewNAF–(HWPW-New)11211222142$15.68$24,492$469,804$494,2962 Standard (PB/MDF - New)5110115268$8.96$12,006$264,141$276,14716. Initial Recordkeeping88,57611,94520,5211$1,000.00$8,576,000$11,945,000$20,521,00017. Recurring Recordkeeping--------18. Initial Labeling9Minor Changes - Producers--------Minor Changes - Fabricators--------Major Changes – Producers32771083851$125.00$34,625$13,500$48,125Major Changes - Fabricators and Wholesalers1016,2666,34422,6101$125.00$2,033,250$793,000$2,826,250Total - Year 1$21,799,672580,413$26,788,78024,182,083$48,588,45345,762,496Notes: 1. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domesticvalue of shipments for these NAICS (which is 39 percent) and 2)applying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typically export compositewood products or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified product being importedinto the U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.Formatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 94 of 118Exhibit 6-26: Incremental First Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber ofRespondentsNumberofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal2. This analysis assumes thatthatmills will seek standard certification for uncertifiedand ULEFproduct lines. The exceptions are1) mills that are both ULEF and NAFcertified, which are assumed toswitch to two NAF product lines; and 2)uncertified hardwood plywood producers, which are assumed to switch to NAF certification.3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be definedas hardwood plywood. A similar proportion of foreign laminatorsexporting to the U.S. are also assumed to continue to use added formaldehyde resins.4. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by aTPC as a result of the TSCA Title VI rule.5. Producers that are already CARB compliantand are not expected adopt a more stringent certification type (e.g., NAF certification)are not assumed to need to perform qualifying or correlation testingbecause it is assumed that theirprevious testing is sufficient.6. On-site audits must be conducted at least once quarterly, unless the mill obtainsULEF orNAF certification. This analysisassumes that producers with new NAFcertifications will incur the burdenassociated with one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existingULEF orNAF certifications under the CARB ATCM will only incur theinitial on-site audit in the first year. All producers withULEF orNAF certification willhave one on-site audit annually thereafter.7. Desk audits are assumed to occur monthlyfor standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated withtwodesk audits in the first year; none are required in subsequentyears. No desk audits are required for respondents with existingULEF orNAF certification.8. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneerlaminated product producers defined as hardwood plywoodproducers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meetsthe emissions standards. However, composite panel producers and fabricators are not expected toneed to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percentof domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying withthe CARB ATCM will have initial burden tochange their recordkeeping systems tocomply with the TSCA Title VI rule.9.FirmsPanel producers, fabricators, and wholesalersthat package or repackage composite wood products or finishedgoods containing composite wood products will need to modify their labels toinclude their name, the date the finished good was produced, and a statement of compliance.Retailers are not required to modify their labeling system to comply with the proposed rule assuming theydo not modify the packaging of the products they purchase.This analysis assumes that all 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are notsold in California) will incur a non-labor cost of $125.00 forpurchasing stamps for labeling. Producers and wholesalers are not expected to incur any non-labor costs from initial labeling.10. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 95 of 118Exhibit 6-27: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber ofRespondentsNumberofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal1. Rule Familiarization--------3. Certification Fee2Uncertified to Standard3,42771544311$6,000$1,662,000$924,000$2,586,000ULEF to Standard111141251$2,300$25,300$262,200$287,500NAF (With New Certification)112112221$3,700$40,700$780,700$821,4004. Initial On-site AuditWith Existing Certifications--------Without Existing Certifications3,4--------5. Develop Quality Control Manual--------6. Qualifying Test51 Product--------2 Products3,4--------7. Qualifying Test Shipping51 Product--------2 Products3,4--------8. Correlation Test5--------9. Quarterly On-site Audit6Uncertified to Standard3,42771544314$450$498,600$277,200$775,800ULEF to Standard111141253$450$14,850$153,900$168,750NAF (With New Certification)1121122213$450$4,95014,850$94,950284,850$99,900299,70010. Large Scale Testing Fee1 New Standard564694$480$9,600$122,880$132,4802 New Standard3,42771544318$480$1,063,680$591,360$1,655,0402 ULEF to 2 Standard111141256$480$31,680$328,320$360,0001 New NAF665711$480$2,880$31,200$34,080Formatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 96 of 118Exhibit 6-27: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber ofRespondentsNumberofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal2 New NAF1152111462221512$480$10,5604,800$202,560140,160$213,120144,9601 NAF and 1 ULEF665715$480$14,400$156,000$170,40011. Large Scale Testing Shipment1 New Standard564694$50$1,000$12,800$13,8002 New Standard3,42771544318$50$110,800$61,600$172,4002 ULEF to 2 Standard111141256$50$3,300$34,200$37,5001 New NAF665711$50$300$3,250$3,5502 New NAF1152111462221512$50$1,100500$21,10014,600$22,20015,10012. On-site Audit Travel1 NAF and 1 ULEF2886365656537115$1,50050$432,0001,500$547,50016,250$979,50017,75013. Desk Audits712. On-site Audit Travel2883656531$1,500$432,000$547,500$979,500Uncertified to Standard3,413. Desk Audits72771544318$250$554,000$308,000$862,000ULEFUncertifiedtoStandardStandard3,4112771141541254318$250$22554,000$228308,000$250862,000NAF (With New Certification)--------14. Purchase of Small Chamber Testing Unit--------15. Quality Control Testing--------16. Lost Product1 New2Standard-PB/MDF(HWPW – Existing)3,45106410969119264416$8.9616$11,82765,229$151,388710,994$163,215776,2232NewStandard-HWPW3(HWPW-New)3,4277154108431385528$15.6816$2,293,294$1,274,972894,136$3,568,266187,4302 ULEF to 2 Standard-PB/MDF32730520$8.96$13,97$125,7$139,7Formatted TableFormatted TableInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 97 of 118Exhibit 6-27: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber ofRespondentsNumberofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal89876*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 98 of 118Exhibit 6-27: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber ofRespondentsNumberofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal2 ULEF to 2 Standard-HWPW88795520$15.68$65,229$709,363$774,5921 ULEF to 1 NAF-PB/MDF11011-3$8.96-$27-$269-$2961 ULEF to 1 NAF–HWPW55560-3$15.68-$235-$2,587-$2,8222NewNAF–(HWPW-New)112112222$15.6816$345$6,617$6,9622 Standard (PB/MDF - New)5110115264$9$11,827$260,198$272,02617. Initial Recordkeeping8--------18. Recurring Recordkeeping--------19. Initial Labeling9Minor Changes - Producers--------Minor Changes - Fabricators--------Major Changes – Producers3--------Major Changes - Fabricators and Wholesalers10--------Total - Years 2 and 3$6,873,711817,285$7,251,0026,506,816$14,124,71313,324,101Notes: 1. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domesticvalue of shipments for these NAICS (which is 39 percent) and 2)applying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typically export compositewood products or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified product being importedinto the U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.2. This analysis assumes thatthatmills will seek standard certification for uncertifiedand ULEFproduct lines. The exceptions are1) mills that are both ULEF and NAFcertified, which are assumed toswitch to two NAF product lines; and 2)uncertified hardwood plywood producers, which are assumed to switch to NAF certification.3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be definedas hardwood plywood. A similar proportion of foreign laminatorsexporting to the U.S. are also assumed to continue to use added formaldehyde resins.4. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by aTPC as a result of the TSCA Title VI rule.5. Producers that are already CARB compliantand are not expected adopt a more stringent certification type (e.g., NAF certification)are not assumed to need to perform qualifying or correlation testingbecause it is assumed that theirprevious testing is sufficient.6. On-site audits must be conducted at least once quarterly, unless the mill obtainsULEF orNAF certification. This analysisassumes that producers with new NAFcertifications will incur the burdenassociated with one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existingULEF orNAF certifications under the CARB ATCM will only incur theinitial on-site audit in the first year. All producers withULEF orNAF certification willhave one on-site audit annually thereafter.7. Desk audits are assumed to occur monthlyfor standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated withtwoFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 99 of 118Exhibit 6-27: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber ofRespondentsNumberofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotaldesk audits in the first year; none are required in subsequentyears. No desk audits are required for respondents with existingULEF orNAF certification.8. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneerlaminated product producers defined as hardwood plywoodproducers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meetsthe emissions standards. However, composite panel producers and fabricators are not expected toneed to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percentof domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying withthe CARB ATCM will have initial burden tochange their recordkeeping systems tocomply with the TSCA Title VI rule.9.FirmsPanel producers, fabricators, and wholesalersthat package or repackage composite wood products or finishedgoods containing composite wood products will need to modify their labels toinclude their name, the date the finished good was produced, and a statement of compliance.Retailers are not required to modify their labeling system to comply with the proposed rule assuming theydo not modify the packaging of theproducts they purchase.This analysis assumes that all 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are notsold in California) will incur a non-labor cost of $125.00 forpurchasing stamps for labeling. Producers and wholesalers are not expected to incur any non-labor costs from initial labeling.10. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 100 of 118Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal1. Rule Familiarization--------2. Certification Fee2Uncertified to Standard3,42771544311.0000$6,000.00$1,662,000$924,000$2,586,000ULEF to Standard111141251.0000$2,300.00$25,300$262,200$287,500NAF (With New Certification)112112221.0000$4,466.67$49,133$942,467$991,601603. Initial On-site AuditWith Existing Certifications82764846-$450.00---Without Existing Certifications3,42883656530.3333$450.00$43,196200$54,745750$97,9409504. Develop Quality Control Manual--------5. Qualifying Test51 Product11512964140691.6667$480.00$8,8004,000$103,20251,200$112,00255,2002 Products3,42883656533.3333$480.00$460,795800$583,994584,000$1,044,7908006. Qualifying Test Shipping51 Product11512964140690.3333$200.00$733333$8,5994,267$9,3324,6002 Products3,42883656530.6667$200.00$38,402400$48,669667$87,0710677. Correlation Test--------8. Quarterly On-site Audit5Uncertified to Standard3,42771544313.6667$450.00$457,054050$254,102100$711,156150ULEF to Standard111141253.0000$450.00$14,850$153,900$168,750NAF (With New Certification)112112221.00002.333$450.00$4,95011,550$94,950221,5$99,900233,1Formatted TableFormatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 101 of 118Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal35000*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 102 of 118Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal9. Large Scale Testing Fee1 New Standard564693.6667$480.00$8,800$112,641640$121,4414402 New Standard3,42771544317.3333$480.00$975,036040$542,078080$1,517,1131202 ULEF to 2 Standard111141256.0000$480.00$31,680$328,320$360,0001 New NAF665711.0000$480.00$2,880$31,200$34,0802 New NAF1152111462221512.0000$480.00$10,5604,800$202,560140,160$213,120144,9601 NAF and 1 ULEF665715.0000$480$14,400$156,000$170,40010. Large Scale Testing Shipment1 New Standard564693.6667$50.00$917$11,733$12,6502 New Standard3,42771544317.3333$50.00$101,566567$56,466467$158,0332 ULEF to 2 Standard111141256.0000$50.00$3,300$34,200$37,5001 New NAF665711.0000$50.00$300$3,250$3,5502 New NAF1152111462221512.0000$50.00$1,100500$21,10014,600$22,20015,10011. On-site Audit Travel1 NAF and 1 ULEF2886365656537115.0000$1,500.0050$432,0001,500$547,50016,250$979,50017,75012. Desk Audits711. On-site Audit Travel2883656531.0000$1,500$432,0$547,5$979,5Formatted TableFormatted TableInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted CellsInserted Cells*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 103 of 118Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal000000*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 104 of 118Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotalUncertified to Standard3,412. Desk Audits72771544318.0000$250.00$554,000$308,000$862,000ULEFUncertifiedtoStandardStandard3,4112771141541254318.0000$250.00$22554,000$228308,000$250862,000NAF (With New Certification)112112220.6667$250.00$1,833$35,168167$37,00200013. Purchase of Small Chamber Testing Unit2952823502086454900.3333$10,000.00$983,235940,000$1,166,550693,333$2,149,7851,633,33314. Quality Control Testing--------15. Lost Product1 New2Standard-PB/MDF(HWPW – Existing)3,45106410969119265.3333416.0000$8.9616$11,88765,229$152,153710,994$164,040776,2232NewStandard-HWPW3(HWPW-New)3,4277154108431385530.6667$15.6816$2,304,877876$1,281,411898,652$3,586,288203,5292 ULEF to 2 Standard-PB/MDF32730522.6667$8.96$14,049$126,444$140,4932 ULEF to 2 Standard-HWPW88795522.6667$15.68$65,563$713,001$778,5641 ULEF to 1 NAF-PB/MDF1101120.3333$8.96$182$1,822$2,0041 ULEF to 1 NAF-HWPW5556020.3333$15.68$1,594$17,535$19,1302NewNAF-(HWPW-New)1121122248.6667$15.6816$8,394$161,013$169,4072 Standard (PB/MDF - New)5110115265.3333$9$11,887$261,513$273,39916. Initial Recordkeeping88,57611,94520,5210.3333$1,000.00$2,858,381667$3,981,269667$6,839,649840,33317. Recurring Recordkeeping--------Deleted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsDeleted CellsFormatted TableFormatted TableFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 105 of 118Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotal18. Initial Labeling9Minor Changes - Producers--------Minor Changes - Fabricators--------Major Changes – Producers32771083850.3333$125.00$11,541542$4,500$16,040042Major Changes - Fabricators and Wholesalers1016,2666,34422,6100.3333$125.00$677,682750$264,307333$941,989942,083Three-Year Average Cost$11,848,570738,328$13,763,04912,398,573$25,611,62024,136,899Notes: 1. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domesticvalue of shipments for these NAICS (which is 39 percent) and 2)applying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typically export compositewood products or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified product being importedinto the U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.2. This analysis assumes thatthatmills will seek standard certification for uncertifiedand ULEFproduct lines. The exceptions are1) mills that are both ULEF and NAFcertified, which are assumed toswitch to two NAF product lines; and 2)uncertified hardwood plywood producers, which are assumed to switch to NAF certification.3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be definedas hardwood plywood. A similar proportion of foreign laminatorsexporting to the U.S. are also assumed to continue to use added formaldehyde resins.4. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by aTPC as a result of the TSCA Title VI rule.5. Producers that are already CARB compliantand are not expected adopt a more stringent certification type (e.g., NAF certification)are not assumed to need to perform qualifying or correlation testingbecause it is assumed that theirprevious testing is sufficient.6. On-site audits must be conducted at least once quarterly, unless the mill obtainsULEF orNAF certification. This analysisassumes that producers with new NAFcertifications will incur the burdenassociated with one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existingULEF orNAF certifications under the CARB ATCM will only incur theinitial on-site audit in the first year. All producers withULEF orNAF certification willhave one on-site audit annually thereafter.7. Desk audits are assumed to occur monthlyfor standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated withtwodesk audits in the first year; none are required in subsequentyears. No desk audits are required for respondents with existingULEF orNAF certification.8. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneerlaminated product producers defined as hardwood plywoodproducers], fabricators, and wholesalers that import composite woodproducts) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meetsthe emissions standards. However, composite panel producers and fabricators are not expected toneed to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percentof domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying withthe CARB ATCM will have initial burden tochange their recordkeeping systems tocomply with the TSCA Title VI rule.9.FirmsPanel producers, fabricators, and wholesalersthat package or repackage composite wood products or finishedgoods containing composite wood products will need to modify their labels toinclude their name, the date the finished good was produced, and a statement of compliance.Retailers are not required to modify their labeling system to comply with the proposed rule assuming theyFormatted TableFormatted Table*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***Page 106 of 118Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010)ActivityNumber of RespondentsNumber ofActivities PerRespondentCostPerActivityTotal CostDomesticForeign1TotalDomesticForeignTotaldo not modify the packaging of the products they purchase.This analysis assumes that all 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are notsold in California) will incur a non-labor cost of $125.00 forpurchasing stamps for labeling. Producers and wholesalers are not expected to incur any non-labor costs from initial labeling.10. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.

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# Page 107 of 118 

# (iii) Total Burden and Costs 1372

1373

Exhibit 6-29 presents a summary of the total non-incremental burden and costs for this 1374

information collection reque st over the first three years of the rule, by geog raphic location. 1375

Exhibit 6-30 presents a summary of the total in cremental burden and costs for this information 1376

collection request over the first three years of the rule, by geographic location. As indicated, the 1377

total average domestic incremental cost over the first three years of the rule is approximately 1378

86 .2 percent of the total domestic cost of the rule. Note that the incremental costs for domestic 1379

respondents presented in Exhibit 6-30 differ from th e values in the Economic Analysis. This is 1380

due to two factors: 1) the Economic Analysis includes the costs of changes to raw materials for 1381

composite panel producers, while the ICR does not (because it is not a reporting or 1382

recordkeeping cost); and 2) the burden in the ICR is calculated at the activity level and rounded 1383

to nearest tenth of a percentage, while the costs in the Economic Analysis are calculated at the 1384

establishment level. 1385

1386

Exhibit 6-29: Total (including baseline) Burden and Costs ($2010)

Geographic Location of

Respondents Labor Non-Labor Cost Total Cost Hours Cost

Year 1

Domestic Respondents 9, 

# 048,102 041,296 $449, 

# 847,909 362,2

35 $22, 

# 991,311 749,0

95 $472, 

# 839,220

111,329

Foreign Respondents 4, 

# 137,039 066,091 $ 

# 157,096,495 152,

033,647 $ 

# 37,563,583 34,6

38,718 $ 

# 194,660,07

8 186,672,365

Total Respondents 13, 

# 185,140 107,388 $ 

# 606,944,290 601,

395,909 $ 

# 60,554,894 57,3

87,813 $ 

# 667,499,18

4 658,783,722

Years 2 and 3

Domestic Respondents 2, 

# 973,560 967,505 $83, 

# 966,474 534,39

0 $7, 

# 799,524 665,84

6 $91, 

# 765,998 2

00,236

Foreign Respondents 2, 

# 379,880 317,142 $ 

# 80,867,858 76,39

0,874 $ 

# 17,801,356 16,4

32,841 $ 

# 98,669,214

92,823,715

Total Respondents 5, 

# 353,441 284,648 $ 

# 164,834,359 159,

925,291 $ 

# 25,600,880 24,0

98,688 $ 

# 190,435,23

9 184,023,979

Three Year Average

Domestic Respondents 4, 

# 998,206 991,901 $205, 

# 914,848 477,0

02 $12, 

# 862,997 693,5

95 $218, 

# 777,845

170,598

Foreign Respondents 2, 

# 965,542 900,068 $ 

# 106,274,877 101,

605,129 $ 

# 24,388,221 22,5

01,467 $ 

# 130,663,09

8 124,106,597

Total Respondents 7, 

# 963,747 891,969 $ 

# 312,189,663 307,

082,164 $ 

# 37,251,216 35,1

95,063 $ 

# 349,440,87

9 342,277,228

Notes: Values may not sum to totals due to rounding



# 1387 Formatted Table

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# Page 108 of 118 Exhibit 6-30: Total Incremental Burden and Costs, by Geographic Location ($2010)

Geographic Location of

Respondents Labor Non-Labor

Cost Total Incremental

Cost Hours Cost

Year 1

Domestic Respondents 7, 

# 935,088 928,2

88 $420, 

# 694,153 2

08,903 $21, 

# 799,672 5

80,413 $ 

# 442,493,825 441,7

89,316

Foreign Respondents 3, 

# 153,692 082,8

28 $ 

# 121,134,32

7 116,077,473 $ 

# 26,788,780

24,182,083 $ 

# 147,923,107 140,2

59,556

Total Respondents 11, 

# 088,777 011,

115 $ 

# 541,828,31

0 536,286,350 $ 

# 48,588,453

45,762,496 $ 

# 590,416,763 582,0

48,846

Years 2 and 3

Domestic Respondents 1, 

# 860,216 854,3

47 $54, 

# 789,167 37

0,354 $6, 

# 873,711 81

7,285 $61, 

# 662,878 187,639

Foreign Respondents 1, 

# 393,518 333,4

75 $ 

# 44,690,540 4

0,405,872 $ 

# 7,251,002 6,

506,816 $ 

# 51,941,542 46,912,

688

Total Respondents 3, 

# 253,732 187,8

21 $ 

# 99,479,608 9

4,776,198 $ 

# 14,124,713

13,324,101 $ 

# 113,604,321 108,1

00,299

Three Year Average

Domestic Respondents 3, 

# 884,972 878,7

93 $176, 

# 745,392 3

16,534 $11, 

# 848,570 7

38,328 $188, 

# 593,962 054,86

3

Foreign Respondents 1, 

# 980,186 916,5

36 $ 

# 70,169,347 6

5,629,736 $ 

# 13,763,049

12,398,573 $ 

# 83,932,396 78,028,

310

Total Respondents 5, 

# 865,153 795,3

29 $ 

# 246,914,48

0 241,946,249 $ 

# 25,611,620

24,136,899 $ 

# 272,526,100 266,0

83,149

Notes: Values may not sum to totals due to rounding



# 1388

1389 Formatted Table

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# Page 109 of 118 

# 1390

6(c) Estimating Agency Burden and Cost 1391

1392

EPA resources would be devoted to reviewing and analyzing data submissions, compiling 1393

and recording data, maintainin g hard-copy files of submitted data, auditing and inspecting 1394

facilities, producing audit and inspection reports , responding to public inquiries, and providing 1395

regulatory interpretations . EPA anticipates that these activities will require the equivalent of one 1396

full-time employee (FTE) at Headquarters. Using the 2010 Washington/Baltimore area annual 1397

salary rate for a GS-13, Step 5 employee ($100,904), and multiplying by a loading factor of 1.6 1398

to reflect overhead and fringe benefits results in an estimated EPA cost of $161,446 per year. 1399

1400

6(d) Bottom Line Burden Hours and Costs/Master Table 1401

1402

Exhibit 6-31 presents the frequency for each of the respondent activities assumed in the 1403

bottom line burden hour and cost tables. Exhibit 6-32 and Exhibit 6-33 present the respective 1404

total and incremental bottom line burden and costs, by activity frequency and respondent type. 1405

In Exhibit 6-32, all activities of a given frequency that a single respondent performs are 1406

accounted for as a single response for that time period. For example, if a respondent performs 1407

two different quarterly activities per quarter this is accounted for as a single response per quarter 1408

or four responses per year (e.g., paying the large scale testing fee and paying shipment costs for 1409

large scale testing is counted as a single response not two separate responses). 1410

1411

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 110 of 118 

# 1412

Exhibit 6-31: Frequency of Activities

Activity Assumed Activity Frequency 1



# 1. Rule Familiarization

Producers One-Time

Fabricators One-Time

Wholesalers One-Time

Retailers One-Time

2. Certification Fee

Standard Annual

New NAF Annual

Existing NAF/ULEF Annual

3. Initial On-site Audit

With Existing Certifications One-Time

Without Existing Certifications One-Time

4. Develop Quality Cont rol Manual One-Time

5. Qualifying Test

1 Product One-Time

2 Products One-Time

6. Qualifying Test Shipping

1 Product One-Time

2 Products One-Time

7. Correlation Test

1 Product One-Time

2 Products One-Time

8. Quarterly On-site Audit

Standard Quarterly

NAF (With New Certification) Annual

NAF (Existing Certifications Only) Annual

9. Large Scale Testing Fee

1 Product with Standard Certification (Existing) Quarterly

2 Products with Standard Certification (New) Quarterly

2 Products with Standard Certification (Existing) Quarterly

1 Product with NAF Ce rtification Annual

2 Product with NAF Ce rtification Annual

10. Quarterly On-site Audit Shipment

Standard Certification Quarterly

NAF (With New Certification) Annual

NAF (With Existing Certification) Annual

10a. Large Scale Testing Shipment

1 Product with Standard Certification (Existing) Quarterly

2 Products with Standard Certification (New) Quarterly

2 Products with Standard Certification (Existing) Quarterly

1 Product with NAF Ce rtification Annual

2 Product with NAF Ce rtification Annual

1 ULEF and 1 NAF Certification Annual

11. On-site Audit Travel Annual

12. Desk Audits

Standard Annual

NAF (With New Certification) Annual

13. Purchase of Small Chamber Testing Unit One-Time

14. Quality Control Testing - HWPW

Standard Certification Daily

New NAF Certification One-Time

15. Lost Product

2 Products with Standard Certification (HWPW - Existing) Daily

2 Products with Standard Certification (HWPW - New) Daily

2 Products with ULEF Certification (HWPW - New) Annual

1 ULEF and 1 NAF Certification (HWPW - Existing)

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 111 of 118 Exhibit 6-31: Frequency of Activities

Activity Assumed Activity Frequency 1



# 1 Product with NAF Certificat ion (HWPW - New) Annual

1 Product with NAF Certificati on (HWPW - Existing) Annual

2 Products with NAF Certification (HWPW - New) Annual

2 Products with NAF Certification (HWPW - Existing) Annual

1 Product with Standard and 1 NAF Certification (PB/MDF -

Existing) Daily

2 Products with Standard Certification (PB/MDF - New) Daily

2 Products with Standard Certification (PB/MDF - Existing) Daily

1 Product with NAF Certificat ion (PB/MDF - New) Annual

1 ULEF and 1 NAF Certification (PB/MDF - Existing) Annual

1 Product with NAF Certificati on (PB/MDF - Existing) Annual

2 Products with NAF Certification (PB/MDF - Existing) Annual

16. Initial Recordkeeping One-Time

17. Recurring Recordkeeping

Producers Annual

Fabricators Annual

Wholesalers Annual

Retailers Annual

18. Initial Labeling

Minor Changes - Producers One-Time

Minor Changes - Fabricators One-Time

Major Changes - Producers One-Time

Major Changes - Fabricators and Wholesalers One-Time

1 

# This represents the activity frequency assumed for th e purpose of the calculations in Exhibit 6-33 (which

classifies activities as one-time, annual, quarterly, or da ily), not the frequency required by the rule. For example,

the rule requires panel producers to be certified by a TPC every two years. Exhibit 6-33 assumes that

certification occurs annually but halves the average burden per response, so that the total burden is unchanged.



# 1413

1414

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 112 of 118 Exhibit 6-32: Summary of Three Year Average Total (including baseline) Burden and Costs, by

Geographic Location ($2010)

Response and

Res p ondent T yp e Number of

Res p ondents Average Responses

p er Res p ondent Average Burden per

Res p onse (hours) Total Burden Total Cost

Domestic

Producers

One-Time 370 0.3333 

# 140.8681 138.5895 17, 

# 372 091 $2, 

# 361,644 293,200

Annual 370 1.0000 59. 

# 6811 2649 

# 22,082

21,928 $ 

# 5,026,015 4,975,931

Quarterly 370 4.0000 3. 

# 7797 6784 5, 

# 594 444 $2, 

# 085,323 056,416

Daily 370 260.0000 1. 

# 8324 7730 

# 176,280

170,560 $ 

# 15,210,894 14,738,661

Fabricators

One-Time 79,701 0.3333 

# 25.7560

26.8287 

# 684,190

712,687 $ 

# 34,047,670 35,348,387

Daily 79,701 1.0000 24.1482 1,924,638 $47,808,008

Wholesalers

One-Time 85,560 0.3333 

# 10.9281 9.9288 

# 311,639

283,142 $ 

# 19,115,185 17,819,748

Annual 85,560 1.0000 9.8697 844,448 $21,567,202

Retailers

One-Time 759,048 0.3333 4.0000 1,011,963 $71, 

# 555,904 563,045

Annual 1 

# 759,048 1.0000 - - -

Total 924,679 4, 

# 998,206

991,901 $218, 

# 777,845 170,598

Forei g n

Producers

One-Time 1,129 0.3333 

# 76.8279 68.7385 

# 28,910

25,866 $3, 

# 888,772 142,139

Annual 1,129 1.0000 

# 58.6873 57.2728 

# 66,258

64,661 $14, 

# 680,318 142,927

Quarterly 1,129 4.0000 

# 2.6050 2.2611 

# 11,764

10,211 $4, 

# 693,501 394,614

Daily 1,129 260.0000 

# 1.2631 1.0611 

# 370,760

311,480 $ 

# 30,709,062 25,732,711

Fabricators

One-Time 31,083 0.3333 

# 25.7470 26.8215 

# 266,738

277,870 $13, 

# 274,319 782,371

Daily 31,083 1.0000 24.2524 753,838 $18,725,336

Wholesalers

One-Time 33,368 0.3333 

# 26.1753 25.1744 

# 291,110

279,978 $14, 

# 652,563 147,271

Annual 33,368 1.0000 

# 35.2483 1,176,164 $30,039,228

Retailers

One-Time - 0.3333 - - - Formatted Table

Formatted Table

Formatted Table

Formatted Table

Formatted Table

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 113 of 118 

# 1415 Total 65,580 2, 

# 965,542

900,068 

# $130,663,099 124,106,

597

Total

Producers

One-Time 1,499 0.3333 

# 92.6350 85.9799 

# 46,282

42,957 $ 

# 6,250,415 5,435,343

Annual 1,499 1.0000 

# 58.9326 57.7645 

# 88,340

86,589 $19, 

# 706,338 118,857

Quarterly 1,499 4.0000 

# 2.8949 2.6109 

# 17,358

15,655 $6, 

# 778,822 451,032

Daily 1,499 260.0000 

# 1.4036 1.2368 

# 547 482 ,040 $ 

# 45,919,953 40,471,373

Fabricators

One-Time 110,784 0.3333 

# 25.7534 26.8267 

# 950,926

990,557 $ 

# 47,321,899 49,130,759

Daily 110,784 1.0000 24.1775 2,678,476 $66,533,344

Wholesalers

One-Time 118,928 0.3333 

# 15.2061 14.2063 

# 602,749

563,120 $ 

# 33,767,748 31,967,019

Annual 

# 99,908 118 118 ,92

8 1.0000 

# 20.2247

16.9902 2,020, 

# 613

612 $51,606,456

Retailers

One-Time 759,048 0.3333 4.0000 1,011,963 $71, 

# 555,904 563,045

Annual 1 

# 759,048 1.0000 - - -

Total 990,259 7, 

# 963,747

891,969 $ 

# 349,440,879 342,277,2

28

1. Retailers are assumed not to import produ cts directly, in which case they are only required to keep invoices and bills of la ding.

These records are typically kept as a customary business practice, so no annual burden is attributed to retailers. Formatted Table

Formatted Table

Formatted Table

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 114 of 118 Exhibit 6-33: Summary of Three Year Average Total Incremental Burden and Costs, by Geographic

Location ($2010)

Response

and

Respondent

Type Number of

Respondents Average

Activities per

Respondent Average Burden

per Response

(hours) Total

Burden Total Cost

Domestic

Producers

One-Time 370 0.3333 

# 140.8681

138.5895 17, 

# 372

091 $2, 

# 349,345 280,900

Annual 370 1.0000 58. 

# 3811 3027 21, 

# 601

572 $4, 

# 317,674 282,669

Quarterly 370 4.0000 3. 

# 1892 0885 4, 

# 720 571 $1, 

# 930,023 904,517

Daily 370 260.0000 1. 

# 5568 4973 

# 149,760

144,040 $ 

# 13,083,250 12,660,686

Fabricators

One-Time 79,701 0.3333 

# 25.7560

26.8287 

# 684,190

712,687 $ 

# 34,047,670 35,348,387

Annual 47,540 1.0000 24.2646 1,153,539 $28,653,909

Wholesalers

One-Time 85,560 0.3333 

# 10.9281 9.9288 

# 311,639

283,142 $ 

# 19,115,185 17,819,748

Annual 

# 23,102 53,73

1 85,560 1.0000 

# 22.9499 9.867

5 0.0002 530,188 $13,541,002

Retailers

One-Time 759,048 0.3333 4.0000 1,011,963 $71, 

# 555,904 563,045

Annual 1 

# 658,150 1.0000

- - -

Total 924,679 3,884,972 $188,593,962

Foreign

Producers

One

- Time 1,129 0.3333 76.8279 28,910 $3,774,183

Annual 1,129 1.0000 54.8654 61,943 $8,201,018

Quarterly 1,129 4.0000 0.9035 4,080 $1,784,589

Daily 1,129 260.0000 0.4748 139,360 $12,217,739

Fabricators

One

- Time 31,083 0.3333 25.7470 266,738 $13,274,319

Annual 18,476 1.0000 24.3314 449,547 $11,166,747

Wholesalers

One

- Time 33,368 0.3333 26.1753 291,110 $14,652,563

Annual 20,955 1.0000 35.2421 738,498 $18,861,239

Retailers

One

- Time

- 0.3333

- - -

Total 65,580 ,980,186 83,932,397

Total

Producers

One

- Time 1,499 0.3333 92.635 46,282 $6,123,528

Annual 1,499 1.0000 55.7325 83,543 $12,518,622

Quarterly 1,499 4.0000 1.4675 8,799 $3,714,540

Daily 1,499 260.0000 0.7418 289,120 $25,300,988 Formatted Table

Formatted Table

Formatted Table

Formatted Table

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 115 of 118 Fabricators

One

- Time 110,784 0.3333 25.7534 950,926 $47,321,899

Annual 66,016 1.0000 24.2833 1,603,086 $39,820,656

Wholesalers

One

- Time 118,928 0.3333 15.2061 602,749 $33,767,748

Annual 74,686 1.0000 39.5069 16.9869 1,268,685 $32,402,215

Retailers

One

- Time 759,048 0.3333 4.0000 1,011,963 $71,555,904

Annual 1 

# 658,150 1.0000

- - -

Total 924,679 3,878,793 $188,054,863

Forei g n

Producers

One-Time 1,129 0.3333 68.7385 25,866 $3,027,539

Annual 1,129 1.0000 55.0540 62,156 $7,936,610

Quarterly 1,129 4.0000 0.5627 2,541 $1,520,865

Daily 1,129 260.0000 0.2728 80,080 $7,585,668

Fabricators

One-Time 31,083 0.3333 26.8215 277,870 $13,782,371

Annual 18,476 1.0000 24.3314 449,547 $11,166,747

Wholesalers

One-Time 33,368 0.3333 25.1744 279,978 $14,147,271

Annual 20,955 1.0000 35.2421 738,498 $18,861,239

Retailers

One-Time

- 0.3333

- - -

Total 65,580 1,916,536 78,028,310

Total

Producers

One-Time 1,499 0.3333 85.9799 42,957 $5,308,443

Annual 1,499 1.0000 55.8559 83,728 $12,219,276

Quarterly 1,499 4.0000 1.1861 7,112 $3,425,382

Daily 1,499 260.0000 0.5751 224,120 $20,246,354

Fabricators

One-Time 110,784 0.3333 26.8267 990,557 $49,130,759

Annual 66,016 1.0000 24.2833 1,603,086 $39,820,656

Wholesalers

One-Time 118,928 0.3333 14.2063 563,120 $31,967,019

Annual 74,686 1.0000 16.9869 1,268,686 $32,402,215

Retailers

One-Time 759,048 0.3333 4.0000 1,011,963 $71,563,045

Annual 1 

# 658,150 1.0000

- - -

Total 990,259 5, 

# 865,15

3 795,329 

# 272,526,100

$266,083,149

1. Retailers are assumed not to import produ cts directly, in which case they are only required to keep invoices and bills of la ding.

These records are typically kept as a customary business practice, so no annual burden is attributed to retailers.



# 1416

1417

6(e) Reasons for Changes in Burden 1418

1419

Not applicable. These are new requirements so there was no previous ICR. 1420

1421

6(f) Burden Statement 1422

1423

The annual public burden for this collection of information, which is approved under 1424

OMB Control No. xxxx-xxxx, is estimated to be 4. 64 60 hours per response (i.e., 1425 Formatted Table

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 116 of 118 

# 7, 963,747 891,969 burden hours for an estimated 1,716,048 responses). 27 

# According to the 1426

Paperwork Reduction Act, “burden” means the total time, effort, or financial resources expended 1427

by persons to generate, maintain, retain, or disclose or provide information to or for a Federal 1428

agency. For this collection it includes su ch activities as annual familiarization with 1429

requirements, recordkeeping, notification, and reporting requirements. An agency may not 1430

conduct or sponsor, and a person is not required to respond to, a collection of information unless 1431

it displays a currently valid OMB control number. The OMB control numbers for EPA’s 1432

regulations in title 40 of the CFR, after appeari ng in the Federal Register, are listed in 40 CFR 1433

part 9 and included on the related collection instrument or form, if applicable. 1434

1435

To comment on the Agency’s need for this information, the accuracy of the provided 1436

burden estimates, and any suggested methods for minimizing respondent burden, including the 1437

use of automated collection techniques, EPA has established a public docket for this ICR under 1438

Docket ID No. EPA-HQ-OPPT- XXXX

- XXXX 2012-0018 . The docket is available for public 1439

viewing at the Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). 1440

The EPA/DC Public Reading Room is located in the EPA West Building, Room 3334, 1301 1441

Constitution Ave., NW., Washington, DC. The EPA/DC Public Reading Room is open from 1442

8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number 1443

for the EPA/DC Public Reading Room is (202) 566-1744, and the telephone number for the 1444

Pollution Prevention and Toxics Docket is (202) 566-0280. An electronic version of the public 1445

docket is available through the Federal Docket Management System (FDMS) at 1446

www.regulations.gov. Use FDMS to submit or view public comments, access the index listing 1447

of the contents of the public docket, and to access those documents in the public docket that are 1448

available electronically. Once in the system, sel ect “search,” then key in the docket ID number 1449

identified above. Also, you can send commen ts to the Office of Information and Regulatory 1450

Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, 1451

Attention: Desk Office for EPA. Please include the EPA Docket ID No. EPA-HQ-OPPT1452

XXXX

- XXXX 2012-0018 and OMB control number xxxx-xxxx in any correspondence. 1453

1454

1455

1456

27 

# The total number of responses is calculated by taking the sum of the products of the number of respondents and the number of

responses presented in Exhibit 6-32.

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 117 of 118 

# References 1457

1458

California Air Resources Board. 2011. CARB List of Certified Mills

. 

# 1459

Composite Panel Association. 2011. 2011 Surface & Panel Buyers Guide

. 

# 1460

Personal Communication with AHFA. 2010. Conversation between Bill Perdue (American Home 

# 1461

Furnishings Alliance) and Abt Associates Inc. November 3, 2010. 

# 1462

Personal Communication with BIFMA. 2010. Brad Miller's (BIFMA) Written Responses to Questions 

# 1463

about FSCWPA Impacts on Members . November 23, 2011. 

# 1464

Personal Communication with CRA. 2011. Conversation between Pamela Williams (California Retailers 

# 1465

Association) and Abt Associates Inc. January 20, 2011. 

# 1466

Personal Communication with HPVA. 2011. Conversation between Kip Howlett (HPVA) and Abt 

# 1467

Associates Inc. January 4, 2011. 

# 1468

U.S. Bureau of Labor Statistics (BLS). 2009. Occupational Employment Statistics 2009 Mean Hourly 

# 1469

Wages

. 

# 1470

U.S. Bureau of Labor Statistics (BLS). 2011. BLS Employer Cost for Employee Compensation (ECEC) 

# 1471

Data for all private industry for 2009-2010

. 

# 1472

U.S. Census Bureau. 1997. 1992 Enterprise Statistics: Company Summary

. 

# 1473

U.S. Census Bureau. 2009. Sector 42: EC0742I1: Wholesale Trade: Industry Series: Preliminary Summary 

# 1474

Statistics for the United States: 2007

. 

# 1475

U.S. Census Bureau. 2010a. Sector 44: EC0744SLLS1: Retail Trade: Subject Series - Product Lines: 

# 1476

Product Lines Statistics by Kind of Busine ss for the United States and States: 2007

. 

# 1477

U.S. Census Bureau. 2010b. Sector 31: EC0731SG3: Manufacturing: Summary Series: General Summary: 

# 1478

Industry Statistics for Subsectors and Industries by Employment Size: 2007. 

# 1479

U.S. Census Bureau. 2010c. Sector 44: EC0744SSSZ3: Retail Trade: Subject Series - Estab & Firm Size: 

# 1480

Summary Statistics for Single Unit and Multiunit Firms for the United States: 2007

. 

# 1481

U.S. Census Bureau. 2010d. Sector 42: EC0742A1: Wholesale Trade : Geographic Area Series: Summary 

# 1482

Statistics for the United States

. 

# 1483

U.S. Census Bureau. 2010e. Sector 31: EC0731A1: Manufacturing: Geographic Area Series: Industry 

# 1484

Statistics for the States

. 

# 1485

U.S. Census Bureau. 2010f. Sector 42: EC0742SSSZ5: Wholesale Trade: Subject Series - Estab & Firm 

# 1486

Size: Summary Statistics by Employment Size of Firms for the United States: 2007

. 

# 1487

U.S. Census Bureau. 2010g. Sector 44: EC0744SSSZ4: Retail Trade: Subject Series - Estab & Firm Size: 

# 1488

Summary Statistics by Sales Size of Firms for the United States: 2007

. 

# 1489

U.S. Census Bureau. 2010h. Sector 00: NS0800A1: 2008 Nonemployer Statistics: Geographic Area Series: 

# 1490

Nonemployer Statistics by Legal Form of Organization: 2008 

# 1491

U.S. Census Bureau. 2010i. Data Item: Wholesale type of operation.” American FactFinder Help. Census 

# 1492

Data Information

. 

# 1493

U.S. Census Bureau. 2010j. Sector 42: EC0742SSSZ3: Wholesale Trade: Subject Series - Estab & Firm 

# 1494

Size: Summary Statistics for Single Units and Multiunit Firms for the United States: 2007

. 

# 1495

U.S. Census Bureau. 2010k. Statistics for U.S. Businesses (SUSB). Number of Firms, Number of 

# 1496

Establishments, Employment, Annual Payroll, and Estim ated Receipts by Enterprise Receipt Size for the 

# 1497

United States, All Industries: 2007 . December 15, 2010. 

# 1498

U.S. Census Bureau. 2010l. Sector 44: EC0744A1: Retail Trade: Geographic Area Series: Summary 

# 1499

Statistics for the United States, States, Metro Areas, Counties, and Places: 2007

. 

# 1500

# *** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***



# Page 118 of 118 U.S. Census Bureau. 2011. Sector 42: EC0742SLLS1: Wholesale Trade: Subject Series - Product Lines: 

# 1501

Product Lines Statistics by Kind of Busine ss for the United States and States: 2007

. 

# 1502

U.S. Internal Revenue Service. 2007. Starting a Business and Keeping Records . Publication 583. Revised 

# 1503

January 2007. 

# 1504

U.S. International Trade Commission. 2011. U.S. Interactive Tariff and Trade Dataweb

. 

# 1505

1506

1507