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1 EO12866_RIN2070-AJ92_Formaldehyde-Imp_NPRM_ICR_2012-01-27.docx 

2 

3 Supporting Statement for OMB Review under 

4 the Paperwork Reduction Act 

5 

6 1. IDENTIFICATION OF THE INFORMATION COLLECTION 

7 

8 l(a) Title of the Information Collection 

9 

10 TITLE: ICR for Proposed Rule Implementing the Formaldehyde Emissions 

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

12 

13 EPA ICR No.: 2446.01 

14 

15 OMB Control No.: 2070-NEW 

16 

17 1(b) Short Characterization

18 

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

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

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

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

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

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

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

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

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

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

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

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

31 this third-party certification program. A separate information collection request covers those 

32 recordkeeping and reporting requirements. 

33 

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

35 this information collection request include: 

36 

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

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

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

40 

41 Examples of proposed recordkeeping requirements include: 

42 

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

44  Records of quality control manuals 

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

46  Records on the disposition of non-compliant lots 
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47  Chain of custody recordkeeping requirements for importers, fabricators, and laminated 

48 products producers 

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

50 wholesalers and retailers 

51  Minimized requirements for non-importing distributors and retailers 

52 

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

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

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

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

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

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

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

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

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

62 Part 2. 

63 

64 2. NEED FOR AND USE OF THE COLLECTION

65 

66 2(a) Need/Authority for the Collection

67 

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

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

70 compliance with the emissions standards, including provisions on testing requirements, 

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

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

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

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

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

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

77 statute and regulations. 

78 

79 2(b) Use of the Data

80 

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

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

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

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

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

86 VI requirements. TSCA Title VI also directs EPA to include labeling provisions. The 

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

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

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

90 offered for sale in the United States. 

91 

92 
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93 

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

95 

96 3(a) Non-Duplication 

97 

98 TSCA Title VI assigns to the EPA Administrator the responsibility for promulgating 

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

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

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

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

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

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

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

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

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

108 

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

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

111 EPA to rely on to ensure compliance with the emissions standards. 

112 

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

114 

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

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

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

118 rulemaking. 

119 

120 3(c) Consultations

121 

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

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

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

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

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

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

128 

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

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

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

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

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

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

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

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

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

138 
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139 EPA convened a Small Business Advocacy Review Panel and hosted two panel outreach 

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

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

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

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

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

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

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

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

148 

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

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

151 Supporting Statement as needed. 

152 

153 3(d) Effects of Less Frequent Collection

154 

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

156 minimum amount necessary to fulfill its statutory mandate to promulgate regulations that ensure 

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

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

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

160 in uncertified and noncompliant products being distributed in commerce in violation of the 

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

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

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

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

165 compliance with the statutory emission standards. 

166 

167 3(e) General Guidelines

168 

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

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

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

172 described below: 

173 

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

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

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

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

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

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

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

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

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

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

184 necessary because the recession increased the amount of time manufacturers needed to clear 
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185 preexisting inventory. (See, e.g., Composite Wood Products Regulation Advisory: 11-01, 

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

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

188 1 Particleboard and Medium Density Fiberboard Panels, available at 

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

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

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

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

193 

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

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

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

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

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

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

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

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

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

203 and retesting these products. 

204 

205 3(f) Confidentiality

206 

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

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

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

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

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

212 confidential nature. 

213 

214 3(g) Sensitive Questions

215 

216 EPA asks no questions of a sensitive nature. 

217 

218 4. THE RESPONDENTS AND THE INFORMATION REQUESTED

219 

220 4(a) Respondents/NAICS Codes 

221 

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

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

224 products. 

225 

226 The following NAICS codes may be affected: 

227 

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

229  Reconstituted Wood Product Manufacturing (NAICS code 321219); 

230  All Other Miscellaneous Wood Product Manufacturing (NAICS code 321999); 
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231  Furniture and Related Product Manufacturing (NAICS code 337); 

232  Miscellaneous Manufacturing (NAICS code 339); 

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

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

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

236 

237 4(b) Information Requested

238 

239 (i) Data Items

240 

241 The proposed recordkeeping requirements and reporting requirements include: 

242 

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

244 accomplish the following reporting tasks: 

245 

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

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

248 

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

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

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

252 

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

254 in writing within 24 hours. 

255 

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

257 information to entities other than EPA as follows: 

258 

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

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

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

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

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

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

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

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

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

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

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

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

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

272 

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

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

275 

276  Composite wood product panel producers must provide their third-party certifier with a 
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277 monthly product data reports that include production information and quality control test 

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

279 

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

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

282 change. 

283 

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

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

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

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

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

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

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

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

292 continued compliance with the reduced formaldehyde emission standards for each 

293 product type. 

294 

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

296 producer’s name (or number), lot or batch number, the number of the accredited third297 party certifier, and markings indicating that the product complies with the TSCA Title VI 

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

299 requirements based on the use of no-added formaldehyde resins must also be marked 

300 with indications that they were produced using no-added formaldehyde resins. Boards 

301 that are shipped into the United 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 the following records for at least five 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 conducting or overseeing the testing 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. 
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322 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 continued 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. 
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368 

369 

370 5. THE INFORMATION COLLECTION — AGENCY ACTIVITIES, COLLECTION 

371 METHODOLOGY, AND INFORMATION MANAGEMENT

372 

373 5(a) Agency Activities

374 

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

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

377 inquiries, providing regulatory interpretations and developing rulemakings. 

378 

379 5(b) Collection Methodology and Management

380 

381 5(c) Small Entity Flexibility

382 

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

384 information collections would apply to all entities that manufacture (including import), sell, 

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

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

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

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

389 regulatory flexibility alternatives to alleviate burden on small business. EPA seeks to implement 

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

391 bundle, as opposed to individual boards. EPA is also requiring quality control tests for 

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

393 fewer tests. 

394 

395 5(d) Collection Schedule

396 

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

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

399 basis rather than by specific dates. 

400 

401 6. ESTIMATING BURDEN AND COST OF THE COLLECTION 

402 

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

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

405 Title VI Implementation Rule. This supporting statement provides average annual burden and 

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

407 dollars. 

408 

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

410 Note that not all entities will incur burden or costs from these activities because they may already 

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

412 labeling systems may already be sufficient. 

413 
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414  Rule Familiarization: All respondents will need to read the rule in order to understand 

415 the requirements; 

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

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

418 from an accredited third-party certifier (TPC). These entities must undergo qualifying 

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

420 and train quality control employees in order to receive initial certification. Once 

421 certified, a mill is required to conduct on-going small scale quality control testing, submit 

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

423 chamber testing to maintain its certified status. Mills that produce products made with 

424 NAF resins that meet more stringent emissions limits may apply for exemptions from 

425 some of the on-going testing requirements; 

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

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

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

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

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

431 required to maintain invoices and bills of lading; and 

432  Labeling: Firms that package or repackage composite wood products or finished goods 

433 containing composite wood products will need to modify their labels to include their 

434 name, the date the finished good was produced, and a statement of compliance. 

435 

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

437 result of the proposed rule: 

438 
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Exhibit 6-1: Summary of Recordkeeping and Reporting Activities, by Sector and Activity 

Activity 

Composite Panel Producer

Fabricator 

Wholesaler 

Retailer Standard 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 Audit1 Quarterly Annual - - - -

9. Large Scale Testing Fee2 Quarterly Annual - - - -

10. Large Scale Testing Shipment2 Quarterly Annual - - - -

11. On-site Audit Travel3 Annual - - - -

12. Desk Audits4 8 per year - - - - -

13. Purchase of Small Chamber 

Testing Unit5 1-time - - - - -

14. Quality Control Testing6 Daily - - - -

15. Lost Product7 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 producers with new NAF certifications will incur the burden associated with one on-site audit (in addition to 

the initial audit) in the first year. The initial on-site audit is assumed to be sufficient for producers with existing NAF certifications. All NAFcertified producers will have one on-site audit annually thereafter. 

2. Mills are required to perform large scale testing quarterly unless all products are certified as NAF. It is assumed that mills with only NAFcertified products will perform large scale testing annually. In the first year, mills with added-formaldehyde products will 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. It is assumed that travel is only necessary for the annual audits, as other intermediate audits can be performed by contracting inspectors closer 

to the mill. 

4. Desk audits are assumed to occur monthly except in months without 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. NAF-certified producers will not have any desk audits in 

subsequent years. 

5. This analysis assumes that mills with standard 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 scale testing facility on-site. Mills with NAF 

certification only require weekly testing for the first three months of certification; as a result, it is assumed that these mills will outsource their 

testing. 

6. Particleboard and MDF mills are required to test samples at least once per eight or twelve hour shift, but the frequency is reduced 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 feet of 

production to as much as four tests per week. This analysis makes the simplifying assumption that all panel producers 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. Mills will need to forfeit a number of panels for initial and on-going testing. Mills are expected to ship five 4’ x 8’ panels per product type for 

qualifying testing. All producers 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.

439 

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

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

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

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

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

445 articles in the shipment either comply with all applicable rules and orders under TSCA or that all 
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446 the articles in the shipment are not subject to TSCA. The statement must be on or attached to a 

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

448 certification is fulfilled by checking a box on an invoice or entry document. It is assumed that 

449 this does not generally impose a significant additional burden or cost on the importer. Any 

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

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

452 

453 Exhibit 6-2 summarizes the activities that have reporting and recordkeeping burden hours 

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

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

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

457 section 6(b). Exhibit 6-2 also summarizes the baseline calculations for this ICR analysis. Many 

458 panel producers are already engaged in these activities because their products are certified under 

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

460 requirements both with and without accounting for this baseline. 

461 

 This analysis assumes that mills making product lines that have a standard certification1 462 

463 or a NAF certification under the CARB ATCM will not need to submit new data or resubmit 

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

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

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

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

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

469 

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

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

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

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

474 baseline included activities performed to comply with the CARB ATCM. As a result, the 

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

476 TSCA rule. 

477 

 

1

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

NAF certification. The proposed rule does not provide for reduced testing frequencies for products made with ULEF resins, so 

mills that have a ULEF certification under the CARB ATCM will incur additional costs under the TSCA Title VI rule. 
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Exhibit 6-2: Summary of 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 the 

TSCA Title VI rule. The incremental burden and cost excludes future 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. 

478 

479 6(a) Estimating Respondent Burden

480 

481 (i) Number of Respondents 

482 

483 Since the rule applies to products imported into the U.S., the certification, testing, 

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

analysis estimates both domestic and foreign entities.2 485 The number of respondents is estimated 

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

487 

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

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

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

exporting to the U.S. is based on the number of foreign mills on the CARB list of certified mills.3 491 

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

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

 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. 3 California Air Resources Board 2011.
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494 the analysis assumes the number of foreign mills that are not currently certified under the CARB 

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

496 foreign mills certified under the CARB ATCM. 

497 

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

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

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

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

502 most domestic laminators not already using NAF resins will switch to them so that their products 

503 will be exempted from the definition of hardwood plywood. However, two percent of wood 

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

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

506 remaining wood veneer laminated product producers (13,597 entities) make products that will 

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

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

509 described in greater detail in the Economic Analysis. 

510 

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

and retail trade firms was estimated using employer and nonemployer data from the Census.4 512 

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

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

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

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

517 Lines Subject Series were used to estimate the percentage of wholesalers and retailers that sell 

composite wood products in affected industries.5 518 

519 

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

521 ratio of the total customs value of imports for the affected fabricator NAICS to the total domestic 

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

523 sector. In addition, the percentage of domestic wholesalers that import composite wood products 

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

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

526 Exhibit 6-3 presents the customs value of imports and the domestic value of shipments for the 

527 affected industries. 

528 

 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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Exhibit 6-3: Customs Value of Imports and Domestic 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 

529 

530 As indicated in Exhibit 6-3. imports are 39.0 percent of the U.S. value of shipments for 

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

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

533 (31,083 foreign fabricators compared to 79,701 domestic fabricators). Similarly, it is assumed 

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

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

536 subject to the rule (33,368 foreign wholesalers compared to 85,560 domestic wholesalers). The 

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

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

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

540 analysis does not estimate that number. 

541 

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

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

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

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

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

547 the 85,560 domestic wholesalers import composite wood products. Since the number of 
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548 wholesalers that import products is estimated using the total customs value of imports (which 

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

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

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

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

553 burden for fabricators is estimated separately). 

554 

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

Sector Domestic 

Respondents 

Foreign 

Respondents1

Total 

Respondents 

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 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 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 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

555 

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

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

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

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

560 and 0.2 percent of the total number of respondents, respectively. 

561 

562 (ii) Burden Per Respondent 

563 

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

565 respondents as a result of the proposed TSCA Title VI rule. Respondent activities are presented 

566 separately for each unique combination of (1) responses per respondent and (2) per-response 
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567 burden that is accounted for in this analysis. For example, while all composite panel producers 

568 are required to have an on-site audit performed quarterly, those with NAF certification are 

569 exempt from subsequent audits after three months of routine small scale testing and one quarterly 

570 test. As a result, even though these audits are assumed to take the same amount of time for all 

571 producers (four managerial-level hours), they are presented as separate activities because they 

572 require a different number of annual responses, depending on the certification type. The section 

573 begins with a description of activities that are common to all respondents, and then separately 

574 discusses the activities by category of respondents (composite panel producers, fabricators, 

575 wholesalers, and retailers). 

576 

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

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

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

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

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

582 affected sectors. For example, this analysis assumes that 1 of the 30 domestic particleboard 

583 respondents (or 3.3 percent) and 2 of the 22 domestic MDF respondents (or 9.1 percent) will 

584 switch from ULEF certification to standard certification as a result of the TSCA Title VI rule. 

585 As a result, it is assumed that 6 certified foreign particleboard respondents (3.3 percent of 173) 

586 and 26 certified foreign MDF respondents (9.1 percent of 228) will switch from ULEF 

587 certification to standard certification as a result of the TSCA Title VI rule. 

588 

589 (A). All Respondents

590 

591 The burden associated with rule familiarization is presented first because this activity is 

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

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

594 sector. Since wood veneer laminated product producers will be defined as either hardwood 

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

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

597 

598 Rule Familiarization (Activity #1) 

599 

600 All entities will need to familiarize themselves with the proposed regulation and either 

601 ensure that their current systems are sufficient for the requirements or identify necessary 

602 changes. The analysis assumes that all respondents will spend 4.0 managerial labor hours on 

603 rule familiarization. This one-time burden is incurred during the first year. 

604 

605 (B). Composite Panel Producers

606 

607 In addition to rule familiarization, composite panel producers will also spend time on 

608 testing and certification, recordkeeping, and labeling activities. This analysis assumes that mills 

609 making product lines that have a standard certification or a NAF certification under the CARB 

610 ATCM will not need to submit new data or resubmit existing data to their existing TPC in order 

611 to receive the equivalent certification under the TSCA Title VI regulations. Thus, this ICR does 

612 not include burdens and costs for these reporting and recordkeeping activities where it is 
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613 assumed the activities were already performed to comply with the CARB ATCM and will not 

614 need to be performed again. This is consistent with the methodology used in the Economic 

615 Analysis for the proposed rule. However, this ICR does include the burdens and costs of 

616 required activities that will continue to be performed under the TSCA Title VI rule, even if those 

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

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

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

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

621 TSCA rule. 

622 

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

624 producers will continue to use added formaldehyde resins and thus be classified as hardwood 

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

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

627 

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

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

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

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

632 certification. Once a TPC certifies a panel producer, that producer is required to conduct on633 going small scale quality control testing, submit monthly reports to the TPC, and receive 

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

635 that make products with NAF resins and meet more stringent emissions limits may apply for 

exemptions from some of the on-going testing requirements.6 636 

637 

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

639 testing and one quarterly primary or secondary method test at the TPC. Product lines approved 

640 for NAF certification are exempt from routine small scale testing and quarterly primary or 

641 secondary method TPC testing for two years, after which point the mill may reapply for NAF 

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

643 this analysis assumes that NAF-certified mills will undertake a TPC audit annually. Where the 

644 frequency of testing is different for composite panel producers with NAF certification and 

645 standard certification, these groups are presented separately. 

646 

647 Initial On-site Audit (Activity #3) 

648 

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

650 the mill’s quality control systems and employees. During the initial visit, the TPC will assist the 

651 mill in setting up quality control systems, including the small scale testing facility, if applicable, 

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

653 visitation, though if the mill requires a substantial number of modifications or is unprepared, the 

duration of the visit may be longer.7 654 This analysis assumes that a managerial-level employee 

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

 6 The proposed rule does not provide for reduced testing frequencies for products made with ultra-low emissions formaldehyde 

(ULEF) resins. 

7 Personal Communication with HPVA 2011.
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656 initial quality control audit (see below) is sufficient for mills with existing CARB certifications. 

657 

658 Quality Control Systems Development (Activity #4) 

659 

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

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

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

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

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

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

666 manual. Prior to the mill’s initial certification, the TPC will assist mills in developing and 

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

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

669 

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

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

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

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

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

675 This analysis assumes that a managerial-level employee will spend forty hours training, 

676 becoming familiarized with the testing and certification requirements, writing the quality control 

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

678 with existing certifications will have quality control systems in place and so will not need to 

679 spend time on these activities. 

680 

681 Qualifying Test (Activities #5 and #6) 

682 

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

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

685 A TPC employee must select and mark the panels to be tested during the initial mill audit, with 

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

ship the marked panels to the TPC for large scale testing.8 687 Results from the five large chamber 

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

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

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

691 wrapped in polyethylene, and protected by cover sheets. The analysis assumes that it will take a 

692 managerial-level employee half an hour to prepare the panels for shipping. Producers that are 

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

694 will not incur this burden. 

695 

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

697 

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

 8

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

this analysis assumes that all qualifying testing is performed 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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699 least once quarterly, unless the mill obtains NAF certification. TPCs may also conduct periodic 

700 “desk audits,” which are quality control checks performed over the phone in which the mill’s 

701 small scale testing procedures and data are reviewed. Desk audits are assumed to occur monthly, 

702 except in months with quarterly on-site audits. This analysis assumes that a managerial-level 

703 employee will be present for four hours for every on-site quality control audit, and one hour for 

704 each desk audit. 

705 

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

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

708 year. The initial on-site audit is assumed to be sufficient for producers with existing NAF 

709 certifications. All NAF-certified producers will have one on-site audit annually thereafter. 

710 

711 Quality Control Testing (Activity #14) 

712 

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

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

715 desiccator test (ASTM D5582). These tests require smaller test samples and can be conducted at 

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

717 develop a statistical correlation between the large scale and small scale test methods using a 

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

719 qualifying testing, though it is possible that some mills may be able to use previous test results or 

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

721 small chamber test or three desiccator tests to calculate the correlation. This analysis assumes 

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

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

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

725 chamber tests. 

726 

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

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

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

730 lab, and the fees and shipping costs associated with hiring a third-party lab. According to CPA 

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

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

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

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

735 exemptions from some of the on-going testing requirements under the CARB ATCM.) However, 

736 the CARB ATCM allows mills to ship panels from certified product lines before test results are 

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

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

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

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

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

742 typically not ship any panels before test results have been determined for that lot, but other mills 

743 may ship out panels on the same day they are produced. This analysis assumes that all mills that 

744 have not already done so will opt to set up and operate a quality control testing facility on-site, in 
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745 order to minimize the time spent waiting for test results, and to maximize their flexibility to ship 

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

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

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

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

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

751 

752 The frequency of small scale testing without NAF certification depends on the product 

753 type and other factors. For hardwood plywood producers, the frequency of testing depends upon 

754 the volume of hardwood plywood produced weekly at each plant. Plants producing less than 100 

755 thousand square feet (msf) per week are required to test once per 100 msf. Plants producing 

756 between 100 msf and 200 thousand square feet (msf) per week are required to test once, plants 

757 producing between 200 msf and 400 msf per week are required to test twice per week, and those 

758 producing greater than 400 msf per week are required to test four times per week. Particleboard 

759 and MDF producers must test samples at least once per eight or twelve hour shift, but this 

760 frequency may be reduced to one test per forty-eight hours if the plant or production line has 

761 shown consistent operations and low variability of test results. This analysis makes the 

762 simplifying assumption that all producers will test each production line once daily. This results 

763 in a conservative estimate of the burden and cost of quality control testing for hardwood 

764 plywood producers. It is assumed that the quality control manager will spend two hours each 

765 day performing routine quality control testing. 

766 

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

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

769 perform 65 daily quality control tests (assuming that the plants are in operation 5 days per week). 

770 It is assumed that producers with existing NAF certifications will not incur the burden associated 

771 with initial quality control testing. NAF certified producers will not incur any additional burden 

772 associated with quality control testing in subsequent years. Note that the numbers of quality 

773 control testing responses are presented at the product line level; as a result, the per-response 

774 burdens have been modified accordingly. 

775 

776 Recurring Recordkeeping (Activity #17) 

777 

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

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

780 

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

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

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

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

785 that the tested material represents, the test method used, and the test results; 

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

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

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

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

790 number or batch produced; 
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791  Records demonstrating initial and continued eligibility for the reduced testing 

792 provisions for products made with no-added formaldehyde-based resins, if 

793 applicable; 

794  Records of changes in production, including changes in resin use, resin 

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

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

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

798 purchase order or invoice number, and amount purchased; 

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

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

801 available, and shipping invoice number; 

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

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

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

805  Copies of labels used; 

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

807 their premises; and 

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

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

810 quality control capacity. 

811 

812 Initial Labeling (Activity #18) 

813 

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

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

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

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

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

819 

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

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

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

823 hours of technical labor) (see below). 

824 

825 (C) Fabricators

826 

827 While all fabricators will incur the burden associated with rule familiarization, only a 

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

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

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

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

832 requirements without any significant modifications. 

833 

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

835 good was produced, and a statement of compliance. Fabricators are also required to take 

836 “reasonable precautions” to ensure that the composite wood products and finished goods they 
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837 acquire are in compliance with the applicable emission standards. This includes keeping records 

838 showing the date of purchase, the supplier, as well as all precautions taken to ensure that the 

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

840 

841 Baseline Compliance for Fabricators 

842 

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

conversations with industry associations.9 844 However, baseline compliance for some industries 

845 was estimated simply as the number of establishments located in California divided by the total 

846 number of U.S. establishments in each industry. Exhibit 6-5 presents the estimated baseline 

847 CARB compliance levels for fabricator industries. The baseline CARB compliance category 

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

849 using certified panels and complying with the recordkeeping requirements. Additional details 

850 are provided in the Economic Analysis for the rulemaking. 

851 

Exhibit 6-5: Baseline CARB Compliance of Fabricator Industries 

NAICS NAICS Definition Baseline CARB 

Compliancea

321211b 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% 

321918c Other Millwork (including Flooring) 9.23% 

337212c Custom Architectural Woodwork and Millwork 9.83% 

321999c All Other Miscellaneous Wood Product Manufacturing 7.84% 

336213c Motor Home Manufacturing 100% 

336214c Travel Trailer and Camper 100% 

321991c Manufactured Home (Mobile Home) Manufacturing 10.90% 

321992c Prefabricated Building Manufacturing 5.92% 

339950c 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 

852 

853 Fabricators incurring Recordkeeping and Labeling Costs 

854 

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

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

857 composite wood products destined for California markets have experience implementing 

858 recordkeeping and labeling requirements that are similar to the proposed TSCA Title VI rule. To 

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

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

to fewer than ten respondents per questionnaire.10 861 These questionnaires asked respondents for 

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

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

864 

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

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

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

868 fabricators are not estimated to incur initial costs for recordkeeping, because their existing 

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

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

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

872 additional recurring recordkeeping costs. 

873 

874 The fabricator questionnaire respondent that reported incurring recurring recordkeeping 

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

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

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

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

879 recordkeeping burden. This fabricator questionnaire respondent was a firm with employees, but 

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

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

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

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

884 associated with keeping records will typically increase with the volume of a fabricator’s sales. 

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

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

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

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

889 

890 For employer firms, the average recurring recordkeeping burden is estimated as 520 

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

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

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

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

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

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

897 approximately 7.21 labor hours per year. 

898 

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

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

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

indicated that retailers’ customary business practices were generally sufficient to meet the chain of custody requirements in the 

CARB ATCM (Personal Communication with CRA 2011), so retailers were not administered a questionnaire. 
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901 However, this analysis assumes that these firms did in fact incur small costs associated with 

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

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

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

905 67 percent of firms that are not already complying with the CARB ATCM, and all firms that are 

already complying with the CARB ATCM, incur the costs associated with 3 labor hours.11 906 Two 

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

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

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

reported by these two firms (100 hours).12 910 It is assumed that fabricators will use technical labor 

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

912 for labeling, no recurring labeling costs are estimated. 

913 

914 (D). Wholesalers

915 

916 While all wholesalers will incur the burden associated with rule familiarization, only a 

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

918 fabricators, this is because 1) many wholesalers are already complying with the CARB ATCM 

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

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

921 any significant modifications. Like fabricators, wholesalers who import composite wood 

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

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

924 standards. These records must be kept for five years. 

925 

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

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

928 records showing the date of purchase, the supplier, and all precautions taken to ensure that the 

929 product meets the emissions standards. Wholesalers that are not defined as manufacturers under 

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

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

practices.13 932 Therefore the requirement to keep invoices and bills of lading is not assumed to 

impose any additional burden on wholesalers that do not import products.14 933 

934 

935 Baseline Compliance for Wholesalers 

936 

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

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

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

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

 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 customary business practices, these firms do count toward the respondent 

and response totals in Exhibit 6-8 through Exhibit 6-13.
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941 steps must be taken to estimate baseline compliance for each affected industry: (1) use 2007 

Economic Census data to identify the number of affected wholesale firms15 942 (2) estimate the 

943 number of single-unit firms in California; (3) estimate the number of multi-unit firms with at 

944 least one establishment in California; and (4) estimate baseline compliance as the percentage of 

945 U.S. firms with at least one establishment in California. Note that this approach may lead to an 

946 understatement of the level of baseline compliance among wholesalers because they may sell 

947 products in states where they do not have physical locations. In addition, two wholesale 

948 industries -- Furniture Merchant Wholesalers (423210) and Home Furnishing Merchant 

949 Wholesalers (423220) -- are assumed to be fully compliant with the CARB ATCM chain of 

custody requirements in the baseline.16 950 Exhibit 6-6 presents a summary of the baseline 

951 compliance estimates for wholesale industries. The Economic Analysis for the rule provides a 

952 detailed description of the baseline calculations. 

 15 U.S. Census Bureau 2009, 2010d, j. 

16 Personal Communication with AHFA 2010, Personal Communication with BIFMA 2010. 
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Exhibit 6-6: Baseline CARB Compliance of Wholesale Industries 

NAICS NAICS Description Baseline 

CARB Compliancea

423210b Furniture merchant wholesalers 100% 

423220b 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 other 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 supplies 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 merchant 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 newspaper 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 Wholesalers (423210) and Home Furnishing Merchant Wholesalers 
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Exhibit 6-6: Baseline CARB Compliance of Wholesale Industries 

NAICS NAICS Description Baseline 

CARB Compliancea

(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 

953 

954 Wholesalers incurring Recordkeeping and Labeling Costs 

955 

956 Seven wholesale firms were administered telephone questionnaires that asked about the 

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

958 CARB recordkeeping and labeling requirements. The questionnaire and the calculation of 

959 recordkeeping costs are described in detail in the Economic Analysis, and are summarized 

960 below. 

961 

962 Based on the questionnaire responses, this analysis assumes that 57 percent of 

963 wholesalers that import composite wood products and/or articles that contain composite wood 

products will incur initial recordkeeping costs associated with 59.15 labor hours.17 964 As indicated 

965 above, this analysis estimates that 28 percent of domestic wholesalers import composite wood 

966 products and/or articles that contain composite wood products. In addition, the analysis assumes 

967 that one percent of wholesalers will repackage their products and so will incur the same burden 

968 as the fabricators who are assumed to incur more substantial initial labeling costs (an average of 

969 100 hours). However, the recurring recordkeeping burden reported by the wholesaler 

970 questionnaire respondent (forty five minutes per day) seems unlikely to be representative for all 

971 the wholesaler firms that incur this type of burden. This wholesaler questionnaire respondent 

972 was a firm with employees, but smaller firms, such as nonemployer firms, are likely to need 

973 much less time than 3.75 hours per week (nearly 10% of a 40 hour work week) to perform the 

974 necessary recordkeeping activities. Since the recordkeeping requirements entail keeping track of 

975 composite wood materials purchased and shipments that contain composite wood products, it is 

976 expected that the burden associated with keeping records will typically increase with the volume 

977 of a wholesaler’s sales. Thus, to estimate the recurring recordkeeping burden for nonemployer 

978 wholesalers, the analysis assumes that there is a fixed-cost component of the recurring 

979 recordkeeping costs associated with two hours of labor and a variable cost component that is 

980 proportional to a firm’s revenue. It is assumed that wholesalers will use clerical labor for 

981 recordkeeping activities and technical labor for labeling. 

982 

983 For employer firms that import composite wood products, the recurring recordkeeping 

984 cost is estimated as 195 hours per year (based on 2 hours of fixed cost labor, with the remaining 

985 hours of variable cost labor). For nonemployer firms that import composite wood products, the 

986 variable cost component is calculated by subtracting two hours of fixed labor cost (at a cost of 

987 $51.08) from the total reported annual cost ($4,980) and then dividing by the estimated average 

988 revenue for affected employer wholesalers ($8,308,417). The resulting variable cost component 

989 (0.05933 percent of revenue) is multiplied by average nonemployer revenues ($82,542) and 

990 results in costs of $100.05, or 3.92 labor hours per year. 

 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. 
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991 

992 It is assumed that one percent of wholesalers incur labeling burden, either because they 

993 are repackaging goods that were originally labeled on the packaging instead of on the individual 

994 items, or because they are replacing an original label applied by the panel producer or fabricator 

995 with a label listing a different company name. It is also assumed that these wholesalers incur the 

996 same burden as the fabricators who are assumed to incur more substantial initial labeling burden 

997 (an average of 100 hours). 

998 

999 (E). Retailers

1000 

1001 It is assumed that retailers do not import composite wood products directly (without a 

wholesaler), and thus are not subject to the rule’s chain of custody requirements.18 1002 Retailers that 

1003 do not import composite wood products must keep invoices and bills of lading. Retailer’s 

1004 customary business practices are assumed to be generally sufficient to meet the proposed rule’s 

recordkeeping requirements.19 1005 Therefore the recordkeeping requirements are not assumed to 

impose any additional burden on retailers.20 1006 In addition, assuming they do not modify the 

1007 packaging of the composite wood products they purchase, retailers are not required to modify 

1008 their labeling system to comply with the proposed rule. 

1009 

1010 Baseline Compliance for Retailers 

1011 

1012 Exhibit 6-7 presents a summary of the baseline compliance estimates for retail industries. 

1013 Baseline CARB compliance was calculated in the same manner as described the wholesale 

1014 section (i.e., by determining the number of firms with at least one establishment in California). 

1015 Additional detail is provided in the Economic Analysis for the rulemaking. 

1016 

 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 directly is accounted for under the wholesaler category. 19 Personal Communication with CRA 2011. 20 While retailers are assumed to meet the proposed rule’s recordkeeping requirements with documents kept as part of their 

customary business practices, these firms do count toward the respondent and response totals in Exhibit 6-8 through Exhibit 6-

13.
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Exhibit 6-7: 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 discount 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% 
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Exhibit 6-7: 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 

1017 

1018 (F). Summary

1019 

1020 Exhibit 6-8 and Exhibit 6-9 summarize the total number of respondents, total burden per 

1021 respondent and total burden for each response activity over the first year, and second and third 

1022 years of the ICR, respectively. Exhibit 6-10 presents the average total value for those variables 

1023 over the first three years of the rule (i.e., without accounting for the baseline compliance with the 

1024 CARB ATCM). Exhibit 6-11 through Exhibit 6-13 mirror the previous three tables, except that 

1025 they account for incremental burdens (excluding baseline burden and cost). Note that most 

1026 respondents are incurring burdens for multiple activities listed in these exhibits. As indicated, 

1027 the average annual burden over the first three years of the rule is estimated to be approximately 

1028 8.0 million hours, while the incremental burden over this time period is estimated at 5.9 million 

1029 hours. The domestic burden accounts for approximately 62.8 percent and 66.2 percent of the 

1030 totals, respectively. 

1031 

1032 

1033 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 32 of 99 

Exhibit 6-8: Total (including baseline) First Year Burden Hours, by Activity and Geographic Location 

Activity 

Labor 

Type1

Number of Entities Number of 

Activities 

Per 

Respondent 

Burden Per 

Activity 

(Hours) 

Tot

Domestic Foreign2 Total Domestic 

1. Rule Familiarization 

Producers3 M 370 1,129 1,499 1 4.00 1,480 Fabricators4 M 79,701 31,083 110,784 1 4.00 318,804 Wholesalers M 85,560 33,368 118,928 1 4.00 342,240 Retailers M 759,048 - 759,048 1 4.00 3,036,192 

2. Certification Fee - - - - - - - 3. Initial On-site Audit 

With Existing Certifications M 82 764 846 1 4.00 328 Without Existing Certifications3,5 M 288 365 653 1 8.00 2,304 

4. Develop Quality Control Manual3 M 288 365 653 1 40.00 11,520 5. Qualifying Test 6. Qualifying Test Shipment6

1 Product M 11 129 140 1 0.50 6 2 Products3,5 M 288 365 653 2 0.25 144 

7. Correlation Test 

1 Product M 11 129 140 10 1.00 110 2 Products3,5 M 288 365 653 20 1.00 5,760 

8. Quarterly On-site Audit7

Standard3,6 M 339 713 1,052 3 4.00 4,068 NAF (With New Certification) M 17 276 293 1 4.00 68 NAF (With Existing Certification) M 14 140 154 - 4.00 - 

9. Large Scale Testing Fee - - - - - - - 10. Large Scale Testing Shipment7

Standard Certification3,5 M 339 713 1,052 3 0.50 509 NAF (With New Certification) M 17 276 293 1 0.50 9 NAF (With Existing Certification) M 14 140 154 - 0.50 - 

11. On-site Audit Travel - - - - - - - 12. Desk Audits8

Standard Certification3,5 M 339 713 1,052 8 1.00 2,712 NAF (With New Certification) M 17 276 293 2 1.00 34 

13. Purchase of Small Chamber Testing Unit9 - - - - - - - 14. Quality Control Testing10

Standard Certification3,6 M 339 713 1,052 260 2.00 176,280 New NAF Certification M 17 276 293 65 2.00 2,210 

15. Lost Product - - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 33 of 99 

Exhibit 6-8: Total (including baseline) First Year Burden Hours, by Activity and Geographic Location 

Activity 

Labor 

Type1

Number of Entities Number of 

Activities 

Per 

Respondent 

Burden Per 

Activity 

(Hours) 

Tot

Domestic Foreign2 Total Domestic 

16. Initial Recordkeeping11 C 8,576 11,945 20,521 1 59.15 507,270 17. Recurring Recordkeeping12

Producers3,5 M 370 1,129 1,499 1 52 19,240 Fabricators with burden- Employers4 C 3,630 1,422 5,052 1 520.00 1,887,600 Fabricators with burden - Nonemployers4 C 5,137 1,997 7,134 1 7.21 37,038 Fabricators without burden C 70,934 27,664 98,598 1 - - Wholesalers with burden - Employers C 4,208 5,861 10,069 1 195.00 820,560 Wholesalers with burden - Nonemployers C 6,094 8,487 14,581 1 3.92 23,888 Wholesalers without burden C 75,258 19,020 94,278 1 - - Retailers C 759,048 - 759,048 1 - - 

18. Initial Labeling13

Minor Changes - Producers4,5

C 93 1,021 1,114 1 6.00 558 

Minor Changes - Fabricators4 T 64,290 24,986 89,276 1 3.00 192,870 Major Changes - Producers3 C 277 108 385 1 100.00 27,700 Major Changes - Fabricators and Wholesalers4 T 16,266 6,344 22,610 1 100.00 1,626,600 

Total - Year 1 9,048,102 

Notes: 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 of imports for the affected fabricator NAICS tshipments 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 typproducts or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified U.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 therefoas hardwood plywood. A similar proportion of foreign laminators exporting 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 as a result of the TSCA Title VI rule. 6. Producers that are already CARB compliant and are not expected adopt a more stringent certification type (e.g., NAF certification) are not assumed to need to perform assumed that their previous testing is sufficient. 7. On-site audits must be conducted at least once quarterly, unless the mill obtains NAF certification. This analysis assumes that producers with new NAF certifications wwith one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing NAF certifications under the CARB ATCM will only the first year. All producers with NAF certification will have one on-site audit annually thereafter. 8. Desk audits are assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with none are required in subsequent years. No desk audits are required for respondents with existing NAF 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 producers test each production line once daily. Composite panel producers need to perform 3 months of routine small scacertified. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 34 of 99 

Exhibit 6-8: Total (including baseline) First Year Burden Hours, by Activity and Geographic Location 

Activity 

Labor 

Type1

Number of Entities Number of 

Activities 

Per 

Respondent 

Burden Per 

Activity 

(Hours) 

Tot

Domestic Foreign2 Total Domestic 

11. Recordkeeping costs are incurred by composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwofabricators, and wholesalers that import composite wood products or articles that contain composite wood products. However, composite panel producers and fabricators any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contaiaddition, it is assumed that 57 percent of wholesalers are not already complying with the CARB ATCM and will have initial burden to change their recordkeeping systemVI rule. 12. While recordkeeping is required for all respondents, not all entities will incur recordkeeping burden and costs. This analysis assumes that some fabricators and wholrecordkeeping 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 anhave recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to proposed rule’s recordkeeping requirements. For fabricators and wholesalers with burden, the analysis assumes that there is a fixed-cost component of the recurring recotwo 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 by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the total reported cost is $12,916.80, and the average revenue 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 recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring recordksum 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 averagrevenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurring and 3.92 hours per year, respectively. 13. Firms that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their nawas 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 tpurchase. This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators that are already cATCM 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 remaininwholesalers are 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 

1034 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 35 of 99 

Exhibit 6-9: Total (including baseline) Second and Third Year Burden Hours, by Activity and Geographic Location 

Activity 

Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent 

Burden Per 

Activity 

(Hours) 

Total 

Domestic Foreign2 Total Domestic 

1. Rule Familiarization 

Producers3 M - - - - - - Fabricators4 M - - - - - - Wholesalers M - - - - - - Retailers M - - - - - - 

2. Certification Fee - - - - - - - 3. Initial On-site Audit 

With Existing Certifications M - - - - - - Without Existing Certifications3,5 M - - - - - - 

4. Develop Quality Control Manual3 M - - - - - - 5. Qualifying Test - - - - - - - 6. Qualifying Test Shipment 

1 Product M - - - - - - 2 Products3,5 M - - - - - - 

7. Correlation Test6

1 Product M - - - - - - 2 Products3,5 M - - - - - - 

8. Quarterly On-site Audit7

Standard3,6 M 339 713 1,052 4 4.00 5,424 NAF (With New Certification) M 17 276 293 1 4.00 68 NAF (With Existing Certification) M 14 140 154 1 4.00 56 

9. Large Scale Testing Fee - - - - - - - 10. Large Scale Testing Shipment7

Standard Certification3,5 M 339 713 1,052 4 0.50 678 NAF (With New Certification) M 17 276 293 1 0.50 9 NAF (With Existing Certification) M 14 140 154 1 0.50 7 

11. On-site Audit Travel - - - - - - - 12. Desk Audits8

Standard Certification3,5 M 339 713 1,052 8 1.00 2,712 NAF (With New Certification) M - - - - - - 

13. Purchase of Small Chamber Testing Unit9 - - - - - - - 14. Quality Control Testing10

Standard Certification3,5 M 339 713 1,052 260 2.00 176,280 New NAF Certification M - - - - - - 

15. Lost Product 16. Initial Recordkeeping11 C - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 36 of 99 

Exhibit 6-9: Total (including baseline) Second and Third Year Burden Hours, by Activity and Geographic Location 

Activity 

Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent 

Burden Per 

Activity 

(Hours) 

Total 

Domestic Foreign2 Total Domestic 

17. Recurring Recordkeeping12

Producers3,5

M 370 1,129 1,499 1 52.00 19,240 

Fabricators with burdenEmployers4 C 3,630 1,422 5,052 1 520.00 1,887,600 Fabricators with burden - Nonemployers4 C 5,137 1,997 7,134 1 7.21 37,038 Fabricators without burden 

C 70,934 27,664 98,598 1 - - 

Wholesalers with burden - Employers 

C 4,208 5,861 10,069 1 195.00 820,560 

Wholesalers with burden - Nonemployers 

C 6,094 8,487 14,581 1 3.92 23,888 

Wholesalers without burden 

C 75,258 19,020 94,278 1 - - 

Retailers 

C 759,048 - 759,048 1 - - 

19. Initial Labeling4,13

Minor Changes - Producers4,5 C - - - - - - Minor Changes - Fabricators4 T - - - - - - Major Changes - Producers3 C - - - - - - Major Changes - Fabricators and Wholesalers4 T - - - - - - 

Total - Years 2 and 3 2,973,560 

Notes: 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 of imports for the affected fabricator NAICS 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 typproducts or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified U.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 therefas hardwood plywood. A similar proportion of foreign laminators exporting 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 TPC as a result of the TSCA Title VI rule. 6. Producers that are already CARB compliant and are not expected adopt a more stringent certification type (e.g., NAF certification) are not assumed to need to perform assumed that their previous testing is sufficient. 7. On-site audits must be conducted at least once quarterly, unless the mill obtains NAF certification. This analysis assumes that producers with new NAF certifications wwith one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing NAF certifications under the CARB ATCM will only the first year. All producers with NAF certification will have one on-site audit annually thereafter. 8. Desk audits are assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with none are required in subsequent years. No desk audits are required for respondents with existing NAF certification. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 37 of 99 

Exhibit 6-9: Total (including baseline) Second and Third Year Burden Hours, by Activity and Geographic Location 

Activity 

Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent 

Burden Per 

Activity 

(Hours) 

Total 

Domestic Foreign2 Total Domestic 

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 producers test each production line once daily. Composite panel producers need to perform 3 months of routine small scacertified. 11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plyand wholesalers that import composite wood products or articles that contain composite wood products. However, composite panel producers and fabricators are not expchanges to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composiis assumed that 57 percent of wholesalers are not already complying with the CARB ATCM and will have initial burden to change their recordkeeping systems to compl12. While recordkeeping is required for all respondents, not all entities will incur recordkeeping burden and costs. This analysis assumes that some fabricators and wholrecordkeeping 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 anhave recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to the proposed rule’s recordkeeping requirements. For fabricators and wholesalers with burden, the analysis assumes that there is a fixed-cost component of the recurring with 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 thdividing by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the total reported cost is $12,916.80, and the average 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 variable cost factors are 0.30338 percenThe recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring reas 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 revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurrinand 3.92 hours per year, respectively. 13. Firms that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their nawas 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 tthey purchase This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators that are alreadATCM 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 remaininwholesalers are 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 

1035 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 38 of 99 

Exhibit 6-10: Three Year Average Burden Hours (including baseline), by Activity and Geographic Location 

Activity 

Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent 

Burden Per 

Activity 

(Hours) 

To

Domestic Foreign2 Total Domestic 

1. Rule Familiarization 

Producers3 M 370 1,129 1,499 0.3333 4.0000 493 Fabricators4 M 79,701 31,083 110,784 0.3333 4.0000 106,257 Wholesalers M 85,560 33,368 118,928 0.3333 4.0000 114,069 Retailers M 759,048 - 759,048 0.3333 4.0000 1,011,963 

2. Certification Fee - - - - - - - 3. Initial On-site Audit 

With Existing Certifications M 82 764 846 0.3333 4.0000 109 Without Existing Certifications3,5 M 288 365 653 0.3333 8.0000 768 

4. Develop Quality Control Manual3 M 288 365 653 0.3333 40.0000 3,840 5. Qualifying Test - - - - - - - 6. Qualifying Test Shipment 

1 Product M 11 129 140 0.3333 0.5000 2 2 Products3,5 M 288 365 653 0.6667 0.2500 48 

7. Correlation Test6 

1 Product M 11 129 140 3.3333 1.0000 37 2 Products3,5 M 288 365 653 6.6667 1.0000 1,920 

8. Quarterly On-site Audit7

Standard3,5 M 339 713 1,052 3.6667 4.0000 4,972 NAF (With New Certification) M 17 276 293 1.0000 4.0000 68 NAF (With Existing Certification) M 14 140 154 0.6667 4.0000 37 

9. Large Scale Testing Fee - - - - - - - 10. Large Scale Testing Shipment7

Standard Certification3,5 M 339 713 1,052 3.6667 0.5000 622 NAF (With New Certification) M 17 276 293 1.0000 0.5000 9 NAF (With Existing Certification) M 14 140 154 0.6667 0.5000 5 

11. On-site Audit Travel - - - - - - - 12. Desk Audits8

Standard Certification3,5 M 339 713 1,052 8.0000 1.0000 2,712 NAF (With New Certification) M 17 276 293 0.6667 1.0000 11 

13. Purchase of Small Chamber Testing Unit9 - - - - - - - 14. Quality Control Testing10

Standard Certification3,5 M 339 713 1,052 260.0000 2.0000 176,280 New NAF Certification M 17 276 293 21.6667 2.0000 737 

15. Lost Product - - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 39 of 99 

Exhibit 6-10: Three Year Average Burden Hours (including baseline), by Activity and Geographic Location 

Activity 

Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent 

Burden Per 

Activity 

(Hours) 

To

Domestic Foreign2 Total Domestic 

16. Initial Recordkeeping11 C 8,576 11,945 20,521 0.3333 59.1500 169,073 17. Recurring Recordkeeping12

Producers3,5 M 370 1,129 1,499 1.0000 52.0000 19,240 

Fabricators with burden- Employers4 C 3,630 1,422 5,052 1.0000 520.0000 1,887,600 Fabricators with burden - Nonemployers4 C 5,137 1,997 7,134 1.0000 7.2100 37,038 Fabricators without burden C 70,934 27,664 98,598 1.0000 - - Wholesalers with burden - Employers C 4,208 5,861 10,069 1.0000 195.0000 820,560 Wholesalers with burden - Nonemployers C 6,094 8,487 14,581 1.0000 3.9200 23,888 Wholesalers without burden C 75,258 19,020 94,278 1.0000 - - Retailers C 759,048 - 759,048 1.0000 - - 

18. Initial Labeling4,13

Minor Changes - Producers4,5 C 93 1,021 1,114 0.3333 6.0000 186 Minor Changes - Fabricators4 T 64,290 24,986 89,276 0.3333 3.0000 64,284 Major Changes - Producers3 C 277 108 385 0.3333 100.0000 9,232 Major Changes - Fabricators and Wholesalers4 T 16,266 6,344 22,610 0.3333 100.0000 542,146 

Total - Three Year Average 4,998,206 

Notes: 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 of imports for the affected fabricator NAICS 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 typproducts or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified U.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 therefas hardwood plywood. A similar proportion of foreign laminators exporting 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 TPC as a result of the TSCA Title VI rule. 6. Producers that are already CARB compliant and are not expected adopt a more stringent certification type (e.g., NAF certification) are not assumed to need to perform assumed that their previous testing is sufficient. 7. On-site audits must be conducted at least once quarterly, unless the mill obtains NAF certification. This analysis assumes that producers with new NAF certifications wwith one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing NAF certifications under the CARB ATCM will only the first year. All producers with NAF certification will have one on-site audit annually thereafter. 8. Desk audits are assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with none are required in subsequent years. No desk audits are required for respondents with existing NAF 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 producers test each production line once daily. Composite panel producers need to perform 3 months of routine small scacertified. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 40 of 99 

Exhibit 6-10: Three Year Average Burden Hours (including baseline), by Activity and Geographic Location 

Activity 

Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent 

Burden Per 

Activity 

(Hours) 

To

Domestic Foreign2 Total Domestic 

11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plyand wholesalers that import composite wood products or articles that contain composite wood products. However, composite panel producers and fabricators are not expchanges to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composiis assumed that 57 percent of wholesalers are not already complying with the CARB ATCM and will have initial burden to change their recordkeeping systems to compl12. While recordkeeping is required for all respondents, not all entities will incur recordkeeping burden and costs. This analysis assumes that some fabricators and wholrecordkeeping 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 anhave recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to the proposed rule’s recordkeeping requirements. For fabricators and wholesalers with burden, the analysis assumes that there is a fixed-cost component of the recurring with 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 thdividing by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the total reported cost is $12,916.80, and the average 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 variable cost factors are 0.30338 percenThe recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring reas 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 revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurrinand 3.92 hours per year, respectively. 13. Firms that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their nawas 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 tthey purchase This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators that are alreadATCM 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 remaininwholesalers are 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 

1036 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 41 of 99 

Exhibit 6-11: Incremental First Year Burden Hours, by Activity and Geographic Location 

Activity Labor Type1 Number of Entities Number of Activities Per Respondent Burden Per Activity (Hours) Increm

Domestic Foreign2 Total Domestic 

1. Rule Familiarization 

Producers3 M 370 1,129 1,499 1 4.00 1,480 Fabricators4 M 79,701 31,083 110,784 1 4.00 318,804 Wholesalers M 85,560 33,368 118,928 1 4.00 342,240 Retailers M 759,048 - 759,048 1 4.00 3,036,192 

2. Certification Fee - - - - - - - 3. Initial On-site Audit 

With Existing Certifications M 82 764 846 1 4.00 328 Without Existing Certifications3,5 M 288 365 653 1 8.00 2,304 

4. Develop Quality Control Manual3 M 288 365 653 1 40.00 11,520 5. Qualifying Test - - - - - - - 6. Qualifying Test Shipment 

1 Product M 11 129 140 1 0.50 6 2 Products3,5 M 288 365 653 2 0.25 144 

7. Correlation Test6

1 Product M 11 129 140 10 1.00 110 2 Products3,5 M 288 365 653 20 1.00 5,760 

8. Quarterly On-site Audit7

Uncertified to Standard3,5 M 277 154 431 3 4.00 3,324 ULEF to Standard M 11 114 125 3 4.00 132 NAF (With New Certification) M 11 211 222 1 4.00 44 

9. Large Scale Testing Fee - - - - - - - 10. Large Scale Testing Shipment7

Uncertified to Standard3,5 M 277 154 431 3 0.50 416 ULEF to Standard M 11 114 125 3 0.50 17 NAF (With New Certification) M 11 211 222 1 0.50 6 

11. On-site Audit Travel - - - - - - - 12. Desk Audits8

Uncertified to Standard3,5 M 277 154 431 8 1.00 2,216 ULEF to Standard M 11 114 125 8 1.00 88 NAF (With New Certification) M 11 211 222 2 1.00 22 

13. Purchase of Small Chamber Testing Unit9 - - - - - - - 14. Quality Control Testing10 - - - - - - - 

Standard Certification3,5 M 288 268 556 260 2.00 149,760 New NAF Certification M 17 276 293 65 2.00 2,210 

15. Lost Product - - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 42 of 99 

Exhibit 6-11: Incremental First Year Burden Hours, by Activity and Geographic Location 

Activity Labor Type1 Number of Entities Number of Activities Per Respondent Burden Per Activity (Hours) Increm

Domestic Foreign2 Total Domestic 

16. Initial Recordkeeping11 C 8,576 11,945 20,521 1 59.15 507,270 17. Recurring Recordkeeping12

Producers3,5 M 370 1,129 1,499 1 52.00 19,240 Fabricators with burden- Employers4 C 2,176 848 3,024 1 520.00 1,131,520 Fabricators with burden - Nonemployers4 C 3,054 1,191 4,245 1 7.21 22,019 Fabricators without burden C 42,310 16,437 58,747 1 - - Wholesalers with burden - Employers 

C 2,642 3,680 6,322 1 195.00 515,190 

Wholesalers with burden - Nonemployers 

C 3,826 5,331 9,157 1 3.92 14,998 

Wholesalers without burden C 47,263 11,944 59,207 1 - - Retailers C 658,150 - 658,150 1 - - 

18. Initial Labeling4,13

Minor Changes - Producers4,5 C 93 1,021 1,114 1 6.00 558 Minor Changes - Fabricators4 T 64,290 24,986 89,276 1 3.00 192,870 Major Changes - Producers3 C 277 108 385 1 100.00 27,700 Major Changes - Fabricators and Wholesalers4 T 16,266 6,344 22,610 1 100.00 1,626,600 

Total - Year 1 7,935,088 

Notes: 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 of imports for the affected fabricator NAICS 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 typproducts or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified U.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 therefas hardwood plywood. A similar proportion of foreign laminators exporting 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 TPC as a result of the TSCA Title VI rule. 6. Producers that are already CARB compliant and are not expected adopt a more stringent certification type (e.g., NAF certification) are not assumed to need to perform assumed that their previous testing is sufficient. 7. On-site audits must be conducted at least once quarterly, unless the mill obtains NAF certification. This analysis assumes that producers with new NAF certifications wwith one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing NAF certifications under the CARB ATCM will only the first year. All producers with NAF certification will have one on-site audit annually thereafter. 8. Desk audits are assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with none are required in subsequent years. No desk audits are required for respondents with existing NAF 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. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 43 of 99 

Exhibit 6-11: Incremental First Year Burden Hours, by Activity and Geographic Location 

Activity Labor Type1 Number of Entities Number of Activities Per Respondent Burden Per Activity (Hours) Increm

Domestic Foreign2 Total Domestic 

10. This analysis assumes that composite panel producers test each production line once daily. Composite panel producers need to perform 3 months of routine small scacertified. 11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plyand wholesalers that import composite wood products or articles that contain composite wood products. However, composite panel producers and fabricators are not expchanges to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composiis assumed that 57 percent of wholesalers are not already complying with the CARB ATCM and will have initial burden to change their recordkeeping systems to compl12. While recordkeeping is required for all respondents, not all entities will incur recordkeeping burden and costs. This analysis assumes that some fabricators and wholrecordkeeping 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 anhave recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to the proposed rule’s recordkeeping requirements. For fabricators and wholesalers with burden, the analysis assumes that there is a fixed-cost component of the recurring with 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 thdividing by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the total reported cost is $12,916.80, and the average 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 variable cost factors are 0.30338 percenThe recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring reas 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 revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurrinand 3.92 hours per year, respectively. 13. Firms that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their nawas 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 tthey purchase. This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators that are alreaATCM 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 assumthe two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).

1037 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 44 of 99 

Exhibit 6-12: Incremental Second and Third Year Burden Hours, by Activity and Geographic Location 

Activity Labor Type1 Number of Entities Number of Activities Per Respondent Burden Per Activity (Hours) Incr

Domestic Foreign2 Total Domes

1. Rule Familiarization 

Producers3 M - - - - - - Fabricators4 M - - - - - - Wholesalers M - - - - - - Retailers M - - - - - - 

2. Certification Fee - - - - - - - 3. Initial On-site Audit 

With Existing Certifications M - - - - - - Without Existing Certifications3,5 M - - - - - - 

4. Develop Quality Control Manual3 M - - - - - - 5. Qualifying Test - - - - - - - 6. Qualifying Test Shipment 

1 Product M - - - - - - 2 Products3,5 M - - - - - - 

7. Correlation Test6

1 Product M - - - - - - 2 Products3,5 M - - - - - - 

8. Quarterly On-site Audit7

Uncertified to Standard3,5 M 277 154 431 4 4.00 4,ULEF to Standard M 11 114 125 3 4.00 NAF (With New Certification) M 11 211 222 1 4.00 

9. Large Scale Testing Fee - - - - - - - 10. Large Scale Testing Shipment7

Uncertified to Standard3,5 M 277 154 431 4 0.50 ULEF to Standard M 11 114 125 3 0.50 NAF (With New Certification) M 11 211 222 1 0.50 

11. On-site Audit Travel - - - - - - - 12. Desk Audits8

Uncertified to Standard3,5 M 277 154 431 8 1.00 2,ULEF to Standard M 11 114 125 8 1.00 NAF (With New Certification) M - - - - - - 

13. Purchase of Small Chamber Testing Unit9 - - - - - - - 14. Quality Control Testing10

Standard Certification3,5 M 288 268 556 260 2.00 149,New NAF Certification M - - - - - - 

15. Lost Product - - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 45 of 99 

Exhibit 6-12: Incremental Second and Third Year Burden Hours, by Activity and Geographic Location 

Activity Labor Type1 Number of Entities Number of Activities Per Respondent Burden Per Activity (Hours) Incr

Domestic Foreign2 Total Domes

16. Initial Recordkeeping11 C - - - - - - 17. Recurring Recordkeeping12

Producers3,5 M 370 1,129 1,499 1 52.00 19,Fabricators with burden- Employers4 C 2,176 848 3,024 1 520.00 1,131,Fabricators with burden - Nonemployers4 C 3,054 1,191 4,245 1 7.21 22,Fabricators without burden C 42,310 16,437 58,747 1 - - Wholesalers with burden - Employers C 2,642 3,680 6,322 1 195.00 515,Wholesalers with burden - Nonemployers C 3,826 5,331 9,157 1 3.92 14,Wholesalers without burden C 47,263 11,944 59,207 1 - - Retailers C 658,150 - 658,150 1 - - 

18. Initial Labeling4,13

Minor Changes - Producers4,5 T - - - - - - Minor Changes - Fabricators4 T - - - - - - Major Changes - Producers3 T - - - - - - Major Changes - Fabricators and Wholesalers4 T - - - - - - 

Total - Years 2 and 3 1,860,

Notes: 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 of imports for the affected fabricator NAICS tshipments 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 typproducts or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified U.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 therefoas hardwood plywood. A similar proportion of foreign laminators exporting 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 as a result of the TSCA Title VI rule. 6. Producers that are already CARB compliant and are not expected adopt a more stringent certification type (e.g., NAF certification) are not assumed to need to perform assumed that their previous testing is sufficient. 7. On-site audits must be conducted at least once quarterly, unless the mill obtains NAF certification. This analysis assumes that producers with new NAF certifications wwith one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing NAF certifications under the CARB ATCM will only first year. All producers with NAF certification will have one on-site audit annually thereafter. 8. Desk audits are assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with none are required in subsequent years. No desk audits are required for respondents with existing NAF 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 producers test each production line once daily. Composite panel producers need to perform 3 months of routine small scacertified. 11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plyw
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 46 of 99 

Exhibit 6-12: Incremental Second and Third Year Burden Hours, by Activity and Geographic Location 

Activity Labor Type1 Number of Entities Number of Activities Per Respondent Burden Per Activity (Hours) Incr

Domestic Foreign2 Total Domes

wholesalers that import composite wood products. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recoassumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 peralready complying with the CARB ATCM and 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 incur recordkeeping burden and costs. This analysis assumes that some fabricators and wholerecordkeeping 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 have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to bproposed rule’s recordkeeping requirements. For fabricators and wholesalers with burden, the analysis assumes that there is a fixed-cost component of the recurring recortwo 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 by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the total reported cost is $12,916.80, and the average revenue ithe 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 recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring recordksum 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 ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurring recordkehours per year, respectively. 13. Firms that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their namproduced, 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 the papurchase. This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators that are already cowill 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 incfirms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).

1038 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 47 of 99 

Exhibit 6-13: Three Year Average Incremental Burden Hours, by Activity and Geographic Location 

Activity Labor Type1 Number of Entities Number of Activities Per Respondent Burden Per Activity (Hours) Incremen

Domestic Foreign2 Total Domestic 

1. Rule Familiarization 

Producers3 M 370 1,129 1,499 0.3333 4.0000 493 Fabricators4 M 79,701 31,083 110,784 0.3333 4.0000 106,257 Wholesalers M 85,560 33,368 118,928 0.3333 4.0000 114,069 Retailers M 759,048 - 759,048 0.3333 4.0000 1,011,963 

2. Certification Fee - - - - - - - 3. Initial On-site Audit 

With Existing Certifications M 82 764 846 0.3333 4.0000 109 Without Existing Certifications3,5 M 288 365 653 0.3333 8.0000 768 

4. Develop Quality Control Manual3 M 288 365 653 0.3333 40.0000 3,840 5. Qualifying Test - - - - - - - 6. Qualifying Test Shipment 

1 Product M 11 129 140 0.3333 0.5000 2 2 Products3,5 M 288 365 653 0.6667 0.2500 48 

7. Correlation Test6

1 Product M 11 129 140 3.3333 1.0000 37 2 Products3,5 M 288 365 653 6.6667 1.0000 1,920 

8. Quarterly On-site Audit7

Uncertified to Standard3,5 M 277 154 431 3.6667 4.0000 4,063 ULEF to Standard M 11 114 125 3.0000 4.0000 132 NAF (With New Certification) M 11 211 222 1.0000 4.0000 44 

9. Large Scale Testing Fee - - - - - - - 10. Large Scale Testing Shipment8

Uncertified to Standard3,5 M 277 154 431 3.6667 0.5000 508 ULEF to Standard M 11 114 125 3.0000 0.5000 17 NAF (With New Certification) M 11 211 222 1.0000 0.5000 6 

11. On-site Audit Travel - - - - - - - 12. Desk Audits8

Uncertified to Standard3,5 M 277 154 431 8.0000 1.0000 2,216 ULEF to Standard M 11 114 125 8.0000 1.0000 88 NAF (With New Certification) M 11 211 222 0.6667 1.0000 7 

13. Purchase of Small Chamber Testing Unit9 - - - - - - - 14. Quality Control Testing10

Standard Certification3,5 M 288 268 556 260.0000 2.0000 149,760 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 48 of 99 

Exhibit 6-13: Three Year Average Incremental Burden Hours, by Activity and Geographic Location 

Activity Labor Type1 Number of Entities Number of Activities Per Respondent Burden Per Activity (Hours) Incremen

Domestic Foreign2 Total Domestic 

New NAF Certification M 17 276 293 21.6667 2.0000 737 

15. Lost Product - - - - - - - 16. Initial Recordkeeping11 C 8,576 11,945 20,521 0.3333 59.1500 169,073 17. Recurring Recordkeeping12

Producers3,5 M 370 1,129 1,499 1.0000 52.0000 19,240 

Fabricators with burdenEmployers4 C 2,176 848 3,024 1.0000 520.0000 1,131,520 Fabricators with burden - Nonemployers4 C 3,054 1,191 4,245 1.0000 7.2100 22,019 Fabricators without burden C 42,310 16,437 58,747 1.0000 - - Wholesalers with burden - Employers C 2,642 3,680 6,322 1.0000 195.0000 515,190 Wholesalers with burden - Nonemployers C 3,826 5,331 9,157 1.0000 3.9200 14,998 Wholesalers without burden C 47,263 11,944 59,207 1.0000 - - Retailers C 658,150 - 658,150 1.0000 - - 

18. Initial Labeling4,13

Minor Changes - Producers4,5 C 93 1,021 1,114 0.3333 6.0000 186 Minor Changes - Fabricators4 T 64,290 24,986 89,276 0.3333 3.0000 64,284 Major Changes - Producers3 C 277 108 385 0.3333 100.0000 9,232 Major Changes - Fabricators and Wholesalers4 T 16,266 6,344 22,610 0.3333 100.0000 542,146 

Total - Three Year Average 3,884,972 

Notes: 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 of imports for the affected fabricator NAICS 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 typproducts or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified U.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 therefas hardwood plywood. A similar proportion of foreign laminators exporting 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 TPC as a result of the TSCA Title VI rule. 6. Producers that are already CARB compliant and are not expected adopt a more stringent certification type (e.g., NAF certification) are not assumed to need to perform assumed that their previous testing is sufficient. 7. On-site audits must be conducted at least once quarterly, unless the mill obtains NAF certification. This analysis assumes that producers with new NAF certifications wwith one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing NAF certifications under the CARB ATCM will only 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 49 of 99 

Exhibit 6-13: Three Year Average Incremental Burden Hours, by Activity and Geographic Location 

Activity Labor Type1 Number of Entities Number of Activities Per Respondent Burden Per Activity (Hours) Incremen

Domestic Foreign2 Total Domestic 

the first year. All producers with NAF certification will have one on-site audit annually thereafter. 8. Desk audits are assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with none are required in subsequent years. No desk audits are required for respondents with existing NAF 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 producers test each production line once daily. Composite panel producers need to perform 3 months of routine small scacertified. 11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plyand wholesalers that import composite wood products or articles that contain composite wood products. However, composite panel producers and fabricators are not expchanges to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composiis assumed that 57 percent of wholesalers are not already complying with the CARB ATCM and will have initial burden to change their recordkeeping systems to compl12. While recordkeeping is required for all respondents, not all entities will incur recordkeeping burden and costs. This analysis assumes that some fabricators and wholrecordkeeping 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 anhave recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to the proposed rule’s recordkeeping requirements. For fabricators and wholesalers with burden, the analysis assumes that there is a fixed-cost component of the recurring with 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 thdividing by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the total reported cost is $12,916.80, and the average 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 variable cost factors are 0.30338 percenThe recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring reas 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 revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurrinand 3.92 hours per year, respectively. 13. Firms that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their nawas 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 tthey purchase. This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators that are alreaATCM 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 assumthe two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).

1039 1040 1041 1042 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 50 of 99 

1043 

1044 6(b) Estimating Respondent Costs

1045 

1046 Respondent costs are estimated by multiplying burden estimates from the previous 

1047 section with loaded wage rates, and adding in capital/startup costs and operating and 

1048 maintenance (O&M) costs. 

1049 

1050 (i) Wage Rates 

1051 

1052 The fully loaded unit labor cost for managerial, technical, and clerical labor in the 

1053 regulated industry and for EPA staff is estimated by adding fringe benefits and overhead costs to 

1054 the hourly wage or annual salary for each category following the method described in Wage 

1055 Rates for Economic Analysis of the Toxics Release Inventory Program. This section describes 

1056 the method employed to estimate the fully loaded unit labor costs for each labor category and 

1057 presents the results of the analysis. 

1058 

1059 Wage data used to calculate the labor costs are from the May 2009 National Industry1060 Specific Occupational Employment and Wage Estimates estimated as part of the Bureau of 

Labor Statistics’(BLS’) Occupational Employment Statistics Program (OES).21 1061 The values were 

1062 inflated to 2010 dollars using data from the BLS’ Employer Costs for Employee Compensation 

(ECEC) for all private industry for 2009 and 2010.22 1063 Thus, the analysis uses domestic wage rates 

1064 to estimate the costs for burden incurred by foreign firms. 

1065 

1066 The costs of fringe benefits (i.e., paid leave and insurance) were estimated using the same 

1067 ECEC data for all private industry in 2010, resulting in a fringe benefit rate of 42 percent. An 

1068 additional loading factor of 17 percent is applied to wages to account for overhead. This 

1069 overhead loading factor is added to the benefits loading factor, and the total (1.59) is then applied 

1070 to the base wage to derive the fully loaded wage. 

1071 

1072 The derivation of the fully loaded costs for managerial, technical, and clerical labor is 

1073 presented in Exhibit 6-14. Note that two types of managerial labor costs are calculated – one for 

1074 rule familiarization (a general managerial labor rate for wood product manufacturing NAICS) 

1075 and one for testing and certification (a more specific managerial labor rate for composite panel 

1076 manufacturing NAICS). 

1077 

 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 51 of 99 

Exhibit 6-14: Derivation of Loaded Industry Wage Rates

Labor 

Category Entity Type Burden Type Data Source for Wage Information 

Wage 

($2010) 

Fringe 

Overhead 

(a) (b) 

Managerial 

Composite Panel Producers 

Rule Familiarization 

BLS OES, Managerial Occupations, NAICS 321000 - Wood Product Manufacturing $46.29 

1.59 

Fabricators Wholesalers BLS OES, Managerial Occupations, Sector 42 - Wholesale Trade $58.67 Retailers 

BLS OES, Managerial Occupations, 321200 - Veneer, Plywood, and Engineered Wood Product Manufacturing 

$44.47 

Composite Panel Producers 

Testing and Certification, Recordkeeping 

BLS OES, Managerial Occupations, 321200 - Veneer, Plywood, and Engineered Wood Product Manufacturing 

$44.88 

Technical Fabricators / Wholesalers Labeling 

BLS OES, Computer and Mathematical Science Occupations, 321200 - Veneer, Plywood, and Engineered Wood Product Manufacturing 

$27.84 

Clerical 

Composite Panel Producers Recordkeeping 

for Fabricators and Wholesalers / Labeling for Producers 

BLS OES, Office and Administrative Support Occupations, NAICS 321000 - Wood Product Manufacturing 

$15.62 

Fabricators Wholesalers BLS OES, Office and Administrative Support Occupations, Sector 42 - Wholesale Trade $16.06 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 52 of 99 

1078 (ii) Costs Per Respondent

1079 

1080 This section describes the recordkeeping and reporting costs for each respondent activity 

1081 as a result of the proposed TSCA Title VI Rule. The total cost is comprised of labor costs, 

1082 capital/start-up costs, and operating and maintenance (O&M) costs. The latter two costs are 

1083 classified as non-labor costs in this analysis. Labor costs are presented first since they are based 

1084 directly on the labor burden and the loaded wage rates summarized above. Costs are broken out 

1085 such that each unique combination of (1) the number of responses per respondent and (2) per1086 response costs is classified as a separate activity. 

1087 

1088 Labor Costs 

1089 

1090 Exhibit 6-15 and Exhibit 6-16 summarize the total per-activity recordkeeping and 

1091 reporting labor costs for all respondents over the first year, and second and third years of the 

1092 rule, respectively. Exhibit 6-17 presents the average labor costs over the first three years of the 

1093 rule, by activity. Exhibit 6-18 through Exhibit 6-20 present the same information as the previous 

1094 three tables, except for the incremental labor costs. These labor costs were estimated by 

1095 multiplying the labor burdens summarized in Exhibit 6-8 through Exhibit 6-13 by the loaded 

1096 wage rates presented in Exhibit 6-14. As indicated, the estimated average annual total labor cost 

1097 over the first three years of the rule is approximately $312.2 million, while the incremental labor 

1098 costs are $246.9 million. The domestic labor cost accounts for approximately 66.0 percent 

1099 ($205.9 million) and 71.6 percent ($176.7 million) of these totals, respectively. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 53 of 99 

Exhibit 6-15: Total (including baseline) First Year Labor Costs, by Activity and Geographic Location ($2010) 

Activity Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical 

1. Rule Familiarization 

Producers1 - - $108,928 - - $332,378 - Fabricators1 - - $23,463,974 - - $9,150,835 - Wholesalers2 - - $31,927,570 - - $12,451,603 - Retailers3 - - $214,689,136 - - - - 

2. Certification Fee - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - $23,406 - - $218,076 - Without Existing Certifications - - $164,413 - - $208,371 - 

4. Develop Quality Control Manual4 - - $822,067 - - $1,041,856 - 5. Qualifying Test - - - - - - - 6. Qualifying Test Shipment4

1 Product - - $428 - - $4,638 - 2 Products - - $10,347 - - $13,059 - 

7. Correlation Test4

1 Product - - $7,850 - - $92,054 - 2 Products - - $411,034 - - $520,928 - 

8. Quarterly On-site Audit4

Standard - - $290,292 - - $610,556 - NAF (With New Certification) - - $4,852 - - $78,781 - NAF (With Existing Certification) - - - - - - - 

9. Large Scale Testing Fee - - - - - - - 10. Large Scale Testing Shipment4

Standard Certification - - $36,322 - - $76,355 - NAF (With New Certification) - - $642 - - $9,848 - NAF (With Existing Certification) - - - - - - - 

11. On-site Audit Travel4 - - - - - - - 12. Desk Audits4

Standard Certification - - $193,528 - - $407,037 - NAF (With New Certification) - - $2,426 - - $39,391 - 

13. Purchase of Small Chamber Testing Unit - - - - - - - 14. Quality Control Testing4

Standard Certification - - $12,579,341 - - $26,457,434 - New NAF Certification - - $157,706 - - $2,560,397 - 

15. Lost Product - - - - - - - 16. Initial Recordkeeping5 $12,955,676 - - $18,045,210 - - $31,000,886 17. Recurring Recordkeeping 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 54 of 99 

Exhibit 6-15: Total (including baseline) First Year Labor Costs, by Activity and Geographic Location ($2010) 

Activity Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical 

Producers4 $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 Labeling 

Minor Changes - Producers6 $13,861 - - $152,170 - - $166,031 Minor Changes – Fabricators7 - $8,538,355 - - $3,318,391 - - Major Changes – Producers6 $688,068 - - $268,272 - - $956,340 Major Changes - Fabricators and Wholesalers7 - $72,009,582 - - $28,084,888 - - $

Total - Year 1 $84,405,781 $80,547,937 $284,894,191 $71,419,619 $31,403,279 $54,273,597 $155,825,426 $Notes: 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 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. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 55 of 99 

Exhibit 6-16: Total (including baseline) Second and Third Year Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical 

1. Rule Familiarization 

Producers1 - - - - - - - Fabricators1 - - - - - - - Wholesalers2 - - - - - - - Retailers3 - - - - - - - 

2. Certification Fee - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - - - - - - Without Existing Certifications - - - - - - - 

4. Develop Quality Control Manual - - - - - - - 5. Qualifying Test - - - - - - - 6. Qualifying Test Shipment7

1 Product - - - - - - - 2 Products - - - - - - - 

7. Correlation Test4

1 Product - - - - - - - 2 Products - - - - - - - 

8. Quarterly On-site Audit4

Standard Certification - - $387,057 - - $814,075 - NAF (With New Certification) - - $4,852 - - $78,781 - NAF (With Existing Certification) - - $3,996 - - $39,962 - 

9. Large Scale Testing Fee - - - - - - - 10. Large Scale Testing Shipment4

Standard Certification - - $48,382 - - $101,759 - NAF (With New Certification) - - $642 - - $9,848 - NAF (With Existing Certification) - - $500 - - $4,995 - 

11. On-site Audit Travel - - - - - - - 12. Desk Audits4

Standard Certification - - $193,528 - - $407,037 - NAF (With New Certification) - - - - - - - 

13. Purchase of Small Chamber - - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 56 of 99 

Exhibit 6-16: Total (including baseline) Second and Third Year Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical 

Testing Unit 14. Quality Control Testing4

Standard Certification - - $12,579,341 - - $26,457,434 - New NAF Certification - - - - - - - 

15. Lost Product - - - - - - - 16. Initial Recordkeeping5 - - - - - - - 17. Recurring Recordkeeping 

Producers4 $1,372,966 - - $4,189,403 - - $5,562,369 

Fabricators 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 - - - - - - - Retailers - - - - - - - 

18. Initial Labeling 

Minor Changes - Producers6 - - - - - - - Minor Changes – Fabricators7 - - - - - - - Major Changes – Producers6 - - - - - - - Major Changes - Fabricators and Wholesalers7 - - - - - - - 

Total - Years 2 and 3 $70,748,176 - $13,218,298 $52,953,967 - $27,913,891 $123,702,169 Notes: 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 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. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 57 of 99 

Exhibit 6-17: Three Year Average Labor Costs (including baseline), by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical T

1. Rule Familiarization 

Producers1 - - $36,285 - - $110,768 - Fabricators1 - - $7,820,515 - - $3,049,984 - Wholesalers2 - - $10,641,497 - - $4,150,099 - Retailers3 - - $71,555,904 - - - - 

2. Certification Fee - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - $7,778 - - $72,716 - Without Existing Certifications - - $54,804 - - $69,433 - 

4. Develop Quality Control Manual4 - - $274,022 - - $347,238 - 5. Qualifying Test - - - - - - - 6. Qualifying Test Shipment4

1 Product - - $143 - - $1,499 - 2 Products - - $3,425 - - $4,353 - 

7. Correlation Test4

1 Product - - $2,640 - - $30,685 - 2 Products - - $137,011 - - $173,619 - 

8. Quarterly On-site Audit4

Standard Certification - - $354,802 - - $746,212 - NAF (With New Certification) - - $4,852 - - $78,781 - NAF (With Existing Certification) - - $2,640 - - $26,617 - 

9. Large Scale Testing Fee - - - - - - - 10. Large Scale Testing Shipment4

Standard Certification - - $44,386 - - $93,268 - NAF (With New Certification) 

- - 

$642

- - 

$9,848

- 

NAF (With Existing Certification) - - $357 - - $3,354 - 

11. On-site Audit Travel - - - - - - - 12. Desk Audits4

Standard Certification - - $193,528 - - $407,037 - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 58 of 99 

Exhibit 6-17: Three Year Average Labor Costs (including baseline), by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical T

NAF (With New Certification) - - $785 - - $13,130 - 

13. Purchase of Small Chamber Testing Unit - - - - - - - 14. Quality Control Testing4

Standard Certification - - $12,579,341 - - $26,457,434 - New NAF Certification - - $52,592 - - $853,466 - 

15. Lost Product - - - - - - - 16. Initial Recordkeeping5 $4,318,124 - - $6,014,466 - - $10,332,590 17. Recurring Recordkeeping 

Producers4 $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 Labeling 

Minor Changes – Producers6 $4,620 - - $50,723 - - $55,344 Minor Changes – Fabricators7 - $2,845,853 - - $1,106,042 - - $Major Changes – Producers6 $229,323 - - $89,424 - - $318,747 Major Changes - Fabricators and Wholesalers7 - $24,000,803 - - $9,360,714 - - $3

Total - Three Year Average $75,300,243 $26,846,656 $103,767,949 $59,108,580 $10,466,756 $36,699,541 $134,408,850 $3Notes: 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 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. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 59 of 99 

Exhibit 6-18: Incremental First Year Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical T

1. Rule Familiarization 

Producers1 - - $108,928 - - $332,378 - Fabricators1 - - $23,463,974 - - $9,150,835 - Wholesalers2 - - $31,927,570 - - $12,451,603 - Retailers3 - - $214,689,136 - - - - 

2. Certification Fee - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - $23,406 - - $218,076 - Without Existing Certifications - - $164,413 - - $208,371 - 

4. Develop Quality Control Manual4 - - $822,067 - - $1,041,856 - 5. Qualifying Test - - - - - - - 6. Qualifying Test Shipment4

1 Product - - $428 - - $4,638 - 2 Products - - $10,276 - - $13,059 - 

7. Correlation Test4

1 Product - - $7,850 - - $92,054 - 2 Products - - $411,034 - - $520,928 - 

8. Quarterly On-site Audit4

Uncertified to Standard - - $237,201 - - $131,873 - ULEF to Standard - - $9,420 - - $97,620 - NAF (With New Certification) - - $3,140 - - $60,228 - 

9. Large Scale Testing Fee - - - - - - - 10. Large Scale Testing Shipment4

Uncertified to Standard - - $29,686 - - $16,484 - ULEF to Standard - - $1,213 - - $12,203 - NAF (With New Certification) - - $428 - - $7,564 - 

11. On-site Audit Travel - - - - - - - 12. Desk Audits4

Uncertified to Standard - - $158,134 - - $87,916 - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 60 of 99 

Exhibit 6-17: Three Year Average Labor Costs (including baseline), by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical T

ULEF to Standard - - $6,280 - - $65,080 - NAF (With New Certification) - - $1,570 - - $30,114 - 

13. Purchase of Small Chamber Testing Unit - - - - - - - 14. Quality Control Testing4

Standard Certification - - $10,686,874 - - $9,944,730 - New NAF Certification - - $157,706 - - $2,560,397 - 

15. Lost Product - - - - - - - 16. Initial Recordkeeping5 $12,955,676 - - $18,045,210 - - $31,000,886 17. Recurring Recordkeeping 

Producers4 $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 Labeling 

Minor Changes - Producers6 $13,861 - - $152,170 - - $166,031 Minor Changes – Fabricators7 - $8,538,355 - - $3,318,391 - - Major Changes – Producers6 $688,068 - - $268,272 - - $956,340 Major Changes - Fabricators and Wholesalers7 - $72,009,582 - - $28,084,888 - - $

Total - Year 1 $57,225,482 $80,547,937 $282,920,734 $52,683,041 $31,403,279 $37,048,007 $109,908,497 $
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 61 of 99 

Exhibit 6-17: Three Year Average Labor Costs (including baseline), by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical T

Notes: 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 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. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 62 of 99 

Exhibit 6-19: Incremental Second and Third Year Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical 

1. Rule Familiarization 

Producers1 - - - - - - - Fabricators1 - - - - - - - Wholesalers2 - - - - - - - Retailers3 - - - - - - - 

2. Certification Fee - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - - - - - - Without Existing Certifications - - - - - - - 

4. Develop Quality Control Manual4 - - - - - - - 5. Qualifying Test - - - - - - - 6. Qualifying Test Shipment4

1 Product - - - - - - - 2 Products - - - - - - - 

7. Correlation Test4

1 Product - - - - - - - 2 Products - - - - - - - 

8. Quarterly On-site Audit4

Uncertified to Standard - - $316,268 - - $175,831 - ULEF to Standard - - $9,420 - - $97,620 - NAF (With New Certification) - - $3,140 - - $60,228 - 

9. Large Scale Testing Fee - - - - - - - 10. Large Scale Testing Shipment4

Uncertified to Standard - - $39,533 - - $21,979 - ULEF to Standard - - $1,213 - - $12,203 - NAF (With New Certification) - - $428 - - $7,564 - 

11. On-site Audit Travel - - - - - - - 12. Desk Audits4

Uncertified to Standard - - $158,134 - - $87,916 - ULEF to Standard - - $6,280 - - $65,080 - NAF (With New Certification) - - - - - - - 

13. Purchase of Small Chamber Testing Unit - - - - - - - 14. Quality Control Testing4

Standard Certification - - $10,686,874 - - $9,944,730 - New NAF Certification - - - - - - - 

15. Lost Product - - - - - - - 16. Initial Recordkeeping5 - - - - - - - 17. Recurring Recordkeeping 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 63 of 99 

Exhibit 6-19: Incremental Second and Third Year Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical 

Producers4 $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 Labeling 

Minor Changes - Producers6 - - - - - - - Minor Changes - Fabricators7 - - - - - - - Major Changes - Producers6 - - - - - - - Major Changes - Fabricators and Wholesalers7 - - - - - - - 

Total - Years 2 and 3 $43,567,877 - $11,221,290 $34,217,389 - $10,473,151 $77,785,240 Notes: 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 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. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 64 of 99 

Exhibit 6-20: Three Year Average Incremental Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical 

1. Rule Familiarization 

Producers1 - - $36,285 - - $110,768 - Fabricators1 - - $7,820,515 - - $3,049,984 - Wholesalers2 - - $10,641,497 - - $4,150,099 - Retailers3 - - $71,555,904 - - - - 

2. Certification Fee - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - $7,778 - - $72,716 - Without Existing Certifications - - $54,804 - - $69,433 - 

4. Develop Quality Control Manual4 - - $274,022 - - $347,238 - 5. Qualifying Test - - - - - - - 6. Qualifying Test Shipment4

1-Product by TPC - - $143 - - $1,499 - 2-Product by TPC - - $3,425 - - $4,353 - 

7. Correlation Test4

1-Product by TPC - - $2,640 - - $30,685 - 2-Product by TPC - - $137,011 - - $173,619 - 

8. Quarterly On-site Audit4

Uncertified to Standard - - $289,936 - - $161,202 - ULEF to Standard - - $9,420 - - $97,620 - NAF (With New Certification) - - $3,140 - - $60,228 - 

9. Large Scale Testing Fee - - - - - - - 10. Large Scale Testing Shipment4

Uncertified to Standard - - $36,251 - - $20,124 - ULEF to Standard - - $1,213 - - $12,203 - NAF (With New Certification) - - $428 - - $7,564 - 

11. On-site Audit Travel - - - - - - - 12. Desk Audits4

Uncertified to Standard - - $158,134 - - $87,916 - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 65 of 99 

Exhibit 6-20: Three Year Average Incremental Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical 

ULEF to Standard - - $6,280 - - $65,080 - NAF (With New Certification) - - $500 - - $10,062 - 

13. Purchase of Small Chamber Testing Unit - - - - - - - 14. Quality Control Testing4

Standard Certification - - $10,686,874 - - $9,944,730 - New NAF Certification - - $52,592 - - $853,466 - 

15. Lost Product - - - - - - - 16. Initial Recordkeeping5 $4,318,124 - - $6,014,466 - - $10,332,590 17. Recurring Recordkeeping 

Producers4 $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 Labeling 

Minor Changes – Producers6 $4,620 - - $50,723 - - $55,344 Minor Changes – Fabricators7 - $2,845,853 - - $1,106,042 - - Major Changes - Producers6 $229,323 - - $89,424 - - $318,747 Major Changes - Fabricators and Wholesalers7 - $24,000,803 - - $9,360,714 - - 

Total - Three Year Average $48,119,944 $26,846,656 $101,778,792 $40,372,002 $10,466,756 $19,330,589 $88,491,921 Notes: 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 testing and certification and recordkeeping for composite panel producers. 5. The analysis uses a loaded wage rate of $25.54 for recordkeeping for wholesalers. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 66 of 99 

Exhibit 6-20: Three Year Average Incremental Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign 

Clerical Technical Managerial Clerical Technical Managerial Clerical 

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. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 67 of 99 

1100 Non-Labor Costs 

1101 

1102 This subsection presents the non-labor costs associated with the recordkeeping and 

1103 reporting requirements of the proposed TSCA Title VI rule. The different categories of 

1104 respondents (composite panel producers, fabricators, wholesalers, and retailers) are presented 

1105 separately because they engage indifferent activities. There are no activities that are common to 

1106 all respondents. Exhibit 6-22 through Exhibit 6-24 summarizes the number of respondents, per1107 respondent and total non-labor costs for each response activity over the next three years. Exhibit 

1108 6-25 through Exhibit 6-27 present the corresponding incremental costs. 

1109 

1110 (A). Composite Panel Producers

1111 

1112 Composite panel producers will incur non-labor costs from testing and certification 

1113 activities. As stated above, this analysis assumes that product lines that have a standard 

1114 certification or a NAF certification under the CARB ATCM will not have to submit new data or 

1115 resubmit existing data to their TPC in order to receive the equivalent certification under the 

1116 TSCA Title VI regulations. In addition, this analysis assumes that two percent of wood veneer 

1117 laminated product producers will continue to use added formaldehyde resins and thus be 

1118 classified as hardwood plywood producers. These entities are not certified by CARB and so will 

1119 incur the burdens associated with first time certification by a TPC. 

1120 

1121 Certification Fees (Activity #2) 

1122 

1123 CPA and HPVA charge administrative fees to mills for certifying their products. CPA 

1124 charges a quarterly fee of $1,500 regardless of NAF status, which is equivalent to $6,000 per 

1125 year. HPVA charges an annual program fee of $4,500 to $5,500 (depending on membership 

1126 status) to mills that are not NAF certified. Mills with NAF certifications are required to pay the 

1127 standard annual program fee in the first year and an annual fee of $2,700 to $3,700 in all 

1128 subsequent years. This analysis assumes that the annual certification fee for mills with standard 

1129 certification is $6,000, the fees for uncertified or standard-certified mills with new NAF 

1130 certifications are $6,000 in the first year and $3,700 in all subsequent years, and the annual 

certification fee for mills with a current NAF or ULEF certification is $3,700.23,24 1131 

1132 

Exhibit 6-21: Certification Fees 

Cost Category Certification Type Fee 

Initial Fee All $6,000 

Annual Fee Standard $6,000 

NAF/ULEF $3,700 

1133 

1134 

1135 

1136 

 23 A mill with NAF/ULEF certifications is assumed to have one product line that is NAF certified and one product line that is 

ULEF certified under the CARB ATCM. It is assumed that all mills with NAF/ULEF certification will seek NAF certification 

for the ULEF product line. 

24 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 NAF and other lines that are not. The NAF testing costs do not apply to any product lines 

that are not NAF certified. 
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1137 Qualifying Test (Activity #5) 

1138 

1139 Under TSCA Title VI, a composite panel producer is required to obtain five qualifying 

1140 tests for each product type (e.g., hardwood plywood – veneer core) and production line from the 

1141 mill for which certification is sought. This ICR assumes that all qualifying testing is performed 

1142 using the primary test method, large chamber test, as defined by ASTM International Standard 

E1333. This ICR assumes a cost of $480 per large scale test based on HPVA’s 2010 fee.25 1143 This 

1144 analysis assumes that mills making product lines that have a standard certification or a NAF 

1145 certification under the CARB ATCM will not need to submit new data or resubmit existing data 

1146 to their existing TPC in order to receive the equivalent certification under the TSCA Title VI 

1147 regulations. Thus, producers that are already CARB compliant and are not expected to adopt a 

1148 more stringent certification type (e.g., NAF certification) will not incur this burden. 

1149 

1150 Qualifying Test Shipping (Activity #6) 

1151 

1152 Mills are expected to ship at least five 4’ x 8’ panels for each product type via a 

1153 commercial shipping carrier. Panels must be dead-stacked (i.e., having no layers between 

1154 panels), bundled air-tight, wrapped in polyethylene, and protected by cover sheets. Based on 

1155 conversations with CPA and with CARB-certified mills, the total shipping cost for the qualifying 

1156 tests is estimated to be approximately $200 per product line. This analysis assumes that mills 

1157 making product lines that have a standard certification or a NAF certification under the CARB 

1158 ATCM will not need to submit new data or resubmit existing data to their existing TPC in order 

1159 to receive the equivalent certification under the TSCA Title VI regulations. Thus, producers that 

1160 are already CARB compliant and are not expected to adopt a more stringent certification type 

1161 will not incur this burden. 

1162 

1163 Quarterly On-site Audit (Activity #8) 

1164 

1165 The TPC is responsible for conducting on-site visits to certified mills. Before the initial 

1166 certification, the TPC is expected to make at least one trip to the mill to inspect the mill’s quality 

1167 control systems and employees. During the initial visit, the TPC will assist the mill in setting up 

1168 quality control systems, including the small scale testing facility, if applicable, and methods for 

1169 selecting samples. After certification has been granted, the TPC is obligated to perform an on1170 site audit at least once quarterly, unless the mill obtains NAF certification. Audits typically do 

1171 not take more than one day of travel and visitation, though if the mill requires a substantial 

number of modifications or is unprepared, the duration of the visit may be longer.26 1172 

1173 

1174 The cost of the audit is borne by the composite panel producer and has two components: 

1175 audit fees and travel costs. Site audit fees can range from $300 to $450 for initial visits and from 

1176 $400 to $450 for quarterly visits, depending on the TPC. Based on these ranges, this analysis 

1177 assumes that will mills will pay a fee of $450 per visit. 

1178 

1179 As in the burden section, this analysis assumes that producers with new NAF 

 25 This is the rate charged by HPVA’s Reston Lab to non-members 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. 26 Personal Communication with HPVA 2011
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1180 certifications will incur the costs associated with one on-site audit (in addition to the initial audit) 

1181 and two desk audits in the first year. The initial on-site audit is assumed to be sufficient for 

1182 producers with existing NAF certifications. All NAF-certified producers will have one on-site 

1183 audit annually thereafter. 

1184 

1185 Large Scale Testing Fees (Activity #9) 

1186 

1187 As described above, it is assumed that each large scale test costs $480. Mills are required 

1188 to perform large scale testing quarterly unless all products are certified as NAF. It is assumed 

1189 that mills with only NAF-certified products will perform large scale testing annually. In the first 

1190 year, mills with added-formaldehyde products will test those products three times in addition to 

1191 the qualifying testing, and mills with NAF products will test those once at the end of the 

1192 qualifying process. Note that some respondents are assumed to have both standard and NAF 

1193 certifications. 

1194 

1195 Large Scale Testing Shipping (Activity #10) 

1196 

1197 Mills are expected to ship one 4’ x 8’ panel for each product type via a commercial 

1198 shipping carrier. Panels must be dead-stacked (i.e., having no layers between panels), bundled 

1199 air-tight, wrapped in polyethylene, and protected by cover sheets. Based on conversations with 

1200 CPA and with CARB-certified mills, the total shipping cost for the quarterly tests is estimated to 

1201 be approximately $50 per product line. Note that some respondents are assumed to have both 

1202 standard and NAF certifications. 

1203 

1204 On-site Audit Travel (Activity #11) 

1205 

1206 Travel costs can vary depending on the relative location of the mill to the TPC; mills 

1207 within a close proximity may not incur any travel costs, whereas a mill across the country may 

1208 incur travel costs of up to $2,000 per visit. It is assumed that travel is only necessary for the 

1209 annual audits, as other intermediate audits can be performed by contracting inspectors closer to 

1210 the mill. Therefore, this analysis assumes that each annual audit costs $1,500 in travel costs. All 

1211 composite panel producers are assumed to incur this cost. 

1212 

1213 Desk Audits (Activity #12) 

1214 

1215 TPCs may conduct periodic “desk audits,” which are quality control checks performed 

1216 over the phone in which the mill’s small scale testing procedures and data are reviewed. Desk 

1217 audits are assumed to occur monthly, except in months with quarterly on-site audits. Based on 

1218 fees charged by CPA and HPVA, it is assumed that each desk audit costs $250. 

1219 

1220 As in the burden section, this analysis assumes that producers with new NAF 

1221 certifications will incur the costs associated with two desk audits in the first year; none are 

1222 performed in subsequent years. No additional desk audits are assumed to be performed as a 

1223 result of this rule for respondents with existing NAF certification. 

1224 

1225 
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1226 Small Chamber Testing Unit (Activity #13) 

1227 

1228 This analysis assumes that all panel manufacturers that are required to perform routine 

1229 quality control testing will use their own small chamber testing unit rather than have the TPC 

1230 perform the testing. It is assumed that the unit costs $10,000 to purchase. 

1231 

1232 Quality Control Testing (Activities #14) 

1233 

1234 To maintain certification, a mill must perform small scale quality control testing for each 

1235 certified product type and production line. Mills have the option of constructing an on-site lab 

1236 and having it approved by a TPC, or contracting a certified third-party lab to perform small scale 

1237 quality control testing. According to CPA and HPVA, particleboard and MDF mills already 

1238 have their own on-site labs to test for formaldehyde (because they have to test their products on a 

1239 daily basis under the CARB ATCM), while most smaller hardwood plywood mills pay their TPC 

1240 to conduct their quality control testing. (In part because hardwood plywood mills often use 

1241 ULEF or NAF resins to qualify for exemptions from some of the on-going testing requirements 

1242 under the CARB ATCM.) However, the CARB ATCM allows mills to ship panels from 

1243 certified product lines before test results are available. By contrast, the proposed TSCA rule 

1244 requires mills to wait until test results indicate that the emissions standards have been met before 

1245 shipping a lot that has been tested. It is uncertain how often mills currently ship product from a 

1246 lot being tested before the test results are available and therefore it is uncertain how mills will 

1247 choose to comply with this requirement. It may be the case that some mills normally maintain a 

1248 level of inventory where they would typically not ship any panels before test results have been 

1249 determined for that lot, but other mills may ship out panels on the same day they are produced. 

1250 This analysis assumes that all mills that do not already do so will opt to set up and operate a 

1251 quality control testing facility on-site, in order to minimize the time spent waiting for test results, 

1252 and to maximize their flexibility to ship out panels shortly after they have been produced. 

1253 (Assuming that mills conduct on-site testing may overstate the costs of this requirement if some 

1254 mills find it more cost effective to hold products in inventory until test results have been 

1255 determined by an outside lab. Producers that are already CARB compliant and are not expected 

1256 to adopt a more stringent certification type will not need to perform correlation testing. 

1257 

1258 HPVA typically uses a desiccator test for small scale testing, but small chamber tests may 

1259 also be performed. Each instance of desiccator testing requires three small samples to be cut 

1260 from a larger panel and tested. It is assumed that mills will incur fees of $70 per desiccator test 

1261 and $405 per small chamber test. The mean cost, weighted by the number of tests needed (three 

1262 for desiccator testing), is $154. 

1263 

1264 Lost Product (Activity #15) 

1265 

1266 Mills will need to forfeit a number of panels for initial and on-going testing. Mills are 

1267 expected to ship five 4’ x 8’ panels per product type for qualifying testing. Producers will lose 

1268 one panel per product type each day for quality control testing. In addition to routine small scale 

1269 testing, mills are required to send one panel per product type to the TPC for large scale testing 

1270 each quarter. However, product lines that are certified as NAF are exempt from routine quality 

1271 control testing after the three month qualifying period, and need only have large scale testing 
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1272 performed annually. Note that the total respondents with lost product costs presented in the 

1273 exhibits below sum to more than the total number of respondents because some respondents are 

1274 assumed to have both standard and NAF certifications. 

1275 

1276 This analysis estimated the cost of each panel using the average cost per square foot of 

1277 hardwood plywood, $0.49 and particleboard, $0.28 (RISI 2010). Assuming a panel size of 32 sq. 

1278 ft., each hardwood plywood panel will cost the mill $15.68, and each particleboard panel will 

1279 cost $8.96. 

1280 

1281 (B). Fabricators

1282 

1283 Fabricators are subject to the proposed rule’s recordkeeping and labeling requirements. 

1284 However, not all fabricators incur the non-labor costs associated with proposed rule because 1) 

1285 they may already complying with the CARB ATCM (Exhibit 6-5) or 2) their existing systems 

1286 are sufficient to meet the requirements. As stated above, this analysis assumes that 98 percent of 

1287 wood veneer laminated product producers will likely switch to NAF resins and be classified as 

1288 fabricators. It is assumed that the entirety of this subset of fabricators will incur the non-labor 

1289 costs associated with supplier notification. 

1290 

1291 As described in the Economic Analysis for the rulemaking, one respondent to the 

1292 fabricator questionnaire reported that that they would incur a one-time cost of $250 for 

1293 purchasing new stamps for labeling. To remain consistent with the labor section, this cost was 

1294 averaged across the two firms that reported more significant costs. As a result, this analysis 

1295 assumes that the 33 percent of fabricators that are not CARB compliant in the baseline will incur 

1296 an initial non-labor cost of approximately $125.00 ($250/2) associated with the labeling 

1297 requirements. There are not expected to be any non-labor costs associated with recordkeeping 

1298 for fabricators. 

1299 

1300 (C). Wholesalers

1301 

1302 Wholesalers are subject to the proposed rule’s recordkeeping and labeling requirements. 

1303 This analysis assumes that 1 percent of wholesalers will repackage their products and so will 

1304 incur an initial non-labor labeling cost. It is assumed that these wholesalers incur the same costs 

1305 as the fabricators described above (an average of $125.00). In addition, not all wholesalers will 

1306 incur the non-labor costs associated with recordkeeping because 1) they are already complying 

1307 with the CARB ATCM (Exhibit 6-6), 2) their existing systems are sufficient to meet the 

1308 requirements, or 3) they do not import composite wood products or articles that contain 

1309 composite wood products and so are only required to keep ordinary business records. 

1310 

1311 As described in the Economic Analysis for the rulemaking, only one respondent to the 

1312 wholesaler questionnaire reported that they incurred non-labor costs (a one-time cost of $2,000 

1313 for programming changes). The average non-labor cost is calculated for firms reporting 

1314 quantified costs. As a result, this analysis assumes that the 57 percent of wholesalers that import 

1315 composite wood products and/or articles that contain composite wood products will incur an 

1316 initial non-labor cost of approximately $1,000 ($2,000/2) associated with the recordkeeping 

1317 requirements (since one of two firms reporting costs reported a non-labor cost of $2,000). As 
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1318 indicated above, this analysis assumes that 28 percent of domestic wholesalers import composite 

1319 wood products and/or articles that contain composite wood products. There are not expected to 

1320 be any non-labor costs associated with recurring recordkeeping costs. 

1321 

1322 (D). Retailers

1323 

1324 As stated above, retailer’s customary business practices are assumed to be generally 

sufficient to meet the proposed rule’s recordkeeping requirements.27 1325 In addition, retailers are 

1326 assumed not to repackage goods made with composite wood products, and thus do not incur 

1327 costs to modify labeling systems to comply with the proposed rule. 

1328 

1329 (E). Summary

1330 

1331 Exhibit 6-22 and Exhibit 6-23 summarize the total (including baseline) per-activity non1332 labor costs for all the respondents over the first year, and second and third years of the rule, 

1333 respectively. Exhibit 6-24 presents the average non-labor costs over the first three years of the 

1334 rule, respectively. Exhibit 6-25 through Exhibit 6-27 mirror the previous three tables, except that 

1335 they account for incremental non-labor costs (excluding baseline non-labor costs). Note that the 

1336 number of respondents cannot be summed across activities because many respondents are 

1337 incurring multiple burdens. As indicated, the average total annual non-labor cost (including 

1338 baseline) over the first three years of the rule is estimated at approximately $37.3 million, while 

1339 the incremental non-labor costs are $25.6 million. The domestic non-labor costs account for 

1340 approximately 34.5 percent ($12.9 million) and 46.3 percent ($11.9 million) of these totals, 

1341 respectively. 

 27 Personal Communication with CRA 2011). 
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Exhibit 6-22: Total (including baseline) First Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

T

Domestic Foreign1 Total Domestic 

1. Rule Familiarization - - - - - - 2. Certification Fee2

Standard3 339 713 1,052 1 $6,000 $2,034,000 NAF (From Uncertified or Standard) 11 211 222 1 $6,000 $66,000 NAF (From NAF or NAF/ULEF) 20 205 225 1 $3,700 $74,000 

3. Initial On-site Audit 

With Existing Certifications 82 764 846 1 $450 $36,900 Without Existing Certifications3,4 288 365 653 1 $450 $129,600 

4. Develop Quality Control Manual - - - - - - 5. Qualifying Test5

1 Product 11 129 140 5 $480 $26,400 2 Products3,4 288 365 653 10 $480 $1,382,400 

6. Qualifying Test Shipping5

1 Product 11 129 140 1 $200 $2,200 2 Products3,4 288 365 653 2 $200 $115,200 

7. Correlation Test - - - - - - 8. Quarterly On-site Audit6

Standard3,4 339 713 1,052 3 $450 $457,650 NAF (With New Certification) 17 276 293 1 $450 $7,650 NAF (With Existing Certification) 14 140 154 - $450 - 

9. Large Scale Testing Fee7

1 Standard (Existing) 8 86 94 4 $480 $15,360 2 Standard (New)3,4 277 154 431 6 $480 $797,760 2 Standard (Existing) 54 473 527 8 $480 $207,360 1 NAF 3 22 25 1 $480 $1,440 2 NAF 31 416 447 2 $480 $29,760 

10. Large Scale Testing Shipment7

1 Standard (Existing) 8 86 94 4 $50 $1,600 2 Standard (New)3,4 277 154 431 6 $50 $83,100 2 Standard (Existing) 54 473 527 8 $50 $21,600 1 NAF 3 22 25 1 $50 $150 2 NAF 31 416 447 2 $50 $3,100 

11. On-site Audit Travel 370 1,129 1,499 1 $1,500 $555,000 12. Desk Audits8

Standard3,4 339 713 1,052 8 $250 $678,000 NAF 17 276 293 2 $250 $8,500 

13. Purchase of Small Chamber Testing 295 350 645 1 $10,000 $2,950,000 
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Exhibit 6-22: Total (including baseline) First Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

T

Domestic Foreign1 Total Domestic 

Unit314. Quality Control Testing - - - - - - 15. Lost Product7

2 Standard (HWPW - Existing)3,4 295 304 599 528 $15.68 $2,442,317 1 NAF (HWPW - New) 5 55 60 71 $15.68 $5,566 1 NAF (HWPW - Existing) 5 55 60 1 $15.68 $78 2 NAF (HWPW - New) 11 211 222 142 $15.68 $24,492 2 NAF (HWPW - Existing) 7 76 83 2 $15.68 $220 1 Standard (PB/MDF - Existing) 8 86 94 264 $8.96 $18,924 2 Standard (PB/MDF - New) - 46 46 536 $8.96 - 2 Standard (PB/MDF - Existing) 36 277 313 528 $8.96 $170,312 1 NAF (PB/MDF - New) 1 10 11 71 $8.96 $636 1 NAF (PB/MDF - Existing) 4 32 36 1 $8.96 $36 2 NAF (PB/MDF - Existing) 7 64 71 2 $8.96 $125 

16. Initial Recordkeeping9 8,576 11,945 20,521 1 $1,000 $8,576,000 17. Recurring Recordkeeping - - - - - - 18. Initial Labeling10

Minor Changes - Producers - - - - - - Minor Changes - Fabricators - - - - - - Major Changes – Producers3 277 108 385 1 $125 $34,625 Major Changes - Fabricators and Wholesalers11 16,266 6,344 22,610 1 $125 $2,033,250 

Total - Year 1 $22,991,311 
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Exhibit 6-22: Total (including baseline) First Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

T

Domestic Foreign1 Total Domestic 

Notes: 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 NAICshipments 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 typroducts or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified prodanalysis 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 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 thhardwood 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 that that mills will seek standard certification for uncertified and ULEF product lines. The exceptions are 1) mills that are both ULEF and NAF certitwo NAF product lines; and 2) uncertified hardwood plywood producers, which are assumed to switch to NAF certification. 5. Producers that are already CARB compliant and are not expected adopt a more stringent certification type (e.g., NAF certification) are assumed not to need to perform qualis assumed that their previous testing is sufficient. 6. On-site audits must be conducted at least once quarterly, unless the mill obtains NAF certification. This analysis assumes that producers with new NAF certifications will inon-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing NAF certifications under the CARB ATCM will only incur the initiaproducers with NAF 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 have both standard and NAF certifications. 8. Desk audits are assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with two required in subsequent years. No desk audits are required for respondents with existing NAF certification. 9. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneer laminated product producers defined as harfabricators, 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 pHowever, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percecomposite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying with the Cto change their recordkeeping systems to comply with the TSCA Title VI rule. 10. Firms that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their name, tproduced, 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 the packaThis 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 incur a nopurchasing 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.
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Exhibit 6-23: Total (including baseline) Second and Third Year Non-Labor Costs, by Activity and Geographic Locat

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

T

Domestic Foreign1 Total Domestic 

1. Rule Familiarization - - - - - - 2. Certification Fee2

Standard3 339 713 1,052 1 $6,000 $2,034,000 NAF (From Uncertified or Standard) 11 211 222 1 $3,700 $40,700 NAF (From NAF or NAF/ULEF) 20 205 225 1 $3,700 $74,000 

3. Initial On-site Audit 

With Existing Certifications - - - - - - Without Existing Certifications3,4 - - - - - - 

4. Develop Quality Control Manual - - - - - - 5. Qualifying Test5

1 Product - - - - - - 2 Products3,4 - - - - - - 

6. Qualifying Test Shipping5

1 Product - - - - - - 2 Products3,4 - - - - - - 

7. Correlation Test5 - - - - - - 8. Quarterly On-site Audit6

Standard3,4 339 713 1,052 4 $450 $610,200 NAF (With New Certification) 17 276 293 1 $450 $7,650 NAF (With Existing Certification) 14 140 154 1 $450 $6,300 

9. Large Scale Testing Fee7

1 Standard (Existing) 8 86 94 4 $480 $15,360 2 Standard (New)3,4 277 154 431 6 $480 $797,760 2 Standard (Existing) 54 473 527 8 $480 $207,360 1 NAF 3 22 25 1 $480 $1,440 2 NAF 31 416 447 2 $480 $29,760 

10. Large Scale Testing Shipment7

1 Standard (Existing) 8 86 94 4 $50 $1,600 2 Standard (New)3,4 277 154 431 6 $50 $83,100 2 Standard (Existing) 54 473 527 8 $50 $21,600 1 NAF 3 22 25 1 $50 $150 2 NAF 31 416 447 2 $50 $3,100 

11. On-site Audit Travel 370 1,129 1,499 1 $1,500 $555,000 12. Desk Audits8

Standard3,4 339 713 1,052 8 $250 $678,000 NAF - - - - - - 

13. Purchase of Small Chamber Testing Unit3 - - - - - - 14. Quality Control Testing - - - - - - 
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Exhibit 6-23: Total (including baseline) Second and Third Year Non-Labor Costs, by Activity and Geographic Locat

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

T

Domestic Foreign1 Total Domestic 

15. Lost Product7

2 Standard (HWPW - Existing)3,4 295 304 599 528 $15.68 $2,442,317 1 NAF (HWPW - New) 5 55 60 1 $15.68 $78 1 NAF (HWPW - Existing) 5 55 60 1 $15.68 $78 2 NAF (HWPW - New) 11 211 222 2 $15.68 $345 2 NAF (HWPW - Existing) 7 76 83 2 $15.68 $220 1 Standard (PB/MDF - Existing) 8 86 94 264 $8.96 $18,924 2 Standard (PB/MDF - New) - 46 46 536 $8.96 - 2 Standard (PB/MDF - Existing) 36 277 313 528 $8.96 $170,312 1 NAF (PB/MDF - New) 1 10 11 1 $8.96 $9 1 NAF (PB/MDF - Existing) 4 32 36 1 $8.96 $36 2 NAF (PB/MDF - Existing) 7 64 71 2 $8.96 $125 

16. Initial Recordkeeping9 - - - - - - 17. Recurring Recordkeeping - - - - - - 18. Initial Labeling10

Minor Changes - Producers - - - - - - Minor Changes - Fabricators - - - - - - Minor Changes – Wholesalers3 - - - - - - Major Changes – Fabricators11 - - - - - - 

Total - Years 2 and 3 $7,799,524 $Notes: 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 Nvalue 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 retacomposite wood products or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that thimported 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 TPC 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 therefas hardwood 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 that that mills will seek standard certification for uncertified and ULEF product lines. The exceptions are 1) mills that are both ULEF and NAF switch 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 compliant and are not expected adopt a more stringent certification type (e.g., NAF certification) are assumed not to need to perform because it is assumed that their previous testing is sufficient. 6. On-site audits must be conducted at least once quarterly, unless the mill obtains NAF certification. This analysis assumes that producers with new NAF certifications wwith one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing NAF certifications under the CARB ATCM will only the first year. All producers with NAF 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 have both standard and NAF certifications. 8. Desk audits are assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with none are required in subsequent years. No desk audits are required for respondents with existing NAF certification. 9. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneer laminated product producers defined aproducers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to 
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Exhibit 6-23: Total (including baseline) Second and Third Year Non-Labor Costs, by Activity and Geographic Locat

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

T

Domestic Foreign1 Total Domestic 

the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule. 10. Firms that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their nawas 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 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 Calicost 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.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 79 of 99 

Exhibit 6-24: Three Year Average Non-Labor Costs (including baseline), by Activity and Geographic Location ($201

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

Domestic Foreign1 Total Domestic 

1. Rule Familiarization - - - - - - 2. Certification Fee2

Standard3 339 713 1,052 1.0000 $6,000.00 $2,034,000 NAF (From Uncertified or Standard) 11 211 222 1.0000 $4,466.67 $49,133 NAF (From NAF or NAF/ULEF) 20 205 225 1.0000 $3,700.00 $74,000 

3. Initial On-site Audit 

With Existing Certifications 82 764 846 0.3333 $450.00 $12,299 Without Existing Certifications3,4 288 365 653 0.3333 $450.00 $43,196 

4. Develop Quality Control Manual - - - - - - 5. Qualifying Test5

1 Product 11 129 140 1.6667 $480.00 $8,800 2 Products3,4 288 365 653 3.3333 $480.00 $460,795 

6. Qualifying Test Shipping5

1 Product 11 129 140 0.3333 $200.00 $733 2 Products3,4 288 365 653 0.6667 $200.00 $38,402 

7. Correlation Test - - - - - - 8. Quarterly On-site Audit6

Standard3,4 339 713 1,052 3.6667 $450.00 $559,355 NAF (With New Certification) 17 276 293 1.0000 $450.00 $7,650 NAF (With Existing Certification) 14 140 154 0.6667 $450.00 $4,200 

9. Large Scale Testing Fee7

1 Standard (Existing) 8 86 94 4.0000 $480.00 $15,360 2 Standard (New)3,4 277 154 431 6.0000 $480.00 $797,760 2 Standard (Existing) 54 473 527 8.0000 $480.00 $207,360 1 NAF 3 22 25 1.0000 $480.00 $1,440 2 NAF 31 416 447 2.0000 $480.00 $29,760 

10. Large Scale Testing Shipment7

1 Standard (Existing) 8 86 94 4.0000 $50.00 $1,600 2 Standard (New)3,4 277 154 431 6.0000 $50.00 $83,100 2 Standard (Existing) 54 473 527 8.0000 $50.00 $21,600 1 NAF 3 22 25 1.0000 $50.00 $150 2 NAF 31 416 447 2.0000 $50.00 $3,100 

11. On-site Audit Travel 370 1,129 1,499 1.0000 $1,500.00 $555,000 12. Desk Audits8

Standard3,4 339 713 1,052 8.0000 $250.00 $678,000 NAF 17 276 293 0.6667 $250.00 $2,833 

13. Purchase of Small Chamber Testing Unit3 295 350 645 0.3333 $10,000.00 $983,235 14. Quality Control Testing - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 80 of 99 

Exhibit 6-24: Three Year Average Non-Labor Costs (including baseline), by Activity and Geographic Location ($201

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

Domestic Foreign1 Total Domestic 

15. Lost Product7

2 Standard (HWPW - Existing)3,4 295 304 599 528.0000 $15.68 $2,442,317 1 NAF (HWPW - New) 5 55 60 24.3333 $15.68 $1,908 1 NAF (HWPW - Existing) 5 55 60 1.0000 $15.68 $78 2 NAF (HWPW - New) 11 211 222 48.6667 $15.68 $8,394 2 NAF (HWPW - Existing) 7 76 83 2.0000 $15.68 $220 1 Standard (PB/MDF - Existing) 8 86 94 264.0000 $8.96 $18,924 2 Standard (PB/MDF - New) - 46 46 536.0000 $8.96 - 2 Standard (PB/MDF - Existing) 36 277 313 528.0000 $8.96 $170,312 1 NAF (PB/MDF - New) 1 10 11 24.3333 $8.96 $218 1 NAF (PB/MDF - Existing) 4 32 36 1.0000 $8.96 $36 2 NAF (PB/MDF - Existing) 7 64 71 2.0000 $8.96 $125 

16. Initial Recordkeeping9 8,576 11,945 20,521 0.3333 $1,000.00 $2,858,381 17. Recurring Recordkeeping - - - - - - 18. Initial Labeling10

Minor Changes - Producers - - - - - - Minor Changes - Fabricators - - - - - - Major Changes – Producers3 277 108 385 0.3333 $125.00 $11,541 Major Changes - Fabricators and Wholesalers11 16,266 6,344 22,610 0.3333 $125.00 $677,682 

Three-Year Average Cost $12,862,997 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 81 of 99 

Exhibit 6-24: Three Year Average Non-Labor Costs (including baseline), by Activity and Geographic Location ($201

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

Domestic Foreign1 Total Domestic 

Notes: 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 Nvalue 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 retacomposite wood products or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that thimported 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 TPC 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 therefas hardwood 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 that that mills will seek standard certification for uncertified and ULEF product lines. The exceptions are 1) mills that are both ULEF and NAF switch 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 compliant and are not expected adopt a more stringent certification type (e.g., NAF certification) are assumed not to need to perform because it is assumed that their previous testing is sufficient. 6. On-site audits must be conducted at least once quarterly, unless the mill obtains NAF certification. This analysis assumes that producers with new NAF certifications wwith one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing NAF certifications under the CARB ATCM will only the first year. All producers with NAF 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 have both standard and NAF certifications. 8. Desk audits are assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with none are required in subsequent years. No desk audits are required for respondents with existing NAF certification. 9. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneer laminated product producers defined aproducers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule. 10. Firms that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their nawas 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 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 Calicost 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.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 82 of 99 

Exhibit 6-25: Incremental First Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Activity 

T

Domestic Foreign1 Total Domestic 

1. Rule Familiarization - - - - - - 2. Certification Fee2

Uncertified to Standard3,4 277 154 431 1 $6,000 $1,662,000 ULEF to Standard 11 114 125 1 $2,300 $25,300 NAF (With New Certification) 11 211 222 1 $6,000 $66,000 

3. Initial On-site Audit 

With Existing Certifications 82 764 846 - $450 - Without Existing Certifications3,4 288 365 653 1 $450 $129,600 

4. Develop Quality Control Manual - - - - - - 5. Qualifying Test5

1 Product 11 129 140 5 $480 $26,400 2 Products3,4 288 365 653 10 $480 $1,382,400 

6. Qualifying Test Shipping5

1 Product 11 129 140 1 $200 $2,200 2 Products3,4 288 365 653 2 $200 $115,200 

7. Correlation Test5 - - - - - - 8. Quarterly On-site Audit6

Uncertified to Standard3,4 277 154 431 3 $450 $373,950 ULEF to Standard 11 114 125 3 $450 $14,850 NAF (With New Certification) 11 211 222 1 $450 $4,950 

9. Large Scale Testing Fee 

1 New Standard 5 64 69 3 $480 $7,200 2 New Standard3,4 277 154 431 6 $480 $797,760 2 ULEF to 2 Standard 11 114 125 6 $480 $31,680 1 New NAF 6 65 71 1 $480 $2,880 2 New NAF 11 211 222 2 $480 $10,560 

10. Large Scale Testing Shipment 

1 New Standard 5 64 69 3 $50 $750 2 New Standard3,4 277 154 431 6 $50 $83,100 2 ULEF to 2 Standard 11 114 125 6 $50 $3,300 1 New NAF 6 65 71 1 $50 $300 2 New NAF 11 211 222 2 $50 $1,100 

11. On-site Audit Travel 288 365 653 1 $1,500 $432,000 12. Desk Audits7

Uncertified to Standard3,4 277 154 431 8 $250 $554,000 ULEF to Standard 11 114 125 8 $250 $22,000 NAF (With New Certification) 11 211 222 2 $250 $5,500 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 83 of 99 

Exhibit 6-25: Incremental First Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Activity 

T

Domestic Foreign1 Total Domestic 

13. Purchase of Small Chamber Testing Unit2 295 350 645 1 $10,000 $2,950,000 14. Quality Control Testing - - - - - - 15. Lost Product 

1 New Standard - PB/MDF 5 64 69 268 $8.96 $12,006 2 New Standard - HWPW3,4 277 154 431 536 $15.68 $2,328,041 2 ULEF to 2 Standard - PB/MDF 3 27 30 528 $8.96 $14,193 2 ULEF to 2 Standard - HWPW 8 87 95 528 $15.68 $66,232 1 ULEF to 1 NAF - PB/MDF 1 10 11 67 $8.96 $600 1 ULEF to 1 NAF – HWPW 5 55 60 67 $15.68 $5,253 2 New NAF – HWPW 11 211 222 142 $15.68 $24,492 

16. Initial Recordkeeping8 8,576 11,945 20,521 1 $1,000.00 $8,576,000 $17. Recurring Recordkeeping - - - - - - 18. Initial Labeling9

Minor Changes - Producers - - - - - - Minor Changes - Fabricators - - - - - - Major Changes – Producers3 277 108 385 1 $125.00 $34,625 Major Changes - Fabricators and Wholesalers10 16,266 6,344 22,610 1 $125.00 $2,033,250 

Total - Year 1 $21,799,672 $Notes: 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 Nvalue 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 dwood products or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is unceinto 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 that that mills will seek standard certification for uncertified and ULEF product lines. The exceptions are 1) mills that are both ULEF and NAF switch 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 therefas hardwood plywood. A similar proportion of foreign laminators exporting 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 TPC as a result of the TSCA Title VI rule. 5. Producers that are already CARB compliant and are not expected adopt a more stringent certification type (e.g., NAF certification) are not assumed to need to perform because it is assumed that their previous testing is sufficient. 6. On-site audits must be conducted at least once quarterly, unless the mill obtains NAF certification. This analysis assumes that producers with new NAF certifications wwith one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing NAF certifications under the CARB ATCM will only the first year. All producers with NAF certification will have one on-site audit annually thereafter. 7. Desk audits are assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with none are required in subsequent years. No desk audits are required for respondents with existing NAF certification. 8. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneer laminated product producers defined aproducers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 84 of 99 

Exhibit 6-25: Incremental First Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Activity 

T

Domestic Foreign1 Total Domestic 

the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule. 9. Firms that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their namproduced, 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 the 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 Californi$125.00 for purchasing 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 85 of 99 

Exhibit 6-26: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Activity 

Domestic Foreign1 Total Domestic 

1. Rule Familiarization - - - - - - 3. Certification Fee2

Uncertified to Standard3,4 277 154 431 1 $6,000 $1,662,000 ULEF to Standard 11 114 125 1 $2,300 $25,300 NAF (With New Certification) 11 211 222 1 $3,700 $40,700 

4. Initial On-site Audit 

With Existing Certifications - - - - - - Without Existing Certifications3,4 - - - - - - 

5. Develop Quality Control Manual - - - - - - 6. Qualifying Test5

1 Product - - - - - - 2 Products3,4 - - - - - - 

7. Qualifying Test Shipping5

1 Product - - - - - - 2 Products3,4 - - - - - - 

8. Correlation Test5 - - - - - - 9. Quarterly On-site Audit6

Uncertified to Standard3,4 277 154 431 4 $450 $498,600 ULEF to Standard 11 114 125 3 $450 $14,850 NAF (With New Certification) 11 211 222 1 $450 $4,950 

10. Large Scale Testing Fee 

1 New Standard 5 64 69 4 $480 $9,600 2 New Standard3,4 277 154 431 8 $480 $1,063,680 2 ULEF to 2 Standard 11 114 125 6 $480 $31,680 1 New NAF 6 65 71 1 $480 $2,880 2 New NAF 11 211 222 2 $480 $10,560 

11. Large Scale Testing Shipment 

1 New Standard 5 64 69 4 $50 $1,000 2 New Standard3,4 277 154 431 8 $50 $110,800 2 ULEF to 2 Standard 11 114 125 6 $50 $3,300 1 New NAF 6 65 71 1 $50 $300 2 New NAF 11 211 222 2 $50 $1,100 

12. On-site Audit Travel 288 365 653 1 $1,500 $432,000 13. Desk Audits7

Uncertified to Standard3,4 277 154 431 8 $250 $554,000 ULEF to Standard 11 114 125 8 $250 $22,000 NAF (With New Certification) - - - - - - 

14. Purchase of Small Chamber Testing Unit - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 86 of 99 

Exhibit 6-26: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Activity 

Domestic Foreign1 Total Domestic 

15. Quality Control Testing - - - - - - 16. Lost Product 

1 New Standard - PB/MDF 5 64 69 264 $8.96 $11,827 2 New Standard - HWPW3,4 277 154 431 528 $15.68 $2,293,294 2 ULEF to 2 Standard - PB/MDF 3 27 30 520 $8.96 $13,978 2 ULEF to 2 Standard - HWPW 8 87 95 520 $15.68 $65,229 1 ULEF to 1 NAF - PB/MDF 1 10 11 -3 $8.96 -$27 1 ULEF to 1 NAF – HWPW 5 55 60 -3 $15.68 -$235 2 New NAF – HWPW 11 211 222 2 $15.68 $345 

17. Initial Recordkeeping8 - - - - - - 18. Recurring Recordkeeping - - - - - - 19. Initial Labeling9

Minor Changes - Producers - - - - - - Minor Changes - Fabricators - - - - - - Major Changes – Producers3 - - - - - - Major Changes - Fabricators and Wholesalers10 - - - - - - 

Total - Years 2 and 3 $6,873,711 Notes: 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 Nvalue 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 dwood products or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is unceinto 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 that that mills will seek standard certification for uncertified and ULEF product lines. The exceptions are 1) mills that are both ULEF and NAF switch 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 therefas hardwood plywood. A similar proportion of foreign laminators exporting 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 TPC as a result of the TSCA Title VI rule. 5. Producers that are already CARB compliant and are not expected adopt a more stringent certification type (e.g., NAF certification) are not assumed to need to perform because it is assumed that their previous testing is sufficient. 6. On-site audits must be conducted at least once quarterly, unless the mill obtains NAF certification. This analysis assumes that producers with new NAF certifications wwith one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing NAF certifications under the CARB ATCM will only the first year. All producers with NAF certification will have one on-site audit annually thereafter. 7. Desk audits are assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with none are required in subsequent years. No desk audits are required for respondents with existing NAF certification. 8. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneer laminated product producers defined aproducers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule. 9. Firms that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their nam
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 87 of 99 

Exhibit 6-26: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Activity 

Domestic Foreign1 Total Domestic 

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 the 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 Californi$125.00 for purchasing 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 88 of 99 

Exhibit 6-27: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of Activities 

Per 

Respondent 

Cost Per 

Activity 

Domestic Foreign1 Total Domestic 

1. Rule Familiarization - - - - - - 2. Certification Fee2

Uncertified to Standard3,4 277 154 431 1.0000 $6,000.00 $1,662,000 ULEF to Standard 11 114 125 1.0000 $2,300.00 $25,300 NAF (With New Certification) 11 211 222 1.0000 $4,466.67 $49,133 

3. Initial On-site Audit 

With Existing Certifications 82 764 846 - $450.00 - Without Existing Certifications3,4 288 365 653 0.3333 $450.00 $43,196 

4. Develop Quality Control Manual - - - - - - 5. Qualifying Test5

1 Product 11 129 140 1.6667 $480.00 $8,800 2 Products3,4 288 365 653 3.3333 $480.00 $460,795 

6. Qualifying Test Shipping5

1 Product 11 129 140 0.3333 $200.00 $733 2 Products3,4 288 365 653 0.6667 $200.00 $38,402 

7. Correlation Test - - - - - - 8. Quarterly On-site Audit5

Uncertified to Standard3,4 277 154 431 3.6667 $450.00 $457,054 ULEF to Standard 11 114 125 3.0000 $450.00 $14,850 NAF (With New Certification) 11 211 222 1.0000 $450.00 $4,950 

9. Large Scale Testing Fee 

1 New Standard 5 64 69 3.6667 $480.00 $8,800 2 New Standard3,4 277 154 431 7.3333 $480.00 $975,036 2 ULEF to 2 Standard 11 114 125 6.0000 $480.00 $31,680 1 New NAF 6 65 71 1.0000 $480.00 $2,880 2 New NAF 11 211 222 2.0000 $480.00 $10,560 

10. Large Scale Testing Shipment 

1 New Standard 5 64 69 3.6667 $50.00 $917 2 New Standard3,4 277 154 431 7.3333 $50.00 $101,566 2 ULEF to 2 Standard 11 114 125 6.0000 $50.00 $3,300 1 New NAF 6 65 71 1.0000 $50.00 $300 2 New NAF 11 211 222 2.0000 $50.00 $1,100 

11. On-site Audit Travel 288 365 653 1.0000 $1,500.00 $432,000 12. Desk Audits7

Uncertified to Standard3,4 277 154 431 8.0000 $250.00 $554,000 ULEF to Standard 11 114 125 8.0000 $250.00 $22,000 NAF (With New Certification) 11 211 222 0.6667 $250.00 $1,833 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 89 of 99 

Exhibit 6-27: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of Activities 

Per 

Respondent 

Cost Per 

Activity 

Domestic Foreign1 Total Domestic 

13. Purchase of Small Chamber Testing Unit 295 350 645 0.3333 $10,000.00 $983,235 14. Quality Control Testing - - - - - - 15. Lost Product 

1 New Standard - PB/MDF 5 64 69 265.3333 $8.96 $11,887 2 New Standard - HWPW3,4 277 154 431 530.6667 $15.68 $2,304,877 2 ULEF to 2 Standard - PB/MDF 3 27 30 522.6667 $8.96 $14,049 2 ULEF to 2 Standard - HWPW 8 87 95 522.6667 $15.68 $65,563 1 ULEF to 1 NAF - PB/MDF 1 10 11 20.3333 $8.96 $182 1 ULEF to 1 NAF - HWPW 5 55 60 20.3333 $15.68 $1,594 2 New NAF - HWPW 11 211 222 48.6667 $15.68 $8,394 

16. Initial Recordkeeping8 8,576 11,945 20,521 0.3333 $1,000.00 $2,858,381 17. Recurring Recordkeeping - - - - - - 18. Initial Labeling9

Minor Changes - Producers - - - - - - Minor Changes - Fabricators - - - - - - Major Changes – Producers3 277 108 385 0.3333 $125.00 $11,541 Major Changes - Fabricators and Wholesalers10 16,266 6,344 22,610 0.3333 $125.00 $677,682 

Three-Year Average Cost $11,848,570 Notes: 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 Nvalue 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 dwood products or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, which assumes that there is unceinto 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 that that mills will seek standard certification for uncertified and ULEF product lines. The exceptions are 1) mills that are both ULEF and NAF switch 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 therefas hardwood plywood. A similar proportion of foreign laminators exporting 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 TPC as a result of the TSCA Title VI rule. 5. Producers that are already CARB compliant and are not expected adopt a more stringent certification type (e.g., NAF certification) are not assumed to need to perform because it is assumed that their previous testing is sufficient. 6. On-site audits must be conducted at least once quarterly, unless the mill obtains NAF certification. This analysis assumes that producers with new NAF certifications wwith one on-site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing NAF certifications under the CARB ATCM will only the first year. All producers with NAF certification will have one on-site audit annually thereafter. 7. Desk audits are assumed to occur monthly, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with none are required in subsequent years. No desk audits are required for respondents with existing NAF certification. 8. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneer laminated product producers defined aproducers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 90 of 99 

Exhibit 6-27: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of Activities 

Per 

Respondent 

Cost Per 

Activity 

Domestic Foreign1 Total Domestic 

the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule. 9. Firms that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their namproduced, 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 the 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 Californi$125.00 for purchasing 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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1342 (iii) Total Burden and Costs 

1343 

1344 Exhibit 6-28 presents a summary of the total non-incremental burden and costs for this 

1345 information collection request over the first three years of the rule, by geographic location. 

1346 Exhibit 6-29 presents a summary of the total incremental burden and costs for this information 

1347 collection request over the first three years of the rule, by geographic location. As indicated, the 

1348 total average domestic incremental cost over the first three years of the rule is approximately 

1349 86.2 percent of the total domestic cost of the rule. Note that the incremental costs for domestic 

1350 respondents presented in Exhibit 6-29 differ from the values in the Economic Analysis. This is 

1351 due to two factors: 1) the Economic Analysis includes the costs of changes to raw materials for 

1352 composite panel producers, while the ICR does not (because it is not a reporting or 

1353 recordkeeping cost); and 2) the burden in the ICR is calculated at the activity level and rounded 

1354 to nearest tenth of a percentage, while the costs in the Economic Analysis are calculated at the 

1355 establishment level. 

1356 

Exhibit 6-28: 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 $449,847,909 $22,991,311 $472,839,220 

Foreign Respondents 4,137,039 $157,096,495 $37,563,583 $194,660,078 

Total Respondents 13,185,140 $606,944,290 $60,554,894 $667,499,184 

Years 2 and 3 

Domestic Respondents 2,973,560 $83,966,474 $7,799,524 $91,765,998 

Foreign Respondents 2,379,880 $80,867,858 $17,801,356 $98,669,214 

Total Respondents 5,353,441 $164,834,359 $25,600,880 $190,435,239 

Three Year Average 

Domestic Respondents 4,998,206 $205,914,848 $12,862,997 $218,777,845 

Foreign Respondents 2,965,542 $106,274,877 $24,388,221 $130,663,098 

Total Respondents 7,963,747 $312,189,663 $37,251,216 $349,440,879 

Notes: Values may not sum to totals due to rounding 

1357 

Exhibit 6-29: Total Incremental Burden and Costs, by Geographic Location ($2010) 

Geographic Location of 

Respondents 

Labor Non-Labor 

Cost 

Total Incremental 

Hours Cost Cost 

Year 1 

Domestic Respondents 7,935,088 $420,694,153 $21,799,672 $442,493,825 

Foreign Respondents 3,153,692 $121,134,327 $26,788,780 $147,923,107 

Total Respondents 11,088,777 $541,828,310 $48,588,453 $590,416,763 

Years 2 and 3 

Domestic Respondents 1,860,216 $54,789,167 $6,873,711 $61,662,878 

Foreign Respondents 1,393,518 $44,690,540 $7,251,002 $51,941,542 

Total Respondents 3,253,732 $99,479,608 $14,124,713 $113,604,321 

Three Year Average 

Domestic Respondents 3,884,972 $176,745,392 $11,848,570 $188,593,962 

Foreign Respondents 1,980,186 $70,169,347 $13,763,049 $83,932,396 

Total Respondents 5,865,153 $246,914,480 $25,611,620 $272,526,100 

Notes: Values may not sum to totals due to rounding 

1358 

1359 
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1360 

1361 6(c) Estimating Agency Burden and Cost 

1362 

1363 EPA resources would be devoted to reviewing and analyzing data submissions, compiling 

1364 and recording data, maintaining hard-copy files of submitted data, auditing and inspecting 

1365 facilities, producing audit and inspection reports, responding to public inquiries, and providing 

1366 regulatory interpretations. EPA anticipates that these activities will require the equivalent of one 

1367 full-time employee (FTE) at Headquarters. Using the 2010 Washington/Baltimore area annual 

1368 salary rate for a GS-13, Step 5 employee ($100,904), and multiplying by a loading factor of 1.6 

1369 to reflect overhead and fringe benefits results in an estimated EPA cost of $161,446 per year. 

1370 

1371 6(d) Bottom Line Burden Hours and Costs/Master Table 

1372 

1373 Exhibit 6-30 presents the frequency for each of the respondent activities assumed in the 

1374 bottom line burden hour and cost tables. Exhibit 6-31 and Exhibit 6-32 present the respective 

1375 total and incremental bottom line burden and costs, by activity frequency and respondent type. 

1376 In Exhibit 6-31, all activities of a given frequency that a single respondent performs are 

1377 accounted for as a single response for that time period. For example, if a respondent performs 

1378 two different quarterly activities per quarter this is accounted for as a single response per quarter 

1379 or four responses per year (e.g., paying the large scale testing fee and paying shipment costs for 

1380 large scale testing is counted as a single response not two separate responses). 

1381 
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Page 93 of 99 

1382 

Exhibit 6-30: 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 Control 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 Certification Annual 

2 Product with NAF Certification 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 Certification Annual 

2 Product with 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 

1 Product with NAF Certification (HWPW - New) Annual 

1 Product with NAF Certification (HWPW - Existing) Annual 

2 Products with NAF Certification (HWPW - New) Annual 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review*** 

Page 94 of 99 

Exhibit 6-30: Frequency of Activities 

Activity Assumed Activity Frequency 1

2 Products with NAF Certification (HWPW - Existing) Annual 

1 Product with Standard 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 Certification (PB/MDF - New) Annual 

1 Product with NAF Certification (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 the purpose of the calculations in Exhibit 6-33 (which 

classifies activities as one-time, annual, quarterly, or daily), 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. 

1383 

1384 
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Page 95 of 99 

1385 

Exhibit 6-31: Summary of Three Year Average Total (including baseline) Burden and Costs, by 

Geographic Location ($2010) 

Response and 

Respondent Type 

Number of 

Respondents 

Average Responses 

per Respondent 

Average Burden per 

Response (hours) Total Burden Total Cost 

Domestic 

Producers 

 One-Time 370 0.3333 140.8681 17,372 $2,361,644

 Annual 370 1.0000 59.6811 22,082 $5,026,015

 Quarterly 370 4.0000 3.7797 5,594 $2,085,323

 Daily 370 260.0000 1.8324 176,280 $15,210,894

Fabricators 

 One-Time 79,701 0.3333 25.7560 684,190 $34,047,670

 Daily 79,701 1.0000 24.1482 1,924,638 $47,808,008

Wholesalers 

 One-Time 85,560 0.3333 10.9281 311,639 $19,115,185

 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

Annual 1 759,048 1.0000 - - - 

Total 924,679 4,998,206 $218,777,845

Foreign 

Producers 

 One-Time 1,129 0.3333 76.8279 28,910 $3,888,772

 Annual 1,129 1.0000 58.6873 66,258 $14,680,318

 Quarterly 1,129 4.0000 2.6050 11,764 $4,693,501

 Daily 1,129 260.0000 1.2631 370,760 $30,709,062

Fabricators 

 One-Time 31,083 0.3333 25.7470 266,738 $13,274,319

 Daily 31,083 1.0000 24.2524 753,838 $18,725,336

Wholesalers 

 One-Time 33,368 0.3333 26.1753 291,110 $14,652,563

 Annual 33,368 1.0000 35.2483 1,176,164 $30,039,228

Retailers 

 One-Time - 0.3333 - - -

Total 65,580 2,965,542 $130,663,099

Total 

Producers 

 One-Time 1,499 0.3333 92.6350 46,282 $6,250,415

 Annual 1,499 1.0000 58.9326 88,340 $19,706,338

 Quarterly 1,499 4.0000 2.8949 17,358 $6,778,822

 Daily 1,499 260.0000 1.4036 547,040 $45,919,953

Fabricators 

 One-Time 110,784 0.3333 25.7534 950,926 $47,321,899

 Daily 110,784 1.0000 24.1775 2,678,476 $66,533,344

Wholesalers 

 One-Time 118,928 0.3333 15.2061 602,749 $33,767,748

 Annual 99,908118,928 1.0000 20.224716.9902 2,020,613 $51,606,456

Retailers 

 One-Time 759,048 0.3333 4.0000 1,011,963 $71,555,904

Annual1 759,048 1.0000 - - - 

Total 990,259 7,963,747 $349,440,879

1. Retailers are assumed not to import products directly, in which case they are only required to keep invoices and bills of lading. 

These records are typically kept as a customary business practice, so no annual burden is attributed to retailers. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review*** 

Page 96 of 99 

Exhibit 6-32: 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 17,372 $2,349,345 

 Annual 370 1.0000 58.3811 21,601 $4,317,674 

 Quarterly 370 4.0000 3.1892 4,720 $1,930,023 

 Daily 370 260.0000 1.5568 149,760 $13,083,250 

Fabricators 

 One-Time 79,701 0.3333 25.7560 684,190 $34,047,670 

 Annual 47,540 1.0000 24.2646 1,153,539 $28,653,909 

Wholesalers 

 One-Time 85,560 0.3333 10.9281 311,639 $19,115,185 

 Annual 

23,10253,731 1.0000 

 

22.94999.8675 

 

530,188 $13,541,002 

Retailers 

 One-Time 759,048 0.3333 4.0000 1,011,963 $71,555,904 

 Annual1 

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

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 39.506916.9869 

1,268,685 $32,402,215 

Retailers 

 One-Time 759,048 0.3333 4.0000 1,011,963 $71,555,904 

 Annual1 658,150 1.0000 - - - 

Total 990,259 5,865,153 272,526,100 

1. Retailers are assumed not to import products directly, in which case they are only required to keep invoices and bills of lading. 

These records are typically kept as a customary business practice, so no annual burden is attributed to retailers. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review*** 

Page 97 of 99 

1386 

1387 6(e) Reasons for Changes in Burden

1388 

1389 Not applicable. These are new requirements so there was no previous ICR. 

1390 

1391 6(f) Burden Statement

1392 

1393 The annual public burden for this collection of information, which is approved under 

1394 OMB Control No. xxxx-xxxx, is estimated to be 4.64 hours per response (i.e., 7,963,747 burden 

hours for an estimated 1,716,048 responses).28 1395 According to the Paperwork Reduction Act, 

1396 “burden” means the total time, effort, or financial resources expended by persons to generate, 

1397 maintain, retain, or disclose or provide information to or for a Federal agency. For this 

1398 collection it includes such activities as annual familiarization with requirements, recordkeeping, 

1399 notification, and reporting requirements. An agency may not conduct or sponsor, and a person is 

1400 not required to respond to, a collection of information unless it displays a currently valid OMB 

1401 control number. The OMB control numbers for EPA’s regulations in title 40 of the CFR, after 

1402 appearing in the Federal Register, are listed in 40 CFR part 9 and included on the related 

1403 collection instrument or form, if applicable. 

1404 

1405 To comment on the Agency’s need for this information, the accuracy of the provided 

1406 burden estimates, and any suggested methods for minimizing respondent burden, including the 

1407 use of automated collection techniques, EPA has established a public docket for this ICR under 

1408 Docket ID No. EPA-HQ-OPPT-XXXX-XXXX. The docket is available for public viewing at 

1409 the Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). The EPA/DC 

1410 Public Reading Room is located in the EPA West Building, Room 3334, 1301 Constitution Ave., 

1411 NW., Washington, DC. The EPA/DC Public Reading Room is open from 8:30 a.m. to 4:30 p.m., 

1412 Monday through Friday, excluding legal holidays. The telephone number for the EPA/DC 

1413 Public Reading Room is (202) 566-1744, and the telephone number for the Pollution Prevention 

1414 and Toxics Docket is (202) 566-0280. An electronic version of the public docket is available 

1415 through the Federal Docket Management System (FDMS) at www.regulations.gov. Use FDMS 

1416 to submit or view public comments, access the index listing of the contents of the public docket, 

1417 and to access those documents in the public docket that are available electronically. Once in the 

1418 system, select “search,” then key in the docket ID number identified above. Also, you can send 

1419 comments to the Office of Information and Regulatory Affairs, Office of Management and 

1420 Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please 

1421 include the EPA Docket ID No. EPA-HQ-OPPT-XXXX-XXXX and OMB control number 

1422 xxxx-xxxx in any correspondence. 

1423 

1424 

1425 

 

28 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 6-31. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review*** 

Page 98 of 99 

1426 References 

1427 

1428 California Air Resources Board. 2011. CARB List of Certified Mills. 

1429 Composite Panel Association. 2011. 2011 Surface & Panel Buyers Guide. 

1430 Personal Communication with AHFA. 2010. Conversation between Bill Perdue (American Home 

1431 Furnishings Alliance) and Abt Associates Inc. November 3, 2010. 

1432 Personal Communication with BIFMA. 2010. Brad Miller's (BIFMA) Written Responses to Questions 

1433 about FSCWPA Impacts on Members. November 23, 2011. 

1434 Personal Communication with CRA. 2011. Conversation between Pamela Williams (California Retailers 

1435 Association) and Abt Associates Inc. January 20, 2011. 

1436 Personal Communication with HPVA. 2011. Conversation between Kip Howlett (HPVA) and Abt 

1437 Associates Inc. January 4, 2011. 

1438 U.S. Bureau of Labor Statistics (BLS). 2009. Occupational Employment Statistics 2009 Mean Hourly 

1439 Wages. 

1440 U.S. Bureau of Labor Statistics (BLS). 2011. BLS Employer Cost for Employee Compensation (ECEC) 

1441 Data for all private industry for 2009-2010. 

1442 U.S. Census Bureau. 1997. 1992 Enterprise Statistics: Company Summary. 

1443 U.S. Census Bureau. 2009. Sector 42: EC0742I1: Wholesale Trade: Industry Series: Preliminary Summary 

1444 Statistics for the United States: 2007. 

1445 U.S. Census Bureau. 2010a. Sector 44: EC0744SLLS1: Retail Trade: Subject Series - Product Lines: 

1446 Product Lines Statistics by Kind of Business for the United States and States: 2007. 

1447 U.S. Census Bureau. 2010b. Sector 31: EC0731SG3: Manufacturing: Summary Series: General Summary: 

1448 Industry Statistics for Subsectors and Industries by Employment Size: 2007. 

1449 U.S. Census Bureau. 2010c. Sector 44: EC0744SSSZ3: Retail Trade: Subject Series - Estab & Firm Size: 

1450 Summary Statistics for Single Unit and Multiunit Firms for the United States: 2007. 

1451 U.S. Census Bureau. 2010d. Sector 42: EC0742A1: Wholesale Trade: Geographic Area Series: Summary 

1452 Statistics for the United States. 

1453 U.S. Census Bureau. 2010e. Sector 31: EC0731A1: Manufacturing: Geographic Area Series: Industry 

1454 Statistics for the States. 

1455 U.S. Census Bureau. 2010f. Sector 42: EC0742SSSZ5: Wholesale Trade: Subject Series - Estab & Firm 

1456 Size: Summary Statistics by Employment Size of Firms for the United States: 2007. 

1457 U.S. Census Bureau. 2010g. Sector 44: EC0744SSSZ4: Retail Trade: Subject Series - Estab & Firm Size: 

1458 Summary Statistics by Sales Size of Firms for the United States: 2007. 

1459 U.S. Census Bureau. 2010h. Sector 00: NS0800A1: 2008 Nonemployer Statistics: Geographic Area Series: 

1460 Nonemployer Statistics by Legal Form of Organization: 2008 

1461 U.S. Census Bureau. 2010i. Data Item: Wholesale type of operation.” American FactFinder Help. Census 

1462 Data Information. 

1463 U.S. Census Bureau. 2010j. Sector 42: EC0742SSSZ3: Wholesale Trade: Subject Series - Estab & Firm 

1464 Size: Summary Statistics for Single Units and Multiunit Firms for the United States: 2007. 

1465 U.S. Census Bureau. 2010k. Statistics for U.S. Businesses (SUSB). Number of Firms, Number of 

1466 Establishments, Employment, Annual Payroll, and Estimated Receipts by Enterprise Receipt Size for the 

1467 United States, All Industries: 2007. December 15, 2010. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review*** 

Page 99 of 99 

1468 U.S. Census Bureau. 2010l. Sector 44: EC0744A1: Retail Trade: Geographic Area Series: Summary 

1469 Statistics for the United States, States, Metro Areas, Counties, and Places: 2007. 

1470 U.S. Census Bureau. 2011. Sector 42: EC0742SLLS1: Wholesale Trade: Subject Series - Product Lines: 

1471 Product Lines Statistics by Kind of Business for the United States and States: 2007. 

1472 U.S. Internal Revenue Service. 2007. Starting a Business and Keeping Records. Publication 583. Revised 

1473 January 2007. 

1474 U.S. International Trade Commission. 2011. U.S. Interactive Tariff and Trade Dataweb. 

1475 

1476