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1 EO12866_RIN2070-AJ92_Formaldehyde-Imp_NPRM_ICR_2013-04-11_MARKUP.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 and 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 53 years is especially critical because these regulated products 

175 (composite wood panels, component parts, and finished goods) may be in commerce for 53 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 ultra-low formaldehyde or no-added formaldehyde 

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

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

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

303 

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

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

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

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

308 was made in compliance with TSCA Title VI. 

309 

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

311 

312  Panel producers must maintain the following records for at least fivethree years and make 

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

314 composite wood products: 

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

316 that identify the TPC conducting or overseeing the testing and the laboratory or 

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

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

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

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

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

322 each product to be traced to a specific lot number or batch produced. 
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323 o Records of changes in production, including changes of more than 10% in the 

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

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

326 changes in press time by more than 20 percent. 

327 o Records demonstrating initial and continued eligibility for the reduced testing 

328 provisions in 40 CFR § 770.17, if applicable. 

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

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

331 purchase order or invoice number, and amount purchased. 

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

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

334 available, and shipping invoice number. 

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

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

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

338 o Copies of labels used. 

339 

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

341 premises. 

342 

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

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

345 capacity. 

346 

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

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

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

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

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

352 

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

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

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

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

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

358 composite wood products are compliant. 

359 

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

361 copies of labels used. 

362 

363 (ii) Respondent Activities

364 

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

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

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

368 accuracy and appropriateness; and record, disclose, and/or report the required information. 
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369 5. THE INFORMATION COLLECTION — AGENCY ACTIVITIES, COLLECTION 

370 METHODOLOGY, AND INFORMATION MANAGEMENT

371 

372 5(a) Agency Activities

373 

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

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

376 inquiries, providing regulatory interpretations and developing rulemakings. 

377 

378 5(b) Collection Methodology and Management

379 

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

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

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

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

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

385 communications.

386 

387 5(c) Small Entity Flexibility

388 

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

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

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

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

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

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

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

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

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

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

399 fewer tests. 

400 

401 5(d) Collection Schedule

402 

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

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

405 basis rather than by specific dates. 

406 

407 6. ESTIMATING BURDEN AND COST OF THE COLLECTION

408 

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

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

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

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

413 dollars. 

414 
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415 This ICR presents the burden and associated costs for the activity types listed below. 

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

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

418 labeling systems may already be sufficient. 

419 

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

421 the requirements; 

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

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

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

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

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

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

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

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

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

431 from some of the on-going testing requirements; 

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

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

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

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

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

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

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

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

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

441 produced, and a statement of compliance. 

442 

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

444 result of the proposed rule: 

445 

446 
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Exhibit 6-1: Summary of Recordkeeping and Reporting Activities, by Sector and Activity

Activity 

Composite Panel Producer 1

Fabricator 

Wholesaler

Retailer Standard ULEF NAF Imports No 

Imports 

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

2. Certification Fee Annual - - - -

3. Initial On-site Audit 1-time - - - -

4. Develop Quality Control 

Manual 1-time - - - -

5. Qualifying Test 1-time - - - -

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

7. Correlation Test 1-time - - - -

8. Recurring On-site 

Audit1Audit2 Quarterly Annual - - - -

9. Large Scale Testing Fee2Fee3 Quarterly Annual - - - -

10. Large Scale Testing 

Shipment2Shipment3 Quarterly Annual - - - -

11. On-site Audit Travel3Travel4 Annual - - - -

12. Desk Audits4Audits5 8 per year - - - - - -

13. Purchase of Small Chamber 

Testing Unit5Unit6 1-time - - - - - -

14. Quality Control 

Testing6Testing7 Up to Daily - - - -

15. Lost Product7Product8 Up to Daily - - - -

16. Initial Recordkeeping - - - 1-time - -

17. Recurring Recordkeeping Annual Annual Annual - -

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

Notes: 

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

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

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

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

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

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

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

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

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

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

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

34. 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. 

45. Desk audits for standard certification are assumed to occur monthly except in months withoutwith quarterly on-site audits. The analysis 

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

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

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

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

6.

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

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

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

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

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

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

Formatted Table

Inserted Cells

Formatted Table

Inserted Cells

Inserted Cells

Formatted Table
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ULEF are exempt from routine quality control testing after the six month qualifying period, and are assumed to have large scale testing 

performed quarterly.

447 

448 

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

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

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

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

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

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

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

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

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

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

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

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

461 

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

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

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

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

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

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

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

469 requirements both with and without accounting for this baseline. 

470 

 This analysis assumes that mills making product lines that have a standard certification1 471 

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

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

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

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

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

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

 

1

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

NAF certification. 
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478 

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

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

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

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

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

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

485 TSCA rule. 

486 

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. 

487 

488 6(a) Estimating Respondent Burden

489 

490 (i) Number of Respondents 

491 

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

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

analysis estimates both domestic and foreign entities.2 494 The number of respondents is estimated 

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

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

The number of domestic entities estimated here is the same as the number in the Economic Analysis. 
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495 separately by sector (i.e., panel producers, fabricators, wholesalers, and retailers). 

496 

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

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

499 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.3 500 

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

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

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

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

505 foreign mills certified under the CARB ATCM. 

506 

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

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

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

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

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

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

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

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

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

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

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

518 described in greater detail in the Economic Analysis. 

519 

520 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.4 521 

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

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

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

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

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

composite wood products in affected industries.5 527 

528 

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

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

 3 California Air Resources Board 2011.

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

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

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

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

424930, 424940, 424950, 424990. 

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

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

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

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

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

454210, 454311, 454312, 454390. 

5

 U.S. Census Bureau 2010a, 2011.
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531 value of shipments for these NAICS and 2) applying it to the number of domestic firms in each 

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

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

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

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

536 affected industries. 

537 

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 

538 

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

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

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

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

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

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

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

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

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

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

549 analysis does not estimate that number. 
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550 

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

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

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

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

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

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

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

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

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

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

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

562 burden for fabricators is estimated separately). 

563 

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 asis 20 percent of the total 

number of certified mills. 

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

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

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

containing composite wood products into the United States. 

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

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

564 

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

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

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

568 fabricators, and composite panel producers account for approximately 12.0 percent, 11.2 percent, 
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569 and 0.2 percent of the total number of respondents, respectively. 

570 

571 (ii) Burden Per Respondent 

572 

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

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

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

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

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

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

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

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

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

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

583 exemption.

584 

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

Category Standard NAF ULEF

Certification Fee Annual

Annual (reduced fee after first 

year)

Annual (reduced fee after first 

year)

Qualifying Testing One-time One-time One-time

TPC Audit Quarterly

Twice initially and annually 

thereafter

Twice initially and annually 

thereafter

TPC Audit Travel First audit each year Annual Annual

Large Chamber TPC 

Testing Quarterly

Once initially and annually 

thereafter

Once initially and quarterly 

thereafter

QC Testing On-going

First 3 months and exempt 

thereafter

First 6 months and exempt or 

reduced thereafter

Desk Audit

Monthly (excludes 

audit months)

First 2 months and exempt 

thereafter

First 4 months and exempt 

thereafter

585 

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

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

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

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

590 from subsequentreceive two audits after three months of routine small scale testingin the first 

year and one quarterly test.then are audited annually thereafter.6 591 As a result, even though these 

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

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

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

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

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

 

6

 This is an example where the TPC requirements are more stringent than the regulatory requirements. 
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597 

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

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

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

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

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

603 affected sectors. For example, this analysis assumes that 17 of the 3041 domestic 

604 particleboardhardwood plywood respondents (or 3.317.1 percent) and 2 of the 22 domestic MDF 

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

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

607 VI rule. As a result, it is assumed that 6 certified76 foreign particleboardhardwood plywood

608 respondents (3.317.1 percent of 173) and 26the 448 foreign hardwood plywood mills with 

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

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

611 certification as a result ofunder the TSCA Title VI rule. 

612 

613 (A). All Respondents

614 

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

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

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

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

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

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

621 

622 Rule Familiarization (Activity #1) 

623 

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

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

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

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

628 

629 (B). Composite Panel Producers

630 

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

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

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

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

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

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

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

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

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

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

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

642 ATCM). This is different from the methodology in the Economic Analysis for the proposed rule, 
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643 where the baseline included activities performed to comply with the CARB ATCM. As a result, 

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

645 TSCA rule. 

646 

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

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

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

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

651 

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

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

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

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

656 certification. Once a TPC certifies a panel producer, that producer is required to conduct on657 going small scale quality control testing, submit monthly reports to the TPC, and receive 

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

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

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

661 

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

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

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

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

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

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

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

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

670 assumes that ULEF product lines will receive quarterly TPC testing, and that ULEF and NAF671 certified mills will undertake a TPC audit annually. Where the frequency of testing is different 

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

673 groups are presented separately. 

674 

675 Initial On-site Audit (Activity #3) 

676 

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

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

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

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

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

duration of the visit may be longer.7 682 This analysis assumes that a managerial-level employee 

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

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

685 

686 Quality Control Systems Development (Activity #4) 

687 

 7 Personal Communication with HPVA 2011.
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688 Mills are required to implement quality control procedures to ensure that all certified 

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

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

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

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

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

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

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

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

697 

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

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

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

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

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

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

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

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

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

707 spend time on these activities. 

708 

709 Qualifying Test (Activities #5 and #6) 

710 

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

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

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

714 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.8 715 Results from the five large chamber 

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

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

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

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

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

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

722 will not incur this burden. 

723 

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

725 

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

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

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

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

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

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

732 and one hour for each desk audit. 

733 

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

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

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

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

738 thereafter. 

739 

740 Quality Control Testing (Activity #14) 

741 

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

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

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

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

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

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

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

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

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

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

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

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

754 chamber tests. 

755 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

776 may overstate the costs of this requirement if some mills find it more cost effective to hold 
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777 products in inventory until test results have been determined by an outside lab.) Producers that 

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

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

780 

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

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

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

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

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

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

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

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

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

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

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

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

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

794 hours each day performing routine quality control testing. 

795 

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

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

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

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

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

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

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

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

804 

805 Recurring Recordkeeping (Activity #17) 

806 

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

808 labor per week (equivalent to $3,710.72 per year) to maintain the following records for 53 years: 

809 

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

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

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

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

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

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

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

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

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

819 number or batch produced; 

820  Records demonstrating initial and continued eligibility for the reduced testing 

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

822 formaldehyde-based resins, if applicable; 
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823  Records of changes in production, including changes in resin use, resin 

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

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

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

827 purchase order or invoice number, and amount purchased; 

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

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

830 available, and shipping invoice number; 

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

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

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

834  Copies of labels used; 

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

836 their premises; and 

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

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

839 quality control capacity. 

840 

841 Initial Labeling (Activity #18) 

842 

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

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

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

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

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

848 

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

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

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

852 hours of technical labor) (see below). 

853 

854 (C) Fabricators

855 

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

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

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

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

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

861 requirements without any significant modifications. 

862 

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

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

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

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

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

868 product meets emissions standards. These records must be kept for fivethree years. 
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869 

870 Baseline Compliance for Fabricators 

871 

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

conversations with industry associations.9 873 However, baseline compliance for some industries 

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

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

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

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

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

879 are provided in the Economic Analysis for the rulemaking. 

880 

Exhibit 6-6: 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 

881 

882 Fabricators incurring Recordkeeping and Labeling Costs 

883 

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

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

886 composite wood products destined for California markets have experience implementing 

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

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

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

 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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to fewer than ten respondents per questionnaire.10 890 These questionnaires asked respondents for 

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

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

893 

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

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

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

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

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

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

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

901 additional recurring recordkeeping costs. 

902 

903 The fabricator questionnaire respondent that reported incurring recurring recordkeeping 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

918 

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

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

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

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

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

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

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

926 approximately 7.21 labor hours per year. 

927 

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

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

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

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

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

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

934 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.11 935 Two 

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

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

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

reported by these two firms (100 hours).12 939 It is assumed that fabricators will use technical labor 

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

941 for labeling, no recurring labeling costs are estimated. 

942 

943 (D). Wholesalers

944 

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

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

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

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

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

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

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

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

953 standards. These records must be kept for fivethree years. 

954 

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

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

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

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

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

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

practices.13 961 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.14 962 

963 

964 Baseline Compliance for Wholesalers 

965 

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

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

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

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

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

 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 6-9 through Exhibit 6-14.
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Economic Census data to identify the number of affected wholesale firms15 971 (2) estimate the 

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

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

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

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

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

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

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

custody requirements in the baseline.16 979 Exhibit 6-7 presents a summary of the baseline 

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

981 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 6-7: 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 6-7: 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 

982 

983 Wholesalers incurring Recordkeeping and Labeling Costs 

984 

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

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

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

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

989 below. 

990 

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

992 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.17 993 As indicated 

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

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

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

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

998 100 hours). However, the recurring recordkeeping burden reported by the wholesaler 

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

1000 the wholesaler firms that incur this type of burden. This wholesaler questionnaire respondent 

1001 was a firm with employees, but smaller firms, such as nonemployer firms, are likely to need 

1002 much less time than 3.75 hours per week (nearly 10% of a 40 hour work week) to perform the 

1003 necessary recordkeeping activities. Since the recordkeeping requirements entail keeping track of 

1004 composite wood materials purchased and shipments that contain composite wood products, it is 

1005 expected that the burden associated with keeping records will typically increase with the volume 

1006 of a wholesaler’s sales. Thus, to estimate the recurring recordkeeping burden for nonemployer 

1007 wholesalers, the analysis assumes that there is a fixed-cost component of the recurring 

1008 recordkeeping costs associated with two hours of labor and a variable cost component that is 

1009 proportional to a firm’s revenue. It is assumed that wholesalers will use clerical labor for 

1010 recordkeeping activities and technical labor for labeling. 

1011 

1012 For employer firms that import composite wood products, the recurring recordkeeping 

1013 cost is estimated as 195 hours per year (based on 2 hours of fixed cost labor, with the remaining 

1014 hours of variable cost labor). For nonemployer firms that import composite wood products, the 

1015 variable cost component is calculated by subtracting two hours of fixed labor cost (at a cost of 

1016 $51.08) from the total reported annual cost ($4,980) and then dividing by the estimated average 

1017 revenue for affected employer wholesalers ($8,308,417). The resulting variable cost component 

1018 (0.05933 percent of revenue) is multiplied by average nonemployer revenues ($82,542) and 

1019 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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1020 

1021 It is assumed that one percent of wholesalers incur labeling burden, either because they 

1022 are repackaging goods that were originally labeled on the packaging instead of on the individual 

1023 items, or because they are replacing an original label applied by the panel producer or fabricator 

1024 with a label listing a different company name. It is also assumed that these wholesalers incur the 

1025 same burden as the fabricators who are assumed to incur more substantial initial labeling burden 

1026 (an average of 100 hours). 

1027 

1028 (E). Retailers

1029 

1030 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 for importers.

18 1031 

1032 Retailers that do not import composite wood products must keep invoices and bills of lading. 

1033 Retailer’s customary business practices are assumed to be generally sufficient to meet the 

proposed rule’s recordkeeping requirements.19 1034 Therefore the recordkeeping requirements are not 

assumed to impose any additional burden on retailers.20 1035 In addition, assuming they do not 

1036 modify the packaging of the composite wood products they purchase, retailers are not required to 

1037 modify their labeling system to comply with the proposed rule. 

1038 

1039 Baseline Compliance for Retailers 

1040 

1041 Exhibit 6-8 presents a summary of the baseline compliance estimates for retail industries. 

1042 Baseline CARB compliance was calculated in the same manner as described the wholesale 

1043 section (i.e., by determining the number of firms with at least one establishment in California). 

1044 Additional detail is provided in the Economic Analysis for the rulemaking. 

1045 

 18 Because all foreign products are assumed to be imported by wholesalers, the burden of the rule’s chain of custody 

requirements for any retailers that do import products directly is accounted for under the wholesaler category. 19 Personal Communication with California Retailers Association 2011. 20 While retailers are assumed to meet the proposed rule’s recordkeeping requirements with documents kept as part of their 

customary business practices, these firms do count toward the respondent and response totals in Exhibit 6-9 through Exhibit 6-

14.
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Exhibit 6-8: Baseline CARB Compliance of Retail Industries

NAICS NAICS Description Baseline CARB 

Compliance 

441110 New car dealers 11.5% 

441210 Recreational vehicle dealers 11.6% 

441221 Motorcycle, ATV, and personal watercraft dealers 10.7% 

441229 All other motor vehicle dealers 10.6% 

441320 Tire dealers 14.7% 

442110 Furniture stores 15.2% 

442210 Floor covering stores 11.2% 

442291 Window treatment stores 15.0% 

442299 All other home furnishings stores 15.4% 

443111 Household appliance stores 10.5% 

443112 Radio, television, and other electronics stores 16.8% 

443120 Computer and software stores 15.1% 

443130 Camera and photographic supplies stores 17.8% 

444110 Home centers 16.2% 

444120 Paint and wallpaper stores 19.0% 

444130 Hardware stores 9.7% 

444190 Other building material dealers 12.3% 

444210 Outdoor power equipment stores 5.7% 

444220 Nursery, garden center, and farm supply stores 8.7% 

445110 Supermarkets and other grocery (except convenience) stores 15.3% 

445120 Convenience stores 11.2% 

445210 Meat markets 10.9% 

445220 Fish and seafood markets 10.3% 

445230 Fruit and vegetable markets 10.4% 

445291 Baked goods stores 12.4% 

445292 Confectionery and nut stores 13.9% 

445299 All other specialty food stores 12.2% 

445310 Beer, wine, and liquor stores 11.3% 

446110 Pharmacies and drug stores 15.5% 

446120 Cosmetics, beauty supplies, and perfume stores 12.4% 

446130 Optical goods stores 16.1% 

446191 Food (health) supplement stores 13.1% 

446199 All other health and personal care stores 13.3% 

447110 Gasoline stations with convenience stores 15.0% 

447190 Other gasoline stations 13.1% 

448110 Men's clothing stores 18.0% 

448120 Women's clothing stores 17.0% 

448130 Children's and infants' clothing stores 15.6% 

448140 Family clothing stores 19.6% 

448150 Clothing accessories stores 15.3% 

448190 Other clothing stores 15.2% 

448210 Shoe stores 19.1% 

448310 Jewelry stores 14.4% 

448320 Luggage and leather goods stores 16.1% 

451110 Sporting goods stores 13.5% 

451120 Hobby, toy, and game stores 14.2% 

451130 Sewing, needlework, and piece goods stores 13.2% 

451140 Musical instrument and supplies stores 12.2% 

451211 Book stores 15.6% 

451212 News dealers and newsstands 11.5% 

451220 Prerecorded tape, compact disc, and record stores 14.5% 

452111 Department stores (except 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% 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 32 of 118 

Exhibit 6-8: Baseline CARB Compliance of Retail Industries

NAICS NAICS Description Baseline CARB 

Compliance 

453210 Office supplies and stationery stores 17.6% 

453220 Gift, novelty, and souvenir stores 12.8% 

453910 Pet and pet supplies stores 12.9% 

453920 Art dealers 13.7% 

453930 Manufactured (mobile) home dealers 7.3% 

453991 Tobacco stores 12.7% 

453998 All other miscellaneous store retailers (except tobacco 

stores) 

11.5% 

454111 Electronic shopping 10.3% 

454113 Mail-order houses 11.3% 

454210 Vending machine operators 11.0% 

454311 Heating oil dealers 11.7% 

454312 Liquefied petroleum gas (bottled gas) dealers 20.4% 

454390 Other direct selling establishments 11.1% 

Total Retailers 13.2%

a. Baseline CARB compliance represents the percent of retailers estimated to be selling their 

products in California, and therefore not expected to incur supplier notification costs. 

Sources:U.S. Census Bureau 1997, 2010g, k, l 

1046 

1047 (F). Summary

1048 

1049 Exhibit 6-9 and Exhibit 6-10 summarize the total number of respondents, total burden 

1050 per respondent and total burden for each response activity over the first year, and second and 

1051 third years of the ICR, respectively. Exhibit 6-11 presents the average total value for those 

1052 variables over the first three years of the rule (i.e., without accounting for the baseline 

1053 compliance with the CARB ATCM). Exhibit 6-12 through Exhibit 6-14 mirror the previous 

1054 three tables, except that they account for incremental burdens (excluding baseline burden and 

1055 cost). Note that most respondents are incurring burdens for multiple activities listed in these 

1056 exhibits. As indicated, the average annual burden over the first three years of the rule is 

1057 estimated to be approximately 8.07.9 million hours, while the incremental burden over this time 

1058 period is estimated at 5.98 million hours. The domestic burden accounts for approximately 

1059 62.863.3 percent and 66.29 percent of the totals, respectively. 

1060 

1061 

1062 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 33 of 118 

Exhibit 6-9: 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) 

Total Burden (Hours) 

Domestic Foreign2 Total Domestic Foreign Total 

1. Rule Familiarization 

Producers3 M 370 1,129 1,499 1 4.00 1,480 4,516 5,996 Fabricators4 M 79,701 31,083 110,784 1 4.00 318,804 124,332 443,136 Wholesalers M 85,560 33,368 118,928 1 4.00 342,240 133,472 475,712 Retailers M 759,048 - 759,048 1 4.00 3,036,192 - 3,036,192 

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

With Existing Certifications M 82 764 846 1 4.00 328 3,056 3,384Without Existing Certifications3,5 M 288 365 653 1 8.00 2,304 2,920 5,224 

4. Develop Quality Control Manual3 M 288 365 653 1 40.00 11,520 14,600 26,120 5. Qualifying Test 6. Qualifying Test Shipment6

1 Product M 115 12964 14069 1 0.50 63 6532 70352 Products3,5 M 288 365 653 2 0.25 144 183 327 

7. Correlation Test 

1 Product M 115 12964 14069 10 1.00 11050 1,290640 1,4006902 Products3,5 M 288 365 653 20 1.00 5,760 7,300 13,060 

8. Quarterly On-site Audit7

Standard3,6 M 339328 713599 1,052927 3 4.00 4,0683,93

6

8,5567,18

8

12,62411,

124

NAF (With New Certification) M 1711 276211 293222 1 4.00 6844 1,104844 1,172888NAF (With Existing Certification)

M 14 140 154 - 4.00 - - -

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

Standard/ULEF Certification3,5 M 339345 713778 1,052123 3 0.50 509518 1,070167 1,578685NAF (With New Certification) M 1711 276211 293222 1 0.50 96 138106 147112NAF (With Existing Certification) M 14 140 154 -1 0.50 -7 -70 -77

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

Standard Certification3,5 M 339328 713599 1,052927 8 1.00 2,712624 5,7044,79

2 87,416 

NAF (With New Certification) M 1711 276211 293222 2 1.00 3422 552422 586444

13. Purchase of Small Chamber Testing - - - - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 34 of 118 

Exhibit 6-9: 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) 

Total Burden (Hours) 

Domestic Foreign2 Total Domestic Foreign Total 

Unit914. Quality Control Testing10

Standard Certification3,6 M 339328 713599 1,052927 260 2.00 176,280 170,560 370,7603 11,480 547482,040 New NAF Certification 

M 1711 276211 293222 65 2.00 2,2101,43

0

35,88027,

430

38,09028,

860

15. Lost Product - - - - - - - - - 16. Initial Recordkeeping11 C 8,576 11,945 20,521 1 59.15 507,270 706,547 1,213,817 17. Recurring Recordkeeping12

Producers3,5 M 370 1,129 1,499 1 52 19,240 58,708 77,948 Fabricators with burden- Employers4 C 3,630 1,422 5,052 1 520.00 1,887,600 739,440 2,627,040 Fabricators with burden - Nonemployers4 C 5,137 1,997 7,134 1 7.21 37,038 14,398 51,436 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 1,142,895 1,963,455 Wholesalers with burden - Nonemployers C 6,094 8,487 14,581 1 3.92 23,888 33,269 57,158 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 6,126 6,684 

Minor Changes - Fabricators4 T 64,290 24,986 89,276 1 3.00 192,870 74,958 267,828 Major Changes - Producers3 C 277 108 385 1 100.00 27,700 10,800 38,500 Major Changes - Fabricators and Wholesalers4 T 16,266 6,344 22,610 1 100.00 1,626,600 634,400 2,261,000 

Total - Year 1 9,048,1020 41,296 4,137,0390 66,091 13,185,1401 07,388

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 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 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 estimates the number of certified foreign mills as 20 percent of the total number of certified mills. 3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined as 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 their products certified by a 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 correlation testing because it is assumed that their previous testing is sufficient. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 35 of 118 

Exhibit 6-9: 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) 

Total Burden (Hours) 

Domestic Foreign2 Total Domestic Foreign Total 

7. On-site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. 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) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the initial on-site audit in the first year. All producers with ULEF or NAF certification will have one on-site audit annually thereafter. 8. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with two desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or 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 with a standard certification or a new NAF certification test each production line once daily. Composite panel producers need to perform 3 months of routine small scale Producers with an existing ULEF or NAF certification will already have been exempted from quality control testing to become NAF certified. 11. Recordkeeping costs are incurred by composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fabricators, and wholesalers that import composite wood products or articles that contain composite wood products. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, 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 systems to comply with the TSCA Title VI rule. 12. While recordkeeping is required for all respondents, not all entities will incur additional recordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existing recordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers will have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products and thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to be generally sufficient to meet 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 recordkeeping costs associated 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 the total reported cost and then dividing 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 is $4,241,245. For wholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variable cost factors are 0.30338 percent and 0.05933 percent of revenue. The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring recordkeeping burden is estimated as the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs, which are calculated as 0.30338 percent of average nonemployer fabricator revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurring recordkeeping burdens are 7.21 and 3.92 hours per year, respectively. 13. Firms Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their name, the date the finished good was produced, and a statement of compliance. Retailers are not required to modify their labeling system to comply with the proposed rule assuming they do not modify the packaging of the products they purchase. This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators that are already complying with the CARB ATCM 33 percent of fabricators, and 1 percent of wholesalers will incur the cost associated with 3 hours of labor for making small changes to their labels. The remaining fabricators and one percent of wholesalers are assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).

1063 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 36 of 118 

Exhibit 6-10: 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 Burden (Hours) 

Domestic Foreign2 Total Domestic Foreign Total 

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 339328 713599 1,052927 4 4.00 5,424248 11,4089, 584 1614,832 NAF (With New Certification) M 1711 276211 293222 1 4.00 6844 1,104844 1,172888NAF (With Existing Certification)

M 14 140 154 1 4.00 56 560 616

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

Standard/ULEF Certification3,5 M 339345 713778 1,052123 4 0.50 678690 1,426556 2,104246NAF (With New Certification) M 1711 276211 293222 1 0.50 96 138106 147112NAF (With Existing Certification) M 14 140 154 1 0.50 7 70 77 

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

Standard Certification3,5 M 339328 713599 1,052927 8 1.00 2,712624 5,7044,79

2 87,416 

NAF (With New Certification) M - - - - - - - - 

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

Standard Certification3,5 M 339328 713599 1,052927 260 2.00 176,280170, 370,760 547482,040 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 37 of 118 

Exhibit 6-10: 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 Burden (Hours) 

Domestic Foreign2 Total Domestic Foreign Total 

560 311,480
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 38 of 118 

Exhibit 6-10: 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 Burden (Hours) 

Domestic Foreign2 Total Domestic Foreign Total 

New NAF Certification M - - - - - - - - 

15. Lost Product 16. Initial Recordkeeping11 C - - - - - - - - 17. Recurring Recordkeeping12

Producers3,5

M 370 1,129 1,499 1 52.00 19,240 58,708 77,948 

Fabricators with burdenEmployers4 C 3,630 1,422 5,052 1 520.00 1,887,600 739,440 2,627,040 Fabricators with burden - Nonemployers4 C 5,137 1,997 7,134 1 7.21 37,038 14,398 51,436 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 1,142,895 1,963,455

Wholesalers with burden - Nonemployers 

C 6,094 8,487 14,581 1 3.92 23,888 33,269 57,158

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 2,973,560967, 505 2,379,8803 17,142 5,353,44128 4,648

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 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 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 estimates the number of certified foreign mills as 20 percent of the total number of certified mills. 3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined as 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 their products certified by a 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 correlation testing because it is assumed that their previous testing is sufficient. 7. On-site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. 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) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 39 of 118 

Exhibit 6-10: 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 Burden (Hours) 

Domestic Foreign2 Total Domestic Foreign Total 

initial on-site audit in the first year. All producers with ULEF or NAF certification will have one on-site audit annually thereafter. 8. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with two desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or 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 with s standard certification or a new NAF certification test each production line once daily. Composite panel producers need to perform 3 months of routine small scale Producers with an existing ULEF or NAF certification will already have been exempted from quality control testing to become NAF certified. 11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fabricators, and wholesalers that import composite wood products or articles that contain composite wood products. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, 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 systems to comply with the TSCA Title VI rule. 12. While recordkeeping is required for all respondents, not all entities will incur additional recordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existing recordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers will have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products and thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to be generally sufficient to meet 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 recordkeeping costs associated 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 the total reported cost and then dividing 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 is $4,241,245. For wholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variable cost factors are 0.30338 percent and 0.05933 percent of revenue. The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring recordkeeping burden is estimated as the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs, which are calculated as 0.30338 percent of average nonemployer fabricator revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurring recordkeeping burdens are 7.21 and 3.92 hours per year, respectively. 13. Firms Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their name, the date the finished good was produced, and a statement of compliance. Retailers are not required to modify their labeling system to comply with the proposed rule assuming they do not modify the packaging of the products they purchase This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators that are already complying with the CARB ATCM 33 percent of fabricators, and 1 percent of wholesalers will incur the cost associated with 3 hours of labor for making small changes to their labels. The remaining fabricators and one percent of wholesalers are assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).

1064 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 40 of 118 

Exhibit 6-11: 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) 

Total Burden (Hours) 

Domestic Foreign2 Total Domestic Foreign Total 

1. Rule Familiarization 

Producers3 M 370 1,129 1,499 0.3333 4.0000 493 1,505 1,998 Fabricators4 M 79,701 31,083 110,784 0.3333 4.0000 106,257 41,440 147,697 Wholesalers M 85,560 33,368 118,928 0.3333 4.0000 114,069 44,486 158,555 Retailers M 759,048 - 759,048 0.3333 4.0000 1,011,963 - 1,011,963 

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

With Existing Certifications M 82 764 846 0.3333 4.0000 109 1,019 1,128 Without Existing Certifications3,5 M 288 365 653 0.3333 8.0000 768 973 1,741 

4. Develop Quality Control Manual3 M 288 365 653 0.3333 40.0000 3,840 4,866 8,706 5. Qualifying Test - - - - - - - - - 6. Qualifying Test Shipment 

1 Product M 115 12964 14069 0.3333 0.5000 21 2111 23122 Products3,5 M 288 365 653 0.6667 0.2500 48 61 109 

7. Correlation Test6 

1 Product M 115 12964 14069 3.3333 1.0000 3717 430213 4672302 Products3,5 M 288 365 653 6.6667 1.0000 1,920 2,433 4,353 

8. Quarterly On-site Audit7

Standard3,5 M 339328 713599 1,052927 3.6667 4.0000 4,972811 10,457 8,785 15,42913, 596NAF (With New Certification) 

M 1711 276211 29322

2 1.0000 4.0000 6844 1,10484

4 1,172888

NAF (With Existing Certification)

M 14 140 154 0.6667 4.0000 37 373 411

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

Standard/ULEF Certification3,5 M 339345 713778 1,052123 3.6667 0.5000 622633 1,30742

6

1,9292,05

9

NAF (With New Certification) 

M 1711 276211 29322

2 1.0000 0.5000 96 138106 147112

NAF (With Existing Certification) M 14 140 154 0.66671.0000 0.5000 57 4770 5177

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

Standard Certification3,5 M 339328 713599 1,052927 8.0000 1.0000 2,712624 5,7044, 792 87,416 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 41 of 118 

Exhibit 6-11: 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) 

Total Burden (Hours) 

Domestic Foreign2 Total Domestic Foreign Total 

NAF (With New Certification) 

M 1711 276211 29322

2 0.6667 1.0000 117 184141 195148

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

Standard Certification3,5

M 339328 713599 1,052927 260.0000 2.0000 176,2801 70,560 370,76

0311,480

547482,04

0 

New NAF Certification 

M 1711 276211 29322

2 21.6667 2.0000 737477 11,960 9,143 12,6979,620

15. Lost Product - - - - - - - - - 16. Initial Recordkeeping11 C 8,576 11,945 20,521 0.3333 59.1500 169,073 235,492 404,565 17. Recurring Recordkeeping12

Producers3,5 M 370 1,129 1,499 1.0000 52.0000 19,240 58,708 77,948 

Fabricators with burden- Employers4 C 3,630 1,422 5,052 1.0000 520.0000 1,887,600 739,440 2,627,040 Fabricators with burden - Nonemployers4 C 5,137 1,997 7,134 1.0000 7.2100 37,038 14,398 51,436 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 1,142,895 1,963,455 Wholesalers with burden - Nonemployers C 6,094 8,487 14,581 1.0000 3.9200 23,888 33,269 57,158157Wholesalers 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 2,042 2,228 Minor Changes - Fabricators4 T 64,290 24,986 89,276 0.3333 3.0000 64,284 24,984 89,267268Major Changes - Producers3 C 277 108 385 0.3333 100.0000 9,232 3,600 12,832 Major Changes - Fabricators and Wholesalers4 T 16,266 6,344 22,610 0.3333 100.0000 542,146 211,446 753,591592

Total - Three Year Average 4,998,20

6991,901

2,965,5

42900,06

8

7,963,747

891,969

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 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 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 estimates the number of certified foreign mills as 20 percent of the total number of certified mills. 3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined as hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use added formaldehyde resins. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 42 of 118 

Exhibit 6-11: 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) 

Total Burden (Hours) 

Domestic Foreign2 Total Domestic Foreign Total 

4. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins. 5. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by a 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 correlation testing because it is assumed that their previous testing is sufficient. 7. On-site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. 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) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the initial on-site audit in the first year. All producers with ULEF or NAF certification will have one on-site audit annually thereafter. 8. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with two desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or 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 with a standard certification or a new NAF certification test each production line once daily. Composite panel producers need to perform 3 months of routine small scale Producers with an existing ULEF or NAF certification will already have been exempted from quality control testing to become NAF certified. 11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fabricators, and wholesalers that import composite wood products or articles that contain composite wood products. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, 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 systems to comply with the TSCA Title VI rule. 12. While recordkeeping is required for all respondents, not all entities will incur additional recordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existing recordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers will have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products and thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to be generally sufficient to meet 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 recordkeeping costs associated 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 the total reported cost and then dividing 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 is $4,241,245. For wholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variable cost factors are 0.30338 percent and 0.05933 percent of revenue. The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring recordkeeping burden is estimated as the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs, which are calculated as 0.30338 percent of average nonemployer fabricator revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurring recordkeeping burdens are 7.21 and 3.92 hours per year, respectively. 13. Firms Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their name, the date the finished good was produced, and a statement of compliance. Retailers are not required to modify their labeling system to comply with the proposed rule assuming they do not modify the packaging of the products they purchase This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators that are already complying with the CARB ATCM 33 percent of fabricators, and 1 percent of wholesalers will incur the cost associated with 3 hours of labor for making small changes to their labels. The remaining fabricators and one percent of wholesalers are assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).

1065 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 43 of 118 

Exhibit 6-12: 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) Incremental Burden (Hours) Domestic Foreign2 Total Domestic Foreign Total 

1. Rule Familiarization 

Producers3 M 370 1,129 1,499 1 4.00 1,480 4,516 5,996 Fabricators4 M 79,701 31,083 110,784 1 4.00 318,804 124,332 443,136 Wholesalers M 85,560 33,368 118,928 1 4.00 342,240 133,472 475,712 Retailers M 759,048 - 759,048 1 4.00 3,036,192 - 3,036,192 

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

With Existing Certifications M 82 764 846 1 4.00 328 3,056 3,384 Without Existing Certifications3,5 M 288 365 653 1 8.00 2,304 2,920 5,224 

4. Develop Quality Control Manual3 M 288 365 653 1 40.00 11,520 14,600 26,120 5. Qualifying Test - - - - - - - - - 6. Qualifying Test Shipment 

1 Product M 115 12964 14069 1 0.50 63 6532 70352 Products3,5 M 288 365 653 2 0.25 144 183 327 

7. Correlation Test6

1 Product M 115 12964 14069 10 1.00 11050 1,290640 1,4006902 Products3,5 M 288 365 653 20 1.00 5,760 7,300 13,060 

8. Quarterly On-site Audit7

Uncertified to Standard3,5 M 277 154 431 3 4.00 3,324 1,848 5,172 ULEF to Standard

M 11 114 125 3 4.00 132 1,368 1,500

NAF (With New Certification) M 11 211 222 1 4.00 44 844 888 

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

Uncertified to Standard3,5 M 277 154 431 3 0.50 416 231 647 ULEF to Standard

M 11 114 125 3 0.50 17 171 188

NAF (With New Certification) M 11 211 222 1 0.50 6 106 111112

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

Uncertified to Standard3,5 M 277 154 431 8 1.00 2,216 1,232 3,448 ULEF to Standard

M 11 114 125 8 1.00 88 912 1,000

NAF (With New Certification) M 11 211 222 2 1.00 22 422 444 

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

Standard Certification3,5 M 288277 268154 556431 260 2.00 149,760 144,040 139,3608 0,080 289224,120 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 44 of 118 

Exhibit 6-12: 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) Incremental Burden (Hours) Domestic Foreign2 Total Domestic Foreign Total 

New NAF Certification 

M 1711 276211 293222 65 2.00 2,2101,430 35,88027, 430 38,09028, 860

15. Lost Product - - - - - - - - - 16. Initial Recordkeeping11 C 8,576 11,945 20,521 1 59.15 507,270 706,547 1,213,817 17. Recurring Recordkeeping12

Producers3,5 M 370 1,129 1,499 1 52.00 19,240 58,708 77,948 Fabricators with burden- Employers4 C 2,176 848 3,024 1 520.00 1,131,520 440,960 1,572,480 Fabricators with burden - Nonemployers4 C 3,054 1,191 4,245 1 7.21 22,019 8,587 30,606 Fabricators without burden C 42,310 16,437 58,747 1 - - - - Wholesalers with burden - Employers 

C 2,642 3,680 6,322 1 195.00 515,190 717,600 1,232,790 

Wholesalers with burden - Nonemployers 

C 3,826 5,331 9,157 1 3.92 14,998 20,898 35,895 

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 6,126 6,684 Minor Changes - Fabricators4 T 64,290 24,986 89,276 1 3.00 192,870 74,958 267,828Major Changes - Producers3 C 277 108 385 1 100.00 27,700 10,800 38,500Major Changes - Fabricators and Wholesalers4 T 16,266 6,344 22,610 1 100.00 1,626,600 634,400 2,261,000

Total - Year 1 7,935,08

8928,288

3,153,692

082,828

11,088,77

7011,115

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 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 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 estimates the number of certified foreign mills as 20 percent of the total number of certified mills. 3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined as 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 their products certified by a 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 correlation testing because it is assumed that their previous testing is sufficient. 7. On-site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. 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) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 45 of 118 

Exhibit 6-12: 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) Incremental Burden (Hours) Domestic Foreign2 Total Domestic Foreign Total 

initial on-site audit in the first year. All producers with ULEF or NAF certification will have one on-site audit annually thereafter. 8. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with two desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or 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 with a standard certification or a new NAF certification test each production line once daily. Composite panel producers need to perform 3 months of routine small scale Producers with an existing ULEF or NAF certification will already have been exempted from quality control testing to become NAF certified. 11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fabricators, and wholesalers that import composite wood products or articles that contain composite wood products. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, 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 systems to comply with the TSCA Title VI rule. 12. While recordkeeping is required for all respondents, not all entities will incur additional recordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existing recordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers will have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products and thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to be generally sufficient to meet 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 recordkeeping costs associated 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 the total reported cost and then dividing 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 is $4,241,245. For wholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variable cost factors are 0.30338 percent and 0.05933 percent of revenue. The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring recordkeeping burden is estimated as the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs, which are calculated as 0.30338 percent of average nonemployer fabricator revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurring recordkeeping burdens are 7.21 and 3.92 hours per year, respectively. 13. FirmsPanel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their name, the date the finished good was produced, and a statement of compliance. Retailers are not required to modify their labeling system to comply with the proposed rule assuming they do not modify the packaging of the products they purchase. This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators that are already complying with the CARB ATCM will incur the cost associated with 3 hours of labor for making small changes to their labels. The remaining fabricators and one percent of wholesalers are assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).

1066 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 46 of 118 

Exhibit 6-13: 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) Incremental Burden (Hours) Domestic Foreign2 Total Domestic Foreign Total 

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 4,432 2,464 6,896 ULEF to Standard

M 11 114 125 3 4.00 132 1,368 1,500

NAF (With New Certification) 

M 11 211 222 13 4.00 44132 8442,53

2

8882,66

4

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

Uncertified to Standard3,5 M 277 154 431 4 0.50 554 308 862 ULEF to Standard

M 11 114 125 3 0.50 17 171 188

NAF (With New Certification) M 11 211 222 1 0.50 6 106 111112

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

Uncertified to Standard3,5 M 277 154 431 8 1.00 2,216 1,232 3,448 ULEF to Standard

M 11 114 125 8 1.00 88 912 1,000

NAF (With New Certification) 

M- - - - - - - - - 

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

Standard Certification3,5

M 288277 268154 556431

260 2.00 

149,7601

44,040

139,36

080,080

289224,

120 

New NAF Certification M - - - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 47 of 118 

Exhibit 6-13: 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) Incremental Burden (Hours) Domestic Foreign2 Total Domestic Foreign Total 

15. Lost Product - - - - - - - - - 16. Initial Recordkeeping11 C - - - - - - - - 17. Recurring Recordkeeping12

Producers3,5 M 370 1,129 1,499 1 52.00 19,240 58,708 77,948 Fabricators with burden- Employers4 C 2,176 848 3,024 1 520.00 1,131,520 440,960 1,572,480 Fabricators with burden - Nonemployers4 C 3,054 1,191 4,245 1 7.21 22,019 8,587 30,606 Fabricators without burden C 42,310 16,437 58,747 1 - - - - Wholesalers with burden - Employers C 2,642 3,680 6,322 1 195.00 515,190 717,600 1,232,790 Wholesalers with burden - Nonemployers C 3,826 5,331 9,157 1 3.92 14,998 20,898 35,895 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 1,860,21

6854,347

1,393,5

18333,47

5

3,253,7

32187,82

1

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 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 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 estimates the number of certified foreign mills as 20 percent of the total number of certified mills. 3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined as 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 their products certified by a 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 correlation testing because it is assumed that their previous testing is sufficient. 7. On-site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. 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) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the initial on-site audit in the first year. All producers with ULEF or NAF certification will have one on-site audit annually thereafter. 8. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with two desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or 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 48 of 118 

Exhibit 6-13: 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) Incremental Burden (Hours) Domestic Foreign2 Total Domestic Foreign Total 

10. This analysis assumes that composite panel producers with a standard certification or a new NAF certification test each production line once daily. Composite panel producers need to perform 3 months of routine small scale Producers with an existing ULEF or NAF certification will already have been exempted from quality control testing to become NAF certified. 11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fabricators, and wholesalers that import composite wood products. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, 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 systems to comply with the TSCA Title VI rule. 12. While recordkeeping is required for all respondents, not all entities will incur additional recordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existing recordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers will have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products and thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to be generally sufficient to meet 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 recordkeeping costs associated 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 the total reported cost and then dividing 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 is $4,241,245. For wholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variable cost factors are 0.30338 percent and 0.05933 percent of revenue. The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring recordkeeping burden is estimated as the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs, which are calculated as 0.30338 percent of average nonemployer fabricator revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurring recordkeeping burdens are 7.21 and 3.92 hours per year, respectively. 13. Firms Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their name, the date the finished good was produced, and a statement of compliance. Retailers are not required to modify their labeling system to comply with the proposed rule assuming they do not modify the packaging of the products they purchase. This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators that are already complying with the CARB ATCM will incur the cost associated with 3 hours of labor for making small changes to their labels. The remaining fabricators and one percent of wholesalers are assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).

1067 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 49 of 118 

Exhibit 6-14: 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) Incremental Burden (Hours) Domestic Foreign2 Total Domestic Foreign Total 

1. Rule Familiarization 

Producers3 M 370 1,129 1,499 0.3333 4.0000 493 1,505 1,998 Fabricators4 M 79,701 31,083 110,784 0.3333 4.0000 106,257 41,440 147,697 Wholesalers M 85,560 33,368 118,928 0.3333 4.0000 114,069 44,486 158,555 Retailers M 759,048 - 759,048 0.3333 4.0000 1,011,963 - 1,011,963 

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

With Existing Certifications M 82 764 846 0.3333 4.0000 109 1,019 1,128 Without Existing Certifications3,5 M 288 365 653 0.3333 8.0000 768 973 1,741 

4. Develop Quality Control Manual3 M 288 365 653 0.3333 40.0000 3,840 4,866 8,706 5. Qualifying Test - - - - - - - - -6. Qualifying Test Shipment 

1 Product M 115 12964 14069 0.3333 0.5000 21 2111 23122 Products3,5 M 288 365 653 0.6667 0.2500 48 61 109 

7. Correlation Test6

1 Product M 115 12964 14069 3.3333 1.0000 3717 430213 4672302 Products3,5 M 288 365 653 6.6667 1.0000 1,920 2,433 4,353 

8. Quarterly On-site Audit7

Uncertified to Standard3,5 M 277 154 431 3.6667 4.0000 4,063 2,259 6,321322

ULEF to Standard

M 11 114 125 3.0000 4.0000 132 1,368 1,500

NAF (With New Certification) M 11 211 222 1.00002.333

3 4.0000 44103 8441,969 8882,072

9. Large Scale Testing Fee - - - - - - - - -10. Large Scale Testing Shipment8

Uncertified to Standard3,5 M 277 154 431 3.6667 0.5000 508 282 790 ULEF to Standard

M 11 114 125 3.0000 0.5000 17 171 188

NAF (With New Certification) M 11 211 222 1.0000 0.5000 6 106 111112

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

Uncertified to Standard3,5 M 277 154 431 8.0000 1.0000 2,216 1,232 3,448 ULEF to Standard

M 11 114 125 8.0000 1.0000 88 912 1,000

NAF (With New Certification) M 11 211 222 0.6667 1.0000 7 141 148 

13. Purchase of Small Chamber Testing Unit9 - - - - - - - - -14. Quality Control Testing10
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

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Exhibit 6-14: 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) Incremental Burden (Hours) Domestic Foreign2 Total Domestic Foreign Total 

Standard Certification3,5 M 288277 268154 556431 260.0000 2.0000 149,76014 4,040 139,3608 0,080 289224,120 New NAF Certification 

M 1711 276211 293222 21.6667 2.0000 737477 11,9609,143 12,6979,620

15. Lost Product - - - - - - - - -16. Initial Recordkeeping11 C 8,576 11,945 20,521 0.3333 59.1500 169,073 235,492 404,565 17. Recurring Recordkeeping12

Producers3,5 M 370 1,129 1,499 1.0000 52.0000 19,240 58,708 77,948 

Fabricators with burdenEmployers4 C 2,176 848 3,024 1.0000 520.0000 1,131,520 440,960 1,572,480 Fabricators with burden - Nonemployers4 C 3,054 1,191 4,245 1.0000 7.2100 22,019 8,587 30,606 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 515,190 717,600 1,232,790Wholesalers with burden - Nonemployers C 3,826 5,331 9,157 1.0000 3.9200 14,998 20,898 35,895896Wholesalers 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 2,042 2,228 Minor Changes - Fabricators4 T 64,290 24,986 89,276 0.3333 3.0000 64,284 24,984 89,267268Major Changes - Producers3 C 277 108 385 0.3333 100.0000 9,232 3,600 12,832 Major Changes - Fabricators and Wholesalers4 T 16,266 6,344 22,610 0.3333 100.0000 542,146 211,446 753,591592

Total - Three Year Average 3,884,9728 78,793 1,980,186 916,536 5,865,153 795,329

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 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 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 estimates the number of certified foreign mills as 20 percent of the total number of certified mills. 3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined as 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 their products certified by a 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

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Exhibit 6-14: 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) Incremental Burden (Hours) Domestic Foreign2 Total Domestic Foreign Total 

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 correlation testing because it is assumed that their previous testing is sufficient. 7. On-site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. 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) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the initial on-site audit in the first year. All producers with ULEF or NAF certification will have one on-site audit annually thereafter. 8. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with two desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or 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 with a standard certification or a new NAF certification test each production line once daily. Composite panel producers need to perform 3 months of routine small scale Producers with an existing ULEF or NAF certification will already have been exempted from quality control testing to become NAF certified. 11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fabricators, and wholesalers that import composite wood products or articles that contain composite wood products. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, 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 systems to comply with the TSCA Title VI rule. 12. While recordkeeping is required for all respondents, not all entities will incur additional recordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existing recordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers will have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products and thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to be generally sufficient to meet 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 recordkeeping costs associated 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 the total reported cost and then dividing 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 is $4,241,245. For wholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variable cost factors are 0.30338 percent and 0.05933 percent of revenue. The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring recordkeeping burden is estimated as the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs, which are calculated as 0.30338 percent of average nonemployer fabricator revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurring recordkeeping burdens are 7.21 and 3.92 hours per year, respectively. 13. FirmsPanel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their name, the date the finished good was produced, and a statement of compliance. Retailers are not required to modify their labeling system to comply with the proposed rule assuming they do not modify the packaging of the products they purchase. This analysis assumes that all producers, 67 percent of fabricators that are not already complying with the CARB ATCM, and all fabricators that are already complying with the CARB ATCM will incur the cost associated with 3 hours of labor for making small changes to their labels. The remaining fabricators and one percent of wholesalers are assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).

1068 1069 1070 1071 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

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1072 

1073 6(b) Estimating Respondent Costs

1074 

1075 Respondent costs are estimated by multiplying burden estimates from the previous 

1076 section with loaded wage rates, and adding in capital/startup costs and operating and 

1077 maintenance (O&M) costs. 

1078 

1079 (i) Wage Rates 

1080 

1081 The fully loaded unit labor cost for managerial, technical, and clerical labor in the 

1082 regulated industry and for EPA staff is estimated by adding fringe benefits and overhead costs to 

1083 the hourly wage or annual salary for each category following the method described in Wage 

1084 Rates for Economic Analysis of the Toxics Release Inventory Program. This section describes 

1085 the method employed to estimate the fully loaded unit labor costs for each labor category and 

1086 presents the results of the analysis. 

1087 

1088 Wage data used to calculate the labor costs are from the May 2009 National Industry1089 Specific Occupational Employment and Wage Estimates estimated as part of the Bureau of 

Labor Statistics’(BLS’) Occupational Employment Statistics Program (OES).21 1090 The values were 

1091 inflated to 2010 dollars using data from the BLS’ Employer Costs for Employee Compensation 

(ECEC) for all private industry for 2009 and 2010.22 1092 Thus, the analysis uses domestic wage rates 

1093 to estimate the costs for burden incurred by foreign firms. 

1094 

1095 The costs of fringe benefits (i.e., paid leave and insurance) were estimated using the same 

1096 ECEC data for all private industry in 2010, resulting in a fringe benefit rate of 42 percent. An 

1097 additional loading factor of 17 percent is applied to wages to account for overhead. This 

1098 overhead loading factor is added to the benefits loading factor, and the total (1.59) is then applied 

1099 to the base wage to derive the fully loaded wage. 

1100 

1101 The derivation of the fully loaded costs for managerial, technical, and clerical labor is 

1102 presented in Exhibit 6-15. Note that two types of managerial labor costs are calculated – one for 

1103 rule familiarization (a general managerial labor rate for wood product manufacturing NAICS) 

1104 and one for testing and certification (a more specific managerial labor rate for composite panel 

1105 manufacturing NAICS). 

1106 

 21 U.S. Bureau of Labor Statistics (BLS) 2009 

22 U.S. Bureau of Labor Statistics (BLS) 2011
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 53 of 118 

Exhibit 6-15: Derivation of Loaded Industry Wage Rates

Labor 

Category Entity Type Burden Type Data Source for Wage Information 

Wage 

($2010) 

Fringe and 

Overhead Factor 

Loaded Wages 

($2010) 

(a) (b) (c) = (a)*(b) 

Managerial 

Composite Panel Producers 

Rule Familiarization 

BLS OES, Managerial Occupations, NAICS 

321000 - Wood Product Manufacturing $46.29 

1.59 

$73.60 Fabricators 

Wholesalers BLS OES, Managerial Occupations, Sector 42 - Wholesale Trade $58.67 $93.29 Retailers 

BLS OES, Managerial Occupations, 321200 - Veneer, Plywood, and Engineered Wood Product Manufacturing 

$44.47 $70.71 

Composite Panel Producers 

Testing and Certification, Recordkeeping 

BLS OES, Managerial Occupations, 321200 - 

Veneer, Plywood, and Engineered Wood Product Manufacturing 

$44.88 $71.36 

Technical Fabricators / Wholesalers Labeling 

BLS OES, Computer and Mathematical Science 

Occupations, 321200 - Veneer, Plywood, and Engineered Wood Product Manufacturing 

$27.84 $44.27 

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 $24.84 Fabricators 

Wholesalers BLS OES, Office and Administrative Support Occupations, Sector 42 - Wholesale Trade $16.06 $25.54 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

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1107 (ii) Costs Per Respondent

1108 

1109 This section describes the recordkeeping and reporting costs for each respondent activity 

1110 as a result of the proposed TSCA Title VI Rule. The total cost is comprised of labor costs, 

1111 capital/start-up costs, and operating and maintenance (O&M) costs. The latter two costs are 

1112 classified as non-labor costs in this analysis. Labor costs are presented first since they are based 

1113 directly on the labor burden and the loaded wage rates summarized above. Costs are broken out 

1114 such that each unique combination of (1) the number of responses per respondent and (2) per1115 response costs is classified as a separate activity. 

1116 

1117 Labor Costs 

1118 

1119 Exhibit 6-16 and Exhibit 6-17 summarize the total per-activity recordkeeping and 

1120 reporting labor costs for all respondents over the first year, and second and third years of the 

1121 rule, respectively. Exhibit 6-18 presents the average labor costs over the first three years of the 

1122 rule, by activity. Exhibit 6-19 through Exhibit 6-21 present the same information as the previous 

1123 three tables, except for the incremental labor costs. These labor costs were estimated by 

1124 multiplying the labor burdens summarized in Exhibit 6-9 through Exhibit 6-14 by the loaded 

1125 wage rates presented in Exhibit 6-15. As indicated, the estimated average annual total labor cost 

1126 over the first three years of the rule is approximately $312.2307 million, while the incremental 

1127 labor costs are $246.9242 million. The domestic labor cost accounts for approximately 66.067

1128 percent ($205.9 million) and 71.673 percent ($176.7 million) of these totals, respectively. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

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Exhibit 6-16: Total (including baseline) First Year Labor Costs, by Activity and Geographic Location ($2010) 

Activity Domestic Foreign Total Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial 

1. Rule Familiarization 

Producers1 - - $108,928 - - $332,378 - - $441,306Fabricators1 - - $23,463,974 - - $9,150,835 - - $32,614,810Wholesalers2 - - $31,927,570 - - $12,451,603 - - $44,379,172Retailers3 - - $214,689,136 - - - - - $214,689,136

2. Certification Fee - - - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - $23,406 - - $218,076 - - $241,482Without Existing Certifications - - $164,413 - - $208,371 - - $372,785

4. Develop Quality Control Manual4 - - $822,067 - - $1,041,856 - - $1,863,9235. Qualifying Test - - - - - - - - - 6. Qualifying Test Shipment4

1 Product - - $428214 - - $4,6382,284 - - $4,9952,498 2 Products - - $10,347276 - - $13,059 - - $23,335 

7. Correlation Test4

1 Product - - $7,8503,568 - - 

$92,05445,67

0 - - $99,90449,238 

2 Products - - $411,034 - - $520,928 - - $931,962 

8. Quarterly On-site Audit4

Standard - - 

$290,292280

,873 - - 

$610,55651

2,936 - - 

$900,849793

,809 

NAF (With New Certification) - - $4,8523,140 - -

$78,78160,2

28 - -

$83,63463,36

8 

NAF (With Existing Certification) - - - - - - - - -

9. Large Scale Testing Fee - - - - - - - - - 10. Large Scale Testing Shipment4

Standard/ULEF Certification - - $36,322964 - -

$76,35583,2

77 - - 

$112,606120

,242 

NAF (With New Certification) - - $642428 - - $9,8487,564 - - $10,4907,992 

NAF (With Existing Certification) - - -$500 - - -$4,995 - - -$5,495 

11. On-site Audit Travel4 - - - - - - - - - 12. Desk Audits4

Standard Certification - - 

$193,528187

,249 - -

$407,03734

1,957 - - 

$600,566529

,206 

NAF (With New Certification) - - $2,4261,570 - - $39,39130,114 - - $41,81731,684 

13. Purchase of Small Chamber Testing Unit - - - - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

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Exhibit 6-16: Total (including baseline) First Year Labor Costs, by Activity and Geographic Location ($2010) 

Activity Domestic Foreign Total Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial 

14. Quality Control Testing4

Standard Certification - - 

$12,579,341

171,162 - - $26,457,43

422,227,213 - - $39,036,77

434,398,374 

New NAF Certification - - 

$157,706102

,045 - - 

$2,560,397

1,957,405 

- - $2,718,1020

59,450 

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 $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 - - $11,856,746 -Major Changes – Producers6 $688,068 - - $268,272 - - $956,340 - - Major Changes - Fabricators and Wholesalers7 - $72,009,582 - - $28,084,888 - - $100,094,470 -

Total - Year 1 

$84,405,781 $80,547,937 $284,894,19

1408,517 $71,419,619 $31,403,279 $54,273,59

749,210,749 $155,825,426 $111,951,216 $339,167,6 48333,619,267 

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 118 

Exhibit 6-16: Total (including baseline) Second and Third Year Costs, by Activity and Geographic Location ($2010)

Activity

Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

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 Test41 Product - - - - - - - - -2 Products - - - - - - - - - 8. Quarterly On-site Audit4Standard Certification - - $387,057 - - $814,075 - - $1,201,132NAF (With New Certification) - - $4,852 - - $78,781 - - $83,634NAF (With Existing Certification) - - $3,996 - - $39,962 - - $43,958

9. Large Scale Testing Fee - - - - - - - - -10. Large Scale Testing Shipment4

Standard Certification - - $48,382 - - $101,759 - - $150,141NAF (With New Certification) - - $642 - - $9,848 - - $10,490NAF (With Existing Certification) - - $500 - - $4,995 - - $5,495

11. On-site Audit Travel - - - - - - - - -12. Desk Audits4

Standard Certification - - $193,528 - - $407,037 - - $600,566NAF (With New Certification) - - - - - - - - -

13. Purchase of Small Chamber Testing Unit - - - - - - - - -14. Quality Control Testing4
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 58 of 118 

Exhibit 6-16: Total (including baseline) Second and Third Year Costs, by Activity and Geographic Location ($2010)

Activity

Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

Standard Certification - - $12,579,341 - - $26,457,434 - - $39,036,774New 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 - $41,132,190

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***

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Exhibit 6-17: Three Year Average Labor CostsTotal (including baseline),) Second and Third Year Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign Total 

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial 

1. Rule Familiarization 

Producers1

- - $36,285- - - $110,76

8-

- - $147,053-

Fabricators1

- - $7,820,5

15-

- - $3,049,9

84-

- - $10,870,49

9-

Wholesalers2

- - $10,641,

497-

- - $4,150,0

99-

- - $14,791,59

6-

Retailers3

- - $71,555,

904-

- - - - - $71,555,90

4-

2. Certification Fee - - - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - $7,778- - - $72,716- - - $80,494-Without Existing Certifications - - $54,804- - - $69,433- - - $124,238-

4. Develop Quality Control Manual4Manual

- - $274,022

-

- - $347,23

8-

- - $621,260-

5. Qualifying Test - - - - - - - - - 6. Qualifying Test Shipment4Shipment7

1 Product - - $143- - - $1,499- - - $1,641-2 Products - - $3,425- - - $4,353- - - $7,778-

7. Correlation Test4

1 Product - - $2,640- - - $30,685- - - $33,325-2 Products 

- - $137,011

-

- - $173,61

9-

- - $310,630-

8. Quarterly On-site Audit4

Standard Certification 

- - $354,802

374,497

- - $746,212

683,914

- - $1,101,0130

58,412

NAF (With New Certification) 

- - $4,8523,1

40

- - $78,7816

0,228

- - $83,63463,3

68

NAF (With Existing Certification) - - $2,640 - - $26,617 - - $29,329

9. Large Scale Testing Fee - - - - - - - - - 10. Large Scale Testing Shipment4
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

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Exhibit 6-17: Three Year Average Labor CostsTotal (including baseline),) Second and Third Year Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign Total 

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial 

Standard/ULEF Certification 

- - $44,38649

,238

- - $93,2681

11,036

- - $137,65316

0,275

NAF (With New Certification) 

- - $642428 - - $9,8487,564 - - $10,4907,99

2

NAF (With Existing Certification) 

- - $357500 - - $3,3544,99

5

- - $3,6395,495

11. On-site Audit Travel - - - - - - - - - 12. Desk Audits4

Standard Certification 

- - $193,528

187,249

- - $407,037

341,957

- - $600,56652

9,206

NAF (With New Certification) - - $785- - - $13,130- - - $13,915-

13. Purchase of Small Chamber Testing Unit - - - - - - - - - 14. Quality Control Testing4

Standard Certification 

- - $12,579,3

41171,162 - - 

$26,457,

43422,227

,213

- - $39,036,77

434,398,374

New NAF Certification 

- - $52,592- - - $853,46

6-

- - $906,058-

15. Lost Product - - - - - - - - - 16. Initial Recordkeeping5

$4,318,1

24-

- - $6,014,4

66-

- - $10,332,5

90-

- - 

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

Page 61 of 118 

Exhibit 6-17: Three Year Average Labor CostsTotal (including baseline),) Second and Third Year Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign Total 

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial 

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 - $12,786,214 $52,953,967 - $23,436,90

7

$123,702,16

9 - $36,223,122

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 118 

Exhibit 6-18: Three Year Average Labor Costs (including baseline), by Activity and Geographic Location ($2010)

Activity

Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

1. Rule Familiarization

Producers1 - - $36,309 - - $110,793 - - $147,102Fabricators1 - - $7,821,325 - - $3,050,278 - - $10,871,603Wholesalers2 - - $10,642,523 - - $4,150,534 - - $14,793,057Retailers3 - - $71,563,045 - - - - - $71,563,045

2. Certification Fee - - - - - - - - -3. Initial On-site Audit4

With Existing Certifications - - $7,802 - - $72,692 - - $80,494Without Existing Certifications - - $54,804 - - $69,457 - - $124,262

4. Develop Quality Control Manual4 - - $274,022 - - $347,285 - - $621,3085. Qualifying Test - - - - - - - - -6. Qualifying Test Shipment4

1 Product - - $71 - - $761 - - $8332 Products - - $3,425 - - $4,353 - - $7,778

7. Correlation Test4

1 Product - - $1,189 - - $15,223 - - $16,4132 Products - - $137,011 - - $173,643 - - $310,654

8. Quarterly On-site Audit4

Standard Certification - - $343,289 - - $626,921 - - $970,211NAF (With New Certification) - - $3,140 - - $60,228 - - $63,368

9. Large Scale Testing Fee - - - - - - - - -10. Large Scale Testing Shipment4

Standard/ULEF Certification - - $45,147 - - $101,783 - - $146,931NAF (With New Certification) - - $428 - - $7,564 - - $7,992

NAF (With Existing Certification) - - $500 - - $4,995 - - $5,495

11. On-site Audit Travel - - - - - - - - -12. Desk Audits4

Standard Certification - - $187,249 - - $341,957 - - $529,206NAF (With New Certification) - - $523 - - $10,038 - - $10,561
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 63 of 118 

Exhibit 6-18: Three Year Average Labor Costs (including baseline), by Activity and Geographic Location ($2010)

Activity

Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

13. Purchase of Small Chamber Testing Unit - - - - - - - - -14. Quality Control Testing4

Standard Certification - - $12,171,162 - - $22,227,213 - - $34,398,374New NAF Certification - - $34,015 - - $652,468 - - $686,483

15. Lost Product - - - - - - - - -16. Initial Recordkeeping5 $4,318,559 - - $6,015,070 - - $10,333,629 - -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

- 

$2,845,85

3846,118 - - 

$1,106,0421

30 - - 

$3,951,85

0952,249 - 

Major Changes – Producers6 $229,323356 - - $89,424 - - $318,747780 - - Major Changes - Fabricators and Wholesalers7

- 

$24,000,80

3003,194 - - 

$9,360,714

361,629 - - 

$33,361,47

4364,823 - 

Total - Three Year Average 

$75,300,2437

11

$26,846,65

6849,312

$103,767,94

9326,979

$59,108,58

0109,184

$10,466,75

6467,759

$36,699,5

4132,028,18

6

$134,408,85

0409,922

$37,313,32

4317,072

$140,467,489

135,355,170

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

Page 64 of 118 

Exhibit 6-18: Three Year Average Labor Costs (including baseline), by Activity and Geographic Location ($2010)

Activity

Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers. Exhibit 6-18: Incremental First Year Labor Costs, by Activity and Geographic Location ($2010)

Activity

Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

1. Rule Familiarization

Producers1 - - $108,928 - - $332,378 - - $441,306Fabricators1 - - $23,463,974 - - $9,150,835 - - $32,614,810Wholesalers2 - - $31,927,570 - - $12,451,603 - - $44,379,172Retailers3 - - $214,689,136 - - - - - $214,689,136

2. Certification Fee - - - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - $23,406 - - $218,076 - - $241,482Without Existing Certifications - - $164,413 - - $208,371 - - $372,785

4. Develop Quality Control Manual4 - - $822,067 - - $1,041,856 - - $1,863,9235. Qualifying Test - - - - - - - - -6. Qualifying Test Shipment4

1 Product - - $428 - - $4,638 - - $4,995
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 65 of 118 

Exhibit 6-19: Incremental First Year Labor Costs, by Activity and Geographic Location ($2010)

Activity

Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

1. Rule Familiarization

Producers1 - - $108,928 - - $332,378 - - $441,306Fabricators1 - - $23,463,974 - - $9,150,835 - - $32,614,810Wholesalers2 - - $31,927,570 - - $12,451,603 - - $44,379,172Retailers3 - - $214,689,136 - - - - - $214,689,136

2. Certification Fee - - - - - - - - -3. Initial On-site Audit4

With Existing Certifications - - $23,406 - - $218,076 - - $241,482Without Existing Certifications - - $164,413 - - $208,371 - - $372,785

4. Develop Quality Control Manual4 - - $822,067 - - $1,041,856 - - $1,863,9235. Qualifying Test - - - - - - - - -6. Qualifying Test Shipment4

1 Product - - $214 - - $2,284 - - $2,4982 Products - - $10,276 - - $13,059 - - $23,335

7. Correlation Test4

1 Product 

- - $7,8503,568 - - $92,05445, 670 - - $99,90449,238

2 Products - - $411,034 - - $520,928 - - $931,962

8. Quarterly On-site Audit4

Uncertified to Standard - - $237,201 - - $131,873 - - $369,074ULEF to Standard - - $9,420 - - $97,620 - - $107,040NAF (With New Certification) - - $3,140 - - $60,228 - - $63,368

9. Large Scale Testing Fee - - - - - - - - - 10. Large Scale Testing Shipment4

Uncertified to Standard - - $29,686 - - $16,484 - - $46,170ULEF to Standard - - $1,213 - - $12,203 - - $13,416NAF (With New Certification) - - $428 - - $7,564 - - $7,921992

11. On-site Audit Travel - - - - - - - - - 12. Desk Audits4

Uncertified to Standard - - $158,134 - - $87,916 - - $246,049
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 66 of 118 

Exhibit 6-19: Incremental First Year Labor Costs, by Activity and Geographic Location ($2010)

Activity

Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

ULEF to Standard - - $6,280 - - $65,080 - - $71,360NAF (With New Certification) 

- - $1,570 - - $30,114 - - $31,684

13. Purchase of Small Chamber Testing Unit - - - - - - - - - 14. Quality Control Testing4

Standard Certification 

- - $10,686,874

278,694

- - $9,944,73

05,714,509 - - $20,631,60

315,993,203

New NAF Certification 

- - $157,70610

2,045

- - $2,560,39

71,957,405

- - 

$2,718,1020

59,450

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 - - $11,856,746 -Major Changes – Producers6 $688,068 - - $268,272 - - $956,340 - - Major Changes - Fabricators and Wholesalers7 - $72,009,582 - - $28,084,888 - - $100,094,470 - 

Total - Year 1 

$57,225,482 $80,547,937 $282,920,73

4435,484 $52,683,041 $31,403,279

$37,048,0

0731,991,15

3

$109,908,497 $111,951,216

$319,968,597314,426,63

7
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 67 of 118 

Exhibit 6-19: Incremental First Year Labor Costs, by Activity and Geographic Location ($2010)

Activity

Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

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 68 of 118 

Exhibit 6-20: Incremental Second and Third Year Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign Total 

Clerical Technic al Managerial Clerical Techni cal Managerial Clerical Technical Managerial 

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 - - $492,099 ULEF to Standard - - $9,420 - - $97,620 - - $107,040NAF (With New Certification) - - $3,1409,420 - - $60,228180,684 - - $63,368190,103

9. Large Scale Testing Fee - - - - - - - - - 10. Large Scale Testing Shipment4

Uncertified to Standard - - $39,533 - - $21,979 - - $61,512 ULEF to Standard - - $1,213 - - $12,203 - - $13,416NAF (With New Certification) - - $428 - - $7,564 - - $7,921992

11. On-site Audit Travel - - - - - - - - - 12. Desk Audits4

Uncertified to Standard - - $158,134 - - $87,916 - - $246,049 ULEF to Standard - - $6,280 - - $65,080 - - $71,360NAF (With New Certification) - - -$6,280 - - -$65,080 - - -$71,360

13. Purchase of Small Chamber Testing Unit - - - - - - - - - 14. Quality Control Testing4
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 69 of 118 

Exhibit 6-20: Incremental Second and Third Year Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign Total 

Clerical Technic al Managerial Clerical Techni cal Managerial Clerical Technical Managerial 

Standard Certification - - 

$10,686,874278,6

94

- - $9,944,7305,714

,509

- - $20,631,60315,9

93,203

New NAF Certification - - - - - - - - - 

15. Lost Product - - - - - - - - - 16. Initial Recordkeeping5 - - - - - - - - - 17. Recurring Recordkeeping 

Producers4

$1,372,9

66 - - 

$4,189,4

03 - - 

$5,562,36

9 - - 

Fabricators with costs - Employers6

$28,106,

957 - - 

$10,953,

446 - - 

$39,060,4

03 - - 

Fabricators with costs - Nonemployers6 $546,952 - - $213,301 - - $760,253 - - 

Fabricators without costs - - - - - - - - - Wholesalers with costs - Employers5

$13,157,

953 - - 

$18,327,

504 - - 

$31,485,4

57 - - 

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 -

$11,221,29010,8

02,477

$34,217,

389 - $10,473,1516,18 8,483 $77,785,240 - $21,694,36816,9 90,958

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 70 of 118 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 71 of 118 

Exhibit 6-21: Three Year Average Incremental Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign Total 

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial 

1. Rule Familiarization 

Producers1 - - $36,285309 - - $110,768793 - - $147,053102Fabricators1

- - $7,820,515

821,325

- - $3,049,98405

0,278

- - $10,870,49987

1,603

Wholesalers2

- - $10,641,49

7642,523

- - 

$4,150,099534 - - $14,791,59679 3,057

Retailers3

- - $71,555,90

4563,045

- - - - - $71,555,90456

3,045

2. Certification Fee - - - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - $7,778802 - - $72,716692 - - $80,494 Without Existing Certifications - - $54,804 - - $69,433457 - - $124,238262

4. Develop Quality Control Manual4 - - $274,022 - - $347,238285 - - $621,2603085. Qualifying Test - - - - - - - - - 6. Qualifying Test Shipment4

1-Product by TPC 

- - $14371 - - $1,499761 - - $1,641833

2-Product by TPC 

- - 

$3,425 

- - 

$4,353 

- - 

$7,778 

7. Correlation Test4

1-Product by TPC 

- - $2,6401,189 - - $30,68515,22

3

- - $33,32516,413

2-Product by TPC 

- - $137,011 - - $173,619643 - - $310,630654

8. Quarterly On-site Audit4

Uncertified to Standard 

- - $289,936912 - - $161,202178 - - $451,067091

ULEF to Standard - - $9,420 - - $97,620 - - $107,040NAF (With New Certification) - - $3,1407,327 - - $60,228140,532 - - $63,368147,85

8

9. Large Scale Testing Fee 

- - - - - - - - - 

10. Large Scale Testing Shipment4
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 72 of 118 

Exhibit 6-21: Three Year Average Incremental Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign Total 

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial 

Uncertified to Standard 

- - $36,251 - - $20,124147 - - $56,374398

ULEF to Standard - - $1,213 - - $12,203 - - $13,416NAF (With New Certification) - - $428 - - $7,564 - - $7,921992

11. On-site Audit Travel - - 

- 

- - 

- 

- - 

- 

12. Desk Audits4

Uncertified to Standard 

- - $158,134 - - $87,916 - - $246,049 

ULEF to Standard - - $6,280 - - $65,080 - - $71,360NAF (With New Certification) - - $500523 - - $10,062038 - - $10,561 

13. Purchase of Small Chamber Testing Unit 

- - - - - - - - - 

14. Quality Control Testing4

Standard Certification 

- - $10,686,87

4278,694 - - $9,944,7305, 714,509 - - $20,631,6031 5,993,203

New NAF Certification 

- - $52,59234,0

15

- - $853,466652,

468

- - $906,058686,4

83

15. Lost Product - - - - - - - - - 16. Initial Recordkeeping5

$4,318,1245

59

- - 

$6,014,46

6015,070

- - 

$10,332,59

0333,629

- - 

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 

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

Page 73 of 118 

Exhibit 6-21: Three Year Average Incremental Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Domestic Foreign Total 

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial 

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

846,118

- - 

$1,106,0421

30

- - 

$3,951,850

952,249

- 

Major Changes - Producers6

$229,32335

6

- - $89,424 - - $318,74778

0

- - 

Major Changes - Fabricators and Wholesalers7

- 

$24,000,80

3003,194 - - 

$9,360,714

361,629

- - 

$33,361,47

4364,823 - 

Total - Three Year Average $48,119,94

4120,412

$26,846,65

6849,312

$101,778,79

2346,810

$40,372,00

2606

$10,466,75

6467,759

$19,330,589

14,789,371

$88,491,92

1492,993

$37,313,32

4317,072

$121,109,235

116,136,184

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 74 of 118 

1129 Non-Labor Costs 

1130 

1131 This subsection presents the non-labor costs associated with the recordkeeping and 

1132 reporting requirements of the proposed TSCA Title VI rule. The different categories of 

1133 respondents (composite panel producers, fabricators, wholesalers, and retailers) are presented 

1134 separately because they engage indifferent activities. There are no activities that are common to 

1135 all respondents. Exhibit 6-23 through Exhibit 6-25 summarizes the number of respondents, per1136 respondent and total non-labor costs for each response activity over the next three years. Exhibit 

1137 6-26 through Exhibit 6-28 present the corresponding incremental costs. 

1138 

1139 (A). Composite Panel Producers

1140 

1141 Composite panel producers will incur non-labor costs from testing and certification 

1142 activities. As stated above, this analysis assumes that product lines that have a standard 

1143 certification or a NAF certificationare certified under the CARB ATCM will not have to submit 

1144 new data or resubmit existing data to their TPC in order to receive the equivalent certification 

1145 under the TSCA Title VI regulations. In addition, this analysis assumes that two percent of 

1146 wood veneer laminated product producers will continue to use added formaldehyde resins and 

1147 thus be classified as hardwood plywood producers. These entities are not certified by CARB and 

1148 so will incur the burdens associated with first time certification by a TPC. 

1149 

1150 Certification Fees (Activity #2) 

1151 

1152 CPA and HPVA charge administrative fees to mills for certifying their products. CPA 

1153 charges a quarterly fee of $1,500 regardless of NAF or ULEF status, which is equivalent to 

1154 $6,000 per year. HPVA charges an annual program fee of $4,500 to $5,500 (depending on 

1155 membership status) to mills that are not NAF or ULEF certified. Mills with ULEF or NAF 

1156 certifications are required to pay the standard annual program fee in the first year and an annual 

1157 fee of $2,700 to $3,700 in all subsequent years. This analysis assumes that the annual 

1158 certification fee for mills with standard certification is $6,000, the fees for uncertified or 

1159 standard-certified mills with new NAF certifications are $6,000 in the first year and $3,700 in all 

1160 subsequent years, and the annual certification fee for mills with a current NAF or ULEF 

certification is $3,700.,23 1161 

1162 

Exhibit 6-22: Certification Fees

Cost Category Certification Type Fee 

Initial Fee All $6,000 

Annual Fee Standard $6,000 

NAF/ULEF $3,700 

1163 

1164 Qualifying Test (Activity #5) 

1165 

1166 Under TSCA Title VI, a composite panel producer is required to obtain five qualifying 

1167 tests for each product type (e.g., hardwood plywood – veneer core) and production line from the 

 23 ULEF and NAF certifications apply to product lines, and not necessarily to the entire facility. Mills with multiple product 

lines could have one or more lines certified as ULEF or NAF and other lines that are not. The ULEF and NAF testing costs do 

not apply to any product lines that are not ULEF or NAF certified. 
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1168 mill for which certification is sought. This ICR assumes that all qualifying testing is performed 

1169 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.24 1170 This 

1171 analysis assumes that mills making product lines that have a standard certification or a NAF 

1172 certification under the CARB ATCM will not need to submit new data or resubmit existing data 

1173 to their existing TPC in order to receive the equivalent certification under the TSCA Title VI 

1174 regulations. Thus, producers that are already CARB compliant and are not expected to adopt a 

1175 more stringent certification type (e.g., NAF certification) will not incur this burden. 

1176 

1177 Qualifying Test Shipping (Activity #6) 

1178 

1179 Mills are expected to ship at least five 4’ x 8’ panels for each product type via a 

1180 commercial shipping carrier. Panels must be dead-stacked (i.e., having no layers between 

1181 panels), bundled air-tight, wrapped in polyethylene, and protected by cover sheets. Based on 

1182 conversations with CPA and with CARB-certified mills, the total shipping cost for the qualifying 

1183 tests is estimated to be approximately $200 per product line. This analysis assumes that mills 

1184 making product lines that have a standard certification or a NAF certificationare certified under 

1185 the CARB ATCM will not need to submit new data or resubmit existing data to their existing 

1186 TPC in order to receive the equivalent certification under the TSCA Title VI regulations. Thus, 

1187 producers that are already CARB compliant and are not expected to adopt a more stringent 

1188 certification type will not incur this burden. 

1189 

1190 Quarterly On-site Audit (Activity #8) 

1191 

1192 The TPC is responsible for conducting on-site visits to certified mills. Before the initial 

1193 certification, the TPC is expected to make at least one trip to the mill to inspect the mill’s quality 

1194 control systems and employees. During the initial visit, the TPC will assist the mill in setting up 

1195 quality control systems, including the small scale testing facility, if applicable, and methods for 

1196 selecting samples. After certification has been granted, the TPC is obligated to perform an on1197 site audit at least once quarterly, unless the mill obtains a ULEF or NAF certification. Audits 

1198 typically do 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.25 1199 

1200 

1201 The cost of the audit is borne by the composite panel producer and has two components: 

1202 audit fees and travel costs. Site audit fees can range from $300 to $450 for initial visits and from 

1203 $400 to $450 for quarterly visits, depending on the TPC. Based on these ranges, this analysis 

1204 assumes that will mills will pay a fee of $450 per visit. 

1205 

1206 As in the burden section, this analysis assumes that producers with new NAF 

1207 certifications will incur the costs associated with one on-site audit (in addition to the initial audit) 

1208 and two desk audits in the first year. The initial on-site audit is assumed to be sufficient for 

1209 producers with existing ULEF or NAF certifications. All ULEF and NAF-certified producers 

1210 will have one on-site audit annually thereafter. 

 24 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. 25 Personal Communication with HPVA 2011
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1211 

1212 Large Scale Testing Fees (Activity #9) 

1213 

1214 As described above, it is assumed that each large scale test costs $480. Mills are 

1215 requiredassumed to perform large scale testing quarterly unless all products are certified as NAF. 

1216 It is assumed that mills with only NAF-certified products will perform large scale testing 

1217 annually. In the first year, mills with added-formaldehyde products will test those products three 

1218 times in addition to the qualifying testing, and mills with NAF products will test those once at 

1219 the end of the qualifying process. Note that some respondents are assumed to have bothdifferent 

1220 certifications for different product lines (i.e., combinations of standard, ULEF and NAF 

1221 certifications.).

1222 

1223 Large Scale Testing Shipping (Activity #10) 

1224 

1225 Mills are expected to ship one 4’ x 8’ panel for each product type via a commercial 

1226 shipping carrier. Panels must be dead-stacked (i.e., having no layers between panels), bundled 

1227 air-tight, wrapped in polyethylene, and protected by cover sheets. Based on conversations with 

1228 CPA and with CARB-certified mills, the total shipping cost for the quarterly tests is estimated to 

1229 be approximately $50 per product line. Note that some respondents are assumed to have 

1230 bothdifferent certifications for different product lines (i.e., combinations of standard, ULEF and 

1231 NAF certifications.).

1232 

1233 On-site Audit Travel (Activity #11) 

1234 

1235 Travel costs can vary depending on the relative location of the mill to the TPC; mills 

1236 within a close proximity may not incur any travel costs, whereas a mill across the country may 

1237 incur travel costs of up to $2,000 per visit. It is assumed that travel is only necessary for the 

1238 annual audits, as other intermediate audits can be performed by contracting inspectors closer to 

1239 the mill. Therefore, this analysis assumes that each annual audit costs $1,500 in travel costs. All 

1240 composite panel producers are assumed to incur this cost. 

1241 

1242 Desk Audits (Activity #12) 

1243 

1244 TPCs may conduct periodic “desk audits,” which are quality control checks performed 

1245 over the phone in which the mill’s small scale testing procedures and data are reviewed. Desk 

1246 audits are assumed to occur monthly, except in months with quarterly on-site audits. Based on 

1247 fees charged by CPA and HPVA, it is assumed that each desk audit costs $250. 

1248 

1249 As in the burden section, this analysis assumes that producers with new NAF 

1250 certifications will incur the costs associated with two desk audits in the first year; none are 

1251 performed in subsequent years. No additional desk audits are assumed to be performed as a 

1252 result of this rule for respondents with existing NAF or ULEF certification. 

1253 

1254 Small Chamber Testing Unit (Activity #13) 

1255 

1256 This analysis assumes that all panel manufacturers that are required to perform routine 
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1257 quality control testing will use their own small chamber testing unit rather than have the TPC 

1258 perform the testing. It is assumed that the unit costs $10,000 to purchase. 

1259 

1260 Quality Control Testing (Activities #14) 

1261 

1262 To maintain certification, a mill must perform small scale quality control testing for each 

1263 certified product type and production line. Mills have the option of constructing an on-site lab 

1264 and having it approved by a TPC, or contracting a certified third-party lab to perform small scale 

1265 quality control testing. According to CPA and HPVA, particleboard and MDF mills already 

1266 have their own on-site labs to test for formaldehyde (because they have to test their products on a 

1267 daily basis under the CARB ATCM), while most smaller hardwood plywood mills pay their TPC 

1268 to conduct their quality control testing. (In part because hardwood plywood mills often use 

1269 ULEF or NAF resins to qualify for exemptions from some of the on-going testing requirements 

1270 under the CARB ATCM.) However, the CARB ATCM allows mills to ship panels from 

1271 certified product lines before test results are available. By contrast, the proposed TSCA rule 

1272 requires mills to wait until test results indicate that the emissions standards have been met before 

1273 shipping a lot that has been tested. It is uncertain how often mills currently ship product from a 

1274 lot being tested before the test results are available and therefore it is uncertain how mills will 

1275 choose to comply with this requirement. It may be the case that some mills normally maintain a 

1276 level of inventory where they would typically not ship any panels before test results have been 

1277 determined for that lot, but other mills may ship out panels on the same day they are produced. 

1278 This analysis assumes that all mills that do not already do so will opt to set up and operate a 

1279 quality control testing facility on-site, in order to minimize the time spent waiting for test results, 

1280 and to maximize their flexibility to ship out panels shortly after they have been produced. 

1281 (Assuming that mills conduct on-site testing may overstate the costs of this requirement if some 

1282 mills find it more cost effective to hold products in inventory until test results have been 

1283 determined by an outside lab. Producers that are already CARB compliant and are not expected 

1284 to adopt a more stringent certification type will not need to perform correlation testing. 

1285 

1286 HPVA typically uses a desiccator test for small scale testing, but small chamber tests may 

1287 also be performed. Each instance of desiccator testing requires three small samples to be cut 

1288 from a larger panel and tested. It is assumed that mills will incur fees of $70 per desiccator test 

1289 and $405 per small chamber test. The mean cost, weighted by the number of tests needed (three 

1290 for desiccator testing), is $154. 

1291 

1292 Lost Product (Activity #15) 

1293 

1294 Mills will need to forfeit a number of panels for initial and on-going testing. Mills are 

1295 expected to ship five 4’ x 8’ panels per product type for qualifying testing. Producers will lose 

1296 one panel per product type for each day forthat quality control testing. is performed. In addition 

1297 to routine small scale testing, standard certification and ULEF mills are requiredassumed to send 

1298 one panel per product type to the TPC for large scale testing each quarter. However, product 

1299 lines that are certified as NAF are exempt from routine quality control testing after the three 

1300 month qualifying period, and need only have large scale testing performed annually. Note that 

1301 the total respondents with lost product costs presented in the exhibits below sum to more than the 

1302 total number of respondents because some respondents are assumed to have both different 
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1303 certifications for different product lines (i.e., combinations of standard, ULEF and NAF 

1304 certifications.).

1305 

1306 This analysis estimated the cost of each panel using the average cost per square foot of 

1307 hardwood plywood, $0.49 and particleboard, $0.28 (RISI 2010). Assuming a panel size of 32 sq. 

1308 ft., each hardwood plywood panel will cost the mill $15.68, and each particleboard panel will 

1309 cost $8.96. 

1310 

1311 (B). Fabricators

1312 

1313 Fabricators are subject to the proposed rule’s recordkeeping and labeling requirements. 

1314 However, not all fabricators incur the non-labor costs associated with proposed rule because 1) 

1315 they may already complying with the CARB ATCM (Exhibit 6-6) or 2) their existing systems 

1316 are sufficient to meet the requirements. As stated above, this analysis assumes that 98 percent of 

1317 wood veneer laminated product producers will likely switch to NAF resins and be classified as 

1318 fabricators. It is assumed that the entirety of this subset of fabricators will incur the non-labor 

1319 costs associated with supplier notification. 

1320 

1321 As described in the Economic Analysis for the rulemaking, one respondent to the 

1322 fabricator questionnaire reported that that they would incur a one-time cost of $250 for 

1323 purchasing new stamps for labeling. To remain consistent with the labor section, this cost was 

1324 averaged across the two firms that reported more significant costs. As a result, this analysis 

1325 assumes that the 33 percent of fabricators that are not CARB compliant in the baseline will incur 

1326 an initial non-labor cost of approximately $125.00 ($250/2) associated with the labeling 

1327 requirements. There are not expected to be any non-labor costs associated with recordkeeping 

1328 for fabricators. 

1329 

1330 (C). Wholesalers

1331 

1332 Wholesalers are subject to the proposed rule’s recordkeeping and labeling requirements. 

1333 This analysis assumes that 1 percent of wholesalers will repackage their products and so will 

1334 incur an initial non-labor labeling cost. It is assumed that these wholesalers incur the same costs 

1335 as the fabricators described above (an average of $125.00). In addition, not all wholesalers will 

1336 incur the non-labor costs associated with recordkeeping because 1) they are already complying 

1337 with the CARB ATCM (Exhibit 6-7), 2) their existing systems are sufficient to meet the 

1338 requirements, or 3) they do not import composite wood products or articles that contain 

1339 composite wood products and so are only required to keep ordinary business records. 

1340 

1341 As described in the Economic Analysis for the rulemaking, only one respondent to the 

1342 wholesaler questionnaire reported that they incurred non-labor costs (a one-time cost of $2,000 

1343 for programming changes). The average non-labor cost is calculated for firms reporting 

1344 quantified costs. As a result, this analysis assumes that the 57 percent of wholesalers that import 

1345 composite wood products and/or articles that contain composite wood products will incur an 

1346 initial non-labor cost of approximately $1,000 ($2,000/2) associated with the recordkeeping 

1347 requirements (since one of two firms reporting costs reported a non-labor cost of $2,000). As 

1348 indicated above, this analysis assumes that 28 percent of domestic wholesalers import composite 
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1349 wood products and/or articles that contain composite wood products. There are not expected to 

1350 be any non-labor costs associated with recurring recordkeeping costs. 

1351 

1352 (D). Retailers

1353 

1354 As stated above, retailer’s customary business practices are assumed to be generally 

sufficient to meet the proposed rule’s recordkeeping requirements.26 1355 In addition, retailers are 

1356 assumed not to repackage goods made with composite wood products, and thus do not incur 

1357 costs to modify labeling systems to comply with the proposed rule.

1358 

1359 (E). Summary

1360 

1361 Exhibit 6-23 and Exhibit 6-24 summarize the total (including baseline) per-activity non1362 labor costs for all the respondents over the first year, and second and third years of the rule, 

1363 respectively. Exhibit 6-25 presents the average non-labor costs over the first three years of the 

1364 rule, respectively. Exhibit 6-26 through Exhibit 6-28 mirror the previous three tables, except that 

1365 they account for incremental non-labor costs (excluding baseline non-labor costs). Note that the 

1366 number of respondents cannot be summed across activities because many respondents are 

1367 incurring multiple burdens. As indicated, the average total annual non-labor cost (including 

1368 baseline) over the first three years of the rule is estimated at approximately $37.335 million, 

1369 while the incremental non-labor costs are $25.624 million. The domestic non-labor costs 

1370 account for approximately 34.536 percent ($12.913 million) and 46.349 percent ($11.912

1371 million) of these totals, respectively. 

 26 Personal Communication with California Retailers Association 2011). 
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Exhibit 6-23: 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 

Total Cost 

Domestic Foreign1 Total Domestic Foreign Total 

1. Rule Familiarization - - - - - - - -2. Certification Fee2

Standard3 339328 713599 1,052927 1 $6,000 $2,0341,968,000 $4,2783,594,000 $6,3125,562

0

NAF (From Uncertified or Standard) 11 211 222 1 $6,000 $66,000 $1,266,000 $1,332,00NAF/ULEF (From NAF or NAF/ULEF) 2031 205319 225350 1 $3,700 $74,000114,700 $758,5001,180,300 

$832,5001,295

0

3. Initial On-site Audit 

With Existing Certifications 82 764 846 1 $450 $36,900 $343,800 $380,70Without Existing Certifications3,4 288 365 653 1 $450 $129,600 $164,250 $293,85

4. Develop Quality Control Manual - - - - - - - -5. Qualifying Test5

1 Product 115 12964 14069 5 $480 $26,40012,000 $309153,600 $336,000165,62 Products3,4 288 365 653 10 $480 $1,382,400 $1,752,000 $3,134,40

6. Qualifying Test Shipping5

1 Product 115 12964 14069 1 $200 $2,2001,000 $2512,800 $28,00013,802 Products3,4 288 365 653 2 $200 $115,200 $146,000 $261,20

7. Correlation Test - - - - - - - -8. Quarterly On-site Audit6

Standard3,4 339328 713599 1,052927 3 $450 $457,650442,800 $962,550808,650 $1,420,200251

5

NAF (With New Certification) 1711 276211 293222 1 $450 $7,6504,950 $124,20094,950 $131,85099,90NAF (With Existing Certification) 14 140 154 - $450 - - -

9. Large Scale Testing Fee7

1 Standard (Existing) 8 86 94 4 $480 $15,360 $165,120 $180,482 Standard (New)3,4 277 154 431 6 $480 $797,760 $443,520 $1,241,282 Standard/ULEF (Existing) 54 473 527 8 $480 $207,360 $1,816,320 $2,023,681 NAF 3 22 25 1 $480 $1,440 $10,560 $12,002 NAF 3125 416351 447376 2 $480 $29,76024,000 $399,360336,960 $429,120360,9

1 NAF and 1 ULEF 6 65 71 5 480 $14,400 $156,000 $170,40

10. Large Scale Testing Shipment7

1 Standard (Existing) 8 86 94 4 $50 $1,600 $17,200 $18,802 Standard (New)3,4 277 154 431 6 $50 $83,100 $46,200 $129,302 Standard (Existing) 54 473 527 8 $50 $21,600 $189,200 $210,80
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Exhibit 6-23: 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 

Total Cost 

Domestic Foreign1 Total Domestic Foreign Total 

1 NAF 3 22 25 1 $50 $150 $1,100 $1,252 NAF 3125 416351 447376 2 $50 $3,1002,500 $41,60035,100 $44,70037,60

1 NAF and 1 ULEF 6 65 71 5 $50 $1,500 $16,250 $17,75

11. On-site Audit Travel 370 1,129 1,499 1 $1,500 $555,000 $1,693,500 $2,248,5012. Desk Audits8

Standard3,4 339328 713599 1,052927 8 $250 $678656,000 $1,426198,000 $2,1041,854,00NAF 1711 276211 293222 2 $250 $85,500 $138,000105,500 $146,500111,0

13. Purchase of Small Chamber Testing Unit3 295282 350208 645490 1 $10,000 $2,950820,000 $3,5002,080,000 $6,4504,900,0014. Quality Control Testing - - - - - - - -15. Lost Product7

2 Standard (HWPW - Existing)3,4 29510 304109 599119 528 $15.68 $2,442,31782,790 

$2,516,828902,41

5 

$4,959,145985

0

1 NAF (HWPW - New) 5277 55108 60385 71536 $15.68 $5,5662,328,041 $61,230907,684 $66,7973,235,71 NAF (HWPW - Existing) 58 5587 6095 18 $15.68 $781,004 $86210,913 $94111,912 NAF (HWPW - New) 5 55 60 5 $15.68 $392 $4,312 $4,702 NAF (HWPW - NewExisting) 11 211 222 142 $15.68 $24,492 $469,804 $494,292 NAF (HWPW1 Standard (PB/MDF - Existing) 

7 76 83 2 $15.68 $220 $2,383 $2,60

1 Standard (PB/MDF - Existing) 8 86 94 264 $8.96 $18,924 $203,428 $222,35

2 Standard (PB/MDF - New) -3 4622 4625 536265 $8.96 -$7,123 $220,91852,237 $220,91859,362 Standard (PB/MDF - Existing) 365 277110 313115 528532 $8.96 $170,31223,834 $1,310,454524,339 

$1,480,765548

7

1 NAF (PB/MDF - New) 133 10250 11283 71528 $8.96 $636156,119 $6,3621,182,720 $6,9981,338,831 NAF (PB/MDF - Existing) 

43 3227 3630 18 $8.96 $36215 $2871,935 $3232,15

2 NAF (PB/MDF - Existing) 7 64 71 2 $8.96 $125 $1,147 $1,271 NAF and 1 ULEF (PB/MDF -Existing) 1 10 11 5 $8.96 $45 $448 $49
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Exhibit 6-23: 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 

Total Cost 

Domestic Foreign1 Total Domestic Foreign Total 

16. Initial Recordkeeping9 8,576 11,945 20,521 1 $1,000 $8,576,000 $11,945,000 $20,521,0017. Recurring Recordkeeping - - - - - - - -18. Initial Labeling10

Minor Changes - Producers - - - - - - - -Minor Changes - Fabricators - - - - - - - -Major Changes – Producers3 277 108 385 1 $125 $34,625 $13,500 $48,12Major Changes - Fabricators and Wholesalers11 16,266 6,344 22,610 1 $125 $2,033,250 $793,000 $2,826,25

Total - Year 1 

$22,991,311749,

095 

$37,563,58334,63

8,718 

$60,554,89457

87,81

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 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 estimates the number of certified foreign mills as 20 percent of the total number of certified mills. 2. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by a TPC as a result of the TSCA Title VI rule. 3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined as 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 certified, which are assumed to 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 qualifying or correlation testing because iis assumed that their previous testing is sufficient. 6. On-site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. 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) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the initial on-site audit in the first year. All producers with ULEF or 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 bothmore than one certification type (i.e., standard, ULEF, and NAF certifications.).8. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with two desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or 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 hardwood plywood producers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meets the emissions standardsHowever, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying with the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule. 10. Firms Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include thename, the date the finished good was produced, and a statement of compliance. Retailers are not required to modify their labeling system to comply with the proposed rule assuming they do not modify the packaging of the products they purchase. This analysis assumes that all 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are not sold in California) will incua non-labor cost of $125.00 for purchasing stamps for labeling. Producers and wholesalers are not expected to incur any non-labor costs from initial labeling. 11. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.
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Exhibit 6-24: Total (including baseline) Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

Total Cost 

Domestic Foreign1 Total Domestic Foreign Total 

1. Rule Familiarization - - - - - - - - 2. Certification Fee2

Standard3 339328 713599 1,052927 1 $6,000 $2,0341,968, 000 

$4,2783,594,00

0 

$6,3125,562,0

00 

NAF (From Uncertified or Standard) 11 211 222 1 $3,700 $40,700 $780,700 $821,400 NAF/ULEF (From NAF or NAF/ULEF) 2031 205319 225350 1 $3,700 $74,000114, 700 

$758,5001,180,

300 

$832,5001,29

5,000 

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 339328 713599 1,052927 4 $450 $610,200590 ,400 $1,283,400078, 200 $1,893668,600 NAF (With New Certification) 1711 276211 293222 1 $450 $7,6504,950 $124,20094,950 

$131,85099,9

00 

NAF (With Existing Certification) 14 140 154 1 $450 $6,300 $63,000 $69,300

9. Large Scale Testing Fee7

1 Standard (Existing) 8 86 94 4 $480 $15,360 $165,120 $180,480 2 Standard (New)3,4 277 154 431 6 $480 $797,760 $443,520 $1,241,280 2 Standard/ULEF (Existing) 54 473 527 8 $480 $207,360 $1,816,320 $2,023,680 1 NAF 3 22 25 1 $480 $1,440 $10,560 $12,000 2 NAF 3125 416351 447376 2 $480 $29,76024,000 

$399,360336,9

60 

$429,120360,

960 

1 NAF and 1 ULEF 6 65 71 5 $480 $14,400 $156,000 $170,400 

10. Large Scale Testing Shipment7

1 Standard (Existing) 8 86 94 4 $50 $1,600 $17,200 $18,800 2 Standard (New)3,4 277 154 431 6 $50 $83,100 $46,200 $129,300 2 Standard (Existing) 54 473 527 8 $50 $21,600 $189,200 $210,800 1 NAF 3 22 25 1 $50 $150 $1,100 $1,250 2 NAF 3125 416351 447376 2 $50 $3,1002,500 $41,60035,100 $44,70037,60
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 84 of 118 

Exhibit 6-24: Total (including baseline) Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

Total Cost 

Domestic Foreign1 Total Domestic Foreign Total 

0 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 85 of 118 

Exhibit 6-24: Total (including baseline) Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

Total Cost 

Domestic Foreign1 Total Domestic Foreign Total 

1 NAF and 1 ULEF 6 65 71 5 $50 $1,500 $16,250 $17,750 

11. On-site Audit Travel 370 1,129 1,499 1 $1,500 $555,000 $1,693,500 $2,248,500 12. Desk Audits8

Standard3,4 339328 713599 1,052927 8 $250 $678656,000 $1,426198,000 $2,1041,854,000 NAF - - - - - - - - 

13. Purchase of Small Chamber Testing Unit3 - - - - - - - - 14. Quality Control Testing - - - - - - - - 15. Lost Product7

2 Standard (HWPW - Existing)3,4 29510 304109 599119 528 $15.68 $2,442,3178 2,790 

$2,516,828902,

415 

$4,959,14598

5,206 

1 NAF (HWPW - New) 5277 55108 60385 1528 $15.68 $782,293,294 $862894,136 $9413,187,430 1 NAF (HWPW - Existing) 58 5587 6095 18 $15.68 $781,004 $86210,913 $94111,917 2 NAF (HWPW - New) 5 55 60 5 $15.68 $392 $4,312 $4,704 2 NAF (HWPW - NewExisting) 11 211 222 2 $15.68 $345 $6,617 $6,962 2 NAF (HWPW1 Standard (PB/MDF - Existing) 7 76 83 2 $15.68 $220 $2,383 $2,603 1 Standard (PB/MDF - Existing) 8 86 94 264 $8.96 $18,924 $203,428 $222,3512 Standard (PB/MDF - New) -3 4622 4625 536265 $8.96 -$7,123 $220,91852,237 

$220,91859,3

60 

2 Standard (PB/MDF - Existing) 365 277110 313115 528 $8.96 $170,31223, 654 

$1,310,454520,

397 

$1,480,76554

4,051 

1 NAF (PB/MDF - New) 133 10250 11283 1528 $8.96 $9156,119 $901,182,720 $991,338,839 1 NAF (PB/MDF - Existing) 

43 3227 3630 18 $8.96 $36215 $2871,935 $3232,150 

2 NAF (PB/MDF - Existing) 7 64 71 2 $8.96 $125 $1,147 $1,272 1 NAF and 1 ULEF (PB/MDF - Existing) 1 10 11 5 $8.96 $45 $448 $493 

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 

$7,799,5246

65,846 

$17,801,35616,

432,841 

$25,600,8802

4,098,688 

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 foreign retailers do not typically export 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 86 of 118 

Exhibit 6-24: Total (including baseline) Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

Total Cost 

Domestic Foreign1 Total Domestic Foreign Total 

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 estimates the number of certified foreign mills as 20 percent of the total number of certified mills. 2. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by a TPC as a result of the TSCA Title VI rule. 3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined as 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 certified, which are assumed to 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 qualifying or correlation testing 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 ULEF or NAF certification. 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) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the initial on-site audit in the first year. All producers with ULEF or 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 bothmore than one certification type (i.e., standard, ULEF, and NAF certifications.).8. Desk audits for standard certifications 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 desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or 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 hardwood plywood producers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meets the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying with the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule. 10. Firms Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their name, the date the finished good was produced, and a statement of compliance. Retailers are not required to modify their labeling system to comply with the proposed rule assuming they do not modify the packaging of the products they purchase. This analysis assumes that all 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are not sold in California) will incur a non-labor cost of $125.00 for purchasing stamps for labeling. Producers and wholesalers are not expected to incur any non-labor costs from initial labeling. 11. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 87 of 118 

Exhibit 6-25: Three Year Average Non-Labor Costs (including baseline), by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

Total Cost 

Domestic Foreign1 Total Domestic Foreign Total 

1. Rule Familiarization - - - - - - - - 2. Certification Fee2

Standard3 339328 713599 1,052927 1.0000 $6,000.00 $2,0341,968, 000 

$4,2783,594,

000 

$6,3125,562,

000 

NAF (From Uncertified or Standard) 

11 211 222 1.0000 $4,466.676,

000 $49,133 $942,467 $991,601600 

NAF/ULEF (From NAF or NAF/ULEF) 2031 205319 225350 1.0000 $3,700.00 $74,000114,700 

$758,5001,18

0,300 

$832,5001,2

95,000 

3. Initial On-site Audit 

With Existing Certifications 82 764 846 0.3333 $450.00 $12,299300 $114,589600 $126,887900 Without Existing Certifications3,4 288 365 653 0.3333 $450.00 $43,196200 $54,745750 $97,940950 

4. Develop Quality Control Manual - - - - - - - - 5. Qualifying Test5

1 Product 115 12964 14069 1.6667 $480.00 $8,8004,000 $103,20251,200 

$112,00255,

200 

2 Products3,4 288 365 653 3.3333 $480.00 $460,795800 $583,994584, 000 $1,044,790800 

6. Qualifying Test Shipping5

1 Product 115 12964 14069 0.3333 $200.00 $733333 $8,5994,267 $9,3324,600 2 Products3,4 288 365 653 0.6667 $200.00 $38,402400 $48,669667 $87,071067 

7. Correlation Test - - - - - - - - 8. Quarterly On-site Audit6

Standard3,4 339328 713599 1,052927 3.6667 $450.00 $559,355541, 200 

$1,176,46198

8,350 

$1,735,8165

29,550 

NAF (With New Certification) 1711 276211 293222 1.0000 $450.00 $7,6504,950 $124,20094,950 

$131,85099,

900 

NAF (With Existing Certification) 14 140 154 0.6667 $450.00 $4,200 $42,002 $46,202

9. Large Scale Testing Fee7

1 Standard (Existing) 8 86 94 4.0000 $480.00 $15,360 $165,120 $180,480 2 Standard (New)3,4 277 154 431 6.0000 $480.00 $797,760 $443,520 $1,241,280 2 Standard/ULEF (Existing) 54 473 527 8.0000 $480.00 $207,360 $1,816,320 $2,023,680 1 NAF 3 22 25 1.0000 $480.00 $1,440 $10,560 $12,000 2 NAF 3125 416351 447376 2.0000 $480.00 $29,76024,000 

$399,360336,

960 

$429,120360

,960 

1 NAF and 1 ULEF 6 65 71 5.0000 $480 $14,400 $156,000 $170,400 

10. Large Scale Testing Shipment7

1 Standard (Existing) 8 86 94 4.0000 $50.00 $1,600 $17,200 $18,800 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 88 of 118 

Exhibit 6-25: Three Year Average Non-Labor Costs (including baseline), by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

Total Cost 

Domestic Foreign1 Total Domestic Foreign Total 

2 Standard (New)3,4 277 154 431 6.0000 $50.00 $83,100 $46,200 $129,300 2 Standard (Existing) 54 473 527 8.0000 $50.00 $21,600 $189,200 $210,800 1 NAF 3 22 25 1.0000 $50.00 $150 $1,100 $1,250 2 NAF 3125 416351 447376 2.0000 $50.00 $3,1002,500 

$41,60035,

100 

$44,70037

,600 

1 NAF and 1 ULEF 6 65 71 5.0000 $50 $1,500 $16,250 $17,750 

11. On-site Audit Travel 370 1,129 1,499 1.0000 $1,500.00 $555,000 $1,693,500 $2,248,500 12. Desk Audits8

Standard3,4 339328 713599 1,052927 8.0000 $250.00 $678656,000 $1,426198,000 

$2,1041,854,

000 

NAF 1711 276211 293222 0.6667 $250.00 $21,833 $46,00235,167 

$48,83637,0

00 

13. Purchase of Small Chamber Testing Unit3 295282 350208 645490 0.3333 $10,000.00 $983,235940, 000 

$1,166,55069

3,333 

$2,149,7851,

633,333 

14. Quality Control Testing - - - - - - - - 15. Lost Product7

2 Standard (HWPW - Existing)3,4 29510 304109 599119 528.0000 $15.68 $2,442,31782 ,790 

$2,516,82890

2,415 

$4,959,1459

85,206 

1 NAF (HWPW - New) 5277 55108 60385 24.3333530. 6667 $15.68 $1,9082,304, 876 

$20,985898,6

52 

$22,8933,20

3,529 

1 NAF (HWPW - Existing) 58 5587 6095 18.0000 $15.68 $781,004 $86210,913 $94111,917 2 NAF (HWPW - New) 5 55 60 5.0000 $15.68 $392 $4,312 $4,704 2 NAF (HWPW - NewExisting) 11 211 222 48.6667 $15.68 $8,394 $161,013 $169,407 2 NAF (HWPW1 Standard (PB/MDF - Existing) 7 76 83 2.0000 $15.68 $220 $2,383 $2,603 12 Standard (PB/MDF - ExistingNew) 83 8622 9425 264265.0000 $8.96 $18,9247,123 $203,42852,237 

$222,35159,

360 

2 Standard (PB/MDF - NewExisting) -5 46110 46115 536.000052 9.3333 $8.96 -$23,714 $220,918521, 711 

$220,918545

,425 

2 Standard1 NAF (PB/MDF - ExistingNew) 3633 277250 313283 528.0000 $8.96 $170,312156, 119 $1,310,45418 2,720 $1,480,7653 38,839 1 NAF (PB/MDF - NewExisting) 13 1027 1130 24.33338.0000 $8.96 $218215 $2,1801,935 $2,398150 12 NAF (PB/MDF - Existing) 

47 3264 3671 12.0000 $8.96 $36125 $2871,147 $3231,272 

21 NAF and 1 ULEF (PB/MDF - Existing) 71 6410 7111 25.0000 $8.96 $12545 $1,147448 $1,272493 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 89 of 118 

Exhibit 6-25: Three Year Average Non-Labor Costs (including baseline), by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Number of 

Activities Per 

Respondent 

Cost Per 

Response 

Total Cost 

Domestic Foreign1 Total Domestic Foreign Total 

16. Initial Recordkeeping9 8,576 11,945 20,521 0.3333 $1,000.00

$2,858,38166

7 

$3,981,26966

7 

$6,839,6498

40,333 

17. Recurring Recordkeeping - - - - - - - - 18. Initial Labeling10

Minor Changes - Producers - - - - - - - - Minor Changes - Fabricators - - - - - - - - Major Changes – Producers3 277 108 385 0.3333 $125.00 $11,541542 $4,500 $16,040042 Major Changes - Fabricators and Wholesalers11 16,266 6,344 22,610 0.3333 $125.00

$677,68275

0 

$264,30733

3 

$941,9899

42,083 

Three-Year Average Cost 

$12,862,9976

93,595 

$24,388,2212

2,501,467 

$37,251,216

35,195,063 

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 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 estimates the number of certified foreign mills as 20 percent of the total number of certified mills. 2. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by a TPC as a result of the TSCA Title VI rule. 3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined as 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 certified, which are assumed to 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 qualifying or correlation testing 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 ULEF or NAF certification. 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) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the initial on-site audit in the first year. All producers with ULEF or 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 bothmore than one certification type (i.e., standard, ULEF, and NAF certifications.).8. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with two desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or 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 hardwood plywood producers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meets the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying with the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule. 10. Firms Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their name, the date the finished good was produced, and a statement of compliance. Retailers are not required to modify their labeling system to comply with the proposed rule assuming they do not modify the packaging of the products they purchase. This analysis assumes that all 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are not sold in California) will incur a non-labor cost of $125.00 for purchasing stamps for labeling. Producers and wholesalers are not expected to incur any non-labor costs from initial labeling. 11. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 90 of 118 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 91 of 118 

Exhibit 6-26: Incremental First Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of 

Respondents 

Number 

of 

Activitie

s Per 

Respon

dent 

Cost 

Per 

Activi

ty 

Total Cost 

Dom

estic 

Forei

gn1

Tota

l 

Domes

tic 

Foreig

n 

Total 

1. Rule Familiarization - - - - - - - - 2. Certification Fee2

Uncertified to Standard3,4 277 154 431 1 

$6,00

0 

$1,662,

000 

$924,0

00 

$2,586,

000 

ULEF to Standard 11 114 125 1

$2,30

0

$25,30

0

$262,2

00

$287,50

0

NAF (With New Certification) 11 211 222 1 

$6,00

0 

$66,00

0 

$1,266,

000 

$1,332,

000 

3. Initial On-site Audit 

With Existing Certifications 82 764 846 - $450 - - -Without Existing Certifications3,4 288 365 653 1 $450 

$129,6

00 

$164,2

50 

$293,85

0 

4. Develop Quality Control Manual - - - - - - - - 5. Qualifying Test5

1 Product 

115 12964 14069 5 $480 

$26,40012,00

0 

$30915

3,600 

$336,000165,60

0 

2 Products3,4 288 365 653 10 $480 

$1,382,

400 

$1,752,

000 

$3,134,

400 

6. Qualifying Test Shipping5

1 Product 115 12964 14069 1 $200 $2,200 1,000 

$2512,

800 

$28,000

13,800 

2 Products3,4 288 365 653 2 $200 

$115,2

00 

$146,0

00 

$261,20

0 

7. Correlation Test5 - - - - - - - - 8. Quarterly On-site Audit6

Uncertified to Standard3,4 277 154 431 3 $450 

$373,9

50 

$207,9

00 

$581,85

0 

ULEF to Standard 11 114 125 3 $450

$14,85

0

$153,9

00

$168,75

0

NAF (With New Certification) 11 211 222 1 $450 $4,950 $94,950 $99,900 

9. Large Scale Testing Fee 

1 New Standard 5 64 69 3 $480 $7,200 

$92,16

0 $99,360 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 92 of 118 

Exhibit 6-26: Incremental First Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of 

Respondents 

Number 

of 

Activitie

s Per 

Respon

dent 

Cost 

Per 

Activi

ty 

Total Cost 

Dom

estic 

Forei

gn1

Tota

l 

Domes

tic 

Foreig

n 

Total 

2 New Standard3,4 277 154 431 6 $480 

$797,7

60 

$443,5

20 

$1,241,

280 

2 ULEF to 2 Standard 11 114 125 6 $480 

$31,68

0 

$328,3

20 

$360,00

0 

1 New NAF 6 65 71 1 $480 $2,880 

$31,20

0 $34,080 

2 New NAF 

115 211146 222 151 2 $480 $10,56

04,800 

$202,560140,

160 

$213,120144,96

0 

1 NAF and 1 ULEF 6 65 71 5 $480 $14,400 $156,000 $170,400 

10. Large Scale Testing Shipment 

1 New Standard 5 64 69 3 $50 $750 $9,600 $10,350 2 New Standard3,4 277 154 431 6 $50 

$83,10

0 

$46,20

0 

$129,30

0 

2 ULEF to 2 Standard 11 114 125 6 $50 $3,300 

$34,20

0 $37,500 

1 New NAF 6 65 71 1 $50 $300 $3,250 $3,550 2 New NAF 

115 211146 222 151 2 $50 $1,100 500 

$21,10014,60

0 

$22,200

15,100 

11. On-site Audit Travel1 NAF and 1 ULEF

2886 36565 65371 15 $1,5 0050

$432,0001,50

0 

$547,50016,2

50 

$979,50

017,750 

12. Desk Audits711. On-site Audit Travel 288 365 653 1

$1,50

0

$432,0

00

$547,5

00

$979,50

0

Uncertified to Standard3,412. Desk Audits7

277 154 431 8 $250 $554,0

00

$308,0

00

$862,00

0

ULEFUncertified to StandardStandard3,4

1127

7

1141

54

1254

31 8 $250 

$22554

,000 

$22830

8,000 

$25086

2,000 

NAF (With New Certification) 11 211 222 2 $250 $5,500 

$105,5

00 

$111,00

0 

13. Purchase of Small Chamber Testing Unit2

295

282

350

208

645

490

1 $10,000 $2,950 820,000 

$3,500

2,080,0

00 

$6,4504

,900,00

0 

14. Quality Control Testing - - - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 93 of 118 

Exhibit 6-26: Incremental First Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of 

Respondents 

Number 

of 

Activitie

s Per 

Respon

dent 

Cost 

Per 

Activi

ty 

Total Cost 

Dom

estic 

Forei

gn1

Tota

l 

Domes

tic 

Foreig

n 

Total 

15. Lost Product 

1 New2 Standard - PB/MDF(HWPW – Existing)3,4

510 6410

9

691

19 268416

$8.9

615.6

8

$12,00665,22

9 

$153,682710,

994 

$165,688776,22

3 

2 New Standard - HWPW3(HWPW-New)3,4

277 154

108

431

385

536 $15.68 $2,328, 041 

$1,294,290907

,684 

$3,622,

331235,

725 

2 ULEF to 2 Standard - PB/MDF 3 27 30 528 $8.96

$14,19

3

$127,7

34

$141,92

6

2 ULEF to 2 Standard - HWPW 8 87 95 528

$15.6

8

$66,23

2

$720,2

76

$786,50

9

1 ULEF to 1 NAF - PB/MDF 1 10 11 67 $8.96 $600 $6,003 $6,6041 ULEF to 1 NAF – HWPW 5 55 60 67

$15.6

8 $5,253

$57,78

1 $63,034

2 New NAF – (HWPW-New) 11 211 222 142 $15.68 $24,492 $469,804 $494,296 2 Standard (PB/MDF - New) 5 110 115 268 $8.96 $12,006 $264,141 $276,147 

16. Initial Recordkeeping8 8,576 

11,94

5 

20,5

21 1 

$1,00

0.00

$8,576,

000 

$11,94

5,000 

$20,521

,000 

17. Recurring Recordkeeping - - - - - - - - 18. Initial Labeling9

Minor Changes - Producers - - - - - - - - Minor Changes - Fabricators - - - - - - - - Major Changes – Producers3 277 108 385 1 

$125.

00

$34,62

5

$13,50

0 $48,125

Major Changes - Fabricators and Wholesalers10

16,26

6 6,344 

22,6

10 1 

$125.

00

$2,033,

250 

$793,0

00 

$2,826,

250 

Total - Year 1 

$21,799,6725

80,413 

$26,788,7802

4,182,0

83 

$48,588

,45345,

762,496 

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 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 estimates the number of certified foreign mills as 20 percent of the total number of certified mills. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 94 of 118 

Exhibit 6-26: Incremental First Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of 

Respondents 

Number 

of 

Activitie

s Per 

Respon

dent 

Cost 

Per 

Activi

ty 

Total Cost 

Dom

estic 

Forei

gn1

Tota

l 

Domes

tic 

Foreig

n 

Total 

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 certified, which are assumed to 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 therefore their products will be defined as 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 their products certified by a 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 qualifying or correlation testing 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 ULEF or NAF certification. 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) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the initial on-site audit in the first year. All producers with ULEF or NAF certification will have one on-site audit annually thereafter. 7. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with two desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or 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 as hardwood plywood producers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meets the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying with the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule. 9. Firms Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their name, the date the finished good was produced, and a statement of compliance. Retailers are not required to modify their labeling system to comply with the proposed rule assuming they do not modify the packaging of the products they purchase. This analysis assumes that all 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are not sold in California) will incur a non-labor cost of $125.00 for purchasing stamps for labeling. Producers and wholesalers are not expected to incur any non-labor costs from initial labeling. 10. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 95 of 118 

Exhibit 6-27: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of 

Respondents 

Number 

of 

Activitie

s Per 

Respond

ent 

Cost 

Per 

Activi

ty 

Total Cost 

Dom

estic 

Forei

gn1

Tota

l 

Domes

tic 

Foreig

n 

Total 

1. Rule Familiarization - - - - - - - - 3. Certification Fee2

Uncertified to Standard3,4 277 154 431 1 

$6,00

0 

$1,662,

000 

$924,0

00 

$2,586,

000 

ULEF to Standard 11 114 125 1

$2,30

0

$25,30

0

$262,2

00

$287,5

00

NAF (With New Certification) 11 211 222 1 

$3,70

0 

$40,70

0 

$780,7

00 

$821,4

00 

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 $277,200 $775,800 ULEF to Standard 11 114 125 3 $450

$14,85

0

$153,9

00

$168,7

50

NAF (With New Certification) 

11 211 222 13 $450 $4,950 14,850 

$94,950284,8

50 

$99,900299,7

00 

10. Large Scale Testing Fee 

1 New Standard 5 64 69 4 $480 $9,600 

$122,8

80 

$132,4

80 

2 New Standard3,4 277 154 431 8 $480 

$1,063,

680 

$591,3

60 

$1,655,

040 

2 ULEF to 2 Standard 11 114 125 6 $480 

$31,68

0 

$328,3

20 

$360,0

00 

1 New NAF 6 65 71 1 $480 $2,880 

$31,20

0 

$34,08

0 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 96 of 118 

Exhibit 6-27: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of 

Respondents 

Number 

of 

Activitie

s Per 

Respond

ent 

Cost 

Per 

Activi

ty 

Total Cost 

Dom

estic 

Forei

gn1

Tota

l 

Domes

tic 

Foreig

n 

Total 

2 New NAF 

115 211 146 222 151 2 $480 $10,56

04,800 

$202,560140,

160 

$213,120144,

960 

1 NAF and 1 ULEF 6 65 71 5 $480 $14,400 $156,000 $170,400 

11. Large Scale Testing Shipment 

1 New Standard 5 64 69 4 $50 $1,000 

$12,80

0 

$13,80

0 

2 New Standard3,4 277 154 431 8 $50 

$110,8

00 

$61,60

0 

$172,4

00 

2 ULEF to 2 Standard 11 114 125 6 $50 $3,300 

$34,20

0 

$37,50

0 

1 New NAF 6 65 71 1 $50 $300 $3,250 $3,550 

2 New NAF 

115 211 146 222 151 2 $50 $1,100 500 

$21,10014,60

0 

$22,20015,10

0 

12. On-site Audit Travel1 NAF and 1 ULEF

2886 36565 65371 15 $1,5 0050

$432,0001,50

0 

$547,50016,2

50 

$979,50017,7

50 

13. Desk Audits712. On-site Audit Travel 288 365 653 1

$1,50

0

$432,0

00

$547,5

00

$979,5

00

Uncertified to Standard3,413. Desk Audits7

277 154 431 8 $250 $554,0

00

$308,0

00

$862,0

00

ULEFUncertified to StandardStandard3,4

1127

7

1141

54

1254

31 8 $250 

$22554

,000 

$2283

08,000 

$25086

2,000 

NAF (With New Certification) - - - - - - - - 

14. Purchase of Small Chamber Testing Unit - - - - - - - - 15. Quality Control Testing - - - - - - - - 16. Lost Product 

1 New2 Standard - PB/MDF(HWPW – Existing)3,4 510 6410

9

691

19 264416 $8.9

616

$11,82765,22

9 

$151,388710,

994 

$163,215776,

223 

2 New Standard - HWPW3(HWPW-New)3,4

277 154

108

431

385

528 $15. 6816 $2,293, 294 

$1,274,97289

4,136 

$3,568,266187

,430 

2 ULEF to 2 Standard - PB/MDF 3 27 30 520 $8.96 $13,97 $125,7 $139,7
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 97 of 118 

Exhibit 6-27: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of 

Respondents 

Number 

of 

Activitie

s Per 

Respond

ent 

Cost 

Per 

Activi

ty 

Total Cost 

Dom

estic 

Forei

gn1

Tota

l 

Domes

tic 

Foreig

n 

Total 

8 98 76
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 98 of 118 

Exhibit 6-27: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of 

Respondents 

Number 

of 

Activitie

s Per 

Respond

ent 

Cost 

Per 

Activi

ty 

Total Cost 

Dom

estic 

Forei

gn1

Tota

l 

Domes

tic 

Foreig

n 

Total 

2 ULEF to 2 Standard - HWPW 8 87 95 520

$15.6

8

$65,22

9

$709,3

63

$774,5

92

1 ULEF to 1 NAF - PB/MDF 1 10 11 -3 $8.96 -$27 -$269 -$2961 ULEF to 1 NAF – HWPW 5 55 60 -3

$15.6

8 -$235

-

$2,587 -$2,822

2 New NAF – (HWPW-New)

11 211 222 2 $15. 6816 $345 $6,617 $6,962 

2 Standard (PB/MDF - New) 5 110 115 264 $9 $11,827 $260,198 $272,026 

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 

$6,873,711817

,285 

$7,251

,0026,

506,81

6 

$14,124,7131

3,324,1

01 

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 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 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 certified, which are assumed to 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 therefore their products will be defined as 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 their products certified by a 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 qualifying or correlation testing 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 ULEF or NAF certification. 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) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the initial on-site audit in the first year. All producers with ULEF or NAF certification will have one on-site audit annually thereafter. 7. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with two 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 99 of 118 

Exhibit 6-27: Incremental Second and Third Year Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of 

Respondents 

Number 

of 

Activitie

s Per 

Respond

ent 

Cost 

Per 

Activi

ty 

Total Cost 

Dom

estic 

Forei

gn1

Tota

l 

Domes

tic 

Foreig

n 

Total 

desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or 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 as hardwood plywood producers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meets the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying with the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule. 9. Firms Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their name, the date the finished good was produced, and a statement of compliance. Retailers are not required to modify their labeling system to comply with the proposed rule assuming they do not modify the packaging of the products they purchase. This analysis assumes that all 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are not sold in California) will incur a non-labor cost of $125.00 for purchasing stamps for labeling. Producers and wholesalers are not expected to incur any non-labor costs from initial labeling. 10. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 100 of 118 

Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Numbe r of 

Activit

ies Per 

Respo

ndent 

Cost 

Per 

Activit

y 

Total Cost 

Dom

estic 

Forei

gn1 Total Dome stic Foreig n Total 

1. Rule Familiarization - - - - - - - - 2. Certification Fee2

Uncertified to Standard3,4 277 154 431 1.0000 

$6,000.

00 

$1,662

,000 

$924,0

00 

$2,586

,000 

ULEF to Standard 11 114 125 1.0000

$2,300.

00

$25,30

0

$262,2

00

$287,5

00

NAF (With New Certification) 11 211 222 1.0000 

$4,466.

67 

$49,13

3 

$942,4

67 

$991,6

0160

3. Initial On-site Audit 

With Existing Certifications 82 764 846 - 

$450.0

0 - - - 

Without Existing Certifications3,4 288 365 653 0.3333 

$450.0

0 

$43,19

6200 

$54,74

5750 

$97,94

0950 

4. Develop Quality Control Manual - - - - - - - - 5. Qualifying Test5

1 Product 

115 1296

4 14069 1.6667 $480.0

0

$8,800

4,000 

$103,20251,2

00 

$112,00255,2

00 

2 Products3,4

288 365 653 3.3333 $480.0

0

$460,7

95800 

$583,994584,

000 

$1,044,79080

0 

6. Qualifying Test Shipping5

1 Product 

115 1296

4 14069 0.3333 $200.0

0

$7333

33 

$8,599

4,267 

$9,332

4,600 

2 Products3,4

288 365 653 0.6667 $200.0

0

$38,40

2400 

$48,66

9667 

$87,07

1067 

7. Correlation Test - - - - - - - - 8. Quarterly On-site Audit5

Uncertified to Standard3,4

277 154 431 3.6667 $450.0

0

$457,0

54050 

$254,1

02100 

$711,1

56150 

ULEF to Standard 11 114 125 3.0000

$450.0

0

$14,85

0

$153,9

00

$168,7

50

NAF (With New Certification) 

11 211 222 1.000

02.333

$450.0

0

$4,950

11,550 

$94,950221,5

$99,900233,1
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 101 of 118 

Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Numbe r of 

Activit

ies Per 

Respo

ndent 

Cost 

Per 

Activit

y 

Total Cost 

Dom

estic 

Forei

gn1 Total Dome stic Foreig n Total 

3 50 00 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 102 of 118 

Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Numbe r of 

Activit

ies Per 

Respo

ndent 

Cost 

Per 

Activit

y 

Total Cost 

Dom

estic 

Forei

gn1 Total Dome stic Foreig n Total 

9. Large Scale Testing Fee 

1 New Standard 

5 64 69 3.6667 $480.0

0 $8,800 $112,6 41640 $121,4 41440 

2 New Standard3,4

277 154 431 7.3333 $480.0

0

$975,0

36040 

$542,0

78080 

$1,517,11312

0 

2 ULEF to 2 Standard 

11 114 125 6.0000 $480.0

0

$31,68

0 

$328,3

20 

$360,0

00 

1 New NAF 

6 65 71 1.0000 $480.0

0 $2,880 $31,200 $34,080 

2 New NAF 

115 211146 22215

1

2.0000 $480.0

0

$10,56

04,800 

$202,560140,

160 

$213,120144,

960 

1 NAF and 1 ULEF 6 65 71 5.0000 $480 $14,400 $156,000 $170,400 

10. Large Scale Testing Shipment 

1 New Standard 

5 64 69 3.6667 $50.0

0 $917 $11,733 $12,650 

2 New Standard3,4

277 154 431 7.3333 $50.0

0

$101,5

66567 

$56,46

6467 

$158,0

33 

2 ULEF to 2 Standard 

11 114 125 6.0000 $50.0

0 $3,300 $34,200 $37,500 

1 New NAF 

6 65 71 1.0000 $50.0

0 $300 $3,250 $3,550 

2 New NAF 

115 211146 22215

1

2.0000 $50.0

0

$1,100

500 

$21,10014,60

0 

$22,20015,10

0 

11. On-site Audit Travel1 NAF and 1 ULEF

2886 3656

5 65371 15.0000 

$1,500.005

0

$432,0001,50

0 

$547,50016,2

50 

$979,50017,7

50 

12. Desk Audits711. On-site Audit Travel 288 365 653 1.0000 $1,500 $432,0 $547,5 $979,5
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 103 of 118 

Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Numbe r of 

Activit

ies Per 

Respo

ndent 

Cost 

Per 

Activit

y 

Total Cost 

Dom

estic 

Forei

gn1 Total Dome stic Foreig n Total 

00 00 00 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 104 of 118 

Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Numbe r of 

Activit

ies Per 

Respo

ndent 

Cost 

Per 

Activit

y 

Total Cost 

Dom

estic 

Forei

gn1 Total Dome stic Foreig n Total 

Uncertified to Standard3,412. Desk Audits7

277 154 431 8.0000 $250.0

0

$554,0

00

$308,0

00

$862,0

00

ULEFUncertified to StandardStandard3,4

1127

7

11415

4 125431 8.0000 

$250.0

0 

$2255

4,000 

$2283

08,000 

$2508

62,000 

NAF (With New Certification) 

11 211 222 0.6667 $250.0

0 $1,833 $35,16

8167 

$37,00

2000 

13. Purchase of Small Chamber Testing Unit 

295

282

3502

08

64549

0

0.3333 $10,00

0.00

$983,235940,

000 

$1,166,55069

3,333 

$2,149

,7851,

633,33

3 

14. Quality Control Testing - - - - - - - - 15. Lost Product 

1 New2 Standard - PB/MDF(HWPW – Existing)3,4

510 6410

9 69119

265.333341

6.0000

$8.96

16

$11,88765,22

9 

$152,153710,

994 

$164,040776,

223 

2 New Standard - HWPW3(HWPW-New)3,4

277 1541

08

43138

5

530.66

67 

$15.6

816

$2,304,87787

6 

$1,281,41189

8,652 

$3,586,28820

3,529 

2 ULEF to 2 Standard - PB/MDF 3 27 30

522.66

67 $8.96

$14,04

9

$126,4

44

$140,4

93

2 ULEF to 2 Standard - HWPW 8 87 95

522.66

67 $15.68

$65,56

3

$713,0

01

$778,5

64

1 ULEF to 1 NAF - PB/MDF 1 10 11

20.333

3 $8.96 $182 $1,822 $2,004

1 ULEF to 1 NAF - HWPW 5 55 60

20.333

3 $15.68 $1,594

$17,53

5

$19,13

0

2 New NAF - (HWPW-New)

11 211 222 48.6667 

$15.6

816 $8,394 $161,013 $169,407 

2 Standard (PB/MDF - New) 5 110 115 265.3333 $9 $11,887 $261,513 $273,399 

16. Initial Recordkeeping8

8,576 11,945 20,521 0.3333 $1,000. 00 $2,858

,38166

7 

$3,981,26966

7 

$6,839,64984

0,333 

17. Recurring Recordkeeping - - - - - - - - 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 105 of 118 

Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Numbe r of 

Activit

ies Per 

Respo

ndent 

Cost 

Per 

Activit

y 

Total Cost 

Dom

estic 

Forei

gn1 Total Dome stic Foreig n Total 

18. Initial Labeling9

Minor Changes - Producers - - - - - - - - Minor Changes - Fabricators - - - - - - - - Major Changes – Producers3 277 108 385 0.3333

$125.0

0

$11,5

41542 $4,500 $16,

0

40042 

Major Changes - Fabricators and Wholesalers10

16,26

6 6,344 22,610 0.3333 $125.00 $677, 6827

50 

$264,

3073

33 

$941,

9899

42,083 

Three-Year Average Cost 

$11,848,5707

38,328 

$13,763,0491

2,398,

573 

$25,611,6202

4,136,

899 

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 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 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 certified, which are assumed to 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 therefore their products will be defined as 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 their products certified by a 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 qualifying or correlation testing 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 ULEF or NAF certification. 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) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the initial on-site audit in the first year. All producers with ULEF or NAF certification will have one on-site audit annually thereafter. 7. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on-site audit. Producers with new NAF certifications will incur the costs associated with two desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or 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 as hardwood plywood producers], fabricators, and wholesalers that import composite wood products) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meets the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying with the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule. 9. FirmsPanel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include their name, the date the finished good was produced, and a statement of compliance. Retailers are not required to modify their labeling system to comply with the proposed rule assuming they 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

Page 106 of 118 

Exhibit 6-28: Three Year Average Incremental Non-Labor Costs, by Activity and Geographic Location ($2010) 

Activity 

Number of Respondents Numbe r of 

Activit

ies Per 

Respo

ndent 

Cost 

Per 

Activit

y 

Total Cost 

Dom

estic 

Forei

gn1 Total Dome stic Foreig n Total 

do not modify the packaging of the products they purchase. This analysis assumes that all 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are not sold in California) will incur a non-labor cost of $125.00 for purchasing stamps for labeling. Producers and wholesalers are not expected to incur any non-labor costs from initial labeling. 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 107 of 118 

1372 (iii) Total Burden and Costs 

1373 

1374 Exhibit 6-29 presents a summary of the total non-incremental burden and costs for this 

1375 information collection request over the first three years of the rule, by geographic location. 

1376 Exhibit 6-30 presents a summary of the total incremental burden and costs for this information 

1377 collection request over the first three years of the rule, by geographic location. As indicated, the 

1378 total average domestic incremental cost over the first three years of the rule is approximately 

1379 86.2 percent of the total domestic cost of the rule. Note that the incremental costs for domestic 

1380 respondents presented in Exhibit 6-30 differ from the values in the Economic Analysis. This is 

1381 due to two factors: 1) the Economic Analysis includes the costs of changes to raw materials for 

1382 composite panel producers, while the ICR does not (because it is not a reporting or 

1383 recordkeeping cost); and 2) the burden in the ICR is calculated at the activity level and rounded 

1384 to nearest tenth of a percentage, while the costs in the Economic Analysis are calculated at the 

1385 establishment level. 

1386 

Exhibit 6-29: Total (including baseline) Burden and Costs ($2010)

Geographic Location of 

Respondents 

Labor Non-Labor Cost Total Cost Hours Cost 

Year 1 

Domestic Respondents 9,048,102041,296 $449,847,909362,235

$22,991,311749,0

95

$472,839,220

111,329

Foreign Respondents 

4,137,039066,091 $157,096,495152,

033,647

$37,563,58334,6

38,718

$194,660,07

8186,672,365

Total Respondents 

13,185,140107,388 $606,944,290601,

395,909

$60,554,89457,3

87,813

$667,499,18

4658,783,722

Years 2 and 3

Domestic Respondents 2,973,560967,505 $83,966,474534,390

$7,799,524665,84

6

$91,765,9982

00,236

Foreign Respondents 2,379,880317,142 $80,867,85876,390,874

$17,801,35616,4

32,841

$98,669,214

92,823,715

Total Respondents 

5,353,441284,648 $164,834,359159,

925,291

$25,600,88024,0

98,688

$190,435,23

9184,023,979

Three Year Average 

Domestic Respondents 4,998,206991,901 $205,914,848477,002

$12,862,997693,5

95

$218,777,845

170,598

Foreign Respondents 

2,965,542900,068 $106,274,877101,

605,129

$24,388,22122,5

01,467

$130,663,09

8124,106,597

Total Respondents 

7,963,747891,969 $312,189,663307,

082,164

$37,251,21635,1

95,063

$349,440,87

9342,277,228

Notes: Values may not sum to totals due to rounding 

1387 

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Formatted Table

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

Page 108 of 118 

Exhibit 6-30: Total Incremental Burden and Costs, by Geographic Location ($2010)

Geographic Location of 

Respondents 

Labor Non-Labor 

Cost 

Total Incremental 

Hours Cost Cost 

Year 1

Domestic Respondents 

7,935,088928,2

88

$420,694,1532

08,903

$21,799,6725

80,413

$442,493,825441,7

89,316

Foreign Respondents 

3,153,692082,8

28

$121,134,32

7116,077,473

$26,788,780

24,182,083

$147,923,107140,2

59,556

Total Respondents 

11,088,777011,

115

$541,828,31

0536,286,350

$48,588,453

45,762,496

$590,416,763582,0

48,846

Years 2 and 3 

Domestic Respondents 

1,860,216854,3

47

$54,789,16737

0,354

$6,873,71181

7,285 $61,662,878187,639

Foreign Respondents 

1,393,518333,4

75

$44,690,5404

0,405,872

$7,251,0026,

506,816

$51,941,54246,912,

688

Total Respondents 

3,253,732187,8

21

$99,479,6089

4,776,198

$14,124,713

13,324,101

$113,604,321108,1

00,299

Three Year Average 

Domestic Respondents 

3,884,972878,7

93

$176,745,3923

16,534

$11,848,5707

38,328

$188,593,962054,86

3

Foreign Respondents 

1,980,186916,5

36

$70,169,3476

5,629,736

$13,763,049

12,398,573

$83,932,39678,028,

310

Total Respondents 

5,865,153795,3

29

$246,914,48

0241,946,249

$25,611,620

24,136,899

$272,526,100266,0

83,149

Notes: Values may not sum to totals due to rounding 

1388 

1389 

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

Page 109 of 118 

1390 

1391 6(c) Estimating Agency Burden and Cost 

1392 

1393 EPA resources would be devoted to reviewing and analyzing data submissions, compiling 

1394 and recording data, maintaining hard-copy files of submitted data, auditing and inspecting 

1395 facilities, producing audit and inspection reports, responding to public inquiries, and providing 

1396 regulatory interpretations. EPA anticipates that these activities will require the equivalent of one 

1397 full-time employee (FTE) at Headquarters. Using the 2010 Washington/Baltimore area annual 

1398 salary rate for a GS-13, Step 5 employee ($100,904), and multiplying by a loading factor of 1.6 

1399 to reflect overhead and fringe benefits results in an estimated EPA cost of $161,446 per year. 

1400 

1401 6(d) Bottom Line Burden Hours and Costs/Master Table 

1402 

1403 Exhibit 6-31 presents the frequency for each of the respondent activities assumed in the 

1404 bottom line burden hour and cost tables. Exhibit 6-32 and Exhibit 6-33 present the respective 

1405 total and incremental bottom line burden and costs, by activity frequency and respondent type. 

1406 In Exhibit 6-32, all activities of a given frequency that a single respondent performs are 

1407 accounted for as a single response for that time period. For example, if a respondent performs 

1408 two different quarterly activities per quarter this is accounted for as a single response per quarter 

1409 or four responses per year (e.g., paying the large scale testing fee and paying shipment costs for 

1410 large scale testing is counted as a single response not two separate responses). 

1411 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review*** 

Page 110 of 118 

1412 

Exhibit 6-31: Frequency of Activities 

Activity Assumed Activity Frequency 1

1. Rule Familiarization 

Producers One-Time 

Fabricators One-Time 

Wholesalers One-Time 

Retailers One-Time 

2. Certification Fee 

Standard Annual 

New NAF Annual 

Existing NAF/ULEF Annual 

3. Initial On-site Audit 

With Existing Certifications One-Time 

Without Existing Certifications One-Time 

4. Develop Quality 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 

1 ULEF and 1 NAF Certification Annual

11. On-site Audit Travel Annual 

12. Desk Audits 

Standard Annual 

NAF (With New Certification) Annual 

13. Purchase of Small Chamber Testing Unit One-Time 

14. Quality Control Testing - HWPW 

Standard Certification Daily 

New NAF Certification One-Time 

15. Lost Product 

2 Products with Standard Certification (HWPW - Existing) Daily 

2 Products with Standard Certification (HWPW - New) Daily

2 Products with ULEF Certification (HWPW - New) Annual

1 ULEF and 1 NAF Certification (HWPW - Existing)
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review*** 

Page 111 of 118 

Exhibit 6-31: Frequency of Activities 

Activity Assumed Activity Frequency 1

1 Product with NAF Certification (HWPW - New) Annual 

1 Product with NAF Certification (HWPW - Existing) Annual 

2 Products with NAF Certification (HWPW - New) Annual 

2 Products with NAF Certification (HWPW - Existing) Annual 

1 Product with Standard and 1 NAF Certification (PB/MDF - 

Existing) Daily 

2 Products with Standard Certification (PB/MDF - New) Daily 

2 Products with Standard Certification (PB/MDF - Existing) Daily 

1 Product with NAF Certification (PB/MDF - New) Annual 

1 ULEF and 1 NAF Certification (PB/MDF - Existing) 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. 

1413 

1414 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review*** 

Page 112 of 118 

Exhibit 6-32: Summary of Three Year Average Total (including baseline) Burden and Costs, by 

Geographic Location ($2010) 

Response and 

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 138.5895 17,372 091 $2,361,644293,200

 Annual 

370 1.0000 59.6811 2649 22,082 

21,928 $5,026,0154,975,931

 Quarterly 370 4.0000 3.7797 6784 5,594 444 $2,085,323056,416

 Daily 

370 260.0000 1.8324 7730 176,280 

170,560 $15,210,89414,738,661

Fabricators 

 One-Time 

79,701 0.3333 25.7560 

26.8287 684,190 

712,687

$34,047,67035,348,387

 Daily 79,701 1.0000 24.1482 1,924,638 $47,808,008 

Wholesalers 

 One-Time 

85,560 0.3333 10.9281 9.9288 311,639 

283,142

$19,115,18517,819,748

 Annual 85,560 1.0000 9.8697 844,448 $21,567,202 

Retailers 

 One-Time 759,048 0.3333 4.0000 1,011,963 $71,555,904563,045

Annual 1 759,048 1.0000 - - - 

Total 924,679 4,998,206 991,901 $218,777,845170,598

Foreign

Producers 

 One-Time 

1,129 0.3333 76.8279 68.7385 28,910 

25,866

$3,888,772142,139

 Annual 

1,129 1.0000 58.6873 57.2728

 66,258 

64,661 $14,680,318142,927

 Quarterly 1,129 4.0000 2.6050 2.2611

 11,764 

10,211 $4,693,501394,614

 Daily 1,129 260.0000 1.2631 1.0611

 370,760 

311,480 $30,709,06225,732,711

Fabricators 

 One-Time 

31,083 0.3333 25.7470 26.8215 266,738 

277,870

$13,274,319782,371

 Daily 31,083 1.0000 24.2524 753,838 $18,725,336 

Wholesalers 

 One-Time 

33,368 0.3333 26.1753 25.1744 291,110 

279,978

$14,652,563147,271

 Annual 

33,368 1.0000 

35.2483 1,176,164 $30,039,228 

Retailers 

 One-Time - 0.3333 - - - 

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Formatted Table

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

Page 113 of 118 

1415 

Total 65,580 2,965,542 900,068

$130,663,099124,106,

597

Total 

Producers 

 One-Time 

1,499 0.3333 92.6350 85.9799 46,282 

42,957

$6,250,4155,435,343

 Annual 

1,499 1.0000 58.9326 57.7645

 88,340 

86,589 $19,706,338118,857

 Quarterly 

1,499 4.0000 2.8949 2.6109

 17,358 

15,655 $6,778,822451,032

 Daily 

1,499 260.0000 1.4036 1.2368 547482,040

$45,919,95340,471,373

Fabricators 

 One-Time 

110,784 0.3333 25.7534 26.8267 950,926 

990,557

$47,321,89949,130,759

 Daily 110,784 1.0000 24.1775 2,678,476 $66,533,344 

Wholesalers 

 One-Time 

118,928 0.3333 15.2061 14.2063 602,749 

563,120

$33,767,74831,967,019

 Annual 

99,908118118,92

8 

1.0000 20.2247

16.9902

2,020,613 

612 $51,606,456 

Retailers 

 One-Time 759,048 0.3333 4.0000 1,011,963 $71,555,904563,045

Annual1 759,048 1.0000 - - - 

Total 990,259 7,963,747 891,969

$349,440,879342,277,2

28

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. 

Formatted Table

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

Page 114 of 118 

Exhibit 6-33: Summary of Three Year Average Total Incremental Burden and Costs, by Geographic 

Location ($2010) 

Response 

and 

Respondent 

Type 

Number of 

Respondents 

Average 

Activities per 

Respondent 

Average Burden 

per Response 

(hours) 

Total 

Burden Total Cost 

Domestic

Producers 

 One-Time 370 0.3333 140.8681 

138.5895

17,372 

091 $2,349,345280,900

 Annual 370 1.0000 58.3811 3027 21,601 

572 $4,317,674282,669

 Quarterly 370 4.0000 3.1892 0885 4,720 571 $1,930,023904,517

 Daily 370 260.0000 1.5568 4973 149,760 

144,040

$13,083,25012,660,686

Fabricators 

 One-Time 79,701 0.3333 25.7560 

26.8287

684,190 

712,687

$34,047,67035,348,387

 Annual 47,540 1.0000 24.2646 1,153,539 $28,653,909 

Wholesalers 

 One-Time 85,560 0.3333 10.9281 9.9288 311,639 

283,142

$19,115,18517,819,748

 Annual 

 

23,10253,73

1 85,560

1.0000 22.94999.867

5 0.0002

530,188 $13,541,002 

Retailers 

 One-Time 759,048 0.3333 4.0000 1,011,963 $71,555,904563,045

 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

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Formatted Table

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

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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 924,679 3,878,793 $188,054,863

Foreign

Producers

 One-Time 1,129 0.3333 68.7385 25,866 $3,027,539

 Annual 1,129 1.0000 55.0540 62,156 $7,936,610

 Quarterly 1,129 4.0000 0.5627 2,541 $1,520,865

 Daily 1,129 260.0000 0.2728 80,080 $7,585,668

Fabricators

 One-Time 31,083 0.3333 26.8215 277,870 $13,782,371

 Annual 18,476 1.0000 24.3314 449,547 $11,166,747

Wholesalers

 One-Time 33,368 0.3333 25.1744 279,978 $14,147,271

 Annual 20,955 1.0000 35.2421 738,498 $18,861,239

Retailers

 One-Time - 0.3333 - - - 

Total 65,580 1,916,536 78,028,310

Total

Producers

 One-Time 1,499 0.3333 85.9799 42,957 $5,308,443

 Annual 1,499 1.0000 55.8559 83,728 $12,219,276

 Quarterly 1,499 4.0000 1.1861 7,112 $3,425,382

 Daily 1,499 260.0000 0.5751 224,120 $20,246,354

Fabricators

 One-Time 110,784 0.3333 26.8267 990,557 $49,130,759

 Annual 66,016 1.0000 24.2833 1,603,086 $39,820,656

Wholesalers

 One-Time 118,928 0.3333 14.2063 563,120 $31,967,019

 Annual 74,686 1.0000 16.9869 1,268,686 $32,402,215

Retailers

 One-Time 759,048 0.3333 4.0000 1,011,963 $71,563,045

 Annual1 658,150 1.0000 - - -

Total 990,259 5,865,15

3 795,329

 272,526,100 

$266,083,149

1. Retailers are assumed not to import 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. 

1416 

1417 

1418 6(e) Reasons for Changes in Burden

1419 

1420 Not applicable. These are new requirements so there was no previous ICR. 

1421 

1422 6(f) Burden Statement

1423 

1424 The annual public burden for this collection of information, which is approved under 

1425 OMB Control No. xxxx-xxxx, is estimated to be 4.6460 hours per response (i.e., 

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

Page 116 of 118 

7,963,747891,969 burden hours for an estimated 1,716,048 responses).27 1426 According to the 

1427 Paperwork Reduction Act, “burden” means the total time, effort, or financial resources expended 

1428 by persons to generate, maintain, retain, or disclose or provide information to or for a Federal 

1429 agency. For this collection it includes such activities as annual familiarization with 

1430 requirements, recordkeeping, notification, and reporting requirements. An agency may not 

1431 conduct or sponsor, and a person is not required to respond to, a collection of information unless 

1432 it displays a currently valid OMB control number. The OMB control numbers for EPA’s 

1433 regulations in title 40 of the CFR, after appearing in the Federal Register, are listed in 40 CFR 

1434 part 9 and included on the related collection instrument or form, if applicable. 

1435 

1436 To comment on the Agency’s need for this information, the accuracy of the provided 

1437 burden estimates, and any suggested methods for minimizing respondent burden, including the 

1438 use of automated collection techniques, EPA has established a public docket for this ICR under 

1439 Docket ID No. EPA-HQ-OPPT-XXXX-XXXX2012-0018. The docket is available for public 

1440 viewing at the Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). 

1441 The EPA/DC Public Reading Room is located in the EPA West Building, Room 3334, 1301 

1442 Constitution Ave., NW., Washington, DC. The EPA/DC Public Reading Room is open from 

1443 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number 

1444 for the EPA/DC Public Reading Room is (202) 566-1744, and the telephone number for the 

1445 Pollution Prevention and Toxics Docket is (202) 566-0280. An electronic version of the public 

1446 docket is available through the Federal Docket Management System (FDMS) at 

1447 www.regulations.gov. Use FDMS to submit or view public comments, access the index listing 

1448 of the contents of the public docket, and to access those documents in the public docket that are 

1449 available electronically. Once in the system, select “search,” then key in the docket ID number 

1450 identified above. Also, you can send comments to the Office of Information and Regulatory 

1451 Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, 

1452 Attention: Desk Office for EPA. Please include the EPA Docket ID No. EPA-HQ-OPPT1453 XXXX-XXXX2012-0018 and OMB control number xxxx-xxxx in any correspondence. 

1454 

1455 

1456 

 

27 The total number of responses is calculated by taking the sum of the products of the number of respondents and the number of 

responses presented in Exhibit 6-32. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review*** 

Page 117 of 118 

1457 References 

1458 

1459 California Air Resources Board. 2011. CARB List of Certified Mills. 

1460 Composite Panel Association. 2011. 2011 Surface & Panel Buyers Guide. 

1461 Personal Communication with AHFA. 2010. Conversation between Bill Perdue (American Home 

1462 Furnishings Alliance) and Abt Associates Inc. November 3, 2010. 

1463 Personal Communication with BIFMA. 2010. Brad Miller's (BIFMA) Written Responses to Questions 

1464 about FSCWPA Impacts on Members. November 23, 2011. 

1465 Personal Communication with CRA. 2011. Conversation between Pamela Williams (California Retailers 

1466 Association) and Abt Associates Inc. January 20, 2011. 

1467 Personal Communication with HPVA. 2011. Conversation between Kip Howlett (HPVA) and Abt 

1468 Associates Inc. January 4, 2011. 

1469 U.S. Bureau of Labor Statistics (BLS). 2009. Occupational Employment Statistics 2009 Mean Hourly 

1470 Wages. 

1471 U.S. Bureau of Labor Statistics (BLS). 2011. BLS Employer Cost for Employee Compensation (ECEC) 

1472 Data for all private industry for 2009-2010. 

1473 U.S. Census Bureau. 1997. 1992 Enterprise Statistics: Company Summary. 

1474 U.S. Census Bureau. 2009. Sector 42: EC0742I1: Wholesale Trade: Industry Series: Preliminary Summary 

1475 Statistics for the United States: 2007. 

1476 U.S. Census Bureau. 2010a. Sector 44: EC0744SLLS1: Retail Trade: Subject Series - Product Lines: 

1477 Product Lines Statistics by Kind of Business for the United States and States: 2007. 

1478 U.S. Census Bureau. 2010b. Sector 31: EC0731SG3: Manufacturing: Summary Series: General Summary: 

1479 Industry Statistics for Subsectors and Industries by Employment Size: 2007. 

1480 U.S. Census Bureau. 2010c. Sector 44: EC0744SSSZ3: Retail Trade: Subject Series - Estab & Firm Size: 

1481 Summary Statistics for Single Unit and Multiunit Firms for the United States: 2007. 

1482 U.S. Census Bureau. 2010d. Sector 42: EC0742A1: Wholesale Trade: Geographic Area Series: Summary 

1483 Statistics for the United States. 

1484 U.S. Census Bureau. 2010e. Sector 31: EC0731A1: Manufacturing: Geographic Area Series: Industry 

1485 Statistics for the States. 

1486 U.S. Census Bureau. 2010f. Sector 42: EC0742SSSZ5: Wholesale Trade: Subject Series - Estab & Firm 

1487 Size: Summary Statistics by Employment Size of Firms for the United States: 2007. 

1488 U.S. Census Bureau. 2010g. Sector 44: EC0744SSSZ4: Retail Trade: Subject Series - Estab & Firm Size: 

1489 Summary Statistics by Sales Size of Firms for the United States: 2007. 

1490 U.S. Census Bureau. 2010h. Sector 00: NS0800A1: 2008 Nonemployer Statistics: Geographic Area Series: 

1491 Nonemployer Statistics by Legal Form of Organization: 2008 

1492 U.S. Census Bureau. 2010i. Data Item: Wholesale type of operation.” American FactFinder Help. Census 

1493 Data Information. 

1494 U.S. Census Bureau. 2010j. Sector 42: EC0742SSSZ3: Wholesale Trade: Subject Series - Estab & Firm 

1495 Size: Summary Statistics for Single Units and Multiunit Firms for the United States: 2007. 

1496 U.S. Census Bureau. 2010k. Statistics for U.S. Businesses (SUSB). Number of Firms, Number of 

1497 Establishments, Employment, Annual Payroll, and Estimated Receipts by Enterprise Receipt Size for the 

1498 United States, All Industries: 2007. December 15, 2010. 

1499 U.S. Census Bureau. 2010l. Sector 44: EC0744A1: Retail Trade: Geographic Area Series: Summary 

1500 Statistics for the United States, States, Metro Areas, Counties, and Places: 2007. 
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Page 118 of 118 

1501 U.S. Census Bureau. 2011. Sector 42: EC0742SLLS1: Wholesale Trade: Subject Series - Product Lines: 

1502 Product Lines Statistics by Kind of Business for the United States and States: 2007. 

1503 U.S. Internal Revenue Service. 2007. Starting a Business and Keeping Records. Publication 583. Revised 

1504 January 2007. 

1505 U.S. International Trade Commission. 2011. U.S. Interactive Tariff and Trade Dataweb. 

1506 

1507