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Supporting Statement for a Request for OMB Review under

The Paperwork Reduction Act

1. IDENTIFICATION OF THE INFORMATION COLLECTION

l(a) Title of the Information Collection

TITLE: Chemical-Specific Rules, Toxic Substances Control Act Section 8(a)

EPA ICR No.: 1198.09 OMB Control No: 2070-0067

1(b) Short Characterization

This information collection request requires OMB’s approval for the continued collection 

of chemical-specific information under section 8(a) of the Toxic Substance Control Act (TSCA, 

15 U.S.C. 2607); see Attachment 1. TSCA section 8(a) authorizes the Administrator of the EPA 

to promulgate rules that require persons who manufacture, import or process chemical 

substances and mixtures, or who propose to manufacture, import, or process chemical substances 

and mixtures, to maintain such records and submit such reports to EPA as may be reasonably 

required. Information that may be collected under TSCA section 8(a) includes, but is not limited

to, chemical names, categories of use, production volume, byproducts of chemical production, 

existing data on deaths and environmental effects, exposure data, and disposal information. 

These data are collected by the Office of Pollution Prevention and Toxics (OPPT) and may be 

used by other EPA offices and/or Federal agencies to ensure knowledge of specific practices that 

may affect human health and the environment.

There may be circumstances when EPA may require different information than is readily 

available or information that is different from that available through existing regulatory

information collection tools, like the TSCA section 8(a) Preliminary Assessment Information 

Rule (PAIR) which is discussed in another ICR under a different OMB control number. EPA 

promulgated PAIR on June 22, 1982 (see 40 CFR Part 712). Whenever a substance is added to 

the PAIR, manufacturers and importers of the substance are required to complete a PAIR report 

form. The PAIR report requests a very limited amount of information on listed chemicals 

regarding activities occurring over a specific time period.

Any chemical covered by TSCA for which OPPT, other EPA Offices or another Federal 

agency has a reasonable need for information, and which cannot be satisfied via readily available 

sources or by use of PAIR, is a proper potential subject for a chemical-specific TSCA section 

8(a) rulemaking. For instance EPA may wish to ask detailed questions in regard to how industry

oversees the use and production of a chemical. These specific monitoring capabilities could 

allow EPA to react to change in market conditions that may warrant a change in EPA’s 

regulatory strategy. Therefore, EPA could promulgate a TSCA section 8(a) rule to gather this 
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information by requesting that current or potential manufacturers, importers or processors of the 

substance provide chemical-specific information.

EPA’s OPPT, other EPA Offices and/or other Federal agencies will generally be the 

primary groups for which information will be collected. However, to the extent that reported 

information is not considered to be confidential business information (CBI), environmental 

groups, environmental justice advocates, state and local government entities and other members 

of the public will have access to this information for their own use.

Rather than requiring respondents to submit information on reporting forms such as those 

used for PAIR, EPA has in the past allowed individual firms to choose the reporting means and 

format that is best suited to their recordkeeping resources. EPA believes that for TSCA section 

8(a) chemical-specific rules, this allowance keeps reporting costs low.

Total annual cost of a rule varies depending upon the number of chemicals per rule and 

the number of respondents per chemical. Based on the recent past usage of chemical-specific 

TSCA section 8(a) rules and expected future usage, EPA assumes that it will promulgate one 

TSCA section 8(a) chemical-specific rule with four respondents (notices) per year for the threeyear duration of the ICR (see Section 6(b), below). The maximum total annual number of 

burden hours for respondents range from 134 hours to 594 hours per TSCA section 8(a) 

chemical-specific rule. The maximum cost associated with the promulgation of a TSCA section 

8(a) chemical-specific rule is $6,868 to $30,504. However, the cost per respondent varies with 

the type of chemical-specific information requested, and subsequently, the tasks required to 

comply with a TSCA section 8(a) chemical-specific rule. Because all respondents may not have 

to provide information on all data items listed (see Sections 3 and 6(b), below), the ranges 

presented above are maximums. Assuming that all respondents do not have to complete all tasks 

identified to comply with a TSCA section 8(a) chemical-specific rule, total annual reporting 

costs to all respondents range from $3,375 to $14,080 per rule.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Generally, EPA may need chemical-specific information under TSCA section 8(a) to 

evaluate the potential for adverse human health and environmental effects caused by the 

manufacture, importation, processing, use or disposal of identified chemical substances and 

mixtures. Additionally, EPA may use TSCA section 8(a) information to assess the need or set 

priorities for testing and/or further regulatory action.

The information required in TSCA section 8(a) chemical-specific rules can be customtailored to aid in achieving EPA’s goals of protecting human health and the environment. 

Information collected may vary depending on the substance, its current and potential uses and 
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EPA’s concerns about potential human or environmental risks caused by exposures to the 

substance. Promulgated TSCA section 8(a) rules may require persons manufacturing, importing 

or processing the chemical substance to report to EPA on specific information such as: a 

chemical’s composition, byproducts, quantity produced, employee exposure and environmental 

release. Persons have in the past also been required to notify EPA of a management decision to 

initiate the manufacturing, importing, or processing of a chemical substance or mixture.

The legal authority for this information collection is TSCA section 8(a), U.S.C. 2607(a). 

TSCA section 8(a) chemical-specific rules have been codified at 40 CFR 704, subpart B; see 

Attachment 2.

2(b) Use/Users of the Data

EPA will use the information obtained through the TSCA section 8(a) reporting rules to 

satisfy specifically identified data needs. The information collected will be relevant to risk 

identification, all stages of risk assessment, and/or control action functions. Receipt of TSCA 

section 8(a) information may also give the Agency an opportunity to work with the respondent, if 

necessary, to minimize exposure risks associated with specific uses. Generally, a specific 

information collection request would be made by the Chemical Control Division, Chemical 

Management Division, or the Chemical Screening and Risk Assessment Division in OPPT. 

However, other regulatory agencies and departments, such as Occupational Safety and Health 

Administration (OSHA), the Food and Drug Administration (FDA), and other members of the 

Interagency Testing Committee (ITC) may also present a need for and subsequently use TSCA 

section 8(a) data to, for example, assess worker or consumer exposures.

An example of a use of a TSCA section 8(a) chemical-specific rule that was key in 

affecting a benefit to human health was 1,1-aminoundecanoic acid (1,1-AA). From submitted 

TSCA section 8(e) “substantial risk” reports, EPA discovered that 1,1-AA is a carcinogen in one 

sex of one rodent species (male rat), and that exposure is limited to workers producing the nylon 

in which the chemical is an ingredient. The manufacturer was contacted to obtain exposure data 

for this chemical. From this contact EPA learned: (1) 1,1-AA was imported and converted into 

nylon by one company and there was no domestic manufacture; (2) 1,1-AA was handled and 

transferred in a closed system and all 1,1-AA was converted during the reaction to produce 

nylon. Consequently, because of limited exposure potential, 1,1-AA was dropped from further 

review. However, concern would arise if 1,1-AA were to be manufactured domestically because 

of the greater likelihood for worker exposure. To alert EPA to domestic manufacture, on May

28, 1987, OPPT promulgated a TSCA section 8(a)/5 (SNUR) rule for 1,1-AA (52 FR 19860) . 

Users of TSCA section 8(a) chemical-specific data rarely make a judgment based solely on the 

content of the TSCA section 8(a) information received but rather use the TSCA section 8(a) 

chemical-specific information as part of the larger risk management strategy. 1,1-AA TSCA 

section 8(a) information would be instrumental in affecting a benefit to human health if a 

company were to begin to manufacture the substance.
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3. NON-DUPLICATION, CONSULTATION, AND OTHER COLLECTION CRITERIA

3(a) Non-Duplication

Section 8(a)(2) of TSCA states, “To the extent feasible, the Administrator shall not 

require any reporting which is unnecessary or duplicative.” The reporting requirements of TSCA 

section 8(a) rules only require information that EPA believes will assist in a reasoned evaluation 

of the human health and environmental effects of chemical substances and mixtures. This 

information is unlikely to be duplicative since, (1) EPA estimates that each rule will generate 

only a few notices, (2) the information required by the TSCA section 8(a) rule is unique to the 

manufacturer, importer or processor (e.g., the proposed date of production or importation, the 

amount produced or imported, the chemical composition, and uses of the chemical substance or 

mixture), and (3) EPA thoroughly checks other public and unpublished sources to see if the 

required data may already be available. Finally, once EPA became aware of a source of 

substantially similar information, for example via comments on a proposed rule, EPA would not 

continue with the information collection.

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

Prior to submission to OMB, this ICR will be made available to the public for comment 

through a Federal Register notice. The public will have 60 days to provide comments. Any

comments received will be given consideration when completing the supporting statement that is 

submitted to OMB.

3(c) Consultations

EPA has not published a proposed or final TSCA section 8(a) chemical-specific 

information gathering rule for more than fifteen years and, therefore, has received no comments 

since that time. EPA has received comments on the use of TSCA section 8(a) reporting rules 

through published Federal Register notices. Various organizations responded to EPA’s request 

for comments during the 1985 to 1988 ICR period. For example, the Agency originally

proposed a SNUR for 4,4,1-methylenebis (2-chloroaniline) (MBOCA) but public comments 

received in July and August of 1986 on the proposed SNUR suggested that a TSCA section 8(a) 

rule would be more appropriate. This suggestion was followed, reducing the burden on the 

public since the TSCA section 8(a) rule exempted small manufacturers, whereas the proposed 

SNUR would not have had this exemption.

Also, after receiving public comment on the proposed SNUR/8(a) rule for 1,1-

aminoundecanoic acid (July 22, 1986), the proposed definition of the term “enclosed process” 

was modified to account for possible releases through emergency pressure relief, thus expanding 

the number of processes that would be considered “enclosed” and lessening compliance costs.
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The Natural Resources Defense Council (NRDC) has also responded to several TSCA 

section 8(a) chemical-specific rules. The NRDC is a national nonprofit environmental 

organization dedicated to the protection of human health and the environment. The NRDC 

generally urges EPA to adopt a more extensive, detailed set of information requirements.

Under 5 CFR 1320.8(d)(1) OMB requires agencies to consult with potential ICR 

respondents and data users about specific aspects of ICRs before submitting an original or 

renewal ICR to OMB for review and approval. In accordance with this regulation, EPA will 

pursue additional consultations with interested parties during the development of the renewal of 

this collection.

3(d) Effects of Less Frequent Collection

Generally companies are required to report only once under a TSCA section 8(a) 

reporting rule. EPA may consider requiring reporting on an annual, semiannual, monthly or 

other basis if the Administrator deems this necessary to protect human health and the 

environment. EPA tailors each rule to meet chemical-specific data requirements, thus reducing 

the potential for too frequent data collections.

3(e) General Guidelines

This information collection activity is necessary to implement the statutory requirements 

of section 8(a) of TSCA and is consistent with the requirements of 5 CFR 1320.6.

3(f) Confidentiality

Submitters may designate information as confidential, trade secret or proprietary. EPA 

has implemented procedures to protect any confidential, trade secret or proprietary information 

from disclosure. These procedures comply with EPA’s confidentiality regulation, 40 CFR Part 

2, Subpart B.

3(g) Sensitive Questions

This section is not applicable. TSCA section 8(a) reporting rules do not include any 

questions of a sensitive nature.
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4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/North American Industrial Classification System (NAICS) Codes

Respondents affected by this collection activity primarily include those businesses that 

fall under NAICS codes 325, Chemical Manufacturers and Processors, and 324110, Petroleum 

Refineries.

4(b) Information Requested

4(b)(i) Data Items

Section 8(a) of TSCA specifically lists a wide range of data items that may be required by

EPA, including information on use, production volume, exposure, and health and safety. Data 

items requested of manufacturers, importers, or processors of certain chemicals vary with each 

collection request, but will not repeat information previously requested in the PAIR or other 

information gathering tools. Some data items requested under TSCA section 8(a) chemicalspecific rules in the past include: notification and description of changes in the end use of 

identified substances and mixtures, information on planned manufacturing and on-site 

processing, and notification of changes to the method of manufacturing the substance (see 40 

CFR subpart B).

An example of a past TSCA section 8(a) chemical-specific rule is one issued on 4,4,1-

methylenebis (2-chloroaniline) (MBOCA). It required persons who propose to manufacture 

MBOCA to notify EPA of that intent and to submit information on their planned manufacturing 

and on-site processing activities. The rule also required persons who are manufacturing 

MBOCA to notify the Agency if they propose to alter their manner or method of manufacturing 

the substance.

4(b)(ii) Respondent Activities

Activities a respondent may be required to perform as a result of TSCA section 8(a) 

chemical-specific rule are as follows:

9 to 29.5 Hours of Managerial Labor

- Identify listed chemicals;

- Assign principal technical contact person;

- Identify by-product;

- Review marketing data;

- Research the date of the initiation of manufacture or importation of the chemical;

- Research occupational exposure, environmental release, health and environmental data, 

disposal methods; and
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- Process, compile, and review information for accuracy, substantiate a claim of 

confidential business information.

17.5 to 98 Hours of Technical Labor

- Identify chemical and trade name and chemical composition;

- Identify by-product;

- Describe use of chemical;

- Report quantity manufactured or imported;

- Research workplace exposures, environmental releases, health and environmental data, 

and disposal methods; and

- Provide occupational description.

7 to 21 Hours of Clerical Labor

- Format research on occupational exposures, environmental releases, health and 

environmental data;

- Format attachments; and

- Prepare notice.

Recordkeeping Estimate

TSCA section 8(a) chemical-specific rules may contain recordkeeping requirements. The 

recordkeeping estimate is rough, but it is reasonably related to the maximum reporting burden. 

EPA estimates that recordkeeping will account for approximately five percent of the reporting 

burden, or a maximum of 12 hours (see Table 2.)

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY AND INFORMATION MANAGEMENT

5(a) Agency Activities Inventory

For any TSCA section 8(a) chemical-specific rule the Agency would have to perform a 

number of tasks. They are:

o Industry/Public Assistance (answering questions regarding rule)

o Data Processing and System Support Personnel

o Storage and Distribution

o Compliance Monitoring
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5(b) Collection Methodology and Management

An improved information technology to minimize burden of a TSCA section 8(a) 

chemical-specific rule has not been found. EPA has not been able to identify a more efficient, 

less expensive, or more flexible means of obtaining the required data than the one currently 

being used. To the extent data are not CBI, all information collected is made available to the 

public through the public docket office. At the present time, EPA is not requiring firms to 

submit this information on one standard reporting form. Reporting facilities will be able to 

choose the format that best suits their reporting resources. TSCA section 8(a) chemical-specific 

rules typically require one-time reporting. As future data needs arise, EPA will consider the use 

of electronic or other types of reporting methods. EPA believes the flexibility already allowed in 

the reporting structure significantly eases burden.

5(c) Small Entity Flexibility

Section 8(a) of TSCA generally exempts small manufacturers and processors. However, 

under TSCA section 8(a)(3), EPA may require small manufacturers and processors to report or 

keep records if the substance or mixture is subject to a rule proposed or promulgated under 

TSCA sections 4, 5(b)(4), or 6 or with respect to which relief has been granted pursuant to a civil 

action brought under sections 5 or 7 of TSCA. All respondents to TSCA section 8(a) chemicalspecific rules, including small businesses, are granted flexibility in their reporting methods.

5(d) Collection Schedule

TSCA section 8(a) chemical-specific rules are generally one-time collections of specific 

information, usually regarding one chemical substance. Proposed TSCA section 8(a) chemicalspecific rules request comments. The comments are then addressed and incorporated as 

appropriate in the final rule, which specifies the reporting deadline. Generally, EPA requires that 

information be reported no sooner than 30 days after the effective date of a final rule.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

Wage rates including fringe benefits and overhead for three broad categories of labor 

(managerial, technical, and clerical) were used in this analysis. The labor categories and 

methods for estimating loaded wage rates were developed during previous studies. The basis for 

estimating wage rates for these purposes is the Bureau of Labor Statistics (BLS) Employer Costs 

for Employee Compensation: Private Manufacturing Industry by Occupation, December 2005. 

The data series used for this and other analyses is no longer published directly by the BLS, but 

the BLS continues to make this data available to EPA. Based on the BLS data, the average 

hourly wage rates (as of December 2005) are $38.22for managerial personnel, $31.02 for
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technical personnel and $15.73 for clerical personnel.

The benefits and overhead loading factors are calculated from the BLS data on the cost of 

benefits, with 17 percent of the average wage added for overhead. The overhead factor of 17 

percent is based on information provided by the chemical industry and chemical industry trade 

associations. The loaded hourly wage rates are $63.61 for managerial personnel, $53.02 for

technical personnel and $26.37 for clerical personnel, as shown in Table 1.

TABLE 1: LOADED HOURLY WAGE RATES BY LABOR CATEGORY

Labor Category

December 2005

Average Wages

December 2005

Benefits and Overhead

Loading Factor

December 2005

Loaded 

Hourly Rate

Managerial $38.22 1.66 $63.61

Technical $31.02 1.71 $53.02

Clerical $15.73 1.68 $26.37

Sources: Unpublished Employer Costs for Employee Compensation: Private Manufacturing Industry by Occupation, 

December 2005. Data received by Carol Rawie, US EPA, from Raphael Branch, US Bureau of Labor Statistics, May 

10, 2006. 

This ICR maintains the assumption of the previous ICR that on average four notices per 

year are submitted in response to one section 8(a) chemical-specific rule per year. Current labor 

rates and burden hours used to calculate cost to respondents are listed below.

 Labor Category Burden Hours Hourly Rate

 Managerial 9 to 29.5 $ 63.61

 Technical 17.5 to 98 $ 53.02

 Clerical 7 to 21 $ 26.37

6(b) Estimating Respondent Costs

The following are the tasks that managers, technical, and clerical personnel are expected 

to perform in preparing a notice. However, as discussed at the end of this section and presented 

in Table 1, not all respondents are likely to be required to perform all tasks under each labor 

category. Therefore, the ranges of labor hours presented below for each labor category (e.g., 9 to 

29.5 hours for managers) are the maximums and are based on the assumption that all tasks are 

performed for each notice.

Managerial Labor

1. Manufacturer identifies listed chemicals;

2. Assign principal technical contact person;
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3. Identify by-product;

4. Review marketing data;

5. Research the date of the initiation of manufacture or importation of the chemical;

6. Research occupational exposure, environmental release, health and environmental 

data, disposal methods;

7. Process, compile, and review information for accuracy, substantiate a claim of 

confidential business information.

In performing these tasks, managerial labor hours have been estimated to range from 9.5 

to 29.5 hours per TSCA section 8(a) chemical-specific rule. At $63.61 per hour for management 

labor times the range of hours predicted, [$63.61 x (9.5 to 29.5)], the range of cost for 

management work is $604 to $1,876 per notice resulting from a TSCA section 8(a) chemicalspecific rule. With an average of four notices per year for the three-year ICR period, the range of 

costs per year for managerial labor is [4 x ($604 to $1,876)] = $2,416 to $7,504.

Technical Labor

1. Identify chemical and trade name and chemical composition;

2. Identify by-product;

3. Describe use of chemical;

4. Report quantity manufactured or imported;

5. Research occupational exposures, environmental releases, health and environmental 

data, and disposal methods; 

6. Provide occupational description.

In performing these tasks, technical labor hours have been estimated to range from 17.5 

to 98 hours per notice resulting from a TSCA section 8(a) chemical-specific rule. At $53.02 per 

hour for technical labor, times the range of hours predicted, ($53.02 x [17.5 to 98]), a range of 

cost for technical work is estimated to be $928 to $5,196 per notice resulting from a TSCA 

section 8(a) chemical-specific rule. With four notices per year for a three-year period, the range 

of annual costs for technical labor is [4 x ($928 to $5,196)] = $3,712 to $20,784.
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Clerical Labor

1. Format research on occupational exposure, environmental releases, health and 

environmental data;

2. Format attachments;

3. Prepare Notice.

In performing these tasks, clerical labor has been estimated to range from 7 to 21 hours 

per notice resulting from a TSCA section 8(a) chemical-specific rule. At $26.37 per hour for 

clerical labor, times the range of hours predicted, ($26.37 x [7 to 21]), the range of cost for 

clerical work is estimated to be $185 to $554 per notice resulting from a TSCA section 8(a) 

chemical-specific rule. With four notices per TSCA section 8(a) chemical-specific rule, the 

range of costs per year for clerical labor is [4 x ($185 to $554)] = $740 to $2,216.

The cost to a respondent for filing a TSCA section 8(a) notice depends upon the various 

tasks performed. These tasks could include gathering the required data, preparing and 

submitting the TSCA section 8(a) notice, and possibly keeping records. Based on promulgated 

TSCA section 8(a) rules, EPA estimates that each respondent will submit one notice per TSCA 

section 8(a) chemical-specific rule. EPA anticipates issuing one TSCA section 8(a) rule per year 

and expects to receive an average of four notices per year.

The cost to a respondent for submitting a TSCA section 8(a) notice is a function of the 

number of hours and the hourly labor costs for the individuals developing and preparing the 

notice. The annual estimated range of cost to the respondent is $1,717 ($604 + $928 + $185) to 

$7,626 ($1,876 + $5,196 + $554) per notice, and $6,868 to $30,504 per TSCA section 8(a) 

chemical-specific rule (above estimates multiplied by four, the number of notices expected per 

rule.) However, as mentioned above, these figures are likely to overstate the true cost because 

not all respondents may be required to supply information regarding each activity. Thus, the 

average actual cost to the respondent will be lower than the $1,717 to $7,626 per notice estimate 

calculated above. The estimated frequency of each activity, along with total respondent cost and 

burden calculations, is presented in Table 1. The total cost to all respondents of reporting under 

a TSCA section 8(a) chemical-specific rule is estimated to range from $3,375 to $14,080 per 

year. On a per respondent basis, the annual cost is estimated to range from $894 to $3,520 per 

notice, based on four notices per year.
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Table 2. Total Annual Respondent Burden and Costs Associated with Preparing and 

Filing a TSCA Section 8(a) Notice

Activity

Managerial 

Hours 

$92.33/hr

Technical 

Hours 

$68.35/hr

Clerical 

Hours 

$27.24/hr

Notices 

per Year

Annual 

Burden 

Hours

Annual 

Costs

Manufacturer ID

and Principal 

Technical Contact

1 - 4 4 4 - 16 $254-

$1,018

Chemical and

Trade Name

1 - 4 3 3 - 12 $159-

$636

Chemical

Composition

0.5 - 2 4 2 - 8 $106-

$424

Byproduct ID 1 1 - 4 2 4 - 10 $233-

$551

Use Description 1 - 4 4 4 - 16 $212-

$848

Quantity

Manufactured

or Imported

1 - 4 4 4 - 16 $212-

$848

Marketing Data 1 - 2 2 2 - 4 $127-

$254

Date of Initiation

of Manufacture or 

Importation

0.5 4 2 $127

Occupational 

Exposure

1 - 4 2 - 16 1 - 3 2 8 - 46 $392-

$2,364

Environmental 

Release

1 - 4 1 - 8 1 - 3 2 6 - 30 $286-

$1,515

Occupational 

Description

1 - 10 1 1 - 10 $53-

$530

Health and Environmental Data2 - 8 8 - 40 1-3 1 11 - 51 $578-

$2,709

Disposal Methods 1 - 2 1 - 6 1 2 - 8 $117-

$445
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Attachments 2 - 6 1 2 - 6 $53-

$158

Preparation of

Notice

1 - 3 4 4 - 12 $105-

$316

Managerial/Legal 

Review of 

Submission

1 - 4 4 4 - 16 $254-

$1,018

Recordkeeping 1 - 3 4 4 - 12 $105-

$316

TOTAL 9.5 - 29.5 17.5 - 98 7 - 21 67 - 275 $3,375 -

$14,080

6(c) Estimating Agency Burden and Cost

The Agency has developed the following burden hour estimates for activities related to 

promulgating a section 8(a) Chemical Specific rule.

Activity Burden

o Industry/Public Assistance (answering 0.1 FTE

 questions regarding the rule)

o Data processing and systems support personnel 0.2 FTE

o Storage and Distribution 0.1 FTE

o Compliance monitoring 0.1 FTE

Total FTEs 0.5 FTE

The Office of Pollution Prevention and Toxics bases its burden hour and labor cost 

estimates on prior experience in gathering and processing information associated with other 

information collections. Because these activities involve a team approach, the Agency has used 

a composite burden hour estimate containing workers at various GS levels and calculated hourly

costs based upon the wage rate for a GS-12 Step 1. The 2006 annual salary for a GS-12 Step 1 in 

the Washington DC area is $65,048. The cost for 0.5 FTE is $32,524. Incorporation of an 

overhead and benefits factor of .6 yields a fully loaded cost of $52,038 to the Agency for

promulgating and supporting a TSCA section 8(a) chemical-specific rule. The full-time work 

year is considered to be 2,080 so that there are 1,040 burden hours associated with 0.5 FTE.
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6(d) Bottom Line Burden Hours and Costs

The following table displays the annual burden and costs borne by respondents and EPA 

associated with preparing, filing and reviewing a notice resulting from a TSCA section 8(a) 

chemical-specific rule.

Table 3. Annual Burden and Cost of a TSCA Section 8(a) Chemical-Specific Rule

Annual Burden Hours Annual Costs

Industry 67 to 275 $3,375 to $14,080

Agency 1,040 $52,038

6(e) Reasons for Change in Burden

The current request for renewal estimates a total annual burden to respondents of 275 

hours, which is unchanged from the previous ICR renewal.

EPA anticipates issuing one TSCA section 8(a) chemical-specific rule per year with an 

average of four respondents submitting notices per rule. EPA may promulgate more than one 

TSCA section 8(a) chemical-specific rule per year over the next three years. If EPA does this, 

the Agency will submit a technical amendment to OMB to reflect the change in estimated burden 

to the regulated industry and the government.

6(f) Burden Statement

The public burden for this collection of information is estimated to average 68.8 hours 

per response (one-quarter of maximum annual burden of 275 hours for four notices). Of the 68.8 

hours, 65.8 hours are associated with reporting tasks such as reviewing instructions, gathering 

the data needed, and completing and reviewing the collection of information. The remaining 

three hours are associated with recordkeeping. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information; adjust the existing ways to comply with any previously applicable 

instructions and requirements; train personnel to be able to respond to a collection of 

information; and transmit or otherwise disclose the information. An Agency may not conduct or 

sponsor such a request and a person or facility is not required to respond to a collection of 

information unless it displays a currently valid OMB control number. The OMB control 

numbers for EPA’s regulations in title 40 of the CFR, after appearing in the Federal Register, are 

listed in 40 CFR part 9 and included on the related collection instrument or form, if applicable.
To comment on the Agency’s need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID No. EPA-HQ-OPPT-2010-0488. The docket is available for public viewing at the 

Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). The EPA/DC 

Public Reading Room is located in the EPA West Building, Room 3334, 1301 Constitution Ave., 

NW., Washington, DC. The EPA/DC Public Reading Room is open from 8:30 a.m. to 4:30 p.m., 

Monday through Friday, excluding legal holidays. The telephone number for the EPA/DC 

Public Reading Room is (202) 566-1744, and the telephone number for the Pollution Prevention 

and Toxics Docket is (202) 566-0280. An electronic version of the public docket is available 

through the Federal Docket Management System (FDMS) at www.regulations.gov. Use FDMS 

to submit or view public comments, access the index listing of the contents of the public docket, 

and to access those documents in the public docket that are available electronically. Once in the 

system, select “search,” then key in the docket ID number identified above. Also, you can send 

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please 

include the EPA Docket ID No. EPA-HQ-OPPT-2010-0488 and OMB control number 2070-

0067 in any correspondence.