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Request for a Non-Substantive Change 

to an Existing Approved Information Collection

I. Introduction

What Information Collection Request (ICR) is EPA changing?

ICR Title: TSCA Section 5(a)(2) Significant New Use Rules for Existing 

Chemicals

ICR Numbers: EPA ICR No. 1188.11; OMB Control No. 2070-0038

What is the Current Status of this ICR?

This ICR is currently approved through 7/31/2016. The ICR currently identifies the information 

collections (ICs), responses per IC and burden subtotal per IC shown in Table 1. The total annual burden 

approved for this ICR is 736, with an estimated 98 responses per year.

Table 1. Currently Approved ICs under EPA ICR No. 1188.11

Information 

Collection

No. of 

Respondents

No. of 

Responses / 

Respondent

Responses 

Subtotal

Annual

Burden Hours 

per Response

Annual

Burden Hours 

per Activity

Per Firm Activities

Rule familiarization 4.24 1 4.24 0.83 3.52

CDX registration 

activities

 CDX registration 4.24 1 4.24 0.92 3.89

 ESA 4.24 1 4.24 1.75 7.42

 Pay.gov account 4.24 1 4.24 0.13 0.57

Preparation, 

submission, and 

recordkeeping for 

SNUN

4.24 1.65 7 92.2 645

Per SNUR Activities

Chemical verification 5 1 5 1.17 5.85

Notifying customers 

(per SNUR) 35 2 70 1 70.00

Totals

61.20 1.33 98.96 98.00 736.25
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Why is EPA Requesting a Non-Substantive Change?

EPA is taking direct final action to amend the Toxic Substance Control Act (TSCA) section 5 electronic 

reporting regulations at 40 CFR Parts 700, 720, 721, 723 and 725. These electronic reporting regulations 

establish standards and requirements for use of EPA’s Central Data Exchange (CDX) to electronically

submit Significant New Use Notices (SNUNs), other TSCA section 5 notices, and support documents to 

the Agency. The direct final action provides the user community with new methods for accessing the ePMN software, new procedures for completing the e-PMN form, and changes to the CDX registration 

process. The action is intended to further streamline and reduce the administrative costs and burdens of 

TSCA section 5 notifications for both industry and EPA.

II. Overview

EPA is amending the reporting procedures for the submission of SNUNs and other TSCA section 5 

notices and support documents to the Agency by mandating the use of an updated version of the e-PMN 

reporting software, the “Thin Client Version” (i.e., a cloud-based software system). Submitters must 

register and submit information electronically using the Agency’s Central Data Exchange (CDX). 

EPA receives significant new use notices under TSCA section 5(a)(2)

Section 5 of the Toxic Substances Control Act (TSCA), 15 U.S.C. 2604, authorizes EPA to determine 

that a use of a chemical substance is a “significant new use.” EPA must make this determination by rule 

after considering all relevant factors, including those listed in TSCA section 5(a)(2). Once EPA 

determines that a use of a chemical substance is a significant new use, TSCA section 5(a)(1)(B) requires 

persons to submit a notice to EPA at least 90 days before they manufacture, import or process the 

substance for that use. Regulations implementing significant new uses appear at 40 CFR part 721. TSCA 

section 5 notices, such as SNUNs, and support documents, are submitted electronically to the Agency 

via CDX. 

Once EPA receives a SNUN, EPA may take regulatory action under TSCA sections 5(e), 5(f), 6 or 7 to 

control the activities for which it has received a SNUN. If EPA does not take action, TSCA section 5(g) 

requires EPA to explain in the Federal Register its reasons for not taking action.

Persons who intend to export a substance identified in a proposed or final SNUR are subject to the 

export notification provisions of TSCA section 12(b). The regulations that interpret TSCA section 12(b) 

appear at 40 CFR part 707.

Does this change require a rulemaking?

Yes. EPA is issuing a direct final rule to amend the premanufacture notification regulations to mandate 

the use of an updated version of the e-PMN reporting software.

III. Description of Non-Substantive Changes

What are the changes that EPA is making to this ICR?

EPA is moving from a Thick Client software system to a “cloud–based,” or Thin Client software system. 

While EPA expects that this change in the software system will reduce the burden to all submitters of 

TSCA section 5 notices, this burden reduction is expected to be minimal and has not been quantified for 

this ICR change request. 
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A. Program Change: e-PMN Reporting Software Update

In January 2010, EPA issued a final rule requiring the use of e-PMN reporting software for the 

submission of Premanufacture Notices (PMNs) and other TSCA section 5 notices and support 

documents to the Agency using the Internet through EPA’s Central Data Exchange (CDX). The new 

version of the e-PMN software will operate as a “cloud,” or Thin Client, software system rather than as a 

downloadable, or Thick Client, software system. EPA expects that both the Agency and TSCA section 5

submitters will experience burden reductions as a result of the software update. The Thin Client Version 

will eliminate certain firewall and file submission size limitations, as well as reduce the potential for 

invalid submissions through built-in validation procedures. The Thin Client Version will also allow 

users to work offline using an Extensible Markup Language (XML) schema, which, in turn, allows them 

to later upload their information to the Thin Client Version and will make information readily accessible 

to registrants of the submitting company and their designated support persons. While EPA expects that 

this change will reduce the burden to all submitters of any TSCA section 5 notice, this burden reduction 

is expected to be minimal and has not been quantified for this ICR change request.

IV. Bottom Line Burden Changes

EPA does not expect a change in annual net burden as a result of the program change to the TSCA 

section 5 Significant New Use Notification regulations. New burden associated with rule familiarization

is estimated to remain at approximately 736 hours annually. These summary level changes are 

highlighted in Table 5, while Table 6 demonstrates the updated list of ICs associated with this collection 

and the related annual burden estimates.

Table 2. Bottom Line Burden Changes

Activity Summary

Burden Hour Change

Adjustments Program Changes

e-PMN Reporting Software Update 0 0

Total Burden Change 0
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Table 3. Updated ICs for OMB Control No. 2070-0038

Information 

Collection

No. of 

Respondents

No. of 

Responses / 

Respondent

Responses 

Subtotal

Annual

Burden Hours 

per Response

Annual

Burden Hours 

per Activity

Per Firm Activities

Rule familiarization 4.24 1 4.24 0.83 3.52

CDX registration 

activities

 CDX registration 4.24 1 4.24 0.92 3.89

 ESA 4.24 1 4.24 1.75 7.42

 Pay.gov account 4.24 1 4.24 0.13 0.57

Preparation, 

submission, and 

recordkeeping for 

SNUN

4.24 1.65 7 92.2 645

Per SNUR Activities

Chemical verification 5 1 5 1.17 5.85

Notifying customers 

(per SNUR) 35 2 70 1 70.00

Totals

61.20 1.33 98.96 98.00 736.25