January 27, 2012 

Page 1 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

Supporting Statement for a Request for OMB Review under 

The Paperwork Reduction Act 

1. Identification of the Information Collection 

 1(a) Title of the Information Collection 

Title: Final Rule Addendum to Partial Update of the TSCA Section 8(b) TSCA 

Inventory Data Base, Production and Site Reports 

EPA ICR No.: 1884.06 OMB Control No.: 2070-0162 

1(b) Short Characterization/Abstract 

 

As part of the Inventory Update Reporting (IUR) Modifications final rule, EPA is 

changing the identification of the regulation from IUR to Chemical Data Reporting (CDR). 

However, EPA is retaining the use of the IUR acronym throughout this document. The reader 

should recognize that where IUR is used to refer to the 40 CFR 711 regulations or to future IUR 

submission periods, IUR and CDR are synonymous. 

The following information collection request (ICR) addendum addresses the paperwork 

requirements contained in a final rule (RIN 2070-AJ43) that amends the information collection 

activities of the TSCA Inventory Update Reporting (IUR) program under the Toxic Substances 

Control Act (TSCA) (40 CFR Part 710). Under TSCA section 8(a) (15 USC 2607), the 

Environmental Protection Agency (EPA) is authorized to collect certain information on chemical 

substances manufactured or processed in the United States. In addition, under TSCA section 

8(b), the Agency is required to compile and keep current, via periodic inquiry, the TSCA 

Inventory of Chemical Substances (TSCA Inventory). The TSCA Inventory is a listing of 

chemical substances manufactured, imported, and processed for commercial purposes in the 

United States. The Office of Pollution Prevention and Toxics (OPPT) has used the IUR to update 

the basic chemical substance production information for selected larger volume chemical 

substances on the TSCA Inventory six times (every four years), beginning in 1986, and to collect 

additional information relating to the manufacture, processing, and use of those chemical 

substances, beginning in 2006. 

EPA has amended the IUR requirements in order to clarify the reporting requirements, 

improve the quality and utility of the data submitted, better match data collected with the 

Agency’s overall information needs, and where possible, reduce the paperwork burden on both 

regulated entities and EPA. Manufacturers (including importers) are required to use e-IURweb 

(the Agency-provided reporting tool) to submit a completed Form U (EPA Form 7740-8) 

electronically via the Internet. The 2012 IUR includes additional manufacturing, processing, and 

use exposure-related data elements, including the volume of the chemical substance used on the 

reporting site; the volume of the chemical substance directly exported; whether the chemical 

substance is being recycled, remanufactured, reprocessed or reused; and the production volume 

for calendar year 2010. Additional amendments to the 2012 IUR include changes to the reporting 

frequency from every five years to every four years; modifications to the method used to 
January 27, 2012 

Page 2 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

determine whether a manufacturer (including importer) is subject to IUR reporting for reporting 

cycles subsequent to the 2012 reporting cycle; production volumes for each year since the last 

principal reporting year (effective after 2012 IUR); modifications to reporting thresholds, 

including the phasing in of reporting thresholds for processing and use; elimination of the 25,000 

lb reporting threshold for certain chemical substances that are the subject to particular TSCA 

rules and/or orders; revisions to industrial classifications used; revisions to the list of commercial 

and consumer product categories; and modifications to situations in which confidentiality may be 

claimed and to the process for making such claims. 

 OPPT will use the updated IUR data in its chemical substance risk-management efforts. 

Individual sites manufacturing (including importing) chemical substances will submit the 

required information. The information will be stored electronically for reference by EPA staff 

and others. Within the constraints of confidentiality claims, the information will be made public 

through the Agency’s IUR website (http://www.epa.gov/iur). Further discussion of how the 

information is used, stored, and collected is included in this document. 

 The collection is expected to involve an average of approximately 4,153 respondents at 

an annual cost of $29 million during the ICR addendum period. The details of the paperwork 

burden and cost estimates are discussed in this document. 

2. Need for and use of the Collection 

2(a) Need/Authority for the Collection 

Under TSCA, EPA is required to identify, assess, and control risks of injury to human 

health and the environment posed by commercial chemical substances. Under TSCA section 

8(b), EPA is required to compile and keep current a complete list of chemical substances 

manufactured or processed in the United States. TSCA section 8(a) authorizes the Administrator 

to promulgate rules to provide for the maintenance and collection of records from manufacturers, 

importers, and processors of commercial chemical substances. Sections 8(a)(1) and (2) of TSCA 

also authorize the Agency to collect information on the chemical substance manufacturing and 

importing industry. EPA possesses broad discretion in determining the information to be 

reported under TSCA section 8(a). The IUR rule was codified at 40 CFR 710. EPA has moved 

the IUR rule to a new Part at 40 CFR 711. 

EPA modified the IUR rule1 to meet four primary goals: (1) to tailor the information 

collected to better meet the Agency’s overall information needs; (2) to increase its ability to 

effectively provide public access to the information; (3) to obtain new and updated information 

relating to potential exposures to a subset of chemical substances listed on the TSCA Inventory; 

and (4) to improve the usefulness of the information reported. EPA believes requiring electronic 

reporting; collecting comprehensive information for most reported chemical substances; and 

adjusting the specific reported information, the frequency the information is reported, and 

confidential business information (CBI) claim requirements will accomplish these goals.

 

1

 The final rule is titled “TSCA Inventory Update Reporting Modifications.” 
January 27, 2012 

Page 3 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

The IUR provides basic exposure-related manufacturing, processing and use information 

used by EPA and others in a wide range of Agency activities. EPA’s efforts to use the 2006 IUR 

data have identified areas where further improvements were needed to improve risk-screening 

capabilities. Screening level data need not be precise, but should be accurate and reliable enough 

for the Agency to develop screening-level exposure assessments. The 2012 IUR will provide 

more detailed information needed to better understand and interpret the IUR data, further 

enhancing the Agency’s ability to identify, screen, and manage potential chemical substance 

risks. Because exposure is a key component of risk, the IUR exposure-related information will 

allow OPPT to screen chemical substances based on the potential for risk in order to protect 

human health and the environment, as required by TSCA. The exposure-related data on 

manufacturing, processing, and use will potentially allow the Agency and others to avoid more 

burdensome regulatory requirements. These enhanced data will allow EPA to conduct a more 

effective and efficient screening level review of chemical substances to identify candidates for 

further evaluation. 

2(b) Practical Utility/Users of the Data 

 The modifications associated with reporting methods and changes to the reporting tool 

will ensure the information reported to EPA is accurate and in compliance with the IUR 

requirements. 

e-IURweb Reporting Tool 

Beginning with the 2012 submission period, EPA is requiring electronic reporting for all 

IUR submissions, including joint submissions and amendments. Persons submitting information 

under the IUR rule are required to use e-IURweb, the Agency-provided, web-based tool to 

complete Form U (the IUR reporting form). The information will be submitted electronically via 

the Internet, through EPA’s Central Data Exchange (CDX). Users of CDX are required to 

register with the system, including submitting an authorized signature agreement to EPA. 

The 2012 submission process is similar to that available for the 2006 IUR, when EPA 

provided an opportunity for IUR respondents to send their reports electronically, through CDX, 

on a voluntary basis. Approximately one-third of the 2006 submissions were filed through CDX, 

using the 2006 e-IUR downloadable software. The elimination of paper-based submissions in 

favor of electronic reporting, including the use of e-IURweb, is expected to greatly improve the 

reporting process, both for EPA and for manufacturers (including importers). 

The 2012 e-IURweb features several improved capabilities over the 2006 e-IUR 

software. These improvements include an enhanced validation system, which alerts users when a 

required field on the form is either missing information or contains certain kinds of potentially 

incorrect information. Other updates include automated chemical identity checks, using EPA’s 

Substance Registry Services (SRS), automated company and site identity checks, using EPA’s 

Facility Registry System (FRS), and the facilitation of joint submissions and amendments. 

Electronic submission will also ensure that IUR data complete a basic validation check, 

can be quickly incorporated into a database and ready for immediate Agency use, and will 
January 27, 2012 

Page 4 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

eliminate subsequent data entry errors which occurred with paper submissions. Furthermore, 

EPA believes the mandatory use of e-IURweb and CDX will reduce the reporting burden on 

industry by reducing both the cost and the time required to review, edit and transmit data to the 

Agency. 

 CDX Registration 

Each IUR submission must have an associated authorized official. The authorized official 

signs the certification statement and submits the IUR report via CDX. During the 2006 IUR, 

respondents were required to complete an electronic signature agreement (ESA) and to submit 

the agreement in hard copy with a wet ink signature to EPA in order to complete the CDX 

registration. For 2012 IUR reports, EPA modified the 2006 ESA to identify more clearly the 

individual(s) required to sign the agreement. To register in CDX, the CDX registrant (also 

referred to as “Electronic Signature Holder”) will complete ESA form. For identity 

authentication, the registrant will complete the ESA, and either submit the form electronically or 

mail the form to EPA. Once EPA receives the form, EPA will activate the registrant’s CDX 

account and send a notification via email. 

 A company may need or desire to have more than one individual complete an electronic 

signature agreement, so that more than one person can add information to an original IUR 

submission. Persons submitting supplemental information for an IUR submission on behalf of a 

company will also need to register with CDX by signing an ESA. The company official can 

authorize an unlimited number of support registrants and support registrants can work with an 

unlimited number of company officials. A support registrant may be an employee of the 

company, an outside consultant for the company, or an authorized representative agent for the 

company. While this individual is not able to sign the certification statement required for the 

initial IUR submission, he or she will be able to provide additional information, if needed, using 

CDX. For 2006 and prior IUR submissions, support registrants were not able to provide 

additional information electronically. 

 Data Elements for IUR Submissions 

The IUR information collection is the only mechanism through which EPA can collect 

basic information on commercial chemical substances listed on the TSCA Inventory, including 

production volume and other manufacturing (including importing) processing, and use exposurerelated data. This information collection is necessary because these data are not otherwise 

available. EPA will use the information it is collecting in the following ways: 

(1) U.S. Parent company identification information: Company identification 

information is collected already by the current IUR. EPA will require reporting of 

additional company identification information associated with the location of the 

company, and will clarify that the company information is to be for the U.S. parent 

company associated with the reporting plant site. These data will help ensure the 

company information is consistently provided. 

 
January 27, 2012 

Page 5 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

 (2) Manufacturing-related information: 

• The production volume for calendar year 2010: The one-year snapshot of 

production volume provided by the 2006 IUR does not provide an accurate picture 

of the chemical substances in commerce, and may provide an erroneous view of the 

exposure scenarios associated with a particular chemical substance. The high turnover of reported chemical substances from one submission period to the next 

indicates a dynamic, changing industry. EPA has received comments from industry 

concerning the year-to-year changes that occur for chemical substance production 

that may affect IUR reporting. For the 2012 IUR, manufactures (including 

importers) will need to report the production volume for calendar year 2010. This is 

in addition to the full manufacturing, processing, and use information for the 

principal reporting year (i.e., 2011). For IUR collections subsequent to the 2012 

IUR collection, EPA will require reporting of production volumes for each of the 

years since the last principal reporting year. EPA will use these data for chemical 

manufacturing, and processing and use trend analyses; and for the assessment of the 

effectiveness of Agency and public programs, among other uses. 

• The production volume of a manufactured (including imported) chemical substance 

used at the reporting site: This data element replaces the data element indicating 

that a chemical substance is site-limited. This new data element identifies whether a 

chemical substance is used by the reporting site. Either domestically manufactured 

or imported chemical substances can be reported as used at the reporting site. This 

information is related to potential exposures associated with the on-site volumes, 

and will provide the Agency with more accurate information for exposure 

assessments and other data analyses. 

• Whether an imported chemical substance is physically at the reporting site: This 

data element will enable the Agency and others to better assess manufacturingrelated potential exposures, thereby enabling more accurate information for 

screening-level analyses and other uses of the IUR data. 

• The production volume directly exported and not domestically processed or used: 

This data element will allow EPA to better identify the completeness of the reported 

processing and use information, by indicating the proportion of the production 

volume potentially covered by the reported processing and use information. IUR 

processing and use information is required only for domestic use situations, and is 

not required for any volumes directly exported. 

• Whether a manufactured (including imported) chemical substance, such as a 

byproduct, is being recycled, remanufactured, reprocessed, or reused: This data 

element will provide valuable information for Agency and public programs that 

encourage industry to find uses for wastes rather than disposing of the wastes, such 

as in a landfill. 
January 27, 2012 

Page 6 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

 These data will also be used in other ways, such as in chemical substance exposure and risk 

screening, testing and/or priority setting, and exposure estimation required by the Interagency 

Testing Committee (ITC) under TSCA section 4; for EPA monitoring activities of newly 

manufactured substances that have completed PMN review under TSCA section 5(a); to support 

the development of TSCA regulations under section 6; and to measure potential human and 

environmental exposure under TSCA section 8(e). Each data element corresponds to a data point 

necessary for basic risk-screening. 

Under the 2006 IUR rule, only manufacturers (including importers) of larger-volume 

chemical substances were required to report processing and use information. Under the final rule, 

the reporting threshold for processing and use information will be phased in, such that the 

threshold is 100,000 lb for the 2012 IUR and 25,000 lb for the next IUR collection in 2016. For 

2012, for example, respondents who manufacture (including import) a chemical substance in 

volumes of 100,000 lb or more at a single site are required to report processing and use 

information, unless the chemical substance is partially exempt. This change provides exposurerelated processing and use information to EPA and others for moderate-volume chemical 

substances, enabling the Agency to address such chemical substances in the same manner as the 

higher-volume chemical substances. 

(3) Industrial processing and use data: The final rule does not add any industrial 

processing and use data elements. The industrial function categories have been revised to 

better identify the functions of the chemical substances. The North American Industrial 

Classification System (NAICS) codes have been replaced with industrial sector (IS) 

codes. The IS codes reduce the number of choices available to the respondent, thus 

streamlining the reporting process and making the data easier to use. 

(4) Consumer and commercial end-use exposure data: EPA added two data elements: an 

indication of consumer or commercial use and the number of commercial workers. These 

data will be used to determine exposure potential based on consumer or commercial 

populations. These two populations are very different from each other, and the ability to 

distinguish uses between the two enables better exposure-based screening of the chemical 

substance. The number of commercial workers is needed to better assess the size of the 

commercial population reasonably likely to be exposed to a chemical substance. In 

addition, the product categories have been revised to better identify the uses of chemical 

substances. 

Special Considerations for Joint Submitters

In certain situations IUR submitters are allowed to report the IUR information jointly 

with the supplier of the chemical substance for which the submitter is reporting. For example, 

importers may not know the specific chemical identity of the imported TSCA Inventory 

substance because the foreign supplier chooses to keep the information confidential. In addition, 

a manufacturer may not know the specific chemical identity of the substance being manufactured 

because the supplier of a reactant used to manufacture the substance chooses to keep the 

information confidential. In such situations, the manufacturer (including importer) is still 

responsible for ensuring that the IUR information is submitted to EPA and may do so by 
January 27, 2012 

Page 7 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

submitting a joint report. For example, in the case of an imported substance, the U.S. importer, as 

the primary submitter, completes the majority of the required information on Form U, and 

provides a trade name in Part II.2.A.4 to identify the chemical substance. The primary submitter 

then contacts the foreign supplier, who is the secondary submitter, to notify them of the need to 

report the specific chemical identity information directly to EPA in the joint submission section 

(Part IV) of Form U, using the reporting tool, e-IURweb. For 2006 and prior IUR submissions, 

submitters were not able to submit joint reports electronically. EPA has added Part IV to Form U 

to accommodate joint submissions. Because signatures are required by each party of a joint 

submission, they must each register with CDX, complete their own sections on Form U, and 

submit their own sections of the same report electronically to EPA. The secondary submitter will 

not be able to access the information provided by the primary submitter and vice versa. The 

reporting tool will match both submissions based upon company and chemical information 

provided by the manufacturer (including importer), acting as a primary submitter, and by the 

supplier, acting as a secondary submitter. The information provided by the primary and 

secondary respondents will be saved and combined as one joint submission. EPA will process 

the joint submission once all Form Us are received and matched by the Agency. 

This information collection will allow EPA to connect submissions from the primary 

submitter and secondary submitter and to request clarification from the secondary submitter if 

needed. The data EPA will collect will be utilized in the following ways: 

(1) Joint Submission Information (primary registrant only): The primary submitter 

provides only a trade name or other designation to identify the chemical substance 

being reported. Therefore, the requested data are needed by the Agency to identify the 

chemical substance correctly and provide the company name and complete mailing 

address of the secondary submitter.

(2) Secondary Company Identification Information: These data identify the secondary 

submitter’s company name and the complete mailing address of the company. The 

information provided will help ensure that the company information is provided 

consistently, and will be used to associate the secondary submitter’s company with 

the primary submitter’s company and site plant. 

(3) Technical Contact Information: The company’s technical contact information will 

provide EPA with the name and complete mailing address of the person who will be 

able to answer questions EPA may have about the reported chemical substance. 

(4) Primary Company Information: These data will provide the trade name and Unique 

Identifier for Joint Submissions number the primary submitter sent to the secondary 

submitter. 

(5) Trade Product Identification Information: These data will identify the primary 

submitters’ company name, site name, and site address, as well as the CAS Registry 

Number, the appropriate specific chemical identities, and product composition. These 

data are needed by EPA to combine the secondary submitters’ chemical-specific 
January 27, 2012 

Page 8 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

information with the primary submitters’ information to result in a complete IUR 

submission. 

Information secured through the IUR collections is used increasingly by a wide variety of 

governmental and non-governmental users. Consistent with Congress’s intent that TSCA data be 

used to facilitate any government public health and environment efforts, IUR data have been 

used by EPA’s Office of Water, Office of Solid Waste and Emergency Response, and Office of 

Air and Radiation to identify and characterize particular chemical substances. Non-confidential 

IUR data are incorporated into a number of databases and products maintained by organizations 

including Right-To-Know-Net and INFORM2

. IUR data were used to identify chemical 

substances of particular concern for the National Institutes of Health. Non-confidential IUR data 

were also released to selected states to help them identify facilities manufacturing suspected 

endocrine disrupters. 

 

Data reported under the 2012 IUR will enhance the capabilities of the Agency and other 

Federal agencies to ensure risk management actions are taken on chemical substances posing the 

most concern. More in-depth reporting of the processing and use data, more careful 

consideration of the need for confidentiality claims, and adjustments to the specific data elements 

will better support a robust risk assessment and management program. By enhancing the data 

supplied to Agency risk-screening programs, EPA expects to more effectively and expeditiously 

identify and address potential risks posed by chemical substances and provide improved access 

and information to the public. 

 EPA will also use the information submitted through the 2012 collection to update the 

Agency’s comprehensive chemical manufacturing, exposure, and use database, maintained as 

part of the Manage Toxic Substances (MTS) system. IUR data prior to the 2006 collection are 

maintained in a series of databases known as the Chemical Update System (CUS). The MTS IUR 

data, combined with CUS and the Chemicals in Commerce Information System (CICIS)

database, serves as a primary source of information about the chemical industry for EPA, as well 

as other Federal Agencies. The MTS IUR data provide information about the chemical 

substances used, where they are produced, how much is produced or imported, and how they are 

processed and used. The chemical industry is dynamic, as demonstrated by the approximately 30 

percent change in chemical substances reported from one IUR submission period to the next; 

therefore continual updating of the database is essential. 

 

3. Non duplication, Consultations, and Other Collection Criteria 

3(a) Non duplication 

 The data included in this information collection (i.e., production volume, chemical 

manufacture, exposure, and processing and use data) are not collected comprehensively or 

systematically at the national level. There are a variety of sources for certain data elements, but 

the sources are either incomplete or incompatible. 

 

2

 INFORM is a nonprofit environmental research organization.
January 27, 2012 

Page 9 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

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

The notice of proposed rulemaking, which served as the public notice for this ICR 

pursuant to 5 CFR 1320.11, published on August 13, 2010 (75 FR 49656). During the public 

comment period for the notice of proposed rulemaking, EPA received comments about the 

Agency's need for and practical utility of the proposed data elements; when reporting should be 

required; reporting frequency; the estimated costs and burdens associated with the updated 

reporting requirements, and mandatory electronic reporting. EPA considered these comments 

when formulating the final rule. Changes made by EPA for the final rule in response to public 

comments include: 

• A 6-month delay to the start of the reporting period for the 2011 principal reporting year 

in order to provide submitters with additional time to gather all of the information 

required by the final rule and prepare it for submission to EPA. 

• Lowering, instead of altogether eliminating, the reporting threshold for specific regulated 

chemical substances and phasing-in that lowered threshold so that it applies beginning 

with the 2016 reporting period instead of the 2012 reporting period. 

• Not finalizing a proposed requirement that electronic signature agreements be submitted 

with a notarized signature. 

EPA summarized the public comments and the Agency's response in the preamble to the 

final rule, and included a response to public comments document in the rulemaking docket 

(Docket ID EPA-HQ-OPPT-2009-0187), which can be accessed electronically at 

http://www.regulations.gov. 

3(c) Consultations 

In addition to the public notice and comment period, OMB regulations, at 5 CFR 

1320.8(d)(1), require agencies to consult with potential ICR respondents and data users about 

specific aspects of an ICR before the agency submits the ICR to OMB for review and approval. 

In accordance with this regulation, EPA solicited consultation feedback from nine potential 

respondents and data users with respect to this final rule ICR 

3(d) Effects of Less Frequent Collection 

EPA has returned the reporting frequency to every four years, which was the frequency in 

effect from 1986 to 2006. In an effort to reduce the reporting burden associated with the 2003 

amendments, EPA had changed the reporting frequency to every five years. While the less 

frequent reporting does reduce burden, a review of the 2006 IUR reporting has revealed an 

approximately 30 percent change in the chemical substances that are reported from one 

submission period to the next. EPA now believes that reporting every five years does not provide 

data sufficiently current to meet Agency and public needs and now considers every four years to 

be the minimum acceptable frequency. In addition, the IUR Modifications proposed rule 

requested comment on even more frequent reporting. Comments from industry representatives 

led EPA to believe that more frequent reporting creates efficiencies, both for the respondent and 
January 27, 2012 

Page 10 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

for EPA. With more frequent reporting, companies will be able to establish standard systems and 

practices to collect the required information. 

 The Agency needs to be able to make accurate chemical substance risk management 

decisions in a timely and cost effective manner, especially because alternative data sources do 

not exist for these data. The effect of less frequent collection of these data is to diminish 

significantly the Agency’s ability to understand the chemical industry and monitor the 

production levels of chemical substances manufactured (including imported) in the United 

States. As described above, the IUR data demonstrate that chemical industry product lines and 

manufacturing in the United States change substantially from one submission period to the next. 

The Agency needs up-to-date information in order to fulfill its mandate to keep the TSCA 

Inventory current under section 8(b) of TSCA; collecting the data every five years means the 

Agency is working with data which are potentially six or more years old, and therefore, cannot 

be considered current. 

 Less frequent collection could result in EPA using outdated information in its decision 

making. For example, changing market conditions, batch processing, or the development of new 

uses for the chemical substance can cause production volumes or chemical substance uses to 

change from one year to the next. Companies buy and sell plant sites, and the chemical 

substances produced at a site can change. Based on past IUR reporting, the Agency would be 

working with the IUR data which approximately 30 percent of the chemical substances known to 

be in commerce at volumes of 25,000 lb or more may not actually be in commerce at those 

levels. 

 3(e) General Guidelines 

 This collection does not exceed any of the Paperwork Reduction Act guidelines at 5 CFR 

1320.6, with the exceptions listed below. 

 The record retention period of this collection is five years, as specified in 40 CFR 710.57, 

exceeding the PRA maximum of three years. This is necessary to ensure companies retain 

records long enough to facilitate completion of Form U (EPA Form 7740-8) in the next 

collection, which is in four years and to allow EPA’s enforcement activities to overlap two IUR 

reporting cycles. 

 Confidential Business Information (CBI) claims limit access to the IUR data, especially 

by the public. EPA recognizes that some information submitted to the Agency is legitimately 

confidential business information; because of this, EPA’s review of CBI data is an inherently 

governmental function that EPA must perform to protect human health and the environment. 

 

3(f) Confidentiality

 Submitters may claim information reported to EPA under this rule as confidential if such 

information reveals the submitter’s trade secrets or proprietary information as defined by TSCA 

section 14 and existing TSCA regulations. EPA has long-established procedures for handling, 

storing, processing, and disposing of TSCA confidential information. Transfers of this 
January 27, 2012 

Page 11 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

information to other governmental agencies can be made only if the other agency agrees to 

adhere to all TSCA confidentiality provisions. EPA will maintain standard CBI procedures to 

protect any confidential, trade secret, or proprietary information from disclosure in accordance 

with EPA’s confidentiality regulation, 40 CFR Part 2, Subpart B. 

3(g) Sensitive Questions 

 This collection does not include questions of a sensitive nature. 

4. The Respondents and the Information Requested 

4(a) Respondents/NAICS Codes 

 The regulated community consists of companies manufacturing or importing chemical 

substances listed on the TSCA Inventory and regulated under TSCA section 8. In general, the 

industry segments that compose the regulated community for the rule are those that produce or 

import organic and inorganic chemical substances. Most respondents previously reported 

information under the IUR. The Agency’s previous experience with IUR collections has shown 

that the majority of the respondents affected by this collection activity are from the following 

North American Industrial Classification System (NAICS) code categories: 

 325 - Chemical Manufacturing (including importing) 

 324 - Petroleum and Coal Product Manufacturing (including importing) 

 The subsectors identified above represent the designation of sites that likely would be 

subject to IUR reporting. However, activities at these sites may vary, making identification of the 

regulated community more difficult. For example, NAICS codes reflect a site’s primary activity, 

omitting substantial participation a company may have in other industry activities. Second, 

NAICS codes selected by U.S. parent companies reflect the parent company’s primary activity, 

even though many U.S. parent companies are primarily holding companies with small 

subsidiaries. Each of these small subsidiaries may belong in a completely different industry 

classification based on its own primary activity. Information on U.S. parent company NAICS 

codes does not provide a very accurate characterization of the types of sites subject to reporting, 

and facilities that do not fall under these categories must still report if they meet the reporting 

criteria. 

 Generally, TSCA section 8 excludes small manufacturers (including importers) from 

reporting. EPA defines small manufacturers (including importers) for purposes of IUR and 

certain other reporting in 40 CFR 704.3. 

 In addition to the anticipated respondents listed above, manufacturers (including 

importers) of byproducts are required to report under the IUR rule. Byproduct manufacturers 

(including importers) may be listed under a different primary activity for a site, such as NAICS 

codes 22, 322, 331, and 3344; e.g., utilities, paper manufacturing, primary metal manufacturing, 

and semiconductor and other electronic component manufacturing. For purposes of the IUR, a 
January 27, 2012 

Page 12 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

byproduct is a chemical substance produced without a separate commercial intent during the 

manufacture, processing, use or disposal of another chemical substance or mixture (40 CFR 

704.3). Such a chemical substance, like any other manufactured chemical substance, is subject to 

IUR reporting if it is manufactured, is listed in EPA’s Master Inventory File, is not otherwise 

excluded from reporting, and its manufacturer is not specifically exempted from IUR reporting 

requirements. For instance, a manufacturer (including importer) that uses a chemical substance in 

the production of an article may produce a byproduct substance that is chemically different from 

the starting substance; the manufacturer (including importer) therefore may incur reporting 

obligations under the IUR for that byproduct. While some manufacturers (including importers) 

of byproducts may not have reported to the IUR in the past, they should be aware now of their 

reporting obligations under the IUR rule. 

4(b) Information Requested 

(i) Reporting Threshold for Certain Regulated Chemicals 

Under the final rule, EPA eliminated the 25,000 lb threshold for certain chemical 

substances that are: 

• The subject of a rule proposed or promulgated under TSCA section 5(a)(2), 5(b)(4), or 6, 

• The subject of an order issued under TSCA section 5(e), or 

• The subject of relief that has been granted under a civil action under TSCA section 5 or 7. 

Beginning with the 2016 reporting period, respondents who manufacture (including 

import) a chemical substance in volumes of 2,500 lb or more at a site are required to report 

manufacturing information on these chemical substances. Chemical substances that are the 

subject of these particular TSCA actions are of demonstrated high interest to the Agency. This 

change will help to ensure the availability of current information when the Agency has expressed 

a concern in the form of regulatory action on those chemical substances manufactured below 

25,000 lb EPA will use the IUR data associated with these regulated chemical substances to 

monitor chemical substance production and compliance with the rules. 

(ii) Data elements, including record keeping requirements 

 The IUR data elements are related to or indicative of three components of exposure. 

These components are: (1) the number of ecosystems or size of human populations potentially 

exposed, (2) the potential human or environmental exposure concentrations, and (3) the 

frequency and duration of potential exposures. The data enhances EPA’s ability to evaluate each 

of these components of exposure. Respondents are required to submit certain known or 

reasonably ascertainable manufacturing, processing, and use exposure-related information. For 

the 2006 IUR, respondents were required to submit the processing and use information to the 

extent it was readily obtainable; the IUR Modifications rule standardizes all of the submitted 

information to the single “known to or reasonably ascertainable by” reporting standard. 

Using e-IURweb, individuals report the data elements as follows (the following list 

identifies new or revised data elements and does not address the full data requirements): 
January 27, 2012 

Page 13 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

• Authorized Company Official’s e-mail Address. The e-mail address of the company 

official authorized to sign and submit the IUR Form U.

• U.S. Parent Company Name and Address. The name and mailing address of the U. S. 

parent company, the requirement that the parent company reported be the U.S. parent 

company is part of the IUR Modifications rule. The parent company name is already 

required by the IUR. This is not a new requirement; rather the change better identifies 

the correct company name.

• Manufacturing Information. Information required for the 2012 submission period and 

for subsequent submission periods vary. 

o For the 2012 submission period, any person who manufactured (including 

imported) for commercial purposes 25,000 lb or more of a reportable chemical 

substance at any single site owned or controlled by that person during the 

principal reporting year (i.e., calendar year 2011) is subject to reporting. 

These persons must report the total annual volume (in pounds) of each 

reportable chemical substance manufactured or imported at each site for 

calendar years 2010 and 2011. 

o For the submission periods subsequent to the 2012 submission period, any 

person who manufactured (including imported) for commercial purposes 

25,000 lb or more of a reportable chemical substance - or 2,500 lb or more of 

any reportable chemical substance that is the subject of a rule proposed or 

promulgated under TSCA section 5(a)(2), 5(b)(4), or 6, or is the subject of an 

order in effect under TSCA section 5(e) or 5(f), or is the subject of relief that 

has been granted under a civil action under TSCA section 5 or 7 - at any 

single site owned or controlled by that person during any calendar year since 

the last principal reporting year (e.g., for the 2016 submission period, consider 

calendar years 2012, 2013, 2014, and 2015, given that 2011 was the last 

principal reporting year) is subject to reporting. These persons must report the 

production volume for each of the years since the last principal reporting year 

(e.g., for the 2016 submission period, report the production volume for each of 

the years: 2012, 2013, 2014, and 2015). 

o Regardless of submission period, if the reporting thresholds are met in any 

given year (2012-2015), submitters must also provide the volume of the 

reported chemical substance used at the reporting site; whether an imported 

chemical substance is physically at the reporting site; the production volume 

directly exported and not domestically processed or used; and whether a 

manufactured (including imported) chemical substance, such as a byproduct, 

is being recycled, reused, reprocessed, or remanufactured. 

• Processing and Use Information. For the 2006 IUR, only those manufacturers 

(including importers) of chemical substances with production volumes of 300,000 lb 

or more were required to report processing and use information. For the IUR 
January 27, 2012 

Page 14 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

Modifications final rule, the reporting threshold for processing and use information 

will be phased in, such that the threshold is 100,000 lb for the 2012 IUR collection 

and 25,000 lb for subsequent IUR collections (e.g. 2016 IUR). Respondents are to 

report this information for all reported chemical substances, unless the chemical 

substance is specifically partially exempted. 

• Industrial Processing and Use Data. For the 2006 IUR, respondents were able to 

select up to 10 unique combinations of the type of process or use (code), NAICS code 

associated with the industrial use, and industrial function category. The IUR 

Modifications rule revised the list of industrial function categories and replaced the 

NAICS codes with Industrial Sectors.

• Consumer and Commercial Use Data. For the 2006 IUR, respondents were able to 

select up to 10 consumer and commercial product categories. The IUR Modifications 

rule revised the list of consumer and commercial product categories. The respondent 

must indicate whether the use is consumer, commercial or both, and, if commercial, 

the number of reasonably likely to be exposed commercial workers must be reported 

as a range. 

 Joint Submissions 

 Joint submissions are allowed only in those instances where a supplier will not disclose to 

the respondent the specific chemical name of the imported TSCA Inventory chemical substance 

or of a reactant used to manufacture the TSCA Inventory substance. This may happen, for 

instance, when a company is importing a mixture under a trade name, and the foreign 

manufacturer does not want to reveal the components in the mixture. (See Special 

Considerations for Joint Submitters in section 2b, above.) Changes to the IUR make it easier for 

respondents to use electronic reporting for both the primary and the secondary portions of a joint 

submission. In addition to signing the certification statement and completing Parts I, II, and III, 

primary respondents will report on data elements in Part II, Blocks 2.A.5 through 2.A.12, on 

Form U as follows: 

• Joint Submission Information. Trade name of the chemical substance being reported, 

secondary respondent name, and complete mailing address (city, state/province, zip 

code, and country (if applicable)). 

 Secondary submitters will register with CDX as secondary authorized submitter or a 

secondary support registrant. . They will provide the primary company’s information and the 

trade product name, supplied to them by the primary submitter, to gain access to the Form U 

containing information specific to the trade product name. After the secondary submitter is 

granted access to the form, they will report on data elements in Part IV on Form U as follows: 

• Certification. The company official must certify by signature and date that to the best 

of his/her knowledge and belief: 1) all information entered on Form U has been 

completed in compliance with the regulatory requirements; and 2) any confidentiality 

claims are true and correct as to that information for which they have been asserted. 
January 27, 2012 

Page 15 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

• Secondary Company Information. The secondary company name and complete 

mailing address (city, state, zip code, and country (if applicable)). 

• Secondary Technical Contact Information. The technical contact name, phone 

number, complete mailing address (city/town, state/province, zip code, and country (if 

applicable)), and email address. 

• Primary Company Information. Trade name and Unique Identifier for Joint 

Submissions number provided the primary submitter sent to the secondary submitter. 

• Trade Product Information. The trade product name, chemical name, CAS Registry 

Number, ID code, and percentage of each chemical substance component of a trade 

product. 

(iii) Submitter Activities/Information Collections (ICs) 

 EPA identified the following ICs in the currently-approved ICR (EPA ICR No. 1884.04) 

for activities that submitters would complete when complying with the rule: 

• Compliance Determination; 

• Rule Familiarization; 

• Report Preparation and Submission – Partial Reports; 

• Report Preparation and Submission - Full Reports; and 

• Recordkeeping. 

As a result of the final rule, EPA will include a new IC addressing the initial paperwork 

activities a company needs to complete in order to be able to submit reports electronically 

through CDX. EPA also will incorporate recordkeeping activities into the ICs that address the 

preparation and submission of partial and full reports, rather than include them as a stand-alone 

IC (see Table 1). 
January 27, 2012 

Page 16 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

Table 1: Information Collections (ICs) for IUR Reporting 

Information 

Collection 

Description 

Compliance 

Determination 

Determine whether reporting is required for a chemical substance manufactured 

(including imported) at a particular site, based on the chemical substance’s 

production volume and the applicability of certain reporting exemptions. 

The 2012 rule modifies the method used to determine whether a manufacturer 

(including importer) is subject to IUR reporting. Reporting is required if the 

production volume of a chemical substance met or exceeded the 25,000 lb 

threshold in the 2011 principal reporting year for the 2012 submission period, 

and in any calendar year since the last principal reporting year in future 

reporting cycles 

Rule Familiarization Become familiar with the full requirements of the rule, which entails reading the 

rule, understanding the various reporting and administrative requirements, and 

determining the manner in which reporting requirements will be met for each 

chemical substance. 

CDX Registration 

Activities 

The 2012 rule requires electronic reporting, and therefore requires that all 

submitters complete the CDX registration process. As part of registering with 

CDX, each submitter will provide identifying information that will comprise all 

or most of the information requested in Part I of Form U (EPA Form 7740-8). 

This information will then be pre-populated whenever the submitter prepares a 

partial or full report. 

In order to submit electronically to EPA via CDX, the authorized official, who 

will be signing and submitting the site’s IUR Form U, must register with CDX 

and must submit an ESA. This is the same process required for electronic 

submissions for the 2006 IUR. 

Once the registration process is complete, the registered individual will be able 

to access the e-IURweb reporting tool. 

Prepare and Submit 

Report, and Maintain 

Records- Partial 

Report 

Compile the required information, determine the CBI status of information and 

fulfill appropriate substantiation measures, and use e-IURweb to complete and 

submit only Parts I and II (and Part IV, if a joint submission) of Form U (EPA 

Form 7740-8) for chemical substances specifically listed in the regulation for 

which there is a partial reporting exemption. Retain all records related to the 

submission for five years after the submission period. 

Prepare and Submit 

Report, and Maintain 

Records- Full Report 

Compile the required information, determine the CBI status of information and 

fulfill appropriate substantiation requirements, and use e-IURweb to complete 

and submit Parts I and II for chemical substances manufactured (including 

imported) in volumes of 25,000 lb or more (or 2,500 lb or more, if applicable), 

and Part IV, if a joint submission, of Form U (EPA Form 7740-8). Complete 

part III for chemical substances manufactured (including imported) in volumes 

of 100,000 lb or more (and Part IV, if a joint submission) of Form U (EPA 

Form 7740-8). Retain all records related to the submission for five years after 

the submission period. 
January 27, 2012 

Page 17 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

5. The Information Collected–Agency Activities, Collection Methodology, and 

Information Management

 

 5(a) Agency Activities

 The activities routinely conducted by EPA related to the processing, analysis and storage 

of the information collected under this rule include the following: 

• Review and verify forms as they are received; 

• Answer submitter questions and provide any necessary assistance; 

• Process submissions for inclusion in IUR database; 

• Review requests for confidentiality in the submissions; 

• Maintain the database; and 

• Distribute the data. 

5(b) Collection Methodology and Management 

 The next IUR collection will occur in 2012. All manufacturers (including importers), 

except for those defined as “small manufacturers” by EPA’s regulations, are required to submit 

information on every substance subject to the 2012 rule that they manufacture (including import) 

in quantities that meet or exceed the IUR thresholds. The collection will occur every four years. 

 (i) Collection Methodology

 Submitters are required to submit information associated with this data collection 

electronically via the Internet using e-IURweb and CDX. The 2006 IUR allowed and encouraged 

electronic reporting, thus providing both submitters and the Agency the opportunity to test an 

electronic reporting system. Comments from submitters and lessons learned from the collection 

of paper, CD, and electronic submissions were used to develop the 2012 collection methodology. 

Some of the changes to this methodology are regulatory and are included in the IUR 

Modifications Final rule; others are process-oriented or internal to EPA or the respondent. 

 Potential submitters were notified of the need to report in three ways: (1) EPA published 

a Federal Register notice, (2) email notices were sent to previous IUR submitters, and (3) articles 

were published in the trade press. Reporting materials, including a non-submission version of the 

e-IURweb reporting tool and a variety of guidance documents (Instruction Manual, Q&As, Case 

Studies), are available on EPA’s IUR website. Submitters also can obtain these materials from 

the TSCA Hotline. Submitters obtain the submission version of the e-IURweb reporting tool as 

part of the CDX registration process, as described in section 4 of this document. 

EPA will receive all IUR submissions electronically. The CDX registration process, 

required for all submitters, will provide a user ID which the submitter will use to access eIURweb. 

Information quality and validation begins with the e-IURweb reporting tool, which is 

programmed to help the submitter provide the information required, in the correct format as 
January 27, 2012 

Page 18 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

required by the IUR rule. Use of e-IURweb will eliminate many of the problems with incorrect 

chemical substance identifications experienced in the past by providing a current listing of the 

TSCA Inventory chemicals and their associated identification numbers. Other respondentgenerated errors, such as incorrect codes, have also been eliminated due to the use of techniques 

such as drop-down menus, restrictions on the specific information that can be entered, and errorchecking algorithms. 

Mandatory IUR reporting via the Internet is the most efficient collection method for 

submitters and EPA. Submitters receive almost immediate notification that EPA has received 

their submission, and EPA is able to upload the information directly into the IUR database, 

which improves the efficiency of EPA’s data receipt and processing activities. This collection 

method also eliminates the introduction of errors by avoiding the need to scan or key-enter data 

submitted on paper or CD. Additional validations have been programmed into the data-entry 

system to further ensure the quality of the data. 

 To aid persons subject to this information collection, the Agency’s TSCA and CDX 

Hotlines are available to answer questions regarding the IUR requirements or submission 

process. When Hotline staff is unable to answer questions, the submitter is referred to OPPT’s 

Information Management Division (IMD) or Chemical Control Division (CCD), as appropriate. 

Other Divisions within OPPT or OEI are used as necessary. 

 (ii) Data Management

 This section describes the Agency tasks required for efficiently processing submissions 

under the IUR. The tasks for which the Agency is responsible are presented under four main 

categories: database systems development, guidance document development, Form U processing, 

and additional tasks. The task descriptions presented below generally do not change from 

collection to collection. 

 IUR data is stored in a database managed by the Agency. Once updated, the IUR 

database is then available to EPA technical reviewers to search or export into their various 

analytical modeling systems and databases. The IUR database is also available for quick 

screening and other direct uses. The Agency makes publicly available as much information as 

possible, within the confines of protecting CBI. 

• Database Systems Development and Maintenance -- The Agency is responsible for 

having adequate information systems in place to support the database that serves as the 

primary data storage medium for IUR collections. File servers with appropriate backup 

are used to contain the IUR databases. Following the 2006 IUR collection, EPA updated 

the technology used to store the IUR data, storing it in a larger Manage Toxic Substances 

(MTS) database. In addition, IUR data are tracked via the correspondence tracking 

system utilized by the Confidential Business Information Tracking System (CBITS) 

located within the Confidential Business Information Center (CBIC). 
January 27, 2012 

Page 19 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

• Guidance Document Development -- The Agency is responsible for developing guidance 

to assist submitters in complying with IUR requirements. The guidance documents 

usually are developed by a contractor with oversight by Agency personnel. 

• Form U Processing -- The Agency is responsible for processing IUR Form U 

submissions. This includes developing standard operating procedures and documentation 

for all stages in the IUR document life cycle, document receipt and tracking, data input, 

quality control, file and database maintenance, information security, CBI aggregation 

policy, data dissemination, and staff training. For the 2012 IUR submission period, EPA 

developed new processes to receive IUR submissions over the Internet, using CDX. 

• Additional Activities -- The Agency develops various supporting documents associated 

with the reporting tool and makes them available on the Internet. In addition, the Agency 

is responsible for providing the TSCA Hotline with standardized responses for frequently 

asked questions; preparing mailings, mailing lists, and labels; and developing outgoing 

information materials. 

 5(c) Small Entity Flexibility 

 The final IUR regulation provides ample flexibility to small entities. This regulation 

affects only businesses -- governmental jurisdictions and not-for-profit organizations are not 

required to take any action. Small manufacturers (including importers), in accordance with 

TSCA section 8(b) (40 CFR Sections 710.29 and 710.28), are exempt and therefore are generally 

not subject to any of the reporting or recordkeeping requirements. A manufacturer (including 

importer) is considered a small business if (1) the firm’s total annual sales when combined with 

those of its U.S. parent company (if any) are less than $40 million for the submission period and 

(2) its total production and/or importation of the chemical substances, mixture or category, for 

the reporting period, does not exceed 100,000 pounds (45,000 kilograms) at an individual site 

owned and controlled by the firm. The Economic Analysis for the Final Inventory Update 

Reporting Modifications Rule determined that the impact on these companies is, on average, 

significantly less than one percent of revenues (EPA, 2011). 

5(d) Collection Schedule 

 The submission period shall be from February 1, 2012 to June 30, 2012. . The submission 

period/schedule follows the requirements of 40 CFR 711.20. 

6. Estimating the Burden and Cost of the Collection 

This section presents the burden and cost estimates incurred by all affected entities as a 

result of the final IUR rule amendments. This addendum to the supporting statement covers the 

years 2011, 2012, and 2013. Therefore, it provides burden and cost estimates for the information 

collection corresponding to the 2012 reporting cycle (which is the first submission after the 2011 

final IUR rule amendments to the IUR rule are finalized), and also for the information collection 

corresponding to the next reporting cycle, for which respondents will be preparing during 2013. 
January 27, 2012 

Page 20 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

Even though reporting occurs only once per reporting cycle (once every six years for the 2012 

cycle and once every four years in the future), EPA believes that rule compliance and data 

collection activities, and thus, costs and burdens, are incurred over the course of the reporting 

cycle. Therefore, for purposes of this analysis, the burden and cost for one reporting cycle are 

averaged over the number of years in the reporting cycle and are presented here as average 

annual figures. All costs are presented in year 2008 dollars. The IUR requires reporting on a “per 

site” basis rather than a “per company” basis. Therefore, each site which is subject to the IUR 

rule is considered a respondent and will submit one Form U containing one or more chemicalspecific reports. EPA estimates that a total of 4,085 respondents will respond to this information 

collection in the 2012 reporting cycle, and 4,289 respondents will respond in future reporting 

cycles. 

Burden and cost calculations are based on the assumption that EPA will receive an 

average of 20,718 full reports and 5,135 partial reports during the first reporting cycle, and 

30,287 full reports and 648 partial reports in future reporting cycles. Each report is for a single 

chemical/site combination. Each site is expected to submit an average of 5.07 full reports and 

1.26 partial reports in the first reporting cycle and 7.06 full reports and 0.15 partial reports in the 

subsequent reporting cycles. The average burden per respondent, which is one site, is estimated 

to be 572 hours for the 2012 reporting cycle, or 95 hours annually over a six-year cycle. For 

future four-year reporting cycles, the average burden per respondent is estimated to be 600 hours 

per cycle, or 150 hours annually. Given that this ICR addendum covers a period that spans both 

the first and a future reporting cycle, the average annual burden over the three year period of 

2011 through 2013 is 114 hours. This is higher than the burden estimated for the currently 

approved ICR (EPA ICR No. 1884.04), due to both program changes and an adjustment in 

reporting requirement criteria, including additional data requirements and modifications to 

reporting thresholds. 

6(a) Estimating Respondent Burden

 For the 2012 reporting cycle, each manufacturing site (including importers) must submit 

a Form U if the site meets or exceeds the 25,000 lb threshold for at least one chemical substance 

in the 2011 principal reporting year. In future cycles, this reporting threshold will apply for any 

calendar year since the last principal reporting year. For purposes of the ICR, one manufacturing 

site is equivalent to one respondent. Form U contains four Parts. Part I contains basic site 

identification information and must be completed by all sites. Part II contains manufacturing data 

(production volumes, etc.) specific to each chemical substance, which also must be completed by 

all sites. Together, Part I and Part II are considered a “partial report.” Part III contains processing 

and use information. Under the final amendments, in future cycles Part III would be completed 

for all chemical substances unless the chemical substance is specifically exempted from the 

requirement to do so. Part IV contains secondary company identification information and 

specific information identifying a chemical substance. Part IV is completed only by a secondary 

respondent (see Section 2(b)). For purposes of this analysis, burden and costs associated with 

Part IV are considered part of the burden and costs estimates of Part I (respondent identification) 

and the beginning of Part II (chemical identification), and therefore were not separately 

calculated. Together, Parts I, II, and III (and Part IV, when applicable) are considered a “full 

report.” One report is submitted for each unique chemical substance/site combination; that is, a 
January 27, 2012 

Page 21 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

site must complete a separate report for each applicable chemical substance, but Part I of Form U 

is completed and submitted only once per site. EPA anticipates that Part I will be completed 

automatically when respondents register with CDX. 

 To comply with the regulation, manufacturers (including importers) must complete the 

activities listed in Table 2. Table 2 also provides a cross-walk of the related Information 

Collection that corresponds to each activity. 

Table 2: Cross-Walk between Industry Activities and Related Information Collections (ICs) 

Activity Description Related IC(s) 

Compliance 

Determination 

Site staff must determine whether reporting is 

required for a chemical substance manufactured 

(including imported) at a particular site, based on the 

chemical substance’s production volume and the 

applicability of certain reporting exemptions. 

Submitters would report all data from 2011 and only 

production volume from 2010. This involves 

determining whether the production volume of a 

chemical substance met or exceeded the 25,000 lb 

threshold in the 2011 principal reporting year. 

Compliance Determination 

Rule 

Familiarization

Site staff must familiarize themselves with the 

requirements of the rule. Staff from sites that 

reported previously must become familiar with new 

requirements, and staff from sites new to reporting 

must become familiar with all requirements. This 

entails reading the rule, understanding the various 

reporting and administrative requirements, and 

determining the manner in which the reporting 

requirements will be met. 

Rule Familiarization 

CDX Registration Before submitting Form U, all respondents must 

register with CDX. In addition, respondents must 

complete an Electronic Signature Agreement form, 

which is signed, dated. and either submitted 

electronically or mailed back to EPA. 

CDX Registration Activities 

Preparation of 

Reports

Site staff must collect all of the required information, 

and complete partial and/or full reports using a Form 

U report form, for each of the reportable chemical 

substances at that site. The information must be 

reviewed, and submitted to EPA. This task involves 

any research necessary to identify the correct 

information to report, the act of completing Form U 

(technical and clerical burden), and managerial 

review. Once Form U is completed, company staff 

must submit it electronically to EPA via CDX. 

Prepare and Submit Report, and 

Maintain RecordsPartial Report 

Prepare and Submit Report, and 

Maintain Records – 

Full Report 

Recordkeeping Respondents must keep records supporting their 

submissions for five years. 

Prepare and Submit Report, and 

Maintain Records - 

Partial Report 

Prepare and Submit Report, and 

Maintain RecordsFull Report 
January 27, 2012 

Page 22 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

 Burden estimates were derived originally from a survey conducted by EPA in 1996 

(under OMB Control No. 2070-0034) to assess the potential burden associated with the IUR, as 

amended at that time. The survey was distributed to previous IUR respondents selected from the 

IUR database. Burden estimates were updated for a 2005 amendment to the rule as described in 

Economic Analysis of IUR Modifications Final Rule (EPA, 2005)3

. Burden estimates for new 

reporting elements in the final rule were derived as described in the Economic Analysis for the 

Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011). 

 Table 3 and Table 4 illustrate the burden for a typical respondent on a per-activity basis, 

including time required to complete each section of Form U. Because IUR reporting for all 

respondents occurs within a required timeframe, which EPA has changed from once every five 

years to once every four years, the Agency expects only one collection to occur, in 2012, during 

the three-year period covered by this ICR addendum. Therefore, burden hour estimates for 2011 

and 2012 (Table 3) are based on the first reporting cycle burdens in the Economic Analysis for 

the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011). Burden hour 

estimates for 2013 (Table 4) are based on the future reporting cycle burdens as also described in 

the economic analysis (EPA, 2011).4

 The section-by-section industry burden estimates for report 

preparation also include the burden of compliance determination and rule familiarization. EPA 

estimates the total industry burden for completing and submitting one partial report to be 53.56 

hours, and the estimated burden for completing and submitting one full report, to be 136.58 

hours in the first reporting cycle. Each site is expected to submit an average of 5.07 full reports 

and 1.26 partial reports in the first reporting cycle. 

 EPA calculated burden estimates for each element of Form U individually using the 1996 

survey results, economic analyses for other rules with similar requirements (such as the 

Premanufacture Notification Electronic Reporting final rule), and EPA’s best professional 

judgment. More detailed information on the derivation of these estimates is found in the 

Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 

2011). 

 

3

 The economic analysis for the 2005 Amendments assumed a 15 percent reduction in burden for the completion of 

Part III because submitters were no longer required to report use and downstream processing information for 

exports. 

4

 EPA believes that the burden for future reporting cycles will be reduced because of efficiencies achieved through 

the establishment of compliance processes; as described in the IUR EA (EPA, 2011). After a site’s first reporting 

cycle, the availability of data from previous reporting cycles and familiarity with reporting requirements will 

expedite the process for submitters who have previously submitted a Form U. 
January 27, 2012 

Page 23 of 54 Office of Pollution Prevention and Toxics  U.S. Environmental Protection Agency Table 3: Total Industry Burden, by Activity, First Reporting Cycle 

Activity 

Clerical Burden 

(hours) 

Technical Burden 

(hours) 

Ma

B

(h

(a) (b) 

PREPARATION OF REPORT (Includes rule familiarization associated with each data element) Part I. Site Identification Information  Certification 0.00 0.85 

Company Information (U.S. Parent Company Name, D&B Number, Mailing Address, Technical Contact, Technical Contact Mailing Address) 

0.00 0.04 

 Plant Site Identification (Site Name, D&B Number, Mailing Address) 0.00 0.06  Information for Joint Submissions (First Reporting Cycle Only) 0.00 0.005 

Total for Part I 0.00 0.95 

Part II. Manufacturing Information Site-Limited, Activity, Production Volume (lb) (2011) 0.00 2.28  Chemical Substance Identification Upfront CBI Substantiation 0.00 1.45  Accession Number Requests 0.00 0.01  Plant Site Upfront Substantiation 0.00 0.83  Total Number of Workers 0.00 1.43 

Maximum Concentration, Physical Form, Percent Volume of Production 0.00 2.79 

 Production Volume for 2010 0.00 1.03  Production Volume Used On-Site 0.00 0.20 

Whether Imported Chemical Substance is Physically at Reporting Site 0.00 0.11 

 Volume Exported 0.00 1.03 

Whether a Chemical Substance is to be Recycled, Remanufactured, Reprocessed, or Reused. 0.00 0.11 Total for Part II 0.00 11.27 

Part III. Processing and Use Information 

Upfront Substantiation for Processing and Use Information CBI Claims 0.00 0.43 

 Industrial Processing and Use Exposure-Related Data  Determination of Applicability 0.00 1.01  Industrial Function Category 0.00 4.67 
January 27, 2012 

Page 24 of 54 Office of Pollution Prevention and Toxics  U.S. Environmental Protection Agency 

Activity 

Clerical Burden 

(hours) 

Technical Burden 

(hours) 

Ma

B

(h

(a) (b) 

 Sector 0.00 0.94  Percent of Production Volume 0.00 10.00  Total Number of Processing and Use Sites 0.00 9.14  Total Number of Potentially Exposed Workers 0.00 15.43  Consumer and Commercial Use Exposure-Related Data  Determination of Applicability 0.00 0.94  Identification of Production Category/Use by Children 0.00 1.68  Percent of Production Volume 0.00 1.26  Maximum Concentration by Category 0.00 1.36 

Number of Commercial Workers Reasonably Likely to be Exposed 0.00 15.43 

Total for Part III 0.00 62.26 

COMPLIANCE DETERMINATION 

Compliance Determination 0.00 2.50 

RULE FAMILIARIZATION 

Rule Familiarization 0.00 19.00 

CDX REGISTRATION ACTIVITIES  CDX Registration 0.00 0.73  CDX Electronic Signature Agreement 0.00 1.00 

Total for CDX Registration Activities 0.00 1,73 

RECORDKEEPING  Recordkeeping 0.75 1.50 TOTAL BURDEN Burden for one Partial Report (Parts I, II, Compliance Determination, 

Rule Familiarization, Recordkeeping and CDX Registration Activities) 0.75 36.96 

Burden for one Full Report (Parts I, II, III, Compliance Determination, 

Rule Familiarization, Recordkeeping and CDX Registration Activities) 0.75 99.22 

Note: Totals may not sum due to rounding.Source: Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011).
January 27, 2012 

Page 25 of 54 Office of Pollution Prevention and Toxics  U.S. Environmental Protection Agency Table 4: Total Industry Burden, by Activity, Future Reporting Cycles 

Activity 

Clerical Burden 

(hours) 

Technical Burden 

(hours) 

Ma

B

(h

(a) (b) 

PREPARATION OF REPORT (Includes rule familiarization associated with each data element) Part I. Site Identification Information  Certification 0.00 0.85 

Company Information (U.S. Parent Company Name, D&B Number, Mailing Address, Technical Contact, Technical Contact Mailing Address) 

0.00 0.01 

 Plant Site Identification (Site Name, D&B Number, Mailing Address) 0.00 0.01 

Total for Part I 0.00 0.87 

Part II. Manufacturing Information Site-Limited, Activity, Production Volume (lb) (2015) 0.00 1.82  Chemical Substance Identification Upfront CBI Substantiation 0.00 1.16  Plant Site Upfront Substantiation 0.00 0.66  Total Number of Workers 0.00 1.14 

Maximum Concentration, Physical Form, Percent Volume of Production 0.00 2.23 Production Volume for Each of the Years since Last Principal Reporting Year (2012 - 2014) 0.00 2.46 

 Production Volume Used On-Site 0.00 0.16 

Whether Imported Chemical Substance is Physically at Reporting Site 0.00 0.09 

 Volume Exported 0.00 0.82 

Whether a Chemical Substance is to be Recycled, Remanufactured, Reprocessed or Reused. 0.00 0.09 Total for Part II 0.00 10.65 

Part III. Processing and Use Information 

Upfront Substantiation for Processing and Use Information CBI Claims 0.00 0.43 

 Industrial Processing and Use Exposure-Related Data  Determination of Applicability 0.00 0.81  Industrial Function Category 0.00 3.53  Sector 0.00 0.75 
January 27, 2012 

Page 26 of 54 Office of Pollution Prevention and Toxics  U.S. Environmental Protection Agency 

Activity 

Clerical Burden 

(hours) 

Technical Burden 

(hours) 

Ma

B

(h

(a) (b) 

 Percent of Production Volume 0.00 8.00  Total Number of Processing and Use Sites 0.00 7.31  Total Number of Potentially Exposed Workers 0.00 12.34  Consumer and Commercial Use Exposure-Related Data  Determination of Applicability 0.00 0.75  Identification of Production Category/Use by Children 0.00 0.67  Percent of Production Volume 0.00 1.01  Maximum Concentration by Category 0.00 1.09 

Number of Commercial Workers Reasonably Likely to be Exposed 0.00 12.34 

Total for Part III 0.00 49.03 

COMPLIANCE DETERMINATION 

Compliance Determination 0.00 2.50 

RULE FAMILIARIZATION 

Rule Familiarization 0.00 2.00 

CDX REGISTRATION ACTIVITIES  CDX Registration 0.00 0.73  CDX Electronic Signature Agreement 0.00 1.00 

Total for CDX Registration Activities 0.00 1.73 

RECORDKEEPING  Recordkeeping 0.75 1.50 TOTAL BURDEN Burden for one Partial Report (Parts I, II, Compliance Determination, 

Rule Familiarization, Recordkeeping and CDX Registration Activities) 0.75 17.52 

Burden for one Full Report (Parts I, II, III, Compliance Determination, 

Rule Familiarization, Recordkeeping and CDX Registration Activities) 0.75 66.54 

Note: Totals may not sum due to rounding.Source: Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011).
January 27, 2012 

Page 27 of 54 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

6(b) Estimating Submitter Cost 

EPA multiplied burden estimates by standard wage rates for managerial, technical, and 

clerical levels developed from information published by the Bureau of Labor Statistics (BLS) 

and a method outlined in the document Wage Rates for Economic Analyses of the Toxics Release 

Inventory Program (EPA, 2002b). Wage data for the three occupational categories was gathered 

for manufacturing industries from Employer Costs for Employee Compensation Supplementary 

Tables: Historical Data December 2006 – December 2008 (BLS, 2009). 

The cost of fringe benefits, such as health insurance and vacation, is taken for each labor 

category from the same ECEC series. Following the methodology outlined in (EPA, 2002b), 

fringe benefits are calculated as a percentage of total wages for each category. EPA added 17 

percent to the wages in each category to account for overhead, based on information provided by 

the chemical industry and chemical industry trade associations in the Revised Economic Analysis 

for the Amended Inventory Update Rule: Final Report (EPA, 2002a). The wages for each of the 

three categories were then multiplied by benefits and overhead factors to estimate loaded, annual 

salaries in year 2008 dollars. Table 5 contains the loaded wage rates for the managerial, technical 

and clerical occupation categories. 

Table 5: Derivation of Loaded Wage Rates for the Private Manufacturing Sector in 2008$ 

Wage1

Fringe 

Benefits1

Fringes as % 

of Wage

Overhead % 

of Wage2

Fringe + 

Overhead 

Factor

Loaded Wages

(a) (b) (c) = (b)/(a) (d) (e)=(1)+(c)+(d) (f) = (a) x (e) 

Managerial $43.22 $19.46 48.37% 17% 1.62 $70.03 

Technical $35.29 $17.55 47.58% 17% 1.67 $58.84 

Clerical $17.22 $8.33 45.03% 17% 1.65 $28.48 1 Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006 – December 

2008, US Bureau of Labor Statistics, March 12, 2009 (BLS, 2009). 2

 An overhead rate of 17 percent was estimated based on industry data gathered for the Revised Economic Analysis 

for the Amended Inventory Update Rule: Final Report (EPA, 2002a). 

 Table 6 contains the cost per activity of completing Form U for one respondent in the 

first reporting cycle. Burden hours presented in Table 3 were multiplied by the corresponding 

loaded wage rage in Table 5. EPA estimates the total cost for completing and submitting one 

partial report in the first reporting cycle is $3,305 and the cost for completing and submitting one 

full report is $8,422. More information on the derivation of these costs is found in the IUR EA 

(EPA, 2011). 

Similarly, Table 7 contains the cost per activity of completing Form U for one respondent 

in future reporting cycles. Burden hours presented in Table 4 were multiplied by the 

corresponding loaded wage rage in Table 5. EPA estimates the total cost for completing and 

submitting one partial report in future reporting cycles is $1,574 and the cost for completing and 

submitting one full report is $5,621. More information on the derivation of these costs is found in 

the IUR EA (EPA, 2011). 
January 27, 2012 

Page 28 of 54 Office of Pollution Prevention and Toxics  U.S. Environmental Protection Agency Table 6: Total Industry Cost, by Activity, First Reporting Cycle 

Activity 

Clerical Cost 

(2008$) 

Technical Cost 

(2008$) 

Ma

(2

(a) (b) 

PREPARATION OF REPORT (Includes rule familiarization associated with each data element) Part I. Site Identification Information  Certification $0.00 $50.01 

Company Information (U.S. Parent Company Name, D&B Number, Mailing Address, Technical Contact, Technical Contact Mailing Address) 

$0.00 $2.35 

 Plant Site Identification (Site Name, D&B Number, Mailing Address) $0.00 $3.53  Information for Joint Submissions (First Reporting Cycle Only) $0.00 $0.27 

Total for Part I $0.00 $56.17 

Part II. Manufacturing Information Site-Limited, Activity, Production Volume (lb) (2011) $0.00 $134.15  Chemical Identification Upfront CBI Substantiation $0.00 $85.32  Accession Number Requests $0.00 $0.78  Plant Site Upfront Substantiation $0.00 $48.84  Total Number of Workers $0.00 $84.14 

Maximum Concentration, Physical Form, Percent Volume of Production $0.00 $164.16 

 Production Volume for 2010 $0.00 $60.37  Production Volume Used On-Site $0.00 $11.71 

Whether Imported Chemical Substance is Physically at Reporting Site $0.00 $6.71 

 Volume Exported $0.00 $60.37 

Whether a Chemical Substance is to be Recycled, Remanufactured, Reprocessed or Reused. $0.00 $6.71 Total for Part II $0.00 $663.25 

Part III. Processing and Use Information 

Upfront Substantiation for Processing and Use Information CBI Claims $0.00 $25.12 

 Industrial Processing and Use Exposure-Related Data  Determination of Applicability $0.00 $59.27  Industrial Function Category $0.00 $274.49 
January 27, 2012 

Page 29 of 54 Office of Pollution Prevention and Toxics  U.S. Environmental Protection Agency 

Activity 

Clerical Cost 

(2008$) 

Technical Cost 

(2008$) 

Ma

(2

(a) (b) 

 Sector $0.00 $55.01  Percent of Production Volume $0.00 $588.41  Total Number of Processing and Use Sites $0.00 $537.89  Total Number of Potentially Exposed Workers $0.00 $907.74  Consumer and Commercial Use Exposure-Related Data  Determination of Applicability $0.00 $55.01  Identification of Production Category/Use by Children $0.00 $98.73  Percent of Production Volume $0.00 $74.02  Maximum Concentration by Category $0.00 $80.02 

Number of Commercial Workers Reasonably Likely to be Exposed $0.00 $907.74 

Total for Part III $0.00 $3,663.47 

COMPLIANCE DETERMINATION 

Compliance Determination $0.00 $147.10 

RULE FAMILIARIZATION 

Rule Familiarization $0.00 $1,117.95 

CDX REGISTRATION ACTIVITIES  CDX Registration $0.00 $43.15  CDX Electronic Signature Agreement $0.00 $58.84 

Total for CDX Registration Activities $0.00 $101.99 

RECORDKEEPING  Recordkeeping $21.36 $88.26 TOTAL COST Cost for one Partial Report (Parts I, II, Compliance Determination, 

Rule Familiarization, Recordkeeping and CDX Registration Activities) $21.36 $2,174.71 

Cost for one Full Report (Parts I, II, III, Compliance Determination, 

Rule Familiarization, Recordkeeping and CDX Registration Activities) $21.36 $5,838.18 

Note: Totals may not sum due to rounding.Source: Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011).
January 27, 2012 

Page 30 of 54 Office of Pollution Prevention and Toxics  U.S. Environmental Protection Agency Table 7: Total Industry Cost, by Activity, Future Reporting Cycles 

Activity 

Clerical Cost 

(2008$) 

Technical Cost 

(2008$) 

Ma

(2

(a) (b) 

PREPARATION OF REPORT (Includes rule familiarization associated with each data element) Part I. Site Identification Information  Certification $0.00 $50.01 

Company Information (U.S. Parent Company Name, D&B Number, Mailing Address, Technical Contact, Technical Contact Mailing Address) 

$0.00 $0.47 

 Plant Site Identification (Site Name, D&B Number, Mailing Address) $0.00 $0.71 

Total for Part I $0.00 $51.19 

Part II. Manufacturing Information Site-Limited, Activity, Production Volume (lb) (2015) $0.00 $107.32  Chemical Identification Upfront CBI Substantiation $0.00 $68.25  Plant Site Upfront Substantiation $0.00 $39.07  Total Number of Workers $0.00 $67.31 

Maximum Concentration, Physical Form, Percent Volume of Production $0.00 $131.33 Production Volume for Each of the Years since Last Principal Reporting Year (2012 - 2014) $0.00 $144.89 

 Production Volume Used On-Site $0.00 $9.37 

Whether Imported Chemical Substance is Physically at Reporting Site $0.00 $5.37 

 Volume Exported $0.00 $48.30 

Whether a Chemical Substance is to be Recycled, Remanufactured, Reprocessed or Reused $0.00 $5.37 Total for Part II $0.00 $626.57 

Part III. Processing and Use Information 

Upfront Substantiation for Processing and Use Information CBI Claims $0.00 $25.12 

 Industrial Processing and Use Exposure-Related Data  Determination of Applicability $0.00 $25.12  Industrial Function Category $0.00 $0.00  Sector $0.00 $47.41  Percent of Production Volume $0.00 $207.82 
January 27, 2012 

Page 31 of 54 Office of Pollution Prevention and Toxics  U.S. Environmental Protection Agency 

Activity 

Clerical Cost 

(2008$) 

Technical Cost 

(2008$) 

Ma

(2

(a) (b) 

 Total Number of Processing and Use Sites $0.00 $44.01  Total Number of Potentially Exposed Workers $0.00 $470.73  Consumer and Commercial Use Exposure-Related Data  Determination of Applicability $0.00 $47.41  Identification of Production Category/Use by Children $0.00 $207.82  Percent of Production Volume $0.00 $44.01  Maximum Concentration by Category $0.00 $470.73 

Number of Commercial Workers Reasonably Likely to be Exposed $0.00 $430.32 

Total for Part III $0.00 $2,884.62 

COMPLIANCE DETERMINATION 

Compliance Determination $0.00 $147.10 

RULE FAMILIARIZATION 

Rule Familiarization $0.00 $117.68 

CDX REGISTRATION ACTIVITIES  CDX Registration $0.00 $43.15  CDX Electronic Signature Agreement $0.00 $58.84 

Total for CDX Registration Activities $0.00 $101.99 

RECORDKEEPING  Recordkeeping $21.36 $88.26 TOTAL COST Cost for one Partial Report (Parts I, II, Compliance Determination, 

Rule Familiarization, Recordkeeping and CDX Registration Activities) $21.36 $1,132.78 

Cost for one Full Report (Parts I, II, III, Compliance Determination, 

Rule Familiarization, Recordkeeping and CDX Registration Activities) $21.36 $4,017.41 

Note: Totals may not sum due to rounding.Source: Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011).
Page 32 of 54 

6(c) Estimating Agency Burden and Cost

EPA is responsible for the following activities associated with administering the IUR rule: 

• Document receipt and tracking; 

• Data entry and quality control of data entry; 

• Backup systems operation; 

• Data processing; 

• Systems development; 

• Contract oversight and management; 

• Publication and printing of forms and materials; and 

• Operation of the TSCA Hotline to handle IUR-related calls. 

Costs related to EPA activities that involve using the data are not included. 

EPA Staff Activities 

Of the tasks listed above, Agency personnel are responsible for 1) quality control of data 

entry; and 2) data processing, systems development, and contract oversight and management. 

Contractors perform the other activities, as described below. 

EPA estimates the total burden of completing Agency tasks to be one full-time equivalent 

at the GS 13 level for data processing, systems development, and contract oversight and 

management, per-reporting cycle. An estimated 0.548 FTEs are needed at the GS 12 level for 

quality control of data entry in the first reporting cycle and 0.193 FTEs are needed in future 

reporting cycles. Calculations of the Agency burden are presented in Economic Analysis for the 

Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011). 

EPA labor costs are based on annual federal wage rates published by the Office of 

Personnel Management for the Washington-Baltimore-Northern Virginia, DC-MD-PA-VA-WV 

locality pay area for 2008 (OPM, 2008). Wages are presented in terms of GS-level and step. 

Based on previous IUR economics analyses, a Step 3 is assumed for all FTEs (EPA, 2002a and 

EPA, 2005). Following the methodology outlined in Economic Analysis for the Amended 

Inventory Update Rule: Final Report (EPA, 2002a), EPA added 58 percent to the wage rate to 

account for fringe benefits and overhead costs. 

Error! Reference source not found.8 shows the loaded wage rates for Agency staff at 

the GS-12 Step 3, and GS-13 Step 3 levels. 
Page 33 of 54 

Table 8: Derivation of Loaded Agency Wage Rates (2008$) 

Pay Grade Annual 

Salary 

Overhead and Fringe 

Benefits 

(% of wages) 

Overhead and Fringe 

Benefit Cost Total 

GS 12 Step 3 $77,416 58% $44,901 $122,317 

GS 13 Step 3 $88,493 58% $51,326 $139,819 

Source: The unloaded Federal salary for 2008 is from the Office of Personnel Management salary table 

for Washington-Baltimore-Northern Virginia (OPM, 2008). 

Error! Reference source not found.9 and Table 10 contains the burden and cost per 

report for all EPA staff activities in the first and future reporting cycles. The activities performed 

by the GS-13 level staff member, including systems development, and contract oversight and 

management, are fixed costs and are not dependent on the number of reports submitted to EPA. 

Therefore, the total burden for systems development and contract oversight is one FTE at the 

GS-13 level, with a cost of $139,819 in both the first and future reporting cycles. Quality control 

of data entry is performed by the GS-12 level staff member and is dependent on the number of 

reports received. The burden for quality control of data is approximately 0.000091 FTE per 

report in the first reporting cycle and 0.000011 FTE in future reporting cycles. The total cost perreport is approximately $15.08 in the first reporting cycle and $1.38 in future reporting cycles. 

The burden and cost of processing each data element in Form U are derived in the Economic 

Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011). EPA 

multiplied the burdens by the number of data elements in each section to estimate the total cost 

and burden of processing each Form U. For more detail on the derivation of these burdens, see 

the IUR EA (EPA, 2011).

Table 9: EPA Staff Burden and Cost of Processing One Report (First Reporting Cycle) 

Activity Agency Burden per 

Activity (FTE) 

Agency 

Burden per 

Activity 

(hours) 

Agency Cost 

per Activity 

(2008$) 

GS-12 Step 3 per-Report Burden 

Quality Control of Data for Part I 0.0000827 0.1720 $11.55 

Quality Control of Data for Part II 0.0000057 0.0118 $3.14 

Quality Control of Data for Part III 0.0000030 0.0063 $0.39 

Total GS-12 Burden, per report 0.0000914 0.1901 $15.08 

GS-13 Step 3 Fixed Cost Burden 

Systems development, and 

contract oversight and 

management 

1 2,080 $139,819 

Total GS-13 Burden, per 

reporting cycle 1 2,080 $139,819 
Page 34 of 54 

Table 10: EPA Staff Burden and Cost of Processing One Report (Future Reporting Cycles) 

Activity 

Agency Burden 

per Activity 

(FTE) 

Agency Burden 

per Activity 

(hours) 

Agency Cost 

per Activity 

(2008$) 

GS-12 Step 3 per-Report Burden 

Quality Control of Data for Part I 0.0000048 0.0100 $0.66 

Quality Control of Data for Part II 0.0000026 0.0054 $0.33 

Quality Control of Data for Part III 0.0000030 0.0063 $0.39 

Total GS-12 Burden, per report 0.0000105 0.0218 $1.38 

GS-13 Step 3 Fixed Cost Burden 

Systems development, and contract 

oversight and management 1 2,080 $139,819 

Total GS-13 Burden, per 

reporting cycle 1 2,080 $139,819 

 Contractor Activities 

 Agency costs also include payment for extramural tasks completed by contractors (this 

category includes costs to EPA, but not burden hours). Contractor activities include document 

receipt, tracking, data entry, maintaining backup systems, printing and publishing forms and 

materials, and managing the TSCA Hotline, as presented in Tables 11 and 12. With the exception 

of document receipt, tracking, and data entry, all contractor costs are fixed and are not dependent 

on the number of reports received. All fixed costs are taken from the last published ICR and were 

inflated from 2007 to 2008 dollars with an inflation factor calculated using the Employment Cost 

Index (ECI), seasonally adjusted, for white-collar occupations in private industry (BLS, 2009). 

EPA calculated the cost estimate per report for document receipt, tracking, and data 

entry, $0.64 in the first reporting cycle and $0.65 in future reporting cycles, by starting with the 

cost estimated in the 2007 ICR, and updating it to reflect the new data elements and the 

electronic submission requirement in the final amendments. The reduction in burden caused by 

the electronic submission requirement is based on a study conducted by EPA, “A Business Case 

Analysis of EPA’s Central Data Exchange” (EPA, 2007), of the costs and benefits of the 

electronic Central Data Exchange (CDX) system. The study estimates an 88.6 percent decrease 

in EPA processing burden as a result of using the CDX system. For more information, see the 

Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 

2011). 
Page 35 of 54 

Table 11: Cost of Contractor Activities (First Reporting Cycle)

Activity Annual Cost 

(2007$) 

Inflation 

Factor 

Annual Cost 

(2008$) 

Variable Costs 

Document receipt, tracking, and data 

entry for Part I $0.78 n/a $0.09 

Document receipt, tracking, and data 

entry for Part II $1.92 n/a $0.25 

Document receipt, tracking, and data 

entry for Part III $2.45 n/a $0.30 

Total Cost of Document receipt, 

tracking, and data entry, per full 

report 

$5.14 n/a $0.64 

Fixed Costs 

Maintaining and Operating Back-Up 

Systems $56,711 1.04 $59,145 

Printing and Publishing Forms and 

Materials $5,298 1.04 $5,525 

Managing the TSCA Hotline $42,855 1.04 $44,694 

Total Fixed Cost $104,864 n/a $109,364 

 

Table 12: Cost of Contractor Activities (Future Reporting Cycles)

Activity 

Annual Cost 

2007$ 

Inflation 

Factor Annual Cost 2008$ 

Variable Costs 

Document receipt, tracking, and data 

entry for Part I $0.78 n/a $0.09 

Document receipt, tracking, and data 

entry for Part II $1.92 n/a $0.26 

Document receipt, tracking, and data 

entry for Part III $2.45 n/a $0.30 

Total Cost of Document receipt, 

tracking, and data entry, per full 

report 

$5.14 n/a $0.65 

Fixed Costs 

Maintaining and Operating Back Up 

Systems $56,711 1.04 $59,145 

Printing and Publishing Forms and 

Materials $5,298 1.04 $5,525 

Managing the TSCA Hotline $42,855 1.04 $44,694 

Total Fixed Cost $104,864 n/a $109,365 

6(d) Bottom-Line Industry Burden and Cost Estimates

 

 This section describes the estimated total social paperwork burden and cost of the IUR 

rule, including the final amendments. The next IUR submission period will occur in 2012 for 

chemical substances manufactured (including imported) during the calendar year 2011. Even 

though reporting occurs only once per reporting cycle (once every six years for the 2012 cycle 

and once every four years in the future), EPA believes rule compliance and data collection 
Page 36 of 54 

activities, and thus, costs and burdens, are incurred over the course of the reporting cycle. 

Therefore, for purposes of this analysis, the burden and cost for one reporting cycle are averaged 

over the number of years in the reporting cycle and are presented here as average annual figures. 

This ICR addendum supporting statement is for the three-year period of 2011 through 2013; 

therefore, average annual figures for each of these three years are presented below. 

Respondent tally 

EPA calculated the numbers of sites and reports submitted based on submission 

information from the December 2008 version of the IUR database, which includes data from the 

most recent (2006) IUR collection. The EPA IUR database contains information collected under 

the IUR for previous submission periods and was used to generate estimates of expected reports 

for the 2012 reporting cycle. In the 2011 and 2012, EPA expects a total of 4,085 sites to submit 

20,718 full reports (80 percent of all reports) and 5,135 partial reports (20 percent of all reports) 

for a total of 25,853 reports. In future reporting cycles, EPA expects 4,289 sites to submit 30,287 

full reports and 648 partial reports for a total of 30,935 reports (98 percent and two percent of all 

reports, respectively). 

 

Total Industry Burden/Cost for First Reporting Cycle. EPA estimates the total 

industry burden for the first reporting cycle, including both current baseline burden and the 

burden resulting from the final amendments, to be 2.34 million hours. Given that this data 

collection is part of a six-year reporting cycle, EPA estimates the annual industry burden for 

2011 and 2012 to be 389,771 hours. As presented in Table 13, EPA estimates the total cost to 

industry would be $144 million, or an annual cost of $24.0 million. 
Page 37 of 54 

Table 13: Estimated Respondent Burden and Cost Associated with the First Reporting Cycle (2011 and 2012)

Activity Total Burden per Activity (hours) Total Number of Units Total Cost per Activity (2008$) Total Burden per Reporting Cycle (hours) 

Total Cost 

per 

Reporting 

Cycle 

(2008$)

Annual 

Burden 

(hours)

Compliance Determination (per Site) 

2.50 4,085 Sites $147.10 10,213 $600,896 1,702 

Rule Familiarization (per Site) 

28.00 4,085 Sites $1,748.19 114,380 $7,141,370 19,063 

CDX Registration Activities (per Site) 

2.67 4,085 Sites $167.35 10,893 $683,613 1,816 

Part I Preparation (per site) 

2.01 4,085 Sites $130.29 8,223 $532,232 1,371 

Partial Report Preparation (Part II, per Report) 

15.37 5,135 Partial Reports $950.29 78,931 $4,879,729 13,155 

Full Report Preparation (Part II and Part III,  per Report) 

98.39 20,718 Full Reports $6,067.24 2,038,430 $125,700,980 339,738 

Recordkeeping  (per Report) 3.00 25,853 Reports $162.14 77,559 $4,191,742 12,927 Total Industry Burden and Cost for the First Reporting Cycle 2,338,629 $143,730,561 389,771 

Note: Totals may not sum due to rounding 
Page 38 of 54 

Total Industry Burden and Cost for Future Reporting Cycles. EPA estimates the total 

industry burden for future reporting cycles, including both current baseline burden and the 

burden resulting from the final amendments, to be 2.57 million hours. Given that this data 

collection will occur every four years, EPA estimates the annual industry burden for future years 

to be 642,823 hours. As presented in Table 14, EPA estimates the total cost to industry would be 

$158 million, or an annual cost of $39.5 million.
Page 39 of 54 

Table 14: Estimated Annual Respondent Burden and Cost Associated with Future Reporting Cycles (2013)

Activity 

Total 

Burden per 

Activity 

(hours) 

Total Number 

of Units 

Total Cost 

per 

Activity 

(2008$) 

Total Burden 

(hours) 

Total Cost per 

Reporting 

Cycle (2008$) 

Annual Burden 

(hours) 

Compliance Determination (per Site) 

2.50 4,289 Sites $147.10 10,723 $630,904 2,681 

Rule Familiarization (per Site) 

4.00 4,289 Sites $257.73 17,156 $1,105,419 4,289 

CDX Registration Activities (per Site) 

2.67 4,289 Sites $167.35 11,437 $717,751 2,859 

Part I Preparation (per Site) 

1.89 4,289 Sites $122.48 8,098 $525,309 2,024 

Partial Report Preparation (Part II, per Report) 

14.33 648 Partial Reports $884.43 9,287 $573,112 2,322 

Full Report Preparation (Part II and Part III, per Report) 

79.96 30,287 Full Reports $4,931.84 2,421,786 $149,370,529 605,447 

Recordkeeping (per Report) 3.00 30,935 Reports $162.14 92,829 $5,017,022 23,207 Total Industry Burden and Cost for Future Reporting Cycles 2,571,291 $157,938,749 642,823 Note: Totals may not sum due to rounding 
Annual Industry Burden and Cost for 2011 to 2013. As shown in Table 15, EPA 

calculated the estimated total annual respondent burden and cost associated with this ICR 

addendum by taking a weighted average of the first and future reporting cycles, to reflect that the 

period covered by this ICR, 2011 through 2013, spans two reporting cycles with different 

burdens and costs. The total annual burden associated with this ICR addendum is 474,122 hours. 

The total annual cost is $29.1 million. 

Table 15: Estimated Annual Average Burden and Cost Associated with this ICR Addendum 

Activity 

2011 2012 2013 2011-2013 Average 

Annual 

Burden 

(hours) 

Annual 

Cost 

(2008$) 

Annual 

Burden 

(hours) 

Annual 

Cost 

(2008$) 

Annual 

Burden 

(hours) 

Annual 

Cost 

(2008$) 

Total 

Annual 

Burden 

(hours) 

Total 

Annual 

Cost 

(2008$) 

Compliance 

Determination 

(per Site) 

1,702 $100,149 1,702 $100,149 2,681 $157,726 2,028 $119,342

Rule 

Familiarization 

(per Site) 

19,063 $1,190,228 19,063 $1,190,228 4,289 $276,355 14,139 $885,604

CDX 

Registration 

Activities 

(per Site) 

1,816 $113,935 1,816 $113,935 2,859 $179,438 2,163 $135,770

Part I 

Preparation 

(per Site) 

1,371 $88,705 1,371 $88,705 2,024 $131,327 1,589 $102,913

Partial Report 

Preparation 

(Part II, 

per Report) 

13,155 $813,288 13,155 $813,288 2,322 $143,278 9,544 $589,952

Full Report 

Preparation 

(Part II and 

Part III, 

per Report) 

339,738 $20,950,163 339,738 $20,950,163 605,447 $37,342,632 428,308 $26,414,320

Recordkeeping 

(per Report) 12,927 $698,624 12,927 $698,624 23,201 $1,253,931 16,351 $883,726

Total 474,122 $29,131,625 

Average Burden and Cost per Site. As shown in Table 16, the Agency estimates the 

typical respondent burden for this information collection activity to be 572 hours in the first 

reporting cycle and 600 hours in future reporting cycles. Given that the 2011 and 2012 (first) 

collection is based on a six-year reporting cycle, the average annual burden for the first reporting 

cycle would be 95 hours. Given that a collection would occur once every four years under the 

final rule, the average annual burden for future cycles would be 150 hours. These burden 

estimates assume each site will submit an average of 5.07 full reports and 1.26 partial reports in 

both the next reporting cycle, and 7.06 full reports and 0.15 partial reports in future reporting 

cycles. This is a decrease of 2.04 partial reports per site and an increase of 1.67 full reports per 

site in the first cycle compared to the average number of reports completed per site presented in 

the currently approved ICR (EPA ICR No. 1884.04). 

 
Table 16: Average Burden per Site 

Activity 

Burden Hours 

Total 

Hours per 

Activity 

Reports 

per 

Average 

Site 

Total 

Burden 

(hours per 

average 

site) 

Annual 

Burden 

(hours per 

average site) 

Managerial Technical Clerical 

First Reporting Cycle 

Rule 

Familiarization. 

Compliance 

Determination, 

CDX 

Registration 

Activities and 

Part I 

Preparation 

(per Site) 

10.99 24.19 0.00 35.18 1.00 35.18 5.86 

Partial Report 

Preparation 

(Part II, 

 per Report) 

4.10 11.27 0.00 15.37 1.26 19.32 3.22 

Full Report 

Preparation 

(Part II and 

Part III, 

 per Report) 

24.85 73.53 0.00 98.39 5.07 499.00 83.17 

Recordkeeping 

 (per Report) 0.75 1.50 0.75 3.00 6.33 18.99 3.16 

Total Hours 572 95.42 

Future Reporting Cycles 

Rule 

Familiarization. 

Compliance 

Determination, 

CDX 

Registration 

Activities and 

Part I 

Preparation 

(per site) 

3.95 7.10 0.00 11.05 1.00 11.05 2.76 

Partial Report 

Preparation 

(Part II, per 

Report) 

3.68 10.65 0.00 14.33 0.15 2.17 0.54 

Full Report 

Preparation 

(Part II and 

Part III, per 

Report) 

20.29 59.67 0.00 79.96 7.06 564.65 141.16 

Recordkeeping 

(per Report) 0.75 1.50 0.75 3.00 7.21 21.64 5.41 

Total Hours 600 150 
Table 17 presents the average cost per site, by activity, for an IUR respondent. EPA 

estimates the average site will submit 5.07 full reports and 1.26 partial reports in the first 

reporting cycle and 7.06 full reports and 0.15 partial reports in future reporting cycles and incur a 

total cost of $35,185 during the first reporting cycle ($5,864 annually), and $36,824 during future 

reporting cycles ($9,206 annually) for Form U completion and submission. 

Table 17: Average Cost per Site 

Activity 

Cost 

 (2008$) 

Total 

Cost per 

Activity 

Reports 

per 

 Average 

Site 

Total Cost 

(2008$ per 

average 

site) 

Annual 

Cost 

(2008$ 

per 

average 

site) 

Managerial Technical Clerical 

First Reporting Cycle 

Rule 

Familiarization. 

Compliance 

Determination, CDX 

Registration 

Activities and Part I 

Preparation 

(per site) 

$770 $1,423 $0.00 $2,193 1.00 $2,193 $365 

Partial Report 

Preparation (Part II, 

per Report) 

$287 $663 $0.00 $950 1.26 $1,195 $199 

Full Report 

Preparation (Part II 

and Part III, per 

Report) 

$1,741 $4,327 $0.00 $6,067 5.07 $30,771 $5,129 

Recordkeeping 

 (per Report) $52.52 $88.26 $21.36 $162 6.33 $1,026 $171 

Total Cost $35,185 $5,864 

Future Reporting Cycles 

Rule 

Familiarization. 

Compliance 

Determination, CDX 

Registration 

Activities and Part I 

Preparation 

(per site) 

$277 $418 $0.00 $695 1.00 $695 $174

Partial Report 

Preparation (Part II, 

per Report) 

$258 $627 $0.00 $884 0.15 $134 $33.41

Full Report 

Preparation (Part II 

and Part III, per 

Report) 

$1,421 $3,511 $0.00 $4,932 7.06 $34,826 $8,707

Recordkeeping 

 (per Report) $52.52 $88.26 $21.36 $162 7.21 $1,169 $292

Total Cost $36,824 $9,206 
As shown in Table 18, EPA calculated the estimated burden and cost per site associated 

with this ICR addendum by taking a weighted average of the first and future reporting cycles to 

reflect that the period covered by this ICR addendum, 2011 through 2013, spans two reporting 

cycles with different burdens and costs. The average annual burden per site is 114 hours and the 

average annual cost per site is $6,978. 

Table 18: Estimated Annual Burden and Cost per Site Associated with this ICR Addendum 

Activity 

2011 2012 2013 2011-2013 Average

Annual 

Burden 

(hours)

Annual 

Cost 

(2008$)

Annual 

Burden 

(hours)

Annual 

Cost 

(2008$)

Annual 

Burden 

(hours)

Annual 

Cost 

(2008$)

Annual 

Burden 

(hours)

Annual 

Cost 

(2008$)

Rule 

Familiarization. 

Compliance 

Determination, 

CDX 

Registration 

Activities and 

Part I 

Preparation 

(per site)

5.86 $365 5.86 $365 2.76 $174 4.83 $302

Partial Report 

Preparation 

(Part II, per 

Report)

3.22 $199 3.22 $199 0.54 $33 2.33 $144

Full Report 

Preparation 

(Part II and 

Part III, per 

Report)

83.17 $5,129 83.17 $5,129 141.16 $8,707 102.50 $6,321

Recordkeeping 

 (per Report) 3.16 $171 3.16 $171 5.41 $292 3.91 $211

Total 114 $6,978

Table 19 presents the annual burden hours, organized by information collection, for both 

the first and future reporting cycle, and weighted, annual averages for the ICR addendum period, 

for IUR respondents. 
Table 19: Annual Information Collection Tally for First and Future Reporting Cycles 

Information Collection No. of 

Respondents 

No. of 

Responses / 

Respondent 

Responses 

Subtotal 

Annual 

Burden Hours 

per Response 

Annual 

Burden Hours 

Subtotal 

First Reporting Cycle (2011 and 2012) 

Compliance 

Determination 4,085 1 4,085 0.42 1,702

Rule Familiarization 4,085 1 4,085 4.67 19,063

CDX Registration 

Activities 4,085 1 4,085 0.44 1,816

− CDX Registration 4,085 1 4,085 0.15 624

− ESA 4,085 1 4,085 0.29 1,191

Prepare Part I of Form U 4,085 1 4,085 0.34 1,371

Prepare and Submit 

Report, and Maintain 

Records – Partial Report 

4,085 1.26 5,135 3.06 15,723

− Part II of Form U 4,085 1.26 5,135 2.56 13,155

− Recordkeeping 4,085 1.26 5,135 0.50 2,568

Prepare and Submit 

Report, and Maintain 

Records - Full Report 

4,085 5.07 20,718 16.90 350,097

− Part II and III of 

Form U 4,085 5.07 20,718 16.40 339,738

− Recordkeeping 4,085 5.07 20,718 0.50 10,359

Future Reporting Cycles (2013) 

Compliance 

Determination 4,289 1.00 4,289 0.63 2,681 

Rule Familiarization 4,289 1 4,289 1.00 4,289 

CDX Registration 

Activities 4,289 1 4,289 0.67 2,859 

− CDX Registration 4,289 1 4,289 0.23 983 

− ESA 4,289 1 4,289 0.44 1,876 

Prepare Part I of Form U 4,289 1 4,289 0.47 2,024 

Prepare and Submit 

Report, and Maintain 

Records – Partial Report 

4,289 0.15 648 4.33 2,808 

− Part II of Form U 4,289 0.15 648 3.58 2,322 

− Recordkeeping 4,289 0.15 648 0.75 486 

Prepare and Submit 

Report, and Maintain 

Records - Full Report 

4,289 7.06 30,287 20.74 628,162 

− Part II and III of 

Form U 4,289 7.06 30,287 19.99 605,447 

− Recordkeeping 4,289 7.06 30,287 0.75 22,715 

Average Burden for ICR Addendum Period

Compliance 

Determination 4,153 1 4,153 0.49 2,028

Rule Familiarization 4,153 1 4,153 3.40 14,139

CDX Registration 

Activities 4,153 1 4,153 0.52 2,163

Prepare Part I of Form 

U 4,153 1 4,153 0.38 1,589 

Prepare and Submit 

Report, and Maintain 4,153 0.89 3,639 3.14 11,418
Information Collection No. of 

Respondents 

No. of 

Responses / 

Respondent 

Responses 

Subtotal 

Annual 

Burden Hours 

per Response 

Annual 

Burden Hours 

Subtotal 

Records – Partial 

Report 

 -- Part II of Form U 4,153 0.89 3,639 2.62 9,544

 -- Recordkeeping 4,153 0.89 3,639 0.51 1,874

Prepare and Submit 

Report, and Maintain 

Records - Full Report

4,153 5.74 23,908 18.52 442,785

 --Part II and III of 

Form U 4,153 5.74 23,908 17.92 428,308

 --Recordkeeping 4,153 5.74 23,908 0.61 14,478

 Some burden estimate subtotals may not calculate due to rounding of unit burden estimates 

Table 20 presents the total burden hours for the ICR period (2011 – 2013), organized by 

information collection, for both the first and future reporting cycles, for IUR respondents. 
Table 20: Information Collection Tally for ICR Reporting Period (2011- 2013) 

Information Collection No. of 

Respondents 

No. of 

Responses / 

Respondent 

Responses 

Subtotal 

Total Burden 

Hours per 

Response 

Total Burden 

Hours Subtotal 

First Reporting Cycle (2011 and 2012) 

Compliance 

Determination 4,085 1 4,085 0.83 3,404 

Rule Familiarization 4,085 1 4,085 9.33 38,127 

CDX Registration 

Activities 4,085 1 4,085 0.89 3,631 

− CDX Registration 4,085 1 4,085 0.31 1,248

− ESA 4,085 1 4,085 0.58 2,383

Prepare Part I of Form U 4,085 1 4,085 0.67 2,741 

Prepare and Submit 

Report, and Maintain 

Records – Partial Report 

4,085 1.26 5,135 6.12 31,445 

− Part II of Form U 4,085 1.26 5,135 5.12 26,310

− Recordkeeping 4,085 1.26 5,135 1.00 5,135

Prepare and Submit 

Report, and Maintain 

Records - Full Report 

4,085 5.07 20,718 33.80 700,195 

− Part II and III of 

Form U 4,085 5.07 20,718 32.80 679,477

− Recordkeeping 4,085 5.07 20,718 1.00 20,718

Future Reporting Cycles (2013) 

Compliance 

Determination 4,289 1.00 4,289 0.63 2,681 

Rule Familiarization 4,289 1 4,289 1.00 4,289 

CDX Registration 

Activities 4,289 1 4,289 0.67 2,859 

− CDX Registration 4,289 1 4,289 0.23 983

− ESA 4,289 1 4,289 0.44 1,876

Prepare Part I of Form U 4,289 1 4,289 0.47 2,024 

Prepare and Submit 

Report, and Maintain 

Records – Partial Report 

4,289 0.15 648 4.33 2,808 

− Part II of Form U 4,289 0.15 648 3.58 2,322

− Recordkeeping 4,289 0.15 648 0.75 486

Prepare and Submit 

Report, and Maintain 

Records - Full Report 

4,289 7.06 30,287 20.74 628,162 

− Part II and III of 

Form U 4,289 7.06 30,287 19.99 605,447

− Recordkeeping 4,289 7.06 30,287 0.75 22,715

Burden for ICR Addendum Period

Compliance 

Determination 4,153 1 4,153 1.47 6,085

Rule Familiarization 4,153 1 4,153 10.21 42,416

CDX Registration 

Activities 4,153 1 4,153 1.56 6,490

Prepare Part I of Form 

U 4,153 1 4,153 1.15 4,766 

Prepare and Submit 

Report, and Maintain 4,153 0.89 3,639 9.41 34,253
Information Collection No. of 

Respondents 

No. of 

Responses / 

Respondent 

Responses 

Subtotal 

Total Burden 

Hours per 

Response 

Total Burden 

Hours Subtotal 

Records – Partial 

Report 

 -- Part II of Form U 4,153 0.89 3,639 7.87 28,632

 -- Recordkeeping 4,153 0.89 3,639 1.54 5,621

Prepare and Submit 

Report, and Maintain 

Records - Full Report

4,153 5.74 23,908 55.56 1,328,356

 --Part II and III of 

Form U 4,153 5.74 23,908 53.75 1,284,923

 --Recordkeeping 4,153 5.74 23,908 1.82 43,433

Agency Tally 

 Tables 21 and 22 present the Agency costs associated with the IUR rule for the first 

reporting cycle and future reporting cycles, respectively. EPA multiplied the costs per report by 

the total number of Parts I, II, and III to calculate the total burden and cost associated with the 

number of reports EPA expects to be submitted. In the first reporting cycle, the total burden is 

0.548 FTEs and the total cost is $149,387 for variable cost activities. In future reporting cycles 

the burden is 0.193 FTE and the cost is $42,331 for variable cost activities. The burden and cost 

of the fixed cost activities remains unchanged by the number of reports submitted; the total fixed 

burden is one FTE per reporting cycle and the cost is $249,184. The total Agency burden is 

1.548 FTEs in the first reporting cycle and 1.193 FTEs in future reporting cycles. The estimated 

total cost incurred by the Agency for the first reporting cycle, $398,571, and $291,515 in future 

reporting cycles was calculated by summing the Agency staff and contractor activities. 
Table 21: Total Cost and Burden of Agency Activities (First Reporting Cycle) 

Activity Staff 

Form 

U 

Section 

Total Burden per 

Activity (FTE) 

Total 

Number 

of Units 

Total 

Cost 

per 

Activity

(2008$) 

Total 

Burden 

(FTE) 

Total Cost 

(2008$) 

Variable Burdens and Costs

Document 

receipt, 

tracking, and 

data entry 

Contractor 

Part I N/A 4,085 

Sites $0.09 N/A $377 

Part II N/A 25,853 

Part IIs $0.25 N/A $6,370 

Part III N/A 20,718 

Part IIIs $0.30 N/A $6,222 

Quality 

Control of 

Data 

EPA 

Employee 

(GS-12 

Step 3) 

Part I 0.0000827 4,085 

Sites $11.55 0.338 $47,170 

Part II 0.0000057 25,853 

Part IIs $3.14 0.147 $81,200 

Part III 0.0000030 20,718 

Part IIIs $0.39 0.063 $8,048 

Total Variable Cost and Burden 0.548 $149,387 

Fixed Burdens and Costs 

Data 

Processing, 

Systems 

Development, 

and Contract 

Oversight and 

Management 

EPA 

Employee 

(GS-13 

Step 3) 

N/A N/A N/A N/A 1.000 $139,819 

Maintaining 

and 

Operating 

Back Up 

Systems 

Contractor N/A N/A N/A N/A N/A $59,145 

Printing and 

Publishing 

Forms and 

Materials 

Contractor N/A N/A N/A N/A N/A $5,525 

Managing the 

TSCA 

Hotline 

Contractor N/A N/A N/A N/A N/A $44,694 

Total Fixed Cost and Burden 1 $249,184 

Total Agency Cost and Burden 1.55 $398,571
Table 22: Total Cost and Burden of Agency Activities (Future Reporting Cycle) 

Activity Staff Form U 

Section 

Total 

Burden 

per 

Activity 

(FTE) 

Total 

Number of 

Units 

Total 

Cost per 

Activity 

(2008$) 

Total 

Burden 

(FTE) 

Total Cost 

(2008$) 

Variable Burdens and Costs

Document receipt, 

tracking, and data 

entry Contractor 

Part I N/A 4,289 Sites $0.09 N/A $396 

Part II N/A 30,935 Part 

IIs $0.26 N/A $7,965 

Part III N/A 30,287 Part 

IIIs $0.30 N/A $9,079 

Quality Control of 

Data 

EPA 

Employee 

(GS-12 

Step 3) 

Part I 0.0000048 4,289 Sites $0.66 0.021 $2,843 

Part II 0.0000026 30,935 Part 

IIs $0.33 0.081 $10,304 

Part III 0.0000030 30,287 Part 

IIIs $0.39 0.092 $11,744 

Total Variable Cost and Burden 0.193 $42,331 

Fixed Burdens and Costs 

Data Processing, 

Systems 

Development, and 

Contract Oversight 

and Management 

EPA 

Employee 

(GS-13 

Step 3) 

N/A N/A N/A N/A 1.000 $139,819 

Maintaining and 

Operating Back Up 

Systems 

Contractor N/A N/A N/A N/A N/A $59,145 

Printing and 

Publishing Forms 

and Materials 

Contractor N/A N/A N/A N/A N/A $5,525 

Managing the 

TSCA Hotline Contractor N/A N/A N/A N/A N/A $44,694 

Total Fixed Cost and Burden 1 $249,184 

Total Agency Cost and Burden 1.19 $291,515

6(e) Reasons for Change in Burden 

EPA estimates industry will incur an increase of 63,637hours in annual burden compared 

to the estimate in the information collection request most recently approved by OMB (from 

410,485 hours as reported in the currently approved ICR (EPA ICR No. 1884.04) (EPA, 2008a), 

to 474,122hours as estimated in Section 6(d) above). Differences in burden and costs from the 

previous ICR are attributed to both adjustments and program changes. Adjustments capture 

changes in the baseline burden not included in the currently approved ICR (EPA ICR No. 

1884.04) (EPA, 2008a). These changes result from updates to the number of affected sites and 

wages, capturing effects of rule amendments that were not included in the currently approved 

ICR, and the correction of estimates in the previous ICR. Program changes reflect the 

amendments of the final IUR modifications rule, which affect per-site costs, the number of 

affected sites, and the number of final and partial reports submitted. As shown in Table 22, EPA 

estimates an annual 66,250 hour burden decrease as a result of adjustment changes and an annual 
increase of 105,534 hours as a result of program changes. More details on the adjustments and 

program changes are outlined below. 

Adjustment Changes

The previous currently approved ICR (EPA ICR No. 1884.04) used data from the 2006 

IUR database that had not gone through quality control to estimate the number of sites, and 

partial and full reports submitted to EPA. EPA ICR No. 1884.04 estimated that a total of 4,190 

sites would submit 13,989 partial reports and 14,409 full reports. EPA has adjusted the number 

of sites and reports using the quality-controlled data and estimates that a total of 4,085 sites will 

submit 8,821 partial reports and 17,075 full reports in the baseline. 

The previous ICR did not take into account the amendment in the 2006 Final IUR 

Revisions Rule that removed the requirement of reporting processing and use information for 

exports. This amendment reduced the burden associated with submitting and completing a final 

report by 15 percent. 

The previous ICR used high-end burden estimates, while the current ICR uses midpoint 

estimates to be consistent with the Economic Analysis for the Final Inventory Update Reporting 

(IUR) Modifications Rule (EPA, 2011). EPA adjusted the burden estimates from the previous 

ICR using midpoint estimates to provide a consistent comparison across ICRs. This change 

reduces the per-site burden associated compliance determination, recordkeeping and submitting a 

report. 

The previous ICR used first-year burden for each burden activity, with the exception of 

rule familiarization which was estimated at 4 hours per site. The first-year range for this activity 

is 26-30 hours. EPA adjusted the rule familiarization to the midpoint estimate (see above) of 28 

hours to reflect the first-year burden. 

The total of all of the adjustments results in a decrease in the baseline total burden of 

149,400 hours from 2,052,423 hours to 1,903,023 and a decrease in the baseline annual burden 

of 29,880 hours from 410,485 hours to 380,605 hours. 

All costs were inflated from 2007$ to 2008$, which slightly increased the costs 

associated with the rule. However, even after adjusting for inflation the total of all of the 

adjustments decreased the annual baseline cost from $22,628,227 to $22,041,964; a decrease of 

$586,263.

Program Changes

The per-site costs, the number of affected sites, and the number of final and partial reports 

submitted, will be impacted by several of the final modifications including: 

• For the reporting cycles subsequent to the 2012 reporting cycle, a requirement was added to 

report whether, for any calendar year since the previous IUR principal reporting year, the 

subject chemical was manufactured in production volumes of 25,000 lb or greater per year; 
• Replace the 300,000 lb reporting threshold for processing and use information by phasing in a lower 

reporting threshold. For the 2012 IUR manufacturers (including importers) of non-excluded 

substances with production volumes greater than 100,000 lb are required to report processing and use 

information. Subsequent to the 2012 reporting cycle, the reporting threshold for processing and use 

information will be 25,000 lb; 

• Reduce the 25,000 lb threshold for reporting to 2,500 lb for specific regulated chemical substances 

and require manufacturers (including importers) of such chemical substances to report under the IUR 

rule, if production volume is greater than 2,500 lb beginning with the 2016 reporting cycle, 

• Chemical substances subject to Enforceable Consent Agreements (ECAs) were made 

ineligible for exemptions; 

• Manufactured water was fully exempted from reporting requirements; 

• Certain reportable data elements, such as the company identification number, technical 

contact, and chemical identity, were amended; 

• Submitters are required to report the chemical substance’s production volume for both 2010 

and 2011. For the reporting cycles subsequent to the 2012 reporting cycle, submitters are required to 

report the chemical substance’s production volume for each year since the last principal reporting 

year; 

• Submitters are required to report separately production volume used on-site; 

• Submitters of imported chemical substances are required to indicate whether the chemical 

substance is physically at the reporting site; 

• Submitters are required to report production volume exported; 

• Submitters are required to indicate whether the chemical substance is to be recycled, 

remanufactured, reprocessed, or reused; 

• For downstream processing and use information: the set of industrial function categories was 

revised, industrial sectors were provided instead of NAICS codes, and the set of consumer 

and commercial product categories was revised; 

• Submitters are required to identify whether a use is a consumer use, a commercial use, or 

both; 

• Submitters are required to report the total number of commercial workers, including those at 

sites not under the submitter’s control, that are reasonably likely to be exposed while using 

the reportable chemical substance, with respect to each commercial use; 

• The reporting standard for processing and use information was changed from “readily 

obtainable” to “known to or reasonably ascertainable by”; 

• Upfront substantiation is required for claims that processing and use data are confidential 

business information (CBI); 

• Submitters are restricted from being able to claim not “known to or reasonably ascertainable 

by” data as CBI; 

• Submitters are required to submit forms electronically using the reporting tool, e-IURweb 

and EPA’s CDX; and 

• The frequency of reporting was changed from every five years to every four years. 

Details on the final amendments and the burden and cost impacts of each amendment when 

taken individually and considered together (i.e., one amendment may change the impact of 

another, are described in the Economic Analysis for the Final Inventory Update Reporting (IUR) 

Modifications Rule (EPA, 2011). 
Table 23: Total Estimate of Annual Burden Hours and Annualized Cost Comparisons

 Annual Burden Hours Annual Cost 

Current OMB Inventory 410,485 $22,628,227 

Change in Burden due to 

Adjustments -29,880 -$586,263 

Change in Burden due to 

Program Changes 93,517 $7,089,661 

Total Change in Burden 63,637 $6,503,398

Total Burden 474,122 $29,131,625 

6(f) Burden Statement 

 The annual public burden for this collection of information is estimated to average 114 

hours per respondent. According to the Paperwork Reduction Act, “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. For this collection it includes the time needed to 

determine whether a site is subject to the rule (Compliance Determination); review and 

understand instructions; prepare and submit reports (including searching data sources); complete 

and review the collection of information; transmit the information; and keep records. 

 An agency may not conduct or sponsor, and a person is not required to respond to, a 

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

control number for this information collection appears above. The OMB control numbers for 

EPA's regulations in title 40 of the CFR, after appearing in the Federal Register when approved, 

are listed in 40 CFR Part 9, are displayed either by publication in the Federal Register or by other 

appropriate means, such as on the related collection instrument or form, if applicable. The 

display of OMB control numbers in certain EPA regulations is consolidated in 40 CFR Part 9. 

 EPA has established a docket for this ICR addendum under Docket ID No. EPA-HQOPPT-2009-0187 which is available for public viewing at the Pollution Prevention and Toxics 

Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., 

NW, Washington, DC. The EPA Docket Center 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 

Reading Room is (202) 566-1544 and the telephone number for the Pollution Prevention and 

Toxics Docket is (202) 566-0280. 

 An electronic version of this docket is available at http://www.regulations.gov/. Use the 

federal government-wide electronic docket system at http://www.regulations.gov to view public 

comments, access the index listing of the docket contents, and to access those documents in the 

docket that are available electronically. Once in the system, select “advance search,” then key in 

the docket ID number identified above for EPA. 
7. Sources 

BLS 2009. U.S. Bureau of Labor Statistics. Employer Costs for Employee Compensation 

Supplementary Tables: Historical Data December 2006 – December 2008. (March12, 2009)

http://www.bls.gov/ncs/ect/sp/ecsuphst.pdf. 

EPA, 2002a. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy 

Analysis Branch. Economic Analysis for the Amended Inventory Update Rule: Final Report 

(EPA-HQ-OPPT-2002-0054-0260). August 2002. 

EPA, 2002b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy 

Analysis Branch. Wage Rates for Economic Analysis of the Toxics Release Inventory Program. 

June 10, 2002. 

EPA, 2005. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis 

Branch. Economic Analysis of IUR Modifications Final Rule (EPA-HQ OPPT 2004-0106-

0055). July 2005. 

EPA, 2006. US EPA, Office of Pollution Prevention and Toxics, Instructions for Reporting for 

the 2006 Partial Updating of the TSCA Chemical Inventory Database. Nov. 2006. Available 

at http://www.epa.gov/iur/pubs/2006_inst_tsca_cheminv.pdf. 

EPA, 2007. U.S. EPA, Office of Environmental Information. A Business Case Analysis of EPA’s 

Central Data Exchange. March, 2007. 

EPA, 2008a. ICR No. 1884.04. [Information Collection Request for] Partial Update of the TSCA 

Section 8(b) Inventory Data Base, Production and Site Report Supporting Statement for a 

Request for OMB Review under the Paperwork Reduction Act. September 5, 2008. EPA-HQOPPT-2008-0504-0002. 

EPA, 2008b. U.S. EPA, Office of Pollution Prevention and Toxics, Information Management 

Division, 2006 IUR Database Statistics for IUR Modifications Rule. Washington, DC. 

December 17, 2008. 

EPA, 2009a. U.S. EPA, Office of Pollution Prevention and Toxics. TSCA Section 4 Federal 

Register Enforceable Consent Agreements.

http://www.epa.gov/oppt/chemtest/pubs/4eca.html. Washington, DC. Updated October 1, 

2009. 

EPA, 2009b. U.S. EPA, Office of Pollution Prevention and Toxics, Sunset Dates of Chemicals 

Subject to Final TSCA Section 4 and Related 12(b) Actions, Modified on September 1, 2009. 

http://www.epa.gov/oppt/chemtest/pubs/sunset.html. Washington, DC. Updated September 1, 

2009.

EPA, 2010. TSCA Section 5 Premanufacture and Significant New Use Notification Electronic 

Reporting; Revisions to Notification Regulations; Final rule. Federal Register (75 FR 773-

790), January 6, 2010) 
EPA, 2011. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy 

Analysis Branch. Economic Analysis for the Final Inventory Update Reporting (IUR) 

Modifications Rule. June, 2011. 

OPM, 2008. Office of Personnel Management, Salary Table 2008-DCB, Washington Baltimore-Northern 

Virginia, DC-MD-PA-VA-WV. Accessed from http://www.opm.gov/oca/08tables/pdf/DCB.pdf.