ECONOMIC ANALYSIS OF EXPEDITED SIGNIFICANT NEW USE RULES 

FOR 65 CHEMICAL SUBSTANCES

 DOES NOT CONTAIN TSCA CBI 

Prepared by:

Economic and Policy Analysis Branch

Economics, Exposure and Technology Division

Office of Pollution Prevention and Toxics

U.S. ENVIRONMENTAL PROTECTION AGENCY

1200 PENNSYLVANIA AVENUE, N.W.

WASHINGTON, DC 20460

September, 2003

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CONTRIBUTORS

The EPA analyst responsible for this report was Carol Rawie. Analytical and draft preparation

support was provided by Abt Associates Inc. under EPA Contract No. 68-W-02-077.

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ABSTRACT

This report estimates costs of a Significant New Use Rule (SNUR) covering 65 chemicals

with recent TSCA Premanufacturing Notifications (PMNs). The SNUR defines Significant

New Uses that trigger EPA notice requirements. To submit a Significant New Use Notice or

request SNUR modification, a firm incurs a $4,456 to $6,956 submission cost, plus a potentially

much higher cost if it performs full health and ecological effects testing to support the

submission. Potential test costs range from under $20,000 to over $2 million per chemical.

By avoiding a Significant New Use, a firm can avoid submission and testing costs, but

may incur other compliance costs. For example, it may incur costs of preventing water releases,

not quantified here but potentially affecting 33 of the 65 chemicals. It may incur costs of

providing worker protection and/or hazard communications, affecting 6 chemicals at $931 to

$20,482 per chemical. Estimates assume 25 exposed workers per site with annual shipments of

roughly 10,000 kg. The firm may also incur hidden costs, not quantified here, for example if it

foregoes profitable opportunities to use the chemical in ways not listed in the PMN (17

chemicals) or limits production volume (4 chemicals). 

Costs are estimated for one chemical at one site, and reflect SNUR restrictions and testing

specific to each chemical, but are not otherwise chemical-specific. EPA receives an average of

ten notices per year due to SNURs. The number of firms affected but not making submissions is

not known, and costs are not aggregated.

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TABLE OF CONTENTS

Page

CONTRIBUTORS ............................................................. i

ABSTRACT ................................................................. ii

LIST OF TABLES ............................................................. v

1.0 INTRODUCTION ....................................................... 1

2.0 COSTS ASSOCIATED WITH A SIGNIFICANT NEW USE RULE (SNUR), BY

OPTION ............................................................... 4

2.1 Comply with SNUR Limits (Option 1) ................................. 5

2.2 Modification or Revocation of a SNUR (Option 2) ....................... 10

2.3 Submission of a SNUN (Option 3) ................................... 13

2.4 Request for an Equivalency Determination (Option 4) .................... 14

2.5 Decision Not to Produce Chemical (Option 5) .......................... 15

2.6 Summary of Costs for Each Option ................................... 15

 3.0 EXPORT NOTIFICATION COSTS .................................. 24

4.0 AGENCY COSTS ...................................................... 24

5.0 ADDITIONAL ANALYSES .............................................. 24

5.1 Regulatory Flexibility Act (RFA) .................................... 25

5.2 Unfunded Mandates Reform Act (UMRA) ............................. 26

5.3 Paperwork Reduction Act (PRA) ..................................... 26

5.4 Executive Order 12866 ............................................ 26

5.5 Executive Order 13132 ............................................ 26

5.6 Executive Order 12898 ............................................ 27

5.7 Executive Order 13045 ............................................ 27

APPENDIX A LIST OF PMNS AND THEIR CHEMICAL NAMES ................ A-1

APPENDIX B INFLATORS AND WAGE RATES ............................... B-1

B.1. Derivation of Loaded Wage Rates ................................... B-1

B.2. Derivation of Inflation Factors ...................................... B-6

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APPENDIX C 

COSTS OF COMPLIANCE WITH A SNUR (OPTION 1): HAZARD

COMMUNICATION, PROTECTION IN THE WORKPLACE, AND

RECORDKEEPING REQUIREMENTS ................................... C-1

C.1 Modifying the Hazard Communication Program ....................... C-1

C.2 Protection in the Workplace ........................................ C-6

C.3 Recordkeeping ................................................. C-19

APPENDIX D COSTS OF TESTING ......................................... D-1

APPENDIX E COSTS OF SUBMITTING A SNUN, REQUEST FOR MODIFICATION OR

REVOCATION OF A SNUR, OR EQUIVALENCY DETERMINATION ......... E-1

APPENDIX F AGENCY COSTS ............................................. F-1

APPENDIX G REFERENCES .............................................. G-1

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LIST OF TABLES

Table 1 Compliance Options and Associated Costs Incurred by a Firm due to SNUR ........ 4

Table 2 Production and Use Restrictions/Requirements ............................... 5

Table 3 Annual Costs of Hazard Communication Requirements ......................... 7

Table 4 Annual Costs of Workplace Protection Requirements .......................... 8

Table 5 Annual Costs of Workplace Protection Requirements - Summary ................. 9

Table 6 Annual Costs of Recordkeeping Requirements ............................... 10

Table 7 Costs of Testing Requirements ........................................... 12

Table 8 Costs of Request to Modify/Revoke SNUR or Submit SNUN ................... 13

Table 9 Costs by PMN Chemical and Option ....................................... 18

Table 10 Annual Per-Site Haz-Comm, Protection in the Workplace, and Recordkeeping Costs,

by Chemical ........................................................... 22

Table A-1 PMNs and Chemical Names Referenced in this SNUR .................... A-1

Table B-1 Derivation of Loaded Wage Rates ...................................... B-4

Table B-2 Derivation of Inflation Factors ......................................... B-6

Table C-1 Annual Costs of Labeling for Distribution in Commerce .................... C-3

Table C-2 Annual Costs of Labeling for Use in Workplace ........................... C-4

Table C-3 Annual Costs for Material Safety Data Sheets (MSDSs) .................... C-5

Table C-4 Annual Costs for Employee Training, Per Chemical ........................ C-6

Table C-5 Annual Costs for Dermal Protection Selection ............................ C-7

Table C-6 Annual Costs of Impermeability Testing ................................. C-8

Table C-7 Annual Cost of Gloves ............................................... C-9

Table C-8 Annual Cost of Protective Eyewear .................................... C-10

Table C-9 Annual Cost of Protective Clothing .................................... C-11

Table C-10 Annual Costs for Respiratory Protection ............................... C-12

Table C-11 Respirator Prices and Average Costs in 1997, by NIOSH Type ............. C-15

Table C-12 Annual Costs of Personal Protective Equipment ......................... C-18

Table C-13 Annual Costs of Recordkeeping Requirements ......................... C-21

Table D-1 Default Parameters for Species, Route, and Study Type .................... D-2

Table D-2 Cost Estimates for Test Guidelines Cited in Batch SNUR .................. D-4

Table D-3 SNUR Testing Requirements and Cost for 65 Chemicals ................... D-7

Table E-1 Industry Costs for SNUN, Request to Modify/Revoke SNUR, or Equivalency

Determination ........................................................ E-1

Table F-1 Agency Costs for SNUN and Other Submission Review and Processing ........ F-2

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1.0 INTRODUCTION

This report presents the U.S. Environmental Protection Agency (EPA), Office of

Pollution Prevention and Toxics  (OPPT s) analysis of the potential costs incurred as a result of a 

Significant New Use Rule (SNUR) being promulgated for 65 chemical substances. EPA

promulgates a SNUR for a substance when potential uses could result in increased exposure to or

releases of the substance, and in turn an unreasonable risk to health or the environment. Each

substance in this group was the subject of at least one premanufacture notice (PMN), and is now

being regulated directly as a result of the PMN review process. Appendix A lists the generic or

specific chemical name and CAS number (if available) for each PMN. 

A SNUR specifies the conditions under which the manufacture, import, and/or processing

of the PMN substance is allowed without prior notice to EPA, thus defining its permissible uses

that do not constitute a Significant New Use. Anything that exceeds what is specified as

allowable in the SNUR is considered a Significant New Use and triggers a submission to EPA. 

For example,

 " if the SNUR specifies that the chemical may only be imported but not manufactured in

the U.S., then manufacture in the U.S. is considered a Significant New Use;

 " if the SNUR specifies a limit to the quantity of the chemical that a firm may produce in

the U.S., then manufacture of any quantity exceeding that limit is considered a

Significant New Use; 

 " if the SNUR limits the use of the chemical to uses (products, applications, and/or

functions) listed in the PMN, then any other use is considered a Significant New Use;

 " if the SNUR limits the amount of the chemical that may be released to water, then any

amount exceeding that limit is considered a Significant New Use; or

 " if the SNUR requires workplace protection or hazard communication (haz comm) for the

chemical, then not providing the required workplace protection or haz comm is

considered a Significant New Use.

If the firm produces, imports, or processes the chemical in commercial quantities, then to

avoid engaging in a Significant New Use that would trigger submission requirements, the firm

must meet the specifications in the SNUR (Option 1). This and four other options are described

below.

"Option 1: Produce the chemical within SNUR restrictions. As described above, the firm

may avoid engaging in a Significant New Use by manufacturing, importing, or

processing within the SNUR restrictions for that chemical. This entails compliance costs

if the firm must change its practices. The firm may also pursue this option temporarily

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while also pursuing options 2, 3, and/or 4 (see below).

 " Option 2: Request for modification or revocation of the SNUR. Under 40 CFR §721.185,

the firm may request modification or revocation of the SNUR. If the request is

successful, then the costs associated with this option are the costs of submitting a request

for modification or revocation of the SNUR, including the costs of developing supporting

data (e.g., testing), plus the possible costs of following Options 1 or 5 during EPA review

of the request.

 " Option 3: Submission of a SNUN. Alternatively or concurrently with other options, the

firm may submit a Significant New Use Notification (SNUN). A SNUN indicates to

EPA that the firm would like to manufacture, import, or process the chemical for a

Significant New Use i.e., in some way other than what is specified as allowable in the

SNUR. The SNUN must be provided to EPA at least 90 days before the firm plans to

commence the manufacture, import, or processing of the substance; it provides EPA with

the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that

activity before it occurs. If EPA allows the new use, then the costs associated with this

option are the costs of submitting the SNUN (including user fee) plus the possible costs

of following Options 1 or 5 during EPA review of the SNUN.

 " Option 4: Request for an equivalency determination. Under 40 CFR §721.30,

manufacturers, importers and processors may petition EPA to consider alternative

controls to prevent release or exposure that are equivalent to those identified in the

SNUR. If EPA allows the alternative controls, then the costs of this option are the costs

of submitting a request for equivalency determination, plus the possible costs of

following Options 1 or 5 during EPA review of the request.

 " Option 5: Decision not to manufacture, import, or process the substance. The firm may

decide simply not to proceed to manufacture, import, or process the substance. While

this option avoids the costs of meeting the specifications in the SNUR or submitting a

request for some alternative, it entails the hidden cost of the profit that will be foregone

as a result of not engaging in the commercial activity originally planned. 

 " Pursue multiple options. The firm may pursue more than one option simultaneously. For

example, it may temporarily produce within the SNUR restrictions (Option 1) while

submitting both a request to modify the SNUR (Option 2) and a SNUN (Option 3). As

another example, the firm may temporarily refrain from production (Option 5) while

petitioning for an equivalency determination (Option 4). 

If the firm makes a submission, there will be a period during which EPA will review the

request or SNUN submitted. Even if EPA grants the firm s request, in addition to the submission

costs, the firm would incur the costs resulting from following Option 1 or Option 5 for the length

of the EPA review period. If EPA does not approve the request, the firm may fall back to

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Options 1 or 5 as a longer term strategy, with their associated costs.

In previous analyses of SNURs, EPA has identified those requirements under Subparts A,

B, C, and D of 40 CFR 721 that may impose costs on manufacturers, importers, and processors

of PMN substances (e.g., RIB 1989). Some of these costs, such as providing personal protective

equipment under §721.63, are estimated and presented as part of this analysis. Other costs, such

as for limiting releases to water, avoiding uses not listed in the PMN, or keeping production

below a specified level, are described only qualitatively.

The different options available to a firm considering the manufacture, import, and/or

processing of a PMN substance covered under a SNUR, and the types of associated costs to the

firm, are summarized in Table 1. The remainder of this report presents estimates of the

quantified portion of costs associated with the SNUR being promulgated for the 65 chemical

substances listed in Appendix A. Section 2 presents estimates of the costs incurred by

manufacturers, importers, and/or processors under each of the possible SNUR options outlined in

Table 1. Section 3 addresses one-time export notification costs. Section 4 presents estimates of

the costs to EPA of administering the SNUR, while Section 5 presents an analysis of other

impacts, as required by various statutes and executive orders.

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Table 1 Compliance Options and Associated Costs Incurred by a Firm due to SNUR

Option Costs

1 Satisfy the limits and/or requirements specified in the

SNUR, such as limiting w ater releases, stick ing to

PMN uses only, impo rting only, limiting volumes,

providing workplace protection, or providing hazard

comm unications.

 

Costs of meeting hazard communication,

personal protective equipment, and

recordk eeping re quirem ents are qu antified in

this report. 

Other costs, such as costs of assessing

compliance with water release restrictions and,

if needed, limiting water releases, or foregoing

non-PM N uses, m ay exist bu t are not qu antified. 

2 Submit a request for modification and revocation of

the SNUR (§721.185).

Costs of submitting a request for modification

or revocation, including costs of developing

supporting data (e.g., testing, if needed).*

3 Submit a Significant New Use Notice (SNUN),

indicating to EPA that the firm would like to

manufacture, import, or process the chemical for a

Significant New Use i.e., in some way other than

what is specified as allowable in the SNUR.

Costs of submitting a SNUN, including user fee.

Testing costs are also possible, but only for a

small minority of chemicals, and so are not

assigned to this option.* 

4 Petition EP A for an equivalency determination to

consider alternative controls to prevent release or

exposure that are equivalent to those identified in the

SNUR.(§721.30)

Costs of submitting a request for equivalency

determination.*

5 Decide not to manufacture, import, or process the

substance, or manufacture only for R&D (The R&D

exemption is cov ered in 40 CFR §7 21.47). 

Cost of the profit foregone as a result of not

engaging in the comm ercial activity o riginally

planned . R&D recordkeeping costs if

manufacture for R&D.

§ numb ers refer to 40 CFR 721 (in the Code of Federal Regulations)

*Firms may follow Options 1 or 5 while pursuing Options 2, 3, and/or 4 (i.e., during the period in which EPA

reviews a submitted request or SNU N), and may fall back to O ptions 1 or 5 if Options 2, 3 or 4 are unsuccessful,

thus incurring costs from m ore than o ne Optio n. 

2.0 COSTS ASSOCIATED WITH A SIGNIFICANT NEW USE RULE (SNUR), BY

OPTION 

As indicated in the introduction, the SNUR specifies the requirements a facility must

meet if it chooses to commence manufacturing, importing, or processing a PMN chemical. When

faced with a SNUR, however, a facility may take one of several courses of action (see Table 1). 

These options are described below in turn, along with estimates of the costs of each. Unless

otherwise indicated, all costs are in year 2002 dollars. Wage rates and inflators used are given in

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Appendix B. 

2.1 Comply with SNUR Limits (Option 1)

Compliance with a SNUR entails meeting one or several requirements related to

production and use, as shown in Table 2 below. While some SNUR requirements or restrictions

may apply to all PMN substances covered in the SNUR, most do not. Among the 65 chemicals

covered in this SNUR, for example, the requirement to provide hazard communication applies to

only four (see Table 2).

 Table 2 Production and Use Restrictions/Requirements

40 CFR Reference

(Code of F ederal Regulations)

Restriction/Requirement Number of PMN C hemica ls

Affected* 

§721.125 Recordkeeping All

§721.90 Limit releases to water 33

§721.80(j) Stick to uses listed in PMN 17

§721.8 0(f) Import only (do not manufacture) 10

§721.80 (p)(q)(r)(s)(t) or (u) Limit production volume 4

§721.63 Workplace protection 3

§721.72 Hazard communication 4

§721.80 (o ther paragraphs) Conform to other restrictions 10

*Some chemicals have more than one type of restriction.

Water releases, production volume limits, PMN uses, import-only

Costs associated with hazard communication (§721.72), protective equipment (§721.63), and

recordkeeping (§721.40) are quantified in this report. Other restrictions may also result in costs

not quantified for this report. For example:

% A producer could incur costs of determining whether discharges to water would constitute

a Significant New Use and of limiting releases in order to avoid the Significant New Use.

% Keeping production volume below specified limits to avoid a Significant New Use could 

result in a decrease in profits if the firm is producing for sale, a potential hidden cost. 

If the firm is producing the chemical for internal use, it may have to substitute to a less

cost-effective chemical, another potential hidden cost. 

% Similarly, avoiding uses not listed in the original PMN could result in hidden costs of

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foregone profits if the firm cannot market the chemical for certain applications. If the

firm wants to use the chemical for internal use, it may have to substitute to other

chemicals or technologies which cost more or have lesser performance resulting in higher

production costs.

% Importing could be costlier than manufacturing a PMN substance in the US.

The requirements and costs of meeting the hazard communication (Haz-Comm),

protective equipment, and recordkeeping requirements are summarized below. A more detailed

presentation of the derivation of these costs is given in Appendix C. The costs of meeting all

Haz-Comm, workplace protection, and recordkeeping requirements are presented, separately for

each PMN, at the end of Section 2 in Table 10. For the present group of 65 PMN substances,

the per-chemical annual quantified costs of complying with these SNUR restrictions to avoid

Significant New Uses range from $923 for chemicals requiring only recordkeeping (most

chemicals) to $21,405 for a chemical requiring both recordkeeping and workplace protection

(including the annual cost of supplying Type 4 respirators).

Hazard Communication Requirements

Each SNUR may require facilities manufacturing, importing, or processing one of the

PMN substances to implement those provisions of their hazard communication (Haz-Comm)

program that pertain to new chemical substances. In the current batch SNUR, compliance with

the Haz-Comm requirements is specified for four of the 65 chemicals.

For purposes of the economic analysis, it is assumed that each facility has in place a HazComm program consistent with that required by OSHA 

s Hazard Communication standard (29

CFR 1910; November 25, 1983). The major elements of the Haz-Comm program that could

apply to a new chemical, based on the requirements in §721.72, are:

% Revision of the existing written Haz-Comm program to incorporate information about the

new chemical [§721.72(a)];

% Creation of labels and application of labels to containers used for distributing the

chemical in commerce [§721.72(b)];

% Creation of labels or signage and posting of hazard data in areas of the facility where the

chemical is used or stored [§721.72(b)];

% Creation and distribution of material safety data sheets (MSDSs) [§721.72(c)]; and 

% Employee awareness training on where and how the chemical is used, the hazards

associated and availability of hazard information about the chemical, and protective

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equipment and other measures in place to reduce and minimize exposure to the chemical

[§721.72(d)]. 

Hazard Communication Costs

The annual costs of compliance with the Haz-Comm requirements for PMN substances

subject to Haz-Comm requirements are estimated at $931 and 15 hours per substance, as

summarized in Table 3. Costs are for substances with full Haz-Comm requirements, and may

overstate Haz-Comm costs for substances with partial requirements. The derivation of these costs

is given in more detail in Appendix C. 

Table 3 Annual Costs of Hazard Communication R equirements

Requirement Cost ($2002) Hours

Update written program $194 4.0

Labeling Distribution in commerce $108 0.5

Use in the workplace $311 1.5

MSDS preparation $96 2.25

Employee training $222 6.75

TOTAL $931 15.0

Figures are roun ded to who le dollars. Substances not subject to all of these requirements may have lower costs.

(See Ap pendix C for derivations.)

Protection in the Workplace Requirements

Under §721.63, manufacturers, importers, or processors must comply with any worker

protection requirements specified in the SNUR for a chemical. The core components of the

worker protection requirements include provision of personal protective equipment (PPE) such

as gloves, goggles, protective clothing, and respirators. PPE requirements are specified for three

of the 65 PMNs covered by this SNUR.

In some cases, EPA specifies the type of PPE required. In other cases, EPA requires

adequate dermal protection but does not specify particular PPE. Instead, it requires the employer

to evaluate worker exposure conditions and hazards, and select appropriate PPE. Generally the

employer is also required to do one or both of the following: (1) perform impermeability testing

on the PPE to ensure the equipment will be impervious to the PMN substance under the expected

conditions of exposure, and/or (2) rely on equipment manufacturers specifications to determine

whether the equipment will provide adequate protection. Employers not already providing

adequate dermal protection would need to do so.

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Protection in the Workplace Costs

The costs of worker protection were originally estimated in a 1989 report, Economic

Analysis of Final Significant New Rules: General Provisions for New Chemical Follow-Up (RIB

1989). They were estimated as a range of costs, depending on the assumed number of workerdays of exposure. The current analysis uses the high-end of the assumptions about worker-day

exposure, and updates costs to 2002 dollars. 

Table 4 Annual Costs of Workplace Protection Requirements

Requirement Cost Hours

Dermal Protection (industrial hygienist) $486 10.0

Impermeability Testing $1,064 2.0

Evaluation of Manufacturer s Specifications $194 4.0

Subtotal $1,745 16.0

Personal Protective Equipment

Gloves (disposable)

Gloves (heavy duty)

$3,012

$9,527

-

Eyewear (standard goggles)

Eyewear (heavy duty goggles)

 $340

 $509

Clothing (coverall, no hood)

Clothing (coverall with hood)

$3,047

$5,145

Respirators*

(i)- Type 1 Respirator $22,530 -

(ii)- Type 2 Respirator $22,530 -

(iii)- Type 3 Respirator $26,121 -

(iv)- Type 4 Respirator $18,737 -

(v)- Type 5 Respirator $67,321 -

(vi)- Type 6 Respirator $52,399 -

(vii)- Type 7 Respirator $10,159 -

(viii)- Type 8 Respirator $27,392 -

(ix)- Type 9 Respirator $67,321 -

(x)- Type 10 Respirator $52,385 -

(xi)- Type 11 Respirator $12,870 -

(xii)- Type 12 Respirator $20,050 -

(xiii)- Type 13 Respirator $80,812 -

(xiv)- Type 14 Respirator $75,583 -

(xv)- Type 15 Respirator $12,829 -

*The numbers in parentheses () refer to paragraphs at 40CFR721.63(a)(5) listing respirator types. Total respirator

costs include costs of the respirator plus the costs of any add-on item s such as hoods, helmets, cartridges, filters,

and caps, if these items are required for a particular resp irator. (See A ppendix C for derivations.)

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The costs of purchasing protective equipment are derived in Appendix C, and have been

annualized based on the assumptions listed above regarding their use and lifetime in the

workplace. Costs for evaluating hazards when PPE is not specified in the SNUR are based on

estimates of the reasonable time required for a safety professional to perform such evaluations. 

Costs for conducting impermeability testing are based on consultation with PPE vendors, as

described in Appendix C. Table 4 summarizes the annual costs associated with protection in the

workplace, including the PPE itself, as well as selecting required dermal protection, and

performing impermeability testing and/or evaluating manufacturer s information.

Table 5 below is a summary of the quantified costs of the worker protection requirements

for substances in this batch SNUR. Costs are per chemical produced at a single site. The costs

are tabulated for each PMN substance in Appendix C. 

In cases where the SNUR specified the type of protective gear, the estimates assume

workers do not currently wear adequate protective equipment. To the extent that workers may

already be adequately protected (as a result of the company s own safety program related to other

chemical hazards, or to comply with OSHA s PPE standards), these costs may be an

overestimate of the actual costs. In cases where the SNUR required dermal protection but did

not specify any particular gear, it was not feasible to determine which particular gear might be

needed, and so only the costs of assessing needs and demonstrating impermeability were

included. This would reflect a situation where the dermal protection is already in place but the

manufacturer must demonstrate that it is adequate. If companies also have to purchase additional

protective gear, costs would be higher than those shown here. For example, if a firm already

providing gloves and goggles determined that it would have to add protective clothing (coverall

without hood) to avoid engaging in a Significant New Use, annual costs would be $3,047 higher

than costs in the table. 

For the three chemicals requiring workplace protection, costs range from $1,745 to

$20,483 per chemical. 

Table 5 Annual Costs of Workplace Protection Requirements - Summary

Protection in the workplace costs No. of C hemica ls Percent of Chemicals

Chemicals with no costs 62 595.4%

Chemicals with costs 3 4.6%

equal to $1,745 * 1 1.5%

equal to $10,164 ** 1 1.5%

equal to $20,483 *, ** 1 1.5%

Total: 65 100.0%

* Covers dermal protection evaluation only, not equipm ent costs (if any).

** Includes costs of respirators

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Recordkeeping Requirements

Recordkeeping requirements are specified for all PMN substances based on the

requirements in §721.125(a-k). While the requirements vary somewhat between substances (i.e.,

there are variations in terms of the types of records that must be kept), the differences are judged

to have a negligible impact on the type of recordkeeping activities that must be performed and

thus, on the costs that will be incurred. 

All recordkeeping requirements essentially involve copying and filing relevant records,

including those related to: manufacturing, importing, or processing volumes; shipment amounts

and customer information; labels (documentation of labeling procedures and copies of labels);

MSDS; and compliance with any additional restrictions on use, disposal, and discharge

limitations. 

Recordkeeping Costs

Annual costs for compliance with the recordkeeping requirements for PMN substances

subject to the SNUR are derived in Appendix C. The costs include technical and clericallabor

time, reproduction charges, and costs for records storage. As shown in Table 6, the

recordkeeping requirements are estimated to cost $923 annually per substance.

Table 6 Annual Costs of Recordkeeping Requirements

Requirement Cost Hours

Technical labor $98 2.25

Clerical labor $551 23.0

Photocopies $130 -

File cabinet $109 -

Miscellan eous m aterials $35 -

TOTAL $923 25.25

Figures are roun ded to who le dollars.

(See Ap pendix C for derivations.)

2.2 Modification or Revocation of a SNUR (Option 2)

Under 40 CFR §721.185, EPA may modify or revoke a SNUR upon review of a submittal

from a manufacturer, importer, or processor. The cost of the option to the manufacturer,

importer, or processor includes the costs of submitting a request for modification or revocation,

plus the cost of developing and submitting data related to the health and environmental effects of

the chemical (e.g., testing costs). This option could have some or all of the following costs: 

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% Costs of testing to develop health and environmental effects data for each chemical

subject to the batch SNUR; 

% Costs of submitting a request for modification or revocation;

% Costs of complying with SNUR restrictions (or of avoiding production) while the

modification request is being processed, and costs of complying with any SNUR

restrictions that are not ultimately revoked (see the discussion of Option 1 for compliance

costs).

These costs are discussed below.

Costs of Developing and Submitting Required Testing Data

For each PMN substance, the SNUR identifies any health, ecological, and/or

fate/transport/transformation testing that would help characterize the risks associated with the

substance. Such testing is recommended but not required in the SNUR, and may be provided by

the submitter to support a request for modification and revocation of a SNUR. 40 CFR

721.185(b)(1) requires that a modification request include information sufficient to support the

request. 

This analysis assumes the firm elects to perform all of the tests. In some cases the

recommended testing is indeed needed for the request to be granted. However, in other cases,

full testing may not be needed for example, if toxicity information has become available from

another source and costs would be lower than shown here. If no testing at all is needed with a

modification request, costs would be similar to costs of a SNUN, less the user fee. (See SNUN

discussion below.)

The SNUR lists recommended tests by guideline numbers which can be used to look up

published test protocols. Testing costs for each PMN substance are calculated by adding up costs

for individual test protocols listed in the SNUR for that substance. The costs for individual test

protocols have been developed by EPA over the years to support TSCA rule development. For

this analysis, costs have been inflated to 2002 dollars. Detailed information on the procedure

used to estimate testing costs for each PMN substance is found in Appendix D. 

Table 7 below summarizes the cost ranges of the testing requirements specified for 63 of

the 65 PMN chemicals. For two chemicals, the SNUR did not recommend tests. The table shows

a range of test costs for persistant bioaccumulator toxic (PBT) chemicals identified for tiered

testing, since tests in later tiers are not always triggered by results of earlier test tiers (see

Appendix D for details). 

For chemicals with tests, testing costs range from $19,980 to $2,070,673 per chemical,

and the mean testing cost is $298,649 per chemical using the low end of testing cost range and

EPA SANITIZED Page 17 of 90
12

$325,026 using the high end. Test costs are per company, and are one-time costs (not

annualized). For many chemicals, if full testing is needed, the test costs could dominate the costs

quantified in this report. However, essential hazard data may become available from other

sources, so tests are not always needed. Test costs in Table 7 most likely represent a high-side

estimate of testing costs attributable to the SNUR.

Table 7 Costs of Testing Requirements

Testing Costs No. of C hemica ls Percent of Chemicals

Less than $30,000 1 1.6%

Between $30,001 and $50,000 23 36.5%

Between $50,001 and $100,000 9 (7) 14.3% (11.1%)

Between $100,001 and $500,000 22 (24) 34.9% (38.1%)

Between $500,000 and $1,000,000 2 3.2%

Over $1,000,000 6 9.5%

Total: 63* 100.0%

Mean: $298,649 ($325,026)

Median: $98,595 ($118,008)

Minimum: $19,980

Maximum: $2,070,673

Numb ers in parenthesis are derived using the high end of testing co sts.

*The SN UR did no t list tests for two of the 65 chem icals.

(See Ap pendix D for details.)

Costs for Submitting a Request for Modification or Revocation of a SNUR

The costs associated with submitting a request for modification and revocation of a

SNUR are estimated to be similar to the costs for preparing a PMN submission. In its

Regulatory Impact Analysis for the amendments to the PMN regulations, EPA relied on industry

estimates of the effort needed to collect and compile all data required for a PMN submission,

prepare the form, and submit the form and data to EPA (RIB 1994). These estimates, based on a

1991 survey conducted by the Chemical Manufacturers Association, indicate that the average

effort required to prepare and submit a PMN is between 95 and 114 hours. This analysis uses the

average of the estimated hours for each step, resulting in a cost of $4,456. The costs associated

with these labor time estimates are derived in Appendix E. 

Other Costs

EPA s review of the submitter s request may cause delays in the start of manufacturing or

processing activities. Such delays could cause the company to forego opportunities to earn

EPA SANITIZED Page 18 of 90
13

profits for the duration of the review period. Alternatively, the submitter may elect to produce

under the constraints of the SNUR during the review period, so as to avoid a Significant New

Use. EPA may not revoke all SNUR provisions as a result of the request. If the company is

allowed to continue production and chooses to do so, it would bear costs of complying with any

SNUR restrictions that are not revoked. Costs of complying with SNUR restrictions are not

quantified in Table 8, but were discussed under Option 1. 

Table 8 Costs of Request to Modify/Revoke SNUR or Submit SNUN

Request to Modify or Revoke

SNUR (Option 2)

Submit a SNUN 

(Option 3)

Hours

Total Labor Cost

(wage × hours) Hours

Total Labor Cost

(wage × hours)

Costs of preparing submission 

105 $4,456 105 $4,456

User fees NONE $2,500

TOTAL $4,456 $6,956

Test Costs More likely Less likely

Figures are rounded to whole dollars. (See Appendix E for derivation)

Total Costs for Option 2

The total costs associated with requesting a modification or revocation of a SNUR include

the costs of performing any needed testing plus the administrative cost of preparing the submittal. 

As shown above, for chemicals with tests, testing costs may range from $19,980 to $2,070,673

per chemical. Other quantified costs of submitting a request for revocation or modification are

$4,456. These costs are combined in Table 9, which shows total costs by option for each of the

PMNs. If full testing is not needed, costs could be much lower than shown in Table 9.

2.3 Submission of a SNUN (Option 3)

Under 40 CFR §721.5, manufacturers, importers, or processors who would like to

undertake a Significant New Use of a PMN substance listed in a SNUR are required to submit a

Significant New Use Notice (SNUN). For example, they could submit a SNUN if they wish to

produce above the volume limit listed in the SNUR for a given chemical, since any production

beyond that volume would be defined as a Significant New Use. The notice form used to submit

a SNUN is the same as that for a PMN, and the costs of submitting a SNUN are estimated based

EPA SANITIZED Page 19 of 90
14

on the costs incurred to submit a PMN. This option could have the following costs:

% Costs of preparing the SNUN. 

% Cost of the $2500 user fee.

% Costs of complying with SNUR restrictions (or of avoiding production) while the SNUN

is being processed; costs of complying with any restrictions resulting from the SNUN

review. (see the discussion of Option 1 for compliance costs).

% The SNUN submitter may need to perform some of the tests listed in the batch SNUR.

However, the likelihood of testing being needed is judged to be less for a SNUN than for

the request to modify the SNUR (Option 2). This analysis assumes the firm would not

perform testing for the SNUN. (If testing were needed, then Option 3 costs may be closer

to those estimated for Option 2.) 

Another option available to sites before the SNUR is promulgated is to seek an advance

compliance exemption under §721.45(h). The submission cost for the option is the same as that

for a SNUN, but by negotiating an advance compliance agreement with EPA a company can

diminish the loss of profits due to delay. This option is not available after the SNUR is

promulgated.

Costs for Submitting a SNUN

As with Option 2 above (Modification or Revocation of a SNUR), the costs for submitting

a SNUN are estimated to be equivalent to the costs of completing a PMN submission. From

Table 8, the costs of preparing a SNUN are $6956, including the $2500 user fee (as shown in

Appendix E). If the SNUN is submitted at the same time as a request to modify a SNUR (Option

2), the added would be less than shown here due to overlap in information in the two submissions. 

In addition, as was mentioned above, there could be testing costs, delay costs, or other costs not

included in Table 9 for this option. 

2.4 Request for an Equivalency Determination (Option 4)

Under 40 CFR §721.30, EPA may review applications from facilities who propose

alternative methods of controlling or preventing exposures or releases to those specified in the

SNUR. In these cases, EPA evaluates the alternatives using an abbreviated review process. The

costs of submitting an equivalency determination request are expected to be the same as those for

submitting a SNUN in Option 3, except that no user fee is required. Thus, the costs for this option

are estimated at $4456. 

EPA SANITIZED Page 20 of 90
15

For this option the EPA review period is 45 days compared to 90 days for a SNUN,

therefore any potential loss of profits due to delays may be less than for a SNUN under Option 3.

In addition to the costs of submitting the equivalency determination request, each

submitter will also incur costs to develop data to support the request. These costs were not

quantified. Presumably, however, a submitter would not choose this option unless the total costs

of this option, including the costs of complying with the proposed alternative requirements, were

less than the costs of complying with controls listed in the SNUR for example, controls related

to workplace protection or environmental release (Option 1). Otherwise there would be no

incentive for the submitter to choose this alternative. 

2.5 Decision Not to Produce Chemical (Option 5)

Some firms may find that the costs of meeting the SNUR requirements and/or restrictions

(Option 1) or preparing a SNUN or other submission (Options 2, 3, or 4) are financially

unattractive. In these cases, the firm could choose not to manufacture, import, or process the

PMN substance. If the firm chooses this option, it would avoid the costs that would be incurred

under these other options, but could instead incur hidden costs as a result of not manufacturing,

importing, or processing the PMN substance. For example, if the firm does not produce the PMN

substance, then it will forego the profit it would have achieved by producing it. That foregone

profit is a potential hidden cost of Option 5. Similarly, if the firm would have used a given

amount of the PMN substance in the production of another product and must substitute to a more

costly substance, it will incur those additional costs of production. If the firm elects to produce

for R&D purposes only, it may have costs associated with R&D recordkeeping.

2.6 Summary of Costs for Each Option

Table 9 presents, for each PMN, the quantified costs of the first four options. Companies

may pursue more than one option at a time, such as temporarily producing in conformance with

Option 1 restrictions, while also submitting a SNUN and requesting a modification to the SNUR.

Costs are estimated for one chemical at one site, and reflect SNUR restrictions and testing

specific to each chemical. They are not otherwise adjusted for the nature of the chemical or

process, volume, location, or other firm-specific or chemical-specific factors. EPA receives an

average of ten notices per year due to SNURs, but the number of firms affected but not making

submissions is not known, and costs are not aggregated.

Most or all of the PMN chemicals in the SNUR are subject to recordkeeping and testing

costs. Most are also subject to unquantified costs due to use, water release, volume or other

restrictions for which the magnitude of impact is not known. By contrast, only a few are subject

to workplace protection or hazard communication costs, which appear to be relatively modest. 

EPA SANITIZED Page 21 of 90
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Of the quantified costs, testing costs have the potential to dominate all other costs, but

only if testing is indeed needed to support a submission.

Table 10 shows the annual per-site costs of haz-comm, protection in the workplace, and

recordkeeping by chemical. All of the chemicals had recordkeeping costs of $923. As mentioned

previously, those chemicals with haz-comm costs were assumed to have the same cost at $931.19. 

Two of the three chemicals that had quantifiable protection in the workplace requirements had

respirator costs and two of the three chemicals had costs for dermal protection selection and

equipment evaluation.

The salient features of the costs of each of the five options are summarized as follows:

Option 1 Compliance with the SNUR restrictions to avoid Significant New Use

Three categories of cost hazard communication, workplace respiratory protection, and

recordkeeping have been quantified for this report. Workplace dermal protection has been partly

quantified. These quantified costs, presented in Table 10, are modest for most of the SNUR

chemicals, when estimated for an assumed 25 exposed workers and roughly 10,000 kg annual

shipment volume per plant for one chemical.

 " Most PMN chemicals (61 of the 65) require only recordkeeping, which is estimated to cost

$923 per year. 

 " Three PMN chemicals require, in addition, hazard communication, which is estimated to

cost $931 per year, for a total annual cost of $1,854. 

 " Quantified annual costs among the remaining three chemicals are estimated to be $2,668,

for dermal protection evaluation (excluding equipment costs), and $12,013 and $21,405

for two different levels of respiratory protection. 

In addition, there are a variety of potential costs that have not been quantified in this report

 not because these costs are necessarily small, but because they are difficult to quantify for

example, the cost of limiting releases to water, the cost of limiting production volume, the cost of

avoiding non-allowed uses of the PMN substance, and the cost of importing rather than

manufacturing the PMN substance. Most chemicals listed in the SNUR have restrictions that

could lead to nonquantified costs.

Option 2 Modification or revocation of the SNUR

As noted in Section 2.2, there are three potential components to the cost of Option 2:

submitting the request, testing, and non-quantified costs. 

 " The cost associated with submitting a request for modification or revocation of a SNUR is

EPA SANITIZED Page 22 of 90
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estimated to be $4,456 and will be incurred if this option is chosen. There is no user fee.

 " In addition, there may be testing costs. Testing is recommended for most chemicals, and

while not mandatory, may be performed by the submitter to support a request for

modification or revocation of a SNUR. The costs of testing are highly variable, depending

on the particular test(s) listed in the SNUR for each chemical. If all listed tests are

performed, testing costs are estimated to range from $19,980 to $2,070,673 per chemical;

however, the bulk of the PMN chemicals would require testing costs between $30,000 and

$500,000. For most chemicals, if all listed tests are performed as a result of the SNUR,

test costs would dominate other quantified costs. 

Both the costs of submission of the request and testing costs are one-time costs (not

annualized). The total quantified cost of this option thus ranges from a one-time cost of $24,436

to a one-time cost of $2,075,129, if testing is involved, and could be as low as $4,456 if it is not. 

As with Option 1, there may also be costs that have not been quantified in this report, and

this lack of quantification reflects the difficulty of quantifying these costs rather than their relative

magnitude. 

Option 3 Submission of a SNUN

The quantified cost of Option 3 consists of the cost of submitting the SNUN, $4,456, plus

a user fee of $2,500, for a total quantified cost of $6,956. As with the cost of Option 2, this is a

one-time cost. 

In addition, there could be testing costs like those in Option 2. These are judged to be

needed in relatively few cases, so were not included in Option 3 quantified costs. There also

could be delay costs, or other costs not quantified in this report. 

Option 4 Request for an equivalency determination

The quantified cost of requesting an equivalency determination consists of the one-time

cost of $4,456 for the submittal of the request. There is no user fee involved. 

Option 5 Avoid manufacture (except for R&D uses)

Although none of the costs of Option 5 are direct costs of satisfying requirements or

preparing submissions, and none of the costs of this option have been quantified in this report,

there may nevertheless be hidden costs if the firm decides to avoid the manufacture, import, or

processing of the PMN substance. The magnitude of these hidden costs is unknown and will

depend on particular circumstances. 

EPA SANITIZED Page 23 of 90
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Table 9 Costs by PMN Chemical and Option

Option 1 Option 2 Option 3 Option 4

 Produce within SNUR

criteria to avoid signif.

new use (a)

Modification or Revocation of SNUR (b) Submission of SNUN (c) Request for Equivalency

Determination (d)(e)

Cost Range Hours Range

No. PMN Cost Hours Low High Low High Cost Hours Cost Hours

1 P-97-1108 $923 25.3 $122,464 $122,464 1,168 1,168 $6,956 105 $4,456 105

2 P-98-848 $923 25.3 $2,075,129 $2,075,129 25,310 25,310 $6,956 105 $4,456 105

3 P-98-1033 $1,854 40.3 $301,972 $301,972 3,392 3,392 $6,956 105 $4,456 105

4 P-98-1034 $1,854 40.3 $301,972 $301,972 3,392 3,392 $6,956 105 $4,456 105

5 P-98-1035 $1,854 40.3 $301,972 $301,972 3,392 3,392 $6,956 105 $4,456 105

6 P-99-783 $923 25.3 $24,435 $24,435 218 218 $6,956 105 $4,456 105

7 P-99-817 $923 25.3 $345,009 $345,009 2,562 2,562 $6,956 105 $4,456 105

8 P-99-897 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

9 P-99-920 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

10 P-99-928 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

11 P-99-951 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

12 P-99-952 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

13 P-99-1075 $923 25.3 $81,653 $81,653 628 628 $6,956 105 $4,456 105

14 P-99-1202 $923 25.3 $422,207 $422,207 3,086 3,086 $6,956 105 $4,456 105

15 P-99-1288 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

16 P-99-1295 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

17 P-99-1304 $923 25.3 $378,613 $378,613 2,742 2,742 $6,956 105 $4,456 105

18 P-99-1341 $923 25.3 $34,673 $34,673 302 302 $6,956 105 $4,456 105

19 P-99-1342 $923 25.3 $34,673 $34,673 302 302 $6,956 105 $4,456 105

20 P-00-7 $923 25.3 $345,009 $345,009 2,562 2,562 $6,956 105 $4,456 105

21 P-00-368 $12,013 40.3 $411,223 $411,223 3,026 3,026 $6,956 105 $4,456 105

22 P-00-636 $2,668 41.3 $1,333,813 $1,333,813 13,404 13,404 $6,956 105 $4,456 105

23 P-00-838 $923 25.3 $38,939 $38,939 396 396 $6,956 105 $4,456 105

24 P-00-912 $923 25.3 $1,081,076 $1,399,774 10,154 13,659 $6,956 105 $4,456 105

EPA SANITIZED Page 24 of 90
Option 1 Option 2 Option 3 Option 4

 Produce within SNUR

criteria to avoid signif.

new use (a)

Modification or Revocation of SNUR (b) Submission of SNUN (c) Request for Equivalency

Determination (d)(e)

Cost Range Hours Range

No. PMN Cost Hours Low High Low High Cost Hours Cost Hours

19

25 P-00-966 $923 25.3 $48,273 $48,273 396 396 $6,956 105 $4,456 105

26 P-00-991 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

27 P-00-1055 $923 25.3 $1,488,592 $1,488,592 14,902 14,902 $6,956 105 $4,456 105

28 P-00-1205 $923 25.3 $38,959 $38,959 326 326 $6,956 105 $4,456 105

29 P-00-1220 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

30 P-01-1 $923 25.3 $57,814 $57,814 516 516 $6,956 105 $4,456 105

31 P-01-7 $923 25.3 $902,690 $902,690 9,536 9,536 $6,956 105 $4,456 105

32 P-01-9 $923 25.3 $160,308 $479,006 1,045 4,550 $6,956 105 $4,456 105

33 P-01-22 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

34 P-01-69 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

35 P-01-71 $923 25.3 $88,747 $88,747 710 710 $6,956 105 $4,456 105

36 P-01-77 $923 25.3 $147,524 $147,524 1,430 1,430 $6,956 105 $4,456 105

37 P-01-85 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

38 P-01-97 $923 25.3 $925,224 $925,224 9,214 9,214 $6,956 105 $4,456 105

39 P-01-144 $923 25.3 $279,249 $279,249 3,306 3,306 $6,956 105 $4,456 105

40 P-01-149 $923 25.3 $125,584 $125,584 938 938 $6,956 105 $4,456 105

41 P-01-152 $923 25.3 $98,637 $501,626 559 4,669 $6,956 105 $4,456 105

42 P-01-170 $21,405 41.3 $4,456 $4,456 104 104 $6,956 105 $4,456 105

43 P-01-298 $923 25.3 $103,051 $103,051 1,262 1,262 $6,956 105 $4,456 105

44 P-01-320 $923 25.3 $345,009 $345,009 2,562 2,562 $6,956 105 $4,456 105

45 P-01-397 $923 25.3 $81,653 $81,653 628 628 $6,956 105 $4,456 105

46 P-01-420 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

47 P-01-423 $923 25.3 $345,009 $345,009 2,562 2,562 $6,956 105 $4,456 105

48 P-01-432 $923 25.3 $1,513,379 $1,513,379 14,680 14,680 $6,956 105 $4,456 105

49 P-01-433 $923 25.3 $378,613 $378,613 2,742 2,742 $6,956 105 $4,456 105

EPA SANITIZED Page 25 of 90
Option 1 Option 2 Option 3 Option 4

 Produce within SNUR

criteria to avoid signif.

new use (a)

Modification or Revocation of SNUR (b) Submission of SNUN (c) Request for Equivalency

Determination (d)(e)

Cost Range Hours Range

No. PMN Cost Hours Low High Low High Cost Hours Cost Hours

20

50 P-01-441 $923 25.3 $98,637 $501,626 559 4,669 $6,956 105 $4,456 105

51 P-01-459 $923 25.3 $345,009 $345,009 2,562 2,562 $6,956 105 $4,456 105

52 P-01-460 $923 25.3 $345,009 $345,009 2,562 2,562 $6,956 105 $4,456 105

53 P-00-992

and

P-01-471

$923 25.3 $81,653 $81,653 628 628 $6,956 105 $4,456 105

54 P-01-481 $923 25.3 $4,456 $4,456 104 104 $6,956 105 $4,456 105

55 P-01-561 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

56 P-01-573 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

57 P-01-578 $923 25.3 $34,673 $34,673 302 302 $6,956 105 $4,456 105

58 P-01-646 $923 25.3 $34,673 $34,673 302 302 $6,956 105 $4,456 105

59 P-01-716 $923 25.3 $260,670 $479,006 1,908 4,550 $6,956 105 $4,456 105

60 P-01-781 $923 25.3 $1,351,498 $1,351,498 12,442 12,442 $6,956 105 $4,456 105

61 P-01-833 $923 25.3 $345,009 $345,009 2,562 2,562 $6,956 105 $4,456 105

62 P-02-17 $923 25.3 $103,051 $103,051 1,262 1,262 $6,956 105 $4,456 105

63 P-02-90 $923 25.3 $345,009 $345,009 2,562 2,562 $6,956 0105 $4,456 105

64 P-02-207 $923 25.3 $38,060 $38,060 284 284 $6,956 105 $4,456 105

65 P-02-262 $923 25.3 $378,613 $378,613 2,742 2,742 $6,956 105 $4,456 105

Minimum $923 25 $4,456 $4,456 105 105 $6,956 105 $4,456 105

Maximum $21,405 41 $2,075,129 $2,075,129 25311 25311 $6,956 105 $4,456 105

Average $1,479 27 $293,916 $319,481 2746 3021 $6,956 105 $4,456 105

Median $923 25 1$98,637 $103,051 710 1168 $6,956 105 $4,456 105

EPA SANITIZED Page 26 of 90
21

(a) Option 1 includes annual costs for recordkeeping ($923), haz-comm ($931), and worker protection. Costs of other restrictions were not quantified (limiting

water discharges, avoiding uses not listed in PMN, import only, limiting production volume, etc.). See Table 10 and Appendix C.

(b) Option 2 includes one-time costs of request to modify/revoke SNUR ($4,456) and for testing. For chemicals with PBT testing, 

low cost assumes Tier 1 test

results do not trigger more testing. High costs assume Tier 1 test results trigger more testing. (See Appendix D.) Costs of following SNUR restrictions pending

Agency revocation of SNUR were not quantified. If full testing is not needed, costs would be lower. For test costs by PMN chemical, see Table D-3.

(c) Option 3 includes one-time costs of SNUN ($4,456) plus a $2500 user fee. Costs of following restrictions during or resulting from Agency review were not

quantified. Analysis assumes no testing costs for this option. If testing is also needed, costs would be higher.

(d) Option 4 includes one-time costs of request for equivalency determination ($4,456). Costs of following SNUR restrictions during review and of alternative

controls were not quantified.

(e) Option 5 (no production or import except for R&D), has no quantified costs and so is not listed in this table. However, most PMN chemicals have other

restrictions which could lead to unquantified costs, such as restrictions on releases to water, uses not listed in PM N, or production volumes.

EPA SANITIZED Page 27 of 90
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Table 10 Annual Per-Site Haz-Comm, Protection in the Workplace, and Recordkeeping Costs, by Chemical

Hazard Commun Workplace Protection Record Keeping Total Total

Cost Hours Cost Hours Cost Hours Cost Hours

No. PMN

1 P-97-1108 $0.00 0 $0.00 0 $923 25.3 $923 25.3

2 P-98-848 $0.00 0 $0.00 0 $923 25.3 $923 25.3

3 P-98-1033 $931.19 15 $0.00 0 $923 25.3 $1,854 40.3

4 P-98-1034 $931.19 15 $0.00 0 $923 25.3 $1,854 40.3

5 P-98-1035 $931.19 15 $0.00 0 $923 25.3 $1,854 40.3

6 P-99-783 $0.00 0 $0.00 0 $923 25.3 $923 25.3

7 P-99-817 $0.00 0 $0.00 0 $923 25.3 $923 25.3

8 P-99-897 $0.00 0 $0.00 0 $923 25.3 $923 25.3

9 P-99-920 $0.00 0 $0.00 0 $923 25.3 $923 25.3

10 P-99-928 $0.00 0 $0.00 0 $923 25.3 $923 25.3

11 P-99-951 $0.00 0 $0.00 0 $923 25.3 $923 25.3

12 P-99-952 $0.00 0 $0.00 0 $923 25.3 $923 25.3

13 P-99-1075 $0.00 0 $0.00 0 $923 25.3 $923 25.3

14 P-99-1202 $0.00 0 $0.00 0 $923 25.3 $923 25.3

15 P-99-1288 $0.00 0 $0.00 0 $923 25.3 $923 25.3

16 P-99-1295 $0.00 0 $0.00 0 $923 25.3 $923 25.3

17 P-99-1304 $0.00 0 $0.00 0 $923 25.3 $923 25.3

18 P-99-1341 $0.00 0 $0.00 0 $923 25.3 $923 25.3

19 P-99-1342 $0.00 0 $0.00 0 $923 25.3 $923 25.3

20 P-00-7 $0.00 0 $0.00 0 $923 25.3 $923 25.3

21 P-00-368 $931.19 15 $10,158.75* 0 $923 25.3 $12,013 40.3

22 P-00-636 $0.00 0 $1,744.65** 16 $923 25.3 $2,668 41.3

23 P-00-838 $0.00 0 $0.00 0 $923 25.3 $923 25.3

24 P-00-912 $0.00 0 $0.00 0 $923 25.3 $923 25.3

25 P-00-966 $0.00 0 $0.00 0 $923 25.3 $923 25.3

26 P-00-991 $0.00 0 $0.00 0 $923 25.3 $923 25.3

27 P-00-1055 $0.00 0 $0.00 0 $923 25.3 $923 25.3

28 P-00-1205 $0.00 0 $0.00 0 $923 25.3 $923 25.3

29 P-00-1220 $0.00 0 $0.00 0 $923 25.3 $923 25.3

30 P-01-1 $0.00 0 $0.00 0 $923 25.3 $923 25.3

31 P-01-7 $0.00 0 $0.00 0 $923 25.3 $923 25.3

32 P-01-9 $0.00 0 $0.00 0 $923 25.3 $923 25.3

33 P-01-22 $0.00 0 $0.00 0 $923 25.3 $923 25.3

34 P-01-69 $0.00 0 $0.00 0 $923 25.3 $923 25.3

35 P-01-71 $0.00 0 $0.00 0 $923 25.3 $923 25.3

36 P-01-77 $0.00 0 $0.00 0 $923 25.3 $923 25.3

37 P-01-85 $0.00 0 $0.00 0 $923 25.3 $923 25.3

38 P-01-97 $0.00 0 $0.00 0 $923 25.3 $923 25.3

39 P-01-144 $0.00 0 $0.00 0 $923 25.3 $923 25.3

EPA SANITIZED Page 28 of 90
Hazard Commun Workplace Protection Record Keeping Total Total

Cost Hours Cost Hours Cost Hours Cost Hours

No. PMN

23

40 P-01-149 $0.00 0 $0.00 0 $923 25.3 $923 25.3

41 P-01-152 $0.00 0 $0.00 0 $923 25.3 $923 25.3

42 P-01-170 $0.00 0 $20,481.99 16 $923 25.3 $21,405 41.3

43 P-01-298 $0.00 0 $0.00 0 $923 25.3 $923 25.3

44 P-01-320 $0.00 0 $0.00 0 $923 25.3 $923 25.3

45 P-01-397 $0.00 0 $0.00 0 $923 25.3 $923 25.3

46 P-01-420 $0.00 0 $0.00 0 $923 25.3 $923 25.3

47 P-01-423 $0.00 0 $0.00 0 $923 25.3 $923 25.3

48 P-01-432 $0.00 0 $0.00 0 $923 25.3 $923 25.3

49 P-01-433 $0.00 0 $0.00 0 $923 25.3 $923 25.3

50 P-01-441 $0.00 0 $0.00 0 $923 25.3 $923 25.3

51 P-01-459 $0.00 0 $0.00 0 $923 25.3 $923 25.3

52 P-01-460 $0.00 0 $0.00 0 $923 25.3 $923 25.3

53 P-00-992 and

P-01-471

$0.00 0 $0.00 0 $923 25.3 $923 25.3

54 P-01-481 $0.00 0 $0.00 0 $923 25.3 $923 25.3

55 P-01-561 $0.00 0 $0.00 0 $923 25.3 $923 25.3

56 P-01-573 $0.00 0 $0.00 0 $923 25.3 $923 25.3

57 P-01-578 $0.00 0 $0.00 0 $923 25.3 $923 25.3

58 P-01-646 $0.00 0 $0.00 0 $923 25.3 $923 25.3

59 P-01-716 $0.00 0 $0.00 0 $923 25.3 $923 25.3

60 P-01-781 $0.00 0 $0.00 0 $923 25.3 $923 25.3

61 P-01-833 $0.00 0 $0.00 0 $923 25.3 $923 25.3

62 P-02-17 $0.00 0 $0.00 0 $923 25.3 $923 25.3

63 P-02-90 $0.00 0 $0.00 0 $923 25.3 $923 25.3

64 P-02-207 $0.00 0 $0.00 0 $923 25.3 $923 25.3

65 P-02-262 $0.00 0 $0.00 0 $923 25.3 $923 25.3

* This cost consists of the annual cost of supplying respirators. For this chemical, the SNUR listed a choice between

Type 3, 4, 5, 6, or 7 respirators. The annual cost of the least expensive respirator (Type 7) is used here.

**This cost consists of dermal protection selection ($486.04) and impermeability testing / evaluation of

manufacturer s specifications ($1258.61). Costs of added dermal protection equipment, if any, not included.

***This cost consists of dermal protection selection ($486.04), impermeability testing / evaluation of manufacturer s

specifications ($1258.61), and the annual cost of supplying Type 4 respirators ($18,737.34). Costs of added dermal

protection equipment, if any, not included. 

EPA SANITIZED Page 29 of 90
24

3.0 EXPORT NOTIFICATION COSTS

Under Section 12(b) of TSCA, exporters must notify EPA if they export or intend to

export a chemical substance or mixture: 

"For which submission of data is required under Section 4 or 5(b);

"For which an order has been issued under Section 5;

"For which a rule has been proposed or promulgated under Section 5 or 6; or

"With respect to which an action is pending or relief has been granted under Section

5 or 7.

Notifications must be submitted in writing and must include the following information:

exporter s name and address, name of the regulated chemical, the date(s) of export or intended

export, the importing country (or countries), and the section of TSCA under which EPA has taken

action. This is a one-time notification requirement, and the exporter need only submit the notice

when it is exporting a particular chemical for the first time to a country for which it has not

previously submitted a notification.

In an economic analysis of an amendment to the rules implementing TSCA Section 12(b),

EPA estimated that the one-time cost of preparing and submitting an export notification was

$62.60 in 1992 (Silagi 1992), or $89.29 when inflated to 2002 dollars by a factor of approximately

1.43, from the Employment Cost Index for White Collar Occupations (BLS 2003a; see Appendix

B). The total costs of export notification will vary per chemical, depending on the number of

required notifications (i.e., number of countries to which the chemical is exported). EPA is

unable to make any estimate of the likely number of export notifications for chemicals covered in

this SNUR.

4.0 AGENCY COSTS

EPA s costs to review and process industry submissions (SNUNs, requests to modify

SNUR, and requests for equivalency determination) are assumed to be the same as EPA costs to

review PMNs. These costs are estimated at $4,034 per case. The Agency actions required, fulltime equivalent (FTE) staff needs, and extramural costs such as for contractor support are derived

in Appendix F from EPA s analysis of the Agency costs of processing PMN submissions (RIB

1994), with updates to 2002 prices. The original EPA analysis used a range of salaries, but this

analysis uses only the average salary. See Appendix F for details. 

5.0 ADDITIONAL ANALYSES

This section presents additional analysis of other potential impacts of this rulemaking, as

required under various statutes and executive orders.

EPA SANITIZED Page 30 of 90
1

Bona fides are submitted to EPA by manufacturers and importers to determine a chemical s TSCA Chemical Inventory and

regulatory status.

2 Due to timing and resource limitations, another possible source of data -- the year 2002 industry reporting under the 1986

Inventory Update Rule (51 FR 21438) -- was not tapped for this report. 

25

5.1 Regulatory Flexibility Act (RFA)

 The Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et. seq.), as amended by the Small

Business Regulatory Enforcement Fairness Act, requires regulators to consider the impact of

regulations on small entities, in particular small businesses. EPA s experience to date is that, in

response to the promulgation of SNURS covering over 1000 chemicals , the Agency receives an

average of only ten notices per year. Of those SNUNs submitted, none appear to be from small

entities in response to any SNUR. In fact, EPA expects to receive few, if any, SNUNs from either

large or small entities in response to any SNUR. 

This leaves open the question of how many small businesses are affected but do not

submit SNUNs. For example, businesses may change their behavior in order to use a chemical in

a manner that avoids triggering the SNUR. 

Data and resources were not available to estimate the number of small businesses affected

by the current rule. However, a 1989 analysis suggested that few small businesses would be

affected by SNURs for chemicals that have undergone PMN review. The 1989 report estimated

that 9% of firms subject to SNURs would be small businesses, based on the portion of PMN

submitters who were small businesses. (Long 1989) The cutoff for small business was $40

million in sales, which is consistent with the definition used at 40 CFR 700.43 to set PMN fees.

Past bona fide submissions also suggest that few firms other than possibly some PMN

submitters will be affected.1

 EPA has received few bona fides indicating interest in

manufacturing or importing chemicals subject to past SNURs. EPA also has received few public

comments during rulemaking on SNURs covering PMN chemicals. For example, a SNUR

published in the Spring of 2003 covering 62 chemicals resulted in industry comments on only

three PMNs, none from small businesses (EPA Docket # OPPT-2002-0060).2

It remains possible that some small businesses are affected by SNURs without EPA being

aware, if the firms have made no submissions or comments to EPA. However, even if a small

business were interested in supplying a SNUR chemical, the SNUR s impact on profits is

generally expected to be minor. For example, the firm may have a small expense of keeping

records and/or of changing workplace practices to comply with restrictions. If modifying

production practices would be overly costly, or if the firm wishes to engage in a Significant New

Use but believes that expensive testing is needed to support a submission to EPA, it may instead

forego production, thus sacrificing profits. The amounts of lost profits, if any, were not quantified

EPA SANITIZED Page 31 of 90
26

for this report, but usually should be low. This is because SNUR chemicals are relatively new and

few compared to the many thousands of chemicals on the TSCA Inventory, and so are unlikely to

be central to a firm s business.

Based on these considerations and on the limited data available, EPA expects that any

compliance with a SNUR will not have a significant economic impact on a substantial number of

small entities.

5.2 Unfunded Mandates Reform Act (UMRA)

EPA has determined that this SNUR does not impose any enforceable duty or contain any

unfunded mandate as described in the Unfunded Mandates Reform Act of 1995 (P.L. 104-4).

5.3 Paperwork Reduction Act (PRA)

According to the Paperwork Reduction Act (PRA), 44 USC 3501 et seq., an agency may

not conduct or sponsor, and a person is not required to respond, to a collection of information that

requires Office of Management and Budget (OMB) approval under the PRA, unless it has been

approved by OMB and displays a currently valid OMB control number. The information

collection requirements related to this action have already been approved by OMB pursuant to the

PRA under OMB control number 2070-0012 (EPA ICR No. 574). This action does not impose

any additional burden requiring OMB approval.

5.4 Executive Order 12866

Executive Order 12866, Regulatory Planning and Review, requires OMB review for rules

with an impact on the economy of $100 million or more, or with any other potential significant

impact. OMB has previously determined that this type of SNUR is not a significant regulatory

action that would require OMB review under this E.O.

5.5 Executive Order 13132

Executive Order 13132, Federalism (64 FR 43255, August 10, 1999), requires EPA to

develop an accountable process to ensure meaningful and timely input by State and local officials

in the development of regulatory policies that have federalism implications. This action does not

have federalism implications because it will not have substantial direct effects on the States, on

the relationship between the national government and the States, or on the distribution of power

and responsibilities among the various levels of government. 

EPA SANITIZED Page 32 of 90
27

5.6 Executive Order 12898

This action does not involve special considerations of environmental justice related issues

as required by Executive Order 12898, Federal Actions to Address Environmental Justice in

Minority Populations and Low-Income Populations (59 FR 7629, February 16, 1994).

5.7 Executive Order 13045

Executive Order 13045, Protection of Children from Environmental Health Risks and

Safety Risks (62 FR 19885, April 23, 1997), requires EPA to identify and assess environmental

health and safety risks that may disproportionately affect children. This type of analysis is

required for rules that will have an impact of $100 million or more only. This impact of this

SNUR will be less than $100 million and therefore no analysis of such impacts on children is

required. 

EPA SANITIZED Page 33 of 90
APPENDIX A

LIST OF PMNS AND THEIR CHEMICAL NAMES

EPA SANITIZED Page 34 of 90
A-1

APPENDIX A LIST OF PMNS AND THEIR CHEMICAL NAMES

Table A-1 PMNs and Chemical Names Referenced in this SNUR

No. PMN CAS Name

1 P-97-1108 N/A (generic) Polycarboxylic acid ester

2 P-98-848 181828-07-9 Silicic acid (H6SiO2O7), magnesium strontium salt(1:1:2), dysprosium and

europium-doped

3 P-98-1033 N/A (generic) Halogen substituted oxetanes

4 P-98-1034 N/A (generic) Halogen substituted oxetanes

5 P-98-1035 N/A (generic) Halogen substituted oxetanes

6 P-99-783 N/A (generic) Chromate(2-), [3-hydroxy-4-[(2-hydroxy-1-naphthenyl)azo]-7-nitro-1-

substituted][N-[7-hydroxy-8-[(2-hydroxy-5-nitrophenyl)azo]-1-substituted]-, salt

7 P-99-817 N/A (generic) Salt of an acrylic acid - acrylamide terpolymer

8 P-99-897 N/A (generic) Substituted benzothiazole-azo-substituted benzoquinoline nickel complex.

9 P-99-920 58857-49-1 Poly(oxy-1,2-ethanediyl), alpha-(9Z)-9-octadecenyl-.omega.-hydroxy-, phosphate,

ammonium salt

10 P-99-928 222975-06-6 2-propanol, 1,1',1'-nitrilotris-, compds. with ethanol 2-[2-(C12-14- alkyloxy) ethoxy]

derivs. hydrogen sulfates

11 P-99-951 N/A (generic) Polyisobutene epoxide

12 P-99-952 N/A (generic) Polyisobutene epoxide

13 P-99-1075 43048-08-4 2-Propenoic acid, 2-methyl-, (octahydro-4,7-methano-1H- indene-5,-

diyl)bis(methylene) ester

14 P-99-1202 N/A (generic) Sulfonyl azide intermediate

15 P-99-1288 N/A (generic) Substituted anilino halobenzamide

16 P-99-1295 N/A (generic) Chlorohydroxyalkyl butyl ether

17 P-99-1304 N/A (generic) Substituted benzenesulfonic acid salt

18 P-99-1341 235083-90-6 2-Naphthalenecarboxylic acid, 4,4'-methylenebis [3-hydroxy-, strontium salt

19 P-99-1342 235083-88-2 2-Naphthalenecarboxylic acid, 4,4'-methylenebis [3-hydroxy-, zinc salt

20 P-00-7 125005-87-0 D-Glucuronic acid, polymer with 6-deoxy-L-mannose and D-glucose, acetate, calcium

magnesium potassium sodium salt

21 P-00-368 N/A (generic) Benzenesulfonamide, alkylphenylsubstitutedphenylsubstitutedcarbonyl22 P-00-636 N/A (generic) Alkylated nitroso-phenylenediamine

23 P-00-838 N/A (generic) Substituted alkyl sulfonamide

24 P-00-912 N/A (generic) Epoxy resin containing phosphorus

25 P-00-966 N/A (generic) Haloarylalkylketoester

26 P-00-991 300371-38-4 Formaldehyde, polymer with (chloromethyl) oxirane and phenol, reaction products with

6H-dibenz[c,e][1,2]oxaphosphorin-6-oxide

27 P-00-1055 N/A (generic) Sulfonated-copper phthalocyanine salt of a triarylmethane dye

28 P-00-1205 N/A (generic) 6-Methoxy-1H-benz[de]isoquinoline-2 [3H]-dione derivative

29 P-00-1220 N/A (generic) Phenol -biphenyl polymer condensate

30 P-01-1 N/A (generic) Chloroformate

31 P-01-7 N/A (generic) Aliphatic polycarboxylic acid metal salt

32 P-01-9 N/A (generic) Halogenated arylsilane

33 P-01-22 137787-41-8 Propanoic acid, 2-(trimethoxysilyl)-, ethyl ester

EPA SANITIZED Page 35 of 90
A-2

34 P-01-69 N/A (generic) Substituted naphthalene hydrazide

35 P-01-71 208343-47-9 Phenol, 2,2'-[6-(2,4-dibutoxyphenyl)-1,3,5-triazine-2,4-diyl]bis[5-butoxy36 P-01-77 N/A (generic) Disubstituted benzenedicarboxcylic acid

37 P-01-85 N/A (generic) Mono esters from 2-propenoic acid

38 P-01-97 N/A (generic) Polyaziridinyl ester of an aliphatic alcohol

39 P-01-144 35544-45-7 Propanamide, N-(2-hydroxyethyl)-3-methoxy40 P-01-149 84501-49-5 Sulfuric acid, mono-C9-11-alkyl esters, sodium salts

41 P-01-152 93072-06-1 Benzenamine, 4-methoxy-2-methyl-N-(3-methylphenyl)

42 P-01-170 99607-70-2 Acetic acid, [(5-chloro-8-quinolinyl)oxy-]-, 1-methylhexyl ester

43 P-01-298 N/A (generic) Substituted propane

44 P-01-320 375-03-1 Propane, 1, 1,1,2,2,3,3-heptafluoro-3-methoxy45 P-01-397 N/A (generic) Dihydro quinacridone derivative

46 P-01-420 N/A (generic) Aromatic acrylate

47 P-01-423 N/A (generic) Substituted benzoic acid

48 P-01-432 N/A (generic) Bis heterocyclic phenylene derivative

49 P-01-433 N/A (generic) Halogenated alkane

50 P-01-441 N/A (generic) Modified phenolic resin

51 P-01-459 178452-72-7 Chromate(3-),

bis[3-[[6-amino-1,4-dihydro-2-[[[4-[(2-hydroxy-1-naphthalenyl)azo]phenyl]sulfonyl]ami

no]-4-(oxo-.kappa.O)-5-pyrimidinyl]azo-.kappaN1]-4-hydroxy-.kappa.O)-5-nitrobenzen

esulfonato(3-)]-, trisodium

52 P-01-460 327177-98-0 Chromate(3-),

bis[3-[[6-amino-1,4-dihydro-2-[[[4-[(2-hydroxy-1-naphthalenyl)azo]phenyl]sulfonyl]ami

no]-4-(oxo-.kappa.O)-5-pyrimidinyl]azo-.kappaN1]-4-hydroxy-.kappa.O)-5-nitrobenzen

esulfonato(3-)]-, sodium triethanolamine salts

53 P-00-992

and

P-01-471

N/A (generic) Phosphorous modified epoxy resin

54 P-01-481 N/A (generic) Polyurethane polymer

55 P-01-561 N/A (generic) Modified phenolic resin

56 P-01-573 N/A (generic) Aromatic aldehyde phenolic resin

57 P-01-578 N/A (generic) Alkoxylated alkyl amine

58 P-01-646 391232-99-8 1-propanaminium, 3-amino-, N, N, N-trimethyl-N-soya acyl derivs., chloride

59 P-01-716 N/A (generic) Polyurea

60 P-01-781 2602-34-8 Silane, triethoxy[3-oxiranylmethoxy)propyl]-

61 P-01-833 N/A (generic) Polyethyleneamine crosslinked with substituted polyethylene glycol

62 P-02-17 N/A (generic) Phenyl azo dye

63 P-02-90 N/A (generic) Nickel, cobalt mixed metal oxide

64 P-02-207 24307-26-4 Piperdinium, 1,1-dimethyl-, chloride

65 P-02-262 N/A (generic) Substituted benzophenone

EPA SANITIZED Page 36 of 90
APPENDIX B

INFLATORS AND WAGE RATES

EPA SANITIZED Page 37 of 90
3 Many Labor hourly rates in this analysis are lower than hourly rates for the same labor categories in an earlier SNUR economic

analysis (EPAB 1999). EPA does not mean to suggest that actual hourly rates declined. Rather, the apparent decline is due to a

changed method of calculating hourly costs for the same labor categories. There were three changes: (1) Previously the 17%

overhead was applied to wages-plus-fringe benefits. Now it is applied only to wages. (See Appendix B, footnote 3.) This

change reduces calculated overhead. (2) Before, most wage rates were based on older data and then inflated to current dollars.

Here, most wage rates are based on recent data. (3) Finally, fringe benefits were based on an assumed percent of wages. Here,

private industry fringe benefits are based on actual fringe benefits taken from recent BLS data. 

4

Employer Costs for Employee Compensation, Private industry workers, Goods-producing industries, white-collar occupations,

as published by the U.S. Department of Labor, Bureau of Labor Statistics. The December 2002 values for these series are listed

in Table 11 of the Employer Costs for Employee Compensation Summary, released March 18, 2003.

B-1

APPENDIX B INFLATORS AND WAGE RATES

This appendix provides a brief discussion of the wage rates, inflators, and methods that

were used to derive the final fully loaded wages and costs of equipment and supplies used in the

calculation of the quantified costs for each of the possible options. Base hourly wages for

relevant labor categories were loaded with factors for benefits and overhead to derive a loaded

hourly rate. If the loaded hourly rate was not already in year 2002 dollars, it was then inflated to

year 2002 dollars by multiplying by the appropriate inflation factor. The derivation of fully

loaded wages in year 2002 dollars, for each of the labor categories used in the report, is discussed

in Section B.1 and is summarized in Table B.1. The derivation of the different inflation factors

used to inflate wages and/or costs of equipment and supplies to year 2002 dollars is discussed in

Section B.2 and is summarized in Table B.2.

B.1. Derivation of Loaded Wage Rates3

B.1.1 Technical, Managerial, and Clerical Labor

The basic method used to derive loaded wage rates for technical, managerial, and clerical

personnel is described more fully in Wage Rates for Economic Analysis of the Toxics Release

Inventory Program (Rice, 2002). 

December 2002 average wages for technical, managerial, and clerical labor were taken

from the Employer Costs for Employee Compensation (ECEC) report from the Bureau of Labor

Statistics (BLS) for all goods-producing, private industries.4

The additional cost of benefits, such as paid leave and insurance ( fringe benefits ),

specific to each labor category, are also taken from the same BLS series. Fringe benefit as a

percentage of wage is then calculated separately for each labor category. For example, the

average wage rate in December 2002 for technical labor was $27.00; the average fringe benefit

was $11.75. So fringe benefit as a percentage of wage rate for technical labor was 11.75/27.00, or

approximately 43.5%. 

EPA SANITIZED Page 38 of 90
5An overhead rate of 17 percent applied to wages is used for consistency with recent EPAB economic analyses for

two major rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory Program, June 10,

2002, and the Revised Economic Analysis for the Amended Inventory Update R ule: Final Report, August 2002. In

reports for an earlier SNUR (EPAB 1999), the 17% was applied to wages-plus-fringe benefits. Applying it only to wages

reduces calculated overhead.

B-2

An additional loading factor of 17 percent is applied to wages for overhead.5

 This

overhead loading factor is added to the benefits loading factor, and the total is then applied to the

base wage to derive the fully loaded wage. The fully loaded wage for technical labor, for

example, is $27.00*(1+0.435 + 0.17) = $27.00*(1.605) = $43.34.

Fully loaded costs for managerial and clerical labor were calculated in a similar manner.

B.1.2 Production Workers

For production workers, the wages are specific to the chemical industry, but the fringe

benefits factor comes from a different BLS series and is for blue collar workers in general. The

December 2002 wage for production workers, taken from the National Employment, Hours, and

Earnings, Average Hourly Earnings of Production Workers (BLS, 2003c), is $19.44. Fringe

benefits as a percentage of wage in December 2002 was calculated from the Employer Costs for

Employee Compensation - December 2002: Private industry, goods-producing workers by

occupational group (BLS 2003d), by dividing total benefits for blue-collar occupations in

December 2002 ($7.37) by the corresponding December 2002 average wage among blue-collar

occupations ($15.39). The result is 47.9 percent. 

As with other labor categories, an additional loading factor of 17 percent of wages was

applied for overhead. The loaded wage for production workers was thus calculated as $19.44*(1

+ 0.479 + 0.17) = $19.44*(1.649) = $32.06.

B.1.3 Industrial Hygienists

Unlike other labor categories, the wage rate for Industrial Hygienists came from 1997 nonBLS data and was inflated to 2002 dollars. The fringe benefits factor, on the other hand, came

from recent BLS data and is generic to professional occupations.

We used a wage rate of $25.05 in 1997 dollars, based on a 1997 survey specific to

industrial hygienists (IHSN 1997). Fringe benefits as a percentage of wages in December 2002

was taken from Employee Compensation - December 2002: Private industry, goods-producing

workers by occupational group(BLS 2003d), by dividing total benefits for professional specialty

and technical occupations in December 2002 ($11.75) by the corresponding December 2002

average wage among professional specialty and technical occupations ($27.00). The result is 43.5

percent. 

EPA SANITIZED Page 39 of 90
6Calculations are based on unrounded values, so the total may not equal the product of the round ed factors.

B-3

An additional loading factor of 17 percent of wages was applied for overhead. The loaded

wage for industrial hygienists in 1997 dollars was thus calculated as $25.05*(1 + 0.435 + 0.17) = 

$25.05*(1.605) = $40.21. Using the fourth quarter Employment Cost Index, Total Compensation

for White Collar Occupations (BLS 2003a), this was then inflated to year 2002 dollars using an

inflation factor of approximately 1.209, to yield $48.60 in fourth quarter 2002 dollars.6

B.1.4 EPA Staff FTE

The annual salary for EPA staff used for calculations of Agency costs is an average of the

Office of Personnel Management (OPM) year 2002 annual salaries for GS-12 Steps 1 and 10 

$55,694 and $72,400, respectively, or $64,047. Multiplying by an assumed loading factor of 1.6

to reflect fringe benefits and overhead (OPPE 1992), the loaded annual salary of EPA staff was

calculated to be $102,475. 

EPA SANITIZED Page 40 of 90
B-4

Table B-1 Derivation of Loaded Wage Rates

Labor

Category

Data Sources

Uninflated wages and

fringes / hour

Fringe

benefits

as % of

wage

Overhead as

% of

wage*

Fringe +

Overhead

factor

Loaded

Wage

Rate

before

inflation

Inflation

factor

Loaded

Wage

Rate

(2002

Date dollars)

Wages 

$

Fringe

benefits

$

Technical BLS Employer Costs for Employee

Compensation, Table 11. Private ind ustry,

goods-producing industries, Profess.

specialty & technical. Dec 02. [BLS 2003d]

Dec

2002

$27.00 $11.75 43.5% 17% 1.605 $43.34 1 $43.34

Managerial BLS Employer Costs for Employee

Comp ensation, Table 11. Private industry,

goods-producing industries, Exe c, admin, &

managerial. Dec 02. [BLS 2003d]

Dec

2002

$33.09 $14.57 44.0% 17% 1.610 $53.29 1 $53.29

Clerical BLS Employer Costs for Employee

Compensation, Table 1 1. Private ind ustry,

goods-producing industries, Admin suppo rt,

incl. clerical. Dec 02. [BLS 2003d]

Dec

2002

$14.89 $6.54 43.9% 17% 1.609 $23.96 1 $23.96

Production

worker

Wage: BLS Natl Em pl, Hrs, and Earnings:

Aver Hourly Earnings of Production

Workers, Chem & Allied Prod, Annual 

(EEU32280006) [BLS 2003c]

Fringes %: BLS Employer Costs for

Employee Compensation, Table 11.

Private/goods-producing industries, bluecollar occupations. Dec 02. [BLS 2003d]

Dec

2002

$19.44 - 47.89% 17% 1.6489 $32.05 1 $32.05

EPA SANITIZED Page 41 of 90
Labor

Category

Data Sources

Uninflated wages and

fringes / hour

Fringe

benefits

as % of

wage

Overhead as

% of

wage*

Fringe +

Overhead

factor

Loaded

Wage

Rate

before

inflation

Inflation

factor

Loaded

Wage

Rate

(2002

Date dollars)

Wages 

$

Fringe

benefits

$

B-5

Industrial

hygienist 

Wages: 1997 trade survey (IHSN 1997)

Fringes %: BLS Employer Costs for

Employee Compensation, Table 11.

Private/goods-producing, Professional

specialty & techn, Dec 02. [BLS 2003d]

Inflation: BLS ECI, White Collar

Occupations, Series ECS11102I, Fourth Q

(see Table B-2) [BLS 2003a]

1997 $25.05 - 43.5% 17% 1.605 $40.21 1.209 4$48.60

EPA staff

FTE

Office of Personnel Management (OPM) pay

rates for GS-12 Steps 1 and 10 for 2002.

[OPM 2003]

(Average of $55,694 and $72,400)

2002 $64,047

per year

- - - 1.6 $102,475

per year

1 $102,475

per year

*An overhead rate of 17 percent applied to wages is used for consistency with recent EPAB economic analyses for two major rulemakings: Wage Rates for

Economic Analyses of the Toxics Release Inventory Program, June 10, 2002, and the Revised Economic Analysis for the Amended Inventory Update Rule: Final

Report, August 2002. 

Note: Calculations are based on unrounded values, so the total may not equal the product of the rounded factors.

EPA SANITIZED Page 42 of 90
B-6

B.2. Derivation of Inflation Factors

In general, costs of equipment and supplies were inflated to year 2002 dollars using the

Consumer Price Index All Urban Consumers (not seasonally adjusted); wages were inflated using

the appropriate Employment Cost Index (ECI), seasonally adjusted. For example, the wage for

industrial hygienists was inflated from 1997 dollars to 2002 dollars using the ECI for White Collar

Occupations. In those cases in which both labor and equipment and supplies were involved (e.g.,

test costs), we used the inflator corresponding to the dominant cost category. For example, test

costs are presumably based on a mix of labor categories and include the costs of equipment and

supplies. Assuming that the largest component of test costs comes from labor, we used the ECI for

private industry, all workers. Complete information on the derivation of the inflation factors used

is given in Table B-2 below. 

Table B-2 Derivation of Inflation Factors

Report

section

Item Inflator data source Starting

year

Inflator for

starting

year (A)

Inflator

for 2002

(B)

Inflation

factor 

(B) / (A)

Chapter 3 Export notification BLS Employ. Cost Index, Seas.

Adj., White Collar Occupations

Series ECS11102I, Fourth Q

1992 116.1 165.6 1.426

Appendix C Industrial hygienist

Impermeability test

BLS E mploy. Co st Index, Seas. 

Adj., White Collar Occupations

Series ECS11102I, Fourth Q

1997 137.0 165.6 1.209

Appendix C Labels, placards,

gloves, clothes,

eyewear,

respirators, 

file cabinet

BLS Consumer P rice Index, all

urban consumers, not seasonally

adjusted, CUUR0000SAO, Annual

 1997 160.5 179.9 1.121

Appendix C Photocopies

Record keeping

materials

BLS Consumer P rice Index, all

urban consumers, not seasonally

adjusted, CUUR0000SAO, Annual

1988 118.3 179.9 1.521

Appendix D Test cost BLS E mpl. Cost Index, Seaso nally

Adj, Private industry, All workers

(Series ID: ECS10002I) December

[Published Jan 2003]

varies varies 162.5 varies*

Ex. for test costed out in 1993 1993 119.9 162.5 1.355

Ex. for test costed out in 2000 2000 151.1 162.5 1.075

Appendix F Agency Extramural

costs

BLS Employ. Cost Index, Seas.

Adj., White Collar Occupations

Series ECS11102I, Fourth Q

1993 120.4 165.6 1.375

*Test costs were first estimated in different years, depending on the test, so that inflation factors vary depending on

when the test was costed out.

EPA SANITIZED Page 43 of 90
APPENDIX C

COSTS OF COMPLIANCE WITH A SNUR (OPTION 1): HAZARD COMMUNICATION,

PROTECTION IN THE WORKPLACE, AND RECORDKEEPING REQUIREMENTS 

EPA SANITIZED Page 44 of 90
C-1

APPENDIX C 

COSTS OF COMPLIANCE WITH A SNUR (OPTION 1): HAZARD COMMUNICATION,

PROTECTION IN THE WORKPLACE, AND RECORDKEEPING REQUIREMENTS 

Section 2.1 of this economic analysis presents a discussion of the methodology for

assessing the costs of the worker protection, hazard communication, and recordkeeping 

requirements of the batch SNUR. This appendix presents the dollar costs and labor hours of these

requirements, for each PMN chemical. The hazard communication (Haz-Comm) costs reflect the

annual costs of updating the written program, creating and applying labels for chemical distribution

and storage, creating and distributing material safety data sheets, and employee training. The 

personal protective equipment (PPE) costs shown reflect the annualized costs of providing required

equipment (i.e., gloves, goggles, clothing, or respirators), assessing dermal protection needs

associated with the chemical, and performing required impermeability testing, and/or evaluating

manufacturer s information. Finally, the annual recordkeeping costs include technical and clerical

labor time, reproduction charges, and costs for the storage of records.

To estimate the costs of haz-comm and worker protection requirements, a number of

assumptions were made. In the original analysis for generic SNUR provisions (RIB 1989), EPA

estimated that the number of workers exposed to any one substance would range from 10 to 25,

and that a worker potentially would be exposed to a substance for a minimum of 50 days per year

to a maximum of 250 days per year. The current analysis uses the high ends of those two ranges. 

Thus, each site is assumed to have 25 chemically-exposed workers requiring training and/or

protective equipment, with each of them assumed to be exposed for 250 days per year. 

Labor costs are derived from the Employer Costs for Employee Compensation (BLS 2003d)

as described in Appendix B. Material costs were primarily obtained from a national safety

equipment supply house catalog (LSS 1997) and are inflated to 2002 dollars using the BLS

Consumer Price Index (BLS 2003b). Please refer to Appendix B for further details on the sources

and methodology of calculating labor and material costs.

Haz-Comm costs, costs of providing protection in the workplace, and recordkeeping costs 

are discussed in Sections C.1, C.2, and C.3, respectively. These costs, as well as total costs

calculated by summing the Haz-Comm, protection in the workplace, and recordkeeping costs, are

summarized for each PMN in Table 10 above.

C.1 Modifying the Hazard Communication Program

As mentioned in Section 2.1, it is assumed that each facility has in place a Haz-Comm

program consistent with that required by OSHA s Hazard Communication standard (29 CFR 1910;

November 25, 1983), so that costs attributable to the SNUR are costs of adding one chemical to the

program. Much of the Haz-Com methodology and assumptions came from an EPA report,

Economic Analysis of Final Significant New Use Rules: General Provisions for New Chemical

EPA SANITIZED Page 45 of 90
C-2

Followup (RIB, 1989), which in turn relied partly on the 1993 OSHA study, Final Regulatory

Impact and Regulatory Flexibility Analyses of the Hazard Communication Standard.

It was assumed that the Haz-Comm costs would be incurred each year for example, there

would be worker turnover and need for refresher training, the MSDS would need revision due to

changing information, placards would wear out (RIB 1989). To the extent that some steps would

not need repeating each year, costs could be lower than estimated here. The hazard

communication costs of $931, summarized in Table 3 above, are detailed here.

C.1.1 Updating the Written Program

If the SNUR cites 40 CFR §721.72(a), then to avoid engaging in a Significant New Use

which would trigger other SNUR requirements, manufacturers must update their written HazComm program to incorporate information about the chemical. The written part of the program

includes data and information about hazardous chemicals present in the workplace, the hazards

associated with such chemicals, procedures for employees who routinely work with or around such

chemicals, procedures for non-routine tasks that may involve exposure (e.g., tank cleaning), and

personal protective equipment requirements when working with or around such chemicals. 

Costs of the haz comm program update are $194.42 per chemical, as described below. 

While MSDS data may provide much of the information needed to update the written HazComm program, many employers may perform a more detailed assessment of exposure risks

associated with the chemical and develop more site-specific procedures for workers potentially

exposed to such chemicals. For purposes of the economic analysis, EPA assumes that each

employer will engage the services of a professional industrial hygienist (IH), either in-house or on

a consulting basis, for four hours to perform such an assessment. Costs for IH services were

obtained from a 1997 salary survey conducted by Industrial Hygiene and Safety News, a

professional trade journal (IHSN 1997). The survey results are based on 602 respondents from the

environmental, health and safety professions, with a range of age, experience, and professional

training. The median gross salary for all respondents in 1997 was $52,100, which represents

$25.05 on an hourly basis. This wage was inflated to year 2002 wages and loaded with fringe

benefits and overhead as described in in Appendix B, for a fully loaded hourly cost of $48.60. 

Costs for four hours of IH time, fully loaded, are $194.42. The estimates in Table 10 assume that

this cost is repeated annually. 

C.1.2 Labeling

If the SNUR cites 40 CFR §721.72(b), then to avoid engaging in a Significant New Use,

manufacturers must ensure that containers used to distribute the PMN substance in commerce are

labeled with the necessary hazardous substance warnings and procedures. In addition, containers

used in the workplace must bear similar labels or, alternatively, the employer must provide

equivalent signage, operating procedures, or other written material to communicate hazard

EPA SANITIZED Page 46 of 90
7

 Data on PMN notices suggest that some PMN submitters expected to produce less than 10,000 kilograms per year of the SNUR

chemicals, but many expected to produce much more, often over 100,000 kg. It is not known whether expected volumes were

realized in practice. Production volumes of secondary suppliers affected by the SNUR is also unknown. Annual volumes

significantly greater than 10,000 kg could lead to higher haz-comm costs than those estimated here.

C-3

information to workers. The cost of providing such labeling has been estimated previously (RIB

1989) and has been updated here using more recent cost information.

 Standard formats are assumed to be used for creating labels or other signage, and the

information required for the labels is assumed to be already available from the MSDS for the

chemical (see below). 

C.1.2.1 Chemicals Distributed in Commerce

For chemicals distributed in commerce, the labeling process is assumed to require 0.5 hours

of technical labor time per chemical to compile label information and 480 labels per chemical. The

assumption of 480 labels per chemical is from RIB (1989), and is based on the assumption that, on

average, each chemical is shipped twice monthly to 20 customers. This is consistent with roughly

10,000 kilograms of chemical per year shipped in 40 five-gallon containers per month (RIB 1989).7

Labor costs for technical labor are based on the Employer Costs for Employee

Compensation (BLS 2003d). The 2002 loaded hourly wage derived for technical labor is $43.34. 

Methods of calculating labor costs for technical and other labor categories are explained in

Appendix B.

Labeling materials costs were obtained from a national safety equipment supply house

catalog (LSS 1997) and were inflated to 2002 dollars using the BLS Consumer Price Index (BLS

2003b). As shown in Table C-1, the resulting costs of labeling for chemicals distributed in

commerce are $107.75 per chemical substance at one site, in 2002 dollars.

Table C-1 Annual Costs of Labeling for Distribution in Commerce [40 CFR §721.72(b)(2)]

Cost Element

Unit Cost 

(1997 Dollars) Inflator

Unit Cost 

(2002 Dollars) Hours

Total

Cost*

0.5 hours technical time $43.34 per hour 0.5 $21.67

480 labels $0.16 per label 1.121 $0.18 per label $86.08

Total 0.5 $107.75

Source: 1997 lab el cost, EPA B 1998 , LSS 19 97; cost elements, quantities, RIB 1989; inflators, labor, Appen dix B. 

*Totals were calculated using unrounded values from Appendix B, and may not equal product of the rounded

values shown in this table.

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C-4

C.1.2.2 Chemicals Used in the Workplace

Workplace labeling requirements are costed by assuming the facility purchases six large

(14" × 10") signs, priced at $38.30 each in 1997 dollars (LSS 1997, EPAB 1998). These signs are

estimated to cost $42.93 in year 2002 dollars (updated by using the CPI) (BLS 2003b). These signs

will be mounted in areas where the chemicals are used or formulated. For example, a placard

might be posted at each of six vessels: a mixing tank, a reactor, two separators, and two storage

vessels (RIB 1989). The labeling process is also assumed to require 0.5 hours of technical time to

compile label informaiton and 10 minutes of production worker time to post each placard. 

Technical labor is costed at $43.34 per hour, as described in Appendix B. 

The resulting costs of labeling for chemicals in the workplace are shown in Table C-2 to be

$311.30 per chemical substance.

Table C-2 Annual Costs of Labeling for Use in Workplace [40 CFR §721.72(b)(1)]

Cost Element

Unit Cost 

(1997 Dollars) Inflator

Unit Cost 

(2002 Dollars) Hours Total Co st*

0.5 hours technical time $43.34 per hour 0.5 $21.67

6 labels or placards (14" x 10") $38.30 per item 1.121 $42.93 per item $257.58

10 minutes per label/placard

production time

$32.05 per hour 1.0 $32.05

Total 1.5 $311.30

Source: 1997 placard cost, EPAB 1998, L SS 1997; cost elem ents and q uantities, RIB 1989; inflators and labor unit

costs, Appendix B. 

*Totals were calculated using unrounded values from Appendix B, and may not equal product of the rounded

values shown in this table.

C.1.3 Preparing Material Safety Data Sheet (MSDS) Information

If the SNUR cites 40 CFR §721.72(c), then to avoid engaging in a Significant New Use,

each facility is required to create, post, and distribute material safety data sheets (MSDSs). Based

on estimates in OSHA 1983, RIB (1989) has estimated that creation of MSDS for a new PMN

substance requires 2.0 hours of technical labor time and 0.25 hours of clerical time. Further, EPA

assumes that the manufacturer provides 20 copies of the MSDS to customers and to retain 20

copies for use onsite, for a total of 40 copies (RIB 1989). The loaded hourly wage rates and the

inflator used in estimating unit photocopy costs are derived in Appendix B. The resulting cost of

MSDS preparation is $95.71 per chemical, as shown in Table C-3.

EPA SANITIZED Page 48 of 90
C-5

Table C-3 Annual Costs for Material Safety Data Sheets (MSDSs) [40 C FR §721.72(c)]

Cost Element

Unit Cost 

(1988 Dollars) Inflator

Unit Cost

(2002 Dollars) Hours Total Co st*

2.0 hours technical time $43.34 per hour 2.0 $86.68

0.25 hours clerical time $23.96 per hour 0.25 $5.99

40 copies $0.5 1.521 $0.08 per copy $3.04

Total 2.25 $95.71

Source: Cost elem ents, quan tities, and 1988 copy cost, RIB 1989; inflators and labor unit costs, App endix B. 

*Totals were calculated using unrounded values from Appendix B, and may not equal product of the rounded

values shown in this table.

C.1.4 Employee Training

The final required component of the Haz-Comm program is employee training, based on

§721.72(d). RIB (1989) assumes that a training program currently is in place, but the existing

program must be modified to add new information pertaining to the PMN substance. 

Subsequently, the training program must be expanded to include such material each time the

training course is presented. Costs of modifying the program and presenting the modified program

are mainly labor costs for the trainer and the trainees.

Inserting the new information about the PMN substance into the training program and

conducting the revised training is assumed to require 0.5 hours of the trainer s time. An additional

0.25 hours per trainee is estimated to be required, and an average of 25 affected workers is

assumed per facility (RIB 1989). If additional production workers needed to be trained, for

example because they might come into contact with the chemical due to spills or leaks, training

costs could be higher than estimated here (RIB 1989).

Labor rates for trainers are based on the rates derived in Appendix B for chemical

technicians ($43.34 per hour) and chemical industry production workers ($32.05 per hour). Based

on these labor costs, the total cost of the employee training requirement is $222.01, as shown in

Table C-4.

EPA SANITIZED Page 49 of 90
C-6

Table C-4 Annual Costs for Employee Training, Per Chemical [40 C FR §721.72(d)]

Cost Element Unit Cost Hours Total Co st*

0.5 hours technical time (trainer) $43.34 per hour 0.50 $21.67

0.25 hours per production employee × average

of 25 workers per plant = 6.25 hours $32.05 per hour 6.25 $200.34

Total 6.75 $222.01

Source: Cost elem ents and q uantities, RIB 1989; L abor un it costs, App endix B. 

*Totals calculated using unrounded values from Appendix B, may not equal product of rounded values in table.

C.2 Protection in the Workplace

The following section estimates costs of assessing needs for dermal protection and

evaluating protective gear for impermeability, as well as the costs of gloves, goggles, protective

clothing, and respirators.

C.2.1 Dermal Protection Selection

If the SNUR cites 40 CFR §721.63(a)(1), then to avoid engaging in a Significant New Use,

the employer must ensure that each person who is likely to experience dermal exposure to a PMN

chemical, must be provided with and is required to wear personal protective equipment (e.g.,

gloves) that will prevent dermal exposure to the substance. The equipment must be selected and

used in accordance with 29 CFR 1910.132 and 1910.133 (promulgated by the Occupational Safety

and Health Administration, OSHA). The selection and administration of this dermal protection is

estimated to require 10 hours labor by an industrial hygienist, annually (EPAB 1999). The wage

rate of the hygienist was calculated as described above in Section C.1.1 and in Appendix B. The

cost calculations for the dermal protection selection requirement are given in Table C-5. This

covers only costs of selecting the dermal protection needed, not costs of the items themselves. For

costs of purchasing dermal protective items, see the sections below on costs of gloves, eyewear,

and clothing.

EPA SANITIZED Page 50 of 90
C-7

Table C-5 Annual Costs for Dermal Protection Selection [40 CFR §721.63(a)(1)]

Cost Element Unit Cost Hours Total Co st*

10 hours industrial hygienist (IH) time $48.60 per hour 10.0 $486.04

Source: Labor rates, IHSN 1997 and Appendix B; Cost elements and quantitites, EPAB 1999.

*Totals were calculated using unrounded values from Appendix B, and may not equal product of the rounded

values shown in this table.

C.2.2 Impermeability Testing

As part of the workplace protection requirements specified under 40 CFR §721.63(a)(3), to

avoid engaging in a Significant New Use, the SNUR may require that employers demonstrate that

each item of protective equipment provided (e.g., gloves) provides an impervious barrier, to

prevent employees from dermal exposure Requirements outlined in §721.63(a)(3) are provided in

two parts, §721.63(a)(3)(i) and (ii). The employer may use a combination of (i) testing and/or (ii)

evaluating manufacturer specifications. The following discussion is based on the Economic

Analysis of Expedited Significant New Use Rules for 168 Chemical Substances and Background

Support Document for Economic Analysis of Significant New Use Rules (EPAB 1998) and assumes

that the manufacturer uses both testing and evaluation of manufacturer specifications. Costs were

assumed to be repeated annually.

The first step (i) is to perform actual impermeability testing. To determine the costs of

impermeability testing compliance, Best Manufacturing Company, a leading manufacturer and

tester of chemical resistant articles, was consulted (Best 1997). 

As described in EPAB 1998, Best used one of two methodologies for impermeability

testing. In the first method, chemical samples were submitted to Best with a specific article to be

tested for impermeability. This method was cheaper, costing $200 per chemical, but the burden of

finding an appropriate article of protection lay with the chemical manufacturer. In the second

method, the chemical manufacturer simply submitted chemical samples to Best, who in turn 

determined the most appropriate product, even if the product were manufactured by a competitor. 

This method was more costly at $800 per chemical. 

The second method of impermeability testing is favored in this analysis for several reasons. 

First, the burden of finding and submitting an article of protection is shifted from the chemical

manufacturer to the testing company, who would have greater experience in PPE selection.

Second, should the article submitted fail the impermeability test, other articles may have to be

submitted until satisfactory test results are obtained. Furthermore, substances subject to SNURs

may include new and/or rare chemicals, which may have undiscovered or unknown properties. 

EPA SANITIZED Page 51 of 90
C-8

This uncertainty may impede chemical manufacturers  ability to effectively submit appropriate

PPE articles for testing. Finally, the first method is essentially a pass-fail test. If an article passes

the impermeability test, then it is acceptable. In the second method, several articles may be tested

and compared, and, while one or more acceptable articles may result, the most impermeable article

is always determined for the chemical. To obtain the best article rather than merely a satisfactory

article of protection, the second method of testing is more appropriate. For these reasons, unit

costs of $800 per chemical (1997 dollars)are assumed for impermeability testing. The cost of the

impermeability testing is assumed to be driven by labor costs of the company performing the

testing, thus test costs were inflated with the Employment Cost Index (BLS 2003a). When inflated

to 2002 dollars, the cost of the test is $967.01. The administration of this test would also require

two hours of industrial hygienist labor. As discussed in Section C.1.1 and in Appendix B, this

labor is estimated to cost $48.60 per hour. 

The second step to compliance with the workplace protection requirements at

§721.63(a)(3)(ii) is the evaluation of specifications from the manufacturer or supplier of the

protective equipment. This requirement helps ensure that the protective equipment will be

impervious to the PMN chemical(s). The evaluation of manufacturer specifications requires an

estimated four hours of industrial hygienist labor.

 Annual costs of the impermeability testing requirements are presented in Table C-6. 

Table C-6 Annual Costs of Impermeability Testing [40 CFR §721.63(a)(3)]

Cost Element

Unit Cost

(1997 Dollars) Inflator

Unit Cost

(2002 Dollars) Hours Total Cost*

Impermeability Testing

[§721.63(a)(3)(i)]

2.0 $1,064.21

 Impermeability Test $800 1.209 $967.01 per chemical 967.01

 2.0 hours industrial 

 hygienist time

$48.60 per hour 2.0 $97.20

Evaluation of

Manufacturer s

Specifications

[§721.63(a)(3)(ii)]

4.0 $194.40

 4.0 hours industrial 

 hygienist time

$48.60 per hour 4.0 $194.40

Total 6.0 $1,258.61

Source: 1997 costs, Best 1997; Cost elements and quantities, EPAB 1998; inflators and labor rates, Appendix B.

*Totals were calculated using unrounded values from Appendix B, and may not equal product of the rounded

values shown in this table.

EPA SANITIZED Page 52 of 90
C-9

C.2.3 Gloves

If the SNUR cites 40 CFR §721.63(a)(2)(i), then gloves must be worn to avoid engaging in

a Significant New Use. Gloves may also be acquired as a result of the dermal protection selection

at 721.63(a)(1). Gloves, where required, are assumed to be worn and discarded by the worker

following each day of exposure, unless otherwise specified. Each site is assumed to have 25

workers, each of them exposed 250 days per year. EPA assumes that standard, disposable,

medical-grade gloves are selected and used for the PPE glove requirements outlined in

§721.63(a)(2)(i). Each pair was estimated to cost $0.43 in 1997 (LSS 1997) and has been inflated

to 2002 dollars using the Bureau of Labor Statistics Consumer Price Index (BLS 2003b). Total

annual costs of providing gloves are developed by applying the assumptions above regarding the

number of workers exposed (25 per site) and frequency of replacement (one pair per worker per

day of exposure × 250 days of exposure per year). For some chemicals, the SNUR may require

heavier-duty gloves, which, are generally not disposed of daily, but are more expensive. The

estimated costs of gloves purchased in compliance with SNUR PPE requirements are presented

below in Table C-7.

Table C-7 Annual Cost of Gloves [40 CF R §721.63(a)(2)(i)]

Cost Element

Unit Cost 

(1997 dollars)

Inflator Unit Cost

(2002 Dollars)

Number of Pairs

Required

Total Co st*

Disposable nitrile gloves

(replaced daily) 

$0.43 1.121 $0.48 per pair 6250 $3,012

Heavy duty butyl gloves

(replaced every 25 work

days)

$34.00 1.121 $38.11 per pair 250 $9,527

Source: 1997 item costs, LSS 1997; item type and quantity, EPAB 1998; Inflator, Appendix B.

*Totals were calculated using unrounded values from Appendix B, and*Totals were calculated using unrounded values from Appendi

shown in this table.

C.2.4 Eyewear

If the SNUR cites 40 CFR §721.63(a)(2)(iii), then to avoid engaging in a Significant New

Use, employer must provide eye protection. Eye protection may also be aquired as a result of the

dermal protection selection at 721.63(a)(1). Protective goggles are expected to be used at a rate of

one set per worker and replaced every four months. Each site is assumed to have 25 workers, each

of them exposed 250 days per year. The SNUR may not specify the exact type of eyewear

required. OSHA guidelines in 29 CFR 1910.133(b)(1), however, state that protective eye and

face devices purchased after July 5, 1994 shall comply with ANSI Z87.1-1989. To determine the

EPA SANITIZED Page 53 of 90
C-10

cost of goggles that meet this standard, EPA consulted with eyewear specialists at equipment

supplier LSS. A standard pair of goggles that meets the ANSI Z87.1-1989 specification was priced

at $4.05 per pair in 1997 (LSS 1997; RIB 1998). When inflated to 2002 dollars using BLS

Consumer Price Index (BLS 2003b), the cost is $4.54 per pair. Costs of protective eyewear are

presented in Table C-8 below. A price estimate for a heavy-duty pair of goggles compliant with

the ANSI standard is also included in Table C-8, should the SNUR require such eyewear.

Table C-8 Annual Cost of Protective Eyewear [40 CFR §721.63(a)(2)(iii)]

Cost Element

Unit Cost 

(1997 Dollars) Inflator

Unit Cost

(2002 Dollars)

Number of

PairsRequired*

Total Cost**

Goggles $4.05 1.121 $4.54 per pair 75 $340

Heavy duty chemicalsplash/impact goggles$6.05 1.121 $6.78 per pair 75 $509

Source: 1997 item costs, LSS 1997; item type and quantity, EPAB 1998; Inflator, Appendix B.

* 25 workers replacing goggles three times per year.

**Totals**Totals were calculated using unrounded values**Totals were calculated using unrounded values from Appendix B,**Totals 

shown in this table.

C.2.5 Clothing

If the SNUR cites 40 CFR §721.63(a)(2)(iv), then to avoid engaging in a Significant New

Use, employer must provide protective clothing. Protective clothing may also be aquired as a

result of the dermal protection selection at 721.63(a)(1). Protective clothing and full-body

chemical resistant clothing are assumed to last four months. Each site is assumed to have 25

workers, each of them exposed 250 days per year. For costing purposes, a standard coverall

clothing set (LSS 1997) was assumed to satisfy protective clothing requirements. As shown in

Table C-9 below, this basic set of clothing costs approximately $40.63 after inflating to 2002

dollars using the BLS Consumer Price Index (BLS 2003b); however, costs for full-body protective

clothing (if specified by the SNUR) are based on the coverall clothing set with a hood (LSS 1997)

and are estimated at $68.60 per set with inflation. 

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Table C-9 Annual Cost of Protective Clothing [40 CFR §721.63(a)(2)(iv)]

Cost Element Unit Cost 

(1997 Dollars)

Inflator Unit Cost 

(2002 Dollars)

Number

Required*

Total Cost**

Coverall with hood

[full-body clothing]

$61.20 1.121 68.20 per set 75 $5,145

Covera ll $36.25 1.121 $40.63 per set 75 $3,047

Source: 1997 item costs, LSS 1997; item type and quantity, EPAB 1998; Inflator, Appendix B.

* 25 workers replace item three times per year.

**Totals were calculated using unrounded values from Appendix B, and may not equal product of the rounded values

shown in this table.

C.2.6 Respirators

 For some PMN chemicals, to avoid engaging in a Significant New Use, the SNUR requires

the use of respirators, as defined in 40 CFR §721.63 (a)(5). The respirators specified in Section

(a)(5) are all comprised of a respirator unit and any number of the following: special cartridges

(such as high efficiency particulate filters, organic vapor cartridges, and paint, lacquer, and enamel

filters), hoods or helmets, and filter caps.

Paragraphs (a)(5)(i) through (xv) of §721.63 reference specific types of NIOSH-approved

respirator units. Table C-10 describes the types of NIOSH-approved respirators with their average

costs in 1997 and 2002 dollars, and estimates costs per plant site for each chemical requiring 

respirators. 

The costs for each site of providing respirators to chemically-exposed workers, shown in

Table 3 of Section 2 of the report, are calculated based on the assumptions stated there, that (1)

there are 25 chemically-exposed workers requiring protective equipment, (2) respirators are

replaced once a year, and (3) cartridges (and cartridge filters and caps) are replaced at a rate of one

pair (2) every five of the 250 days that workers are exposed, or 50 times per year. For example, if

type 15 respirator is used, the total annual cost would be ($12.14 + $10.02*50)*25 = $12,829.

For some PMN chemicals the SNUR may list more than one NIOSH-type respirator, but

only one type of respirator is needed to comply with the workplace protection requirements. In

such cases, the NIOSH-type with the lowest average cost was assumed in order to estimate

workplace protection costs in Table 10. 

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Table C-10 Annual Costs for Respiratory Protection [40 CFR §721.63(a)(5)]

40 CFR

§721.63

(a)(5) NIOSH Approval Type

 Average Costs (1997 Dollars) Average Costs (2002 Dollars)*

Per Respirator Per Respirator Annual Per

Worker**

Annual

Per Site

Unit Cartridge Unit Cartridge (25 workers)

(i) 19C Type C Supplied-air with

full facepiece

$804.03 -- $901.21 -- $901.21 $22,530

(ii) 19C Type C Supplied-air with

tight-fitting facepiece

$804.03 -- $901.21 -- $901.21 $22,530

(iii) 19C Type C Supplied-air with

hood or helmet or tight-fitting

facepiece

$932.15 -- $1,044.82 -- $1,044.82 $26,121

(iv) 21C A ir-purifying with full

facepiece and high efficiency

particulate filters (HEPAs)

$180.67 $9.76 $202.51 $10.94 $749.49 $18,737

(v) 21C Powered air-purifying

(PAPR) with tight fitting

facepiece and HEPAs

$627.45 $35.50 $703.29 $39.79 $2,692.84 $67,321

(vi) 21C PAPR with loose hood or

helmet and HEPAs

$525.43 $26.89 $588.94 $30.14 $2,095.95 $52,399

(vii) 21C Air-purifying with HEPA

and disposable respirators

$12.53 $7.00 $14.04 $7.85 $406.35 $10,159

(viii) 23C air-purifying with full

facepiece and combination

cartridges approved for paints,

lacquers and enamels (PLE)

$192.02 $15.71 $215.23 $17.61 $1,095.68 $27,392

(ix) 23C PAPR with tight-fitting

facepiece and combination

cartridges approved PLE

$627.45 $35.50 $703.29 $39.79 $2,692.84 $67,321

(x) 23C PAPR with loose-fitting

hood or helmet and

combination cartridges for PLE

$525.43 $26.88 $588.94 $30.13 $2,095.39 $52,385

EPA SANITIZED Page 56 of 90
40 CFR

§721.63

(a)(5) NIOSH Approval Type

 Average Costs (1997 Dollars) Average Costs (2002 Dollars)*

Per Respirator Per Respirator Annual Per

Worker**

Annual

Per Site

Unit Cartridge Unit Cartridge (25 workers)

C-13

(xi) 23C Air-purifying with

combination cartridges for

PLE, including dispo sable

respirators

$14.30 $8.90 $16.03 $9.98 $514.82 $12,870

(xii) 23C Air-purifying with fullfacepiece and organic

gas/vapor cartridges

$192.02 $10.47 $215.23 $11.74 $802.00 $20,050

(xiii) 23C PAPR with tight-fitting

facepiece and organic

gas/vapor cartridges

$826.40 $41.15 $926.29 $46.12 $3,232.48 $80,812

(xiv) 23C PAPR with a loose-fitting

hood or helmet and organic

gas/vapor cartridges

$639.80 $41.15 $717.13 $46.12 $3,023.33 $75,583

(xv) 23C Air-purifying with organic

gas/vapor cartridges, including

disposable cartridges

$10.83 $8.94 $12.14 $10.02 $513.17 $12,829

Source: See Table C-11 for derivation o f 1997 average costs

*Inflated to 2002 dollars using Consumer Price Index BLS Series CUUR0000SA0 (BLS 2003b)

** Assumes cartridge sets (2 cartridges and any filters or caps required) replaced every 5 days or 50 times during 250 exposure days. Respirator costs includ e costs

of add-on item s such as hoods and helmets, if these items are required for a particular respirator. Cartridge costs reflect the costs of cartridges, filters, and caps.

EPA SANITIZED Page 57 of 90
C-14

Table C-11 shows how the average costs per NIOSH-type respirator were calculated, 

based on prices of respirators listed in a 1997 catalog. To calculate the cost of respirators that meet

the NIOSH criteria, the prices of all units in the supplier catalog (LSS 1997) that meet each

NIOSH criteria were averaged. Costs of additional items such as hoods, helmets, cartridges, and

filter caps were also obtained. These are added to the cost of the basic respirator unit if they are

required under the SNUR regulation and if the unit does not already include the item. For

example, §721.63(a)(5)(x) requires a hood or helmet. One model in the catalog that satisfies the

requirement already includes a hood, while another unit requires that a separate hood be purchased. 

The cost of the hood was added to the unit cost and the combined cost was then averaged with the

model with integrated hood.

Many respirator specifications also require cartridges. The costs of the cartridges listed in

LSS (1997) were averaged for the corresponding requirements. In some instances, certain

cartridges or filters require a secondary cartridge to function properly (e.g., some paint, lacquer and

enamel filters required the organic vapors cartridges and filter retainer caps). These additional

items were priced and added to the cost for the basic cartridge before averages were taken. 

Some cartridge prices were unavailable from LSS (1997). For instance, §721.63(a)(5)(ix)

and (x) require a powered air-purifying respirator (PAPR) with a paint, lacquer and enamel

cartridge. The only cartridges available for these models of respirators in LSS (1997) are HEPA

cartridges. In these cases the costs of a paint, lacquer, and enamel cartridge are assumed to be the

same as for a HEPA cartridge.

The 1997 purchase costs of the varying types of respiratory protective equipment, are

shown in Table C-11.

EPA SANITIZED Page 58 of 90
C-15

Table C-11 Respirator Prices and Average Costs in 1997, by NIOSH Type

40CFR

§721.63

(a)(5) 

NIOSH

type 

Catalog 

Item Number Description 1997 Cost

1997 Average Cost

Unit Cartridge

(i) 19C Type C Supplied-air with full facepiece $804.03 --

7A-24506 Allegro Economical Full-Face Airline Kits, p144 $758.95

7A-32366 311Survivair Supplied Air Respirator Kits, p144 $849.10

(ii) 19C Type C Supplied-air with tight-fitting facepiece $804.03 --

7A-24506 Allegro Economical Full-Face Airline Kits, p144 $758.95

7A-32366 Survivair Supplied Air Respirator Kits, p144 $849.10

(iii) 19C Type C Supplied-air with hood or helmet or tight-fitting facepiece $932.15 --

7A-29363 Allegro Hood Systems, p144 $932.15

(iv) 21C Air-purifying with full facepiece and high efficiency particulate filters (HEPAs) $180.67 $9.76

7A-9838 North Full-Face Respirator, p114 $210.10

7A-7122 North HEPA Cartridge, p115 $11.15

7A-12338 Willson Full-Face Silicone Respirator, p116 $215.10

7A-7526 Willson HEPA Cartridge, p117 $11.75

7A-10516 3M 7800 Full-Facepiece Respirator, p118 $202.10

7A-11839 3M HEPA Cartridge, p118 $7.00

7A-33446 Pro-Tech Full-Face Respirator, p122 $106.45

7A-3070-1 Pro-Tech HEPA Cartridge, p123 $9.87

7A-3195 Willson 1600/1700 Series Full-Fave Respirators, p124 $215.10

7A-3202 Willson HEPA Cartridge, p125 $12.50

7A-23959 AO7Star Full-Face Respirator (Silicone), p126 $203.25

7A-9940 AO7Star HEPA Cartridge, p127 $9.44

7A-24158 MSA Advantage 1000 Full-Face Respirator, p134 $112.60

7A-29946 MSA HEPA Cartridge, p134 $6.60

(v) 21C Powered air-purifying (PAPR) with tight fitting facepiece and HEPAs $627.45 $35.50

7A-13599 3M Face-Mounted PAPR System, p142 $720.00

7A-13601 3M HEPA Replacement Cartridge, p142 $36.50

7A-32505 RACAL Powerflow PAPR, p142 $534.90

7A-11936 RACAL Replacement Cartridge, p142 $34.50

(vi) 21C PAPR with loose hood or helmet and HEPAs $525.43 $26.89

7A-32506 RACAL Air-Mate PAPR 12, p143 $411.05

7A-24505 RACAL HEPA Replacement Cartridge, p143 $24.65

7A-32477 RACAL Breathe-Easy HEPA Cartridges and Turbo Unit, p141 $548.50

7A-12838 RACAL HEPA Replacement Cartridge $29.12

7A-12840 RACAL Breathe-Easy 10 Tyvek Hood, p140 $91.30

(vii) 21C Air-purifying with H EPA and disposable respirators $12.53 $7.00

7A-15255 3M 6000 Series Low-Maintenance Respirator, p135 $10.90

7A-12518P 3M Adaptor, p135 $1.63

EPA SANITIZED Page 59 of 90
40CFR

§721.63

(a)(5) 

NIOSH

type 

Catalog 

Item Number Description 1997 Cost

1997 Average Cost

Unit Cartridge

C-16

7A-11839 3M HEPA Cartridge, p135 $7.00

(viii) 23C air-purifying with full facep iece and com bination cartridges approved for paints, lacquers

and enamels (PLE)

$192.02 $15.71

7A-9838 North Full-Face Respirator, p114 $210.10

7A-7117 North Organic Vapors Cartridge, p115 $10.50

7A-7125 North Paint Spray/Mists Prefilter, p115 $2.38

7A-7125-2 North Filter Covers, p115 $4.35

7A-12338 Willson Full-Face Silicone Respirator, p116 $215.10

7A-7527 Willson Organic Vapors Cartridge, p117 $10.25

7A-7531 Willson Dusts/Mists/Pesticides/Paint Spray Prefilter, p117 $2.52

7A-7532 Willson Retainer Caps, p117 $4.00

7A-10516 3M 7800 Full-Facepiece Respirator, p118 $202.10

7A-9279 3M Organic Vapors Cartridge, p119 $8.91

7A-9284 3M Paint Spray Prefilter, p119 $2.37

7A-9292 3M Retainer Caps, p119 $3.90

7A-33446 Pro-Tech Full-Face Respirator, p122 $106.45

7A-955-4 Pro-Tech Organic Vapors Cartridge, p123 $9.27

7A-9605 Pro-Tech Paint Spray Prefilter, p123 $1.95

7A-3195 Willson 1600/1700 Series Full-Fave Respirators, p124 $215.10

7A-3197 Willson Organic Vapors Cartridge, p125 $11.22

7A-3203 Willson Pesticides/Paint Spray Prefilter, p125 $3.36

7A-3858 Willson Retainer Caps, p125 $4.27

7A-23959 AO7Star Full-Face Respirator (Silicone), p126 $203.25

7A-9935 AO7Star Organic Vapors Cartridge, p127 $8.76

7A-10043 AO7Star Dusts/Mists/Paint Spray Prefilter, p127 $3.07

7A-10044 AO7Star Retainer Clips, p 127 $3.20

(ix) 23C PAPR with tight-fitting facepiece and combination cartridges approved PLE $627.45 $35.50

7A-13599 3M Face-Mounted PAPR System, p142 $720.00

--- Paint, Lacquer, Enamel Cartridge* $36.50

7A-32505 RACAL Powerflow PAPR, p142 $534.90

--- Paint, Lacquer, Enamel Cartridge* $34.50

( x) 23C PAPR with loose-fitting hood or helmet and combination cartridges for PLE $525.43 $26.88

7A-32506 RACAL Air-Mate PAPR 12, p143 $411.05

--- Paint, Lacquer, Enamel Cartridge* $24.65

7A-32477 RACAL Breathe-Easy HEPA Cartridges and Turbo Unit, p141 $548.50

7A-12840 RACAL Breathe-Easy 10 Tyvek Hood, p140 $91.30

--- Paint, Lacquer, Enamel Cartridge* $29.10

(xi) 23C Air-purifying with combination cartridges for PLE , including disposable respirators $14.30 $8.90

7A-12711 Willson Freedom 2000 Series Organic Vapors Respirator, p136 $17.85

7A-7531 Willson Dusts/Mists/Paint Spray/Pesticides Prefilter, p136 $2.52

EPA SANITIZED Page 60 of 90
40CFR

§721.63

(a)(5) 

NIOSH

type 

Catalog 

Item Number Description 1997 Cost

1997 Average Cost

Unit Cartridge

C-17

7A-13509 Willson Retainer Caps, p136 $2.03

7A-33826 Moldex 8000 Series Half-Mask Respirator, p139 $10.75

7A-22751 Moldex Organic Vapors Cartridge, p139 $8.03

7A-22753 Moldex Paint Spray/Pesticides Prefilter, p139 $2.56

7A-22754 Moldex Retainer Caps, p139 $2.65

(xii) 23C Air-purifying with full-facepiece and organic gas/vapor cartridges $192.02 $10.47

7A-9838 North Full-Face Respirator, p114 $210.10

7A-7117 North Organic Vapors Cartridge, p115 $10.50

7A-12338 Willson Full-Face Silicone Respirator, p116 $215.10

7A-7527 Willson Organic Vapors Cartridge, p117 $10.25

7A-10516 3M 7800 Full-Facepiece Respirator, p118 $202.10

7A-9279 3M Organic Vapors Cartridge, p119 $8.91

7A-9292 3M Retainer Caps, p119 $3.90

7A-33446 Pro-Tech Full-Face Respirator, p122 $106.45

7A-955-4 Pro-Tech Organic Vapors Cartridge, p123 $9.27

7A-3195 Willson 1600/1700 Series Full-Fave Respirators, p124 $215.10

7A-3197 Willson Organic Vapors Cartridge, p125 $11.22

7A-23959 AO7Star Full-Face Respirator (Silicone), p126 $203.25

7A-9935 AO7Star Organic Vapors Cartridge, p127 $8.76

(xiii) 23C PAPR with tight-fitting facepiece and organic gas/vapor cartridges $826.40 $41.15

7A-32473 RACAL Breathe-Easy Organic Vapors and Turbo Unit, p141 $548.50

7A-12844 RACAL Breathe-Easy 7 Full Face, p140 $277.90

7A-12830 RACAL Organic Vapors Replacement Cartridges, p141 $41.15

(xiv) 23C PAPR with a loose-fitting hood or helmet and organic gas/vapor cartridges $639.80 $41.15

7A-32473 RACAL Breathe-Easy Organic Vapors and Turbo Unit, p141 $548.50

7A-12840 RACAL Breathe-Easy 10 Tyvek Hood, p140 $91.30

7A-12830 RACAL Organic Vapors Replacement Cartridges, p141 $41.15

(xv) 23C Air-purifying with organic gas/vapor cartridges, including disposable cartridges $10.83 $8.94 

7A-15255 3M 6000 Series Low-Maintenance Respirator, p135 $10.90

7A-15256 3M Organic Vapors Cartridge, p135 $9.85

7A-33826 Moldex 8000 Series Half-Mask Respirator, p139 $10.75

7A-22751 Moldex Organic Vapors Cartridge, p139 $8.03

Source: LSS 1997; EPAB 1999

*Paint, lacq uer and ename l (PLE) cartridges for PAPR s were no t listed in the catalog. The costs for PL E cartridges are assum ed to

be the same as HEPA cartridges.

EPA SANITIZED Page 61 of 90
C-18

C.2.7 Annual Costs of Protection in the Workplace Requirements

Based on the equipment purchase costs shown above in Tables C-7, C-8, C-9 C-10, and the

assumptions made regarding replacement intervals for the equipment, Table C-12 below shows the

annual costs of providing the various types of personal protective equipment in the workplace, per

chemical, at one manufacturing site, with 25 exposed workers.

Table C-12 Annual Costs of Personal Protective Equipment

PPE and Requirement Citation at 40

CFR

Unit Cost

(2002 Dollars)

Quantity

Required

Annual Cost 

(2000 Dollars)

Gloves §721.6 3(a)(2)(i)

Standard (disposable) $0.48 6250 $3,012

Heavy-duty butyl $38.11 250 $9,527

Protective clothing §721.63(a)(2)

(ii)- Full-body (coverall with hood) $68.60 75 $5,145

(iv)- Coverall (no hood) $40.63 75 $3,047

Eyewear §721.63(a)(2)(i)

Standard goggles $4.54 75 $340

Heavy-duty goggles $6.78 75 $509

Respirators §721.63(a)(5) Respirator Cartridge

Unit Cost Quantity Unit Cost Quantity Total

(i)- Type 1 Respirator $901.21 25 -- -- $22,530

(ii)- Type 2 Respirator $901.21 25 -- -- $22,530

(iii)- Type 3 Respirator $1,044.82 25 -- -- $26,121

(iv)- Type 4 Respirator $202.51 25 $10.94 1250 $18,737

(v)- Type 5 Respirator $703.29 25 $39.79 1250 $67,321

(vi)- Type 6 Respirator $588.94 25 $30.14 1250 $52,399

(vii)- Type 7 Respirator $14.04 25 $7.85 1250 $10,159

(viii)- Type 8 Respirator $215.23 25 $17.61 1250 $27,392

(ix)- Type 9 Respirator $703.29 25 $39.79 1250 $67,321

(x)- Type 10 Respirator $588.94 25 $30.13 1250 $52,385

(xi)- Type 11 Respirator $16.03 25 $9.98 1250 $12,870

(xii)- Type 12 Respirator $215.23 25 $11.74 1250 $20,050

(xiii)- Type 13 Respirator $926.29 25 $46.12 1250 $80,812

(xiv)- Type 14 Respirator $717.13 25 $46.12 1250 $75,583

(xv)- Type 15 Respirator $12.14 25 $10.02 1250 $12,829

Note: To tal annual costs assum e: 1) 25 w orkers ex posed 250 days per year; 2) standard gloves replaced daily and heavy-duty

gloves replaced every 25 days; 3) respirators replaced annually and cartridge sets replaced every five days; 4) goggles and

protective clothing replaced three times y early

Source: Tables C-6, C-7, C-8, C-9, and C-11.

EPA SANITIZED Page 62 of 90
C-19

C.3 Recordkeeping

Recordkeeping requirements are specified for all PMN substances listed in the current SNUR. 

Companies submitting a SNUN must keep records under 40 CFR §721.40. In addition, whether or not

they submit a SNUN, all manufacturers, importers, and processors of the SNUR substance must keep

records based on §721.125(a) through (k), to document compliance with SNUR conditions for avoiding a

Significant New Use. (Companies manufacturing only for R&D use must add the SNUR chemical to their

R&D records system.) 

For example, for all chemicals in the current SNUR, manufacturers, importers, and processors

must keep records on quantities supplied or purchased under §721.125(a), (b), and (c). For chemicals

with water discharge restrictions, companies must keep records concerning water discharge compliance,

under §721.125(k). For those few chemicals with workplace protection or hazard communication

restrictions, companies must keep records to document compliance.

 

The requirements vary between substances (i.e., there are variations in terms of the types of

records that must be kept, reflecting differences in SNUR restrictions) . This analysis estimates

recordkeeping costs for a chemical with numerous SNUR restrictions, including workplace protection,

hazard communication, water discharge, and disposal. Since few if any chemicals will have all of those

restrictions, actual recordkeeping costs may be less than estimated here. However, the differences are

judged to have a minimal impact on the type of recordkeeping activities that must be performed and the

costs that will be incurred.

All recordkeeping requirements basically involve copying and filing relevant records, including

those related to: manufacturing, importing, or processing volumes; shipment amounts and customer

information; labels (documentation of labeling procedures and copies of labels); MSDS; and compliance

with any additional restrictions on use, disposal, and discharge. Records must be maintained for five

years from the date of their creation.

Costs for compliance with the recordkeeping requirements for substances subject to a SNUR are

based on the approach in RIB (1989). On an annual basis, recordkeeping associated with each substance

is estimated to require: 2.3 hours technical time, 23 hours clerical time, 1,715 photocopies, one half of a

4-drawer file cabinet, and other miscellaneous materials such as folders. 

To calculate labor costs associated with these requirements, EPA used the labor rates for chemical

technicians and clerical support described earlier in this report and in Appendix B (BLS 2003d). Also as

before, photocopying was inflated from $0.5 per page in 1988. A standard, four-drawer, full-suspension

file cabinet was priced from a national office products supplier at $195.00 (BT Office Products 1997;

Item #LGM-202401), or $218.57, when inflated to 2002 dollars (BLS 2003b). Miscellaneous materials

costs were estimated at $23.00 per chemical in 1989 (RIB 1989), or $33.37 when inflated to 2002 dollars

(BLS 2003b).

EPA SANITIZED Page 63 of 90
C-20

Other assumptions underlying the recordkeeping cost estimates, based on RIB 1989 and

information used in preparing the RIB 1989 report (Kearney 1988), are listed below.

 " The SNUR chemical is present at one of a company s sites.

 " Manufacture and import volume, and sales and transfer data require 480 pages of records per year. 

This reflects 40 invoices per month (see Haz-Comm Section C.1 above). 

 " Disposal compliance records, if required, cover items such as waste production, shipping

manifests, permits, and transfer receipts.

 " The ratios of labor hours to page count for each labor category, file drawer space to page count,

and cost of miscellaneous supplies such as folders and labels to page count, are the same as those

estimated for EPA s Comprehensive Assessment and Reporting Rule (CAIR). 

Total costs for recordkeeping, as shown in Table C-13, are $923 per chemical with numerous

SNUR restrictions. Recordkeeping costs would be lower for chemicals with relatively few SNUR

restrictions and therefore fewer pages needed to document SNUR compliance.

EPA SANITIZED Page 64 of 90
C-21

Table C-13 Annual Costs of Recordkeeping Requirements [40 CFR §721.125]

Cost Element

Unit Cost

(2002 Dollars) Hours

Total

Cost

2.25 hours technical time $43.34 per hour 2.25 $97.52

23 hours clerical time Pages $23.96 per hour 23.0 $551.11

1,715 pages of copying resulting from 40 CFR 

§721.125 (a) through (k): *

 (a), (b), (c) Volumes & data ** 

 (d) Protective clothing [721.63] 

 (e) Impermeability [721.63(a)(3)] 

 (f) Haz com program [721.72] 

 (g) Label copies[721.72(b)]

 (h) MSDS copies [721.72(c)]

 (i) Use limitations compliance [721.80]

 (j) Disposal compliance [721.85]

 (k)Water discharge compliance [721.90] 

485 

20

 

250

 5

 5

250

 600

100

1715

$0.076 per copy $130.34

Half of a four-drawer filing cabinet ($195 in 1997,

inflated using a factor of 1.121) 

$218.57 each $109.29

Misc. materials ($23 in 1988, inflated using a factor

of 1.521)

$34.98 per chemical $34.98

Total 25.3 $923

Source: File cabinet 1997 price, LSS 1997; quantities, RIB 1989 and Kearney 1988; labor rates, Appendix B; inflators, BLS

2003b and Appendix B.

* 40 CFR 721.125(a) through (k) lists recordkeeping requirements that are triggered by other SNUR restrictions, indicated

in the bracketed CFR references §721.63, §721.72, §721.80, §721.85, and §721.90.

** Kearney 1988 had 5 pages for manufacture/import volume and 480 pages for sales/transfer data.

 Protective clothing pages assumed same as pages for protective gloves  in RIB 1989. Haz com pages assumed same

as pages for employee information and training in RIB 1989. Impermeability not separately costed in RIB 1989. Assume

it is included under Protective clothing. 

 Inflated from $0.5 per copy in 1988 using Consumer Price Index factor 1.521. See Appendix B.

NOTE: Totals were calculated using unrounded values from Appendix B, and may not equal product of the rounded values

shown in this table. 

EPA SANITIZED Page 65 of 90
APPENDIX D

COSTS OF TESTING

EPA SANITIZED Page 66 of 90
D-1

APPENDIX D COSTS OF TESTING

This appendix presents a detailed description of the methodology used to estimate costs for health

and environmental effects testing recommended for chemicals subject to the current SNUR.

Table D-2 contains a master list of all guidelines cited in the batch SNUR and the dollar cost and

hours estimate for each, based on the assumptions and adjustments discussed below. In cases where cost

information was not available for a particular guideline, cost information was obtained from a

corresponding test as indicated by parenthesis in the Guideline column.

Testing Guidelines

For some or all chemicals in a SNUR, EPA identifies tests that can be used by submitters to

characterize risks of the PMN substances. The tests are recommended in the SNUR, not mandatory, and

they are identified by guideline numbers which can be used to look up published test protocols. The

types of guidelines are described below.

 " OPPTS Harmonized. Most SNUR tests are identified by their OPPTS number from the series of

OPPTS Harmonized Test Guidelines and OPPTS harmonized public drafts not yet promulgated as

OPPTS guidelines. For example, the OPPTS 835 series covers Fate, Transport and

Transformation; the 850 series covers Ecological Effects, and the 870 series covers Health

Effects. An example is OPPTS Guideline 850.1400, Fish Early Life Stage Toxicity. These

guidelines may have equivalent Code of Federal Regulations (CFR) or Organization for

Economic Cooperation and Development (OECD) guidelines. They are available electronically

on EPA s website. 

 " CFR. A few SNUR tests are identified as coming from the Code of Federal Regulations. An

example is the two-year bioassay test at 40 CFR 799.9420. These CFR guidelines may have

equivalent OPPTS harmonized guidelines, but are listed in the SNUR by their CFR reference.

 " OECD. A few SNUR tests are identified by their OECD number. The OECD guidelines may

also have OPPTS equivalents. For example, OECD 407 28-Day Oral Toxicity in Rats is

essentially equivalent to OPPTS 870.3050.

 " PBT Category. Finally, for some chemicals, the SNUR cites tiered testing according to a testing

strategy published in the Federal Register (FR), Category for Persistant, Bioaccumulative, and

Toxic New Chemical Substances, November 4, 1999 (64 FR 60194), which in turn refers to a

number of tests by OPPTS or OECD guideline number.

EPA SANITIZED Page 67 of 90
D-2

Testing Costs

Testing costs for each PMN substance are calculated by adding up costs of individual tests listed

in the SNUR for that substance. EPA regularly develops cost estimates of many test 

guidelines to support TSCA rule development. These costs are used where possible. If costs of a test

have not been estimated, EPA identifies an equivalent guideline for which the cost have been developed,

and uses that cost. All test costs have been updated to 2002 dollars using Employment Cost Index

inflators from the Bureau of Labor Statistics (see Appendix B).

In cases where EPA had not estimated costs of the exact test called for in the SNUR, or where the

SNUR left open aspects of method, EPA made the adjustments described below. 

Default parameters and other adjustments

Costs for many of the guidelines have been estimated for different combinations of species, route,

length of study and other aspects of methodology, but in some cases the SNUR may not specify all of

these variables. Where this occurs, EPA has used certain default parameters, which are listed in Table D1. 

Table D-1 Default Parameters for Species, Route, and Study Type

Variab le Default

Species Mamm als

Fish

Invertebrates

Algae

Rats

Fathead minnow*

Daphnids

[Four species see text]

Route/Method Mammalian

Fish

Invertebrates

Gavage

Flow-through

Flow-through

* For guideline 850.1400 tests duplicated in P BT tier tests, rainbow tro ut is the default. (See PB T test discussion below.)

 

There were other adjustments as well:

 " The SNUR recommends algal acute toxicity testing following OPPTS Guideline 850.5400 for

several PMNs. This guideline has been previously costed by EPA for four separate algal species 

(Navicula pelliculosa, Skeletonema costatum, Anabaena flos-aquae, and Selenastrum

capricornutum). Since the SNUR does not specify the algal species to be used, the average costs

of the four algal species tests were used in this analysis.

EPA SANITIZED Page 68 of 90
D-3

 " For OPPTS test guideline 870.3700 for prenatal developmental toxicity, the SNUR specified twospecies testing using rats and mice. Test cost information was not available for testing rats and

mice as the two species or for mice testing by the gavage route. For a corresponding CFR test (40

CFR 798.4900), costs for testing rats are greater than for testing mice. Therefore, cost

information was used for rats by the gavage route for 870.3700. Cost information for 870.3700

was used instead of 798.4900 because the cost information was more recent. Using the rat testing

by gavage cost information errs on the conservative side (presents an overestimate of cost). 

 " In cases where OECD 421 and OECD 422 reproductive and developmental toxicity tests were

listed as alternatives, costs for the more expensive test, OECD 422, were used.

Persistent Bioaccumulative Toxic (PBT) tiered testing

For some chemicals, the SNUR cites tiered testing for Persistant Bioaccumulative Toxic chemical

substances (PBTs) according to the testing strategy in Category for Persistant, Bioaccumulative, and

Toxic New Chemical Substances, November 4, 1999, at 64 FR 60194. In 64 FR 60194, there are three

tiers of testing. The results of tier 1 determine whether tier 2 testing is needed and the results of tier 2

testing determine whether tier 3 testing is needed. To obtain a cost estimate for chemicals citing this

tiered testing, two estimates were made: a low estimate which includes Tier 1 test costs plus any

additional tests listed in the SNUR for that chemical, and a high estimate that includes Tiers 1, 2, and 3

testing as well as any additional testing listed in the SNUR. Costs were adjusted to avoid

doublecounting tests listed in both the PBT tiers and in the SNUR. Further details are provided in Table

D-2. 

Other assumptions are described below:

 " For some chemicals, test guideline 850.1400 is referenced both explicitly in the SNUR and

implicitly as part of PBT tier 3. The PBT test referenced at 64 FR 60194 specifies rainbow trout

as the species. Test costs for those chemicals assume the test explicitly listed in the SNUR would

be conducted with rainbow trout, to be consistent with the species designated in PBT tier 3 for

the same test.

 " For PBT tier 1 ready biodegradability tests, firms may either choose among six methods in test

guideline 835.3110 or follow test guideline 835.3120. The costs estimates assume 835.3110 was

used and calculates the average cost of its six methods.

Costs by test and by PMN chemical

Table D-3 presents recommended test guidelines, the costs associated with each guideline, and the

total testing costestimates for each of the 65 chemicals. An asterisk denotes that the SNUR did not

specify which species or route/method to use and the default assumptions mentioned above were used. 

No tests were listed in the SNUR for two of the 65 chemicals.

EPA SANITIZED Page 69 of 90
D-4

Table D-2 Cost Estimates for Test Guidelines Cited in Batch SNUR

Guideline Test Species Route/Method Cost ($2002) Hours

799.9420 Two year bioassay Rats inhalation $1,730,120.19 22748

835.1110 Activated sludge sorption/desorption isotherm $9,904.29 82

835.2120

(796.3500)

Hydrolysis study at 25 degrees centigrade and pH 7 $9,541.00 120

835.3110 Ready biodegradability avg of 6 tests $10,213.00 112

835.3170 Shake-flask die-away (biodegradability) $41,645.29 88

835.3220 Porous pot study $40,810.68 539

850.1010

(797.1300)

Daphnid acute toxicity Daphnid flow-through $8,995.98 54

850.1010

(797.1300)

Daphnid acute toxicity Daphnid static $8,834.23 53

850.1075

(797.1400)

Fish acute toxicity static $10,398.79 84

850.1075

(797.1400)

Fish acute toxicity Fathead Minnow flow-through $13,624.62 65

850.1085 Fish acute toxicity mitigated by humic acid Fathead Minnow static $10,974.19 74

850.1300 Daphnid chronic toxicity Daphnid flow-through $31,730.77 173

850.1400 Fish early life stage chronic toxicity Fathead Minnow flow-through $34,483.17 291

850.1400 Fish early life stage chronic toxicity Rainbow trout flow-through $52,560.10 432

850.1730 Fish bioaccumulation (BCF) Fathead Minnow flow through $58,716.50 775

850.5400 Algal acute toxicity Average of four species $10,983.68 60

870.1100 Acute oral toxicity Rats gavage $3,533.69 44

870.3100 90- day subchronic oral study in rats Rats gavage $121,128.45 834

870.3465 90-day inhalation toxicity study Rats inhalation $340,553.22 2458

870.3700 Prenatal developmental toxicity Rats gavage $98,594.95 1157

870.3800 Two generation reproductive and toxicity study Rats gavage $529,717.65 5024

870.4200 2-year, two-species oral carcinogenicity Rats gavage $799,639.42 8275

870.4300 Combined chronic toxicity/carcinogenicity study Rats gavage $972,884.62 9701

870.5100 Ames assay/salmonella Direct plate $7,892.53 48

870.5265 Salmonella typhimurium reverse mutation assay Average of Direct plate 

and Azo reduction

$7,347.50 48

EPA SANITIZED Page 70 of 90
Guideline Test Species Route/Method Cost ($2002) Hours

D-5

870.5395 In vivo mouse micronucleus assay (intraperitoneal) Mice gavage 

(avg of 1 and 3 day doses)

$14,687.50 114

OECD 407 28-day oral toxicity study in rats Rats gavage $43,750.00 328

OECD 407

(mod : FOB + histo)

28-day oral toxicity study in rats modified with FOB and

histopathology

Rats gavage $150,629.43 1838

OECD 421 Reproductive/Development Toxicity Rats gavage $51,875.00 445

OECD 422 Combined Repeated Dose with

Reproductive/Developmental Toxicity

Rats gavage $109,464.00 1146

60 FR 60194 Persistent Bioaccumulative Toxic (PBT) Tiered Testing

TIER 1 $60,577.38 275.5

830.7570

(796.1570)

Log Kow (liquid chromatography) Liquid chromatography $2412.11 28

830.7560 Log Kow (generator column) Generator column $3,316.65 39

Log Kow (liquid chromatography or generator column) Average of 2 tests $2,864.38 33.5

835.2110 Hydrolysis in water $47,500.00 130

835.3110 Ready biodegradability (chose one of six methods) Average of 6 methods $10,213.00 112

TIERS 2 and 3 $402,989.02 4110

TIER 2

835.3170 Shake-flask die-away (biodegradability) $41,645.29 88

850.1730 Fish bioaccumulation (BCF) Fathead minnow Flow-through $58,716.50 775

TIER 3

OECD 422 Combined Repeated Dose Oral Toxicity with

Reproductive/Developmental Toxicity screen 

Rat gavage $109,464.00 1146

EPA SANITIZED Page 71 of 90
Guideline Test Species Route/Method Cost ($2002) Hours

D-6

835.3180 Sediment/water microcosm biodegradation Flow-through $108,872.37 1496

850.1400 Fish chronic toxicity Rainbow trout Flow-through $52,560.10 432

850.1300 Daphnid chronic toxicity Daphnid Flow-through $31,730.77 173

TIERS 2 and 3 excluding 850.1400 and 850.1300 $318,698.16 3505

TIERS 2 and 3 excluding 850.1400, 850.1300, 835.3170, and 850.1730 $218,336.37 2642

Guidelines in parenthesis indicate corresponding test guidelines from which cost information was calculated.

EPA SANITIZED Page 72 of 90
D-7

Table D -3 SNU R Testing Requ irements a nd Cost for 65 C hemicals

No. PMN Guideline Species Route/Method Cost ($2002) Hours Total Cost ($2002) Total Hours

1 P-97-1108 850.1400 Fathead Minnow* flow-through* $34,483.17 291 $118,008.30 1,063

850.1300 Daphnid flow-through* $31,730.77 173

850.5400 Average of four species* - $10,983.68 60

835.3220 - - $40,810.68 539

2 P-98-848 870.3465 Rats* inhalation $340,553.22 2458 $2,070,673.41 25206

799.9420 Rats* inhalation $1,730,120.19 22748

3 P-98-1033 OECD 407 

(mod : FOB + histo)

Rats gavage* $150,629.43 1838 $297,516.16 3288

870.5395 Mice gavage

(avg of 1 and 3 day doses)*

$14,687.50 114

870.3700 Rats* gavage* $98,594.95 1157

850.1075 Fathead Minnow* flow-through* $13,624.62 65

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

4 P-98-1034 OECD 407 

(mod : FOB + histo)

Rats gavage* $150,629.43 1838 $297,516.16 3288

870.5395 Mice gavage

(avg of 1 and 3 day doses)*

$14,687.50 114

870.3700 Rats* gavage* $98,594.95 1157

850.1075 Fathead Minnow* flow-through* $13,624.62 65

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

5 P-98-1035 OECD 407 

(mod : FOB + histo)

Rats gavage* $150,629.43 1838 $297,516.16 3288

870.5395 Mice gavage

(avg of 1 and 3 day doses)*

$14,687.50 114

870.3700 Rats* gavage* $98,594.95 1157

850.1075 Fathead Minnow* flow-through* $13,624.62 65

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

EPA SANITIZED Page 73 of 90
No. PMN Guideline Species Route/Method Cost ($2002) Hours Total Cost ($2002) Total Hours

D-8

6 P-99-783 850.1010 Daphnid flow-through $8,995.98 54 $19,979.66 114

850.5400 Average of four species* - $10,983.68 60

7 P-99-817 870.3465 Rats* inhalation $340,553.22 2458 $340,553.22 2458

8 P-99-897 850.1075 Fathead Minnow* flow-through* $13,624.62 65 $33,604.28 179

850.1010 Daphnid* flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

9 P-99-920 850.1075 Fathead Minnow* flow-through $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

10 P-99-928 850.1075 Fathead Minnow* flow-through $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

11 P-99-951 850.1075 Fathead Minnow* flow-through $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

12 P-99-952 850.1075 Fathead Minnow* flow-through $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

13 P-99-1075 850.1400 Fathead Minnow* flow-through* $34,483.17 291 $77,197.62 524

850.1300 Daphnid flow-through* $31,730.77 173

850.5400 Average of four species* - $10,983.68 60

14 P-99-1202 850.1400 Fathead Minnow* flow-through $34,483.17 291 $417,750.84 2982

850.1300 Daphnid flow-through $31,730.77 173

850.5400 Average of four species* - $10,983.68 60

870.3465 Rats* inhalation $340,553.22 2458

15 P-99-1288 850.1075 Fathead Minnow* flow-through $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

16 P-99-1295 850.1075 Fathead Minnow* flow-through $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

EPA SANITIZED Page 74 of 90
No. PMN Guideline Species Route/Method Cost ($2002) Hours Total Cost ($2002) Total Hours

D-9

17 P-99-1304 850.1075 Fathead Minnow* flow-through $13,624.62 65 $374,157.49 2637

850.1010 Daphnid flow-through $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

870.3465 Rats* inhalation $340,553.22 2458

18 P-99-1341 850.1075 - static $10,398.79 84 $30,216.70 197

850.1010 Daphnid static $8,834.23 53

850.5400 Average of four species* - $10,983.68 60

19 P-99-1342 850.1075 - static $10,398.79 84 $30,216.70 197

850.1010 Daphnid static $8,834.23 53

850.5400 Average of four species* - $10,983.68 60

20 P-00-7 870.3465 Rats* inhalation $340,553.22 2458 $340,553.22 2458

21 P-00-368 870.3465 Rats* inhalation $340,553.22 2458 $406,767.16 2922

850.1400 Fathead Minnow* flow-through* $34,483.17 291

850.1300 Daphnid flow-through* $31,730.77 173

22 P-00-636 870.3800 Rats* gavage* $529,717.65 5024 $1,329,357.07 13299

870.4200 Rats* gavage* $799,639.42 8275

23 P-00-838 850.1400 Fathead Minnow* flow-through $34,483.17 291 $34,483.17 291

24 P-00-912

(low estimate)

64 FR 60194 - PBT T ier 1 $60,577.38 275.5 $1,076,619.80 10049 .5

850.1400 Rainbow Trout flow-through* $52,560.10 432

850.1300 Daphnid flow-through $31,730.77 173

850.5400 Average of four species* - $10,983.68 60

870.4200 Rats* gavage* $799,639.42 8275

870.3100 Rats gavage* $121,128.45 834

24 P-00-912

(high estimate)

64 FR 60194 - PBT T ier 1 $60,577.38 275.5 $1,395,317.95 13554 .5

64 FR 60194 - PBT Tiers 2 and 3 (a) $318,698.16 3505

850.1400 Rainbow trout* flow-through $52,560.10 432

850.1300 Daphnid flow-through $31,730.77 173

850.5400 Average of four species* - $10,983.68 60

870.4200 Rats* gavage* $799,639.42 8275

EPA SANITIZED Page 75 of 90
No. PMN Guideline Species Route/Method Cost ($2002) Hours Total Cost ($2002) Total Hours

D-10

870.3100 Rats gavage* $121,128.45 834

(a) Excluding 850.1400 and 850.1300 to avoid doublecounting

25 P-00-966 850.5400 Average of four species* - $10,983.68 60 $43,817.28 291

850.1010 Daphnid* flow-through $8,995.98 54

850.1075 Fathead Minnow* flow-through $13,624.62 65

835.3110 Ready biodegradation avg of 6 tests* $10,213.00 112

26 P-00-991 850.1075 Fathead Minnow* flow-through* $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

27 P-00-1055 870.3700 Rats* gavage $98,595.00 1157 $1,484,136.38 14797

870.3800 Rats* gavage* $529,717.65 5024

870.5100 Salmonella Direct plate* $7,892.53 48

870.5395 Mice gavage

(avg of 1 and 3 day doses)*

$14,687.50 114

870.4200 Rats gavage* $799,639.42 8275

850.1075 Fathead Minnow* flow-through* $13,624.62 65

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

28 P-00-1205 850.1075 Fathead Minnow* flow-through* $13,624.62 65 $34,503.10 221

850.1085 Fathead Minnow* static* $10,974.19 74

835.1110 - - $9,904.29 82

29 P-00-1220 850.1075 Fathead Minnow* flow-through* $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* $10,983.68 60

30 P-01-1 835.2130 - - $9,541.00 120 $53,358.28 411

835.3110 - avg of 6 tests* $10,213.00 112

850.1075 Fathead Minnow* flow-through* $13,624.62 65

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

31 P-01-7 870.3700 Rats* gavage* $98,594.95 1157 $898,234.37 9432

870.4200 Rats* gavage* $799,639.42 8275

EPA SANITIZED Page 76 of 90
No. PMN Guideline Species Route/Method Cost ($2002) Hours Total Cost ($2002) Total Hours

D-11

32 P-01-9

(low estimate)

64 FR 60194 - PBT T ier 1 $60,577.38 275.5 $155,851.93 940.5

850.1400 Rainbow Trout flow-through $52,560.10 432

850.1300 Daphnid flow-through $31,730.77 173

850.5400 Average of four species* - $10,983.68 60

32 P-01-9

(high estimate)

64 FR 60194 - PBT T ier 1 $60,577.38 275.5 $474,550.09 4445.5

64 FR 60194 - PBT Tiers 2 and 3 (a) $318,698.16 3505

850.1400 Rainbow Trout flow-through $52,560.10 432

850.1300 Daphnid flow-through $31,730.77 173

850.5400 Average of four species* - $10,983.68 60

(a) Excluding 850.1400 and 850.1300 to avoid doublecounting

33 P-01-22 850.1075 Fathead Minnow* flow-through $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

34 P-01-69 850.1075 Fathead Minnow* flow-through $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

35 P-01-71 850.1400 Rainbow Trout flow-through $52,560.10 432 $84,290.87 605

850.1300 Daphnid flow-through $31,730.77 173

36 P-01-77 OECD 422

or OECD 421

Rats* gavage $109,464.00 1146 $143,068.28 1325

850.1075 Fathead Minnow* flow-through $13,624.62 65

850.1010 Daphnid flow-through $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

37 P-01-85 850.1075 Fathead Minnow* flow-through $13,624.62 65 $33,604.28 $179.00

850.1010 Daphnid* flow-through $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

38 P-01-97 870.3100 Rats gavage* $121,128.45 834 $920,767.87 9109

870.4200 Rats gavage* $799,639.42 8275

39 P-01-144 870.3700 Rats* gavage* $98,594.95 1157 $274,793.07 3201

EPA SANITIZED Page 77 of 90
No. PMN Guideline Species Route/Method Cost ($2002) Hours Total Cost ($2002) Total Hours

D-12

OECD 407 

(mod: FOB + histo)

Rats gavage $150,629.43 1838

870.1100 Rats* gavage $3,533.69 44

870.5395 Mice* gavage

(avg of 1 and 3 day doses)*

$14,687.50 114

870.5265 Average of Direct plate

and Azo reduction*

$7,347.50 48

40 P-01-149 870.3100 Rats* gavage $121,128.45 834 $121,128.45 834

41 P-01-152 

(low estimate)

64 FR 60194 - PBT T ier 1 $60,577.38 275.5 $94,181.66 454.5

850.1075 Fathead Minnow* flow-through* $13,624.62 65

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* $10,983.68 60

41 P-01-152 

(high estimate)

64 FR 60194 - PBT T ier 1 $60,577.38 275.5 $497,170.68 4564.5

64 FR 60194 - PBT Tiers 2 and 3 $402,989.02 4110

850.1075 Fathead Minnow* flow-through* $13,624.62 65

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

42 P-01-170 N/A [No tests listed in SNUR] N/A N/A $0.00 0

43 P-01-298 870.3700 Rats* gavage* $98,594.95 1157 $98,594.95 1157

44 P-01-320 870.3465 Rats* inhalation $340,553.22 2458 $340,553.22 2458

45 P-01-397 850.1400 Fathead Minnow* flow-through $34,483.17 291 $77,197.62 524

850.1300 Daphnid flow-through $31,730.77 173

850.5400 Average of four species* - $10,983.68 60

46 P-01-420 850.1075 Fathead Minnow* flow-through* $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

47 P-01-423 870.3465 Rats* inhalation $340,553.22 2458 $340,553.22 2458

48 P-01-432 870.5395 Mice gavage

(avg of 1 and 3 day doses)*

$14,687.50 114 $1,508,923.02 14575

OECD 407 Rats gavage $43,750.00 328

EPA SANITIZED Page 78 of 90
No. PMN Guideline Species Route/Method Cost ($2002) Hours Total Cost ($2002) Total Hours

D-13

870.3100 Rats gavage $121,128.45 834

870.3800 Rats gavage* $529,717.65 5024

870.4200 Rats* gavage* $799,639.42 8275

49 P-01-433 870.3465 Rats* inhalation $340,553.22 2458 $374,157.49 2637

850.1075 Fathead Minnow* flow-through* $13,624.62 65

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

50 P-01-441

(low estimate)

64 FR 60194 - PBT T ier 1 $60,577.38 275.5 $94,181.66 454.5

850.1075 Fathead Minnow* flow-through* $13,624.62 65

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

50 P-01-441

(high estimate)

64 FR 60194 - PBT T ier 1 $60,577.38 275.5 $497,170.68 4564.5

64 FR 60194 - PBT Tiers 2 and 3 $402,989.02 4110

850.1075 Fathead Minnow* flow-through* $13,624.62 65

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

51 P-01-459 870.3465 Rats* inhalation $340,553.22 2458 $340,553.22 2458

52 P-01-460 870.3465 Rats* inhalation $340,553.22 2458 $340,553.22 2458

53 P-00-992

and P-01-471

850.1400 Fathead Minnow* flow-through $34,483.17 291 $77,197.62 524

850.1300 Daphnid flow-through $31,730.77 173

850.5400 Average of four species* - $10,983.68 60

54 P-01-481 N/A [No tests listed in SNUR] N/A N/A $0.00 0

55 P-01-561 850.1075 Fathead Minnow* flow-through* $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

56 P-01-573 850.1075 Fathead Minnow* flow-through* $13,624.62 65 $33,604.28 179

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

EPA SANITIZED Page 79 of 90
No. PMN Guideline Species Route/Method Cost ($2002) Hours Total Cost ($2002) Total Hours

D-14

57 P-01-578 850.5400 Average of four species* - $10,983.68 60 $30,216.70 197

850.1010 Daphnid static $8,834.23 53

850.1075 - static $10,398.79 84

58 P-01-646 850.1075 - static $10,398.79 84 $30,216.70 197

850.1010 Daphnid static $8,834.23 53

850.5400 Average of four species* - $10,983.68 60

59 P-01-716 

(low estimate)

850.5400 Average of four species* - $10,983.68 60 $256,213.72 1803.5

850.1400 Rainbow Trout flow-through* $52,560.10 432

850.1300 Daphnid flow-through* $31,730.77 173

850.1730 Fathead Minnow* flow through* $58,716.50 775

835.3170 - - $41,645.29 88

64 FR 60194 PBT T ier 1 $60,577.38 275.5

59 P-01-716 

(high estimate)

850.5400 Average of four species* - $10,983.68 60 $474,550.09 4445.5

850.1400 Rainbow Trout flow-through* $52,560.10 432

850.1300 Daphnid flow-through* $31,730.77 173

850.1730 Fathead Minnow* flow through* $58,716.50 775

835.3170 - - $41,645.29 88

64 FR 60194 - PBT T ier 1 $60,577.38 275.5

64 FR 60194 - PBT Tiers 2 and 3 (b) $218,336.37 2642

(b) Excluding OPPTS 850.1400, 850.1300, 850.1730, and 835.3170 to avoid doublecounting

60 P-01-781 870.4300 Rats* gavage* $972,884.62 9701 $1,347,042.11 12338

870.3465 Rats* inhalation $340,553.22 2458

850.1075 Fathead Minnow* flow-through* $13,624.62 65

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

61 P-01-833 870.3465 Rats* inhalation $340,553.22 2458 $340,553.22 2458

62 P-02-17 870.3700 Rats* gavage* $98,594.95 1157 $98,594.95 1157

63 P-02-90 870.3465 Rats* inhalation $340,553.22 2458 $340,553.22 2458

64 P-02-207 850.1075 Fathead Minnow* flow-through* $13,624.62 65 $33,604.28 179

EPA SANITIZED Page 80 of 90
No. PMN Guideline Species Route/Method Cost ($2002) Hours Total Cost ($2002) Total Hours

D-15

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

65 P-02-262 870.3465 Rats inhalation $340,553.22 2458 $374,157.49 2637

850.1075 Fathead Minnow* flow-through* $13,624.62 65

850.1010 Daphnid flow-through* $8,995.98 54

850.5400 Average of four species* - $10,983.68 60

* default assumptions used in cases where species and/or route/method not specified in SNUR

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APPENDIX E

COSTS OF SUBMITTING A SNUN, REQUEST FOR MODIFICATION OR REVOCATION OF

A SNUR, OR EQUIVALENCY DETERMINATION

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8

In the economic analysis for an earlier SNUR (EPAB 1999), EPA estimated SNUN submission costs (before user fee) at $6005

to $7240 (95 to 114 hours), compared with $4456 for 105 hours here. This is not meant to suggest that actual costs declined. 

Rather, the apparent decline is due to a revised method for calculating labor rates. The method was revised to use more current

data and to be consistent with recent EPAB economic analyses. See Appendix B for details. 

E-1

APPENDIX E COSTS OF SUBMITTING A SNUN, REQUEST FOR MODIFICATION OR

REVOCATION OF A SNUR, OR EQUIVALENCY DETERMINATION

Estimates of the costs of completing a SNUN form are based on the costs of completing a PMN

submission, since the data requirements and the submission form are essentially identical. EPA s

Regulatory Impact Analysis (RIA) for amendments to the PMN regulations (RIB 1994) relied on industry

estimates of the effort needed to collect and compile all data required for a PMN submission, prepare the

form, and submit the form and data to EPA (RIB 1994). These estimates, based on a survey conducted

by the Chemical Manufacturers Association (CMA 1991), indicate that the average effort required to

prepare and submit a PMN is 95 to 114 hours. For this analysis, the costs of a preparing a SNUN were

derived using the 2002 loaded wage rates and average of the hours for clerical, technical, and managerial

labor. Wage rate derivations are discussed in Appendix B. As shown in Table E-1, the resulting cost of

submitting a request to modify or revoke a SNUR is $4,456, the cost of submitting a SNUN is $6,956,

including a $2500 user fee, and the cost for an equivalency determination is $4,456.8 

Table E-1 Industry Costs for SNUN, Request to Modify/Revoke SNUR, or

Equivalency Determination

Labor

Category

Hours

Range*

Averag

e

Hours

Loaded Wage

Rate**

(2002 dollars)

Total Labor Cost (loaded wage × hours)

Request to

Modify SNUR 

(Option 2)

SNUN 

(Option 3)

Equivalency

Determination

(Option 4)

Clerical 12 - 14 13.0 $23.96 $311 $311 $311

Technical 67- 80 73.5 $43.34 $3,185 $3,185 $3,185

Manageri

al

16 - 20 18.0 $53.29 $959 $959 $959

Subtotal 95 - 114 104.5 $4,456 $4,456 $4,456

User fees (SNUN only) $0 $2,500

TOTAL $4,456 $6,956 $4,456

Figures may not add due to rounding. 

*Hours range for each labor category are from the PMN Amendments RIA (RIB 1994) 

** Loaded wages include fringe benefits and overhead. See Appendix B for derivation.

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APPENDIX F

AGENCY COSTS

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F-1

APPENDIX F AGENCY COSTS

EPA s costs to review and process industry submissions (SNUNs, requests to modify SNUR, and

requests for equivalency determination) are assumed to be the same as EPA costs to review PMNs. 

EPA s costs associated with SNUR submissions are presented in Table F-1. The EPA staff level (GS12), staff-year full-time equivalents (FTEs) and extramural costs such as costs for contractor support are

derived from the costs estimated for processing PMN submissions (RIB 1994). The percent of cases are

from RIB 1994 and from an 1999 SNUR economic analysis (EPAB 1999). FTE costs have been

calculated using 2002 GS-12 salary data (OPM 2002) and a loading factor of 1.6 to reflect fringe benefits

and overhead (OPPE 1992). 

The original PMN cost estimates were presented as low and high estimates, based on the most

junior (Step 1) and the most senior (Step 10) GS-12 pay rates, respectively. For simplicity, this analysis

uses the average of the two pay rates. 

 The GS-12 costs in the table below are calculated by multiplying the number of FTEs (in the first

column) by the fully loaded average salary, $102,475. This shows EPA staff cost for those chemicals

requiring this review step. The Extramural Cost column shows costs for contractor support and other

outside purchases for those chemicals requiring this review step, inflated from 1993 prices to 2002 using

the Employment Cost Index, Total Compensation for White-Collar Occupations (BLS 2003a). The

Weighted Cost column is calculated by multiplying GS-12 staff cost plus extramural costs (Unweighted

Cost) by the percentage of cases requiring this review step. This calculation yields total Agency costs for

submission review and processing of $4,034 per case.

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F-2

Table F-1 Agency Costs for SNUN and Other Submission Review and Processing

Review Step EPA 

FTE

EPA staff

(GS-12)

(a)

Extra-mural

Cost

Unweighted

Cost

Pct.

of

Cases

Weighted

Cost

1993

dollar

s

2002

dollars

(b)

(1) (2) (3) (4) (5)=(2)+(4) (6) (7)=(5)*(6)

Prenotice consultation 0.0024 $245.94 4 $5.52 $251.46 41% $103.10

Administrative prescreen/notice

receipt/user fee

0.0024 $245.94 92 $126.96 $372.90 100% $372.90

CRSS (Chemical Review and

Search Strategy)

0.0025 $256.19 268 $369.84 $626.03 100% $626.03

SAT (Structure Activity Team) 0.0006 $61.49 14 $19.32 $80.81 100% $80.81

Engineering/Exposure 0.0015 $153.71 56 $77.28 $230.99 100% $230.99

Exposure/Fate 0.0008 $81.98 0 $0.00 $81.98 100% $81.98

Focus 0.0009 $92.23 23 $31.74 $123.97 100% $123.97

Standard Review Functions 0.0219 $2,244.21 511 $705.18 $2,949.39 29% $855.32

Division Directors Meeting 0.0129 $1,321.93 113 $155.94 $1,477.87 15% $221.68

Order Development/Negotiation

Review

0.0171 $1,752.33 22 $30.36 $1,782.69 3% $53.48

Post Order Data Review 0.0886 $9,079.30 0 $0.00 $9,079.30 3% $272.38

Order Modification 0.2167 $22,206.38 0 $0.00 $22,206.38 3% $666.19

New Chemical SNUR

Development

0.0277 $2,838.56 85 $117.30 $2,955.86 7% $206.91

Notices of Commencement 0.0012 $122.97 40 $55.20 $178.17 31% $55.23

FOIA (Freedom of Information

Act) Requests

0.0333 $3,412.42 287 $396.06 $3,808.48 1% $38.08

CBI (Confidential Business

Information) Substantiation

0.0004 $40.99 3 $4.14 $45.13 100% $45.13

TOTAL $4,034

Sources: FTEs per review step and 1993 extramural costs are from RIB 1994. Percents of cases are from

RIB 1994 and EPAB 1999. GS-12 salaries are from OPM 2002. 

(a) The average of GS-12 Step 1 and GS-12 Step 10 salaries for 2002 was ($55,694 + $72,400) / 2 =

$64,047. This was multiplied by an assumed loading factor of 1.6 to reflect fringe benefits and overhead,

resulting in a fully loaded cost per FTE of 1.6 X $64,047 = $102.475.

EPA SANITIZED Page 86 of 90
F-3

(b) Extramural costs consist of contracting support and other purchases directly attributable to the PMN

review process. They were inflated from 1993 prices to 2002 prices using a factor of approximately 1.38 

(see Appendix B).

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APPENDIX G

REFERENCES

EPA SANITIZED Page 88 of 90
G-1

APPENDIX G REFERENCES

29 CFR 1910. Occupational Safety and Health Standards. Code of Federal Regualtions, Part 1910, Title

29, November 25, 1983.

Best 1997. Personal communication between Tom DeCoff of Eastern Research Group, Lexington, MA and

Best Manufacturing Co. technical support services, Austin, TX, December 1997. 

BLS 2003a. Bureau of Labor Statistics. Employment Cost Index, Total Compensation: White-Collar

Occupations (Series ID: ECS11102I), extracted May 28, 2003. 

BLS 2003b. Bureau of Labor Statistics. Consumer Price Index- All Urban Consumers, U.S. City Average

(Series ID: CUUR0000SA0), extracted May 28, 2003.

BLS 2003c. Bureau of Labor Statistics. National Employment, Hours, and Earnings, Average Hourly

Earnings of Production Workers (Series ID: EEU32280006), extracted May 28, 2003.

BLS 2003d. Bureau of Labor Statistics. Employer Costs for Employee Compensation - December 2002:

Private industry, goods-producing workers by occupational group (Table 11), March 18, 2003.

BT Office Products 1997. BT Office Products International. Office Products Catalog, 1997.

CMA 1991. Chemical Manufacturers Association. Responses to Questions on Burden Associated with

PMN Submissions. Distributed by the Chemical Manufacturers Association, Washington, DC.

EPAB 1998. Economic Analysis of Expedited Significant New Use Rules for 168 Chemical Substances and

Background Support Document for Economic Analysis of Significant New Use Rules. Washington,

DC: U.S.EPA/OPPT/EETD/EPAB, January 1998.

EPAB 1999. Economic Analysis of Expedited Significant New Use Rules for 41 Chemical Substances and 

Background Support Document for Economic Analysis of Significant New Use Rules. Washington,

DC: U.S.EPA/OPPT/EETD/EPAB, July 20, 1999. EPA Docket OPPTS-50635.

EPAB 2002. Revised Economic Analysis for the Amended Inventory Update Rule: Final Report.

Washington, DC: U.S.EPA/OPPT/EETD/EPAB, August 2002.

IHSN 1997. Industrial Hygiene and Safety News. 1997 EHS Salary Survey. August, 1997.

Kearney, 1988. Memorandum to Bill Massouda, Reporting and recordkeeping costs for a generic

SNUR,  February 3, 1988. [Memo submitted to U.S. EPA/Office of Toxic Substances (now OPPT)

under contract 68-02-3980 with A.T.Kearney, Inc.]. 

LSS 1997. Lab Safety Supply. 1997 Product Catalog.

EPA SANITIZED Page 89 of 90
G-2

OPM 2002. U.S. Office of Personnel Management. Salary Table 2002-DCB (Washington-Baltimore).

OPPE 1992. Office of Policy, Planning, and Evaluation. Instructions for Preparing Information

Collection Requests (ICRs). Washington, DC: U.S. EPA, June 1, 1992.

OSHA 1983. Final Regulatory Impact and Regulatory Flexibility Analyses of the Hazard Communication

Standard. US Dept of Labor, OSHA, Office of Regulatory Analysis, Washington DC, 8/9/83.

RIB 1989. Regulatory Impacts Branch. Economic Analysis of Final Significant New Rules: General

Provisions for New Chemical Follow-Up. Washington, DC: U.S. EPA/OTS/EETD/RIB, July 19,

1989.

RIB 1994. Regulatory Impacts Branch. Regulatory Impact Analysis of Amendments to Regulations for

TSCA Section 5 Premanufacture Notifications. Washington, DC: U.S. EPA/OPPT/EETD/RIB,

September 9, 1994.

Rice 2002. Cody Rice. Wage Rates for Economic Analysis of the Toxics Release Inventory Program. 

Washington, DC: U.S.EPA/OPPT/EETD/EPAB, June 10, 2002.

Silagi 1992. William Silagi. Economic Analysis in Support of the Final Rule Promulgated under TSCA

Section 12(b). Washington, DC: U.S. EPA/OPPT/RIB, June 1992. 

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