## 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

## i 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.

## ii 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.

## iii 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

## iv

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

## v 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-21



## 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 temporarily2



## 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 to3



## 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.4

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 in5



## 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 of6



## 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 protective7



## 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.8



## 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.)9



## 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 respirators10



## 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:11



## % 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 and12



## $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 earn13



## 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 based14



## 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 $4456.15



## 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  costsas a result ofnot 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.16



## 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 is17



## 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 areone-timecosts (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-timecost. 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 theone-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.18

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 105Option 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 105Option 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 10521

(a) Option 1 includesannualcosts 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 includesone-timecosts 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 includesone-timecosts 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 includesone-timecosts 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.22

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

HazardCommun WorkplaceProtection RecordKeeping 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 2P-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 4P-98-1034 $931.19 15 $0.00 0 $923 25.3 $1,854 40.3 5P-98-1035 $931.19 15 $0.00 0 $923 25.3 $1,854 40.3 6P-99-783 $0.00 0 $0.00 0 $923 25.3 $923 25.3 7P-99-817 $0.00 0 $0.00 0 $923 25.3 $923 25.3 8P-99-897 $0.00 0 $0.00 0 $923 25.3 $923 25.3 9P-99-920 $0.00 0 $0.00 0 $923 25.3 $923 25.3 10P-99-928 $0.00 0 $0.00 0 $923 25.3 $923 25.3 11P-99-951 $0.00 0 $0.00 0 $923 25.3 $923 25.3 12P-99-952 $0.00 0 $0.00 0 $923 25.3 $923 25.3 13P-99-1075 $0.00 0 $0.00 0 $923 25.3 $923 25.3 14P-99-1202 $0.00 0 $0.00 0 $923 25.3 $923 25.3 15P-99-1288 $0.00 0 $0.00 0 $923 25.3 $923 25.3 16P-99-1295 $0.00 0 $0.00 0 $923 25.3 $923 25.3 17P-99-1304 $0.00 0 $0.00 0 $923 25.3 $923 25.3 18P-99-1341 $0.00 0 $0.00 0 $923 25.3 $923 25.3 19P-99-1342 $0.00 0 $0.00 0 $923 25.3 $923 25.3 20P-00-7 $0.00 0 $0.00 0 $923 25.3 $923 25.3 21P-00-368 $931.19 15 $10,158.75* 0 $923 25.3 $12,013 40.3 22P-00-636 $0.00 0 $1,744.65** 16 $923 25.3 $2,668 41.3 23P-00-838 $0.00 0 $0.00 0 $923 25.3 $923 25.3 24P-00-912 $0.00 0 $0.00 0 $923 25.3 $923 25.3 25P-00-966 $0.00 0 $0.00 0 $923 25.3 $923 25.3 26P-00-991 $0.00 0 $0.00 0 $923 25.3 $923 25.3 27P-00-1055 $0.00 0 $0.00 0 $923 25.3 $923 25.3 28P-00-1205 $0.00 0 $0.00 0 $923 25.3 $923 25.3 29P-00-1220 $0.00 0 $0.00 0 $923 25.3 $923 25.3 30P-01-1 $0.00 0 $0.00 0 $923 25.3 $923 25.3 31P-01-7 $0.00 0 $0.00 0 $923 25.3 $923 25.3 32P-01-9 $0.00 0 $0.00 0 $923 25.3 $923 25.3 33P-01-22 $0.00 0 $0.00 0 $923 25.3 $923 25.3 34P-01-69 $0.00 0 $0.00 0 $923 25.3 $923 25.3 35P-01-71 $0.00 0 $0.00 0 $923 25.3 $923 25.3 36P-01-77 $0.00 0 $0.00 0 $923 25.3 $923 25.3 37P-01-85 $0.00 0 $0.00 0 $923 25.3 $923 25.3 38P-01-97 $0.00 0 $0.00 0 $923 25.3 $923 25.3 39P-01-144 $0.00 0 $0.00 0 $923 25.3 $923 25.3HazardCommun WorkplaceProtection RecordKeeping Total Total Cost Hours Cost Hours Cost Hours Cost Hours No.PMN

23 40P-01-149 $0.00 0 $0.00 0 $923 25.3 $923 25.3 41P-01-152 $0.00 0 $0.00 0 $923 25.3 $923 25.3 42P-01-170 $0.00 0 $20,481.99 16 $923 25.3 $21,405 41.3 43P-01-298 $0.00 0 $0.00 0 $923 25.3 $923 25.3 44P-01-320 $0.00 0 $0.00 0 $923 25.3 $923 25.3 45P-01-397 $0.00 0 $0.00 0 $923 25.3 $923 25.3 46P-01-420 $0.00 0 $0.00 0 $923 25.3 $923 25.3 47P-01-423 $0.00 0 $0.00 0 $923 25.3 $923 25.3 48P-01-432 $0.00 0 $0.00 0 $923 25.3 $923 25.3 49P-01-433 $0.00 0 $0.00 0 $923 25.3 $923 25.3 50P-01-441 $0.00 0 $0.00 0 $923 25.3 $923 25.3 51P-01-459 $0.00 0 $0.00 0 $923 25.3 $923 25.3 52P-01-460 $0.00 0 $0.00 0 $923 25.3 $923 25.3 53P-00-992 and P-01-471 $0.00 0 $0.00 0 $923 25.3 $923 25.3
54P-01-481 $0.00 0 $0.00 0 $923 25.3 $923 25.3 55P-01-561 $0.00 0 $0.00 0 $923 25.3 $923 25.3 56P-01-573 $0.00 0 $0.00 0 $923 25.3 $923 25.3 57P-01-578 $0.00 0 $0.00 0 $923 25.3 $923 25.3 58P-01-646 $0.00 0 $0.00 0 $923 25.3 $923 25.3 59P-01-716 $0.00 0 $0.00 0 $923 25.3 $923 25.3 60P-01-781 $0.00 0 $0.00 0 $923 25.3 $923 25.3 61P-01-833 $0.00 0 $0.00 0 $923 25.3 $923 25.3 62P-02-17 $0.00 0 $0.00 0 $923 25.3 $923 25.3 63P-02-90 $0.00 0 $0.00 0 $923 25.3 $923 25.3 64P-02-207 $0.00 0 $0.00 0 $923 25.3 $923 25.3 65P-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.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 toreview 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.1Bona fidesare submitted to EPA by manufacturers and importers to determine a chemical s TSCA Chemical Inventory and

regulatory status.

2Due 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.
Pastbona fidesubmissions also suggest that few firms other than possibly some PMN submitters will be affected.1

## EPA has received fewbona fidesindicating 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 quantified26



## 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.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.

## APPENDIX A
LIST OF PMNS AND THEIR CHEMICAL NAMESA-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 esterA-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

## APPENDIX B
INFLATORS AND WAGE RATES3Many 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.

4Employer 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 theEmployer 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 inWage 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%.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 theRevised 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 theNational 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 theEmployer 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 HygienistsUnlike 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 fromEmployee 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.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.1.4EPA 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.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 dollars) Date 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 $32.05Labor

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 dollars) Date 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 theRevised 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.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.

## APPENDIX C

COSTS OF COMPLIANCE WITH A SNUR (OPTION 1): HAZARD COMMUNICATION, PROTECTION IN THE WORKPLACE, AND RECORDKEEPING REQUIREMENTS

## 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 theEmployer 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

## 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 Usewhich 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 hazard7Data 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.

## 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.

## 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.

## 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.

## 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 theEconomic Analysis of Expedited Significant New Use Rules for 168 Chemical SubstancesandBackground 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.

## 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 thebest 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.

## 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 Appendix B, and may not equal product of *Totals were calculated using unrounded values from Appendix B, and may not equal product of the rounded values 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

## 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 $340Heavy 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 were calculated using unrounded values from Appendix B, and may not equal product of the rounded values 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 setwitha hood (LSS 1997) and are estimated at $68.60 per set with inflation.

## C-11

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.

## C-12

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 (25 workers) Unit Cartridge Unit Cartridge (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 $52,38540 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 (25 workers) Unit Cartridge Unit Cartridge



## 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.

## 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.

## 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 $1.6340CFR

§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 $2.5240CFR

§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.

## 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.

## 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,allmanufacturers, 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).

## 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.

## 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.

## APPENDIX D
COSTS OF TESTING

## 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.

## 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 ofthese 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.

## 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.

## 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 48Guideline 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 1146Guideline 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.

## 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 $1,730,120.1922748 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 60No. 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 60No. 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 8275No. 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 8275No. 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 3201No. 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 328No. 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 60No. 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 179No. 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

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

A SNUR, OR EQUIVALENCY DETERMINATION8In 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.

## APPENDIX F
AGENCY COSTS

## 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.

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

Review Step EPA FTEEPA staff (GS-12) (a) Extra-mural

Cost Unweighted

Cost Pct.

of CasesWeighted

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.

## 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).

## APPENDIX G
REFERENCES

## 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 Substancesand 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 Substancesand 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

.

## 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.