1 **Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act** 
**1. IDENTIFICATION OF THE INFORMATION COLLECTION**  **1(a) Title and Number of the Information Collection**  **Title: Use of Mercury and Mercury Compounds in P**  **roducts and P**  **rocesses EPA ICR No. 2532.01**  **OMB Control No.: 2070**  **- NEW**  **1(b) Short Characterizatio**  **n/Abstract** The U.S. Environmental Protection Agency ’s ( EPA’s ) Office of Chemical Safety and Pollution Prevention is working to further reduce the use of mercury 1 and mercury compounds 2 in products and certain manufacturing processes to prevent future release s of mercury to the environment. A fter negotiating and joining a global agreement called the Minamata Convention on M ercury (Minamata Convention , see Attachment 2 ) , EPA continues to pursue measures to reduce the use of mercury in various media . EPA investigated current information on the use of mercury and mercury

compounds in products and certain manufacturing processes in the United States and found significant data gaps that prevent the Agency from taking systematic, strategic, and effective actions to reduce the use of mercury and mercury compounds in order to prevent pot ential releases to the environment

. To close such data gaps, EPA will collect information from persons who process mercury or mercury

compounds for use in the production of mercury

- added products , 3 import mercury for use in the production of mercury

- added products, import mercury- added products , and/or export mercury- added products

. Inaddition, EPA will request information from persons who process mercury or mercury

compounds for use in certain industrial processes

. EPA is particularl y interested in the amount of mercury or mercury compounds used in mercury

- added products as a whole and among various categories of products , including mercury or mercury compounds that are added during domestic manufacture , 4 as well as contained in imported and exported products. Initiall y, this will be a one

- time information collection request (ICR) , but EPA may request subsequent renewal s, as necessary . EPA first will invite companies that manufacture, import, or export a product (or products) containing mercury or mercury

compounds or companies that use mercury or mercury

compounds in a manufacturing process (or processes) to

1 The term “mercury” means elemental mercury, (Chemical Abstracts Service Registry Number 7439

- 97

- 6). 2 The term “mercury compound” means mercury reacted with another substance (e.g., mercury chloride, mercury oxide, methylmercury). 3 The term “mercury

- added product” means a product or product component that contains mercury or a mercury compound that was intentionally added

. 4 The term “manufacture” means to manufacture or produce for commercial purposes . Unlike other definitions in T S CA regulations (e.g., 40 CFR 711.3), this definition of “manufacture” does not include “import.” 5 EPA. EPA

FDA Advisory on Mercury in Fish and Shellfish. Available at http://www.epa.gov/fish

- tech/epa

- fda

- advisory

mercury - fish

- and

- shellfish

.2

voluntarily submit responses to a questionnaire (see Attachment 4 ) for a period of 60 days after the proposed ICR is approved by the Office of Management and Budget

. Thereafter , EPA will issu e more formal measures under s ection 11 of the T oxic S ubstances C ontrol A ct (TSCA) to obtain the information

. For all information received after the IC R is in place, the Agency anticipates some form of follow

- up with respondents (e .g., emails or telephone calls) to clarify information received from respondents

. Examples of such follow

- up correspondence include, but are not limited to questions regarding reported amounts of mercury or mercury

compounds th at deviate from currently

observed trends, disproportionately large or small volumes reported, or other discrepancies in reported information (e.g., reported volumes in sections of the questionnaire expected to match or be consistent appear to be incorrect per human error). In other instances, EPA anticipates that respondents might reach out to the Agency prior to submitting information for assistance in interpreting questions or in preparation of responses. E PA anticipates that the information collection activity will involve approximately 250 private entities that either manufacture, import, or export mercury

- added products, or use mercury or mercury

compounds in manufacturing processes, although the number of entities may be as high as 646. Respondents will answer set of questions about the amounts of mercury or mercury

compounds the entities use and in which products. The years of interest are 2010, 2013, and 2016. EPA will use the collected information to determine if and what type of actions , including voluntary

and/or mandatory

measures, are needed to reduce the use of mercury or mercury compounds

. The Agency will also use such information to prioritize where and how measures are applied in order to help prevent potential risks of mercury exposure to human health and the environment. Inaddition, this information also will be used to facilitate compliance with obligations of the United States under the Minamata Convention to continue to reduce the use of mercury in products and processes , and to report on actions taken to do so.

**2. NEED**  **FOR AND USE**  **OF THE COLLECTION**  **2(a) Need** **/ Authority for the Collection**  Background Mercury is known to cause adverse health effects on humans and wildlife. Domestically , the most prevalent human and wildlife exposure to mercury results from ingesting fish contaminated with methylmercury , which forms when mercury in the air is deposited to water. Methylmercury

is a highly

toxic substance that affects nervous s ys tems, particularly during an organism’s development. The federal government and all fifty states have issued advisories concerning ingestion of mercury in fish

. 5 In addition to methylmercury , exposure to mercury can al so pose health risks. M ercury primarily causes health effects when it is inhaled as a vapor that can be absorbed through the

5 EPA. EPA

- FDA Advisory on Mercury in Fish and Shellfish. Available at http://www.epa.gov/fish

- tech/epa

- fda

advisory

- mercury - fish

- and

- shellfish

.3

lungs. These exposures can occur when mercury is spilled or products that contain mercury break, resulting in release of mercury to the air, particularl y in warm or poorly

- ventilated indoor spaces. Mercury and mercury compounds are used in the manufacture of mercury- added products and certain manufacturing processes. The typical lifecycle of products includes manufacture, distribution in commerce, use, disposal, or recycling. At any point in the lifecycle, there is potential for mercury

to be released

. 6 Trends ofMercury Use in Products Over the past three decades, the United States has seen a strong downward trend in the domestic use of mercury

in products

. 7 Nonetheless, more than 50 tons of mercury continues to be used or imported every

year in products, many

of which have cost

- effective, non

- mercury substitutes. 8 In 2015, to collect information on domestic mercury suppl y and trade, the Agency collected domestic sales information for the ye ars 2010 and 2013 from five companies identified as the primary

recyclers and distributors of mercury in the United States. 9 Comparing totals for mercury in products sold and the amount of bulk mercury sold in the United States in 2013 revealed a significant gap. EPA believes mercury may be used in manufacturing processes as a reactant or formulation component , including the production of poly urethane elastomers , which may not be reflected in the amount of mercury reported as sold in products

. Inaddition, EPA is interested in finding out the amount of mercury in products manufactured in the United States and sold overseas, which would not be reported in domestic sales. The Agency is committed to continue working to explain such data gaps and to reduce the use of mercury in products and processes , where feasible. Minamata Convention on Mercury and EPA Strategy In 2013, the United S tates joined the Minamata Convention, an international environmental agreement with multiple obligations to governments aimed at reducing the production and use of mercury worldwide . Article s 4 and 5 of the Minamata Convention contain require d actions by all P arties related to mercury- added products and manufacturing processes in which mercury or mercury compounds are used , including , but not limited to :

 Implement measures and strategies to reduce or prohibit the use of mercury in listed products ;  Report to the Conference of P arties to the Convention on the measures or strategies implemented, including a quantification of the reductions achieved ;  Consider additional measures to achieve further reductions of listed products ;

6 EPA. Elemental Mercury Used in Barometers, Manometers, Hygrometers, and Psychrometers; Significant New Use Rule. Federal Register. 77 FR 31728, May 30, 2012 (FRL

- 9345

- 9). 7 EPA. EPA’s Roadmap for Mercury, EPA

- 747R

- 06

- 001, July 2006, and New England Waste Management Officials’ Association (NEWMOA). IMERC Fact Sheet: Mercury Use in Products, p. 1, February 2014

. Available at http://www.newmoa.org/prevention/mercury/imerc/factsheets/all_products_2014.pdf

. 8 NEWMOA. IMERC Fact Sheet: Mercury Use in Products, p. 1, February 2014. 9 EPA. Subpoena and Information Request. March 20, 2015. Available at http://www.epa.gov/mercury/2015

- subpoena

- and

- information

- request
- epa - mercury - recyclers

.4

 Take measures to prevent the listed products from being incorporated into assemble d products ;  Discourage the manufa cture and sale of mercury

‐ added products not covered by any known use of mercury

- added products prior to the date of entry into force of the Convention ;  Take appropriate measures to re strict or prohibit the use of mercury or mercury compounds in manufacturing processes ;  C ollect and maintain information on processes that use mercury or mercury c ompounds and their alternatives ; and
 D iscourage the development of any facility using any other manufacturing process in which mercury

or mercury

compounds are intentionally used that did not exist prior to the date of entry

into force of the Convention

. In order to carry

out its work on mercury

- added products and manufacturing processes , and to facilitate compliance with the U.S. obligations under the Minamata Convention , EPA wrote and published a plan called the “ EPA Strategy to Address Mercury
- Containing Products ” (EPA Strategy ; see Attachment 3 ) 10

. The EPA Strategy is divided into five phases, the first of which is to update EPA’s information on mercury

- added products and manufacturing processes. In later phases, EPA will use the improved information to inform voluntary or regulatory actions , as appropriate, to reduce the unnecessary use of mercury or mercury compounds

. Purpose of the ICR The purpose of this ICR is to enable EPA to obtain the information necessary to achieve its goal to further reduce the use of mercury and mercury

compounds in products and certain manufacturing processes in order to prevent future releases to the environment, as well as assist the United States in its implementation of its obligations under the Minamata Convention. EPA seeks to enhance its current information on how much mercury is used and in which products, and whether those products are manufactured domes tically , imported, or exported. Overview of Existing Information on Mercury

- added Products EPA has investigated federal and state reports and databases, among other sources, in order to accumulate as complete a collection of available information on mercury products as possible. The Agency

found that its current collection lacks the specificity and level of detail that would allow EPA to target its use reduction efforts efficientl y for both the government and private sectors. Internet research resulted in mostly anecdotal information. Proprietary databases and that of the U.S. Census Bureau do no t distinguish between mercury products and non

mercury products. EPA’s Chemical Data Reporting (CDR) rule collects quantity information on chemical substances manufactured or processed in the United States , but not on individual or categories of products c ontaining those substances. Although the CDR rule asks manufacturers and importers for information on end

- uses of their chemical substances, the required information is too general to be useful to implement the mercury- added products strategy . The EPA Toxi c s

10 EPA. EPA Strategy to Address Mercury

- Containing Products. September 2014. Available at http://www.epa.gov/sites/production/files/2015

- 10/documents/productsstrategy.pdf

.5

Release Inventory (TRI) program requires manufacturers and processors to report whether mercury is used in , among other things, manufacturing or processing , as well as whether it is used in an article, but not the amount of mercury o r which articles it is used in. States collect useful information on the amount of mercury in mercury

- added products sold in the United States . Laws in eight states (Connecticut, Louisiana, Maine, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont) require manufacturers and importers to identify the mercury

products they

sell and the volume of mercury in them. The volume informati on is reported at a national level, although only companies se lling mercury products within those eight state s need to report. These data are reported online in the Interstate Mercury Education and Reduction Clearinghouse (IMERC), which is managed b y the N ortheast Waste Management Officials’ Association (NEWMOA). S tates also collect information on mercury in products as part of separate programs. For example, EPA reviewed data reported under Washington ’s Children's Safe Product Act, 11 which requires manufacturers of children ’ s products sold in Washington to report if their product contains a Chemical of High Concern to Children , including mercury

. Most states, however, do not colle ct information about mercury products

. Limitations on Existing Information In the past, the IMERC database has been a key source of national data on mercury used in product s . The database houses information that s tates require the private se ctor to report to them on a triennial basis. The database provides a detailed picture of some aspects of the mercury product market . However , as reported b y IMERC, there are limitations 12 of the use of such data for EPA’s implementation of the Minamata Convention and targeting use reduction . For example :

 The data may

underestimate the amount of mercury sold in products in the United States

. 13 The manufacturers , importers, and distributors in eight “IMERC Notification” states must report on mercury- added products so ld in the United S tates , 14 so the information is national in scale . However, if a mercury product is onl y sold in states other than the IMERC Notification states , then the product manufacturer, importer, or distributor is not required to report to IMERC

. Inaddition, IM ERC no longer collects data on a significant category of mercury

- added product s , specifically switches and relays , because these produc ts are banned from sale in each of the eight IM ERC Notification States

.

11 WASH
. REV
. C ODE § 70.240. 12 NEWMOA. Mercury

- Added Products Database

– C aveats & Limitations. Available at http://www.newmoa.org/prevention/mercury/imerc/Notification/caveats.cfm

. 13 Ibid

. 14 NEWMOA. Mercury - Added Products Database

– About the Database. Available at http://www.newmoa.org/prevention/mercury/imerc/Notification/about.cfm

.6

 In other instances, the data may overestimate the total amount of mercury sold in products

. 15 In some cases, manufacturers supplied data for earlier reporting years , but are out of compliance for one or more ye ars. Rather than assuming that this non

- reporting is a result of a company having phas ed

- out its mercury

- added product, IMERC takes a more conservative approach and assumes that the mercury total for non

- reporters for the current reporting period is the same as its most recently reported ye ar .

 IMERC does not cover mercury compounds manufactured or imported for use in manufacturing processes or mercury

- added products, with the exception of formulated products. And companies report the amount of mercury in products they

sell in the United States , but not the amount in products they manufacture, import, or exp ort
. Such shortcomings also were noted in 2013 b y the Quicksilver Caucus, a coalition of state environmental association leaders dedicated to reducing mercury in the environment. 16 In sum, without the ICR information , EPA’s future ability to anal y ze the use of mercury and mercury

compounds in products and certain manufacturing processes in the United States would need to rel y on incomplete databases, assumptions, professional judgment, and anecdotal information

. Priority Data to be Collected and Statutory Authorities Using the available sources described above , EPA has compiled estimate s of the amount of mercury used by

some manufacturers and importers in some product s . EPA does not need estimates for each individual mercury- added product or manufacturing process, given that some products are almost completely phased out of the U.S. market and others are essential products without adequate substitutes (e.g., replacement components in larger equipment) . However, in order to better implement the Minamata Convention and fulfill its mercury products strategy

to reduce non

- essential mercury uses , the Agen cy need s reliable estimates of :

 The amount of mercury used in : o Batteries o Cosmetics (including skin lightening soaps and creams) o Dental amalgam o Formulated products (e.g., commercial chemical products, including catal ysts, reactants, reagents, preservatives ) o Li ghting, lamps, bulbs (including neon lighting and backlighting displays) o Pesticides, biocides, and topical antiseptics (including paint) o Pumps o Measuring instruments (e.g., barometers, thermometers) o Switches, relays, sensors, valves (including thermostats)

15 NEWMOA. Mercury

- Added Products Database

– Caveats & Limitations. Available at http://www.newmoa.org/prevention/mercury/imerc/Notification/caveats.cfm

. 16 Quicksilver Caucus. Status Report on Select Products, Processes and Technologies Utilizing Mercury. August 2013. Available at https://dec.alaska.gov/eh/docs/mercury/Status%20Report%20by%20Quicksilver.pdf.7 o Miscellaneous mercury

- added products o Products derived from the use of mercury or mercury

compounds in a manufacturing process

 The amount of m ercury and mercury

compounds used in manufacturing processes ; and

 The amount of mercury imported and exported in mercury- added products

. EPA’s authority

for this information collection is TSCA s ection s 2(b)(1) and 11(c) (see Attachment 1)

. More detail on information the Agency intends to collect is described in S ection 4(b) of this supporting statement. **2(b) Practical Utility** **/ Users of the Data**  EPA will use the collected information to fill gaps in existing data , enabling the Agency to more accuratel y estimate the amount of mercury used in manufactured, imported, and exported products in priority produ ct categories . The Agency will use the results to decide whether actions are necessary to reduce specific mercury uses and to plan voluntary and regulatory

action to achieve its goal to further reduce mercury use in products and certain processes in order to prevent future releases to the environment

. 17 The information will also assist the United States in its sustained implementation of its obligation s under the Minamata Convention. 18 For example, the Agency intends to use the results to determine whether and how much the United S tates continues to manufacture products that are not essential ( i.e. , those that have already been successfully pha sed out in some states and/or readily can be replaced b y non mercury substitutes )

. Similarly, EPA is interested in determining whether certain mercury

- added products are manufactured solel y for replacement parts or for uses for civil protection and military purposes, as well as research, calibration of instrumentation, or reference standards. The Agency believes that the totality

of such information will not only lead to a more complete understanding of if and how mercury

is currently

used in mercury

- added products and manufacturing processes, but also the degree to which such uses may be considered essential. Based on such anal ys is, EPA would be able to opt f

or voluntary

or regulatory

options best suited for a particular product or category of products, as well as the companies that manufacture, sell, or use such products.

17 EPA. EPA Strategy to Address Mercury

- Containing Products. Septe mb er 2014. Available at http://www.epa.gov/sites/production/files/2015

- 10/documents/productsstrategy.pdf

. 18 Ibid

.8

**3. NON**  **- DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION**  **CRITERIA 3(a)**  **Non -** **Duplication** To the best of EPA’s knowledge, the data to be collected through this questionnaire are not publically available. As described in S ection 2( a) , EPA has devoted significant resources to investigate available data on mercury use, including federal and s tate reports and databases

. **3(b) Public Notice Required Prior to ICR Submission to OMB**  Prior to submission to OMB, this I CR will be made available to the public for comment through a Federal Register notice. The public will have 60 days to provide comments. Any comments received will be given consideration when completing the supporting statement that is submitted to OMB. **3(c) Consultations**  Under 5 CFR 1320.8(d)(1) OMB requires agencies to consult with potential I CR respondents and data users about specific aspects of ICRs before submitting an original or renewal ICR to OMB for review and approval. In accordance with this regulation, EPA will pursue additional consultations with interested parties during the development of the renewal o f this collection. **3(d) Effects of Less Frequent Collection**  Initiall y, this will be a one

- time information collection

. EPA may collect the information in multiple years if it should prove necessary and would renew this ICR accordingl y . **3(e) General**  **Guidelines** This IC R complies with the guidelines in 5 CFR 1320.5(d)(2)

. **3(f) Confidentiality**  The questionnaire will contain information for respondents on how to make a claim to EPA that all or part of their information is Confidential Business Information. **3(g) Sensitive Questions**  Not applicable. The information requested is not sensitive in nature.9

**4. THE RESPONDENTS AND THE INFORMATION REQUESTED**  Based on the described investigation of available data, EPA determined that the best way to acquire the needed information is to collect it directly from the entities that use mercury or mercury compounds to manufacture mercury

- added products or in manufacturing processes, or that import or export mercury

- added products. The existing databases were useful in helping to identify product categories, individual products, and NAICS codes to include in the information collection to ensure that the scope is sufficient without being overly broad. **4(a) Respondents and**  **North American Industrial Classification System (** **NAICS )**  **Codes** Respondents affected b y this collection activity primarily include those businesses that fall under the NAI CS Codes in the table below.

**Primary NAICS Codes**  **and Definitions Code**  **Definition**

**Primary Product Manufacturing Industries**  314110 Carpet and rug mills 322121 Paper (except newsprint) mills 322130 Paperboard mills 324122 Asphalt shingle and coating materials m anufacturing 325180 Other basic inorganic chemical manufacturing 325199 All other basic organic chemical manufacturing 325211 Plastics material and resin manufacturing 325312 Phosphatic fertilizer manufacturing 325320 Pesticide and other agricultural chemical manufacturing 325411 Medicinal and botanical manufacturing 325412 Pharmaceutical preparation manufacturing 325413 In

- vitro diagnostic substance manufacturing 325414 Biological product (except diagnostic) manufacturing 325510 Paint and coating manufacturing 325520 Adhesive manufacturing 325991 Custom compounding of purchased resins 325992 Photographic film, paper, plate, and chemical manufacturing 325998 All other miscellaneous chemical product and preparation manufacturing 326113 Unlaminated plastics film and sheet (except packaging) manufacturing 326150 Urethane and other foam product (except pol ys ty rene) manufacturing 326199 All other plastics product manufacturing 326299 All other rubber product manufacturing10

327215 Glass product manufacturing made of purchased g lass 332911 Industrial valve m anufacturing 332993 Ammunition except small arms m anufacturing 332994 Small arms, ordnance, and ordnance accessories m anufacturing 334413 Semiconductor and related device manufacturing 334419 Other electronic component manufacturing 334511 Search, detection, navigation, guidance, aeronautical, and nautical system and instrument manufacturing 334512 Automatic environmental control manufacturing for residential, commercial, and appliance use 334513 Instruments and related products manufacturing for measuring, displaying, and controlling industrial process variables 334515 Instrument manufacturing for measuring and testing electricity and electrical s ignals 334516 Analy

tical l abo ratory

instrument m anufacturing 334519 Other measuring and controlling device manufacturing 335110 Electric lamp bulb and part manufacturing 335122 Commercial, industrial, and institutional electric lighting fixture manufacturing 335314 Relay

and industrial control manufacturing 335912 Primary

battery manufacturing 335931 Current

- c arrying wiring device m anufacturing 335999 All other miscellaneous electrical equipment and component manufacturing 336413 Other aircraft parts and auxiliary equipment manufacturing 336612 Boat building 339914 Costume jewelry and novelty

manufacturing 339950 Sign manufacturing 541712 Research and development in the physical, engineering, and life sciences (except b iotechnology) 928110 National security

**Secondary Product Manufacturing Industries** 333294 Food product machinery manufacturing 333313 Office machinery m anufacturing 333319 Other commercial and service industry machinery m anufacturing 333414 Heating equipment (except warm air furnaces) manufacturing 333415 Air

- conditioning and warm air heating equipment and commercial and industrial refrigeration equipment m anufacturing 334412 Bare printed circuit board m anufacturing11

334413 Semiconductor and related device m anufacturing 334510 Electromedical and e le ctrotherapeutic apparatus m anufacturing 334514 Totalizing fluid meter and counting device m anufacturing 334515 Instrument manufacturing for measuring and testing electricity and electrical s ignals 334518 Watch, clock, and part m anufacturing 334519 Other measuring and controlling device m anufacturing 335129 Other lighting equipment m anufacturing 335211 Electric house wares and household fan manufacturing 335212 Household vacuum cleaner manufacturing 335221 Household cooking appliance m anufacturing 335222 Household refrigerator and home freezer manufacturing 335224 Household laundry equipment m anufacturing 335228 Other major household appliance m anufacturing 335313 Switchgear and switchboard apparatus m anufacturing 336112 Li ght truck and utility vehicle m anufacturing 336120 Heavy duty truck m anufacturing 336213 Motor home m anufacturing 336214 Travel trailer and camper m anufacturing 339112 Surgical and medical instrument m anufacturing 339932 Game, to y, and children’s vehicle m anufacturing 424690 Other chemical and allied products merchant wholesalers **4(b) Information Requested**  **(i) Data**  **items** The questionnaire “Collection of Information on Use of Mercury and Mercury Compounds in Products and Processes ” is Attachment 4

. Generally , the questionnaire seeks to collect information on whether a company manufactures, imports, or exports products containing mercury or mercury

compounds, or uses mercury or mercury

compounds in a manufacturing process . For ease of responding, the questionnaire is divided into three primary sections requiring varying degrees of detail. However, the sections are divided such that a respondent may not be required to proceed past the first section or may not need to answer all of the questions in the two subsequent sections. Where feasible, questions are posed to provide boxes to check off instead of written responses and so that respondents are able to skip further questions within a section or skip sections altogether. Section 1. The first section poses two “yes/no” question s for the years 2010, 2013, and/or 2016 : “Did your company manufacture, import, or export products containing mercury or mercury compounds ; ” and “ Did your company use mercury

or mercury

compounds in a12

manufacturing process ? ” Th ese inquiries serve as the threshold certification s that a company currentl y manufactures, imports, or exports products with mercury or uses mercury or mercury compounds in a manufacturing process of interest to EPA

. Respondents answering “yes” to one of the questions would proceed to the second section. Two “no” answer s would complete the questionnaire

. However, the Agency will also ask respondents providing two “no” answers, if possible, to report the calendar year when the ir use of mercury

or mercury

compounds ceased. Section 2. The second section will present a table of eleven product and process categories. Respondents are onl y required to mark a box or boxes for general categories corresponding to products or pro cesses for which a respondent’s company manufactured, imported, or exported a product or products in the years 2010, 2013, and/or 2016

. If a respondent cannot identify

a product or process among the general categories, he/she is instructed to check a miscellaneous category . The respondent is then directed to specific subsections of Section 3 p er marked general category . This inquiry serves to determine the kinds of products particular companies manufactured, imported, or exported . Based on experience with the domestic mercury market, the Agency

believes that a respondent will likely onl y check one general category

. In addition, this section provides respondents with check boxes that correspond to exclusions from reporting under the Minamata Convention where a product or process: (1) is essential for civil protection or military

uses; (2) is only used for research, calibration of instruments, as a reference standard, or as a vaccine; or (3) contains only trace contaminants of mercury

. Section 3. The third section poses questions to elicit information for each category a respondent checked in Section 2.There are approx imately five multi

-part questions per category , which are designed to be nearl y identical . H owever, they are structured so that subsequent parts of a question or an entire question could be skipped. For each category , the questions are limited to the years 2010, 2013, and/or 2016 and the respondents are allowed to use either metric or U.S. customary

units. There is also a space allowed for respondents to provide additional comments should they

so choose. The five multi

-part questions include: 1. A sking if a respondent’s company manufactured a product that contained mercury or mercury compounds. If the respondent answers “no,” then he/she skips to the fourth question. If the respondent answers “yes , ” then he/she is asked to report the total amount of mercury

or mercury

compounds per product A list of specific varieties of products or processes, as well as an “other” option is presented to assist respondents. 2. A sking if a respondent’s company purchases in the United States mercury or mercury compounds to be used in the production a product. If the respondent answers “no, ” then he/she skips to the fourth question. If the respondent answers “yes , ” then he/she is asked to report the total amount of mercury or mercury

compounds purchased in the United States

. This question does not ask for amounts reported to be broken out among specific vari eties of products or processes. 3. A sking if a respondent’s company imported mercury or mercury compounds to be used in the production of a specific product

. If the respondent answers “no,” then he/she skips to the fourth question. If the respondent answers “yes , ” then he/she is asked to report the total amount of mercury

or mercury

compounds imported

.13

4. A sking if a respondent’s company imported a product containing mercury or mercury compounds . If the respondent answers “no,” then he/she skips to the fifth question. If the respondent answers “yes , ” then he/she is asked to report the total amount of mercury or mercury compounds per product. A list of specific varieties of products or processes, as well as an “other” option is p resented to assist respondents. 5. A sking if a respondent’s company exported a product containing mercury or mercury compounds . If the respondent answers “no,” then he/she may choose to prov ide any additional comments and then skips to the next category for which the respondent checked in Section 2 . If the respondent answers “yes , ” then he/she is asked to report the amount of mercury

or mercury

compounds per product. A list of specific varieties of products or processes, as well as an “other” option is presented to assist respondents. Certain subsections will contain additional questions that correspond to provisions of the Minamata Convention, such as whether a specific product exceeds mercury or mercury compound content limits

. These types of questions are posed as “yes/no” question s . Such inquiries are intended to inform more specific reporting requirements and, in some cases, exemptions from reporting obligations under the Minamata Convention. EPA welcomes public comment on how to enhance the quality , utility , and clarity of the information to be collected. In particular, EPA seeks comment on these aspects of the questionnaire: 1. Are there additional products or product categories that should be included in the questionnaire? 2. Are there additional products or product categories that should be eliminated from the questionnaire ? 3. Should the questionnaire ask respondents to identify which products are intended solel y as replacement parts ? **(i) Respondent Activities**  Individuals who are contacted to participate in this information collection activity could potentially

perform each of the following tasks:

 Read the F ederal Register notice or information collection letter ;  Read the questionnaire and in structions ;  Gather, organize, and compile records ;  Respond to questions ; and
 Email or mail the completed questionnaire to EPA.14

**4. THE INFORMATION COLLECTED**  **- AGENCY ACTIVITIES, COLLECTION**  **METHODOLOGY, AND INFORMATION MANAGEMENT 5(a)**  **Agency Activities** The Agency

will conduct the following activities to complete the information collection :

 Request responses to the questionnaire via second Federal Register n otice , to be provided by respondents after the ICR is approved ;  Send letters/ formal measures to non - respondents ;  Follow up with non

- responders , as needed;
 Review data;  Follow up with respondents , if clarifications are needed ; and
 Report findings. **5(b) Collection Methodology and Management**  The Agency

will initially

publish and request comment on the efficacy of the questionnaire in the first Federal Register notice for the proposed ICR. After revisions, as appropriate, EPA in the second Federal Register notice for the proposed ICR will invit e appropriate members of the general public to voluntarily provide information as set forth in a questionnaire for a period of 60 days after the proposed ICR is approved. Thereafter, EPA will issue subpoenas containing the same questionnaire under TSCA section 11 to obtain the information. For all information received after the ICR is in place, the Agency anticipates that some form of follow

-up with respondents (e.g., emails or telephone calls), to clarify information received from respondents or to assist respondent in the preparation of responses. EPA will then compile the responses to produce an understanding of mercury use across product categories, a list of individual products containing the most mercury, and other tools to help the Agency

identify the best opportunities for use reduction and to construct reports to the Conference of Parties of the Minamata Convention

. **5(c) Small Entity Flexibility**  The majority

of respondents will be small entities. The instrument has been developed to minimize the burden on all respondents while obtaining sufficient and accurate information. **5(d) Collection Schedule**  Exhibit 5.1 provides the schedule of the various tasks involved in conducting the proposed information collection activity . As shown in the schedule, data collection would start within one week of OMB approval of the IC R and would end 14 weeks later.15 **Exhibit 5.1: Information**  **Collection Schedule Task**  **Week (from receipt of OMB approval)**  **1 2**  **3 4**  **5 6**  **7 8**  **9 10**  **11 12**  **13 14**  Send subpoenas to respondents requiring completion of the questionnaire 30 days (4 weeks) for respondents to respond Preliminary d ata review Follow u p with non

responders as needed Follow up with respondents if clarifications are needed Compile responses

**6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION**  This section presents the burden and cost estimates incurred b y all potentially affected entities as a result of the data collection. All costs are presented in 2014 dollars. The proposed information collection requires reporting at the company level. EPA estimates that up to 646 companies in the United States manufacture, import, or export mercury

- added products, or use mercury or mercury

compounds in manufacturing processes. The following burden and cost estimate is based on this number; however, the Agency initially intends to narrow the scope of this ICR to up to 250 facilities. While the EPA expects to require information from approximately

250 entities, the Agency may need to request submi ssion s from as many as 646 respondents

. While the EPA expects to require information from approximately 250 entities, it may need to request submittals from as many as 646. The requested burden for this collection represents th e burden associated with the maximum number of respondents, i.e., 646

. All respondents will respond to Section 1 of this information collection; in addition, companies that use mercury

or mercury

compounds for the purposes described in Section 1 will respond to one or more categories in Section 2 and sets of questions in Sections 3 responding to one or more sections of the questionnaire. Respondents are comprised of firms that are currently required under state law to report data to IMERC and firms that are not required to do so. EPA believes that firms that have reported data to IMERC will have a reduced burden compared with firms that have not submitted IMERC data, because they keep, manage, and report data on their products that contain mercury

.16

**6(a) Estimating Respondent Burden**  This section details the estimated burden to respondents participating in this ICR. For purposes of the ICR, a company that processes mercury

or mercury

compounds for use in the production of mercury

- added product s , imports mercury for use in the production of mercury

added products, imports mercury

- added products, exp orts mercury
- added products, and/or processes mercury

or mercury

compounds for use in certain industrial processes is equivalent to one respondent. The questionnaire contains 1 3 separate sections; Section 1 contains company information and yes/no screening questions which determine whether the company should complete the rest of the questionnaire, Section 2 contains check boxes to indicate the types of products manufactured, imported, or exported by the company , and Sections 3 through 1 3 ask specific questi ons about each product ty pe. **Unit Burden Estimates** Section 1 Section 1 of the form asks the respondent for basic company information as well as initial questions to indicate if a company manufactured, imported, or exported any products containing mercury or if mercury

was used in a manufacturing process in the ye ars 2010, 2013, and/or 2016. Company Information The first part of Section 1 requires the respondent to provide their company name, address, the name(s) and title(s) of the responding and certifying official(s), and the contact information for the certifyingofficial. EPA assumes providing this information will take approximately

6 minutes, based on data in the 2011 Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule

. 19 EPA expects this burden to be identical regardless of a particular respondent’s experience with IMERC reporting.

**Table 1**  **: Hourly Unit Burden for**  **Providing Company and Contact Inform ation**  **Question s**  **Unit Burden (Hours)**

**Clerical Technical**  **Managerial Total**  **Responders that Have not Submitted Data to IMERC Company Inform**  **ation** 0.04 0.04 0.02 **0.10 IMERC Data**  **Submitters Company Inform**  **ation** 0.04 0.04 0.02 **0.10 Source(s):**  U

. S

. Environmental Protection Agency, Office of Pollution Prevention and Toxics. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule . June 30, 2011

. Burden for submitters provide company and technical contact information. Questions 1(a) and 1(b)

19 EPA

. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule . June 30, 2011.17

The second part of Section 1 asks respondents to indicate whether they manufactured, imported, or exported any products containing mercury or whether mercury

was used in a manufacturing process in the years 2010, 2013, and/or 2016. EPA estimated the burden for reviewing their records to determine this information is 2.5 hours.

**Table 2**  **: Hourly Unit Burden for Determ** **ining Whether the Respondent Manufactures, Imports, or Exports Products Containing Mercury or u**  **ses**

**Mercury in a Manufacturing Process Question**  **s Unit Burden (Hours)** 

**Clerical Technical**  **Managerial Total**  **Responders that Have not Submitted Data to IMERC 1**  **(a) and 1(b)** 0.00 2.50 0.00 **2.50 IMERC Data**  **Submitters 1**  **(a) and 1(b)** 0.00 2.50 0.00 **2.50 Source(s):**  U

. S

. Environmental Protection Agency, Office of Pollution Prevention and Toxics. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule . June 30, 2011

. Burden for compliance determination

. Total Industry Unit Burden Estimates for Section 1 Table 3 presents the total unit burden estimates for all submitters to complete S ection 1 of the document. To calculate the total burden, the estimates derived above are weighted b y the percentage of respondents completing a given section, that are expected to respond to a given question and the number of responses per respondent, in this case all respondents completing Se ction 1 are expected to respond to all questions in Section 1, with one response per respondent.
**Table 3**  **: To**  **tal Burden to Complete Section One for**  **All Submitters**
**Question Total per Unit**  **Burden (Hours)**  **Percentage of**

**Respondents who Complete the Section**  **that Respond to the Question**  **Responses per**  **Respondent Total** 

**Burden (Hours)**  **Company Inform ation**  0.10 100% 1 **0.10 1**  **(a) and 1(b)** 2.50 100% 1 **2.50 Total**  **2.60** Section 2 Section 2 of the form requires respondents to indicate the mercury added

-product(s) they manufacture, import, or export and whether their products are used within certain end use categories, such as military products or onl y for research and development purposes. EPA believes that the burden to check the box indic ating the product category is negligible, and the burden to indicate certain end use categories is approximately 1.23 hours per respondent for firms that have not submitted IMERC data and 0.98 hours per respondent for IMERC data submitters, based on the burden to indicate consumer/commercial product categories in IUR18

reporting. 20 See Table 4. EPA believes that 100 percent of respondents will complete this section.
**Table 4**  **: Hourly Unit Burden for Indicating Certain End Uses** 

**Question s**  **Unit Burden (Hours) Clerical**  **Technical Managerial**  **Total Responders that Have not Submitted Data to IMERC**  **Inform ation on Certain Uses**  0.14 0.84 0.25 **1.23 IMERC**  **Data Submitters**  **Inform ation on Certain Uses**  0.12 0. 75 0 .20 **0.98 Source(s):**  US Environmental Protection Agency, Office of Pollution Prevention and Toxics. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule. June 30, 2011

. Burden for submitters provide commercial and consumer end use categories. Sec tions 3 to 1 3 Sections 3 to 1 3 of the form ask for information on the use of mercury and mercury compounds in specific end products. The sections below present the burden estimates for each question in these sections. Questions 1, 2, 3, 4, and 5. Questions 1, 2, 3, 4, and 5 are yes/no questions that require the respondent to indicate whether the company manufactured, imported, or exported a product containing elemental mercury or mercury

compounds, or whether the company purchased or imported elemental mercury or mercury

compounds to manufacture a product, in 2010, 2013, or 2016. EPA assumed the burden for responding to these questions to be negligible, as it is likely the submitter would have reviewed this information when responding to questions 1 .a. and 1.b. in Section 1 of the questionnaire. Questions 1(a), 2(a), 3(a), and 5(a). Questions 1(a), 2(a), 3(a), and 5(a) require the respondent to provide the total amount of mercury or mercury

compounds manufactured in products manufactured or export ed by the company or the amount of elemental mercury or mercury compounds domestically purchased or imported by

the company

to be used to products. EPA estimates that the burden associated with each one of these questions is similar to reporting product vo lumes on the paper Inventory Update Rule (IUR) form and is 1.51 hours for firms that have not submitted IMERC data and 1.21 hour for IMERC data submitters. 21

20 EPA

. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule . June 30, 2011

. 21 Ibid.19 **Table 5**  **: Hourly Unit Burden for Questions**  **1 (a), 2(a), 3(a), and 5(a)**  **Question s**  **Unit Burden (Hours)**

**Clerical Technical**  **Managerial Total**  **Responders that Have not Submitted Data to IMERC 1**  **(a), 2(a), 3(a), and 5(a)** 0.23 1.03 0.25 **1.51 IMERC Data**  **Submitters 1**  **(a), 2(a), 3(a), and 5(a)** 0.19 0.82 0.20 **1.21 Source(s):**  U

. S

. Environmental Protection Agency, Office of Pollution Prevention and Toxics. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule. June 30, 2011

. Burden for submitters to report production volumes, EPA assumes that Non

- IMEC submitters have the same burden as a firm that reports CDR data for the first time and IMERC data submitters have the burden of a recurring CDR submitter

. Question 4(a) Question 4(a) requires the respondent to indicate the total amount of mercury or mercury compounds in manufactured products imported b y the respondent. EPA believes that identifying the amount of mercury

in imported products may be more burdensome that in domestically manufactured products or exports. Therefore, EPA uses the burden estimate for importers to collect information on the chemicals contained in imported articles from their suppliers as presented in the white paper Understanding the Costs Associated with Eliminating Exemptions for Articles in SNURs. 22 The white paper estimates that this task will take between 0.08 and 8 hours, therefore, for the purposes of this ICR, EPA used the midpoint estimate of 4.04 hours. For IMERC data submitters EPA used the 20% burden reduction estimates for the IUR form 23 and estimated a unit burden of 3.23 hours

. **Table 6**  **: Hourly Unit Burden for Question 4**  **(a) Question**  **Unit Burden (Hours)**

**Clerical Technical**  **Managerial Total**  **Responders that Have not Submitted Data to IMERC**  **4(a)** 0.00 4.04 0.00 **4.04**

**IMERC Data Submitters**  **4(a)** 0.00 3.23 0.00 **3.23 Source(s):**  Based on the average burden to collect information from suppliers on the chemicals in imported products in Understanding the Costs Associated with Eliminating Exemptions for Articles in SNURs

. IMERC data submitters are assumed to have a 20% burden reduction based on the IUR EA, burden savings estimates for repeat submitters. Questions 1(b) and 5(b) [Sections 3 and 4 Only ]. Questions 1(b) and 5(b) are only found in Section 3 of the form , which requires the respondent to indicate whether the company has manufactured or exported cosmetics with a mercury concentration greater than 1 ppm or batteries with mercury content of 2% or greater
. EPA estimates this burden to be similar to reporting chemical concentrations in a consumer or

22 EPA. Understanding the Costs Associated with Eliminating Exemptions for Articles in SNURs . November 20, 2014

. 23 EPA. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule . June 30, 2011.20

commercial product under the paper IUR form; 1.46 hours for IMERC data submitters and 1.81 hours for firms that have not submitted IMERC data. 24
**Table 7**  **: Hourly Unit Burden for Questions 1(b) and 5(b)**  **Question s**  **Unit Burden (Hours)**

**Clerical Technical**  **Managerial Total**  **Responders that Have not Submitted Data to IMERC 1(b) and 5(b)**  0.11 1.36 0.34 **1.81**

**IMERC Data Submitters**  **1(b) and 5(b)**  0.09 1.09 0.28 **1.46 Source(s):**  US Environmental Protection Agency, Office of Pollution Prevention and Toxics. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule. June 30, 2011

. Burden for submitters to report chemical concentrations in a consumer or commercial product, EPA assumes that Non

- IMEC submitters have the same burden as a firm that reports CDR data for the first time and IMERC data submitters have the burden of a recurring CDR submitter

. Question 4(b) [Sections 3 and 4 Only ]. Similar to question 4(a), EPA believes that importers may have a larger burden than domestic manufacturers or exporters, when reporting whether they imported any

cosmetics with a mercury concentration greater than 1 ppm or batteries with mercury content of 2% or greater
. EPA estimates the burden to respond to this question to be half of the burden for question 4(a), or 2.02 hours for firms that have not submitted IMERC data and 1 .62 hours for IMERC data submitters.
**Table 8**  **: Hourly Unit Burden for Questions 4(b)** 

**Question Unit Burden (Hours)** 

**Clerical Technical**  **Managerial Total**  **Responders that Have not Submitted Data to IMERC 4(b)**  0.00 2.02 0.00 **2.02**

**IMERC Data Submitters**  **4(b)** 0.00 1.62 0.00 **1.62 Source(s):**  Assumed to be half of the burden to collect information from suppliers on the chemicals in imported products from the Article Importation white paper, as submitters will already be looking at this information for the question above. IMERC data submitters are assumed to have a 20% burden reduction based on the IUR EA, burden savings estimates for repeat submitters

. Questions 1(c), 4(c) and 5(c) [Sections 3 and 4 Only ]. Questions 1(c), 4(c), and 5(c) require submitters to provide the percentage of the total number of cosmetics with greater than 1 ppm of mercury content or lower or batteries with mercury content of 2% or greater that they manufactured, imported, or exporte d. EPA believes submitters will calculate this total using information gathered to answer previously answered on the form, and therefore assumes this burden to be similar to calculating the volume of a chemical that is recycled or disposed of off

- site on the TRI F orm R, as this information is calculated using

24 EPA

. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule . June 30, 2011

.21

other information supplied on Form R (EPA, 2011b). 25 EPA estimates the time to calculate these numbers to be 5 minutes of technical time and approximately 3.5 minutes of managerial review time per field (EPA, 2011b). 26 For this ICR EPA multiplied these totals by three, to account for the three ye ars’ worth of data, for a total burden of 0.44 hours for firms that have not submitted IMERC data. EPA assumes that IMERC data submitters will have a 20% burden reduction based on the IUR EA (EPA, 2011a) 27 and a burden of 0.35 hours per question.

**Table 9**  **: Unit Per Question Burden for Questions**  **1(c), 4(c) and 5(c) Question**  **s Unit Burden (Hours)** 

**Clerical Technical**  **Managerial Total**  **Responders that Have not Submitted Data to IMERC**  **1(c), 4(c) and 5(c)** 0.19 0.25 0.00 **0.44 IMERC Data**  **Submitters 1(c), 4(c) and 5(c)**  0.15 0.20 0.00 **0.35 Source(s):**  Based on TRI (EPA, 2011b) burden estimate for calculating the volume of a chemical that is recycled or disposed of off

- site. This is assumed to be 5 minutes of technical time to calculate a single value based other data in the form, plus managerial review time. The five minute total is multiplied by 3 for 3 years of data. IMERC data submitters are assumed to have a 20% burden reduction based on the IUR EA, burden savings estimates for repeat submitters. Question 6. Question 6 is an optional open ended question asking for additional comments, therefore this question has no burden by convention. 28
**Table 10**  **: Unit Per Question Burden for Question 6**  **Question Unit Burden (Hours)** 

**Clerical Technical**  **Managerial Total**  **Responders that Have not Submitted Data to IMERC**  **6** 0.00 0.00 0.00 **0.00**

**IMERC Data Submitters**  **6** 0.00 0.00 0.00 **0.00 Source**  **(s) :**  EPA, 2011b Total Industry

Unit Burden Estimates for Sections 3 to 13 Table 11 presents the burden estimates for non

- IM ERC data submitting firms to complete one product specific section. Table 12 presents the burden estimates for IM ERC data submitting firms to complete one product specifi c section . To calculate the burden, the estimates derived in Tables 11 and 12 are weighted b y the percentage of respondents completing a given section that are expected to respond to a given question and the number of responses per respondent. EPA estimate d the number of respondents who domestically manufacture products (85%), import

25 EPA

. Revising the TRI Burden to Ration Based Methodology. Information Collection Request Renewal (ICR) 2nd FR Notice . April 28, 2011

. 26 Ibid. 27 EPA. Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule . June 30, 2011. 28 EPA. Revising the TRI Burden to Ration Based Methodology. Information Collection Request Renewal (ICR) 2nd FR Notice . April 28, 2011

.22

products (21%), and export products (28%) b y assuming the proportions are similar to the proportions reported b y the U.S. Census Bureau data on the number of importing and expo rting manufacturing and wholesale firms. 29 EPA estimated the number of manufacturer s domesticall y purchasing mercury

(59% of all companies) or importing mercury (26% of all companies) b y multiplying the number of domestic manufacturer s with the percentage o f mercury imported or domestically

manufactured from EPA’s CDR database. The estimated number of product ty pes per respondent (1.77) and the number of respondents answering the de minim is value questions in Sections 3 and 4 is based on data samples from th e IMERC database

. 30

29 U.S. Census, Profile of US Importing and Exporting Companies: 2012

- 2013 . Released April 7, 2015. 30 IMERC, Mercury Added Produ cts Database . Modified December 19, 2014.23 **Table 11**  **: To**  **tal Burden to Com plete One Product Specific Section (Sections 3** 

**– 13) for**  **Responders that Have not Submitted Data to IMERC Question**  **Burden for 100%**  **of Section Percentage of Respondents who** 

**Complete the Section that**  **Respond to the Question Responses**  **per Respondent**  **Total**

**Burden** 1. Did your company manufacture [product] that contain mercury or mercury compounds in 2010, 2013 or 2016? 0.00 100% 1 **0.00** 1.a. If yes, then provide the total amount of mercury or mercury compounds in each of the following types of [product] per year(s) 1.51 85% 1 1.77 2 **2.28** 1.b. Did your company manufacture any [product] with mo re than a de minimis level of mercury content? 1.81 85% 1 1 **1.54** 1.c. If yes, then provide the approximate number (or percentage) of the number provided for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 0.44 10% 3 1 **0.04** 2. Did your company purchase in the United States elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016? 0.00 100% 1 **0.00** 2.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company purchased in the United States for use in the manufacture of [p roduct] in each of the following years: 2010, 2013, 2016 1.51 59% 4 1.77 2 **1.57** 3. Did your company import elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016? 0.00 100% 1 **0.00** 3.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company im ported for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016 1.51 26% 5 1.77 2 **0.70** 4. Did your company import [product] containing elemental mercury or mercury compounds in 2010, 2013, or 2016? 0.00 100% 1 **0.00** 4.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed types of [product] per year(s) 4.04 21% 6 1.77 2 **1.50** 4.b. Did your com

pany import any [product] more than a de minimis level of mercury content? 2.02 21% 6 1 **0.42** 4.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 0.44 2.5% 7 1.00 **0.01** 5. Did your company export [product] containing mercury or mercury compounds in 2010, 2013, or 2016? 0.00 100% 1 **0.00** 5.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed ty pes of [product] per year(s) 1.51 28% 8 1.77 2 **0.75** 5.b. Did your company export any [product] with mo re than a de minimis level of mercury content? 1.81 28% 8 1 **0.51** 5.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 0.44 3.4% 9 1 **0.01** 6. Additional comments question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 0.00

- **- 0.00** 24 **Table 11**  **: To**  **tal Burden to Com plete One Product Specific Section (Sections 3** 

**– 13) for**  **Responders that Have not Submitted Data to IMERC Question**  **Burden for 100%**  **of Section Percentage of Respondents who** 

**Complete the Section that**  **Respond to the Question Responses**  **per Respondent**  **Total**

**Burden Total for Section 3**  **and 4 (Batteries**  **and Cosmetics -**  **- -**  **9.35 Total for Sections 5**  **- 13 (All Other Products; Excluded Questions 1.b, 1.c, 4.b, 4.c, 5.b, and 5.c)**  **- -**  **- 6.81**  **Notes:** Totals may not sum due to rounding 1 Estimated percentage (85%) of manufacturing and wholesale firms, that domestically manufacture or purchase products based on U

. S

. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012

- 2013 . Released April 7, 2015 ). 2 Each firm makes an average of 1.77 types of each product based on a sample of 30 IMERC firms 3 The percentage of firms that domestically manufacture products (85%) times the times the percentage of firms that have a product above a de minimis level (12% based on ( IMERC, Mercury Added Products Database . Modified December 19, 2014 )) = 10%. 4 The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compou nds that are domestically manufactured (69% (EPA

. 2012 Chemical Data Reporting (CDR) Database . Updated April 3, 2014 ) ) = 59%. 5 The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compou nds that are imported (31% (EPA

. 2012 Chemical Data Reporting (CDR) Database . Updated April 3, 2014 ) ) = 26%. 6 Estimated percentag e (21%) of manufacturing and wholesale firms, that import products based on U

. S

. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012

-2013 . Released April 7, 2015 ). 7 The percentage of firms that import products (21%) times the times the percentage of firms that have a product above a de minimis level (12% ( IMERC, Mercury Added Products Database . Modified December 19, 2014 )) = 2.5 %. 8 The percentage of firms that export products (2 8 % ) based on U

. S

. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012

- 2013 . Released April 7, 2015 ). 9 The percentage of firms that export products (2 8 %) times the times the percentage of firms that have a product above a de minimis level (12% ( IMERC, Mercury Added Produc ts Database . Modified December 19, 2014 )) = 3.4 %.25 **Table 12**  **: To**  **tal Hourly Burden to Com plete One Product Specific Section (Sections 3** 

**– 13) for**  **IMERC Data Subm** **itters**

**Question Total per**  **Question Burden**  **Percentage of Respondents**

**who Complete the Section that Respond to the Question**  **Responses per Respondent**  **Total**

**Burden** 1. Did your company manufacture [product] that contain mercury or mercury compounds in 2010, 2013 or 2016? 0.00 100% 1 **0.00** 1.a. If yes, then provide the total amount of mercury or mercury compounds in each of the following types of [product] per year(s) 1.21 85% 1 1.77 2 **1.82** 1.b. Did your company manufacture any [product] with mer cury content of 2% or greater ? 1.46 85% 1 1 **1.24** 1.c. If yes, then provide the approximate number (or percentage) of the number provided for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 0.35 10% 3 1 **0.04** 2. Did your company purchase in the United States elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016? 0.00 100% 1 **0.00** 2.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company purchased in the United States for use in the manufacture of [p roduct] in each of the following years: 2010, 2013, 2016 1.21 59% 4 1.77 2 **1.26** 3. Did your company import elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016? 0.00 100% 1 **0.00** 3.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company imported for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016 1.21 26% 5 1.77 2 **0.56** 4. Did your company import [product] containing elemental mercury or mercury compounds in 2010, 2013, or 2016? 0.00 100% 1 **0.00** 4.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed ty pes of [product] per year(s) 3.23 21% 6 1.77 **1.20** 4.b . Did your company import any [product] with mercury content of 2% or greater ? 1.62 21% 6 1 **0.34** 4.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 0.35 2.5% 7 1 **0.01** 5. Did your company export [product] containing mercury or mercury compounds in 2010, 2013, or 2016? 1.21 28% 8 1.77 **0.60** 5.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed ty pes of [product] per year(s) 1.46 28% 8 1 **0.41** 5.b. Did your company export any [product] with mercury content of 2% or greater mercury? 0.35 3.4% 9 1 **0.01** 5.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 0.35 2.8% 9 1 **0.01** 6. Additional comments question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 0.00

- **- 0.00** 26 **Table 12**  **: To**  **tal Hourly Burden to Com plete One Product Specific Section (Sections 3** 

**– 13) for**  **IMERC Data Subm** **itters**

**Question Total per**  **Question Burden**  **Percentage of Respondents**

**who Complete the Section that Respond to the Question**  **Responses per Respondent**  **Total**

**Burden Total for Section 3**  **and 4 (Batteries**  **and Cosmetics )**  **- -**  **- 7.**  **49 Total for Sections 5**  **- 13 (All Other Products; Excluded Questions 1.b, 1.c, 4.b, 4.c, 5.b, and 5.c)**  **- -**  **- 5.**  **45 Notes:**  Totals may not sum due to rounding 1 Estimated percentage (85%) of manufacturing and wholesale firms, that domestically manufacture or purchase products based on U

. S

. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012

- 2013 . Released April 7, 2015 ). 2 Each firm makes an average of 1.77 types of each product based on a sample of 30 IMERC firms 3 The percentage of firms that domestically manufacture products (85%) times the times the percentage of firms that have a product above a de minimis level (12% based on ( IMERC, Mercury Added Products Database . Modified December 19, 2014 )) = 10 %. 4 The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compou nds that are domestically manufactured (69% ( EP A. 2012 Chemical Data Reporting (CDR) Database . Updated April 3, 2014 ) ) = 59%. 5 The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compou nds that are imported (31% ( EP A. 2012 Chemical Data Reporting (CDR) Database . Updated April 3, 2014 ) ) = 26%. 6 Estimated percentage (21%) of manufacturing and wholesale firms, that import products based on U

. S

. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012

-2013 . Released April 7, 2015 5). 7 The percentage of firms that import products (21%) times the times the percentage of firms that have a product above a de minimis level (12% ( IMERC, Mercury Added Products Database . Modified December 19, 2014 )) = 2.5 %. 8 The percentage of firms that export products (2 8 % ) based on U

. S

. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012

- 2013 . Released April 7, 2015 ). 9 The percentage of firms that export products (2 8 %) times the times the percentage of firms that have a product above a de minimis level (12% ( IMERC, Mercury Added Produc ts Database . Modified December 19, 2014 )) = 3.4 %.27 **6(b) Estimating Respondent Costs**  This section presents estimates of the cost expected to be incurred as a result of the information collection activity . This estimate is based on the cost of the burden estimates provided above, and includes other costs associated with this ICR. Labor costs in this report have been updated using the most recentl y available, revised wage rates and information on cost of benefits. These wage rates are taken from the Bureau of Labor Statistics (BLS) Emplo yer Costs for Employee Compensation Supplemental Tables, December 2014 (released on March 11, 2015), with the information extracted from Table 2, Private industry workers in manufacturing industries, by occupational group . This table is available online at http://www.bls.gov/news.release/pdf/ecec.pdf in PDF format. The clerical wages are taken from the BLS data for “office and administrative support.” The technical wages are taken from the BLS data f or “professional and related.” The managerial wages are taken from the BLS data for “management, business and financial.” Labor wage rates and hourly cost of benefits taken from those sources have been used to calculate the labor cost for respondents, as s hown below. The hourl y overhead is calculated as 17 percent of the base wage. This approach is used for consistency with Office of Pollution Prevention and Toxics economic analyses practices, and is based on the anal ys is in Wage Rates for Economic Analyses of the Toxics Release Inventory Program

. Table 13 presents $2014 hourly industry wages. **Table 13**  **: Loaded Wage Rates**  **Labor Category**  **Date Wage**  **1 Fringe**  **Benefits 1**  **Fringes as %**

**of Wage Overhead %** 

**of Wage 2**  **Fringe +**

**Overhead Factor**  **Loaded**

**Wages (a)**  **(b) (c) = (b)/(a)**  **(d) (e)=(1)+(c)+(d)**  **(f) = (a) x (e) Managerial**  Dec '14 $47.90 $24.18 50% 17% 1.67 **$80.22 Technical**  Dec '14 $42.19 $22.85 54% 17% 1.71 **$72.21 Clerical**  Dec '14 $18.68 $9.40 50% 17% 1.67 **$31.26 Source**  **(s) :**  1 Employer Costs for Employee Compensation Supplementary Tables: December 2006

- September 2015, U

. S

. Bureau of Labor Statistics, December 9, 2015 (pp

. 31,33,37) (http://www.bls.gov/ncs/ect/sp/ecsuphst.pdf, accessed January 25, 2016 2 An overhead rate o f 17 percent was estimated based on industry data gathered for the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report and Wage Rates for Economic Analyses of the Toxics Release Inventory Program

. To estimate costs, EPA multiplied the per

- hour loaded labor rates found in column ( f ) of Table 13 with the hourly labor estimates in Section 6(a). Table 14 presents the total per unit cost to complete Section 1 as $186 for all submitters. Table 15 presents the total cost for completing Section 2 as $85 for respondents that have not submitted IMERC data and $73 for IMERC data submitters, and Table 16 and Table 17 present the cost associated with completing one product specific section (Sections 3 to 13). EPA estimates the cost for completing Section 3 or 4 to be $645 for respondents that have not submitted IMERC data and $517 for IMERC data submitters. The cost of completing a single section in Sections 5 through 13 is estimated to be $465 for respondents that have not submitted IMERC data and $372 for IM ERC data submitters.28 **Table 14**  **: To**  **tal Cost**  **to Complete Section One for**  **All Submitters Question**  **Total per Unit Cost**  **($2014) Percentage of Respondents who** 

**Complete the Section that Respond to the Question**  **Responses per Respondent**  **Total**

**Cost (**  **$2014 )**  **Company Inform ation**  $5.59 100% 1.00 **$5.59 1**  **(a) and 1(b)** $18 1 100% 1.00 **$18 1**  **Total $186** 

**Table 15**  **: To**  **tal Cost**  **to Complete Section Tw**  **o Question**  **Total per Unit Cost ($2014)**  **Percentage of Respondents who**

**Complete the Section that Respond to the Question**  **Responses per**  **Respondent Total** 

**Cost (**  **$2014 )**  **Firms that Have not Subm itted Data to IMERC**  **Total for All of Section 2** $85.09 100% 1.00 **$85.09 IMERC Data**  **Submitters Total for All of Section 2**  $73.95 100% 1.00 **$73.95**29 **Table 16**  **: To**  **tal Cost**  **to Complete One Product Specific Section (Sections 3**

**– 13) for**  **Responders that Have not Submitted Data to IMERC**

**Question Total per**  **Unit Cost ($2014)**  **Percentage of Respondents who**

**Complete the Section that Respond to the Question**  **Responses per**  **Respondent Total** 

**Cost (**  **$2014 )**  1. Did your company manufacture [product] that contain mercury or mercury compounds in 2010, 2013 or 2016? $0.00 100% 1 **$0.00** 1.a. If yes, then provide the total amount of mercury or mercury compounds in each of the following types of [product] per year(s) $102 85% 1 1.77 2 **$153** 1.b. Did your company manufacture any [product] with mo re than a de minimis level of mercury content? $129 85% 1 1 **$110** 1.c. If yes, then provide the approximate number (or percentage) of the number provided for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 $23.93 10% 3 1 **$2.44** 2. Did your company purchase in the United States elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016? $0.00 100% 1 **$0.00** 2.a. If yes, then provide the total amount of elemental mercury or mercury com pounds your company purchased in the United States for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016 $102 59% 4 1.77 2 **$106** 3. Did your company import elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016? $0.00 100% 1 **$0.00** 3.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company im ported for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016 $102 26% 5 1.77 2 **$47.32** 4. Did your company import [product] containing elemental mercury or mercury compounds in 2010, 2013, or 2016? $0.00 100% 1 **$0.00** 4.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed types of [product] per year(s) $292 21% 6 1.77 2 **$109** 4.b. Did your company import any [product] more than a de minimis level of mercury content? $146 21% 6 1 **$30.63** 4.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 $23.93 2.5% 7 1.00 **$0.60** 5. Did your company export [product] containing mercury or mercury compounds in 2010, 2013, or 2016? $0.00 100% 1 **$0.00** 5.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed types of [product] per year(s) $102 28% 8 1.77 2 **$50.40** 5.b. Did your company export any [product] with mo re than a de minimis level of mercury content? $129 28% 8 1 **$36.10** 5.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 $23.93 3.4% 9 1 **$0.80** 6. Additional comments question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 $0.00

- **- $0.00** 30 **Table 16**  **: To**  **tal Cost**  **to Complete One Product Specific Section (Sections 3**

**– 13) for**  **Responders that Have not Submitted Data to IMERC**

**Question Total per**  **Unit Cost ($2014)**  **Percentage of Respondents who**

**Complete the Section that Respond to the Question**  **Responses per**  **Respondent Total** 

**Cost (**  **$2014 )**  **Total for Section 3 and 4**  **(Batteries and Cosmetics**  **) -**  **- -**  **$645 Total for Sections 5**  **- 13 (All Other Products; Excluded Questions 1.b, 1.c, 4.b, 4.c, 5.b, and 5.c)**  **- -**  **- $465**  **Notes:** Totals may not sum due to rounding 1 Estimated percentage (85%) of manufacturing and wholesale firms, that domestically manufacture or purchase products based on U

. S

. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012

- 20 13 . Released April 7, 2015 ). 2 Each firm makes an average of 1.77 types of each product based on a sample of 30 IMERC firms 3 The percentage of firms that domestically manufacture products (85%) times the times the percentage of firms that have a product a bove a de minimis level (12% based on ( IMERC, Mercury Added Products Database . Modified December 19, 2014 )) = 10%. 4 The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compou nds that are domestically manufactured (69% ( EP A. 2012 Chemical Data Reporting (CDR) Database . Updated April 3, 2014 ) ) = 59%. 5 Th e percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compound s that are imported (31% ( EP A. 2012 Chemical Data Reporting (CDR) Database . Updated April 3, 2014 ) ) = 26%. 6 Estimated percentage ( 21%) of manufacturing and wholesale firms, that import products based on U

. S

. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012

-2013 . Released April 7, 2015 ). 7 The percentage of firms that import products (21%) times the time s the percentage of firms that have a product above a de minimis level (12% ( IMERC, Mercury Added Products Database . Modified December 19, 2014 )) = 2.5 %. 8 The percentage of firms that export products (2 8 % ) based on U

. S

. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012

- 2013 . Released April 7, 2015 ). 9 The percentage of firms that export products (2 8 %) times the times the percentage of firms that have a product above a de minimis level (12% ( IMERC, Mercury Added Products Database . Modified December 19, 2014 )) = 3.4 %.31 **Table 17**  **: To**  **tal Cost**  **to Complete One Product Specific Section (Sections 3**

**– 13) for**  **IMERC Data Subm** **itters Question**  **Total per Unit Cost**  **($2014) Percentage of Respondents** 

**who Complete the Section that**  **Respond to the Question Responses per**  **Respondent Total** 

**Cost (**  **$2014 )**  1. Did your company manufacture [product] that contain mercury or mercury compounds in 2010, 2013 or 2016? $0.00 100% 1 **$0.00** 1.a. If yes, then provide the total amount of mercury or mercury compounds in each of the following types of [product] per year(s) $81.29 85% 1 1.77 2 **$122** 1.b. Did your company manufacture any [product] with mer cury content 2% or greater ? $104 85% 1 1 **$88.39** 1.c. If yes, then provide the approximate number (or percentage) of the number provided for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 $19.14 10% 3 1 **$1.95** 2. Did your company purchase in the United States elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016? $0.00 100% 1 **$0.00** 2.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company purchased in the United States for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016 $81.29 59% 4 1.77 2 **$84.55** 3. Did your company import elemental mercury or mercury compounds to be used in the production of [product] manufactured by your company in 2010, 2013, or 2016? $0.00 100% 1 **$0.00** 3.a. If yes, then provide the total amount of elemental mercury or mercury compounds your company imported for use in the manufacture of [product] in each of the following years: 2010, 2013, 2016 $81.29 26% 5 1.77 2 **$37.86** 4. Did your company import [product] containing elemental mercury or mercury compounds in 2010, 2013, or 2016? $0.00 100% 1 **$0.00** 4.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed ty pes of [product] per year(s) $233 21% 6 1.77 **$86.82** 4.b. Did your company import any [product] with mercury content 2% or greater ? $117 21% 6 1 **$24.51** 4.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 $19.14 2.5% 7 1 **$0.48** 5. Did your company export [product] containing mercury or mercury compounds in 2010, 2013, or 2016? $0.00 28% 8 1.77 **$0.00** 5.a. If yes, then provide the total amount of mercury or mercury compounds in each of the listed ty pes of [product] per year(s) $81.29 28% 8 1 **$40.32** 5.b. Did your company export any [product] with mercury content 2% or greater ? $104 3.4% 9 1 **$29.12** 5.c. If yes, then provide the approximate number (or percentage) of the number of [product] reported for question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 $19.14 2.8% 9 1 **$0.64** 6. Additional comments question 3.a.(1)(c) in each of the following years: 2010, 2013, 2016 $0.00

- **- $0.00** 32 **Table 17**  **: To**  **tal Cost**  **to Complete One Product Specific Section (Sections 3**

**– 13) for**  **IMERC Data Subm** **itters Question**  **Total per Unit Cost**  **($2014) Percentage of Respondents** 

**who Complete the Section that**  **Respond to the Question Responses per**  **Respondent Total** 

**Cost (**  **$2014 )**  **Total for Section 3 and 4**  **(Batteries and Cosmetics**  **) -**  **- -**  **$517 Total for Sections 5**  **- 13 (All Other Products; Excluded Questions 1.b, 1.c, 4.b, 4.c, 5.b, and 5.c)**  **- -**  **- $372**  **Notes:** Totals may not sum due to rounding 1 Estimated percentage (85%) of manufacturing and wholesale firms, that domestically manufacture or purchase products based on U

. S

. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012

- 2013 . Released April 7, 2015 ). 2 Each firm makes an average of 1.77 types of each product based on a sample of 30 IMERC firms 3 The percentage of firms that domestically manufacture products (85%) times the times the percentage of firms that have a product above a de minim is level (12% based on ( IMERC, Mercury Added Products Database . Modified December 19, 2014 )) = 10 %. 4 The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compou nds that are domestically manufactured (69% ( EP A. 2012 Chemical Data Reporting (CDR) Database . Updated April 3, 2014 ) ) = 59%. 5 The percentage of firms that domestically manufacture products (85%) times the times the amount of mercury and mercury compou nds that are imported (31% EP A. 2012 Chemical Data Reporting (CDR) Database . Updated April 3, 2014 ) ) = 26%. 6 Estimated percentag e (21%) of manufacturing and wholesale firms, that import products based on U

. S

. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012

-2013 . Released April 7, 2015 ). 7 The percentage of firms that import products (21%) times the times the percentage of firms that have a product above a de minimis level (12% ( IMERC, Mercury Added Products Database . Modified December 19, 2014 )) = 2.5 %. 8 The percentage of firms that export products (2 8 % ) based on U

. S

. Census data (U.S. Census, Profile of US Importing and Exporting Companies: 2012

- 2013 . Released April 7, 2015 ). 9 The percentage of firms that export products (2 8 %) times the times the percentage of firms that have a product above a de minimis level (12% ( IMERC, Mercury Added Produc ts Database . Modified December 19, 2014 )) = 3.4 %.33 **6(c) Estimating Agency Burden and Cost**  EPA estimates that the Agency cost for administering and mailing out the survey is $24,726, and includes both labor and materials costs. Labor costs are 1/7th of a full

time employee (FTE) 13, Step 5 employee in the Washington

- Baltimore locality , with a to tal annual wage of $101,914 (OPM, 2014). EPA applied a government overhead factor of 1.6 to account for fringe benefits and overhead, for a total EPA staff cost of approximately

$23,295 in $2014 (($101,914 x 1.6)/7=$23,295). EPA’s cost for sending 646 ques tionnaires with stamped return envelopes is $2.22 each ($0.98 in postage and $1.24 in materials and processing cost). Both labor and material costs estimates are based on data from EPA ICR No. 249.10 OMB Control No. 2070

-NEW [Information Collection Request for

] Survey of Public and Commercial Buildings. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act

. 31 Stamps cost estimates are based on current U.S. postage rates for first class mail

. 32 **Table 18**  **: Agency Costs ($2014)**  **Activity Agency Cost**  EPA Staff Time (1/7 of a GS 13

- Step 5) $23,295 Mailing Questionnaire $1,432 **Total $24,726**  **6(d) Bottom** **- Line Industry Burden and Cost Estimates**  **Respondent tally** EPA used various data sources including IMERC, TRIdata, March 2015 subpoenas, and Internet research to identify companies to that may

manufacture, import, or export mercury

in a product, or use mercury in a manufacturing process. EPA identified up to 646 facilities in the United States that manufacture, import, or export mercury- added products, or use mercury or mercury

compounds in manufacturing processes ; 515 companies that have not previously submitted data to IMERC and 131 companies that have submitted IM ERC data. If all 646 companies received a questionnaire, EPA expects that each would complete Sections 1 and 2 of the questionnaire. However some of these companies may not be using mercury

in any products of interest to EPA, such as mercury present in fuel sources for coal

- fired boilers or other industrial furnaces , and these firms will not complete S ections 3 to 13. Based on company data, EPA estimates that a total of 27 companies would respond to Sections 3 or 4 and 528 would respond to Sections 5 through 13. 33 EPAs research indicates that no firms manufacture both batteries and cosmetics (Section 3 and 4), however for Sections 5

- 13 the average of 1.09 products categories per respondent was calculated from an

31 EPA. EPA ICR No. 2 49.10 OMB Control No. 2070

-NEW [Information Collection Request for] Survey of Public and Commercial Buildings. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act . July 30, 2014. 32 Stamps.com. “Current Postage Rates: USPS Postage Rates

. ” Available at http://www.stamps.com/usps/current

-postage
- rates/

. 33 The total of 528 companies, includes 6 companies that are expected to complete Section 3 or 4

.34

IMERC sample of 30 active companies. Table 19 presents the total number of responders and responses for each section.
**Table 19**  **: Total Num** **ber of Responders and Responses Section**  **Number of Responders 1**  **Sections per Respondent**  **Number of Responses Non**  **- IMERC**  **IMERC 2**  **T otal**  **Non -**  **IMERC IMERC**  **Total Section 1**  515 131 646 1 515 131 646 **Section 2** 515 131 646 1 515 131 646 **Sections 3 or**  **4 3**  2 25 27 1 2 25 27 **Sections 5**  **- 13**  416 112 528 1.09 454 122 576 **Total Industry Burden and Cost for All Submitters** Table 20 contains the total burden and cost for all potential respondents

. EPA e stimates the total industry burden to be 6,399 hours and $444,430.
**Table 20**  **: Total Burden and Cost for**  **A ll Submitters**  **Activity Total** 

**Number of Companies**  **Responses**

**per Company**  **Total**

**Number of Responses**  **Total**

**Burden per Activity**  **(hours) Total Cost** 

**per Activity ($2014)**  **Total Burden**

**(hours) Total** 

**Cost ($2014)**  **Responders that Have not Submitted Data to IMERC**  **Section 1 Completion**  515 1 515 2.60 $186 **1,337 $95,889**  **Section 2**  **Completion** 515 1 515 1.23 $85 **634 $43,839**  **Section 3 -**  **4 Completion**  2 1 2 9.35 $645 **19 $1,290**  **Sections 5**  **- 13**  **Completion** 416 1.09 454 6.81 $465 **3,090 $211,107**  **Total 5,080**  **$352,125 IMERC Data**  **Submitters Section 1**  **Completion** 131 1 131 2.60 $186 **339 $24,343**  **Section 2**  **Completion** 131 1 131 0.98 $74 **128 $9,673**  **Section 3 -**  **4 Completion**  25 1 25 7.49 $517 **187 $12,926**  **Sections 5**  **- 13**  **Completion** 112 1.09 122 5.45 $372 **664 $45,363**  **Total 1,319**  **$92,305 Summary for**  **A ll Submitters**  **Section 1 Completion**  646 1 646 2.60 $186 **1,676 $120,232**  **Section 2**  **Completion** 646 1 646 1.18 $83 **762 $53,512**  **Section 3 -**  **4 Completion**  27 1 27 7.63 $527 **206 $14,216**  **Sections 5**  **- 13**  **Completion** 528 1.09 576 6.52 $445 **3,755 $256,470**  **Total 6,399**  **$444,430**35 For comparison, the Agency used the above approach to generate a total burden and cost for a narrowed scope of up to 250 respondents. As set forth in Table 20a, EPA estimates the total industry burden to be 2,5 66 hours and $178,961

. **Table 21**  **a :**  **Total Burden and Cost for all Submitters**

**– 250 Firm**  **s Activity**  **Total**

**Number of Companies**  **Responses**

**per Company**  **Total**

**Number of Responses**  **Total**

**Burden per Activity**  **(hours) Total Cost** 

**per Activity**  **($2014) Total Burden** 

**(hours) Total** 

**Cost ($2014)**  **Responders that Have not Submitted Data to IMERC Section 1**  **Completion** 65 1 65 2.60 $186 **169 $12,094**  **Section 2 Completion**  65 1 65 1.23 $85 **80 $5,529**  **Section 3 -**  **4 Completion**  3 1 3 9.35 $645 **28 $1,935**  **Sections 5 -**  **13 Completion**  62 1.09 68 6.81 $465 **460 $31,436**  **Total 737**  **$50,994 IMERC Data Submitters**  **Section 1 Completion**  185 1 185 2.60 $186 **480 $34,436**  **Section 2 Completion**  185 1 185 0.98 $74 **181 $13,683**  **Section 3 -**  **4 Completion**  21 1 21 7.49 $517 **157 $10,858**  **Sections 5 -**  **13 Completion**  170 1.09 185 5.45 $372 **1,010 $68,990**  **Total 1,829**  **$127,967 Summary for**  **A ll Submitters**  **Section 1 Completion**  250 1 250 2.60 $186 **649 $46,529**  **Section 2 Completion**  250 1 250 1.04 $77 **261 $19,212**  **Section 3 -**  **4 Completion**  24 1 24 7.73 $533 **185 $12,793**  **Sections 5 -**  **13 Completion**  232 1.09 253 5.81 $397 **1,471 $100,426**  **Total 2,566**  **$178,961**36 **Average Burden and Cost per Respondent** Table 22 present s the average total burden per respondent; 9.37 hours for companies that have not submitted IMERC data and 10.18 hours for companies that have submitted IMERC data. Table 23 presents the average cost per submitter, which EPA estimates to be $683 for companies that have not submitted IMERC data and $706 for companies that have.
**Table 22**  **: Average Burden per Respondent**  **Activity Hours**  **Responses per**  **Average Company**  **Average**

**Burden (hours)**  **Clerical Technical**  **Managerial Total**  **Responders that Have not Submitted Data to IMERC Section 1**  **Completion** 0.04 2.54 0.02 2.60 1 **2.60 Section**  **2 Completion**  0.14 0.84 0.25 1.23 1 **1.23 Section 3**  **- 4**  **Completion** 1.01 6.69 1.15 8.85 0.004 **0.03 Sections**  **5 -**  **13 Completion**  0.80 4.69 0.77 6.25 0.88 **5.51 Total**  **9.37 IMERC Data**  **Submitters Section 1**  **Completion** 0.04 2.54 0.02 2.60 1 **2.60 Section**  **2 Completion**  0.12 0.75 0.20 1.07 1 **1.07 Section 3**  **- 4**  **Completion** 0.79 5.68 1.03 7.49 0.19 **1.43 Sections**  **5 -**  **13 Completion**  0.66 4.07 0.71 5.45 0.93 **5.08 Total**  **10.18 Notes:**  Totals may not sum due to rounding The average number of responses per company is calculated by dividing the total number of responses for each section by the total number of companies. For example the average number of Section 3

- 4s per company for firms that have not submitted IMERC data is calculated as 2 responses/565 companies = .004.37 **Table 23**  **: Average Cost per Respondent**  **Activity Cost ($2014)**  **Responses per**  **Average Company**  **Average**

**Cost (**  **$2014 )**  **Clerical Technical**  **Managerial Total**  **Responders that Have not Submitted Data to IMERC**  **Section 1 Completion**  $1.09 $183.42 $1.60 $186.12 1.00 **$186 Section**  **2 Completion**  $4.38 $60.66 $20.06 $85.09 1.00 **$85 Section 3**  **- 4**  **Completion** $30.48 $512.90 $101.73 $645.11 0.004 **$2.50 Sections**  **5 -**  **13 Completion**  $25.65 $368.39 $70.91 $464.95 0.88 **$410 Total**  **$683 IMERC**  **Section 1 Completion**  $1.09 $183.42 $1.60 $186.12 1.00 **$186 Section**  **2 Completion**  $3.75 $54.16 $16.04 $73.95 1.00 **$74 Section 3**  **- 4**  **Completion** $24.65 $410.03 $82.36 $517.04 0.19 **$99 Sections**  **5 -**  **13 Completion**  $20.72 $294.26 $56.98 $371.96 0.93 **$347 Total**  **$706 Notes:**  Totals may not sum due to rounding The average number of responses per company is calculated by dividing the total number of responses for each section by the total number of companies. For example the average number of Section 3

- 4s per company for firms that have not submitted IMERC data is calculated as 2 responses/565 companies = .004 **6(e) Bottom Line Burden Hours and Cost Tables**  Table 23 contains the bottom line burden and cost estimate for all potential respondents. EPA estimates the total burden to be 6,399 hours and $469,156 , including Agency costs
. **Table 24**  **: Bottom** **Line Burden and Costs for all Submitter**  **s**

**Cost Category Labor Hours**  **Cost** Respondent Labor 6,399 $444,430 EPA Labor N.A. $23,295 Other Direct EPA Costs N.A. $1,432 **Total 6,399**  **$469,156** For comparison, the Agency used the above approach to generate a total burden and cost for a narrowed scope of up to 250 respondents. As set forth in Table 23a, EPA estimates the total industry burden to be 2,566 hours and $202,810 , including Agency costs
.38 **Table 23 a**  **: Bottom Line Burden and Costs** 

**– 250 Firm**  **s Cost Category**  **Labor Hours Cost**  Respondent Labor 2,566 $178,961 EPA Labor N.A. $23,295 Other Direct EPA Costs N.A. $554 **Total 2,566**  **$202,810 6(**  **f) Reasons for Change in Burden**  Not applicable because this request is for a new collection of information

. **6(g) Burden Statement**  The annual public burden for this collection of information is estimated to average 9.9 hours per respon se (response in this context meaning submission by a respondent of a completed questionnaire )

. Burden is defined in 5 CFR 1320.3(b). An agency may not conduct or sponsor, and a person is not required to respond to a collection of information unless it displays a current and valid OMB control number. The OMB control numbers for EPA’s regulations in title 40 of the CFR, after appearing in the Federal Regis ter, are listed in 40 CFR part 9 and included on the related collection instrument or form, if applicable. The Agency has established a public docket for this ICR under Docket ID No. EPA

- HQ

- OPPT

- 20 16

- 01 25 , which is available for online viewing at www.regulations.gov, or in person viewing at the Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). The EPA/DC Public Reading Room is located in the EPA West Building, Room 333 4, 1301 Constitution Ave., NW., Washington, DC. The EPA/DC Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday

through Friday , excluding legal holidays. The telephone number for the EPA/DC Public Reading Room is (202) 566

- 1744, and the telephone number for the Pollution Prevention and Toxics Docket is (202) 566

- 0280. You may submit comments regarding the Agency's need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden, including the use of automated collection techniques. Submit your comments, referencing Docket ID No. EPA

- HQ

- OPPT

- 2016

- 0125 and OMB Control No. 2070

-NEW, to (1) EPA online using www.regulations.gov (our preferred method), or by mail to: Pollution Prevention and Toxics Docket, Environmental Protection Agency D ocket Center (EPA/DC), Mailcode: 28221T, 1200 Pennsylvania Ave., NW., Washington, DC 20460, and (2) OMB b y mail to: Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, NW, W ashington, DC 20503.39 **LIST OF ATTACHMENTS TO THE SUPPORTING STATEMENT**  **Attachment 1**

– Toxic Substances Control Act, section 2(b)(1) [ 15 U.S.C. 2601 ] and section 11(c) [ 15 U.S.C. 2610 ] **Attachment 2**

– Minamata Convention on Mercury **Attachment 3** 

– EPA Strategy to Address Mercury

- Containing Products **Attachment 4** 

– Questionnaire : Collection of Information on Use of Mercury and Mercury Compounds in Products and Processes