*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 1 of 32 

### EO12866_RIN2070-AJ44_Formaldehyde-TPCs-NPRM_ICR_2012-03-12.docx 1



## Draft document as submitted for review under EO 12866/13563. 2

3 

### Supporting Statement for a Request for OMB Review under 4 

### the Paperwork Reduction Act 5

6

7



### 1. IDENTIFICATION OF THE INFORMATION COLLECTION 8

9 

### l(a) Title of the Information Collection 10

11 

### TITLE: Formaldehyde Emissions From Composite Wood Products, Third12 

### party Certification Framework, Recordkeeping and Reporting – 13 

### Proposed Rule (RIN 2070-AJ44) 14

15 

### EPA ICR No.: 2441.01 OMB Control No: 2070-[NEW] 16

17 

### 1(b) Short Characterization 18

19 

### The Formaldehyde Standards for Composite Wood Products Act, which established Title 20 

### VI of the Toxic Substances Control Act (TSCA) , set forth formaldehyde emission standards for 21 

### hardwood plywood, particleboard and medium-density fiberboard a nd directs EPA to promulgate 22 

### implementing regulations by January 2013. TSCA Title VI includes a provision directing EPA 23 

### to promulgate implementing regulations relate d to a third-party certification system for 24 

### composite wood panels. This consolidated ICR covers the recordkeeping and reporting 25 

### requirements for accreditation bodies and third-party certifiers that wish to participate in this 26 

### third-party certification program. It is a rule -related ICR for the Notice of Proposed Rulemaking 27 

### entitled “Third-Party Certific ation Framework for the Formaldehyde Standards for Composite 28



### Wood Products Rule.” Additional information coll ection requests, such as those related to 29 

### disclosure requirements for panel producers and product labeling requirement s, will be covered 30 

### later in a separate ICR. 31

32 

### Some examples of proposed reporting and th ird-party reporting re quirements include: 33

34



###  Product accreditation bodi es that wish to participate in the program must submit an 35 

### application to become recognized by EPA. 36



###  Laboratory accreditation bodies that wish to pa rticipate in the program must submit an 37 

### application to become recognized by EPA. 38



###  Third-party certifiers that wish to participate in the program must submit an application 39 

### for accreditation to a recognized product acc reditation body and a recognized laboratory 40 

### accreditation body. 41



###  Recognized product accreditation bodies must submit an annu al report to EPA on their 42



### accreditation activities. 43



###  Recognized laboratories accreditation bodies must submit an annual report to EPA on 44



### their accreditation activities. 45*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 2 of 32 

###  TSCA Title VI accredited third-party certifier s must submit an annual report to their 46 

### accreditation body or bodies (product accredi tation body and laboratory accreditation 47 

### body, if not the same entity) and to EPA on their TSCA Title VI accreditati on activities. 48

49 

### Examples of proposed recordkeeping requirements would include: 50



###  Recognized accreditation bodies must retain checklists and other records documenting 51 

### compliance with the requirements for systems audits and on-site assessments of third52 

### party certifiers for as long as the third-pa rty certifier is accredited or for 5 years, 53 

### whichever is longer. 54



###  A TSCA Title VI accredited thir d-party certifier mu st retain a list of panel producers and 55 

### their respective product type s, including resins used, that it has certified. 56



###  A TSCA Title VI accredited third-party certif ier must retain records on the results of 57 

### inspections, audits, and emission tests conduc ted for and linked to each panel producer 58 

### and product type. 59



###  A TSCA Title VI accredited third-party certifier must retain a list of laboratories that they 60 

### use, test methods, including test conditions and conditioning time and test results. 61



###  A TSCA Title VI accredited th ird-party certifier must reta in records on the methods and 62 

### results for establishing test met hod correlations and equivalence. 63

64



### The information collected under this ICR would be used by EPA’s Regional 65


### Administrators, the Office of Enforcement a nd Compliance Assurance (OECA), and/or the 66 

### Office of Chemical Safety and Pollution Preven tion (OCSPP), as appropr iate. Some of the 67 

### information would also be made available to the public via the internet. Confidential business 68 

### information (CBI) submitted to EPA will be ma intained by the Agency pursuant to TSCA § 14 69



### and 40 CFR Part 2. 70

71



### 2. NEED FOR AND USE OF THE COLLECTION 72

73 

### 2(a) Need/Authority for the Collection 74

75 

### The reporting and recordkeeping requirements of this consolidated ICR are implemented 76 

### under the authority of TSCA Title VI. TSCA T itle VI directs EPA to promulgate regulations, 77 

### including provisions relating to “t hird-party testing a nd certification” in “a manner that ensures 78 

### compliance with the emission standards.” To me et its statutory obliga tions, EPA must obtain 79



### sufficient information to establish and oversee a credible third-party certification program for 80 

### composite wood products. This information will help EPA ensure that all program participants 81 

### are carrying out their responsibilities dilig ently, impartially, and uniformly. The proposed 82 

### regulations aim to ensure consistent applicati on of the requirements of TSCA Title VI by using 83 

### voluntary consensus standards as requirements, a nd by leveraging the expertise of international 84



### accreditation bodies. 85

86 

### High quality third-party certi fiers are essential in ensuri ng that domestic and foreign 87 

### composite wood panel producers supplying products to the U.S. have ade quate quality assurance 88 

### and quality control procedures, ar e adequately testing their products to determine that they are 89 

### compliant, and are otherwise acting in manner that is consistent with th e requirements of TSCA 90 

### Title VI. The reporting and record maintenance re quirements in this ICR would help ensure that 91*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 3 of 32 

### all program participants remain qualified and ar e held accountable for thei r activities, and would 92 

### allow panel producers to obtain credible TSCA Title VI certifications for their regulated 93 

### composite wood products. 94

95 

### 2(b) Use of the Data 96

97



### EPA would use the information co llected to evaluate the creden tials of entities that wish 98 

### to participate in the program, oversee compliance with the program requirements, monitor issues 99 

### as they arise, and inform interested parties where they can obtain EPA-recognized TSCA Title 100



### VI accreditation and certification services. 101

102

103 

### 3. NON-DUPLICATION, CONSULTATION S, AND OTHER COLLECTION CRITERIA 104

105 

### 3(a) Non-Duplication 106

107 

### TSCA Title VI assigns the responsibility for promulgating regulations that ensure 108 

### compliance with the statutorily established emission standards fo r formaldehyde from composite 109 

### wood products to the EPA Administrator. The info rmation collection requirements addressed in 110 

### this ICR are not duplicative of any other Federal requirement. No other Federal agency requires 111 

### respondents to report or maintain information on their accreditation or ce rtification activities 112 

### related to formaldehyde emissions from composite wood products. 113

114 

### EPA based the framework for this program on other Federal and State third-party 115 

### certification systems. However, because the th ird-party certification framework is necessarily 116 

### tailored to the unique TSCA Title VI requirements, these records and reports are the sole source 117 

### of information for EPA to rely on in order to determine the number of program participants, 118


### evaluate their credentials, mon itor their compliance with the program, determine the number of 119 

### panel producers receiving certifi cation services, and evaluate a panel producer’s compliance 120 

### history. 121

122 

### 3(b) Public Notice Required Prior to ICR Submission to OMB 123

124 

### This ICR will be made available to the public for comment through a Federal Register 125 

### notice. The public will have 60 days to provide comments. Any comments received will be given 126 

### consideration when completing the supporting statement that is submitted to OMB. 127

128 

### 3(c) Consultations 129

130 

### On numerous occasions during the course of developing the proposed regulation, the 131 

### Agency has consulted with the regulated commun ity and the public. These consultations have 132 

### been held directly with industry officials and, on an ongoing basis, with owners and operators of 133 

### regulated facilities. EPA has also consulted wi th the California Air Resources Board (CARB), 134 

### which operates a similar third-party certifi cation program for formaldehyde standards for 135 

### composite wood products that are sold, supplied, or offered for sale in the State of California. 136

137*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 4 of 32 

### Since EPA began its regulatory investigati on into formaldehyde emissions from pressed 138 

### wood products with an Advanced Notice of Proposed Rulemaking (ANPR) published in 2008, 139



### EPA has met on numerous occasions with the co mposite wood panel and related industries. 140 

### These meetings have been in the form of pres entations at trade shows and industry association 141 

### conferences, and meetings with the Composite Panel Association (CPA), the Hardwood Plywood 142 

### and Veneer Association (HPVA), the Kitchen Cabinet Manufacturing Association (KCMA), the 143 

### American Home Furnishings Alliance (AHF A), the Business and Institutional Furniture 144 

### Manufacturer’s Association (BIFMA), and indivi dual companies. EPA staff have, at the 145 

### invitation of potentially regulated manufactures , conducted factory tours and site visits. 146

147 

### EPA convened a Small Business Advocacy Revi ew Panel and hosted two panel outreach 148 

### meetings with small entity representatives (SER). Prior to each meeting, EPA distributed 149


### outreach materials to the SERs, and after each m eeting the SERs were asked to provide written 150 

### feedback on how EPA might reduce regulatory bu rden on small entities. The Panel received 151 

### written comments from the SERs in response to the discussions at the meetings and the outreach 152



### materials. The Panel summarized written and oral comments from the SERs and developed Panel 153 

### recommendations in its Panel Report. ( See Panel Report of the Small Business Advocacy 154 

### Review Panel on EPA’s Planned Proposed Rule Implementing the Formaldehyde Standards for 155 

### Composite Wood Products Act (TSCA Title VI), April 4, 2011). 156

157 

### EPA intends to carry out further consultati ons and outreach with potentially regulated 158 

### entities concurrent with the public comment period. These comments will be used to update the 159 

### Supporting Statement as needed. 160

161 

### 3(d) Effects of Less Frequent Collection 162

163 

### EPA has judged that the reporting and record keeping requirements of the ICR are the 164 

### minimum amount necessary to fulfill its statutor y mandate to promulgate regulations on a third165 

### party certification program that ensure complia nce with the emission st andards. Although the 166 

### third-party certification program is critical to the implementation of TSCA Title VI, EPA cannot 167 

### delegate its statutory duty to ensure compliance with TSCA Title VI to third-party certifiers. 168 

### Likewise it cannot delegate it s oversight duties to accreditation bodies. The reports and records 169 

### in this ICR would allow EPA carry out its st atutorily delegated roles in program design, 170 

### enforcement, and oversight. EPA believes that requi ring applications, annual reports, and certain 171



### one-time notifications from the accreditation bodies a nd third-party certifiers that wish to be 172 

### recognized or accredited as progr am participants would allow EP A to effectively monitor the 173 

### program. Annual reports and notifications that ar e triggered by specific occurrences will allow 174 

### EPA to ensure compliance with the emission standa rds, as required by the statute. EPA believes 175 

### that less frequent reporting and failure to require notice of sign ificant events (e.g., a third-party 176 

### certifier losing its accreditation) could result in uncertified and noncompliant products being 177



### distributed in commerce. 178

179



### 3(e) General Guidelines 180

181*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 5 of 32 

### This information collection co mplies with the guidelines at 5 CFR 1320.5(d)(2). The 182 

### exceptions to OMB’s Paperwork Reduction Act Gu idelines, and the explanation of why such 183 

### characteristics are needed to fulfill the statutory requirements, are described below: 184

185 

### Under the information collection requiremen ts, participating accreditation bodies must 186 

### retain applications for accreditation from third-part y certifier applicants for 5 years after the date 187 

### the third-party certifier’s accreditation terminates. Because this initial application is unlikely to 188 

### change, EPA believes the burden associated with maintaining a copy of the application in 189



### electronic form will be minimal. Moreover, the contents of these applications form the basis for 190 

### the accreditation body’s ongoing accreditation of the thir d-party certifier. 191

192 

### Under the information collection requiremen ts checklists and other records documenting 193 

### compliance with the requirements for systems audits and on-site assessments of third-party 194 

### certifiers must be retained for as long as the th ird-party certifier is accr edited or for 5 years, 195 

### whichever is longer. This peri od corresponds to the statute of limitations period. EPA believes 196 

### the accrediting bodies should be requ ired to maintain these records for the statute of limitations 197 

### period because these records are the only source of information documenting how the accrediting 198 

### body verifies the third-party ce rtifier’s ongoing compliance with the accreditation requirements 199



### for TSCA Title VI accreditation. 200

201 

### A participating third-party cer tifier’s would be required to maintain the following records 202 

### for five years: 1) A list of panel producers a nd their respective product types, including resins 203 

### used, that it has certified; 2) Results of inspec tions, audits, and emissi on tests conducted for and 204 

### linked to each panel producers a nd product type; 3) A list of labor atories it uses, test methods, 205 

### including test conditions and c onditioning time and test results; 4) Methods and results for 206 

### establishing test method correla tions and equivalence; and 5) A list of panel producers and 207 

### products approved for reduced testing. EPA believes it is necessary for a third-party certifier to 208 

### keep these records on the panel producers that recei ve its TSCA Title VI certification services in 209 

### order to establish that the pane l producers are complying with regulatory requirements and have 210 

### earned that third-party certifier’ s certification. Because accredited third-party certifiers would be 211 

### continually responsible for auditing, testing, a nd certification of com posite wood products, EPA 212 

### believes that these records are both necessary to do cument a third-party certifier’s efforts to carry 213 

### out its responsibilities under the program, and us eful to the third-party certifiers while they 214 

### evaluate products fo r certification. 215

216 

### There are a number of provisi ons that would require reportin g within a certain number of 217 

### days of an occurrence of a specific event. Fo r example, notice that an accredited third-party 218 

### certifier has failed to comply with any provision of this section must be provided to EPA within 219



### 24 hours of the time the failure is identified. These reporting requirement s are not triggered by 220 

### the calendar (i.e., they are not requ ired quarterly or at more fre quent intervals). Therefore, the 221 

### Agency does not believe that these provisions ne ed special justificati on. Moreover, EPA believes 222 

### that unless these notifications are provided within the intervals prescribed in the proposed rule, a 223 

### change in circumstances could re sult in uncertified products bei ng distributed in commerce, in 224



### violation of the statute. 225

226 

### 3(f) Confidentiality 227*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 6 of 32 228 

### Accreditation bodies or third-pa rty certifiers may claim all or part of any information 229 

### given to EPA as confidential business information (CBI). EPA handles claims of confidentiality 230 

### pursuant to established CBI procedures, as foun d at Section 14 of TSCA and 40 CFR Part 2, and 231 

### the Agency’s TSCA CBI Manual. CBI is also protected under the Freedom of Information Act 232 

### (5 USC Section 525). Most of the information requested in the reporti ng requirements of these 233



### collections is not of a confidential nature. 234

235 

### 3(g) Sensitive Questions 236

237 

### EPA asks no questions of a sensitive nature. 238

239

240 

### 4. THE RESPONDENTS AND THE INFORMATION REQUESTED 241

242 

### 4(a) Respondents/NAICS Codes 243

244 

### The primary respondents would be accrediting bodies and third-party certifiers that wish 245 

### to participate in the TSCA Title VI third-party certification program. 246

247 

### Third-party certifiers are indepe ndent entities that review pr oducts, processes or services 248 

### to verify that a set of norms, criteria, claims, pr actices or standards are being met. In this case 249



### the set of standards would be set by EPA in the proposed TSCA Title VI implementing 250 

### regulations and would require c onformity with specified voluntary consensus standards. 251

252 

### An accreditation body is an organization that provides an impartial verification of the 253 

### competency of conformity assessment bodies such as third-party certifiers . Accreditation bodies 254 

### are themselves evaluated by their own internatio nal oversight bodies to ensure their compliance 255 

### with voluntary consensus standards. 256

257 

### The following NAICS codes are relevant: 258

259



###  Engineering services (NAICS code 541330). 260



###  Testing laboratories (NAICS code 541380). 261



###  Administrative management and general mana gement consulting services (NAICS code 262 

### 541611). 263



###  All other professional, sc ientific, and technical services (NAICS code 541990). 264



###  All other support servic es (NAICS code 561990). 265



###  Business associations (NAICS code 813910). 266



###  Professional organizatio ns (NAICS code 813920). 267

268 

### 4(b) Information Requested 269

270 

### (i) Data Items 271

272*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 7 of 32 

### The information collection requirements are triggered when an entity desires to 273 

### participate in the program either as an accreditin g body or a third-party cert ifier. Entities that 274 

### wish to participate in the program and offer serv ices related to TSCA Title VI accreditation or 275 

### certification must submit an application. Accr editation bodies would apply to be recognized 276 

### through a memorandum of understanding with EPA. Third-party certifiers would then apply to 277 

### an EPA-recognized accreditation body to b ecome TSCA Title VI accredited. 278

279 

### Once an accreditation body is recognized or a third-party certifier is TSCA Title VI 280 

### accredited, that entity then becomes subject to other reporting, notification, and record keeping 281 

### requirements. If an entity were to leave the program, the reporting and notification requirements 282 

### would cease, and the record keeping requirements w ould lapse at the end of the record retention 283 

### period. 284

285 

### The proposed recordkeeping requirements and reporting requirements include: 286

287 

### (A) Notifications/Reports . Respondents are required to submit information to EPA to 288 

### accomplish the following reporting tasks: 289

290



###  Product accreditation bodi es that wish to participate in the program must submit an 291 

### application to become recognized by EPA via a memorandum of understanding. The 292 

### application must include: 1) The name, addr ess, telephone number, and email address of 293 

### a primary contact; 2) Documentation of its International Accr editation Forum Inc., 294 

### Multilateral Recognition Arrangement signatory st atus, or equivalent; 3) If not a domestic 295 

### entity, the name and address of an agent for service located in the United States; and 4) A 296 

### description of any other qualif ications related to its expe rience in performing product 297 

### accreditation of conformity assessment bodies or third-party certifiers. Qualifications 298 

### required for applicants incl ude ongoing conformance with International Organization for 299



### Standardization and International El ectrotechnical Commission (ISO/IEC) 17011 300 

### (including associated recordkeeping and repor ting requirements) and demonstrating basic 301 

### competence to perform accreditation activitie s for product certification according to 302



### ISO/IEC Guide 65. 303

304



###  Laboratory accreditation bodies that wish to pa rticipate in the program must submit an 305 

### application to become recognized by EPA via a memorandum of understanding. The 306 

### application would include: 1) The name, addr ess, telephone number, and email address of 307 

### primary contact; 2) Documentation of International Laboratory Accreditation 308 

### Cooperation Mutual Recognition Arrangement signatory status, or equivalent; 3) If not a 309 

### domestic entity, the name and address of an agent for service located in the United States; 310 

### and 4) a description of any other qualifications related to the laboratory accreditation 311 

### body’s experience in performing laboratory acc reditation and inspec tion certification of 312 

### conformity assessment bodies or third-party certifiers. Qualifications required for 313 

### applicants include ongoing conformance w ith ISO/IEC 17011 (including associated 314 

### record keeping and reporting requirements) a nd a demonstration of basic competence to 315 

### perform accreditation activitie s for laboratory accreditati on according to ISO/IEC 17025. 316

317



###  Recognized product accreditation bo dies would be required to submit an annual report to 318*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 8 of 32 

### EPA on their accreditation activities. This report would include the number and locations 319 

### of systems audits and on-sit e assessments performed, and th e results of accredited third320 

### party certifier laboratory proficiency testing or inte r-laboratory comparisons. 321

322



###  Recognized laboratory accredita tion bodies would be required to submit an annual report 323



### to EPA on their accreditation activities. This report would include the number and 324 

### locations of systems audits and on-site assessments performed, and the results of 325 

### accredited third-party certifie r laboratory proficiency testing or inter-laboratory 326 

### comparisons. 327

328



###  Recognized product accreditation bodies would be required to forward copies of third329 

### party certifiers’ applications to EPA at th e address identified in the memorandum of 330 

### understanding within 90 days of the date of receipt. 331

332



###  Recognized product accreditation bo dies would be required to submit notice if it loses its 333 

### status as a signatory to the Internatio nal Accreditation Forum Inc. Multilateral 334 

### Recognition Arrangement (or membership in an equivalent organization) within 5 335 

### business days of the date that the body receives notice of the lo ss of its signatory status. 336

337



###  Recognized laboratory accredita tion bodies would be required to submit notice if it loses 338 

### its status as a signatory to the International Laboratory Accreditation Cooperation Mutual 339 

### Recognition Arrangement (or membership in an equivalent organization) within 5 340 

### business days of the date that the body receives notice of the lo ss of its signatory status. 341

342



###  Recognized accreditation bodies would be requir ed to submit notice when it accredits a 343 

### third-party certifier within 5 business days of the date that the certifier is TSCA Title VI 344



### accredited. 345

346



###  Recognized accreditation bodies would be requir ed to submit notice that an accredited 347 

### third-party certifier has failed to comply w ith any provision of the regulation within 24 348



### hours of the time the accreditati on body identifies the failure. 349

350



###  A recognized accreditation body would be required to submit notice when it suspends or 351 

### revokes a third-party certifie r’s accreditation w ithin 24 hours of the time that the 352 

### suspension or revocation takes effect. 353

354



###  A recognized accreditation body would be requir ed to submit notice of a decision to 355 

### make changes in its organizational policies or management structure that could adversely 356 

### affect the third-party certifie r accreditation program within 30 days of the decision to 357 

### make the changes. 358

359



###  Recognized accreditation bodies would be requ ired to provide checklists and other 360 

### records documenting compliance with the re quirements for systems audits and on-site 361 

### assessments of third-party certifiers to EPA w ithin 30 days of request. The records must 362 

### be retained for as long as the third-party certif ier is accredited or for 5 years, whichever is 363 

### longer. 364*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 9 of 32 365



###  TSCA Title VI accredited third-party certifier s would be required to supply the following 366 

### records to EPA within 30 days of request: 1) A list of panel producers that it has certified 367 

### and their respective product t ypes, including resins used; 2) The results of inspections, 368


### audits, and emission tests conducted for a nd linked to each panel producer and product 369 

### type; 3) A list of laboratories it uses, te st methods, including test conditions and 370 

### conditioning time and test results; and 4) Th e methods and results for establishing test 371 

### method correlations and equivalence. These reco rds must be maintained for 5 years. 372

373



###  If a third-party certifier appr oves an application for reduced testing, it must notify and 374 

### forward copies of the application for re duced testing to EPA within 30 days. 375

376 

### (B) Third-Party Reports . Respondents are required to submit information to entities 377



### other than EPA as follows: 378

379



###  Recognized product accreditation bodies would be required to provide a unique tracking 380 

### number (i.e., third-party cer tified number) to every third-party-certifier it accredits. 381

382



###  Recognized laboratory accred itation bodies would be requi red, within 15 days of a 383 

### request by a third-party cert ifier or their EPA-recognized product accreditation body, to 384 

### forward copies of a third-party certifier’s laboratory applicat ion and accreditation 385 

### documentation to the applicable EPA-r ecognized product accreditation body (if the 386 

### laboratory accreditation body is not also recognized as a pr oduct accreditation body) at 387 

### the address identified by the third-party certifier. 388

389



###  Third-party certifiers that wish to participate in the program must submit an application 390 

### for accreditation to a recognized laboratory accreditation body and th en to a recognized 391 

### product accreditation body. Th e product accreditation body a nd laboratory accreditation 392 

### body may, in some cases, be the same entity. In such cases, the applications can be made 393 

### concurrently. The application to the product a ccreditation would be requ ired to include: 394 

### 1) The name, address, telephone number, and em ail address of primary contact; 2) If not 395 

### a domestic entity, the name and address of an agent for service located in the United 396 

### States; 3) The type of com posite wood products that the a pplicant intends to certify if 397 

### accredited; and 4) A description of the third- party certifier’s qualifications including 398 

### experience or ability in product certificat ion and complying with ISO/IEC Guide 65 399 

### (including associated record keeping requirements); experi ence in the composite wood 400 

### product industry with the specifi c product(s) the app licant intends to cer tify, and ability to 401 

### inspect and properly train a nd supervise inspectors pursuan t to ISO/IEC 17020 (including 402 

### associated record keeping requirements). Th e application to the laboratory accreditation 403 

### would be required to include: 1) The name, a ddress, telephone number, and email address 404 

### of primary contact; 2) If not a domestic ent ity, the name and address of an agent for 405 

### service located in the United States; 3) A description of the th ird-party certifier 406 

### laboratory’s qualifications (inc luding contract laboratories ), including experience in 407 

### performing or verifying formaldehyde tes ting on composite wood products, experience 408 

### complying with ISO/IEC 17025 (including associ ated record keeping requirements), and 409*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 10 of 32 

### experience with test method ASTM E- 1333-96 (2002) and experience evaluating 410



### correlation between test methods. 411

412



###  TSCA Title VI accredited third-party certifier s must provide their third-party certifier 413 

### numbers to any panel producers receiving their TSCA Title VI certification services. 414

415



###  TSCA Title VI accredited third-party certifier s must submit an annual report to their 416 

### accreditation body or bodies (product accredi tation body and laboratory accreditation 417 

### body, if not the same entity) and to EPA on th eir TSCA Title VI accr editation activities. 418 

### The report would include: 1) A list of panel producers that the certifier has certified 419 

### during the previous year and their products, including resins used and the average and 420 

### range of formaldehyde emissions by panel produ cer, resin, and product ty pe; 2) A list of 421 

### any noncomplying products or events by a pane l producer; 3) A list of laboratories and 422 

### test methods used by the certifier; and 4) th e results of inter-laboratory comparison or 423 

### proficiency testing for the labor atories used by the certifier. 424

425



###  TSCA Title VI accredited third-party certifi ers would be required to inform their 426 

### accreditation body or bodies (product accredi tation body and laboratory accreditation 427 

### body, if not the same entity) within 30 days of any changes in personnel qualifications, 428 

### procedures, or laboratorie s used by the certifier. 429

430



###  Should a TSCA Title VI accredited third-party certifier withdraw from the program or 431


### lose its accreditation, it would be required to notify all panel produ cers that receive its 432 

### TSCA Title VI accreditation services within 3 business days. 433

434



###  Should a recognized accreditati on body be removed or withdraw from the program it 435 

### must notify all third-party certifiers that receive its accreditati on services within 5 436 

### business days. 437

438



###  Third-party certifiers that receive applicati ons from panel producer s for reduced testing 439 

### must act on those applications within 90 days. 440

441 

### (C) Records . Respondents are required to maintain records as follows: 442

443



###  Recognized accreditation bodies must retain checklists and other records documenting 444 

### compliance with the requirements for systems audits and on-site assessments of third445 

### party certifiers for as long as the third-pa rty certifier is accredited or for 5 years, 446 

### whichever is longer. 447

448



###  A TSCA Title VI accredited thir d-party certifier must retain a list of panel producers that 449 

### it has certified and their respec tive product types, including re sins used, for 5 years. 450

451



###  TSCA Title VI accredited third-party certifier s must retain records on the results of 452 

### inspections, audits, and emission tests conduc ted for and linked to each panel producer 453 

### and product type for 5 years. 454

455*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 11 of 32 

###  A TSCA Title VI accredited third-party certifie r must retain a list of laboratories that it 456 

### uses, test methods, including test conditions and conditioning time and test results for 5 457



### years. 458

459



###  TSCA Title VI accredited third-party certifier s must retain records on the methods and 460 

### results for establishing test method corre lations and equivalence for 5 years. 461

462 

### (ii) Respondent Activities 463

464 

### Typical respondents include accreditation bodies and third-party certif iers that wish to 465



### offer TSCA Title VI accreditation or certification services. All respondents would need to read 466 

### the rule and determine which prov isions would be applicable to their operations; plan and modify 467 

### their procedures to come into compliance with the rule; provide training to appropriate staff; 468 

### process, compile, and review information for accu racy and appropriateness; and record, disclose, 469 

### and/or report the required information. 470

471

472



### 5. THE INFORMATION CO LLECTION — AGENCY AC TIVITIES, COLLECTION 473 

### METHODOLOGY, AND INFORMATION MANAGEMENT 474

475 

### 5(a) Agency Activities 476

477



### EPA resources would be devoted to reviewing and analyzi ng data submissions, compiling 478 

### and recording data, maintaining hard-copy files of submitted data, auditing and inspecting 479 

### facilities, producing audit and inspection reports, responding to public inquiries, providing 480 

### regulatory interpretations and developing rulemaki ngs. EPA plans to continue/expand its review 481 

### of the use of the Internet to facilitate the transfer of information from EPA to the public. More 482 

### specific Agency activities are as follows: 483

484



###  Receive and evaluate applications from accreditation bodies that wish to 485 

### participate in the program. 486

487



###  Develop and enter into memoranda of unde rstanding with qualified accreditation 488



### bodies. 489

490



###  Supply a point of contact for each memorandum of understanding for 491



### accreditation bodies to consult with on implementation of the memorandum of 492 

### understanding. 493

494



###  Maintain a current and publically available list of recognized accreditation bodies 495 

### and accredited third-party certifiers. 496

497



###  Evaluate the annual reports from recogni zed accreditation bodies and TSCA Title 498 

### VI accredited third-party certifiers. 499

500



###  Evaluate all notices received from accreditat ion bodies and third-party certifiers to 501*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 12 of 32 

### determine whether further ag ency action is warranted. 502

503 

### 5(b) Collection Methodology and Management 504

505 

### While EPA would prepare an application form for accreditation bodies that wish to be 506 

### recognized by EPA, the majority of the other info rmation requirements would not require the use 507 

### of a specific form or format, except that it must be submitted electronically. 508

509 

### Annual reports, and notifications triggered by a specific occurrences would be submitted 510 

### electronically. Records are maintained at EP A by the staff overseeing the TSCA Title VI 511



### program. 512

513 

### 5(c) Small Entity Flexibility 514

515 

### Small businesses are not exempt from the requirements of TSCA Title VI. The 516 

### information collections would apply to all entities that wish to participate in the TSCA Title VI 517 

### third-party certification program, regardless of size. EPA has elec ted to require equal disclosure 518 

### by all participating accreditati on bodies and third-party certif iers because the third-party 519 

### certification program is essential to ensuring compliance with the highly technical requirements 520



### of TSCA Title VI. 521

522 

### 5(d) Collection Schedule 523

524 

### Most of the reporting activities are triggered by specific events or on an as needed basis 525 

### rather than by specific dates, as shown on Table 5-1. 526

527


### Table 5-1: Collection Requirements and Schedule

Ref. # Collection Requirement Collection Schedule

1 Application to EPA from a product accred itation body When product accreditation
body wishes to participate in
the program and every three
years thereafter for as long as

it wishes to continue to
participate

2 Application to EPA from a laboratory accr editation body When laboratory accreditation
body wishes to participate in
the program and every three
years thereafter for as long as

it wishes to continue to
participate

3 Annual report to EPA from a product accreditation body Annually, on the month its

memorandum of
understanding was signed

4 Annual report to EPA from a laboratory accreditation
body Annually, on the month its

memorandum of*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 13 of 32 

### Table 5-1: Collection Requirements and Schedule

Ref. # Collection Requirement Collection Schedule

understanding was signed

5 Copies of third-party certifie rs’ applications forwarded
from a recognized product accreditation body to EPA Within 90 days of receipt of
those applications

6 A recognized product accreditation bodies must submit
notice if it loses its status as a signatory to the

International Accreditation Forum Inc., Multilateral
Recognition Arrangement (or membership in an
equivalent organization) Within 5 business days of
being informed of loss of

status

7 A recognized laboratory accreditation bodies must submit
notice if it loses its status as a signatory to the
International Laboratory Accreditation Cooperation
Mutual Recognition Arrangement (or membership in an
equivalent organization) Within 5 business days of
being informed of loss of

status

8 A recognized accreditation body must submit notice when
it accredits a third-party certifier Within 5 business days of the

date that the certifier is

accredited

9 A recognized accreditation body must submit notice that a
TSCA Title VI accredited third-party certifier has failed
to comply with any provision of the regulation Within 24 hours of the time
the accreditation body

identifies the failure

10 A recognized accreditation body must submit notice when
it suspends or revokes a third-party certifier’s

accreditation Within 24 hours of the time
that the suspension or

revocation takes effect

11 A recognized accreditation body must submit notice of a
decision to make changes in its organizational policies or
management structure that could adversely affect the
third-party certifier accreditation program Within 30 days of the decision
to make the changes

12 A recognized accreditation body must provide checklists
and other records documenting compliance with the
requirements for systems audits and on-site assessments
of third-party certifiers to EPA Within 30 days of a request by

EPA

13 A recognized product accreditation body must provide a
unique tracking number to every third-party-certifier it

accredits At the time the third-party

certifier receives its

accreditation

14 An accredited third-party certifier must supply the
following records to EPA: 1) A list of panel producers
and their respective product types, including resins used,
that it has certified; 2) The results of inspections, audits,
and emission tests conducted for and linked to each panel
producer and product type; 3) A list of laboratories it Within 30 days of request by

EPA*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 14 of 32 

### Table 5-1: Collection Requirements and Schedule

Ref. # Collection Requirement Collection Schedule

uses, test methods, including test conditions and
conditioning time and test r esults; and 4) The methods
and results for establishing test method correlations and
equivalence

15 A recognized laboratory accreditation body must forward
copies of a third-party certifier’s laboratory application
and accreditation documentation to the applicable EPArecognized product accreditation body (if the product
accreditation body is not also recognized as a laboratory
accreditation body ) at the address identified by the thirdparty certifier Within 15 days of a request by
a third-party certifier or its
EPA-recognized product
accreditation body

16 A third-party certifier that wishes to participate in the
program must submit an application for accreditation to a
recognized laboratory accreditation body and then to a
recognized product accreditation body When it desires to become
accredited to perform TSCA

Title VI certification services,
and every two years thereafter
for as long as it desires to
continue providing TSCA

Title VI certification services

17 A TSCA Title VI accredited third-party certifier would be
required to provide its third-party certifier number to any
panel producer receiving its TSCA Title VI certification

services When a panel producer begins
receiving its services

18 A TSCA Title VI accredited third-party certifier must
submit an annual report to its accreditation body or bodies
(product accreditation body and laboratory accreditation
body, if not the same entity) and to EPA on its TSCA

Title VI certification activities Annual, on anniversary of

accreditation

19 A TSCA Title VI accredited third-party certifier must
inform its accreditation body or bodies (product
accreditation body and laboratory accreditation body) of
any changes in the personnel qualifications, procedures,
or laboratories used by the certifier Within 30 days

20 Should a TSCA Title VI accredited third-party certifier
withdraw from the program or lose its accreditation, it
would be required to notify all panel producers that

receive its TSCA Title VI accreditation services Within 3 business days

21 Should a recognized accreditation body be removed or
withdraw from the program it must notify all third-party

certifiers that receive its accreditation services Within 5 business days

22 Notify EPA of approval of an application for reduced
testing forward copies of all approved applications for
reduced testing to EPA Notification with 5 days of
approval,

Forward copy of application*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 15 of 32 

### Table 5-1: Collection Requirements and Schedule

Ref. # Collection Requirement Collection Schedule

within 30 days of receipt

23 Third-party certifiers must act on applications for reduced
testing Within 90 days of receipt of a
complete application

528

529



### 6. ESTIMATING BURDEN AND CO ST OF THE COLLECTION 530

531



### This section estimates the incremental burden of the recordkeeping and reporting 532 

### requirements for accreditation bodies (ABs) and th ird-party certifiers (TPCs) that wish to 533 

### participate in the TSCA Title VI third-party certification progra m for composite wood products. 534

535 

### 6(a) Estimating Respondent Burden 536

537 

### This ICR presents the estimated annual burden and associated annual costs for the 538 

### following information collection components of the third party certif ication framework: 539

540



###  Accreditation Bodies: 541



### o Rule Familiarization: Reading the rule in order to understand the requirements; 542



### o Application Submission: Submitting an application to enter into a Memorandum 543 

### of Understanding (MOU) with EPA; 544



### o Prepare a MOU: If the application is approved, enter into an MOU with EPA; 545



### o EPA Notification: Provide EPA with notifications in the following instances: 546 

### loss of signatory status; TPC application; TPC accr editation; TPC compliance 547 

### failure; organization policy or management structure changes that could adversely 548 

### affect accreditation program; and provide checklists and other records 549 

### documenting compliance with systems audits and on-site assessments; 550



### o TPC Notification: Provide TPCs with notificati ons if they withdraw or are 551 

### removed from the program; 552



### o Recordkeeping: Maintain records documenting TPC accreditation applications, 553



### and checklists and other records documen ting compliance with systems audits and 554 

### on-site assessments. Applications must be retained for a mi nimum of five years 555



### from the date that the TPC’ s accreditation terminates; and 556



### o 

### Reporting: Provide an annual report to EPA wi th the number of TPC applications 557


### received; the number of TPCs approved and denied; the names and contact 558


### information of all accredited TPCs; the number and locations of systems audits 559


### and on-site assessments; and the results of accredited TPC proficiency testing and 560 

### inter-laboratory comparisons. 561

562



###  Third Party Certifiers: 563



### o Rule Familiarization: Reading the rule in order to understand the requirements; 564



### o Application Submission: submitting an application to the accrediting body; 565*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 16 of 32 

### o Obtain Accreditation: initially obtain accredita tion (i.e., to demonstrate 566 

### compliance with the relevant ISO/IEC standards and test method ASTM E-1333- 567 

### 96 and experience correlati ng between test methods); 568



### o Manufacturer Notifications and Recordkeeping: the annual cost of 569



### manufacturer notification and of maintaining records; and 570



### o Accrediting Body Notifications and Reporting: provide an annual report and 571 

### other notifications to the accrediting body. 572

573 

### (i) Number of Respondents 574

575



### The number of domestic accreditation bodies was estimated to be 8, the number of 576 

### signatories to the International Accreditation Foru m, Inc. (IAF) or the International Laboratory 577 

### Accreditation Cooperation (ILAC). Of the 8 dom estic accrediting bodies, 4 were determined to 578 

### be small. The number of foreign accreditation bodies was estimated to be 17, the number of 579 

### signatories for ISO Guide 65, ISO 17020, or ISO 17025 in countries with CARB-approved 580



### TPCs. Based on the small business determinatio ns for domestic accrediting bodies, it is 581 

### estimated that 9 of the foreign accrediting bodies are small. 582

583 

### As shown in Exhibit 6-1, CARB has appr oved a total of 36 TPCs, nine of which are 584 

### located in the U.S. (although most U.S. TPCs provide services internationally). Of the nine U.S. 585


### firms, two are classified as “small” based on the U.S. Small Business Administration’s size 586 

### standards, two are classified as large, and the small business status could not be determined for 587 

### five remaining firms. Thus, it is estimated that half of all TPCs (both foreign and domestic) are 588 

### small. It is assumed that there will be 9 domestic TPCs and 27 foreign TPCs in the TSCA Title 589 

### VI program, the same as in the CARB program. 590

591
Exhibit 6-1: Summary of CARB-A pproved Third Party Certifiers

Country Where TPC is Located Number of TPCs

Australia 1

Austria 1

Belgium 1

China 5

Czech Republic 1

Denmark 1

France 1

Germany 4

Hong Kong 3

Indonesia 1

Italy 3

New Zealand 1

Poland 1

Spain 1

Sweden 1

Taiwan 1

United States 9

Total 36


### Source: California Air Resources Board. 2011. List of CARB

Approved Third Party Certifiers.

592*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 17 of 32 

### Exhibit 6-2 presents a summary of the number of respondents by size and type. 593

594
Exhibit 6-2: Summary of Respondents

Respondent Type Total

Number of

Respondents Total Number

of Small

Respondents

Domestic Accrediting Bodies 8 4

Foreign Accrediting Bodies 17 9

Domestic Third Party Certifiers 9 5

Foreign Third Party Certifiers 25 13

595 

### (ii) Burden Per Respondent 596

597 

### Exhibit 6-3 and Exhibit 6-4 present the estimated per-activity recordkeeping and 598 

### reporting burdens for accreditati on bodies and third party certifi ers, respectively. Exhibit 6-5 599 

### summarizes the total hour burden by type of firm. Exhibit 6-5 provides separate estimates for 600



### TPCs that are accredited for all three relevant ISO/IEC standards (Guide 65, 17020, and 17025) 601



### and for those that need to obtain an additional a ccreditation. The latter group will pay fees to an 602 

### accreditation body, which are accounted for as costs in section 6(b)(ii), and described in more 603 

### detail there. The recordkeep ing and reporting requirements do not differ between TPCs that 604



### have all of their accreditations and those that do not, so the two groups have identical burdens in 605 

### Exhibit 6-5. The two groups are listed separately here in order to carry them through the analysis 606 

### consistently. 607*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***March 12, 2012Page 18 of 32Exhibit 6-3: Recordkeeping and Reporting Burden for Accreditation Bodies, by ActivityActivity1Per Activity Burden HoursNumber ofAnnualActivities(d)Clerical Technical ManagerialTotal Burden(hours)(a) (b) (c)(e) =(d)*{(a)+(b)+(c)}1. Rule Familiarization 0.00 5.00 5.00 1.00 10.00002. Application SubmissionCompany Information (Name, Address,Telephone Number, and Email Addressof Primary Contact)20.00 0.04 0.021.000.0600Documentation of IAF MLA, ILAC MRA, or Equivalent Signatory Status20.00 0.04 0.02 1.00 0.0600Description of Any Other QualificationsRelated to Experience in PerformingAccreditation of Conformity Assessment Bodies or Third Party Certifiers30.00 0.83 0.511.001.34003. Memorandum of Understanding41.00 1.00 4.001.006.00004. EPA NotificationLoss of Status as a Signatory to theIAF MLA, ILAC MRA, or EquivalentOrganization50.00 0.08 0.04 0.05 0.0060Third Party Certifier Applications50.00 0.08 0.04 3.00 0.3600Third Party Certifier Accreditation50.00 0.08 0.04 3.00 0.3600Third Party Certifier Compliance Failure50.00 0.08 0.04 0.33 0.0396Third Party Certifier Accreditation Suspension or Revocation (Product ABs) /Accredited Laboratory Compliance Failure (Laboratory ABs)50.00 0.08 0.04 0.33 0.0396Change to Organizational Policy or Management Structure that Could AdverselyAffect Accreditation Program50.00 0.08 0.04 0.20 0.0240Checklists and Other Records Documenting Compliance with the Requirementsfor Systems Audits and On-site Assessment of Third Party Certifiers50.00 0.08 0.04 1.00 0.1200Change in Name or Address of Domestic Agent (Foreign Entities Only)50.00 0.08 0.04 0.50 0.06005. Third Party Certifier NotificationUnique Tracking Number20.00 0.04 0.02 3.00 0.1800Withdraw from or be Removed from Program20.00 0.04 0.02 0.25 0.01506. RecordkeepingAccreditation Applications60.75 1.50 0.75 1.00 3.0000Checklists and Other Records Documenting Compliance with the Requirementsfor Systems Audits and On-site Assessment of Third Party Certifiers60.75 1.50 0.75 1.00 3.00007. Annual Report to EPANumber of Third Party Certifier Applications Received70.25 0.50 0.25 1.00 1.0000Number of Third Party CertifierApplications Approved and Denied70.25 0.50 0.25 1.00 1.0000The Names and Contact Information ofAll Accredited Third Party Certifiers70.25 0.50 0.25 1.00 1.0000Number and Locations of Systems Audits and On-site Assessments70.25 0.50 0.25 1.00 1.0000*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***March 12, 2012Page 19 of 32Results of Accredited Third Party Certifier Laboratory Proficiency Testing orInter-laboratory Comparisons70.25 0.50 0.25 1.00 1.0000Domestic Total in First Year 29.6042Foreign Total in First Year 29.6642Domestic Total in Year 2 and 3 12.1442Foreign Total in Year 2 and 3 12.2042Notes: 1. Under the proposed rule, accreditation bodies are required to submit an application to renew their MOU every three years. As a result, this analysisassumes that accreditation bodies incurapplication submission and MOU preparation costs in the first year and subsequently every three years thereafter.2. Based on the estimated burden associated withreporting "company information" (EPA 2011).3. Based on the estimated burden associatedwith answering substantiation questionswhen making plant siteconfidentiality claims (EPA 2011).4. Based on conversationswith accreditation bodies.5. Based on the estimated burden associated with reporting "company information" (EPA 2011). Values have been doubled based onbest professional judgment.6. Based on the estimated burden associated with "recordkeeping" (EPA 2011). The rule requires that records be kept for 5 yearsthat show theproduction volume, plant site, and site-limited status of each reported substance.7. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011). Estimate based on best professional judgment.Source: U.S. Environmental Protection Agency. 2011. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule Addendum toPartial Update of the TSCA Section 8(b) TSCAInventory Data Base, Production and Site Reports.*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***March 12, 2012Page 20 of 32Exhibit 6-4: Recordkeeping and Reporting Burden for Third Party Certifiers, by ActivityPer Activity Burden Hours Number ofAnnualActivities(d)Total Burden(hours)(e) =(d)*{(a)+(b)+(c)}Activity1Clerical Technical Managerial(a) (b) (c)1. Rule Familiarization 0.00 5.00 5.00 1.00 10.002. Product Accreditation Body Application SubmissionCompany Information (Name, Address,Telephone Number, and Email Addressof Primary Contact) and Type of Composite Wood Products Applicant Intendsto Certify20.00 0.04 0.02 1.00 0.06Description of TPC's Experience or Ability in Product Certification andComplying with ISO/IEC Guide 6530.00 0.83 0.51 1.00 1.34Description of TPC's Experience inthe Composite Wood Product Industry withthe Product(s) Intended to be Certified30.00 0.83 0.51 1.00 1.34Description of TPC's Ability to Inspect and Properly Train and SuperviseInspectors Pursuant to ISO/IEC 1702030.00 0.83 0.51 1.00 1.343. Laboratory Accreditation Body Application SubmissionCompany Information (Name, Address,Telephone Number, and Email Addressof Primary Contact; if foreign, name and address of an agent for service locatedin the U.S.)20.00 0.04 0.02 1.00 0.06Description of TPC's Experience inPerforming or Verifying FormaldehydeTesting on Composite Wood Products30.00 0.83 0.51 1.00 1.34Description of TPC's Experience Operating or Using Laboratories that Complywith ISO/IEC 1702530.00 0.83 0.51 1.00 1.34Description of TPC's Experience with Test Method ASTM E-1333-96 (2002)and Experience Evaluating Correlation between Test Methods30.00 0.83 0.51 1.00 1.344. Manufacturer NotificationThird Party Certifier Number20.00 0.04 0.02 1.00 0.06Withdraw from Program or Lose Accreditation20.00 0.04 0.02 0.25 0.0155. RecordkeepingList of Manufacturers and their Product Types (including Resins Used) Certifiedby TPC40.75 1.50 0.75 1.00 3.00Results of Inspections, Audits, and Emission Tests Conducted for EachManufacturer and Product Type40.75 1.50 0.75 1.00 3.00List of the TPC's Laboratories, TestMethods (including Test Conditions andConditioning Time), and Test Results40.75 1.50 0.75 1.00 3.00Methods and Results for Establishing Test Method Correlations andEquivalence40.75 1.50 0.75 1.00 3.00List of Manufacturers and Products Approved for Reduced Testing40.75 1.50 0.75 1.00 3.006. Annual Report to Accreditation Bodies*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***March 12, 2012Page 21 of 32List of Manufacturers and their Products Certified by the TPC during thePrevious Year (including Resins Used, and the Average and Range ofFormaldehyde Emissions by Manufacturer, Resin, and Product Type)50.25 0.50 0.25 1.00 1.00List of Noncomplying Productsor Events by Manufacturer50.25 0.50 0.25 1.00 1.00List of Laboratories and Test Methods Used by the TPC50.25 0.50 0.25 1.00 1.00Results of Inter-Laboratory Comparison or Proficiency Testing for theLaboratories Used by the TPC40.25 0.50 0.25 1.00 1.007. Accreditation Board NotificationPersonnel Qualification Changes20.00 0.04 0.02 0.50 0.03Procedure Changes20.00 0.04 0.02 0.50 0.03Laboratory Changes20.00 0.04 0.02 0.50 0.038. EPA NotificationChange in Name or Address of Domestic Agent (Foreign TPCs Only)20.00 0.04 0.02 0.50Domestic Total in First Year37.325Foreign Total in First Year37.355Domestic Total in Non-Reapplication Year (Year 2)19.165Foreign Total in Non-Reapplications Year (Year 2)19.195Domestic Total in Reapplication Year (Year 3)27.325Foreign Total in Reapplications Year (Year 3)27.355Notes: 1.Under the proposed rule, TPCs are required to apply for re-accreditation every two years. As aresult, application and accreditation costs are incurred every other year.2. Based on the estimated burden associated withreporting "company information" (EPA 2011).3. Based on the estimated burden associatedwith answering substantiation questionswhen making plant siteconfidentiality claims (EPA 2011).4. Based on the estimated burden associated with "recordkeeping" (EPA 2011). The rule requires that records be kept for 5 yearsthat show theproduction volume, plant site, and site-limited status of each reported substance.5. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011). Estimate based on best professional judgment.Source: U.S. Environmental Protection Agency. 2011. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final RuleAddendum to Partial Update of the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 22 of 32 

### 6(b) Estimating Respondent Costs

Respondent costs are estimated by combining bur den estimates from the previous section
with loaded wage rates, and adding in materials costs.

(i) Wage Rates

The fully loaded unit labor cost for managerial, professional/t echnical, and clerical labor
in the regulated industry and for EPA staff is estimated by adding fringe benefits and overhead
costs to the hourly wage or annual salary for each category following the method described in
Wage Rates for Economic Analysis of the Toxics Release Inventory Program . This section
describes the method employed to estimate the fully loaded unit labor costs for each labor
category and presents the results of the analysis. Exhibit 6-5: Total Burden by Firm Type (2010$)

Firm Type Number of

Firms Burden Per Firm Total Burden

Year 1

Domestic Accrediting Body 8 31.0642 249

Foreign Accrediting Body 17 31.1242 529

Domestic TPC obtaining one additional accreditation 3 37.3250 112

Domestic TPC with current accreditations 6 37.3250 224

Foreign TPC obtaining one additional accreditation 9 37.3550 336

Foreign TPC with current accreditations 18 37.3550 672

Year 2

Domestic Accrediting Body 8 12.1442 97

Foreign Accrediting Body 17 12.2042 207

Domestic TPC obtaining one additional accreditation 3 19.1650 57

Domestic TPC with current accreditations 6 19.1650 115

Foreign TPC obtaining one additional accreditation 9 19.1950 173

Foreign TPC with current accreditations 18 19.1950 346

Year 3

Domestic Accrediting Body 8 12.1442 97

Foreign Accrediting Body 17 12.2042 207

Domestic TPC obtaining one additional accreditation 3 27.3250 82

Domestic TPC with current accreditations 6 27.3250 164

Foreign TPC obtaining one additional accreditation 9 27.3550 246

Foreign TPC with current accreditations 18 27.3550 492

Three Year Average

Domestic Accrediting Body 8 18.4509 148

Foreign Accrediting Body 17 18.5109 315

Domestic TPC obtaining one additional accreditation 3 27.9383 84

Domestic TPC with current accreditations 6 27.9383 168

Foreign TPC obtaining one additional accreditation 9 27.9683 252

Foreign TPC with current accreditations 18 27.9683 503

All Entities 61 24.0800 1,469*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 23 of 32 

### Labor categories used in the an alysis correspond to the U.S. Bureau of Labor Statistics
(BLS) Standard Occupational Classification (SOC ) system. In March 2004, BLS began using the
North American Industry Classification System (NAICS) instead of the Standard Industrial
Classification (SIC) System, and the Standard Oc cupational Classification (SOC) system instead
of the Occupational Classification System (O CS). Exhibit 6-6 summarizes the crosswalk
between old and new occupational titles, and lists the SOC titles that correspond to the
managerial, professional/technica l, and clerical labor categor ies used in this analysis.

Exhibit 6-6: Detail of Labor Categories Used in the Analysis

Labor Category Used in the Analysis BLS Old Title (OCS) BLS New Title (SOC)

Managerial Executive, administrative, and
managerial Management, busine ss, and financial

Professional/Technical Professi onal specialty and technical Professional and related

Clerical Administrative support, including

clerical Office and administrative support



### Wages and fringe benefit data for managerial , professional/technical , and clerical labor
are from the BLS Employer Costs for Employee Compensation (ECEC) historical data for

December 2006 – March 2011. 1



### The costs of fringe benefits such as paid leave and insurance, sp ecific to each labor
category, are taken from the same BLS report. Fr inge benefits as a percentage of wages are
calculated separately for each labor category. For example, for December 2010, the average
wage rate for professional/ technical labor was $36.57, and th e average fringe benefit was

$13.52. 2 

### Therefore, fringe benefits as a percentage of wages were $13.52/$36.57, or

approximately 37 percent (see Exhibit 6-7).

An additional loading factor of 17 percent is applied to wages to account for overhead. 3



### This approach is used for consistency with O ffice of Pollution Preven tion and Toxics (OPPT)
economic analyses for two major rulemakings: Wage Rates for Economic Analyses of the Toxics
Release Inventory Program , June 2002, and the Revised Economic Analysis for the Amended
Inventory Update Rule: Final Report . This overhead load ing factor is added to the benefits
loading factor, and the total is th en applied to the base wage to derive the fully loaded wage. For
example, the December 2010 fully loaded wage for professional/technical labor is $36.97 × (1+
0.37 + 0.17) = $56.31.

1 U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Comp ensation: Supplementary Tables:

Historical Data: December 2006 - March 2011 . Past economic analyses used ECEC data series specific to whitecollar workers in the manufacturing sector. However, those data sets were discontinued in March 2007, and these

historical data were the best altern ative. In a phone conver sation (February 11, 2009), a BLS employee could not
identify a better data set to use.

2 Past analyses have used the term “technical” labor. Here the category is called “professional/t echnical” labor, to
make clear how it relates to BLS categories. In 2004, BLS changed from the Occupational Classification System,
OCS, to the Standard Occupational Classification system , SOC. In the process, th e “Professional specialty and
technical” category became the “Professional and related” category. However, the coverage of the old and new
occupational groups is approximately the same. See the BL S article, “Comparing Current and Former Industry and
Occupation ECEC Series” (Weinstein and Loewenstein, 2004).

3 The change was used in the 2003 PMN SNUR economic analysis (EPA, 2003b). In some earlier reports, the 17
percent had been applied to wages-plus-fringe benefits.*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 24 of 32 

### Fully loaded costs for managerial and clerical labor are calculated in a similar manner, as

shown in Exhibit 6-7.

Exhibit 6-7: Derivation of Loaded Industry Wage Rates

Labor

Category Data Source for Wage

Information Date Wage Fringe

Benefit Fringes as

% wage Overhead as

% wage a Fringe +

overhead factor Loaded

Wages

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

(a)*(e)

Clerical BLS ECEC , Private

Professional and Business

Services Industries, “Office
and Administrative Support” 2 Dec-10 $16.72 $6.09 36.42% 17% 1.53 $25.65

Professional/

Technical BLS ECEC , Private

Professional and Business

Services Industries,

“Professional and related“ 2 Dec-10 $36.57 $13.52 36.97% 17% 1.54 $56.31

Managerial BLS ECEC , Private

Professional and Business
Services Industries, “Mgt,

Business, and Financial” 2 Dec-10 $42.42 $17.15 40.43% 17% 1.57 $66.78

Notes:

a An overhead rate of 17% is used.

b Data for this occupational series found in U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee
Compensation: Supplementary Tables: Historical Data: December 2006 - March 2011

.



### (ii) Costs Per Respondent

Labor costs for accrediting bodies and third part y certifiers are presented in Exhibit 6-8

and Exhibit 6-9. These labor costs were estim ated by multiplying the respondent burdens in
Exhibit 6-3 and Exhibit 6-4 by the loaded wage ra tes presented in Exhibi t 6-7. In addition to

these labor costs, some TPCs will incur non-labor costs associated with obtaining accreditation.
The accreditation costs of TPCs will depend on whet her they have the systems and equipment in
place to satisfy the accreditation requirements or whether they will have to establish these.
Based on the telephone interviews, the cost of obt aining a single accreditation initially is about $20,000 to $30,000 for each quality system. This analysis uses the mid-point of the range,

$25,000, as the cost estimate. The cost would be about three times that if th e firm needed to be
newly accredited for all three standards (Gui de 65, 17020, and 17025). Based on discussions
with the six TPCs, the analysis assumes that tw o-thirds of the CARB-certified TPCs will already
have accreditations in place and that one-third wi ll need to obtain one additional accreditation. As a result, this analysis assumes that one-third of TPCs will incur a cost of $25,000 to obtain

one additional accreditation, while two-thirds of TPCs will not incur any additional costs
associated with obtaining and ma intaining additional accreditations.

In addition to obtaining the initial accredi tation, the TPCs will need to renew their
systems and testing certifications. Two responde nts reported costs that ranged from $5,000 to $15,000 per year associated with main taining certification, such as pa ying audit fees to their AB
(typical accreditation lasts two years). Note that the systems and testing certifications for which
the laboratories report ed costs may cover more than the specific formaldehyde testing, and
therefore these estimates may overstate costs if th ese labs would incur these costs even if they
were not acting as TPCs under FSCWPA. However, to be conservative and not underestimate*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 25 of 32 

### costs, it is assumed that laborat ories do not incur these costs in th e baseline. Because the audits

include tests other than formalde hyde, the analysis uses the low e nd of the costs reported as the
annual reaccreditation cost, $5,000. As discussed a bove, based on discussions with the six TPCs
the analysis assumes that two-thirds of the CA RB-certified TPCs will already be maintaining
these accreditations and that one-third will be maintaining one additional accreditation. Thus,
one-third of TPCs will incur a cost of $5,000 from maintaining an additi onal accreditation, while
two-thirds of TPCs will not incur any additional costs associated with obtaining and maintaining

additional accreditations.*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***March 12, 2012Page 26 of 32Exhibit 6-8: Recordkeeping and Reporting Labor Costs for Accreditation Bodies, by Activity (2010$)ActivityEstimated AnnualFrequency1Clerical Cost2TechnicalCost2Managerial Cost2Total Cost1. Rule Familiarization 1 $0.00 $281.55 $333.90 $6152. Application SubmissionCompany Information (Name, Address, Telephone Number, and EmailAddress of Primary Contact)31 $0.00 $2.25 $1.34 $3.59Documentation of IAF MLA, ILACMRA, or Equivalent SignatoryStatus31 $0.00 $2.25 $1.34 $3.59Description of Any Other Qualifications Related to Experience inPerforming Accreditation of Conformity Assessment Bodies or ThirdParty Certifiers41 $0.00 $46.74 $34.06 $80.80Application Submission Subtotal $883. Memorandum of Understanding51 $25.65 $56.31 $267.12 $3494. EPA NotificationLoss of Status as a Signatory to the IAF MLA, ILAC MRA, orEquivalent Organization60.05 $0.00 $0.23 $0.13 $0.36Third Party Certifier Application63 $0.00 $13.51 $8.01 $21.53Third Party Certifier Accreditation63 $0.00 $13.51 $8.01 $21.53Third Party Certifier Compliance Failure60.33 $0.00 $1.49 $0.88 $2.37Third Party Certifier Accreditation Suspension or Revocation (ProductABs) / Accredited Laboratory Compliance Failure (Laboratory ABs)60.33 $0.00 $1.49 $0.88 $2.37Change to Organizational Policy orManagement Structure that CouldAdversely Affect Accreditation Program60.2 $0.00 $0.90 $0.53 $1.44Checklists and Other Records Documenting Compliance with theRequirements for Systems Audits andOn-site Assessment of Third PartyCertifiers61 $0.00 $4.50 $2.67 $7.18Change in Name or Address of Domestic Agent (Foreign Entities Only)60.5 $0.00 $2.25 $1.34 $3.59EPA Notification Subtotal (Domestic) $57EPA Notification Subtotal (Foreign) $605. Third Party Certifier NotificationUnique Tracking Number33 $0.00 $6.76 $4.01 $10.76Withdraw from or be Removed from Program30.25 $0.00 $0.56 $0.33 $0.90TPC Notification Subtotal $126. RecordkeepingAccreditation Applications71 $19.24 $84.47 $50.09 $153.79Checklists and Other Records Documenting Compliance with theRequirements for Systems Audits andOn-site Assessment of Third PartyCertifiers71 $19.24 $84.47 $50.09 $153.79Recordkeeping Subtotal $3087. Annual Report to EPANumber of Third Party Certifier Applications Received81 $6.41 $28.16 $16.70 $51.26*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***March 12, 2012Page 27 of 32Exhibit 6-8: Recordkeeping and Reporting Labor Costs for Accreditation Bodies, by Activity (2010$)ActivityEstimated AnnualFrequency1Clerical Cost2TechnicalCost2Managerial Cost2Total CostNumber of Third Party CertifierApplications Approved and Denied81 $6.41 $28.16 $16.70 $51.26The Names and Contact Information of All Accredited Third PartyCertifiers81 $6.41 $28.16 $16.70 $51.26Number and Locations of Systems Audits and On-site Assessments81 $6.41 $28.16 $16.70 $51.26Results of Accredited Third Party Certifier Laboratory ProficiencyTesting or Inter-laboratory Comparisons81 $6.41 $28.16 $16.70 $51.26Annual Report Subtotal $256Domestic Total in First Year$1,685Foreign Total in First Year$1,688Domestic Total in Year 2 and 3$633Foreign Total in Year 2 and 3$636Notes: 1. Based on best professional judgment and rule requirements. Under the proposed rule, accreditation bodies are requiredto submit an application to renewtheir MOU every three years. As aresult, this analysis assumesthat accreditation bodies incur application submission and MOU preparation costs in the first year and subsequently everythree years thereafter.2. Based on Employer Costs for Employee Compensation wage and benefit data for private professional and business services industries (BLS 2011a). Clerical costs are estimated using data from the"office and administrative support" occupational group; technical costs are estimated using datafrom the "professional and related" occupational group; and managerial costs are estimated using datafrom the "management, business, and financial" occupational group.3. Based on the estimated burden associated withreporting "company information" (EPA 2011a).4. Based on the estimated burden associatedwith answering substantiation questionswhen making plant siteconfidentiality claims (EPA 2011a).5. Based on conversationswith accreditation bodies.6. Based on the estimated burden associated with reporting "company information" (EPA 2011a). Values have been doubled based onbest professional judgment.7. Based on the estimated burden associated with "recordkeeping" (EPA 2011a). The rule requires that records be kept for 5 years that show the production volume, plant site, and site-limited status ofeach reported substance.8. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011a). Estimatebased on best professional judgment.Sources: (1) U.S. Bureau of LaborStatistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: HistoricalData: December 2006 - March 2011, and (2)U.S. Environmental Protection Agency. 2011.Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule Addendum to PartialUpdate of the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***March 12, 2012Page 28 of 32Exhibit 6-9: Recordkeeping and Reporting Labor Costs for Third Party Certifiers, by Activity (2010$)ActivityEstimated AnnualFrequency1Clerical Cost2Technical Cost2Managerial Cost2Total Cost1. Rule Familiarization1.00$0.00 $281.55 $333.90 $6152. Product Accreditation Body Application SubmissionCompany Information (Name, Address, Telephone Number, andEmail Address of Primary Contact;if foreign, name and addressof an agent for service located in the U.S.) and Type ofComposite Wood Products Applicant Intends to Certify31.00$0.00 $2.25 $1.34 $3.59Description of TPC's Experience or Ability in ProductCertification and Complying with ISO/IEC Guide 6541.00$0.00 $46.74 $34.06 $80.80Description of TPC's Experience in theComposite WoodProduct Industry with the Product(s) Intended to be Certified41.00$0.00 $46.74 $34.06 $80.80Description of TPC's Ability to Inspect and Properly Train andSupervise Inspectors Pursuant to ISO/IEC 1702041.00$0.00 $46.74 $34.06 $80.80Product Accreditation Subtotal$2463. Laboratory Accreditation Body Application SubmissionCompany Information (Name, Address, Telephone Number, andEmail Address of Primary Contact;if foreign, name and addressof an agent for service located in the U.S.)31.00$0.00 $2.25 $1.34 $3.59Description of TPC's Experiencein Performing or VerifyingFormaldehyde Testing on Composite Wood Products41.00$0.00 $46.74 $34.06 $80.80Description of TPC's Experience Operating or UsingLaboratories that Comply with ISO/IEC 1702541.00$0.00 $46.74 $34.06 $80.80Description of TPC's Experiencewith Test Method ASTM E1333-96 (2002) and Experience Evaluating Correlation betweenTest Methods41.00$0.00 $46.74 $34.06 $80.80Laboratory Accreditation Subtotal$2464. Manufacturer NotificationThird Party Certifier Number31.00$0.00 $2.25 $1.34 $3.59Withdraw from Program or Lose Accreditation30.25$0.00 $0.56 $0.33 $0.90Manufacturer Notification Subtotal$45. RecordkeepingList of Manufacturers and theirProduct Types (including ResinsUsed) Certified by TPC51.00$19.24 $84.47 $50.09 $153.79Results of Inspections, Audits, and Emission Tests Conductedfor Each Manufacturer and Product Type51.00$19.24 $84.47 $50.09 $153.79List of the TPC's Laboratories,Test Methods (including TestConditions and Conditioning Time), and Test Results51.00$19.24 $84.47 $50.09 $153.79Methods and Results for Establishing Test Method Correlationsand Equivalence51.00$19.24 $84.47 $50.09 $153.79List of Manufacturers and Products Approved for Reduced1.00$19.24 $84.47 $50.09 $153.79*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***March 12, 2012Page 29 of 32Exhibit 6-9: Recordkeeping and Reporting Labor Costs for Third Party Certifiers, by Activity (2010$)ActivityEstimated AnnualFrequency1Clerical Cost2Technical Cost2Managerial Cost2Total CostTesting5Recordkeeping Subtotal$7696. Annual Report to Accreditation BodiesList of Manufacturers and their Products Certified by the TPCduring the Previous Year (including Resins Used, and theAverage and Range of Formaldehyde Emissions byManufacturer, Resin, and Product Type)61.00$6.41 $28.16 $16.70 $51.26List of Noncomplying Productsor Events by Manufacturer61.00$6.41 $28.16 $16.70 $51.26List of Laboratories and Test Methods Used by the TPC61.00$6.41 $28.16 $16.70 $51.26Results of Inter-Laboratory Comparison or Proficiency Testingfor the Laboratories Used by the TPC61.00$6.41 $28.16 $16.70 $51.26Annual Report to AB Subtotal$2057. Accreditation Board NotificationPersonnel Qualification Changes30.50$0.00 $1.13 $0.67 $1.79Procedure Changes30.50$0.00 $1.13 $0.67 $1.79Laboratory Changes30.50$0.00 $1.13 $0.67 $1.79Accreditation Board Notification Subtotal$58. EPA NotificationChange in Name or Address of Domestic Agent (ForeignTPCs Only)30.50$0.00 $1.13 $0.67 $2Domestic Total in First Year$2,090Foreign Total in First Year$2,092Domestic Total in Non-Reapplication Year (Year 2)$983Foreign Total in Non-Reapplications Year (Year 2)$985Domestic Total in Reapplication Year (Year 3)$1,475Foreign Total in Reapplications Year (Year 3)$1,477Notes: 1. Based on best professional judgment and rule requirements. Under the proposedrule, TPCs are required to apply for re-accreditation every two years.As a result, application andaccreditation costs are incurred every other year.2. Based on Employer Costs for Employee Compensation wage and benefit data for private professional and business services industries (BLS 2011a). Clerical costs are estimated using data from the"office and administrative support" occupational group; technical costs are estimated using datafrom the "professional and related" occupational group; and managerial costs are estimated using datafrom the "management, business, and financial" occupational group.3. Based on the estimated burden associated withreporting "company information" (EPA 2011a).4. Based on the estimated burden associatedwith answering substantiation questionswhen making plant siteconfidentiality claims (EPA 2011a).5. Based on the estimated burden associated with "recordkeeping" (EPA 2011a). The rule requires that records be kept for 5 years that show theproduction volume, plant site, and site-limited status of each reported substance.6. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011a). Estimatebased on best professional judgment.Sources: (1) U.S. Bureau of LaborStatistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: HistoricalData: December 2006 - March 2011, and (2)U.S. Environmental Protection Agency. 2011.Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule Addendum to PartialUpdate of the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 30 of 32 

### (iii) Total Burden and Costs

Exhibit 6-10 presents a summary of the to tal burden and costs for this information
collection request by the type of firm. The tota l burden and cost are calculated by multiplying
the burdens and costs per firm by the number of affected firms.

Exhibit 6-10: Total Burden and Costs (2010$)

Firm Type Number

of Firms Per Firm Burden and Cost Total Burden and Cost

Labor NonLabor

Cost Labor NonLabor

Cost Hours Cost Hours Cost

Year 1

Domestic Accrediting Body 8 31.0642 $1,685 249 $13,480

Foreign Accrediting Body 17 31.1242 $1,688 529 $28,696

Domestic TPC obtaining one additional accreditation 3 37.3250 $2,090 $25,000 112 $6,270 $75,000

Domestic TPC with current accreditations 6 37.3250 $2,092 224 $12,552

Foreign TPC obtaining one additional accreditation 9 37.3550 $2,090 $25,000 336 $18,810 $225,000

Foreign TPC with current accreditations 18 37.3550 $2,092 672 $37,656

Year 2

Domestic Accrediting Body 8 12.1442 $633 97 $5,064

Foreign Accrediting Body 17 12.2042 $636 207 $10,812

Domestic TPC obtaining one additional accreditation 3 19.1650 $983 $5,000 57 $2,949 $15,000

Domestic TPC with current accreditations 6 19.1650 $983 115 $5,898

Foreign TPC obtaining one additional accreditation 9 19.1950 $985 $5,000 173 $8,865 $45,000

Foreign TPC with current accreditations 18 19.1950 $985 346 $17,730

Year 3

Domestic Accrediting Body 8 12.1442 $633 97 $5,064

Foreign Accrediting Body 17 12.2042 $636 207 $10,812

Domestic TPC obtaining one additional accreditation 3 27.3250 $1,475 $5,000 82 $4,425 $15,000

Domestic TPC with current accreditations 6 27.3250 $1,475 164 $8,850

Foreign TPC obtaining one additional accreditation 9 27.3550 $1,477 $5,000 246 $13,293 $45,000

Foreign TPC with current accreditations 18 27.3550 $1,477 492 $26,586

Three Year Average

Domestic Accrediting Body 8 18.4509 $983.67 148 $7,869.33

Foreign Accrediting Body 17 18.5109 $986.67 315 $16,773.33

Domestic TPC obtaining one additional accreditation 3 27.9383 $1,516.00 $11,667 84 $4,548.00 $35,000

Domestic TPC with current accreditations 6 27.9383 $1,516.67 168 $9,100.00

Foreign TPC obtaining one additional accreditation 9 27.9683 $1,517.33 $11, 667 252 $13,656.00 $105,000

Foreign TPC with current accreditations 18 27.9683 $1,518.00 503 $27,324.00

All Entities 61 24.0800 $1,299.52 $2,295.08 1469 $79,271 $140,000*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 31 of 32 

### 6(c) Estimating Agency Burden and Cost

EPA resources would be devoted to reviewing and analyzing data submissions, compiling and

recording data, maintaining hard-copy files of submitted data, auditing and inspecting facilities,

producing audit and inspection reports, responding to public inquiries, and providing regulatory

interpretations. EPA anticipates that these activities will require the equivalent of one full-time employee

(FTE) at Headquarters. Using the 2010 Washington/Ba ltimore area annual salary rate for a GS-13, Step 5

employee ($100,904), and multiplying by a loading fact or of 1.6 to reflect overhead and fringe benefits

results in an estimated EPA cost of $161,446 per year.



### 6(d) Bottom Line Burden Hours and Costs/Master Table

Exhibit 6-10 presents the bottom line burden and costs.

Exhibit 6-11: Total Burden and Costs

Year 1 Year 2 Year 3 Average

N umber of Respondents and

Responses 61 61 61 61

Total Burden Hours 2,122.14 995.38 1,289.14 1,469
Total Cost $417,464 $111,318 $129,030 $219,271



### 6(e) Reasons for Changes in Burden

Not applicable. These are new requir ements so there was no previous ICR.

6(f) Burden Statement

The annual public burden for this collect ion of information, which is approved under

OMB Control No. xxxx-xxxx, is estimated to be 24.08 hours per response (i.e., 1,469 burden
hours for an estimated 61 respons es). According to the Paperwork Reduction Act, “burden”

means the total time, effort, or financial reso urces expended by persons to generate, maintain,
retain, or disclose or provide information to or for a Federal agency. For this collection it

includes such activities as annua l familiarization with requirements, recordkeeping, notification,
and reporting requirements. An agency may not conduct or sponsor, and a person is not required
to respond to, a collection of information unless it displays a currently valid OMB control
number. The OMB control numbers for EPA’s regulat ions in title 40 of th e CFR, after appearing
in the Federal Register, are li sted in 40 CFR part 9 and included on the related collection
instrument or form, if applicable.

To comment on 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, EPA has established a public docket for this ICR under

Docket ID No. EPA-HQ-OPPT-XXXX-XXXX. The docket is available for public viewing at

the Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). The EPA/DC*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During the Review ***

March 12, 2012 Page 32 of 32 

### Public Reading Room is located in the EPA West Building, Room 3334, 1301 Constitution Ave.,
NW., Washington, DC. The EPA/DC Public Readi ng 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 th e telephone number for the Pollution Prevention

and Toxics Docket is (202) 566-0280. An electr onic version of the public docket is available
through the Federal Docket Management Syst em (FDMS) at www.regulations.gov. Use FDMS
to submit or view public comments, access the inde x listing of the contents of the public docket,
and to access those documents in the public docket that are available electronically. Once in the
system, select “search,” then key in the docket ID number identified above. Also, you can send

comments to the Office of Information and Re gulatory Affairs, Offi ce of Management and
Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please

include the EPA Docket ID No. EPA-HQ- OPPT-XXXX-XXXX and OMB control number
xxxx-xxxx in any correspondence.