TSCA Title VI Proposed TPC Rule Economic Analysis

Economic Analysis of the Third-Party Certification 

Framework for the Formaldehyde Standards for 

Composite Wood Products Proposed Rule
TSCA Title VI Proposed TPC Rule Economic Analysis

Economic and Policy Analysis Branch

Economics, Exposure and Technology Division

Office of Pollution Prevention and Toxics

Office of Chemical Safety and Pollution Prevention

U.S. Environmental Protection Agency

May 2013
TSCA Title VI Proposed TPC Rule Economic Analysis

Acknowledgment

EPA acknowledges the analytical and draft preparation support of Abt Associates Inc. of Cambridge, 

Massachusetts in the preparation of this report, provided under Contract No. EP-W-08-10.

Notice

This is not an official guidance document and should not be relied upon to determine 

applicable regulatory requirements. This document was prepared to provide economic 

information for the rulemaking process, and to meet various administrative and legislative 

requirements. Due to the nature of the information available to EPA, the document contains 

various assumptions that may not reflect the regulatory determinations that an individual 

firm or organization would make were it to apply the rule's requirements to its specific 

circumstances. Persons seeking information on specific regulatory requirements should 

consult 40 CFR Part 770, and the preamble for the regulatory action.

Mention of the names of specific companies, organizations, or entities does not constitute 
TSCA Title VI Proposed TPC Rule Economic Analysis i

Table of Contents

Notice

1 Summary of Economic Analysis.................................................................................................1

2 Certification System .................................................................................................................8

2.1 Certification System Framework ........................................................................................................ 8

2.2 Profile of Third Party Certifiers and Accreditation Bodies ............................................................... 13

3 Costs of the TSCA Title VI TPC Rule..........................................................................................23

3.1 Proposed Rule Requirements........................................................................................................... 23

3.2 Wage Rates Used in the Analysis...................................................................................................... 25

3.3 Costs to Accreditation Bodies........................................................................................................... 26

3.4 Third-Party Certifier Costs................................................................................................................ 29

3.5 Total Cost to TPCs............................................................................................................................. 43

3.6 Total Costs of the Rule for U.S. Accreditation Bodies and TPCs....................................................... 45

4 Impact Analyses.....................................................................................................................51

4.1 Paperwork Reduction Act Analysis................................................................................................... 51

4.2 Regulatory Flexibility Act Analysis.................................................................................................... 54

4.3 Unfunded Mandates Reform Act (UMRA)........................................................................................ 60

4.4 Executive Order 13132 - Federalism ................................................................................................ 60

4.5 Executive Order 13175 - Tribal Implications .................................................................................... 61

4.6 Executive Order 13045 - Protection of Children .............................................................................. 61

4.7 Executive Order 13211 - Energy Effects........................................................................................... 62

4.8 National Technology Transfer and Advancement Act...................................................................... 62

4.9 Executive Order 12898 – Environmental Justice.............................................................................. 63

Appendix A: Wage Rates

Appendix B: Recordkeeping and Reporting Burdens
TSCA Title VI Proposed TPC Rule Economic Analysis ii

Appendix C: Costs and Benefits of Electronic Reporting
TSCA Title VI Proposed TPC Rule Economic Analysis 1

1 Summary of Economic Analysis

This report presents an economic analysis of the U.S. Environmental Protection Agency (EPA)’s 

proposed Third Party Certification rule. The Formaldehyde Standards for Composite Wood Products 

Act, which created Title VI of the Toxic Substances Control Act (TSCA), established formaldehyde 

emission standards for composite wood products (hardwood plywood, medium-density fiberboard, and 

particleboard) sold, supplied, offered for sale or manufactured in the United States. Under TSCA Tile VI, 

manufacturers of composite wood products must comply with specific formaldehyde emission

standards, and their compliance must be verified by a third party certifier (TPC). 

Third-party certification involves a process by which a product, process or service is reviewed by 

a reputable and qualified independent third-party to verify that a set of norms, criteria, claims, practices 

or standards are being met. The standards used in a third-party certification process are typically 

voluntary consensus standards developed by nationally or internationally recognized standardsproducing organizations or industry groups. TPCs are overseen by accreditation bodies (ABs), which 

provide an impartial verification of the competency of the TPCs.

The proposed TPC rule establishes a framework whereby ABs accredit TPCs so that the TPCs may 

certify composite wood product manufacturers under TSCA Title VI. The proposed rule identifies the 

roles and responsibilities ABs and TPCs, as well as the criteria for participating in the program. Under 

the proposed framework, participating ABs would accredit TPCs, audit TPCs, maintain records on their 

accredited TPCs, and report to EPA on TPCs’ activities. TPCs would be responsible for activities such as 

regularly auditing manufacturers, conducting and verifying formaldehyde emissions tests, and ensuring 

that manufacturer quality assurance and quality control procedures and testing comply with the 

requirements set forth in the TSCA Title VI rule.

Under the TSCA Title VI rule, participating accreditation bodies will need to familiarize 

themselves with the rule (in the first year), submit an application and enter into a recognition 

agreement with EPA (in the first year and every three years thereafter), and provide notifications and 

reports and keep records (every year). As shown in Table 1-1, accreditation bodies are expected to incur

costs of $1,685 in the first year, $1,070 in years with reapplication and recognition agreement 

resubmissions, and $633 in other years. 
TSCA Title VI Proposed TPC Rule Economic Analysis 2

Table 1-1: Costs per Accreditation Body

Type of Cost

Cost (2010$)

First Year Reapplication Years1Non-Reapplication Years

Rule Familiarization $615 $0 $0

Application or Reapplication Process $88 $88 $0

Prepare Recognition Agreement $349 $349 $0

EPA Notification $57 $57 $57

TPC Notification $12 $12 $12

Recordkeeping $308 $308 $308

Reporting $256 $256 $256

Cost per Accreditation Body $1,685 $1,070 $633

1

Accreditation bodies are required to reapply to the program every three years.

Eight accreditation bodies in the U.S. are assumed to participate in the TSCA Title VI program. 

As shown in Table 1-2, total annual costs to U.S. accreditation bodies are estimated to be $13,480 in the 

first year, $8,560 in years when accreditation bodies must reapply to the program, and $5,064 in other 

years. Annualized costs are estimated at $6,303 to $6,320 per year, depending on the discount rate.

Table 1-2: Total Costs for U.S. Accreditation Bodies

Type of Cost

Cost (2010$)

First Year Reapplication Years1Non-Reapplication Years

Cost per Accreditation Body $1,685 $1,070 $633

Number of U.S. Accreditation Bodies 8 8 8

Total Costs for U.S. Accreditation Bodies $13,480 $8,560 $5,064

Annualized Costs (30 years, 3 percent) $6,303

Annualized Costs (30 years, 7 percent) $6,320

1

Accreditation bodies are required to reapply to the program every three years.
TSCA Title VI Proposed TPC Rule Economic Analysis 3

TPCs participating in the TSCA Title VI program will need to conform to several voluntary 

standards and guides by the International Organization for Standardization (ISO) and International 

Electrotechnical Commission (IEC). Accreditations can cost TPCs up to $25,000 obtain and $5,000 per 

year to maintain, but most TPCs will already have all the necessary accreditations. TPCs will also have to

familiarize themselves with the rule and submit an application to the TSCA Title VI program (in the first 

year); reapply to the program (every three years); and submit notifications and reports and maintain 

records (every year). As shown in Table 1-3, TPCs that already have all accreditations in place will incur 

an estimated cost of $2,090 in the first year, $1,475 in reapplication years, and $983 in nonreapplication years. TPCs that need to obtain an additional accreditation will incur an estimated cost of 

$27,090 in the first year, $6,475 in reapplication years and $5,983 in non-reapplication years. 

Table 1-3: Costs per TPC

Type of Cost

Cost (2010$)

First Year Reapplication Years2Non-Reapplication 

Years

Have 

Accred.

Need 

Accred.

Have 

Accred.

Need 

Accred.

Have 

Accred.

Need 

Accred.

Accreditation1$0 $25,000 $0 $5,000 $0 $5,000

Rule Familiarization $615 $615 $0 $0 $0 $0

Application or Reapplication Process $492 $492 $492 $492 $0 $0

Manufacturer Notification and Recordkeeping $773 $773 $773 $773 $773 $773

Annual Report and Notifications of Changes $210 $210 $210 $210 $210 $210

Cost per TPC $2,090 $27,090 $1,475 $6,475 $983 $5,983

1

Two-thirds of TPCs are assumed to be accredited for all three standards required by the rule (ISO/IEC Guide 65, 17020, and 

17025) and thus incur no cost for accreditation or reaccreditation. One-third of TPCs will need to become accredited (and 

maintain accreditation) for one additional standard at a cost of $25,000 in the first year and $5,000 per year in subsequent years. 

2

TPCs are required to reapply every three years. CARB TPCs are grandfathered in for the first year.

Nine TPCs in the U.S. are assumed to participate in the TSCA Title VI program. Six of them are 

assumed to already have all the necessary accreditations, while three are assumed to need to obtain 

and maintain an additional accreditation. As shown in Table 1-4, total annual costs to U.S. TPCs are 

estimated to be $93,810 in the first year, $28,275 per year in reapplication years, and $23,847 per year 
TSCA Title VI Proposed TPC Rule Economic Analysis 4

in the remaining years. Total annualized costs are estimated at $27,232 to $28,123 per year, depending 

on the discount rate.
TSCA Title VI Proposed TPC Rule Economic Analysis 5

Table 1-4: Total Costs for U.S. TPCs

Type of Cost

Cost (2010$)

First Year Reapplication Years2Non-Reapplication Years

Have 

Accred.

Need 

Accred.

Have 

Accred.

Need 

Accred.

Have 

Accred.

Need 

Accred.

Cost per TPC $2,090 $27,090 $1,475 $6,475 $983 $5,983

Number of U.S. TPCs 6 3 6 3 6 3

Total Cost by Accreditation Status $12,540 $81,270 $8,850 $19,425 $5,898 $17,949

Total Costs for U.S. TPCs $93,810 $28,275 $23,847

Total Annualized Costs (30 years, 3%) $27,232 

Total Annualized Costs (30 years, 7%) $28,123 

1

Two-thirds of TPCs are assumed to be accredited for all three standards required by the rule (ISO/IEC Guide 65, 17020, and 

17025) and thus incur no cost for accreditation or reaccreditation. One-third of TPCs will need to become accredited (and 

maintain accreditation) for one additional standard. 

2

TPCs are required to reapply every three years. CARB TPCs are grandfathered in for the first year.

Table 1-5 summarizes the estimated costs attributable to the proposed rule. The estimated 

total cost is $107,290 in the first year. Total subsequent year costs range from $28,911 to $36,835 

depending on whether it is a reapplication year for ABs and TPCs. Annualized costs, calculated over a 

30-year period at three and seven percent discount rates, are $33,535 to $34,443.
TSCA Title VI Proposed TPC Rule Economic Analysis 6

Table 1-5: Summary of Costs to U.S. Accreditation Bodies and TPCs (2010$)

Type of Cost U.S. ABs

U.S. TPCs

All Affected U.S. 

Have Necessary Firms

Accreditation

Need Additional 

Accreditation

Per Firm Costs: Year 1 $1,685 $2,090 $27,090 -

Per Firm Costs: Subsequent Years $633 to $1,070 $983 to $1,475 $5,983 to $6,475 -

Number of Affected Firms 8 6 3 17

Total Year 1 Costs $13,480 $12,540 $81,270 $107,290

Total Costs: Subsequent Years $5,064 to $8,560 $5,898 to $8,850 $17,949 to $19,425 $28,911 to $36,835

Total Annualized Costs (30-Years, 3 

percent discount rate) $6,303 $6,755 $20,477 $33,535 

Total Annualized Costs (30-Years, 7 

percent discount rate) $6,320 $6,706 $21,416 $34,443 

The rule will affect an estimated nine small entities in the U.S. – four accreditation bodies and 

five TPCs. Some of the small entities are expected to be businesses, and others to be non-profit 

organizations. The rule’s impacts on small entities are analyzed by determining the ratio of costs to 

revenues for small businesses, and the ratio of costs to expenses for small non-profit organizations. The 

cost impacts are then categorized as being under one percent, between one and three percent, and over 

three percent.

As shown in Table 1-6, there five small non-profits predicted to be affected by the rule, all of 

which are estimated to have cost impacts of less than one percent of expenses. Four small businesses 

are predicted to be affected by the rule; two of them are estimated to have cost impacts of less than

one percent of revenues, and two are estimated to have cost impacts between one percent and three 

percent of revenues. No small entities are predicted to have cost impacts over three percent.
TSCA Title VI Proposed TPC Rule Economic Analysis 7

Table 1-6: Summary of Small Entity Impacts

Entity Type

Number of U.S. Entities that 

are Small

Estimated Number of Small Entities with Impacts

Under One 

Percent

Between One and 

Three Percent

Over Three Percent

TPCs

Non-profit 2 2 0 0

Business 3 1 2 0

ABs

Non-profit 3 3 0 0

Business 1 1 0 0

Combined

Non-profit 5 5 0 0

Business 4 2 2 0

Total 9 7 2 0
TSCA Title VI Proposed TPC Rule Economic Analysis 8

2 Certification System 

2.1 Certification System Framework

The certification system under the proposed TSCA Title VI TPC rule is based on a framework of

international standards organizations and existing voluntary consensus standards, accreditation and 

inspection oversight organizations, accreditation bodies, and third party certifiers, as described below. 

See Figure 1 for a diagrammatic approach to the relationships between the organizations in the 

certification system framework.

The certification system under the TSCA Title VI TPC rule will be similar, although not 

identical, to that under the California Air Resources Board’s (CARB) Air Toxics Control Measure (ATCM) 

to reduce formaldehyde emissions from composite wood products. Under the CARB ATCM, 

manufacturers of composite wood products must have their compliance with the emission standards 

verified by a TPC approved by CARB. The CARB ATCM requires TPCs to: verify that composite wood 

product manufacturers are complying with the quality assurance requirements; verify formaldehyde 

emission test results; work with manufacturers to establish quality control limits for each product type 

and production line; provide independent inspections and audits of manufacturers and records; use 

laboratories that are certified by an accreditation body that is a signatory to the International 

Laboratory Accreditation Cooperation Mutual Recognition Arrangement; and provide an annual report 

to CARB. In order to implement the ATCM, CARB directly evaluates and approves TPCs seeking to 

participate in the program.

2.1.1 International Standards Organizations

The International Organization for Standardization, known as ISO, is a non-governmental 

international standard-setting body comprising representatives from various national standards 

organizations. The organization promulgates worldwide proprietary industrial and commercial 

standards. The International Electrotechnical Commission (IEC) is a non-profit, non-governmental 

international standards organization that prepares and publishes International Standards for electrical, 

electronic and related technologies. The IEC cooperates with the ISO when appropriate. The use of the 

ISO/IEC prefix covers publications from ISO/IEC Joint Technical Committee on Information Technology, 

as well as conformity assessment standards developed by ISO’s committee on conformity assessment 

(CASCO).
TSCA Title VI Proposed TPC Rule Economic Analysis 9

The ISO/IEC standards relevant to the TSCA Title VI TPC rule include ISO/IEC Guide 65, which 

specifies requirements for bodies operating product certification systems; ISO/IEC 17011, which 

specifies general requirements for accreditation bodies accrediting conformity assessment bodies; 

ISO/IEC 17020, which specifies requirements for competence of calibration and testing laboratories; and 

ISO/IEC 17025, which specifies the general requirements for laboratories to demonstrate they are 

competent to conduct testing and/or calibrations, including sampling.

2.1.2 Accreditation and Inspection Oversight Organizations 

Accreditation and inspection oversight organizations ensure that their accreditation body 

members only accredit laboratories that are competent to do the work they undertake and are not 

subject to conflicts of interest. They also establish mutual recognition arrangements among 

accreditation bodies to ensure that the results from accredited laboratories will be accepted anywhere 

in the world. Examples of accreditation and inspection oversight organizations include the International 

Accreditation Forum, Inc. (IAF), and the International Laboratory Accreditation Cooperation (ILAC). 
TSCA Title VI Proposed TPC Rule Economic Analysis 10

Figure 1. TSCA Tile VI Proposed Third-Party Certification Framework

International Standards 

Organizations

Develop consensus-based international 

standards for quality management

and conformity assessment

Accreditation and Inspection

Oversight Organizations 

Ensure competency of Accreditation 

Bodies and their conformance with 

international standards:

 Ensures AB conformance to 

ISO/IEC 170111

 Ensure ABs are qualified to oversee 

TPC conformance to ISO/IEC Guide 65

ISO/IEC17020 and/or ISO/IEC 17025

Accreditation Bodies

Ensure competency of TPCs; verify 

accuracy of emission test procedures;

monitor quality assurance programs, audit 

and inspect TPCs and panel producers:

 Management systems conform to 

International Organization for

Standardization (ISO) 

International Electrotechnical 

International Accreditation 

Forum, Inc (IAF) 

or equivalent organization

 Ensures AB conformance to 

ISO/IEC 170111

International Laboratory 

Accreditation Cooperation (ILAC) 

or equivalent organization

 Ensures AB conformance to ISO/IEC 

170111

AB Type #3 

Product & Lab 

Accreditation Body

 Recognition Agreement

with EPA 

 Signatory to IAF MLA and 

AB Type #2 Laboratory 

Accreditation Body

 Recognition Agreement

with EPA

 Signatory to ILAC MRA or 

equivalent

AB Type #1 

Product 

Accreditation Body

 Recognition Agreement

with EPA
TSCA Title VI Proposed TPC Rule Economic Analysis 11

ISO/IEC 17011

 Ensure TPC conformance to 

applicable ISO/IEC Guides & Standards

Third Party Certifiers

Ensure that panel producers are in 

compliance with statutory 

formaldehyde emission standards:

 Management systems conform to 

ISO/IEC Guide 65

 Conform to applicable ISO/IEC 

Guides & Standards for

Product & Laboratory Certification

and Inspections

Composite Wood

Product Panel Producer

1

ISO/IEC 17011 – General Requirements for Accreditation Bodies Accrediting Conformity Assessment Bodies

2MLA – IAF’s Multilateral Recognition Arrangement requires AB signatories to demonstrate they are capable of accrediting product certification 

bodies in conformance with ISO/IEC Guide 65 – General Requirements for Bodies Operating Product Certification Systems and ISO/IEC 17020 –

General Criteria for the Operation of Various Types of Bodies Performing Inspection.

3MRA – ILAC’s Mutual Recognition Arrangement requires AB signatories to demonstrate they are capable of accrediting testing laboratories in 

conformance with ISO/IEC 17025 – General Requirements for the Competence of Testing and Calibration Laboratories. 

TPC #2

Accredited by AB #3 (acting as 

TPC #1

Accredited by AB #1 (Product AB) & 

Panel Producer #1 Panel Producer #2 Panel Producer #3 Panel Producer #4
TSCA Title VI Proposed TPC Rule Economic Analysis 12

2.1.3 Accreditation Bodies

An accreditation body (AB) is an organization that provides an impartial verification of the 

competency of a laboratory or TPC. In the context of formaldehyde and composite wood products, ABs 

ensure that TPCs can verify the accuracy of the emission test procedures used by composite wood 

product manufacturers to conduct formaldehyde emissions tests; monitor manufacturer quality 

assurance programs; and provide independent audits and inspections of manufacturers’ mills and 

testing facilities. There are ABs located throughout the world. ABs in the U.S. that are IAF or ILAC 

signatories include the AIHA Laboratory Accreditation Program (AIHA-LAP), the American Association for 

Laboratory Accreditation (A2LA), the American National Standards Institute (ANSI), Forensic Quality 

Services (FQS), the International Accreditation Service (IAS), the Laboratory Accreditation Bureau (L-AB), the National Voluntary Laboratory Accreditation Program (NVLAP), and Perry Johnson Laboratory 

Accreditation, Inc. (PJLA).

The proposed TSCA Title VI TPC rule requires ABs to be either a signatory to IAF’s Multilateral 

Recognition Arrangement (MLA) or the equivalent for inspection and lab competency; ILAC’s Mutual 

Recognition Arrangement (MRA) or the equivalent for product certification competency; or both. An AB 

that is an IAF signatory is responsible for ensuring that the TPC is in conformity with ISO/IEC Guide 65 

and ISO/IEC 17020. An AB that is an ILAC signatory is responsible for ensuring that a TPC is in conformity 

with ISO/IEC 17025. 

Thus, TPCs will need to be accredited by two ABs unless their AB is a signatory to both ILAC and 

IAF (or equivalent oversight bodies). In the TSCA Title VI program, a Product AB is an organization that is 

a signatory to the IAF MLA or the equivalent, and that can verify the accuracy of the test procedures and 

facilities used by manufacturers to conduct tests, monitor manufacturer quality assurance and quality 

control programs, and provide audits and inspections. A Laboratory AB is an organization that is a 

signatory to the ILAC MRA, or the equivalent, and that is qualified to verify that testing and calibration 

laboratories can operate a quality management system, are technically competent, and are able to 

generate technically valid emissions results.

2.1.4 Third Party Certifiers 
TSCA Title VI Proposed TPC Rule Economic Analysis 13

The third-party certifiers (TPCs) are responsible for activities such as regularly auditing 

manufacturers, conducting and verifying formaldehyde emissions tests, and ensuring that manufacturer 

quality assurance and quality control procedures and testing complies with TSCA Title VI TPC rule. 

Specific requirements include verifying that composite wood product manufacturers have adequate 

quality assurance controls and are complying with quality assurance and quality control requirements; 

verifying quality control test results compared with ASTM E-1333-96 test results by having laboratories 

conduct quarterly tests and evaluate test method equivalence; reviewing applications from 

manufacturers for reduced testing; working with manufacturers to establish quality control limits, and, if 

applicable, other limits for each product type and production line; informing manufacturers of criteria 

that will be used to determine if product lots are consistently exceeding the applicable quality control 

limit; inspecting and auditing manufacturers and their records at least quarterly; using a testing 

laboratory or laboratories that comply with ISO/IEC 17025; certifying composite wood product types 

that comply with requirements under TSCA Title VI; following ISO/IEC Guide 65; following ISO/IEC 17020 

in the carrying out of their inspections of the manufacturers; providing an approved TPC number 

(supplied by the accrediting AB) to the manufacturer for labeling and recordkeeping; and using

laboratories that participate in an annual inter-laboratory comparison or proficiency testing program.

In the example shown in Figure 1, TPC #1 is accredited by two ABs: AB #1 (which is a signatory 

to the IAF MLA and acts as the Product AB) and AB #2 (which is a signatory to the ILAC MRA and acts a 

Laboratory AB). TPC #2 is accredited by a single AB, AB #3, which is a signatory to both the IAF MLA and 

the ILAC MRA and acts as both a Product AB and a Laboratory AB. 

2.2 Profile of Third Party Certifiers and Accreditation Bodies

2.2.1 Third Party Certifiers

CARB has approved nine TPCs located in the U.S. (although most of these U.S. TPCs provide 

services internationally). Two of these TPCs are non-profit organizations, and the rest are businesses. 

Table 2-1 lists the domestic TPCs approved by CARB, their NAICS code, the type of organization, the 

sales volume or expenditures and the number of employees for the TPC or its parent organization, the 

U.S. Small Business Administration’s size threshold for the NAICS code, and the TPC’s small entity status. 

This analysis assumes that 9 U.S. entities will act as TPCs under the TSCA Title VI program, and 

uses existing CARB TPCs as a proxy for their size and characteristics, but that does not mean that all of 
TSCA Title VI Proposed TPC Rule Economic Analysis 14

the CARB TPCs will become TPCs under Title VI. In reality, some of the CARB TPCs may choose not to 

participate in the federal program, and/or new entities may apply that are not part of the CARB 

program.

Size information was available for four of the nine U.S. TPCs, including the two non-profits. The 

size of the TPCs ranges from a non-profit with 10 employees and $1.6 million in expenditures to a 

business with 2,500 employees in 125 offices with parent company that manages $3.1 billion in assets. 

Under the Regulatory Flexibility Act (RFA), unless an agency establishes an alternate definition, 

the term “small organization” means any not-for-profit enterprise which is independently owned and 

operated and is not dominant in its field. The RFA does not provide any guidance on how to judge 

whether an organization is dominant in its field. Non-profit TPCs and accreditation bodies perform the 

same activities (such as conducting and verifying formaldehyde emissions tests, accrediting, and 

auditing) as their for-profit counterparts. In order to interpret the RFA criteria for small organizations 

and treat all affected entities consistently, this analysis determines the size status of non-profits by 

applying the SBA size thresholds for the NAICS codes the non-profits are classified in. 

Based on the data in Table 2-1, the two U.S. TPCs that are non-profits are classified as small

entities, and two of the businesses are classified as large. The size status for five CARB TPCs could not 

be determined using the data in Table 2-1, so the small entity analysis in Section 4.2 estimates a generic 

distribution of sizes based on Census data for the relevant NAICS codes. 

TPCs come from a diverse set of industries – the six U.S.-based CARB TPCs for which Dun & 

Bradstreet listed an industry classification fall into five different NAICS codes. Thus, the firms that are 

likely to seek TPC accreditation may be very different from each other in terms of size, organization, and 

financial condition. Table 2-2 presents key industry summary statistics for these NAICS codes. However, 

the domestic TPCs approved by CARB represent a very small share of the 142,000 firms in these 

industries. And comparing Table 2-1 and Table 2-2, the CARB TPCs appear to be larger than the average 

firms in these industries. Thus, these Census statistics may not be representative of current CARB TPCs 

or potential new TSCA Title VI TPCs. 
TSCA Title VI Proposed TPC Rule Economic Analysis 15

Table 2-1: CARB-Approved Third Party Certifiers Based in the U.S.

Company Name

NAICS

code

Organization 

Type

Annual Sales 

Volume or 

Expenditures

1

(millions $)

Total Employees

SBA Size 

Threshold: 

Revenues ($ 

Millions) or 

Employees

Small Entity 

Status 

Certification Services 

International, LLC

Unknown Unknown Unknown Unknown Unknown Unknown 

Composite Panel 

Association North 

America, Inc. (CPA)

813910 Non-Profit $3.0 14 $7.0 Small 

Forestwood 

Industries, Inc.

Unknown Unknown Unknown Unknown Unknown Unknown 

Hardwood Plywood 

and Veneer 

Association (HPVA)

813910 Non-Profit $1.6 10 $7.0 Small

NTA Incorporated

541330

Private 

Company

$5.4 80 $4.5 Large 

PFS Corporation

541611

Private 

Company

Unknown

According to 

company website, 

more than 100 

employees

$7.0

Unknown

Professional Service 

Industries, Inc. (PSI), 

owned by Olympus 

Partners

Unknown

Private 

Company

Unknown, but 

Olympus Partners 

website reports 

they manage $3.1 

billion in assets.

Unknown, but PSI 

website reports 

they have more 

than 2,500 

employees in 125 

offices 

Unknown

Assumed to 

be large 

because of 

reported 

assets. 

Scientific 

Certification 

Systems (SCS)

541380

Private 

Company

Unknown

SCS web site lists 

87 employees

$12.0

Unknown 

TIMBERCO (dba 

TECO)

561990

Private 

Company

Unknown 31 $7.0 Unknown 

1

Annual sales volume is reported for businesses, and annual expenditures are reported for non-profits

Sources: California Air Resources Board (CARB) 2011, Dun & Bradstreet 2011, U.S. Small Business Administration 2010 (size 

standards), and company web sites for data on their sales volume and employees (PSI 2012, PFS 2012, SCS 2012a and SCS 2012b)
TSCA Title VI Proposed TPC Rule Economic Analysis 16

Table 2-2: Industry Summary Statistics for NAICS Identified for U.S. Third Party Certifiers

NAICS Firms

EstablishmentsRevenues 

($1000)

Number of

Employees

Average 

Revenues 

per Firm 

($1000)

Average 

Employees 

per Firm

541330 - Engineering services 47,714 58,391 $187,531,866 977,031 $3,930 20

541380 - Testing laboratories 5,288 6,549 $12,386,831 106,618 $2,342 20

541611 - Administrative 

management consulting services 59,612 61,583 $67,994,053 351,829 $1,141 6

561990 - All other support services 12,888 14,539 $20,897,346 195,544 $1,621 15

813910 - Business associations 16,418 17,028 $22,482,137 116,055 $1,369 7

Total 141,920 158,090 311,292,233 1,747,077 $2,193 12

Note that TPCs could potentially be classified in additional NAICS as well; as a result, this list may not be comprehensive.

Sources: U.S. Census Bureau 2010a; U.S. Census Bureau 2010b; U.S. Census Bureau 2010c; U.S. Census Bureau 2010d

Because Executive Order 12866, the Regulatory Flexibility Act, and the Unfunded Mandates 

Reform Act are all focused on entities located in the U.S., this analysis estimates costs and small entity 

impacts based on the expected number of domestic entities. But because the approval requirements 

for information collection requests under the Paperwork Reduction Act is not limited to U.S. entities, the 

reporting and recordkeeping burden of the rule is calculated for both foreign and domestic entities. 

Therefore, the analysis estimates the number of TPCs and ABs in other countries that are expected to 

participate in the Title VI program.

As shown in Table 2-3, there are a total of 27 CARB approved TPCs outside of the U.S., bringing 

the total number of CARB approved TPCs to 36. For the purpose of calculating reporting and 

recordkeeping burden under the Paperwork Reduction Act in Section 4.1, this analysis assumes that

there will be 9 domestic and 27 foreign TPCs under the Title VI program, the same number as under the 

CARB program. 
TSCA Title VI Proposed TPC Rule Economic Analysis 17

Table 2-3: CARB-Approved Third Party Certifiers by Country

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

 Sub-total for TPCs outside the U.S. 27

United States 9

 Total 36

Source: California Air Resources Board (CARB) 2011

2.2.2 Accreditation Bodies

There are eight ABs in the U.S. that are currently IAF or ILAC signatories. Table 2-4 lists the 

domestic ABs, their NAICS code, the type of organization, the sales volume or expenditures and the 
TSCA Title VI Proposed TPC Rule Economic Analysis 18

number of employees for the AB or its parent organization, the U.S. Small Business Administration’s size 

threshold for the NAICS code, and the AB’s small entity status. 

This analysis assumes that 8 U.S. ABs will participate in the TSCA Title VI program, and uses the 

characteristics of the ABs in Table 2-4 as proxies to estimate the impacts of the rule. This assumption 

may overestimate the number of affected entities, because some ABs that are IAF or ILAC signatories 

may not choose to participate in the TSCA Title VI program.1 And it is unlikely that additional bodies will 

become signatories as a result of the TSCA Title VI TPC rule, because becoming a signatory to IAF, ILAC, 

or an equivalent organization is a time-intensive process that may take up to a year to complete

(Personal Communication with IAS 2011). 

Five of the domestic ABs that are IAF or ILAC signatories are non-profit organizations, so this 

analysis assumes that five similarly sized non-profit ABs will participate in the TSCA Title VI program. 

Under the Regulatory Flexibility Act (RFA), unless an agency establishes an alternate definition, the term 

“small organization” means any not-for-profit enterprise which is independently owned and operated 

and is not dominant in its field. The RFA does not provide any guidance on how to judge whether an 

organization is dominant in its field. Non-profit TPCs and accreditation bodies perform the same 

activities (such as conducting and verifying formaldehyde emissions tests, accrediting, and auditing) as 

their for-profit counterparts. In order to interpret the RFA criteria for small organizations and treat all 

affected entities consistently, this analysis determines the size status of non-profits by applying the SBA 

size thresholds for the NAICS codes the non-profits are classified in. This results in an estimate that 

three small non-profits and one small business will participate in the TSCA Title VI program as ABs.

 

1

For example, Forensic Quality Services does not appear to accredit any labs providing product or environmental 

testing, and states that its mission is “to provide training, education, quality assurance management and accreditation 

for providers of forensic science testing services to federal, state and local law enforcement agencies” (IRS 2010). So 

FQS seems unlikely to serve as an accreditation body for TPCs testing formaldehyde from composite wood products.
TSCA Title VI Proposed TPC Rule Economic Analysis 19

Table 2-4: U.S. Accreditation Bodies that are IAF or ILAC Signatories

Company Name

NAICS

code

Organization Type

Sales Volume / 

Expenditures 

($ Millions)1

Total 

Employees

SBA Size 

Threshold: 

Revenues 

($ Millions) or 

Employees

Small 

Entity 

Status

AIHA Laboratory Accreditation 

Programs, LLC 2 561990 Non-Profit $14.9 63 $7.0 Large

American Association For 

Laboratory Accreditation

813920 Non-Profit $10.6 48 $14.0 Small

American National Standards 

Institute (ANSI)

813910 Non-Profit $31.3 122 $7.0 Large

Forensic Quality Services, Inc. 541990 Non-Profit $0.6 4 $7.0 Small

International Accreditation 

Service (IAS)

813319 Non-Profit $2.5 54 $7.0 Small

Laboratory Accreditation 

Bureau

541712

Private 

Company

$0.4 6 500 employees Small

National Voluntary Laboratory 

Accreditation Program 

(NVLAP), operated by the 

National Institute of Standards 

and Technology (NIST)

-

Federal 

Government

- - - Large

Perry Johnson Laboratory 

Accreditation Inc.3 541618

Private 

Company

$17.0 147 $7.0 Large

Notes: 1. Sales volume data are presented for businesses. Expenditure data are presented for non-profits.

2. Size data for AIHA Laboratory Accreditation Programs, LLC is based on the size of the parent organization, the American 

Industrial Hygiene Association (AIHA).

3. Sales volume and employee size data for Perry Johnson Laboratory Accreditation Inc. include D&B sales and employee data 

for "Perry Johnson Laboratory Accreditation" and the American Business Directory sales data for the related companies 

"Perry Johnson Inc" and "Perry Johnson Registrars".

Sources: American Business Directory 2011 (sales and employee data for Perry Johnson Inc. and Perry Johnson Registrars), Dun 

& Bradstreet 2011 (business sales volumes and employee data and NAICS codes for all entities), U.S. Internal Revenue Service 

2009, 2010 (non-profit expenditures and employees), U.S. Small Business Administration 2010 (size standards), and company 

web sites for AIHA and Perry Johnson for relationships among entities in their family tree (AIHA-LAP LLC 2012, Perry Johnson & 

Associates 2012).
TSCA Title VI Proposed TPC Rule Economic Analysis 20

Table 2-5 lists the foreign countries with CARB-approved TPCs, the ILAC or IAF signatory ABs in 

that country, and their status as signatories for ISO/IEC Guide 65, 17020, and 17025. It is not known 

which ABs these CARB-approved TPCs use. However, every country with a CARB approved TPC also has 

an AB that is an IAF or ILAC signatory, and most of the ABs are signatories to all three relevant ISO/IEC 

standards. The exceptions are Australia, New Zealand, and Hong Kong, each of which lacks an AB that is 

a signatory for ISO/IEC Guide 65. However, there is a joint AB for Australia and New Zealand that is a 

signatory for ISO/IEC Guide 65, and there is an AB in China that is a signatory for ISO/IEC Guide 65. 

Therefore, each foreign TPC could use a local AB for the TSCA Title VI program.

There are a total of 17 ABs shown in Table 2-5 that are IAF or ILAC signatories and are located in 

foreign countries with CARB-approved TPCs. While EPA does not know whether these ABs accredit 

CARB TPCs or whether some CARB TPCs use ABs located outside their own country, for the purpose of 

calculating reporting and recordkeeping burdens under the Paperwork Reduction Act, the analysis in 

Section 4.1 assumes that there will be 17 foreign ABs that participate in the TSCA Title VI program.
TSCA Title VI Proposed TPC Rule Economic Analysis 21

Table 2-5: Summary of IAF or ILAC Signatory Accreditation Bodies in Foreign Countries with 

CARB TPCs

Country

Number of CARBapproved TPCs in 

Country Accreditation Body

ISO/IEC

Guide 65

ISO/IEC

17020

ISO/IEC

17025

1. Australia 1

National Association of Testing 

Authorities, Australia (NATA) X X

2. Australia and 

New Zealand

Joint Accreditation System of Australia 

and New Zealand (JAS-ANZ) X

3. Austria 1

Bundesministerium fur Wirtschaft,

Familie und Jugend (BMWA) X X X

4. Belgium 1 Belgian Accreditation Structure (BELAC) X X X

5. China 5

China National Accreditation Service for

Conformity Assessment (CNAS) X X X

6. Czech 

Republic 1 Czech Accreditation Institute (CAI) X X X

7. Denmark 1 Danish Accreditation (DANAK) X X X

8. France 1

Comite Francais d’Accreditation 

(COFRAC) X X X

9. Germany 4

Deutsche Akkreditierungsstelle GmbH

(DakkS) X X X

10. Hong Kong 3 Hong Kong Accreditation Service (HKAS) X X

11. Indonesia 1

National Accreditation Body of Indonesia

(KAN) X X X

12. Italy 3

Sistema Italiano di Accreditamento

(ACCREDIA) X X X

13. New Zealand 1

International Accreditation New Zealand

(IANZ) X X

14. Poland 1 Polish Centre for Accreditation (PCA) X X X

15. Spain 1 Entidad Nacional de Acreditacion (ENAC) X X X

16. Sweden 1

Swedish Board for Accreditation and

Conformity Assessment (SWEDAC) X X X

17. Taiwan 1 Taiwan Accreditation Foundation (TAF) X X X
TSCA Title VI Proposed TPC Rule Economic Analysis 22

Result: there are a total of 17 ABs that are IAF or ILAC signatories in foreign countries with CARB-approved TPCs 

Sources: IAF 2011; ILAC 2011; CARB 2011.
TSCA Title VI Proposed TPC Rule Economic Analysis 23

3 Costs of the TSCA Title VI TPC Rule

This section describes the proposed regulatory requirements for accreditation bodies and TPCs 

and presents the estimated costs for obtaining and maintaining accreditation.

3.1 Proposed Rule Requirements

EPA is proposing to administer the TPC program by developing recognition agreements with 

accreditation bodies. The ABs would then process TPC applications and oversee the TPCs. 

3.1.1 Requirements for Accreditation Bodies 

As described in Section 2.1, the proposed rule would require ABs to be either a signatory to the 

International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA) or 

the equivalent for inspection and lab competency, the International Accreditation Forum, Inc. (IAF) 

Multilateral Recognition Arrangement (MLA) or the equivalent for product certification competency, or 

both. EPA would also require that ABs:

 Conform with ISO/IEC 17011, which lists the basic criteria for an international accreditation 

body who reviews and audits the TPC2;

 Submit an application to enter into a recognition agreement with EPA. The application 

would include their contact information; documentation of their IAF MLA, ILAC MRA, or 

equivalent signatory status; and a description of any other qualifications related to 

performing product or laboratory accreditation. The recognition agreement would need to 

be renewed every three years;

 Notify EPA in the following instances: loss of signatory status; TPC application; TPC 

accreditation; TPC compliance failure; organization policy or management structure changes 

 

2

 In order to become an IAF or ILAC signatory, an AB is reviewed by its peers to ensure that it is in compliance with 

ISO/IEC 17011, as well as to verify that it is qualified to ensure TPC compliance with other voluntary consensus 

standards. Therefore, it is assumed that IAF or ILAC signatories are already in conformance with ISO/IEC 17011, and 

would not incur additional costs for conformance as a result of this rule.
TSCA Title VI Proposed TPC Rule Economic Analysis 24

that could adversely affect accreditation program; and with checklists and other records 

documenting compliance with systems audits and on-site assessments;

 Notify TPCs if the AB withdraws or is removed from the program;

 Maintain records documenting TPC accreditation applications, and checklists and other 

records documenting compliance with systems audits and on-site assessments. Applications 

must be retained for three years from the date they were submitted; and

 Provide an annual report to EPA with the number of TPC applications received; the number 

of TPCs approved and denied; the names and contact information of all accredited TPCs; the 

number and locations of systems audits and on-site assessments; and the results of 

accredited TPC proficiency testing and inter-laboratory comparisons.

3.1.2 Requirements for TPCS

The proposed rule would require that TPCs:

 Conform to ISO/IEC Guide 65 (general requirements for bodies operation product 

certification systems) and ISO/IEC 17020 (general criteria for the operation of various types 

of bodies performing inspection);

 Use a laboratory that conforms to ISO/IEC 17025 (requirements for competence of

calibration and testing laboratories); and

 Be qualified to administer the approved formaldehyde test methods they will be using.

EPA would also require the following recordkeeping and reporting activities for TPCs:

 Submit an application to the Product accreditation body every three years with domestic 

contact information; type of composite wood product(s) intended to be certified; and a 

description of experience with ISO/IEC Guide 65, ISO/IEC 17020, and the product(s) the 

intended to be certified;

 Submit an application to the Laboratory accreditation body every three years with domestic 

contact information; and a description of experience with test method ASTM E-1333-96 and 

in evaluating correlation between tests, performing formaldehyde tests on composite wood 

products, and operating or using laboratories that comply with ISO/IEC 17025;

 Maintain records for three years that document the certified manufacturers and products, 

including those approved for reduced testing; the results of inspections, audits, and 

emissions tests; the laboratories and tests used; and the methods and results for 

establishing test method correlations;
TSCA Title VI Proposed TPC Rule Economic Analysis 25

 Provide an annual report to its accreditation body or bodies with a list of manufacturers and 

products certified during the previous year; a list of non-complying products or events; a list

of laboratories and tests used by the TPC; and the results of inter-laboratory comparison or 

proficiency tests for laboratories used by the TPC; and

 Inform accreditation body or bodies within 30 days of any changes in personnel 

qualifications, procedures, or laboratories used by the TPC.

3.2 Wage Rates Used in the Analysis

The proposed rule involves activities that may require efforts by employees in three labor 

classifications: managerial, technical, and clerical. Costs for each activity are calculated by estimating 

the labor hours required in each labor category and multiplying those burdens by the wage rate for each 

labor category. This section summarizes the estimated wage rate in each labor category. Additional 

details are provided in Appendix A.

Loaded wage rates for managerial, technical, and clerical personnel are derived by combining 

data on wages and fringe benefits with estimates of overhead rates, following the methodology 

described in “Wage Rates for Economic Analysis of the Toxics Release Inventory Program” (EPA, 2002b).

Wage data for each labor category are provided by the Employer Costs for Employee Compensation 

(ECEC) Supplemental Tables available on the BLS website (U.S. Bureau of Labor Statistics (BLS) 2011). 

The loaded wage rate for managerial labor is $66.78; for technical labor, $56.31; and for clerical labor, 

$25.65. Table 3-1 presents the basic data used to calculate the loaded wage rates for all three 

categories of labor.
TSCA Title VI Proposed TPC Rule Economic Analysis 26

Table 3-1: Loaded Industry Wage Rates, 2010$

Labor Category

B

ase Wages

Fringe benefits 

+ overhead factor

Load

ed Wages

Managerial $42.42a1.57b,c $66.78

Professional/

Technical

$36.57a1.54b,c $56.31

Clerical $16.72a1.53b,c $25.65

Notes:

a Base wages are estimated in the ECEC Supplemental Tables (U.S. Bureau of Labor Statistics (BLS) 2011).

b Fringe benefits are estimated in the ECEC Supplemental Tables (U.S. Bureau of Labor Statistics (BLS) 2011).

c An overhead rate of 17% of base wages is used here, based on methodology and assumptions in U.S. 

Environmental Protection Agency (EPA) 2002a, b.

Source:U.S. Bureau of Labor Statistics (BLS) 2011, U.S. Environmental Protection Agency (EPA) 2002a, b.

3.3 Costs to Accreditation Bodies

The proposed TSCA Title VI TPC rule requires accreditation bodies to be signatories to IAF, ILAC 

or equivalent oversight bodies. The process of becoming a signatory is time-intensive and may take up 

to a year to complete, so it is unlikely that additional bodies will become signatories as a result of the 

TSCA Title VI TPC rule (Personal Communication with IAS 2011). Thus, costs are estimated assuming that 

only existing IAF and ILAC signatories will serve as accreditation bodies for the third-party certifiers 

under this regulation. Therefore, the estimated incremental costs to the accreditation bodies related to 

the proposed rule will include:

1. Rule Familiarization: Reading the rule in order to understand the requirements;

2. Application Submission: Submitting an application to enter into a recognition 

agreement with EPA;

3. Prepare Recognition Agreement: If the application is approved, enter into a recognition 

agreement with EPA;

4. EPA Notification: Provide EPA with notifications in the following instances: loss of 

signatory status; TPC application; TPC accreditation; TPC compliance failure; 

organization policy or management structure changes that could adversely affect 
TSCA Title VI Proposed TPC Rule Economic Analysis 27

accreditation program; and provide checklists and other records documenting 

compliance with systems audits and on-site assessments;

5. TPC Notification: Provide TPCs with notifications if the AB withdraws or is removed 

from the program;

6. Recordkeeping: Maintain records documenting TPC accreditation applications, and 

checklists and other records documenting compliance with systems audits and on-site 

assessments. Applications must be retained for three years from the date they were 

submitted; and

7. Reporting: Provide an annual report to EPA with the number of TPC applications 

received; the number of TPCs approved and denied; the names and contact information 

of all accredited TPCs; the number and locations of systems audits and on-site 

assessments; and the results of accredited TPC proficiency testing and inter-laboratory 

comparisons.

Accreditation bodies are required to renew their recognition agreement with EPA every three 

years. This analysis assumes that accreditation bodies incur application submission and recognition 

agreement preparation costs in the first year and subsequently every three years thereafter. Costs

associated with EPA notification, TPC notification, recordkeeping and reporting are assumed to be 

incurred annually. Rule familiarization is a one-time cost incurred in the first year. As a result, 

accreditation bodies are expected to incur costs of $1,685 in the first year, $1,070 in reapplication years, 

and $633 in the non-reapplication years, as summarized below in Table 3-2 and described in more detail 

in Appendix B (see Table B-1 and Table B-3). This analysis assumes that eight organizations in the U.S. 

will become accreditation bodies, resulting in estimated total annualized costs of $6,303 per year at a 

three percent discount rate, and $6,320 per year at a seven percent discount rate.

Table 3-2: Costs for Accreditation Bodies

Type of Cost

Cost (2010$) 1

First Year Reapplication Years 2Non-Reapplication Years 3

Rule Familiarization $615 $0 $0

Application or Reapplication Process 1$88 $88 $0

Prepare Recognition Agreement $349 $349 $0

EPA Notification $57 $57 $57

TPC Notification $12 $12 $12
TSCA Title VI Proposed TPC Rule Economic Analysis 28

Recordkeeping $308 $308 $308

Reporting $256 $256 $256

Cost per Accreditation Body $1,685 $1,070 $633

Number of U.S. Accreditation Bodies 8 8 8

Total Costs for U.S. Accreditation Bodies $13,480 $8,560 $5,064

Total Annualized Costs (30 years, 3%) 4$6,303 

Total Annualized Costs (30 years, 7%) 4$6,320 

Notes: 

1 See Table B-1 and Table B-3 for detailed description of these estimates.

2

Under the proposed rule, accreditation bodies are required to reapply every three years. Reapplication is assumed to occur at

the end of years 3, 6, 9, 12, 15, 18, 21, 24, 27, and 30.

3

Non-reapplication years are years 2, 4, 5, 7, 8, 10, 11, 13, 14, 16, 17, 19, 20, 22, 23, 25, 26, 28, and 29.

4 Costs are annualized over thirty years for 3 and 7 percent discount rates using the following formula: 

(present discounted value of 30-year stream-of-costs)*(discount rate*(1+ discount rate)30)/((1+ discount rate)31-1). Rule 

familiarization, application costs, and recognition agreement costs are assumed to be incurred immediately and therefore are 

not discounted. Other costs are discounted assuming that they are incurred at the end of each year.

EPA is considering requiring accreditation bodies to submit their notifications and reports to the 

Agency electronically using the Central Data Exchange (CDX). Appendix C discusses the incremental 

change in costs if EPA finalizes a mandatory electronic reporting requirement. As shown in section 

C.1.4, the total annualized savings to U.S. accreditation bodies would be $1,193 per year at a 3 percent 

discount rate, and $1,146 per year at a 7 percent discount rate. 
TSCA Title VI Proposed TPC Rule Economic Analysis 29

3.4 Third-Party Certifier Costs

Costs that TPCs may incur under the proposed rule can be classified into five categories: (1) the 

cost of rule familiarization, (2) the cost of applying to the accreditation body in order to participate in 

the TSCA Title VI program, (3) the cost to obtain and maintain any necessary accreditations that the TPC 

does not already have, (4) the annual cost of providing notifications to manufacturers and of 

maintaining records, and (5) the cost of providing an annual report and other notifications to the AB or 

EPA. To the extent that requirements in the TSCA Title VI rule are similar to requirements in the CARB 

rule, CARB-approved TPCs will incur relatively little additional cost to comply with EPA’s rule.

Under the proposed rule, TPCs are required to apply for re-accreditation every three years. As a 

result, application and accreditation costs are incurred every third year. The costs associated with 

notifications, maintaining records, and providing an annual report are assumed to be incurred on an 

annual basis. Rule familiarization is a one-time cost incurred in the first year. Each of these types of 

costs is discussed in more detail in the subsections below.

3.4.1 TPC Rule Familiarization

The level of effort associated with rule familiarization was estimated based on professional 

judgment, and burden hours were multiplied by the corresponding labor category’s wage rate as 

derived in Section 3.2 (U.S. Bureau of Labor Statistics (BLS) 2011) to estimate costs. As shown in Table 

3-3 below, the total cost for each firm is estimated to be $615 in the first year.

Table 3-3: Application Process Burden and Costs for TPCs, by Activity

Activity

Clerical 

Burden/Cost

Technical 

Burden/Cost

Managerial 

Burden/Cost Total

(hours)1(2010$) (hours)1(2010$) (hours)1(2010$) (hours)1(2010$)

(a) (b) (c) (d) (e) (f) (g)=(a)+(c)+(e) (h)=(b)+(d)+(f)

Rule Familiarization 0.00 $0.00 5.00 $281.55 5.00 $333.90 10.00 $615 

Notes: 1. Burden hours are based on best professional judgment.
TSCA Title VI Proposed TPC Rule Economic Analysis 30

3.4.2 TPC Application Process

The application process for TPCs includes completing a form with standard information about 

the firm and also describing the firms experience with the ISO/IEC standards. The level of effort for 

these elements were estimated based on prior economic analyses (EPA 2011a), and burden hours were 

multiplied by the corresponding labor category’s wage rate as derived in Section 3.2 (U.S. Bureau of 

Labor Statistics (BLS) 2011) to estimate costs. As shown in Table 3-4 below, the total application cost for 

each firm is estimated to be $492 in reapplication years and $0 in non-reapplication years. For more 

information, see Appendix B.

A TPC must reapply every three years in order to participate in the TSCA Title VI program. TPCs 

that are approved by CARB will be grandfathered under the TSCA Title VI rule for one year, provided that 

they are compliant with all other aspects of the TSCA Title VI rule. To simplify the analysis, costs are 

calculated as though all Title VI TPCs are grandfathered in for one year, even though some of them may 

not have been approved by CARB. Thus, costs are calculated assuming that reapplication occurs every 

third year starting three years after the rule is promulgated (i.e., in years 4, 7, 10, etc.).
TSCA Title VI Proposed TPC Rule Economic Analysis 31

Table 3-4: Application Process Burden and Costs for TPCs, by Activity

Activity

Clerical Burden/Cost Technical Burden/Cost Managerial Burden/Cost Total

(hours)

(a)

(2010$)1

(b)

(hours)

(c)

(2010$)1

(d)

(hours)

(e)

(2010$)1

(f)

(hours)

(g)=(a)+(c)+(e)

(2010$)1

(h)=(b)+(d)+(f)

Product Accreditation Body Application Submission 

Company Information (Name, Address, 

Telephone Number, and Email Address of 

Primary Contact) and Type of Composite Wood 

Products Applicant Intends to Certify2

0 $0.00 0.04 $2.25 0.02 $1.34 0.06 $3.59 

Description of TPC's Experience or Ability in 

Product Certification and Complying with ISO/IEC 

Guide 653

0 $0.00 0.83 $46.74 0.51 $34.06 1.34 $80.80 

Description of TPC's Experience in the Composite 

Wood Product Industry with the Product(s) 

Intended to be Certified3

0 $0.00 0.83 $46.74 0.51 $34.06 1.34 $80.80 

Description of TPC's Ability to Inspect and 

Properly Train and Supervise Inspectors Pursuant 

to ISO/IEC 170203

0 $0.00 0.83 $46.74 0.51 $34.06 1.34 $80.80 

Laboratory Accreditation Body Application Submission

Company Information (Name, Address, 

Telephone Number, and Email Address of 

Primary Contact; if foreign, name and address of 

an agent for service located in the U.S.)2

0 $0.00 0.04 $2.25 0.02 $1.34 0.06 $3.59 

Description of TPC's Experience in Performing or 

Verifying Formaldehyde Testing on Composite 

0 $0.00 0.83 $46.74 0.51 $34.06 1.34 $80.80 
TSCA Title VI Proposed TPC Rule Economic Analysis 32

Wood Products3

Description of TPC's Experience Operating or 

Using Laboratories that Comply with ISO/IEC 

170253

0 $0.00 0.83 $46.74 0.51 $34.06 1.34 $80.80 

Description of TPC's Experience with Test 

Method ASTM E-1333-96 (2002) and Experience 

Evaluating Correlation between Test Methods3

0 $0.00 0.83 $46.74 0.51 $34.06 1.34 $80.80 

TOTAL – REAPPLICATION YEARS 0.00 $0.00 5.06 $284.93 3.10 $207.02 8.16 $492 

TOTAL – NON-REAPPLICATION YEARS 0.00 $0.00 0.00 $0.00 0.00 $0.00 0.00 $0

Notes: 1. Note that under the proposed rule, TPCs are required to apply for re-accreditation every three years. As a result, reapplication costs are incurred every third year. 

2. Based on the estimated burden associated with reporting “company information” (EPA 2011a). 

3. Based on the estimated burden associated with answering substantiation questions when making plant site confidentiality claims (EPA 2011a).

Source: EPA 2011a
TSCA Title VI Proposed TPC Rule Economic Analysis 33

3.4.3 TPCs Obtaining Accreditation for the Required Standards

Through a series of telephone interviews, representatives from six TPCs that have been 

approved by CARB for formaldehyde testing provided information about the accreditations they already 

had, and the costs of receiving and maintaining the accreditation. Several TPCs also spoke in general 

terms about the costs of accreditation. The information collected from each TPC is included in Table 

3-5.

As indicated in Table 3-5, the cost to TPCs of obtaining accreditation will depend on whether 

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 initial cost of obtaining a single 

accreditation 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 the firm needed to 

be newly accredited for all three relevant ISO/IEC standards (Guide 65, 17020, and 17025). Based on 

discussions with the six TPCs, the analysis assumes that two-thirds of the CARB-certified TPCs will 

already have all three accreditations in place and that one-third will need to obtain one additional 

accreditation from an AB. 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 additional accreditations.

In addition to obtaining the initial accreditation, the TPCs will need to maintain and renew their 

systems and testing certifications. (A typical accreditation lasts for two years.) Two of the six TPCs 

provided information on the cost of maintaining and renewing accreditations. They reported costs that 

ranged from $5,000 to $15,000 per year associated with maintaining certification, such as paying audit 

fees to their AB. Note that the systems and testing certifications for which the laboratories reported 

costs may cover more than the specific formaldehyde testing. Therefore, these estimates may overstate 

costs if the labs would incur these costs even if they were not acting as TPCs under TSCA Title VI. 

Because the audits include tests other than formaldehyde, this analysis uses $5,000 (the low end of the 

costs reported) as the annual reaccreditation cost for TPCs that need an additional accreditation. 

As discussed above, based on discussions with the six TPCs, the analysis assumes that two-thirds 

of the CARB-certified TPCs will already be maintaining all three of the relevant accreditations (i.e., 

ISO/IEC Guide 65, 17020, and 17025) and that one-third of TPCs will need to maintain a single additional 

accreditation in order to participate in the TSCA Title VI program. Thus, one-third of TPCs are assumed 

to incur an annual cost of $5,000 per year in subsequent years for maintaining one additional 

accreditation, while two-thirds of TPCs will not incur any additional costs associated with maintaining 
TSCA Title VI Proposed TPC Rule Economic Analysis 34

additional accreditations because they were already maintaining all of the necessary accreditations in 

the baseline.

In interviews with TPCs, three said they had excess capacity for additional testing and two said 

they could easily add extra capacity either by building additional chambers or subcontracting the work 

to accredited laboratories. For example, one said that while they currently have 3 small chambers, 

within two months they could add 25 small chambers that would allow them to do 100 tests per day. In 

addition, it would be possible to add large chamber capacity within a 3-6 month period. The firms 

indicated that if the new equipment added were similar to what they already had in place, their 

accreditation body would allow for desk audit approval (which could be done quickly, instead of 

requiring a site visit prior to approval, which would take more time). Therefore, this analysis assumes 

there is adequate existing testing capacity, and that no additional costs for adding additional testing 

capacity will be incurred. 
TSCA Title VI Proposed TPC Rule Economic Analysis 35

Table 3-5: CARB TPCs Estimates of Previous Accreditation Costs

TPC Estimated Cost of Accreditation Other Information

NSF International 1About $5,000 for application process and 

between $5,000 for approval of 10 test 

processes to $20,000 for approval of 100 test 

processes. (The tests are grouped in 

disciplines and priced for each discipline. For 

this conversation the representative was 

discussing batteries of tests, for example toys 

have 10 tests.)

Estimated that it would cost about $10,000 every 

two years to get reaccredited (or $5,000 a year 

average).

PSI, Inc. $5,000 to $6,000 if laboratory has 

accreditations, inspections, testing and 

quality systems in place. Estimated $50,000 

to $60,000 to develop the accreditations, 

inspections, testing and quality systems if 

they are not in place.

SCS International Estimated it cost about $9,000 to $15,000 to 

write manual and complete application. SCS 

already had the quality system in place.

Mentioned that CARB does not require ISO 

accreditation as long as the laboratory has 

demonstrated ISO equivalence. Getting ISO 

accreditation is expensive ($25,000). They do not 

have a lab but contract the testing portion out to 

labs that are ISO 17025 accredited.

NTA Incorporated Estimated it cost $10,000 to set up their 

CARB accredited program. They were already 

an ISO product certification firm.

Forestwood Industries, 

Inc

For CARB, they needed ISO 17020 and Guide 

65 which they did not have. Each cost 

between $20,000 and $30,000 to get. The 

application took one day to complete but 

gathering the information took longer.

PFS Corporation PFS is a product testing laboratory and had 

IAS approval for testing formaldehyde. The 

cost of a new accreditation is at least $2,550 

with $800 for additional fields of testing 

(formaldehyde could be considered a field) 

and another $250 for each facility.

It costs PFS about $15,000 to get an IAS on-site 

audit each year although the audit includes more 

than formaldehyde. The cost for a desk audit to 

add an additional small test chamber where 

existing small chambers have already been 

approved is $600, but it costs at least $2,000 for a 

standard inspection audit.

1

NSF International was approved as a TPC by CARB, but has subsequently withdrawn from the program.

Sources: Personal Communication with Forestwood Industries 2011, Personal Communication with NSF International 2011a, b, 

Personal Communication with NTA Inc. 2011, Personal Communication with PFS Corporation 2011, Personal Communication 
TSCA Title VI Proposed TPC Rule Economic Analysis 36

with PSI 2011, Personal Communication with SCS International 2011.
TSCA Title VI Proposed TPC Rule Economic Analysis 37

3.4.4 Annual Cost of TPCs Notifications Relating to Manufacturers

Under the proposed rule, TPCs would have to provide its third-party certifier number to any 

manufacturer receiving its TSCA Title VI certification services. And should a TPC withdraw from the 

program or lose its accreditation, it would be required to notify all manufacturers that receive its TSCA 

Title VI certification services. 

Upon request, TPCs must provide EPA with a list of the manufacturers and their product types 

certified, the results of inspections, audits, and emission tests conducted for each manufacturer and 

product type, the list of the TPCs laboratories, test methods, and test results, the methods and results 

for establishing test method correlations and equivalence and the list of manufacturers and products 

approved for reduced testing. As shown in Table 3-6 below, the sum of these costs is approximately 

$773 per firm per year in all years. For more information, see Appendix B.
TSCA Title VI Proposed TPC Rule Economic Analysis 38

Table 3-6: Annual Burden and Cost to TPCs of Notifications Relating to Manufacturers, by Activity

Activity

Clerical Burden/Cost Technical Burden/Cost Managerial Burden/Cost Total

(hours)

(a)

(2010$)

(b)

(hours)

(c)

(2010$)

(d)

(hours)

(e)

(2010$)

(f)

(hours)

(g)=(a)+(c)+(e)

(2010$)

(h)=(b)+(d)+(f)

Notifications to EPA 

Third Party Certifier Number10 $0.00 0.04 $2.25 0.02 $1.34 0.06 $3.59 

Withdraw from Program or Lose Accreditation10 $0.00 0.01 $0.56 0.005 $0.33 0.015 $0.90 

Recordkeeping and Reporting to EPA

List of Manufacturers and their Product Types 

(including Resins Used) Certified by TPC2 0.75 $19.24 1.5 $84.47 0.75 $50.09 3 $153.79 

Results of Inspections, Audits, and Emission Tests 

Conducted for Each Manufacturer and Product 

Type2

0.75 $19.24 1.5 $84.47 0.75 $50.09 3 $153.79 

List of the TPC's Laboratories, Test Methods 

(including Test Conditions and Conditioning 

Time), and Test Results2

0.75 $19.24 1.5 $84.47 0.75 $50.09 3 $153.79 

Methods and Results for Establishing Test 

Method Correlations and Equivalence2 0.75 $19.24 1.5 $84.47 0.75 $50.09 3 $153.79 

List of Manufacturers and Products Approved for 

Reduced Testing2 0.75 $19.24 1.5 $84.47 0.75 $50.09 3 $153.79 

TOTAL 3.75 $96.20 7.55 $425.14 3.775 $252.09 15.075 $773 
TSCA Title VI Proposed TPC Rule Economic Analysis 39

Notes: 1. Based on best professional judgment and rule requirements.

2. Based on the estimated burden associated with “recordkeeping” (EPA 2011a). 

Sources: BLS 2011, EPA 2011a
TSCA Title VI Proposed TPC Rule Economic Analysis 40

3.4.5 Cost of TPC Annual Reports and Notifications of Changes

Table 3-7 shows the cost of the required annual report to the accreditation bodies that lists the 

manufacturers and their products certified by TPCs during the previous year, the list of non-complying 

products or events by manufacturer, the list of laboratories and test methods used by the TPC, and the 

results of inter-laboratory comparison or proficiency testing for the laboratories used by the TPC. The 

cost of notifying the accreditation body of any changes in personnel, procedure, or laboratory changes is 

also included. The sum of these costs is approximately $210 per firm per year in all years. For more 

information, see Appendix B.
TSCA Title VI Proposed TPC Rule Economic Analysis 41

Table 3-7: Annual TPC Burden and Costs for Reporting to Accreditation Body, by Activity

Activity

Clerical 

Burden/Cost

Technical 

Burden/Cost

Managerial 

Burden/Cost

Total

(hours)

(a)

(2010$)

(b)

(hours)

(c)

(2010$)

(d)

(hours)

(e)

(2010$)

(f)

(hours)

(g)=(a)+(c)+(e)

(2010$)

(h)=(b)+(d)+(f)

Annual Report to Accreditation Bodies

List of Manufacturers and their Products 

Certified by the TPC during the Previous Year 

(including Resins Used, and the Average and 

Range of Formaldehyde Emissions by 

Manufacturer, Resin, and Product Type)1

0.25 $6.41 0.5 $28.16 0.25 $16.70 1 $51.26 

List of Non-complying Products or Events by 

Manufacturer1 0.25 $6.41 0.5 $28.16 0.25 $16.70 1 $51.26 

List of Laboratories and Test Methods Used by 

the TPC1 0.25 $6.41 0.5 $28.16 0.25 $16.70 1 $51.26 

Results of Inter-Laboratory Comparison or 

Proficiency Testing for the Laboratories Used by 

the TPC1

0.25 $6.41 0.5 $28.16 0.25 $16.70 1 $51.26 

Accreditation Board Notification

Personnel Qualification Changes20 $0.00 0.02 $1.13 0.01 $0.67 0.03 $1.79 

Procedure Changes20 $0.00 0.02 $1.13 0.01 $0.67 0.03 $1.79 

Laboratory Change20 $0.00 0.02 $1.13 0.01 $0.67 0.03 $1.79 

TOTAL 1 $25.65 2.06 $116.00 1.03 $68.78 4.09 $210 
TSCA Title VI Proposed TPC Rule Economic Analysis 42

Notes: 1. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011a). Revised estimate based on best professional judgment.

2. Based on the estimated burden associated with reporting "company information" (EPA 2011a). 

Sources: EPA 2011a
TSCA Title VI Proposed TPC Rule Economic Analysis 43

3.5 Total Cost to TPCs 

3.5.1 Costs per TPC in the First Year 

Table 3-8 presents the estimated costs for TPCs in the first year. There are different cost 

estimates for TPCs that already have all of the necessary accreditations, and TPCs that need to obtain an 

additional accreditation. 

Table 3-8: Costs per TPC in the First Year

Type of Cost

Cost (2010$)1

TPCs with All Necessary 

Accreditations

TPCs Obtaining One 

Additional Accreditation

Rule Familiarization $615 $615 

Application Process $492 $492 

Obtaining Accreditation $0 $25,000 

Manufacturer Notification and Recordkeeping $773 $773 

Annual Report and Notifications of Changes $210 $210 

TOTAL $2,090 $27,090 

3.5.2 Costs per TPC in Subsequent Years

Table 3-9 presents the estimated costs incurred in subsequent years by TPCs. Again, there are 

different cost estimates for TPCs that already have all of the necessary accreditations, and TPCs that 

need to obtain an additional accreditation. And costs differ between years when the TPC must reapply 

to the accreditation body to participate in the TSCA Title VI program (which occurs every three years)

and the alternate years.
TSCA Title VI Proposed TPC Rule Economic Analysis 44

Table 3-9: Costs per TPC in Subsequent-Years

Type of Cost1

Cost (2010$)2

TPCs with All Necessary 

Accreditations

TPCs Obtaining One 

Additional Accreditation

Reapplication Process $492 $492 

Reaccreditation $0 $5,000 

Manufacturer Notification and Recordkeeping $773 $773 

Annual Report and Notifications of Changes $210 $210 

TOTAL – REAPPLICATION YEARS $1,475 $6,475 

TOTAL – NON-REAPPLICATION YEARS $983 $5,983

Notes: 1. Under the proposed rule, TPCs are required to apply for re-accreditation every three years. As a result, reapplication 

and reaccreditation costs are incurred every third year.

2. Costs may not sum due to rounding.

3.5.3 Total Cost to U.S. TPCs 

Table 3-10 summarizes the total costs to U.S. firms assumed to become TPCs under the TSCA 

Title VI program. As indicated, the rule is expected to cost the affected TPCs a total of $93,810 in the 

first year, $28,275 in reapplication years, and $23,847 in non-reapplication years. Annualized costs were 

also calculated, over a 30-year period, at three and seven percent discount rates.
TSCA Title VI Proposed TPC Rule Economic Analysis 45

Table 3-10: Total Costs to U.S. TPCs (2010$)

Cost Component

Cost (2010$)

TPCs with All Necessary 

Accreditation

TPCs Obtaining One 

Additional Accreditation

Total

Number of Affected Firms 6 3 9

Per Firm Costs: Year 1 $2,090 $27,090 -

Per Firm Costs: Reapplication Years $1,475 $6,475 -

Per Firm Costs: Non-reapplication Years $983 $5,983 -

Total First Year Costs $12,540 $81,270 $93,810

Total Reapplication Year Costs $8,850 $19,425 $28,275

Total Non-Reapplication Year Costs $5,898 $17,949 $23,847

30-Year Annualized Costs (3 percent 

discount rate)

$6,755 $20,477 $27,232 

30-Year Annualized Costs (7 percent 

discount rate)

$6,706 $21,416 $28,123 

Note: Costs are annualized over thirty years for 3 and 7 percent discount rates using the following formula: (present discounted 

value of 30-year stream-of-costs)*(discount rate*(1+ discount rate)30)/((1+ discount rate)31-1). Rule familiarization costs are 

assumed to be incurred immediately and therefore are not discounted. Other costs are discounted assuming that they are 

incurred at the end of each year.

EPA is considering requiring TPCs to submit their notifications and reports to the Agency 

electronically using the CDX. Appendix C discusses the incremental change in costs if EPA finalizes a 

mandatory electronic reporting requirement. As shown in section C.1.4, the total annualized savings to 

U.S. TPCs would be $2,852 per year at a 3 percent discount rate, and $2,754 per year at a 7 percent 

discount rate. 

3.6 Total Costs of the Rule for U.S. Accreditation Bodies and TPCs 

This section calculates the total cost for U.S. TPCs and accreditation bodies as a result of the 

TSCA Title VI TPC rule. While the costs analysis is limited to domestic entities, the burden analysis in 

Section 4.1 includes both foreign and domestic entities.
TSCA Title VI Proposed TPC Rule Economic Analysis 46

The different cost components of the rule (initial costs; notification, reporting, and 

recordkeeping costs; TPC reapplication costs; and AB reapplication costs) are incurred at different times 

and with different frequencies. Figure 2 demonstrates how the different cost components occur over 

the first nine years, and how they are categorized into five different categories of years, depending on 

which component occurs in that year. These same five categories are used in Table 3-11 and Table 3-12. 

Table 3-11 presents the per-firm costs for accreditation bodies and TPCs in each of these categories of 

years. Table 3-12 presents the total costs for the eight U.S. accreditation bodies and nine U.S. TPCs 

combined. To estimate total costs, per-firm costs were multiplied by the number of affected firms. 

Annualized costs were also calculated, over a 30-year period, at three and seven percent discount rates.
TSCA Title VI Proposed TPC Rule Economic Analysis 47

Figure 2. Timing of Cost Components Over the First Nine Years of the Program

Cost Component Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9

Initial costs X

Notification, reporting, 

and recordkeeping 

X X X X X X X X X

TPC reapplication X X

AB reapplication X X X

All TPCs are assumed to have been approved by CARB and thus grandfathered into the federal program for one year, so TPC 

reapplication occurs every 3 years starting in Year 4. AB reapplication occurs every 3 years starting in Year 3.

Key Description

Initial Applications for ABs (beginning of Year 1) and TPCs (end of Year 1)

Non-Reapplication Years for ABs, Non-Reapplication Years for TPCs

Non-Reapplication Years for ABs, Reapplication Years for TPCs

Reapplication Years for ABs, Non-Reapplication Years for TPCs

Reapplication Years for ABs, Reapplication Years for TPCs
TSCA Title VI Proposed TPC Rule Economic Analysis 48

Table 3-11: Cost per Year for Accreditation Bodies and Third Party Certifiers (2010$)

Year ABs

TPCs

Have Necessary 

Accreditation

Need Additional 

Accreditation

Per Firm Costs: Year 1 $1,685 $2,090 $27,090 

Per Firm Costs: Years 2, 5, 8, 11, 14, 17, 20, 

23, 26, 29 (Non-Reapplication Years for 

ABs, Non-Reapplication Years for TPCs)

$633 $983 $5,983

Per Firm Costs: Years 3, 6, 9, 12, 15, 18, 21, 

24, 27, 30 (Reapplication Years for ABs, 

Non-Reapplication Years for TPCs)

$1,070 $983 $5,983 

Per Firm Costs: Years 4, 7, 10, 13, 16, 19, 

22, 25, 28 (Non-Reapplication Years for 

ABs, Re-Application Years for TPCs)

$633 $1,475 $6,475 
TSCA Title VI Proposed TPC Rule Economic Analysis 49

Table 3-12: Total Costs to U.S. Accreditation Bodies and Third Party Certifiers (2010$)

Year U.S. ABs

U.S. TPCs

All Affected U.S. 

Have Necessary Firms

Accreditation

Need Additional 

Accreditation

Number of Affected Firms 8 6 3 17

Total Year 1 Costs $13,480 $12,540 $81,270 $107,290 

Total Costs in Years 2, 5, 8, 11, 14, 17, 20, 23, 

26, 29 (Non-Reapplication Years for ABs, NonReapplication Years for TPCs)$5,064 $5,898 $17,949 $28,911 

Total Costs in Years 3, 6, 9, 12, 15, 18, 21, 24, 

27, 30 (Reapplication Years for ABs, NonReapplication Years for TPCs)$8,560 $5,898 $17,949 $32,407 

Total Costs in Years 4, 7, 10, 13, 16, 19, 22, 25, 

28 (Non-Reapplication Years for ABs, ReApplication Years for TPCs)$5,064 $8,850 $19,425 $33,339 

30-Year Annualized Costs 

(3 percent discount rate)

$6,303 $6,755 $20,477 $33,535 

30-Year Annualized Costs 

(7 percent discount rate)

$6,320 $6,706 $21,416 $34,443 

Note: Annualized costs are annualized over thirty years for 3 and 7 percent discount rates using the following formula: (present discounted 

value of 30-year stream-of-costs)*(discount rate*(1+ discount rate)30)/((1+ discount rate)31-1). Rule familiarization, AB application costs, and 

AB recognition agreement costs are assumed to be incurred immediately and therefore are not discounted. Other costs are discounted 

assuming that they are incurred at the end of each year.

EPA is considering requiring accreditation bodies and TPCs to submit their notifications and 

reports to the Agency electronically using the CDX. Appendix C discusses the incremental change in 

costs if EPA finalizes a mandatory electronic reporting requirement. As shown in section C.1.4, 

electronic reporting via CDX would reduce the annualized costs of the rule to U.S. accreditation bodies 

and TPCs from $33,535 to $29,490 per year at a 3 percent discount rate, a savings of $4,045 per year. At 

a 7 percent discount rate, costs are estimated to decrease from $34,443 to $30,542, a savings of $3,900 

per year. There are additional unquantified improvements in efficiency and higher data quality due to 

electronic reporting.
TSCA Title VI Proposed TPC Rule Economic Analysis 50
TSCA Title VI Proposed TPC Rule Economic Analysis 51

4 Impact Analyses

In addition to the cost analysis presented in Chapter 3, several other types of impacts are 

important to consider in evaluating the effects of a regulation. This chapter presents the incremental 

impact of the proposed TPC Rule on:

 Paperwork burden, as required by the Paperwork Reduction Act (PRA);

 Financial condition of small entities, as required by the Regulatory Flexibility Act (RFA);

 State and Local Governments, as required by the Unfunded Mandates Reform Act;

 Federalism, as required by Executive Order 13132–Federalism;

 Tribal governments, as required by Executive Order 13175–Consultation and Coordination 

with Indian Tribal Governments;

 The environmental health risk or safety risk to children due to the regulation, as required by 

Executive Order 13045–Protection of Children From Environmental Health & Safety Risks;

 Whether voluntary consensus standards are used in its regulatory activities; and

 Low income and minority populations, as required by Executive Order 12898.

4.1 Paperwork Reduction Act Analysis

This section estimates the burden of reporting and recordkeeping for the proposed Third Party 

Certification rule. It presents average annual burden and cost estimates for affected accreditation 

bodies and third party certifiers over the first three years of the program. The labor hours and costs per 

firm are the same as those shown in Chapter 3 – the sum of the rule familiarization, application, 

recordkeeping, and reporting burdens and costs. However, the numbers of firms considered here are 

greater than in the cost analysis in Chapter 3 because both domestic and foreign firms are included.

Table 4-1 presents the PRA per-firm labor burdens and costs by the type of affected firm. The 

total burden and cost are calculated by multiplying the burdens and costs per firm by the number of 

affected firms.

EPA is considering requiring accreditation bodies and TPCs to submit their notifications and 

reports to the Agency electronically using the CDX. Appendix C discusses the incremental change in 
TSCA Title VI Proposed TPC Rule Economic Analysis 52

burden and costs if EPA finalizes a mandatory electronic reporting requirement. As shown in section 

C.1.4, electronic reporting via CDX would reduce the average total burden hours for all 61 domestic and 

foreign respondents from 1,421 hours to 1,029 hours per year, a savings of 392 hours per year. 
TSCA Title VI Proposed TPC Rule Economic Analysis 53

Table 4-1: Total PRA Burdens and Costs (2010$) 

Firm Type

Number 

of Firms

Per Firm Burden and Cost Total Burden and Cost

Labor 

Non-Labor 

Cost

Labor 

Non-Labor 

Cost

Hours Cost Hours Cost

Year 1

Domestic Accreditation Body 8 29.6042 $1,685 237 $13,480 

Foreign Accreditation Body 17 29.6642 $1,688 504 $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 $2,090 224 $12,540 

Foreign TPC obtaining one additional accreditation 9 37.3550 $2,092 $25,000 336 $18,828 $225,000 

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

Year 2

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

Foreign Accreditation 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 Accreditation Body 8 19.6042 $1,070 157 $8,560 

Foreign Accreditation Body 17 19.6642 $1,073 334 $18,241 

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 
TSCA Title VI Proposed TPC Rule Economic Analysis 54

Three Year Average

Domestic Accreditation Body 8 20.4509 $1,129 164 $9,035

Foreign Accreditation Body 17 20.5109 $1,132 349 $19,250

Domestic TPC obtaining one additional accreditation 3 25.2183 $1,352 $11,667 76 $4,056 $35,000 

Domestic TPC with current accreditations 6 25.2183 $1,352 151 $8,112 

Foreign TPC obtaining one additional accreditation 9 25.2483 $1,354 $11,667 227 $12,186 $105,000 

Foreign TPC with current accreditations 18 25.2483 $1,354 454 $24,372 

All Entities 61 23.2945 $1,262 $2,295 1421 $77,010 $140,000 

4.2 Regulatory Flexibility Act Analysis

This section presents the impact of the costs of accreditation under the proposed TSCA Title VI 

TPC rule on the financial condition of small entities. The Regulatory Flexibility Act (RFA) of 1980, 

amended by the Small Business Regulatory Enforcement Fairness Act (SBREFA) of 1996, requires 

regulators to assess the effects of regulations on small entities including businesses, nonprofit 

organizations, and governments. In some instances, agencies are also required to examine regulatory 

alternatives that may reduce adverse economic effects on significantly impacted small entities. The RFA 

requires agencies to prepare an initial and final regulatory flexibility analysis for each rule unless the 

Agency certifies that the rule will not have a significant economic impact on a substantial number of 

small entities. The RFA, however, does not specifically define “a significant economic impact on a 

substantial number” of small entities. Sections 603 and 604 of the RFA require that regulatory flexibility 

analyses identify the types, and estimate the numbers, of small entities to which the rule will apply; and 

describe the rule requirements to which small entities will be subject and any regulatory alternatives, 

including exemptions and deferral, which would lessen the rule’s burden on small entities. 

The TPC rule will affect small businesses and small non-profit organizations. (No small 

governments are expected to be affected by the TPC rule.) Under the Regulatory Flexibility Act (RFA), a 

“small business” is determined by the U.S. Small Business Administration’s regulations at 13 CFR 

121.201 (which create small business size standards using either a sales or employment threshold, 

depending on the nature of the industry), unless an agency establishes an alternate definition. And 

unless an agency establishes an alternate definition, under the RFA the term “small organization” means 
TSCA Title VI Proposed TPC Rule Economic Analysis 55

any not-for-profit enterprise which is independently owned and operated and is not dominant in its 

field. The RFA does not provide any guidance on how to judge whether an organization is dominant in 

its field. Non-profit TPCs and accreditation bodies perform the same activities (such as conducting and 

verifying formaldehyde emissions tests, accrediting, and auditing) as their for-profit counterparts. In 

order to interpret the RFA criteria for small organizations and treat all affected entities consistently, this 

analysis determines the size status of non-profits by applying the SBA size thresholds for the NAICS 

codes the non-profits are classified in. 

To fulfill the requirements of the RFA, this analysis addresses two basic questions regarding the 

proposed rule: (1) the number and type of small entities potentially affected, and (2) the extent of the 

rule’s potential economic impact on those entities as measured by the cost-to-revenue ratio for 

businesses and the cost-to-expenses ratio for small non-profit organizations.

3

This ratio is a good 

measure of entities’ ability to afford the costs attributable to a regulatory requirement, because 

comparing compliance costs to revenues or expenses provides a reasonable indication of the magnitude 

of the regulatory burden relative to a commonly available measure of economic activity. Where 

regulatory costs represent a small fraction of a typical entity’s revenues or expenses, the financial 

impacts of the regulation on such entities may be considered as not significant. The impact ratios are 

calculated using annualized costs, because these costs are more representative of the continuing costs 

entities face to comply with the rule.

4.2.1 Small Entity Impacts for Accreditation Bodies

As described in Section 2.2.1, five of the eight U.S. accreditation bodies that are IAF or ILAC 

signatories are non-profit organizations, while two are businesses, and one is a federal government 

agency. Using the size standard thresholds from the U.S. Small Business Administration, three of the 

non-profits and one of the businesses are classified as “small”. Per-firm costs were calculated as the 

quotient of the 30-year annualized costs and the number of affected firms presented in Table 3-2 (i.e., 

$6,303 ÷ 8), which results in an annualized cost estimate of $788 per entity per year. Estimated cost 

impacts ranged from 0.01 percent to 0.14 percent of expenditures for the three small non-profits, and 

were 0.21 percent of sales for the small business. As a result, no small accreditation bodies are 

expected to be significantly impacted by the rule.

 

3

Expenses and revenues were close to each other for the non-profit ABs and TPCs that were analyzed, so either 

measurement of impacts would provide similar results.
TSCA Title VI Proposed TPC Rule Economic Analysis 56

Table 4-2: Small Entity Impacts for U.S. ABs

Type

Annualized Costs 

Per Entity

(3% discount rate)

Estimated Number of Small Entities with Impacts

Under One 

Percent

Between One 

and Three 

Percent

Over Three 

Percent

Non-profits $788 3 0 0

Business $788 1 0 0

Total 4 0 0

4.2.2 Small Entity Impacts for Third-Party Certifiers

The cost of the rule to TPCs depends on whether the TPC already has all of the necessary 

accreditations. A TPC with all of the accreditations in place is estimated to incur an annualized cost of 

$1,126 per year for the required applications, reporting, and recordkeeping, while a TPC that needs to 

obtain an additional accreditation is estimated to incur an annualized cost of $6,826 per year.4 

Data were available to make size determinations for four of the nine U.S. TPCs participating in 

the CARB program. Using the data in Table 2-1 and the size standard thresholds from the U.S. Small 

Business Administration, two of these four TPCs are large businesses, and two are small non-profit

organizations. The small non-profits are assumed to have all of their accreditations currently in place, 

and thus incur a cost of $1,126 per year due to the rule, as shown in Table 4-3. Based on the 

expenditure data in Table 2-1, both of the small non-profit TPCs have cost impacts of less than 0.1%.

 

4

Based on the information in Table 3-10, $6,755 ÷ 6 = $1,126 per year for TPCs that have all accreditations in place, and 

$20,477 ÷ 3 = $6,826 per year for TPCs that need an additional accreditation.
TSCA Title VI Proposed TPC Rule Economic Analysis 57

Table 4-3: Impacts to Small Non-Profit TPCs in the U.S.

Type

Annualized Costs 

Per Entity

(3% discount rate)

Estimated Number of Small Entities with Impacts

Under One 

Percent

Between One 

and Three 

Percent

Over Three 

Percent

Non-profits $1,126 2 0 0

Size information was not located for the remaining five U.S. TPCs. This analysis assumes that 50 

percent of the remaining five TPCs are small businesses, which rounds up to three additional firms. 

Based on the information in Section 3.4.3, the analysis also assumes that two of the three will already 

have all their accreditations in place and that one will need to obtain an additional accreditation. As a 

result, the two TPCs with accreditations in place will incur an estimated annualized cost of $1,126 and 

the TPC that needs to obtain an additional accreditation will incur an estimated annualized cost of 

$6,826.

Data from the 2007 Economic Census data (U.S. Census Bureau 2007) was used to estimate 

impacts on the three TPCs that are assumed to be small businesses. The Census data provided the 

number of firms in different revenue brackets (less than $100,000 per year, $100,000 to $499,999, 

$500,000 to $999,999, etc.) for the affected NAICS codes (541330, 541380, 541611, and 561990). 

Revenue thresholds were then back-calculated such that annualized compliance costs created a one or 

three percent impact. For example, revenue would have to be less than $112,600 in order for a firm 

with all of its accreditations to have at least a one percent impact, and less than $37,533 in order to 

have an impact of at least three percent.

5

The next step was to interpolate the number of firms below each of these revenue thresholds, 

assuming that firms are evenly distributed within a revenue bracket. For example, out of 123,359 firms 

in these NAICS codes, the Census reported that 32,987 firms had revenues of less than $100,000, and 

49,013 firms had revenues between $100,000 and $499,999. Therefore, as shown in Table 4-4, an 

estimated 34,222 firms have revenues below $112,600.

6

 

5

For a firm with all of its certifications, compliance cost of $1,126 ÷ 1% impact = $112,600 in revenues, and $1,126 ÷ 3% 

impact = $37,533 in revenues.

6

32,987 firms under $100,000 + (($112,600 - $100,000) ÷ $499,999) x 49,013 firms between $100,000 and $499,999 = 

34,222 firms under $112,600. 
TSCA Title VI Proposed TPC Rule Economic Analysis 58

In this example, these 34,222 firms represent 28% of the firms in these NAICS codes. 7 

Multiplying the two small business TPCs with all necessary accreditations by 28%, and rounding to the 

nearest whole number, yields the result that one of these firms is estimated to have impacts over the 

one percent level. Performing a similar calculation for the three percent impact level yields the result 

that neither of the two small business TPCs with all their accreditations are predicted to have an impact 

over the three percent level. So the second TPC with all of its accreditation has an impact of less than 

one percent (not shown in Table 4-4). Repeating these calculations for the small business TPC that 

needs an additional accreditation yields the result that it is estimated to have a cost impact between 

one percent and three percent.

Table 4-4: : Impacts to Small Business TPCs in the U.S.

Firm Type

Annualized 

Costs Per 

Firm (3% 

discount 

rate)

Associated Revenue 

Thresholds

Number of Firms 

Below Threshold1

Percent of Firms 

Below Threshold2

Estimated Number 

of Small TPCs with 

Impacts Over3

1% 

Impact

3% 

Impact

1% 

Impact

3% 

Impact

1% 

Impact

3% 

Impact

1% 

Impact

3% 

Impact

Firms with all 

necessary 

accreditations

(n = 2) $1,126 $112,600 $37,533 34,222 12,381 28% 10% 1 0

Firms that need 

to obtain one 

additional 

accreditation

(n = 1) $6,826 $682,600 $227,533 84,700 45,489 69% 37% 1 0

Notes: 1. The analysis assumes that firms are distributed evenly within a revenue bracket.

2. The percentage of firms below the threshold is calculated by dividing the number of firms below the threshold by 123,359 

(the total number of firms in NAICS codes 541,330, 541380, 541611, and 561990. 

3. The analysis assumes that two of the three small business TPCs will already have accreditations in place and that one will 

need to obtain additional accreditation. 

 

7

34,222 firms under $112,600 is 28% of the 123,359 total firms.
TSCA Title VI Proposed TPC Rule Economic Analysis 59

As described in Section 2.2.1, the CARB TPCs appear to be larger than the average firms in these 

industries, so Census statistics may underestimate the revenues and overestimate the impacts on TPCs 

(which represent just 0.006 percent of the firms in these NAICS codes).

Table 4-5 summarizes the annualized per-firm costs, and the number of affected number of 

TPCs with impacts exceeding the one and three percent levels. Costs are estimated to exceed the one 

percent level for two small businesses. However, given that these firms have the incentive to seek 

accreditation only if they can pass through their costs to the firms they are certifying, they are not 

expected to experience a negative economic impacts as a result of this proposed rule. 

Table 4-5: Small Entity Impacts for U.S. TPCs

Certification Status

Annualized Costs 

Per Entity

(3% discount rate)

Small Entity Type

Estimated Number of Small Entities 

with Impacts

Under One 

Percent

Between One 

and Three 

Percent

Over Three 

Percent

TPCs with current AB 

certification

$1,126 

Non-profit 2 0 0

Business 1 1 0

TPCs that need to obtain 

new AB certification $6,826

Non-profit 0 0 0

Business 0 1 0

Combined

Non-profit 2 0 0

Business 1 2 0

Total 3 2 0

4.2.3 Summary of Small Entity Impacts to ABs and TPCs

As shown in Table 4-6, there are a total of 9 small entities in the U.S. assumed to be directly 

affected by the Title VI TPC rule. Five of these are non-profits, all of which are estimated to have cost 

impacts of less than one percent of expenditures. Four are businesses, two of which are estimated to 
TSCA Title VI Proposed TPC Rule Economic Analysis 60

have cost impacts of less than one percent of revenues, and two of which are estimated to have cost 

impacts between one percent and three percent of revenues. 

Table 4-6: Summary of Small Entity Impacts to ABs and TPCs

Entity Type

Number of U.S. Entities that 

are Small

Estimated Number of Small Entities with Impacts

Under One 

Percent

Between One and 

Three Percent

Over Three Percent

TPCs

Non-profit 2 2 0 0

Business 3 1 2 0

ABs

Non-profit 3 3 0 0

Business 1 1 0 0

Combined

Non-profit 5 5 0 0

Business 4 2 2 0

Total 9 7 2 0

4.3 Unfunded Mandates Reform Act (UMRA)

Title II of the Unfunded Mandates Reform Act of 1995, Pub. L. 104-4, establishes requirements 

for Federal agencies to assess the effects of their regulatory actions on State, local, and Tribal 

governments, and the private sector. Under section 202 of the UMRA, EPA generally must prepare a

written statement, including a cost-benefit analysis, for proposed and final rules with “Federal 

mandates” that might result in expenditures by State, local, and Tribal governments, in the aggregate, or 

by the private sector, of $100 million or more (when adjusted annually for inflation) in any one year.

The cost of the proposed TPC rule is well below $100 million per year in any one year. The rule 

is not expected to affect State, local, and Tribal governments.

4.4 Executive Order 13132 - Federalism
TSCA Title VI Proposed TPC Rule Economic Analysis 61

Executive Order 13132, entitled Federalism (64 FR 43255, August 10, 1999), directs federal 

agencies to consider whether a rule has federalism implications (i.e. whether it has substantial direct 

effects on the states, on the relationship between the national government and the states, or on the 

distribution of power and responsibilities among the various levels of government, as specified in 

Executive Order 13132).

The TPC rule does not have a substantial direct effects on states or local governments 

(individually or collectively), on the relationship between the national government and the states, or on 

the distribution of power and responsibilities among the various levels of government. No state or local 

governments are expected to become TPCs or accreditation bodies, and thus state and local 

governments will not incur direct compliance costs as a result of the rule. The rule does not preempt 

state or local law, and the rule is required by statute.

4.5 Executive Order 13175 - Tribal Implications

Executive Order 13175, entitled Consultation and Coordination with Indian Tribal Governments

(59 FR 22951, November 6, 2000), directs federal agencies to consider whether a rule has tribal 

implications (i.e. whether it has substantial direct effects on tribal governments, on the relationship 

between the Federal government and the Indian tribes, or on the distribution of power and 

responsibilities between the Federal government and Indian tribes). No tribal government is expected to 

become a TPC or an accreditation body, and thus tribal governments will not incur direct compliance 

costs as a result of the rule. The rule does not change the relationship between the Federal government 

and Indian tribes, or change the distribution of power. 

4.6 Executive Order 13045 - Protection of Children

Under Executive Order 13045, a regulation must be reviewed if the regulatory action is 

economically significant and concerns an environmental health risk or safety risk that may 

disproportionately affect children. The proposed TPC rule is not economically significant because it will 

not have an annual impact on the economy of $100 million or more.
TSCA Title VI Proposed TPC Rule Economic Analysis 62

4.7 Executive Order 13211 - Energy Effects

Executive Order 13211, entitled Actions Concerning Regulations that Significantly Affect Energy 

Supply, Distribution, or Use (66 FR 28355, May 22, 2001), directs federal agencies to identify actions that 

will have a significant adverse energy effect. Adverse effects are defined as:

 Reductions in crude oil supply in excess of 10,000 barrels per day; 

 Reductions in fuel production in excess of 4,000 barrels per day; 

 Reductions in coal production in excess of 5 million tons per year; 

 Reductions in natural gas production in excess of 25 million mcf per year; 

 Reductions in electricity production in excess of 1 billion kilowatt-hours per year or in excess of 

500 megawatts of installed capacity; 

 Increases in energy use required by the regulatory action that exceed any of the thresholds 

above; 

 Increases in the cost of energy production in excess of one percent; 

 Increases in the cost of energy distribution in excess of one percent; or 

 Other similarly adverse outcomes. 

The regulations under consideration will not significantly reduce energy production nor significantly 

increase energy costs.

4.8 National Technology Transfer and Advancement Act

Section 12(d) of the National Technology Transfer and Advancement Act of 1995 (“NTTAA”), 

Public Law No. 104-113 (15 U.S.C. 272 note) directs EPA to use voluntary consensus standards in its 

regulatory activities unless to do so would be inconsistent with applicable law or otherwise impractical. 

Voluntary consensus standards are technical standards (e.g., materials specifications, test methods, 

sampling procedures, business practices, etc.) that are developed or adopted by voluntary consensus 

standards bodies. NTTAA directs EPA to provide Congress, through OMB, explanations when the Agency 

decides not to use available and applicable voluntary consensus standards. 

This proposed rulemaking involves technical standards, and EPA proposes to use voluntary 

consensus standards. The proposed framework of this third party certification program is based on the 

ability of ABs to review TPCs for their conformity to ISO/IEC Guide 65, ISO/IEC 17025, and ISO/IEC 17020. 
TSCA Title VI Proposed TPC Rule Economic Analysis 63

Both Product ABs and Laboratory ABs must maintain their conformity to ISO/IEC 17011 and ISO/IEC 

Guide 65.

4.9 Executive Order 12898 – Environmental Justice

Under Executive Order 12898, when promulgating a regulation, EPA investigates whether there 

are disproportionately high and adverse human health or environmental effects on minority and lowincome populations. Since this proposed rulemaking addresses the process for accreditation bodies and 

TPCs, this proposed rule does result in any adverse human health or environmental effects.
TSCA Title VI Proposed TPC Rule Economic Analysis 64

References

AIHA-LAP LLC. 2012. About AIHA Laboratory Accreditation Programs. Available at: 

http://www.aihaaccreditedlabs.org/about/pages/default.aspx (Accessed April 27, 2012)

American Business Directory. 2011. 2011 American Business Information: Perry Johnson Inc. and Perry 

Johnson Registrars.

California Air Resources Board (CARB). 2011. List of CARB Approved Third Party Certifiers.

Dun & Bradstreet. 2011. Company Reports. Proprietary Database.

International Accreditation Forum (IAF). 2011. Signatories to the IAF MLA for ISO 9001, ISO 14001, 

Product, 31 May 2011.

International Laboratory Accreditation Cooperation (ILAC). 2011. Signatories to the ILAC Mutual 

Recognition Arrangement, Updated 16 May 2011.

Perry Johnson & Associates. 2012. Contact us - Perry Johnson & Associates, Inc. Available at: 

www.pjats.com/contact-us/ (Accessed April 27, 2012)

Personal Communication with Forestwood Industries. 2011. Conversation between Gary Poserina 

(Forestwood Industries, Inc.) and Abt Associates Inc. . March 2, 2011.

Personal Communication with IAS. 2011. Conversation between Patrick McCullen (International 

Accreditation Service) and Abt Associates Inc. June 22, 2011.

Personal Communication with NSF International. 2011a. Conversation between Kerri Levanseler (NSF 

International) and Abt Associates Inc. March 2, 2011.

Personal Communication with NSF International. 2011b. Conversation between Craig Moore (NSF 

International) and Abt Associates Inc. March 11, 2011.

Personal Communication with NTA Inc. 2011. Conversation between Dale Arter (NTA Inc.) and Abt 

Associates Inc. March 2, 2011.

Personal Communication with PFS Corporation. 2011. Conversation between James Van Schoyck and 

Ron Reindl (PFS Corporation, Inc.) and Abt Associates Inc. February 25, 2011.

Personal Communication with PSI. 2011. Conversation between Randy Webb (Professional Service 

Industries, Inc.) and Abt Associates Inc. February 14, 2011.

Personal Communication with SCS International. 2011. Conversation between Michael Wolfe (SCS 

International) and Abt Associates Inc. February 28, 2011.

PFS Corporation. 2012. History - PFS Corporation. Available at: www.pfscorporation.com/history.php

(Accessed April 27, 2012)

Professional Service Industries Inc. (PSI). 2012. Welcome to PSI. Available at: www.psiusa.com (Accessed 

April 27, 2012)
TSCA Title VI Proposed TPC Rule Economic Analysis 65

Scientific Certification Systems (SCS). 2012a. Staff Roster - Scientific Certification Systems. Available at: 

www.scscertified.com/scs_staff.php (Accessed April 27, 2012)

Scientific Certification Systems (SCS). 2012b. Management Roster - Scientific Certification Systems. 

Available at: www.scscertified.com/scs_management.php (Accessed April 27, 2012)

U.S. Bureau of Labor Statistics (BLS). 2011. Employer Costs for Employee Compensation: Supplementary 

Tables: Historical Data: December 2006 - March 2011.

U.S. Census Bureau. 2010a. Sector 54: EC0754SSSZ4: Professional, Scientific, and Technical Services: 

Subject Series - Estab & Firm Size: Receipts/Revenue Size of Firms for the United States: 2007.

U.S. Census Bureau. 2010b. Sector 56: EC0756SSSZ4: Administrative and Support and Waste 

Management and Remediation Services: Subject Series - Establishment and Firm Size: Receipts 

Size of Firms for the United States: 2007.

U.S. Census Bureau. 2010c. Sector 81: EC0781SSSZ4: Other Services (Except Public Administration): 

Subject Series - Estab & Firm Size: Receipts/Revenue Size of Firms for the United States: 2007.

U.S. Census Bureau. 2010d. Sector 31: EC0731I1: Manufacturing: Industry Series: Detailed Statistics by 

Industry for the United States: 2007.

U.S. Environmental Protection Agency (EPA). 2002a. Economic Analysis for the Amended Inventory 

Update Rule: Final Report (EPA-HQ-OPPT-2002-0054-0260). August 2002.

U.S. Environmental Protection Agency (EPA). 2002b. Wage Rates for Economic Analysis of the Toxics 

Release Inventory Program. June 10, 2002.

U.S. Environmental Protection Agency (EPA). 2009. Economic Analysis of the Premanufacture 

Notification Electronic Reporting Final Rule. U. S. E. P. A. Office of Pollution Prevention and 

Toxics. July 13, 2009.

U.S. Environmental Protection Agency (EPA). 2011a. Supporting Statement for a Request for OMB 

Review under the Paperwork Reduction Act: the Final Rule Addendum to Partial Update of the 

TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.

U.S. Environmental Protection Agency (EPA). 2011b. Supporting Statement for EPA Information 

Collection Request Number 2002.05, “Cross-Media Electronic Reporting Rule” Office of 

Environmental Information, U.S. Environmental Protection Agency. June 22, 2011.

U.S. Internal Revenue Service. 2009. Form 990: Return of Organization Exempt from Income Tax for 

Nonprofit ABs and TPCs.

U.S. Internal Revenue Service. 2010. Form 990: Return of Organization Exempt from Income Tax for 

Nonprofit ABs and TPCs.

U.S. Small Business Administration. 2010. Table of Small Business Size Standards Matched to North 

American Industry Classification System Codes.
TSCA Title VI Proposed TPC Rule Economic Analysis 66

Weinstein, H. G. and M. A. Loewenstein. 2004. Comparing Current and Former Industry and Occupation 

ECEC Series. August 25, 2004.
TSCA Title VI Proposed TPC Rule Economic Analysis A-1

Appendix A– Wage Rate Calculations

This appendix describes the derivation of the fully loaded wage rates and inflation factors used 

in calculating costs of labor, materials, and other inputs. All cost estimates are presented in fourth 

quarter, calendar year 2010 dollars, representing the most recent full year of data available.

The fully loaded unit labor cost for managerial, professional/technical, 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 (EPA 2002b). This appendix describes the 

method employed to estimate the fully loaded unit labor costs for each labor category and presents the 

results of the analysis.

Labor categories used in the analysis 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 Occupational Classification (SOC) system instead of the Occupational Classification System 

(OCS). Exhibit A-1 summarizes the crosswalk between old and new occupational titles, and lists the SOC 

titles that correspond to the managerial, professional/technical, and clerical labor categories used in this 

analysis (Weinstein and Loewenstein 2004).

Exhibit A-1: 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, business, and financial

Professional/Technical Professional specialty and technical Professional and related

Clerical Administrative support, including clerical Office and administrative support

Source: Weinstein and Loewenstein 2004
TSCA Title VI Proposed TPC Rule Economic Analysis A-2

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 (BLS 2011).8

The costs of fringe benefits such as paid leave and insurance, specific to each labor category, are 

taken from the same BLS report (BLS 2011). Fringe 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 the average fringe benefit was $13.52.9Therefore, fringe 

benefits as a percentage of wages were $13.52/$36.57, or approximately 37 percent (see Exhibit A-2).

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

approach is used for consistency with Office of Pollution Prevention and Toxics (OPPT) economic 

analyses for two major rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory 

Program, June 2002 (EPA 2002b), and the Revised Economic Analysis for the Amended Inventory Update 

Rule: Final Report, August 2002 (EPA 2002a). This overhead loading factor is added to the benefits 

loading factor, and the total is then applied to the base wage to derive the fully loaded wage. For 

example, the December 2010 fully loaded wage for professional/technical labor is $36.97 × (1+ 0.37 + 

0.17) = $56.31. 

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

in Exhibit A-2.

 

8

Past economic analyses used ECEC data series specific to white-collar workers in the manufacturing sector. However, 

those data sets were discontinued in March 2007, and these historical data were the best alternative. In a phone 

conversation (February 11, 2009), a BLS employee could not identify a better data set to use.

9

Past economic analyses have used the term “technical” labor. Here the category is called “professional/technical” 

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, the “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 BLS article, “Comparing Current and Former Industry and 

Occupation ECEC Series” (Weinstein and Loewenstein, 2004).
TSCA Title VI Proposed TPC Rule Economic Analysis A-3

Exhibit A-2: 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 based on assumptions in EPA (2002a) and EPA (2002b).

b

Data for this occupational series found in BLS (2011).
TSCA Title VI Proposed TPC Rule Economic Analysis B-1

Appendix B – Recordkeeping and Reporting Burdens

Table B-1 and Table B-2 present the estimated per-activity recordkeeping and reporting burdens 

for accreditation bodies and third party certifiers, respectively. Table B-3 and Table B-4 present the 

estimated annual frequency of the recordkeeping and reporting activity as well as the associated 

clerical, technical, and managerial cost. Total costs are calculated as the sum of the component costs. 
TSCA Title VI Proposed TPC Rule Economic Analysis B-2

Table B-1: Recordkeeping and Reporting Burden for Accreditation Bodies, by Activity

Activity1

Per Activity Burden Hours

Number of 

Annual Activities

(d)

Clerical Technical Managerial

Total Burden 

(hours)

(a) (b) (c)

(e) = 

(d)*{(a)+(b)+(c)}

1. Rule Familiarization 0.00 5.00 5.00 1.00 10.0000

2. Application Submission 

Company Information (Name, Address, Telephone Number, and Email Address of 

Primary Contact)2 0.00 0.04 0.021.00

0.0600

Documentation of IAF MLA, ILAC MRA, or Equivalent Signatory Status20.00 0.04 0.02 1.00 0.0600

Description of Any Other Qualifications Related to Experience in Performing 

Accreditation of Conformity Assessment Bodies or Third Party Certifiers3 0.00 0.83 0.511.00

1.3400

3. Recognition Agreement41.00 1.00 4.00 1.00 6.0000

4. EPA Notification

Loss of Status as a Signatory to the IAF MLA, ILAC MRA, or Equivalent Organization50.00 0.08 0.04 0.05 0.0060

Third Party Certifier Applications50.00 0.08 0.04 3.00 0.3600

Third Party Certifier Accreditation50.00 0.08 0.04 3.00 0.3600

Third Party Certifier Compliance Failure50.00 0.08 0.04 0.33 0.0396
TSCA Title VI Proposed TPC Rule Economic Analysis B-3

Table B-1: Recordkeeping and Reporting Burden for Accreditation Bodies, by Activity

Activity1

Per Activity Burden Hours

Number of 

Annual Activities

(d)

Clerical Technical Managerial

Total Burden 

(hours)

(a) (b) (c) (e) = 

(d)*{(a)+(b)+(c)}

Third Party Certifier Accreditation Suspension or Revocation (Product ABs) / 

Accredited Laboratory Compliance Failure (Laboratory ABs)5 0.00 0.08 0.04 0.33 0.0396

Change to Organizational Policy or Management Structure that Could Adversely Affect 

Accreditation Program5 0.00 0.08 0.04 0.20 0.0240

Checklists and Other Records Documenting Compliance with the Requirements for 

Systems Audits and On-site Assessment of Third Party Certifiers5 0.00 0.08 0.04 1.00 0.1200

Change in Name or Address of Domestic Agent (Foreign Entities Only)

5

0.00 0.08 0.04 0.50 0.0600

5. Third Party Certifier Notification

Unique Tracking Number20.00 0.04 0.02 3.00 0.1800

Withdraw from or be Removed from Program20.00 0.04 0.02 0.25 0.0150

6. Recordkeeping

Accreditation Applications60.75 1.50 0.75 1.00 3.0000

Checklists and Other Records Documenting Compliance with the Requirements for 

Systems Audits and On-site Assessment of Third Party Certifiers6 0.75 1.50 0.75 1.00 3.0000

7. Annual Report to EPA
TSCA Title VI Proposed TPC Rule Economic Analysis B-4

Table B-1: Recordkeeping and Reporting Burden for Accreditation Bodies, by Activity

Activity1

Per Activity Burden Hours

Number of 

Annual Activities

(d)

Clerical Technical Managerial

Total Burden 

(hours)

(a) (b) (c) (e) = 

(d)*{(a)+(b)+(c)}

Number of Third Party Certifier Applications Received70.25 0.50 0.25 1.00 1.0000

Number of Third Party Certifier Applications Approved and Denied70.25 0.50 0.25 1.00 1.0000

The Names and Contact Information of All Accredited Third Party Certifiers70.25 0.50 0.25 1.00 1.0000

Number and Locations of Systems Audits and On-site Assessments70.25 0.50 0.25 1.00 1.0000

Results of Accredited Third Party Certifier Laboratory Proficiency Testing or Interlaboratory Comparisons7 0.25 0.50 0.25 1.00 1.0000

Domestic Total in First Year 29.6042

Foreign Total in First Year 29.6642

Domestic Total in Year 2(Non-Reapplication Year) 12.1442

Foreign Total in Year 2 (Non-Reapplication Year) 12.2042

Domestic Total in Year 3 (Reapplication Year) 19.6042

Foreign Total in Year 3 (Reapplication Year) 19.6642
TSCA Title VI Proposed TPC Rule Economic Analysis B-5

Table B-1: Recordkeeping and Reporting Burden for Accreditation Bodies, by Activity

Activity1

Per Activity Burden Hours

Number of 

Annual Activities

(d)

Clerical Technical Managerial

Total Burden 

(hours)

(a) (b) (c) (e) = 

(d)*{(a)+(b)+(c)}

Notes: 1. Under the proposed rule, accreditation bodies are required to submit an application to renew their recognition agreement every three years. As a result, this analysis assumes that 

accreditation bodies incur application submission and recognition agreement preparation costs in the first year and subsequently every three years thereafter.

2. Based on the estimated burden associated with reporting "company information" (EPA 2011a). 

3. Based on the estimated burden associated with answering substantiation questions when making plant site confidentiality claims (EPA 2011a).

4. Based on conversations with accreditation bodies.

5. Based on the estimated burden associated with reporting "company information" (EPA 2011a). Values have been doubled based on best professional judgment.

6. Based on the estimated burden associated with "recordkeeping" (EPA 2011a). The rule requires that records be kept for 3 years that show the

production volume, plant site, and site-limited status of each reported substance.

7. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011a). Estimate based on best professional judgment.

Sources: (1) U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: Historical Data: December 2006 - March 2011, and (2) U.S. 

Environmental Protection Agency. 2011a. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule Addendum to Partial Update of 

the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.
TSCA Title VI Proposed TPC Rule Economic Analysis B-6

Table B-2: Recordkeeping and Reporting Burden for Third Party Certifiers, by Activity

Per Activity Burden Hours Number of 

Annual 

Activities

(d)

Total Burden 

(hours)

(e) = 

(d)*{(a)+(b)+(c)}

Activity1

Clerical Technical Managerial 

(a) (b) (c)

1. Rule Familiarization 0.00 5.00 5.00 1.00 10.00

2. Product Accreditation Body Application Submission 

Company Information (Name, Address, Telephone Number, and Email Address 

of Primary Contact) and Type of Composite Wood Products Applicant Intends 

to Certify2

0.00 0.04 0.02 1.00 0.06

Description of TPC's Experience or Ability in Product Certification and 

Complying with ISO/IEC Guide 653 0.00 0.83 0.51 1.00 1.34

Description of TPC's Experience in the Composite Wood Product Industry with 

the Product(s) Intended to be Certified3 0.00 0.83 0.51 1.00 1.34

Description of TPC's Ability to Inspect and Properly Train and Supervise 

Inspectors Pursuant to ISO/IEC 170203 0.00 0.83 0.51 1.00 1.34

3. Laboratory Accreditation Body Application Submission

Company Information (Name, Address, Telephone Number, and Email Address 

of Primary Contact; if foreign, name and address of an agent for service located 

in the U.S.)2

0.00 0.04 0.02 1.00 0.06

Description of TPC's Experience in Performing or Verifying Formaldehyde 

Testing on Composite Wood Products3 0.00 0.83 0.51 1.00 1.34

Description of TPC's Experience Operating or Using Laboratories that Comply 

with ISO/IEC 170253 0.00 0.83 0.51 1.00 1.34
TSCA Title VI Proposed TPC Rule Economic Analysis B-7

Table B-2: Recordkeeping and Reporting Burden for Third Party Certifiers, by Activity

Per Activity Burden Hours Number of 

Annual 

Activities

(d)

Total Burden 

(hours)

(e) = 

(d)*{(a)+(b)+(c)}

Activity1

Clerical Technical Managerial 

(a) (b) (c)

Description of TPC's Experience with Test Method ASTM E-1333-96 (2002) and 

Experience Evaluating Correlation between Test Methods3 0.00 0.83 0.51 1.00 1.34

4. Manufacturer Notification

Third Party Certifier Number2 0.00 0.04 0.02 1.00 0.06

Withdraw from Program or Lose Accreditation2 0.00 0.04 0.02 0.25 0.015

5. Recordkeeping

List of Manufacturers and their Product Types (including Resins Used) Certified 

by TPC4 0.75 1.50 0.75 1.00 3.00

Results of Inspections, Audits, and Emission Tests Conducted for Each 

Manufacturer and Product Type4 0.75 1.50 0.75 1.00 3.00

List of the TPC's Laboratories, Test Methods (including Test Conditions and 

Conditioning Time), and Test Results4 0.75 1.50 0.75 1.00 3.00

Methods and Results for Establishing Test Method Correlations and 

Equivalence4 0.75 1.50 0.75 1.00 3.00

List of Manufacturers and Products Approved for Reduced Testing40.75 1.50 0.75 1.00 3.00

6. Annual Report to Accreditation Bodies

List of Manufacturers and their Products Certified by the TPC during the 

Previous Year (including Resins Used, and the Average and Range of 

0.25 0.50 0.25 1.00 1.00
TSCA Title VI Proposed TPC Rule Economic Analysis B-8

Table B-2: Recordkeeping and Reporting Burden for Third Party Certifiers, by Activity

Per Activity Burden Hours Number of 

Annual 

Activities

(d)

Total Burden 

(hours)

(e) = 

(d)*{(a)+(b)+(c)}

Activity1

Clerical Technical Managerial 

(a) (b) (c)

Formaldehyde Emissions by Manufacturer, Resin, and Product Type)5

List of Noncomplying Products or Events by Manufacturer50.25 0.50 0.25 1.00 1.00

List of Laboratories and Test Methods Used by the TPC50.25 0.50 0.25 1.00 1.00

Results of Inter-Laboratory Comparison or Proficiency Testing for the 

Laboratories Used by the TPC4 0.25 0.50 0.25 1.00 1.00

7. Accreditation Board Notification

Personnel Qualification Changes20.00 0.04 0.02 0.50 0.03

Procedure Changes20.00 0.04 0.02 0.50 0.03

Laboratory Changes20.00 0.04 0.02 0.50 0.03

8. EPA Notification

Change in Name or Address of Domestic Agent (Foreign TPCs Only)

2

0.00 0.04 0.02 0.50 0.03

Domestic Total in First Year 37.325

Foreign Total in First Year 37.355

Domestic Total in Non-Reapplication Year 19.165

Foreign Total in Non-Reapplications Year 19.195
TSCA Title VI Proposed TPC Rule Economic Analysis B-9

Table B-2: Recordkeeping and Reporting Burden for Third Party Certifiers, by Activity

Per Activity Burden Hours Number of 

Annual 

Activities

(d)

Total Burden 

(hours)

(e) = 

(d)*{(a)+(b)+(c)}

Activity1

Clerical Technical Managerial 

(a) (b) (c)

Domestic Total in Reapplication Year 27.325

Foreign Total in Reapplications Year 27.355

Notes: 1. Under the proposed rule, TPCs are required to apply for re-accreditation every three years. As a result, application and accreditation costs are incurred every other year.

2. Based on the estimated burden associated with reporting "company information" (EPA 2011a). 

3. Based on the estimated burden associated with answering substantiation questions when making plant site confidentiality claims (EPA 2011a).

4. Based on the estimated burden associated with "recordkeeping" (EPA 2011a). The rule requires that records be kept for 3 years that show the

production volume, plant site, and site-limited status of each reported substance.

5. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011a). Estimate based on best professional judgment.

Sources: (1) U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: Historical Data: December 2006 - March 2011, and 

(2) U.S. Environmental Protection Agency. 2011a. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule Addendum to 

Partial Update of the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.
TSCA Title VI Proposed TPC Rule Economic Analysis B-10

Table B-3: Recordkeeping and Reporting Labor Costs for Accreditation Bodies, by Activity (2010$)

Activity

Estimated Annual 

Frequency1 Clerical Cost2

Technical Cost2 Managerial Cost2Total Cost

1. Rule Familiarization 1 $0.00 $281.55 $333.90 $615 

2. Application Submission 

Company Information (Name, Address, Telephone Number, and Email 

Address of Primary Contact)3 1 $0.00 $2.25 $1.34 $3.59 

Documentation of IAF MLA, ILAC MRA, or Equivalent Signatory Status31 $0.00 $2.25 $1.34 $3.59 

Description of Any Other Qualifications Related to Experience in 

Performing Accreditation of Conformity Assessment Bodies or Third 

Party Certifiers4

1 $0.00 $46.74 $34.06 $80.80 

Application Submission Subtotal $88

3. Recognition Agreement51 $25.65 $56.31 $267.12 $349 

4. EPA Notification

Loss of Status as a Signatory to the IAF MLA, ILAC MRA, or Equivalent 

Organization6 0.05 $0.00 $0.23 $0.13 $0.36 

Third Party Certifier Application63 $0.00 $13.51 $8.01 $21.53 

Third Party Certifier Accreditation63 $0.00 $13.51 $8.01 $21.53 

Third Party Certifier Compliance Failure60.33 $0.00 $1.49 $0.88 $2.37 

Third Party Certifier Accreditation Suspension or Revocation (Product 

ABs) / Accredited Laboratory Compliance Failure (Laboratory ABs)6 0.33 $0.00 $1.49 $0.88 $2.37 
TSCA Title VI Proposed TPC Rule Economic Analysis B-11

Table B-3: Recordkeeping and Reporting Labor Costs for Accreditation Bodies, by Activity (2010$)

Activity

Estimated Annual 

Frequency1 Clerical Cost2

Technical Cost2 Managerial Cost2Total Cost

Change to Organizational Policy or Management Structure that Could 

Adversely Affect Accreditation Program6 0.2 $0.00 $0.90 $0.53 $1.44 

Checklists and Other Records Documenting Compliance with the 

Requirements for Systems Audits and On-site Assessment of Third Party 

Certifiers6

1 $0.00 $4.50 $2.67 $7.18 

Change in Name or Address of Domestic Agent (Foreign Entities Only)

6

0.5 $0.00 $2.25 $1.34 $3.59 

EPA Notification Subtotal (Domestic) $57

EPA Notification Subtotal (Foreign) $60

5. Third Party Certifier Notification

Unique Tracking Number33 $0.00 $6.76 $4.01 $10.76 

Withdraw from or be Removed from Program30.25 $0.00 $0.56 $0.33 $0.90 

TPC Notification Subtotal $12

6. Recordkeeping

Accreditation Applications71 $19.24 $84.47 $50.09 $153.79 

Checklists and Other Records Documenting Compliance with the 

Requirements for Systems Audits and On-site Assessment of Third Party 

Certifiers7

1 $19.24 $84.47 $50.09 $153.79 

Recordkeeping Subtotal $308
TSCA Title VI Proposed TPC Rule Economic Analysis B-12

Table B-3: Recordkeeping and Reporting Labor Costs for Accreditation Bodies, by Activity (2010$)

Activity

Estimated Annual 

Frequency1 Clerical Cost2

Technical Cost2 Managerial Cost2Total Cost

7. Annual Report to EPA

Number of Third Party Certifier Applications Received81 $6.41 $28.16 $16.70 $51.26 

Number of Third Party Certifier Applications Approved and Denied81 $6.41 $28.16 $16.70 $51.26 

The Names and Contact Information of All Accredited Third Party 

Certifiers8 1 $6.41 $28.16 $16.70 $51.26 

Number and Locations of Systems Audits and On-site Assessments81 $6.41 $28.16 $16.70 $51.26 

Results of Accredited Third Party Certifier Laboratory Proficiency 

Testing or Inter-laboratory Comparisons8 1 $6.41 $28.16 $16.70 $51.26 

Annual Report Subtotal $256

Domestic Total in First Year $1,685 

Foreign Total in First Year $1,688 

Domestic Total in Year 2(Non-Reapplication Year) $633 

Foreign Total in Year 2 (Non-Reapplication Year) $636 

Domestic Total in Year 3(Reapplication Year) $1,070

Foreign Total in Year 3 (Reapplication Year) $1,073
TSCA Title VI Proposed TPC Rule Economic Analysis B-13

Table B-3: Recordkeeping and Reporting Labor Costs for Accreditation Bodies, by Activity (2010$)

Activity

Estimated Annual 

Frequency1 Clerical Cost2

Technical Cost2 Managerial Cost2Total Cost

Notes: 1. Based on best professional judgment and rule requirements. Under the proposed rule, accreditation bodies are required to submit an application to renew their recognition agreement every 

three years. As a result, this analysis assumes that accreditation bodies incur application submission and recognition agreement preparation costs in the first year and subsequently every three 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 data from the "professional and related" occupational group; and managerial costs are estimated using 

data from the "management, business, and financial" occupational group.

3. Based on the estimated burden associated with reporting "company information" (EPA 2011a). 

4. Based on the estimated burden associated with answering substantiation questions when making plant site confidentiality claims (EPA 2011a).

5. Based on conversations with accreditation bodies.

6. Based on the estimated burden associated with reporting "company information" (EPA 2011a). Values have been doubled based on best professional judgment.

7. Based on the estimated burden associated with "recordkeeping" (EPA 2011a). The rule requires that records be kept for 3 years that show the production volume, plant site, and site-limited status 

of each reported substance.

8. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011a). Estimate based on best professional judgment.

Sources: (1) U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: Historical Data: December 2006 - March 2011, and (2) U.S. 

Environmental Protection Agency. 2011a. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule Addendum to Partial Update of 

the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.
TSCA Title VI Proposed TPC Rule Economic Analysis B-14

Table B-4: Recordkeeping and Reporting Labor Costs for Third Party Certifiers, by Activity (2010$)

Activity

Estimated Annual 

Frequency1 Clerical Cost2

Technical Cost2 Managerial Cost2Total Cost

1. Rule Familiarization 1.00 $0.00 $281.55 $333.90 $615 

2. Product Accreditation Body Application Submission 

Company Information (Name, Address, Telephone Number, 

and Email Address of Primary Contact; if foreign, name and 

address of an agent for service located in the U.S.) and Type of 

Composite Wood Products Applicant Intends to Certify3

1.00 $0.00 $2.25 $1.34 $3.59 

Description of TPC's Experience or Ability in Product 

Certification and Complying with ISO/IEC Guide 654 1.00 $0.00 $46.74 $34.06 $80.80 

Description of TPC's Experience in the Composite Wood 

Product Industry with the Product(s) Intended to be Certified4 1.00 $0.00 $46.74 $34.06 $80.80 

Description of TPC's Ability to Inspect and Properly Train and 

Supervise Inspectors Pursuant to ISO/IEC 170204 1.00 $0.00 $46.74 $34.06 $80.80 

Product Accreditation Subtotal $246

3. Laboratory Accreditation Body Application Submission

Company Information (Name, Address, Telephone Number, 

and Email Address of Primary Contact; if foreign, name and 

address of an agent for service located in the U.S.)3

1.00 $0.00 $2.25 $1.34 $3.59 

Description of TPC's Experience in Performing or Verifying 

Formaldehyde Testing on Composite Wood Products4 1.00 $0.00 $46.74 $34.06 $80.80 

Description of TPC's Experience Operating or Using 

Laboratories that Comply with ISO/IEC 170254 1.00 $0.00 $46.74 $34.06 $80.80 
TSCA Title VI Proposed TPC Rule Economic Analysis B-15

Table B-4: Recordkeeping and Reporting Labor Costs for Third Party Certifiers, by Activity (2010$)

Activity

Estimated Annual 

Frequency1 Clerical Cost2

Technical Cost2 Managerial Cost2Total Cost

Description of TPC's Experience with Test Method ASTM E1333-96 (2002) and Experience Evaluating Correlation between 

Test Methods4

1.00 $0.00 $46.74 $34.06 $80.80 

Laboratory Accreditation Subtotal $246

4. Manufacturer Notification

Third Party Certifier Number31.00 $0.00 $2.25 $1.34 $3.59 

Withdraw from Program or Lose Accreditation30.25 $0.00 $0.56 $0.33 $0.90 

Manufacturer Notification Subtotal $4

5. Recordkeeping

List of Manufacturers and their Product Types (including Resins 

Used) Certified by TPC5 1.00 $19.24 $84.47 $50.09 $153.79 

Results of Inspections, Audits, and Emission Tests Conducted 

for Each Manufacturer and Product Type5 1.00 $19.24 $84.47 $50.09 $153.79 

List of the TPC's Laboratories, Test Methods (including Test 

Conditions and Conditioning Time), and Test Results5 1.00 $19.24 $84.47 $50.09 $153.79 

Methods and Results for Establishing Test Method Correlations 

and Equivalence5 1.00 $19.24 $84.47 $50.09 $153.79 

List of Manufacturers and Products Approved for Reduced 

Testing5 1.00 $19.24 $84.47 $50.09 $153.79 
TSCA Title VI Proposed TPC Rule Economic Analysis B-16

Table B-4: Recordkeeping and Reporting Labor Costs for Third Party Certifiers, by Activity (2010$)

Activity

Estimated Annual 

Frequency1 Clerical Cost2

Technical Cost2 Managerial Cost2Total Cost

Recordkeeping Subtotal $769

6. Annual Report to Accreditation Bodies

List of Manufacturers and their Products Certified by the TPC 

during the Previous Year (including Resins Used, and the 

Average and Range of Formaldehyde Emissions by 

Manufacturer, Resin, and Product Type)6

1.00 $6.41 $28.16 $16.70 $51.26 

List of Noncomplying Products or Events by Manufacturer61.00 $6.41 $28.16 $16.70 $51.26 

List of Laboratories and Test Methods Used by the TPC61.00 $6.41 $28.16 $16.70 $51.26 

Results of Inter-Laboratory Comparison or Proficiency Testing 

for the Laboratories Used by the TPC6 1.00 $6.41 $28.16 $16.70 $51.26 

Annual Report to AB Subtotal $205

7. Accreditation Board Notification

Personnel Qualification Changes30.50 $0.00 $1.13 $0.67 $1.79 

Procedure Changes30.50 $0.00 $1.13 $0.67 $1.79 

Laboratory Changes30.50 $0.00 $1.13 $0.67 $1.79 

Accreditation Board Notification Subtotal $5

8. EPA Notification

Change in Name or Address of Domestic Agent (Foreign TPCs 0.50 $0.00 $1.13 $0.67 $2
TSCA Title VI Proposed TPC Rule Economic Analysis B-17

Table B-4: Recordkeeping and Reporting Labor Costs for Third Party Certifiers, by Activity (2010$)

Activity

Estimated Annual 

Frequency1 Clerical Cost2

Technical Cost2 Managerial Cost2Total Cost

Only)

3

Domestic Total in First Year $2,090 

Foreign Total in First Year $2,092 

Domestic Total in Non-Reapplication Year $983 

Foreign Total in Non-Reapplications Year $985 

Domestic Total in Reapplication Year $1,475 

Foreign Total in Reapplications Year $1,477 

Notes: 1. Based on best professional judgment and rule requirements. Under the proposed rule, TPCs are required to apply for re-accreditation every three years. As a result, application and 

accreditation costs are incurred every third 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 data from the "professional and related" 

occupational group; and managerial costs are estimated using data from the "management, business, and financial" occupational group. 3. Based on the estimated burden associated with 

reporting "company information" (EPA 2011a). 4. Based on the estimated burden associated with answering substantiation questions when making plant site confidentiality claims (EPA 2011a).

5. Based on the estimated burden associated with "recordkeeping" (EPA 2011a). The rule requires that records be kept for 3 years that show the production volume, plant site, and site-limited 

status of each reported substance. 6. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011a). Estimate based on best professional judgment.

Sources: (1) U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: Historical Data: December 2006 - March 2011, and (2) 

U.S. Environmental Protection Agency. 2011a. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule Addendum to Partial 

Update of the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.
TSCA Title VI Proposed TPC Rule Economic Analysis C-1

Appendix C – Costs and Benefits of Electronic Reporting

EPA is considering requiring mandatory electronic reporting requirement for accreditation 

bodies and TPCs (both referred to here as respondents). If EPA adopts this requirement for the TPC rule, 

respondents would submit their notifications and reports to EPA using the Central Data Exchange (CDX). 

The costs and benefits to respondents and to EPA are described below.

C.1 Costs and Benefits of Electronic Reporting to Accreditation Bodies and TPCs

All respondents incur costs in the first year to complete a subscriber agreement and register 

with CDX. Some respondents will incur CDX costs in subsequent years due to employee turnover or 

compromised electronic signatures. These costs are offset by reductions in reporting and recordkeeping 

costs due to electronic reporting.

CDX users are assigned to one of two roles in the CDX system, an Authorizing Official or a 

Support Registrant.

Authorized Official (AO): The AO is the person legally responsible for the submission. The AO is 

typically a senior official for the respondent. The AO is the only user who can start a new form, or 

reopen a completed form to begin the amendment process, and is the only user who can electronically 

sign and submit a form. AOs can also assign Support Registrants to edit and complete forms on his or 

her behalf. AOs must submit a subscriber agreement to EPA, and register with CDX.

Support Registrants: A Support Registrant is a person designated by an AO to submit supporting 

documents on his or her behalf. Support Registrants can edit a submission that is created by the AO. 

Support Registrants are only allowed to edit submissions that the AO has granted him or her access. 

Support Registrants do not have any access rights to create or submit a form. Once the AO creates a 

form, they will provide the Support Registrant with a passphrase to access the submission and complete 

all sections of the form. Once the Support Registrant has finished completing the form, the AO will 

access the submission, review it, and submit it. Support Registrants must register with CDX, but do not 

need to submit a subscriber agreement to EPA.
TSCA Title VI Proposed TPC Rule Economic Analysis C-2

This analysis uses a simplifying assumption that an average of five employees at each 

respondent will register with CDX: one manager (who will serve as AO) four technical staff members 

(who will serve as Support Registrants). 

C.1.1 First Year Costs for Accreditation Bodies and TPCs 

Respondents will incur electronic reporting costs in the first year to submit a subscriber 

agreement, register with CDX, and contact EPA’s CDX Help Desk.

Subscriber Agreement. An AO must complete a subscriber agreement in order to establish their identity 

and their relation to the entity for which they will submit electronic documents, as well as to document 

a unique correlation with the device that will be used to create their electronic signature. Users can 

comply with the subscriber agreement provisions in CDX either by submitting a paper subscriber 

agreement with a wet-ink signature, or by submitting an electronic signature agreement.

• Paper subscriber agreement. Preparing, submitting, and filing a paper subscriber agreement is 

estimated to require an average of 20 minutes of time per registrant (EPA 2011b), which is assumed 

to be managerial time. 

• Electronic signature agreement. Preparing, submitting, and filing an electronic signature agreement 

is estimated to require an average of 15 minutes of time per registrant (EPA 2011b), which is 

assumed to be managerial time. 

CDX Registration. CDX users will need to register with CDX, which involves selecting a user name and 

password, providing contact information, and identifying the facility and the registrant’s role at the 

facility. This is estimated to take an average of 10 minutes per user (EPA 2011b). This results in an 

estimate that each respondent will spend 10 minutes of managerial time and 40 minutes of technical 

time to register with CDX. 

Help Desk. CDX users are assumed to spend an average of 4 minutes contacting EPA’s CDX Help Desk 

for technical support (EPA 2011b), which results in an estimate of 4 minutes of managerial time and 16 

minutes of technical time per respondent. 
TSCA Title VI Proposed TPC Rule Economic Analysis C-3

Problem Resolution. Three percent of respondents each year are assumed to spend an average of one 

hour of technical time working with EPA’s CDX Help Desk to resolve problems involving their 

registrations or agreements (EPA 2011b).

C.1.2 Subsequent Year Costs for Accreditation Bodies and TPCs

In subsequent years, respondents may incur electronic reporting costs due to employee 

turnover and compromised electronic signatures.

Employee Turnover. It is assumed that each year 10 percent of CDX users will be replaced by new 

employees, who will have to comply with the subscriber agreement and/or CDX registration 

requirements (EPA 2011b). Thus, in subsequent years 10 percent of AOs will spend 15 to 20 minutes of 

managerial time to complete a subscriber agreement. In addition, 10 percent of all users (both 

managerial and technical) will spend 10 minutes to register with CDX and 4 minutes contacting EPA’s 

CDX Help Desk.

Report Compromised Signature. Each year 1 percent of respondents are assumed to report a 

compromised or surrendered electronic signature, which requires the submittal of a new subscriber 

agreement (EPA 2011b). This will entail 15 to 20 minutes of managerial time to prepare, submit, and file 

a new agreement, and 4 minutes of managerial time to contact EPA’s CDX Help Desk.

C.1.3 Savings for Accreditation Bodies and TPCs

Electronic reporting is assumed to reduce the recordkeeping burden by 50 percent, and to 

eliminate the use of clerical time for reporting and recordkeeping(EPA 2009). For ABs, this is estimated 

to result in average savings of 3.75 hours of clerical time in the first year and 2.75 hours in subsequent 

years, as well as 1 hour of technical time and 0.5 hours of managerial time in all years. For TPCs, this is 

estimated to result in average savings of 4.75 hours of clerical time, 2.5 hours of technical time, and 1.25 

hours of managerial time per year.

Electronic reporting also has the following benefits for respondents:
TSCA Title VI Proposed TPC Rule Economic Analysis C-4

• The number of forms that need to be resubmitted because they are incomplete or invalid should be 

greatly reduced because forms cannot be submitted via CDX if any required fields are incomplete, or 

if the submission fails internal validation checks;

• All of the respondent’s relevant staff will be able to access the CDX forms easily and directly input 

their information, so the system will facilitate easier internal review by the respondent prior to 

submission;

• Filling out a form similar to one previously submitted will be faster with electronic reporting, as the 

respondent will already have an electronic copy of the earlier form to edit rather than having to fill 

out a new form; and

• All routine correspondence with the Agency (including submission of supporting documents) will be 

via CDX, which saves time and delivery costs and reduces delays in EPA’s review.

EPA has not estimated the value of these additional savings to respondents. 

C.1.4 Changes in Costs to Accreditation Bodies and TPCs due to Electronic Reporting 

As shown in Table C-1, accreditation bodies would accrue savings of $99 to $177 per year 

(depending on whether it is the initial year, reapplication year, or non-reapplication year). TPCs would 

accrue savings of $259 to $337 per year (depending on whether it is the initial year, a reapplication year, 

or non-reapplication year), as shown in Table C-2. The total savings for U.S. accreditation bodies would 

be $1,193 per year using a 3 percent discount rate and $1,146 per year using a 7 percent discount rate, 

as shown in Table C-3. As shown in Table C-4, the total savings for U.S. TPCs would be $2,852 per year 

using a 3 percent discount rate and $2,754 per year using a 7 percent discount rate. 

As shown in Table C-5, electronic reporting via CDX would reduce the annualized costs of the 

rule to U.S. accreditation bodies and respondents from $33,535 to $29,490 per year using a 3 percent 

discount rate, a savings of $4,045 per year. Using a 7 percent discount rate, costs are estimated to 
TSCA Title VI Proposed TPC Rule Economic Analysis C-5

decrease from $34,443 to $30,542, a savings of $3,900 per year. There are additional unquantified 

improvements in efficiency and higher data quality due to electronic reporting.

As shown in Table C-6, electronic reporting via CDX would reduce the average total burden 

hours for all 61 domestic and foreign respondents from 1,421 hours to 1,029 hours per year, a savings of 

392 hours per year. 
TSCA Title VI Proposed TPC Rule Economic Analysis C-6

Table C-1: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Accreditation Body

Activity

Per Activity Burden Hours

Number 

of 

Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr)

Total

(a) (b) (c) (e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

1. CDX Electronic Reporting (First Year)

Electronic Subscriber Agreements 

(domestic firms)

- - 0.250 1.00 0.250 - - $16.70 $16.70

Paper Subscriber Agreements 

(foreign firms) - - 0.330 1.00 0.330 - - $22.04 $22.04

CDX Registration - 0.670 0.170 1.00 0.840 - $37.73 $11.35 $49.08

Help Desk - 0.270 0.070 1.00 0.340 - $15.20 $4.67 $19.88

Problem Resolution - 1.000 - 0.03 0.030 - $1.69 - $1.69

Subtotal (domestic) 1.460 $87.00

Subtotal (foreign) 1.540 $93.00

2. CDX Electronic Reporting (Subsequent Years)

Electronic Subscriber Agreements 

(domestic firms)

- - 0.250 0.10 0.025 - - $1.67 $1.67

Paper Subscriber Agreements 

(foreign firms)

- - 0.330 0.10 0.033 - - $2.20 $2.20
TSCA Title VI Proposed TPC Rule Economic Analysis C-7

Table C-1: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Accreditation Body

Activity

Per Activity Burden Hours

Number 

of 

Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr)

Total

(a) (b) (c)

(e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

CDX Registration - 0.670 0.170 0.10 0.084 - $3.77 $1.14 $4.91

Help Desk - 0.270 0.070 0.10 0.034 - $1.52 $0.47 $1.99

Report Compromised Signature 0.400 0.01 0.004 - - $0.27 $0.27

Subtotal (domestic) 0.147 $9.00

Subtotal (foreign) 0.155 $9.00

3. Recognition Agreement (1.000) - - 1.000 (1.000) $(25.65) - - ($26.00)

4. Recordkeeping

Accreditation Applications (0.750) (0.500) (0.250) 1.000 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)

Checklists and Other Records 

Documenting Compliance with the 

Requirements for Systems Audits 

and On-site Assessment of Third 

Party Certifiers

(0.750) (0.500) (0.250) 1.000 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)

Subtotal (3.000) ($128.00)

5. Annual Report to EPA
TSCA Title VI Proposed TPC Rule Economic Analysis C-8

Table C-1: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Accreditation Body

Activity

Per Activity Burden Hours

Number 

of 

Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr)

Total

(a) (b) (c)

(e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

Number of Third Party Certifier 

Applications Received

(0.250) - - 1.000 (0.250) $(6.41) - - $(6.41)

Number of Third Party Certifier 

Applications Approved and Denied

(0.250) - - 1.000 (0.250) $(6.41) - - $(6.41)

The Names and Contact 

Information of All Accredited Third 

Party Certifiers

(0.250) - - 1.000 (0.250) $(6.41) - - $(6.41)

Number and Locations of Systems 

Audits and On-site Assessments

(0.250) - - 1.000 (0.250) $(6.41) - - $(6.41)

Results of Accredited Third Party 

Certifier Laboratory Proficiency 

Testing or Inter-laboratory 

Comparisons

(0.250) - - 1.000 (0.250) $(6.41) - - $(6.41)

Subtotal (1.250) $(32.00)

Domestic Total in First Year (3.790) ($99.00)

Foreign Total in First Year (3.710) ($93.00)

Domestic Total in Non-Reapplication 

Year 

(4.103) ($151.00)
TSCA Title VI Proposed TPC Rule Economic Analysis C-9

Table C-1: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Accreditation Body

Activity

Per Activity Burden Hours

Number 

of 

Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr)

Total

(a) (b) (c)

(e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

Foreign Total in Non-Reapplications 

Year 

(4.095) ($151.00)

Domestic Total in Reapplication Year (5.103) ($177.00)

Foreign Total in Reapplications Year (5.095) ($177.00)
TSCA Title VI Proposed TPC Rule Economic Analysis C-10

Table C-1: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Accreditation Body

Activity

Per Activity Burden Hours

Number 

of 

Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr)

Total

(a) (b) (c)

(e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

Notes:

1. CDX Electronic Reporting (first year): 

 Electronic signature agreement. Preparing, submitting, and filing an electronic signature agreement is estimated to require an average of 15 minutes of time per

respondent, which is assumed to be managerial time (EPA 2011b). 

 Paper subscriber agreement. Preparing, submitting, and filing a paper subscriber agreement is estimated to require an average of 20 minutes of time per respondent, 

which is assumed to be managerial time (EPA 2011b). 

 CDX Registration. CDX users will need to register with CDX, which involves selecting a user name and password, providing contact information, and identifying the facility 

and the registrant’s role at the facility. This is estimated to take an average of 10 minutes per user (EPA 2011b). This results in an estimate that each respondent will 

spend 10 minutes of managerial time and 40 minutes of technical time to register with CDX. 

 Help Desk. CDX users are assumed to spend an average of 4 minutes contacting EPA’s CDX Help Desk for technical support (EPA 2011b), which results in an estimate of 4 

minutes of managerial time and 16 minutes of technical time per respondent. 

 Problem Resolution. Three percent of respondents each year are assumed to spend an average of one hour of technical time working with EPA’s CDX Help Desk to resolve 

problems involving their registrations or agreements (EPA 2011b).

2. CDX Electronic Reporting (subsequent years): 

 Employee Turnover. It is assumed that each year 10 percent of CDX users will be replaced by new employees, who will have to comply with the subscriber agreement 

and/or CDX registration requirements (EPA 2011b). Thus, in subsequent years 10 percent of CDX users will spend 15 to 20 minutes of managerial time to complete a 

subscriber agreement. In addition, 10 percent of all CDX users (both managerial and technical) will spend 10 minutes to register with CDX and 4 minutes contacting EPA’s 

CDX Help Desk. 

 Report Compromised Signature. Each year 1 percent of respondents are assumed to report a compromised or surrendered electronic signature, which requires the 

submittal of a new subscriber agreement (EPA 2011b). This will entail 15 to 20 minutes (20 assumed here) of managerial time to prepare, submit, and file a new 

agreement, and 4 minutes of time to contact EPA’s CDX Help Desk.



3. Recognition Agreement 

 Electronic reporting is assumed to eliminate the use of clerical time for the recognition agreement.

4. Recordkeeping

 Electronic reporting is assumed to reduce the recordkeeping burden by 50 percent (EPA 2009). 

5. Annual Report to EPA

 Electronic reporting is assumed to reduce the recordkeeping burden by 50 percent (EPA 2009).

Sources: (1) U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: Historical Data: December 2006 - March 2011, and 

(2) U.S. Environmental Protection Agency. 2011a. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule Addendum to 

Partial Update of the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.
TSCA Title VI Proposed TPC Rule Economic Analysis C-11
TSCA Title VI Proposed TPC Rule Economic Analysis C-12

Table C-2: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Third Party Certifier

Activity

Per Activity Burden Hours

Number 

of Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr)

Total

(a) (b) (c)

(e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

1. CDX Electronic Reporting (First Year)

Electronic Subscriber 

Agreements (domestic firms)

- - 0.250 1.00 0.250 - - $16.70 $16.70

Paper Subscriber Agreements 

(foreign firms)

- - 0.330 1.00 0.330 - - $22.04 $22.04

CDX Registration - 0.670 0.170 1.00 0.840 - $37.73 $11.35 $49.08

Help Desk - 0.270 0.070 1.00 0.340 - $15.20 $4.67 $19.88

Problem Resolution - 1.000 - 0.03 0.030 - $1.69 $1.69

Subtotal (domestic) 1.460 $87.00

Subtotal (foreign) 1.540 $93.00

2. CDX Electronic Reporting (Subsequent Years)

Electronic Subscriber 

Agreements (domestic firms) - - 0.250 0.10 0.025 $0.00 $0.00 $1.67 $1.67

Paper Subscriber Agreements 

(foreign firms) - - 0.330 0.10 0.033 $0.00 $0.00 $2.20 $2.20

CDX Registration - 0.670 0.170 0.10 0.084 $0.00 $3.77 $1.14 $4.91
TSCA Title VI Proposed TPC Rule Economic Analysis C-13

Table C-2: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Third Party Certifier

Activity

Per Activity Burden Hours

Number 

of Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr)

Total

(a) (b) (c)

(e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

Help Desk - 0.270 0.070 0.10 0.034 $0.00 $1.52 $0.47 $1.99

Report Compromised Signature - - 0.400 0.01 0.004 $0.00 $0.00 $0.27 $0.27

Subtotal (domestic) 0.147 $9.00

Subtotal (foreign) 0.155 $9.00

3. Manufacturer Notification and Recordkeeping

List of Manufacturers and their 

Product Types (including Resins 

Used) Certified by TPC

(0.750) (0.5) (0.25) 1.00 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)

Results of Inspections, Audits, 

and Emission Tests Conducted 

for Each Manufacturer and 

Product Type

(0.750) (0.5) (0.25) 1.00 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)

List of the TPC's Laboratories, 

Test Methods (including Test 

Conditions and Conditioning 

Time), and Test Results

(0.750) (0.5) (0.25) 1.00 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)

Methods and Results for 

Establishing Test Method 

Correlations and Equivalence

(0.750) (0.5) (0.25) 1.00 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)
TSCA Title VI Proposed TPC Rule Economic Analysis C-14

Table C-2: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Third Party Certifier

Activity

Per Activity Burden Hours

Number 

of Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr)

Total

(a) (b) (c)

(e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

List of Manufacturers and 

Products Approved for 

Reduced Testing

(0.750) (0.5) (0.25) 1.00 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)

Subtotal (7.500) $(320.00)

4. Annual Report and Notifications 

of Changes

List of Manufacturers and their 

Products Certified by the TPC 

during the Previous Year 

(including Resins Used, and the 

Average and Range of 

Formaldehyde Emissions by 

Manufacturer, Resin, and 

Product Type)

(0.250) - - 1.00 (0.250) ($6.41) - - ($6.41)

List of Noncomplying Products 

or Events by Manufacturer

(0.250) - - 1.00 (0.250) ($6.41) - - ($6.41)

List of Laboratories and Test 

Methods Used by the TPC

(0.250) - - 1.00 (0.250) ($6.41) - - ($6.41)
TSCA Title VI Proposed TPC Rule Economic Analysis C-15

Table C-2: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Third Party Certifier

Activity

Per Activity Burden Hours

Number 

of Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr)

Total

(a) (b) (c)

(e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

Results of Inter-Laboratory 

Comparison or Proficiency 

Testing for the Laboratories 

Used by the TPC

(0.250) - - 1.00 (0.250) ($6.41) - - ($6.41)

Subtotal (1.00) $(26.00)

Domestic Total in First Year (7.040) ($259.00)

Foreign Total in First Year (6.960) ($253.00)

Domestic Total in NonReapplication Year 

(8.353) ($337.00)

Foreign Total in NonReapplications Year 

(8.345) ($337.00)

Domestic Total in Reapplication 

Year

(8.353) ($337.00)

Foreign Total in Reapplications 

Year

(8.345) ($337.00)
TSCA Title VI Proposed TPC Rule Economic Analysis C-16

Table C-2: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Third Party Certifier

Activity

Per Activity Burden Hours

Number 

of Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr)

Total

(a) (b) (c)

(e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

Notes:

1. CDX Electronic Reporting (first year): 

 Electronic signature agreement. Preparing, submitting, and filing an electronic signature agreement is estimated to require an average of 15 minutes of time per user, 

which is assumed to be managerial time (EPA 2011b). 

 Paper subscriber agreement. Preparing, submitting, and filing a paper subscriber agreement is estimated to require an average of 20 minutes of time per user, which is 

assumed to be managerial time (EPA 2011b). 

 CDX Registration. CDX users will need to register with CDX, which involves selecting a user name and password, providing contact information, and identifying the facility 

and the registrant’s role at the facility. This is estimated to take an average of 10 minutes per registrant (EPA 2011b). This results in an estimate that each respondent 

will spend 10 minutes of managerial time and 40 minutes of technical time to register with CDX. 

 Help Desk. CDX users are assumed to spend an average of 4 minutes contacting EPA’s CDX Help Desk for technical support (EPA 2011b), which results in an estimate of 4 

minutes of managerial time and 16 minutes of technical time per respondent. 

 Problem Resolution. Three percent of respondents each year are assumed to spend an average of one hour of technical time working with EPA’s CDX Help Desk to 

resolve problems involving their registrations or agreements (EPA 2011b).

2. CDX Electronic Reporting (subsequent years): 

 Employee Turnover. It is assumed that each year 10 percent of CDX users will be replaced by new employees, who will have to comply with the subscriber agreement 

and/or CDX registration requirements (EPA 2011b). Thus, in subsequent years 10 percent of CDX users will spend 15 to 20 minutes of managerial time to complete a 

subscriber agreement. In addition, 10 percent of all registrants will spend 10 minutes to register with CDX and 4 minutes contacting EPA’s CDX Help Desk. Paper 

subscriber agreement. Preparing, submitting, and filing a paper subscriber agreement is estimated to require an average of 20 minutes of time per registrant (EPA 

2011b). This results in an estimate of 20 minutes of managerial time per respondent submitting a paper subscriber agreement. 

 Report Compromised Signature. Each year 1 percent of respondents are assumed to report a compromised or surrendered electronic signature, which requires the 

submittal of a new subscriber agreement (EPA 2011b). This will entail 15 to 20 minutes (20 assumed here) of managerial time to prepare, submit, and file a new 

agreement, and 4 minutes of time to contact EPA’s CDX Help Desk.

 Problem Resolution. Three percent of respondents each year are assumed to spend an average of one hour of technical time working with EPA’s CDX Help Desk to 

resolve problems involving their registrations or agreements (EPA 2011b).

3. Recordkeeping

 Electronic reporting is assumed to reduce the recordkeeping burden by 50 percent (EPA 2009). 

4. Annual Report to Recordkeeping Bodies

 Electronic reporting is assumed to reduce the recordkeeping burden by 50 percent (EPA 2009).

Sources: (1) U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: Historical Data: December 2006 - March 2011, 

and (2) U.S. Environmental Protection Agency. 2011a. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule 

Addendum to Partial Update of the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.
TSCA Title VI Proposed TPC Rule Economic Analysis C-17
TSCA Title VI Proposed TPC Rule Economic Analysis C-18

Table C-3: U.S. Accreditation Body Cost Summary With Electronic Reporting Requirements

Type of Cost

Cost (2010$)

First Year Reapplication Years1Non-Reapplication Years

Costs without CDX Requirements

Rule Familiarization $615 $0 $0

Application or Reapplication Process $88 $88 $0

Prepare Recognition Agreement $349 $349 $0

EPA Notification $57 $57 $57

TPC Notification $12 $12 $12

Recordkeeping $308 $308 $308

Reporting $256 $256 $256

Cost per Accreditation Body $1,685 $1,070 $633

Number of Accreditation Bodies 8 8 8

Total Costs for U.S. Accreditation Bodies $13,480 $8,560 $5,064

Annualized Costs (30 years, 3 percent) $6,303 

Annualized Costs (30 years, 7 percent) $6,320 

Incremental Costs for CDX Requirements

CDX Registration $87 $9 $9 

Prepare Recognition Agreement ($26) ($26)
TSCA Title VI Proposed TPC Rule Economic Analysis C-19

Recordkeeping ($128) ($128) ($128)

Reporting ($32) ($32) ($32)

Cost per Accreditation Body ($99) ($177) ($151)

Number of Accreditation Bodies 8 8 8

Total Costs for U.S. Accreditation Bodies ($792) ($1,416) ($1,208)

Annualized Costs (30 years, 3 percent) ($1,193)

Annualized Costs (30 years, 7 percent) ($1,146)

Total Costs, Including Incremental Costs for CDX Requirements

Rule Familiarization $615 $0 $0 

CDX Registration $87 $9 $9 

Application or Reapplication Process $88 $88 $0 

Prepare Recognition Agreement $323 $323 $0 

EPA Notification $57 $57 $57 

TPC Notification $12 $12 $12 

Recordkeeping $180 $180 $180 

Reporting $224 $224 $224 

Cost per Accreditation Body $1,586 $893 $482 

Number of Accreditation Bodies 8 8 8

Total Costs for U.S. Accreditation Bodies $12,688 $7,144 $3,856 

Annualized Costs (30 years, 3 percent) $5,102 
TSCA Title VI Proposed TPC Rule Economic Analysis C-20

Annualized Costs (30 years, 7 percent) $5,167 
TSCA Title VI Proposed TPC Rule Economic Analysis C-21

Table C-4: U.S. TPC Cost Summary With Electronic Reporting Requirements

Type of Cost

Cost (2010$)

First Year Reapplication Years1Non-Reapplication Years

Have Accred. Need Accred. Have Accred. Need Accred. Have Accred. Need Accred.

Costs without Electronic Reporting Requirements

Accreditation $0 $25,000 $0 $5,000 $0 $5,000

Rule Familiarization $615 $615 $0 $0 $0 $0

Application or Reapplication Process $492 $492 $492 $492 $0 $0

Manufacturer Notification and Recordkeeping $773 $773 $773 $773 $773 $773

Annual Report and Notifications of Changes $210 $210 $210 $210 $210 $210

Cost per TPC $2,090 $27,090 $1,475 $6,475 $983 $5,983

Number of TPCs 6 3 6 3 6 3

Total Costs for U.S. TPCs $12,540 $81,270 $8,850 $19,425 $5,898 $17,949

Annualized Costs (30 years, 3 percent) $27,232 

Annualized Costs (30 years, 7 percent) $28,123 

Incremental Costs for Electronic Reporting Requirements

CDX Electronic Reporting $87 $87 $9 $9 $9 $9

Manufacturer Notification and Recordkeeping ($320) ($320) ($320) ($320) ($320) ($320)

Annual Report and Notifications of Changes ($26) ($26) ($26) ($26) ($26) ($26)
TSCA Title VI Proposed TPC Rule Economic Analysis C-22

Cost per TPC ($259) ($259) ($337) ($337) ($337) ($337)

Number of TPCs 6 3 6 3 6 3

Total Costs for U.S. TPCs ($1,554) ($777) ($2,022) ($1,011) ($2,022) ($1,011)

Annualized Costs (30 years, 3 percent) ($2,852)

Annualized Costs (30 years, 7 percent) ($2,754)

Total Costs, Including Incremental Costs for Electronic Reporting Requirements

Accreditation $0 $25,000 $0 $5,000 $0 $5,000

Rule Familiarization $615 $615 $0 $0 $0 $0

CDX Electronic Reporting $87 $87 $9 $9 $9 $9

Application or Reapplication Process $492 $492 $492 $492 $0 $0

Manufacturer Notification and Recordkeeping $453 $453 $453 $453 $453 $453

Annual Report and Notifications of Changes $184 $184 $184 $184 $184 $184

Cost per TPC $1,831 $26,831 $1,138 $6,138 $646 $5,646

Number of TPCs 6 3 6 3 6 3

Total Costs for U.S. TPCs $10,986 $80,493 $6,828 $18,414 $3,876 $16,938

Annualized Costs (30 years, 3 percent) $24,380 

Annualized Costs (30 years, 7 percent) $25,368 
TSCA Title VI Proposed TPC Rule Economic Analysis C-23
TSCA Title VI Proposed TPC Rule Economic Analysis C-24

Table C-5: Cost Summary for U.S. Accreditation Bodies and TPCs With Electronic Reporting Requirements

Type of Cost

Cost (2010$)

First Year Reapplication Years1Non-Reapplication Years

Costs without CDX Requirements

Accreditation Bodies $13,480 $8,560 $5,064

Third Party Certifiers $93,810 $28,275 $23,847

Total Costs $107,290 $36,835 $28,911

Annualized Costs (30 years, 3 percent) $33,535 

Annualized Costs (30 years, 7 percent) $34,443 

Incremental Costs for CDX Requirements

Accreditation Bodies ($792) ($1,416) ($1,208)

Third Party Certifiers ($2,331) ($3,033) ($3,033)

Total Costs ($3,123) ($4,449) ($4,241)

Annualized Costs (30 years, 3 percent) ($4,045)

Annualized Costs (30 years, 7 percent) ($3,900)

Total Costs, Including Incremental Costs for CDX Requirements

Accreditation Bodies $12,688 $7,144 $3,856

Third Party Certifiers $91,479 $25,242 $20,814

Total Costs $104,167 $32,386 $24,670
TSCA Title VI Proposed TPC Rule Economic Analysis C-25

Annualized Costs (30 years, 3 percent) $29,490 

Annualized Costs (30 years, 7 percent) $30,542 
TSCA Title VI Proposed TPC Rule Economic Analysis C-26

Table C-6: Total Bottom Line Burden and Costs (Domestic and Foreign)

Year 1 Year 2 Year 3 Average

Costs without Electronic Reporting Requirements

Number of Respondents and Responses 61 61 61 61

Total Burden Hours 2,085.64 995.38 1,181.88 1,421

Total Cost $417,470 $111,318 $122,243 $217,010

Incremental Burden and Costs for Electronic Reporting Requirements

Number of Respondents and Responses 61 61 61 61

Total Burden Hours (344.67) (402.93) (427.93) (392)

Total Cost ($11,535) ($15,907) ($16,557) ($14,666)

Total Burden and Costs, Including Incremental Burden and Costs for Electronic Reporting Requirements

Number of Respondents and Responses 61 61 61 61

Total Burden Hours 1,740.97 592.44 753.94 1,029

Total Cost $405,935 $95,411 $105,686 $202,344 
TSCA Title VI Proposed TPC Rule Economic Analysis C-27

C.2 Costs and Benefits of Electronic Reporting to EPA

A portion of the cost that EPA incurs to operate the CDX system can be attributed to the TSCA 

Title VI program. These costs are described below.

CDX O&M – The cost of CDX operations and maintenance for TSCA Title VI electronic reporting is 

estimated to be approximately $3,000 per year.

CDX Application Support O&M – The cost of application support operations and maintenance (for Help 

Desk support, resolving technical problems, software maintenance and upgrades, etc.) for TSCA Title VI 

electronic reporting is estimated to be approximately $25,000 per year.

CDX Software Licensing Costs – EPA’s cost of software licensing attributable to TSCA Title VI is estimated 

to be approximately $6,000 per year.

CDX CBI LAN O&M – The cost attributable of operations and maintenance of EPA’s confidential business 

administration (CBI) local area network (LAN) attributable to TSCA Title VI is estimated to be 

approximately $15,000 per year.

EPA staff – Managing the CDX system related to the TSCA Title VI program is estimated to require 

approximately 0.1 FTE per year of EPA staff. Based on the 2010 Washington/Baltimore area annual 

salary rate for a GS-13, Step 5 employee ($100,904) and a loading factor of 1.6 for overhead and fringe 

benefits, the cost of the EPA staff needed to manage the CDX program attributable to the TSCA Title VI is 

estimated to be $16,145 per year. 

Overall, EPA’s cost for operating the CDX system that can be attributed to the TSCA Title VI program is 

estimated at $65,145 per year.

The use of electronic reporting and CDX also has benefits for EPA. It is expected to improve 

efficiency and lead to higher quality data being available more quickly to EPA. EPA typically keys or 

scans in the data from paper submissions, which can result in errors. Consequently, EPA must perform 
TSCA Title VI Proposed TPC Rule Economic Analysis C-28

quality assurance checks on extracted and scanned information. When data is submitted electronically, 

the time required for EPA staff to review and process the information is reduced because manual data 

entry or processing is eliminated. Electronic reporting also improves data quality because it facilitates 

data correction and validation by highlighting fields with omitted or inconsistent data prior to 

submission. EPA has not estimated the value of these efficiencies and improvements in data quality.