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 INFORMATION COLLECTION REQUEST (ICR) 

 SF-83 SUPPORTING STATEMENT 

 ENVIRONMENTAL PROTECTION AGENCY 

 STRATOSPHERIC OZONE PROTECTION 

1. Identification of Information Collection

a) Title: Significant New Alternatives Policy (SNAP) Program Final Rulemaking under Title VI 

of the Clean Air Act Amendments of 1990 (OMB Control Number: 2060-0226) 

b) Short Characterization

Title VI of the Clean Air Act Amendments of 1990 (the Act) implements the obligation of the 

United States under the Montreal Protocol on Substances that Deplete the Ozone Layer to 

phase out the use of ozone-depleting substances. Section 612 of Title VI establishes as U.S. 

policy the requirement that Class I and Class II ozone-depleting substances shall be replaced, 

to the maximum extent practicable, by chemicals, product substitutes, or alternative 

manufacturing processes that reduce overall risks to human health and the environment. 

EPA developed its Significant New Alternatives Policy (SNAP) program to fulfill the 

requirements of Section 612. The five major provisions of Section 612 are: 

Rulemaking: Section 612(c) requires EPA to enact rules making it unlawful to replace any 

Class I or II substance with any substitute that the Administrator determines may present 

adverse effects to human health or the environment where an alternative has been identified 

that (1) reduces the overall risk to human health and the environment, and (2) is currently or 

potentially available. 

Listing of Unacceptable/Acceptable Substitutes: Section 612(c) also requires EPA to publish a 

list of the substitutes prohibited for specific uses. EPA must publish a corresponding list of 

acceptable alternatives for specific uses as well. 

 Petition Process: Section 612(d) grants the right for any person to petition EPA to add or delete 

a substance from the lists published in accordance with Section 612(c). EPA has 90 days to 

grant or deny a petition. 

 90-day notification: Section 612(e) authorizes EPA to require any person who produces a 

chemical substitute for a Class I substance to notify EPA not less than 90 days before the new 

or existing chemicals are introduced into interstate commerce for significant new uses as 

substitutes for a Class I substance. The producer must also provide EPA with all unpublished 

health and safety studies on such substitutes. 

 Clearinghouse: Section 612(b)(4) requires EPA to set up a public clearinghouse of alternative 

chemicals, product substitutes, and alternative manufacturing processes that are available for 

products and manufacturing processes which use Class I and II substances. 

EPA issued regulations on March 18, 1994, in 59 FR 13043, which are codified at 40 Code of 

Federal Regulations (CFR) Part 82, Subpart G (Section 82.170 et seq.), establishing the SNAP 
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program. EPA’s major activities in the SNAP program are to review proposed substitutes based 

on the risk-assessment criteria and the procedures set forth in the regulations, and to publish 

(and update) lists of acceptable and unacceptable substitutes by end use categories. 

The information required for collection under the SNAP regulations is described below in 

Section 4 of this statement, and is currently approved by OMB for use through June 30, 2011. 

EPA is in the process of publishing a notice of intention to renew this information collection 

request. This notice of intention will be published in the Federal Register. 

The previous ICR of 2007 had the following Terms of Clearance: 

“The collection is approved for 3 years. OMB notes that the recordkeeping requirement does not 

stem from the requirements of the SNAP program but from the enforcement requirements as 

stated in the supporting statement. If the agency revises the enforcement requirements, then 

the recordkeeping requirement should be updated accordingly. “ 

EPA is not revising enforcement requirements at this time. 

2. Need for and Use of the Collection 

a) Authority for the Collection 

Information required to be collected under the SNAP program is intended to fulfill the general 

mandate in Section 612(c) of identifying acceptable substitutes that can serve as replacements 

for ozone-depleting substances being phased out under the Act, as well as unacceptable 

substances which may not be used as replacements for ozone-depleting substances being 

phased out under the Act. Section 612 (42 U.S.C. 7671k) is attached as Appendix B, and 

EPA’s implementing regulations (40 CFR Part 82, Subpart G, Sect. 82.170 et seq.) are attached 

as Appendix C. 

b) Use/Users of the Data

EPA's Stratospheric Protection Division (SPD) uses the information submitted to evaluate the 

health and environmental effects of proposed alternatives for industrial and commercial uses 

that have historically used Class I and Class II ozone-depleting substances. 

3. Non-duplication, Consultations, and Other Collection Criteria 

a) Non-duplication 

The specific information requested by this notice is not currently collected by EPA or any other 

government agency. According to the United Nations Environment Programme (UNEP) report, 

Environmental Effects of Ozone Depletion and its Interactions with Climate Change: 2010 

Assessment, EPA’s SNAP program is the only national program in the world designed to 

evaluate alternatives to ozone-depleting substances, and as such, represents the most 

comprehensive and accessible resource for information on alternatives. 

Use of the Toxic Substances Control Act (TSCA) SNAP Addendum form (described in section 

4(b) of this statement) will ensure that companies participating in the TSCA Pre-Manufacture 

Notice (PMN) program will not duplicate their data in reporting to the SNAP program. 
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b) Public Notice Required Prior to ICR Submission to OMB

In compliance with the 1995 Paperwork Reduction Act (PRA), EPA sought public comments for 

a 60-day period prior to submitting the ICR renewal package to OMB. These comments, which 

are used partly to determine realistic burden estimates for respondents, must be considered 

when completing the Supporting Statement that is submitted to OMB. 

The announcement of a public comment period for this renewal ICR was published in the 

Federal Register on January 31, 2011 (76 FR 5366). EPA sought public comments, pursuant to 

5 CFR 1320.8(d), on the previous burden estimates being sought by the Agency. EPA received 

no comments. 

c) Consultations

In developing the regulations under the Act, EPA established an advisory committee for issues 

relating to stratospheric ozone. The Stratospheric Ozone Protection Advisory Committee 

(STOPAC) membership included representatives from affected industries, environmental 

interest groups, and academics in related fields. Within the STOPAC, subcommittees were 

formed to look at more detailed issues. The subcommittee on the SNAP program met several 

times to discuss possible substitutes for ozone-depleting substances, guiding principles for 

SNAP evaluations, and strategies to obtain information about substitutes from industry. This 

consultation was invaluable in developing the SNAP Information Notice form (described below 

in section 4(b).) EPA also received comments on its proposed SNAP regulations, which 

identified the information to be collected through the SNAP program, and these comments were 

also helpful in developing the SNAP Information Notice form. 

In preparing to renew this information collection request, EPA consulted with fewer than nine 

actual or potential respondents to discuss estimated burden hours and costs associated with 

this information collection request. The respondents with whom EPA consulted are from various 

industries, companies, and organizations that have recently reported to the SNAP program. 

They include: Katarzyna Bober of Honeywell at 973-455-4420; Kelley Kline of General Electric 

at 502-452-7603; and Nesa Dunn of Global Safety Labs at 918-551-5514. 

d) Effects of Less Frequent Collection

The SNAP program has minimized the number of reporting and recordkeeping requirements as 

much as possible by requiring only a one-time application, and a one-time recordkeeping of 

documents submitted to EPA. 

e) General Guidelines 

This rule does not exceed any of the guidelines, except for records retention for more than 3 

years. Retention periods for the two SNAP recordkeeping requirements (described below in 

section 4(b) of this statement) are not specified in Title VI of the Act or in the SNAP regulations, 

but EPA requires retention of these records for five years for enforcement purposes, pursuant to 

statutory authority under 28 U.S.C. Section 2462, the applicable statute of limitations. Sec. 

2462 states: 

Except as otherwise provided by Act of Congress, an action, suit or proceeding for the 

enforcement of any civil fine, penalty, or forfeiture, pecuniary or otherwise, shall not be 
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entertained unless commenced within five years from the date when the claim first accrued 

if, within the same period, the offender or the property is found within the United States in 

order that proper service may be made thereon.

f) Confidentiality 

Measures to protect confidentiality of information collected under the SNAP program are based 

on EPA’s confidentiality regulations (40 CFR 2.201 et seq., or Subpart B.) SNAP regulations (at 

40 CFR 82.182) describe these measures, which are also mentioned on the front page of each 

of the SNAP forms. Each form mentions basic information about asserting confidentiality 

claims, and also instructs the submitter to read the Instruction Manual, which contains more 

detailed discussion of the procedures for confidentiality claims. (See pages 7-9 of the 

Instruction Manual, which, as described in section 4(b), is attached as Appendix F). These 

procedures are described briefly below. 

Submitters may designate all or portions of their forms or petitions as confidential. EPA requires 

the submitters to substantiate their claim of confidentiality. The submitter is advised that, under 

Section 114(c) of the Act, emissions data may not be claimed as confidential. The submitter is 

also advised that there are further instances, described in the provisions of 40 CFR Part 2, 

Subpart B, in which confidential assertions may be reopened or denied even when 

confidentiality claims are initially received. The submitter will be contacted as part of such an 

evaluation process. If required substantiation is not provided along with the submission of 

information claimed as confidential, EPA may make the information available to the public 

without further notice. The submitter must provide one copy of the submission which contains 

no information claimed as confidential. The non-confidential submission will be put in the public 

docket. 

If toxicity or health and safety studies are listed as confidential, this information cannot be 

maintained as confidential where such data are also submitted under TSCA or the Federal 

Insecticide, Fungicide and Rodenticide Act (FIFRA) to the extent that confidential treatment is 

prohibited under those statutes. However, information in a toxicity study that is not health and 

safety data and is not relevant to the effects of a substance on human health and the 

environment, e.g., discussion of process information, or proprietary blends, can be maintained 

as confidential subject to 40 CFR Part 2, Subpart B. 

Information submitted as part of a joint submission to either SNAP/TSCA or SNAP/FIFRA must 

adhere to the security provisions of the program offices implementing these statutes. For such 

submissions, the SNAP handling of such notices will follow the security provisions under these 

statutes. 

g) Sensitive Questions 

This section does not apply because the SNAP regulations and the associated information 

collection request do not seek information of a sensitive nature. 
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4. The Respondents and the Information Requested 

a) Respondents

Respondents for reporting requirements, as well as for the recordkeeping requirement for the 

exemption for small volume use, include manufacturers, importers, formulators and processors 

of substitutes for ozone-depleting substances. Principally, these respondents are in the 

following major categories of industry groups, by Standard Industry Code (SIC) and North 

American Industry Classification System (NAICS): 

Manufacturers, Chemicals and Allied Products 

Industry SIC NAICS 

Plastics materials and 

synthetics 

282 325211 

Soap, cleaners, and toilet 

goods 

284 325611 

Paints and allied products 285 32551 

Industrial organic chemicals 286 325191 

Miscellaneous chemical 

products 

289 325998 

Manufacturers, Rubber and Misc. Plastics Products

Industry SIC NAICS 

Plastics foam products 3086 32615

Wholesale Trade- Nondurable Goods

Industry SIC NAICS 

Chemicals and allied products 516 42261 

Miscellaneous nondurable 

products 

519 42299 

 

Respondents for the recordkeeping requirement for substitutes acceptable subject to use 

conditions or narrowed use limits include end users of the substitutes in the following industrial 

sectors: 

Construction- Special Trade Contractors

Industry SIC NAICS 

Plumbing, heating, and airconditioning 171 23511

 

Manufacturing- Industrial Machinery & Equipment

Industry SIC NAICS 

Computer and office 

equipment 

357 334111 , 333313 

Refrigeration and service 

machinery 

358 333415 

Manufacturing- Electronic & Other Electric Equipment

Industry SIC NAICS 
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Electric distribution equipment 361 335311 

Electric industrial apparatus 362 335312 

Communications equipment 366 33421 

Electronic components and 

accessories 

367 334411 

Manufacturing- Transportation Equipment

Industry SIC NAICS 

Automobile manufacturing 371 336111 

Aircraft and parts 372 336412 

Ship and boat building and 

repairing 

373 336611 

Manufacturing- Instruments & Related Products

Industry SIC NAICS 

Search and navigation 

equipment 

381 334511 

Medical instruments and 

supplies 

384 339112 

Ophthalmic goods 385 339115 

 

Services

Industry SIC NAICS 

Services to buildings 734 56179 

Computer and data 

processing services 

737 541511 

Refrigeration service and 

repair 

7623 811412, 81131 

b) Information Requested 

i) Data Items (including recordkeeping requirements): 

To simplify and expedite the submission and review of SNAP notices, EPA has developed the 

following forms and an instruction manual: 

- SNAP Information Notice (Appendix D) 

- TSCA/SNAP Addendum (Appendix E) 

- Instructions for the SNAP Program Information Notice and TSCA/SNAP 

 Addendum (Appendix F) 

The SNAP Information Notice is the form used in most submissions to give notice of a 

respondent’s plans to introduce a proposed substitute into the marketplace. The TSCA/SNAP 

Addendum is an abbreviated SNAP form for submissions in situations where there is joint 

statutory review between the TSCA PMN program and the SNAP program. The full SNAP 

Information Notice should be used in the case of a joint review with the FIFRA. A petition 

should include the same information that is requested in the SNAP Information Notice. No 

additional information is required for a petition. The instruction manual provides further 

information for a respondent preparing any of these submissions. 
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The forms were developed to minimize the reporting burden for the submitter; however, their 

use is optional. Respondents with more efficient means of submitting the information are 

encouraged to use them. EPA has based the estimated respondent burden and cost on the use 

of the recommended forms; to the extent a respondent uses more efficient means to submit the 

data, the estimates contained in this analysis may overestimate the respondent burden and 

cost. 

1. SNAP Information Notice/ Petition Data Items: Reference: Sections 82.176(a), 82.178, 

82.180(a)(5), 82.184(c) 

The information requested on the SNAP Information Notice includes the following data items: 

Name and description of the substitute. To the extent possible, the substitute should be 

identified by its (1) commercial name, (2) chemical name, (3) trade name(s), (4) generic name, 

(5) identification numbers (e.g., CAS registry, NIOSH RTECS, EPA hazardous waste, OHMTADS, DOT/UN/NA/IMCO shipping, HSDB, NCI), (6) chemical formula, and (7) chemical 

structure. 

Physical and chemical information. Key properties that should be included to characterize the 

substitute are: molecular weight; physical state; melting point; boiling point; density; odor 

threshold; solubility; partition coefficients (Log Kow, Log Koc); and vapor pressure. 

Substitute applications. Identification of the applications in which the substitutes are likely to be 

used is required. It is essential to provide a complete list of potential uses as the substitute 

listing required by section 612(c) is specific to application. 

Process description. For each application identified, EPA is requesting available descriptive 

data on processing, including in-place pollution controls. Such information will be helpful in 

characterizing workplace and environmental releases and exposures. 

Ozone depletion potential. The predicted ozone depletion potential (ODP) of substitute 

chemicals is requested. The submitter should also provide sufficient supporting documentation-

- either a citation or the background information used to develop the ODP. For purposes of 

calculating ODP, EPA recommends the methodology used in the most recent Scientific 

Assessment of Ozone Depletion, which was prepared for the United Nations Environment 

Programme. 

Global warming potential. EPA requests readily available data on the global warming potential 

(GWP) and atmospheric lifetime of the substitute in its particular application (e.g., as a 

refrigerant, foam blowing agent, etc.) EPA requests that all GWPs be referenced to CO2 using 

the methodology recommended by the most recent assessment report from the 

Intergovernmental Panel for Climate Change (IPCC). To the extent that data is available, EPA 

also considers indirect effects. Indirect effects explicitly consider the impact on global warming 

arising from changes in energy consumption associated with the use of a substitute (e.g., an 

alternative refrigerant). This latter measure can be identified as changes in energy efficiency or 

demand relative to the substitute being replaced. 

Toxicity data. Information on toxicity from acute and chronic exposure to a substitute chemical, 

its impurities, and its degradation products on any organism (e.g., humans, mammals, fish, 

wildlife, and plants) is required. For mammals, EPA requests a minimum submission of the 
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following tests to characterize substitute risks: a range-finding study, and a 28-day subchronic 

repeated dose study in an appropriate rodent species. For substitutes that are being evaluated 

as fire suppressants, refrigerants, or aerosols, a cardiotoxicity study, usually performed on a 

dog, may be required. Additional mammalian toxicity tests will be identified based on the 

substitute and application being evaluated. To sufficiently characterize aquatic toxicity 

concerns, both acute and chronic toxicity test results for a variety of species is required. EPA 

requires a minimum data set as described in "Guidelines for Deriving Numerical National Water 

Quality Criteria for the Protection of Aquatic Organisms and their Uses," which is available 

through the National Technical Information Service (#PB 85-227049). Other relevant 

information and data summaries, such as the Material Safety Data Sheets, should also be 

submitted. Submission of the actual toxicity studies is most beneficial; however, it is not 

necessary to submit these reports if they have been supplied to EPA as part of other regulatory 

submissions. To assist in locating these studies, the submitter must provide a sufficiently clear 

citation to ensure that these studies can be located by EPA in a timely fashion. EPA requires 

that submitters providing information on new chemicals for joint review under TSCA and SNAP 

adhere to the TSCA minimum testing requirements described in TSCA section 5. 

Environmental Fate and Transport. Where available, information must be submitted on the 

environmental fate and transport of substitutes. Such data shall include information on 

bioaccumulation, biodegradation, adsorption, volatility, transformation, and other data necessary 

to characterize movement and reaction of substitutes in the environment. 

Flammability. Data on the flammability of a substitute chemical or mixture are required. 

Specifically, data on flash point and flammability limits are needed, as well as information on the 

procedures used for determining the flammability limits. For substitutes that will be used in 

consumer applications, documentation of testing results conducted by independent laboratories 

(e.g., Underwriters Laboratories) should be submitted where appropriate. Detail on any 

suggested abatement techniques to minimize the risks associated with the use of flammable 

substances or blends should also be provided. EPA recognizes that many promising 

alternatives may be considered marginally flammable, but can be used safely and effectively. 

The information requested on this topic will help EPA make a balanced decision regarding the 

use of a flammable alternative. 

Exposure data. The submitter should provide extant modeling or monitoring data on exposures 

associated with the manufacture, formulation, transport, and use of a substitute. Descriptive 

process information for each substitute application, as requested above, will be used to develop 

exposure estimates where measured exposure data are not readily available. Depending on 

the application, exposure profiles will be needed for workers, consumers, and the general 

population. 

Environmental release data. Available data on emissions from the substitute application and 

equipment, as well as pollutant releases or discharge to all environmental media (ambient air, 

surface water, hazardous/solid waste), are needed to complete the risk characterization. 

Submitters should provide information on release locations, if known. Any information on 

pollution controls used or that could be used in association with the substitute (e.g., emissions 

reduction technologies, wastewater treatment, and treatment of hazardous waste) and the costs 

of such technology are also requested. 
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Replacement ratio for a chemical substitute. EPA is requesting information on the replacement 

ratio for a chemical substitute versus the Class I or II substances being replaced. For example, 

in the case of a degreasing agent, how much more or less of the substitute chemical is needed? 

This will have an impact on the estimated incremental cost and environmental effects 

associated with use of the substitute. 

Required changes in technoloqy. Detail on the changes in technology needed to use the 

alternative is requested. Such information should include a description of whether the substitute 

can be used in existing equipment-- with or without some retrofit--or in new equipment. Data on 

the cost (capital and operating) and estimated life of the technology modifications should also 

be submitted. These economic data are essential to understanding the near-term potential of 

using an alternative. 

Cost of substitute. EPA is requesting data on the expected average cost of the alternative. The 

cost of the substitute can be expressed, for example, in terms of $/pound (for a chemical 

substitute) or as incremental capital and operating costs associated with a retrofit or new 

equipment. In addition, information is needed on the expected equipment lifetime for an 

alternative technology. Other critical cost considerations should be identified, as appropriate. 

For example, it is important to understand the incremental costs associated with losses or gains 

in energy efficiency associated with use of a substitute relative to current experience. 

Availability of substitute. EPA needs to understand the extent to which a substitute is already 

commercially available or the expected date at which it may become available. The timing of 

availability is an important factor in assessing the overall health and environmental impacts of 

the substitute. 

Anticipated market share. Data on the anticipated near-term and long-term (over the next five 

years) nationwide substitute sales (not just those of the submitter) is requested. This 

information can be presented in several ways, for example: a percentage of existing nationwide 

use of Class I or Class II chemicals in a particular application; number of units/products to be 

produced; or pounds of substitute sold. This information is required to assess the potential 

impacts related to total consumption and environmental releases. 

Applicable regulations under other environmental statutes. The submitter is requested to 

provide information on whether the substitute(s) are regulated under other statutory authorities, 

in particular the Clean Water Act, Safe Drinking Water Act, the Resource Conservation and 

Recovery Act, FIFRA, TSCA, and other titles under the CAA. EPA will evaluate substitutes 

under the SNAP program subject to these existing regulatory constraints. 

Information already submitted to EPA. Individuals may have already submitted information 

being requested in the SNAP program notice to EPA as part of past regulatory and informationgathering activities. If such a situation exists, and to minimize reporting burden, the submitter 

should provide the following information to help locate the data already maintained at EPA: type 

of information submitted; the date of submission; the name of the EPA office to which the data 

were sent; description of the regulatory program; and a document-control number, if assigned 

(e.g., a PMN number). If the submitter cannot provide references to data sent previously to 

EPA, he or she should include all requested information in the SNAP notice. 

Information already available in the literature. If any of the data needed to complete the SNAP 

program notice are available in the literature, the submitter should provide EPA with references 
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for such information. Failure to provide EPA with sufficient citation, however, will delay review 

of the notice. Additionally, submitters are encouraged to provide copies of any literature to 

expedite review, particularly if the citation is from a source not readily available to EPA 

researchers. Any references from sources in foreign languages should be translated. 

Additional information. If critical new information becomes available during the review period 

that may influence EPA’s evaluation of a substitute, the submitter must notify EPA of the 

existence of such information within 10 days of learning of such data. The submitter must also 

inform EPA of new studies underway, even if the results will not be available within the review 

period. 

2. TSCA/SNAP Addendum Form Data Items: Reference: Sections 82.176(a), 82.178, 

82.180(a)(5) 

EPA has identified only a few additional data elements, beyond those already required by the 

Premanufacture Notice (PMN) program that would need to be included for review under the 

SNAP program. For this reason, the added burden to respondent from the SNAP program, 

above that already required by the PMN program, is very small. 

The additional data elements in the TSCA/SNAP Addendum include: 

- The ozone-depletion potential, 

- The global-warming potential, 

- Explicit quantification of the cost of using the substitute and information on when the 

substitute is expected to be available (including the chemical replacement data, chemical cost 

data, incremental equipment expenditures needed to use the substitute, and information on the 

cost implications resulting from changes in energy consumption), and 

- Documentation of testing results regarding the flammability of substitutes that will be used in 

consumer applications. 

If critical new information becomes available during the review period that may influence EPA’s 

evaluation of a substitute, the submitter must notify EPA of the existence of such information 

within 10 days of learning of such data. The submitter must also inform EPA of new studies 

underway, even if the results will not be available within the review period. 

3. Notification for Test Marketing Activity Data Items Reference: Section 82.176(b)(5) 

Uses of substitutes for the sole purpose of test marketing are exempt from requirements for 

submitting a SNAP Information Notice or equivalent until 90 days prior to the introduction of 

such substitutes for full-scale commercial sale in interstate commerce. Persons taking 

advantage of this exemption are, however, required to notify EPA in writing that they are 

conducting test marketing 30 days prior to the commencement of such marketing. Notification 

shall include the following data items: 

- Name of the substitute 

- Volume used in the test marketing 

- Intended sector and end uses 

- Expected duration of the test marketing period 
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4. Recordkeeping for Substitutes Acceptable Subject to Use Conditions or Subject to 

Narrowed Use Limits Data Items Reference: Section 82.180(b)(2) and (b)(3) 

If a substitute is listed by EPA, in a decision on a SNAP information notice, TSCA/SNAP 

addendum, or petition, as acceptable subject to narrowed use limits, end users intending to use 

the substitute must determine that other alternatives are not technically feasible. For some 

substitutes listed as acceptable subject to use conditions, the end user needs to perform an 

assessment that other alternatives are not technically feasible due to safety, performance, or 

technical reasons. Such end users must document the results of their evaluation and retain the 

results on file for the purpose of demonstrating compliance. This documentation shall include 

the following data items: 

- Descriptions of substitutes examined and rejected 

- Processes or products in which the substitute is needed 

- Reason for rejection of other alternatives, e.g., performance, technical or safety standards 

- The anticipated date other substitutes will be available and projected time for switching to 

other available substitutes. 

Respondents are required to maintain these records for five years. See section 3(d) of this 

statement for the justification for this length of time. 

In addition, some substitutes subject to use conditions may have specific recordkeeping 

requirements imposed through a use condition (e.g., requirement to keep records of failure 

mode and effects analysis when introducing certain automotive refrigerants, consistent with 

requirements of industry standards). Respondents are required to maintain these records for 

three years. 

5. Recordkeeping for Small Volume Use Exemption Data Items Reference: Section 

82.176(b)(3) 

Within the eight principal SNAP sectors, persons introducing a substitute whose expected 

volume of use amounts to less than 10,000 pounds per year within a SNAP sector are exempt 

from notification requirements. Persons taking advantage of this exemption for small uses must 

maintain documentation for each substitute describing how the substitute meets this small use 

definition. This documentation must include the following data item: 

- Annual production and sales information by sector 

Respondents are required to maintain these records for five years. See section 3(d) of this 

statement for the justification for this length of time. 

ii) Respondent Activities 

There are five types of respondent reporting and recordkeeping activities required pursuant to 

Section 612 of the Act and the SNAP regulations promulgated thereunder, 40 CFR Sections 

82.170- 82.184: 
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Reporting: SNAP Information Notice/ Petition

This includes the following types of activities: 

- Pre-submittal contact with EPA. 

- Prepare and submit notice or petition to EPA. 

- Respond to EPA requests for additional information and/or notify EPA of additional 

information as it becomes available. 

Reporting: TSCA/SNAP Addendum

This includes the following types of activities: 

- Pre-submittal contact with EPA. 

- Prepare and submit form to EPA. 

- Respond to EPA requests for additional information and/or notify EPA of additional 

information as it becomes available. 

Reporting: Notification for Test Marketing Activity

- Compile information, and prepare and submit letter to EPA with the information. 

Recordkeeping: Substitutes Acceptable Subject to Use Conditions or Narrowed Use Limits

- Assess other acceptable alternative substitutes. 

- Compile and prepare record of assessment or other records as required by use conditions. 

Recordkeeping: Small Volume Uses

- Assess sector sales. 

- Compile and prepare record of sector sales. 

 5. The Information Collected - Agency Activities, Collection Methodology and Information

Management.

a) Agency Activities

 EPA activities associated with reviewing SNAP submissions consist of the following: 

Pre-submittal contact with respondent

- Send forms and guidance document to potential respondents. 

 - Answer questions regarding the completion of SNAP program forms and the need to submit 

a SNAP notice. 

Review and communication regarding submission

- Assign tracking number to SNAP notice or petition. 

- Review SNAP notice or petition for sufficiency of information provided, send letter of receipt, 

and notify submitter if additional information is required. 
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- Review requests for confidentiality and provide appropriate protection. 

- Review SNAP notice or petition, and notify submitter of decision. 

- Review TSCA/SNAP Addendum in detail, coordinate with TSCA office, and notify submitter 

of decision. 

 - Prepare and evaluate EPA-initiated changes to the SNAP determinations. 

Administrative operations

- Maintain administrative tracking system for all submissions. 

- Maintain technical clearinghouse to help users identify acceptable substitutes that are listed 

under SNAP. 

- Prepare and publish in the Federal Register periodic notices and rulemakings to inform the 

public of any changes to the SNAP lists and of all pending determinations. 

b) Collection Methodology and Management 

EPA collects information through respondents’ submission of a SNAP Information Notice, a 

TSCA/SNAP Addendum, or a petition. In each case, the collection methodology is the same. 

EPA has 90 days from receipt of a complete submission to respond to the filing, and EPA must 

publish its decisions in these submissions in its periodic Federal Register notices and 

rulemakings. 

Initially, EPA reviews each submission for completeness within 15 days of receipt of the 

submission. If information is incomplete, the submitter will be contacted for this information. 

Thus, the 15 day completeness review period begins on the date EPA receives a submission, 

and it ends 15 days after the date of receipt. 

The 90-day review period will not commence until EPA judges the submission complete, 

although manufacturers of a new substitute may introduce the substitute into interstate 

commerce 90 days after EPA receives a submission if EPA has not already rendered an 

unacceptability determination. Once the 90-day review period has begun, EPA may determine 

that additional data are necessary, or the submitter may notify EPA of additional information 

which has become available and may influence EPA’s evaluation of the proposed substitute. In 

either case, EPA may contact the submitter to explore extending or suspending the review 

period, depending on the type of data and the stage of review. Thus, the 90-day review period 

begins on the date a complete submission is received by EPA, and it ends 90 days thereafter, 

unless EPA and the submitter have agreed to another date. 

EPA will check data quality of each submission by its review of the data in each submission. 

EPA will use its existing systems for telephones and computers to process each submission. 

The public can get access to non-confidential data in each submission by visiting the public 

docket maintained in Washington, DC or by checking the online version of the docket at 

www.regulations.gov, docket number EPA-HQ-OAR-2003-0118. 

There is a means for filing electronic SNAP submissions with EPA. To help respondents reduce 

the burden of gathering information to prepare a SNAP submission, EPA has established an 

electronic clearinghouse of useful information about the SNAP program, including updated lists 

of acceptable and unacceptable substitutes. In addition, the online docket provides examples of 

submissions of various types. 
14 

c) Small Entity Flexibility

Submission of a notice to EPA 90 days before introducing a new substitute into commerce is 

required by statute, regardless of the size of the submitter. The information requested in the 

SNAP program is necessary for EPA to evaluate the proposed substitute chemicals which will 

be listed as acceptable or unacceptable, depending on the evaluations. The SNAP program 

has directed the burden on manufacturers and formulators, rather than the end user, which 

greatly reduces the potential burden on small entities. 

Additionally, SNAP reporting requirements provide an exemption for persons introducing a 

substitute whose expected volume of use amounts to less than 10,000 pounds per year within a 

SNAP industrial sector. This exemption reduces the potential burden on small entities, although 

such persons are subject to a recordkeeping requirement documenting their qualification for this 

exemption. 

d) Collection Schedule

The SNAP regulations were promulgated March 18, 1994, and collection of information as 

required therein commenced on that date. EPA accepts and reviews SNAP submissions as 

respondents provide them to EPA. Information in the public docket on these submissions has 

been available since submissions have been received. 

6. Estimating the Burden and Cost of Collection

a) Estimating Respondent Burden 

b) Estimating Respondent Costs 

The following tables (6A/B-1 through 6A/B-5) present estimates of annual respondent burden 

hours and costs for each of the respondent activities described in section 4(b)(ii), with 

explanations of the assumptions made in each table. All cost values are in 2010 dollars and 

reflect inflation since the previous ICR. Labor costs are from the Bureau of Labor Statistics. 

Exhibit 6A/B-1: SNAP Information Notice/Petition: Annual Respondent Burden and Cost 

(1) 

The following table shows estimates of respondent burden hours and costs for the first set of 

activities listed above in section 4(b)(ii). In making these estimates, relied on its experience in 

sixteen years of implementing the SNAP program and its consultations with respondents, and 

made the following assumptions: 

- The number of inquiries about filing a SNAP Information Notice or petition is 14 per year, of 

which 50% submit the filing. The number of CBI requests is 67% of the 7 submittals. The 

number of filings for which additional information is required is 67% of the 7 submittals. 

- Labor cost of $68 represents an average hourly rate of pay, including overhead and benefits, 

for a private company for labor that would be classified as “technical” time for the bulk of the 

effort and “clerical” time for a small part of the effort. 

- Estimated start-up cost is based on the cost of required toxicological data which, in 25% of 

SNAP filings, is a one-time event incurred for the sole purpose of fulfilling SNAP requirements. 

EPA estimates the cost of such data ranges from $30,000 to $350,000, with more than half of 
15 

respondents incurring such costs in an amount equal to or less than $75,000. EPA multiplied a 

weighted average of these costs ($133,610) by 0.25 to get an estimated average start-up cost 

of $33,402 which represents the cost distributed among all respondents. EPA calculated the 

annualized cost per respondent by using 20 years as the useful life of the chemical for which 

data was collected and 7% as the discount value. 

- There is no annual operating and maintenance cost associated with this reporting requirement. 

Table 6A/B-1: SNAP INFORMATION NOTICE / PETITION 

 

(A) 

Hours/ 

Year 

Resp. 

(B) 

Labor 

Cost 

(@ $68/ 

hr) per 

Resp. 

per 

Year 

(C) 

Annualized 

Start-up 

Cost per 

Resp. 

(D) No. of Resp. 

(E)Total 

Hrs/Year (All 

Resp.) 

(A*D) 

(F) 

Total 

Annualized 

Cost per 

Year (All 

Resp.) 

(C*D) 

(G) Total 

Labor 

Cost per 

Year (All 

Resp.) 

(B*D) 

(H) Total 

Cost per 

Year (All 

Resp.) 

(F+G) 

a) Pre-submittal 

contact with EPA 

Obtain form and 

guidance document from 

EPA 0.75 $51 $0 7 5.25 $0 $357 $357 

Review form and 

guidance document from 

EPA 3 $204 7 21 $1,428 $1,428 

Identify chemical and 

applications 9 $612 $0 7 63 $0 $4,284 $4,284 

b) Prepare and submit 

form to EPA $0 

Collect data for form 75 $5,100 $3,153 7 525 $22,071 $35,700 $57,771 

Prepare notification form 12 $816 $0 7 84 $0 $5,712 $5,712 

Prepare non-confidential 

version of form if CBI is 

declared 3 $204 $0 5 15 $0 $1,020 $1,020 

c) Respond to EPA 

requests for add’l 

information and/or 

notify EPA of add’l. 

info. 

Communicate with EPA 7 $476 $0 5 35 $0 $2,380 $2,380 

Collect data 58 $3,944 $0 5 290 $0 $19,720 $19,720 

Prepare data to send to 

EPA 3 $204 $0 5 15 $0 $1,020 $1,020 

 

Subtotals 170.75 $11,611 $3,153 

varies but 7 is 

most 1,053.3 $22,071 $71,621 $93,692 

Exhibit 6A/B-2: TSCA/SNAP ADDENDUM: Annual Respondent Burden and Cost (2) 

The following table shows estimates of respondent burden hours and costs for the second set of 

activities listed above in section 4(b)(ii). In making these estimates, EPA relied on its 

experience in sixteen years of implementing the SNAP program and its consultations with 

respondents, and made the following assumptions: 
16 

- Three inquiries per year come in regarding a TSCA/SNAP Addendum. EPA receives three 

submittals per year. Three CBI claims come from those 3 submittals. Additional information is 

usually required from the submitter. 

- Labor cost of $68 represents an average hourly rate of pay, including overhead and benefits, 

for a private company for labor that would be classified as “technical” time for the bulk of the 

effort and “clerical” time for a small part of the effort. 

-There is no start-up or operating and maintenance cost associated with the TSCA/SNAP 

Addendum. 

Table 6A/B-2: TSCA/SNAP Addendum 

 

(A) 

Hours/ 

Year 

Resp. 

(B) 

Labor 

Cost 

(@ $68/ 

hr) per 

Resp. 

per 

Year 

(C) No. 

of Resp. 

(D)Total 

Hrs/Year (All 

Resp.) 

(A*C) 

(E) Total 

Labor Cost per 

Year (All 

Resp.) 

(B*C) 

a) Pre-submittal contact 

with EPA 

Obtain form and 

guidance document from 

EPA 0.5 $34 3 1.5 $102 

Review form and 

guidance document from 

EPA 3 $204 3 9 $612 

Identify chemical and 

applications 0.5 $34 3 1.5 $102 

b) Prepare and submit 

form to EPA 

Collect data for form 20 $1,360 3 60 $4,080 

Prepare notification form 5 $340 3 15 $1,020 

Prepare non-confidential 

version of form if CBI is 

declared 2 $136 3 6 $408 

c) Respond to EPA 

requests for add’l 

information and/or 

notify EPA of add’l. 

info. 

Communicate with EPA 1 $68 3 3 $204 

Collect data 3 $204 3 9 $612 

Prepare data to send to 

EPA 1 $68 3 3 $204 

 

Subtotals 36 $2,448 3 108.0 $7,344 

Exhibit 6A/B-3: Notification for Test Marketing Activity: Annual Respondent Burden and 

Cost (3) 

The following table shows estimates of respondent burden hours and costs for the third set of 

activities listed above in section 4(b)(ii). In making these estimates, EPA relied on its 
17 

experience in sixteen years of implementing the SNAP program and its consultations with 

respondents, and made the following assumptions: 

- The number of notifications for test marketing activity is one per year, and the number of hours 

per notification is two. 

- Labor cost of $68 represents an average hourly rate of pay, including overhead and benefits, 

for a private company for labor that would be classified as “technical” time for the bulk of the 

effort and “clerical” time for a small part of the effort. 

- There is no start-up or operating and maintenance cost associated with the notification. 

 

Table 6A/B-3: Notification for Test Marketing Activity 

 

(A) 

Hours/ 

Year 

Resp. 

(B) 

Labor 

Cost 

(@ $68/ 

hr) per 

Resp. 

per 

Year 

(C) No. 

of Resp. 

(D)Total 

Hrs/Year (All 

Resp.) 

(A*C) 

(E) Total 

Labor Cost per 

Year (All 

Resp.) 

(B*C) 

a) Compile information 

and prepare letter 2 $136 1 2 $136 

Subtotal 2 $136 1 2 $136 

 

Exhibit 6A/B-4: Recordkeeping for Substitutes Acceptable Subject to Use Conditions or 

Narrowed Used Limits: Annual Respondent Burden and Cost (4) 

The following table shows estimates of respondent burden hours and costs for the fourth set of 

activities listed above in section 4(b)(ii). In making these estimates, EPA relied on its 

experience in sixteen years of implementing the SNAP program and its consultations with 

respondents, and made the following assumptions: 

- The number of recordkeeping collections is 200 per year. Each collection is a one-time 

occurrence. Users of restricted alternatives may periodically reevaluate alternatives available. 

- Labor cost of $68 represents an average hourly rate of pay, including overhead and benefits, 

for a private company for labor that would be classified as “technical” time for the bulk of the 

effort and “clerical” time for a small part of the effort. 

- There is no start-up cost associated with the recordkeeping collection. 

- Annual operating and maintenance cost represents an estimate of cost of storage space for 

keeping the records. 
18 

Table 6A/B-4: Recordkeeping For Substitutes Acceptable Subject to Use Conditions or 

Narrowed Used Limits 

 

(A) 

Hours/ 

Year 

Resp. 

(B) 

Labor 

Cost 

(@ $68/ 

hr) per 

Resp. 

per 

Year 

(C) 

Annualized 

O&M 

Cost per 

Resp. 

(D) No. 

of Resp. 

(E)Total 

Hrs/Year 

(All Resp.)

(A*D) 

(F) 

Total 

Annualized 

Cost per 

Year (All 

Resp.) 

(C*D) 

(G) Total 

Labor Cost 

per Year 

(All Resp.) 

(B*D) 

(H) Total 

Cost per 

Year (All 

Resp.) 

(F+G) 

a) Assessment of other 

acceptable alternatives 25 $1,700 $0 200 5,000 $0 $340,000 $340,000 

b) Compile information 

and prepare 

recordkeeping 2 $136 $1 200 400 $200 $27,200 $27,400 

Subtotal 27 $1,836 $1 200 5,400 $200 $367,200 $367,400 

 

Exhibit 6A/B-5: Recordkeeping for Small Volume Uses: Annual Respondent Burden and 

Cost (5)

The following table shows estimates of respondent burden hours and costs for the fifth set of 

activities listed above in section 4(b)(ii). In making these estimates, EPA relied on its 

experience in sixteen years of implementing the SNAP program and its consultations with 

respondents, and made the following assumptions: 

- The number of recordkeeping collections is 10 per year, and each collection is a one-time 

occurrence. 

- Labor cost of $68 represents an average hourly rate of pay, including overhead and benefits, 

for a private company for labor that would be classified as “technical” time for the bulk of the 

effort and “clerical” time for a small part of the effort. 

- There is no start-up cost associated with the recordkeeping collection. 

- Annual operating and maintenance cost represents an estimate of cost of storage space, filing 

materials and other associated, non-labor costs for keeping the records. 

Table 6A/B-5: Recordkeeping for Small Volume Uses: Annual Respondent Burden and Cost 

 

(A) 

Hours/ 

Year 

Resp. 

(B) 

Labor 

Cost 

(@ $68/ 

hr) per 

Resp. 

per 

Year 

(C) 

Annualized 

O&M 

Cost per 

Resp. 

(D) No. 

of 

Resp. 

(E)Total 

Hrs/Year 

(All Resp.)

(A*D) 

(F) 

Total 

Annualized 

Cost per 

Year (All 

Resp.) 

(C*D) 

(G) Total 

Labor Cost 

per Year 

(All Resp.) 

(B*D) 

(H) Total 

Cost per 

Year (All 

Resp.) 

(F+G) 

a) Assessment of 

sector sales 10 $680 $0 10 100 $0 $6,800 $6,800 

b) Compile information 

and prepare 

recordkeeping 2 $136 $1 10 20 $10 $1,360 $1,370 

Subtotal 12 $816 $1 10 120 $10 $8,160 $8,170 
19 

c) Estimating Agency Burden and Costs

Exhibit 6C-1: Annual Agency Burden and Costs 

The following table shows estimates of EPA burden hours and costs (including the cost of 

contractor services) for the activities listed in section 5 above. In making these estimates, EPA 

made the following assumptions: 

- The number of occurrences is based on the number of inquiries and submittals by respondents 

estimated above in tables 6A-1 and 6A-2. 

- The number of EPA-initiated changes in SNAP determinations is estimated to be two per year. 

- The number of hours per detailed review of a TSCA/SNAP Addendum assumes 60 hours per 

form. 

- Labor cost is based on the annual 2010 salary for a GS 12/ Step 2 employee ($77,368), which 

is divided by 2,080 hours, the number of hours in a federal work year (resulting in an hourly rate 

of $37.20), then multiplied by 1.6, the standard government benefits multiplication factor 

(resulting in a final hourly rate of $59.52). 

- The cost of contractor services in the two circumstances noted in the chart is based on a 

percentage of the total annual cost to SPD of the contractor’s charges under the respective 

2010 contracts. The percentage in each case represents an estimate of the time spent by the 

contractor on SNAP issues as distinguished from other SPD issues not related to SNAP. The 

hourly rate noted in each case represents the average rate charged per hour under these 

contracts. 

- Total Agency costs have decreased. This is primarily due to a substantial decrease in the cost 

of contractor services for administrative support of the SNAP program. EPA staff complete an 

increasing proportion of clearinghouse maintenance and updates, rather than using contractor 

services. 
20 

Table 6C1: EPA burden hours and costs 

 

No. of 

Occurrences 

No. of 

Hours 

per 

Occurrence 

Total no. 

of Hours 

per Year 

Labor Cost (@ 

$59.52/hr) per 

Year 

Cost of 

Contract 

Services per 

Year 

Total Cost 

per Year 

1) Pre-submittal contact 

w/ respondent 

Send forms/ guidance to 

potential submitters 14 0.1 1.4 $83.33 n/a $83 

Answer questions re 

potential submissions 14 3 42 $2,499.84 n/a $2,500 

2) Review & 

communication re 

submission 

Assign tracking number 

to submission 7 0.5 3.5 $208.32 n/a $208 

Review submission, send 

receipt, notify if add’l info 

required 7 2 14 $833.28 n/a $833 

Review CBI requests and 

protect as appropriate 5 4 20 $1,190.40 n/a $1,190 

Review submission in 

detail and notify submitter 

of decision 7 120 840 $49,996.80 n/a $49,997 

Contractor assistance in 

reviewing submissions 

(@ $132/per hr) n/a n/a 2325 n/a $306,900 $306,900 

Review TSCA/SNAP 

Addendum in detail and 

notify submitter of 

decision 3 60 180 $10,713.60 n/a $10,714 

Prepare and evaluate 

EPA-initiated changes to 

determinations 2 40 80 $4,761.60 n/a $4,762 

3) Administrative 

operations 

Maintain system of 

tracking submissions 

ongoing 120 120 $7,142.40 n/a $7,142 

Maintain clearinghouse to 

help users 

ongoing 150 150 $8,928.00 n/a $8,928 

Contractor assistance for 

clearinghouse(@ $99/per 

hr) n/a n/a 25 n/a $2,475 $2,475 

Prepare FR notices and 

rule-makings re changes 

to SNAP lists 5 80 400 $23,808.00 n/a $23,808 

Totals varies varies 4200.9 $250,037.57 $309,375 $419,541 
21 

d) Estimating the Respondent Universe and Total Burden and Costs See the tables in 

section 6(a) and (b) for these estimates. 

e) Bottom Line Burden Hours and Cost Tables 

Exhibit 6E-1: Information Collection Activity: Total Estimated Respondent Burden and 

Cost Summary 

Table 6E1: Total Estimated Respondent Burden and Cost Summary 

 

No. of 

Respondents 

per 

year 

No. of 

Activities 

per year 

Total 

Hours 

per Year 

Total Labor 

Cost per 

Year @$68 

Total 

Annualized 

Start-up 

Costs 

Total 

Annualized 

O&M 

Costs 

Total 

Annualized 

Costs Total Costs 

SNAP Information 

Notice/ Petition 7 7 1,053 $71,621 $22,071 $0 $22,071 $93,692 

TSCA/SNAP 

Addendum 3 3 108.0 $7,344 $0 $0 $0 $7,344 

Notification for test 

marketing activity 1 1 2 $136 $0 $0 $0 $136 

Recordkeeping for 

Substitutes 

Acceptable Subject to 

Use Conditions or 

Limits 200 200 5,400 $367,200 $0 $200 $200 $367,400 

Recordkeeping for 

Small Volume Uses 10 10 120 $8,160 $0 $10 $10 $8,170 

 Totals 221 221 6,683 $454,461 $22,071 $210 $22,281 $476,742 

These numbers are from the subtotals of tables in 6(a) and 6(b), and are used to complete 

items 13 and 14 in Form 83-1. 

Exhibit 6E-2: Total Estimated Agency Burden and Cost Summary 

Table 6E2: Total Estimated Agency Burden and Cost Summary 

 

No. of 

Respondents 

No. of 

Activities 

Total 

Hours 

per Year 

Total Govt 

Labor Hours per 

Year 

Total Annual 

Govt Labor 

Cost 

@$59.52 

Cost of 

Contract 

Services per 

Year 

Total 

Cost per 

Year 

Pre-submittal 

contact with 

respondents 14 14 43.4 43.4 $2,583 $ - $2,583 

Review and 

communicate re 

submission 7 7 3,463 1,138 $67,704 $306,900 $374,604 

Administrative 

operations varies varies 695 670 $39,878 $2,475 $42,353 

Totals varies varies 4,200.9 1,851 $110,166 $309,375 $419,541 
22 

f) Reasons for Change in Burden 

The total number of respondent burden hours requested annually (Exhibit 6E-1) for this 

information collection has decreased from 8,204 hours in 2007 to 6,683 hours in 2010. The 

SNAP burden hours have been decreasing since 2000, starting at 10,363 hours and decreasing 

to 8,972 hours in 2004, 8,204 hours in 2007, and 6,683 hours in 2010. This is due to changes 

in EPA’s estimates of the burden hours and number of respondents fulfilling reporting and 

recordkeeping requirements. 

The development of new substitutes caused the number of persons filing a SNAP Information 

Notice or TSCA/SNAP Addendum to increase slightly, but also resulted in fewer respondents 

keeping records for alternatives that are subject to use conditions or narrowed use limits. In 

addition, respondents filing a SNAP Information Notice reported a decrease in total annual 

burden of hours when collecting data to complete the form and when responding to requests for 

additional information. This decrease may be attributable to increased respondent familiarity 

with EPA’s forms, more examples in the public record for respondents to research and use in 

preparing responses, and general increased availability of computer software and information 

via the Internet. 

 

g) Burden Statement

Exhibits 6A/B-1 through 6A/B-5 present the average annual respondent burden for each person 

subject to SNAP reporting and recordkeeping requirements. For persons filing a SNAP 

Information Notice or petition, the reporting burden is estimated to average 171 hours per year. 

For persons filing a TSCA/SNAP Addendum, the reporting burden is estimated to average 36 

hours per year. For persons filing a notification of test marketing activity, the reporting burden is 

estimated to average 2 hours per year. For persons keeping records of use of a substitute 

subject to use conditions or narrowed use limits, the recordkeeping burden is estimated to 

average 27 hours per year. For persons keeping records of a small volume use, the 

recordkeeping burden is estimated to average 12 hours per year. 

Burden means the total time, effort, or financial resources expended by persons to generate, 

maintain, retain, or disclose or provide information to or for a Federal agency. This includes the 

time needed to review instructions; develop, acquire, install, and utilize technology and systems 

for the purposes of collecting, validating, and verifying information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the 

collection of information; and transmit or otherwise disclose the information. An agency may not 

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

unless it displays a currently valid OMB control number. The OMB control numbers for EPA’s 

regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. 

Appendices 

A- Draft FR notice announcing request for ICR renewal 

B- Text of Section 612 of the Clean Air Act as amended in1990 

C- Text of SNAP Regulations, 40 CFR Part 82, Subpart G 

D- SNAP Information Notice (EPA Form 1265-07) 

E- TSCA/SNAP Addendum (EPA Form 1265-07) 

F- Instructions for the SNAP Program Information Notice and TSCA/SNAP Addendum (EPA 

 Form 1265-93(1)