Economic Analysis of the Final Significant New Use Rule for Alkanes, C12-13, 

chloro (CAS RN: 71011-12-6)

(EPA Docket EPA-HQ-OPPT-2010-0573)

November 20, 2014

—Does not contain TSCA CBI—

Prepared by:

Economics and Policy Analysis Branch

Chemistry, economics, and Sustainable Strategies Division

Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) i Economic and Policy Analysis Branch 

CONTRIBUTORS

The EPA analyst responsible for this report was Joe Callahan. Analytical and draft preparation support 

was provided by Abt Associates Inc. under EPA Contract No. EP-W-08-010.
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) ii Economic and Policy Analysis Branch 

ABSTRACT

This report estimates the costs of the U.S. Environmental Protection Agency (EPA)’s final Significant

New Use Rule (SNUR) for the chemical alkanes, C12-13, chloro (C12-13 chloro alkanes, Chemical Abstracts 

Service Registry Number (CAS RN): 71011-12-6). C12-13 chloro alkanes, are short chained chlorinated 

paraffins (SCCPs); an SCCP is defined as any chlorinated paraffin with a carbon chain length between 

C10 and C13.

The final SNUR applies to all manufacturing, import, and processing of C12-13 chloro alkanes for any use.

EPA found no evidence of any manufacturing or importation into the United States of the chemical, and 

no data was reported in the 2006 Toxic Substances Control Act (TSCA) Inventory Update Reporting 

(IUR) database for C12-13 chloro alkanes (EPA 2006a).

1 Because the domestic manufacture, import and 

processing of C12-13 chloro alkanes has been discontinued, there is expected to be no economic impact 

from the final SNUR.

The final SNUR will require persons to notify EPA at least 90 days before commencing the manufacture,

import, or processing of C12-13 chloro alkanes for any significant new use as defined in the SNUR. A firm 

intending to engage in these activities will be required to submit a Significant New Use Notice (SNUN).

EPA is proposing the SNUR because of concerns regarding the environmental fate and the exposure 

pathways that lead to C12-13 chloro alkanes presence in aquatic organisms. Because C12-13 chloro alkanes is 

not currently manufactured in or imported into the United States it is important that EPA is notified if a 

company chooses to produce, import, or process C12-13 chloro alkanes for any significant new use. The 

SNUN provides the Agency with an opportunity to evaluate the intended use and, if necessary, to prohibit 

or limit that activity before it occurs.

To submit this SNUN, a firm incurs a modest submission cost of $8,112 and potentially other minor 

costs. However, since no firms have been identified which import, manufacture, or process C12-13 chloro 

alkanes for any significant new uses, it is highly unlikely that any firm will incur this cost. EPA does not 

require the development of test data for submission of a SNUN, although a firm may submit test data 

already in its possession or describe any other available data. Because EPA does not require the 

development of test data, EPA assumes that no firms will incur testing costs as a result of the final SNUR.

In addition to the firms that make a SNUN submission, the final SNUR may also impact firms that do not 

make a submission. By avoiding a significant new use, a firm can avoid submission and testing costs but 

may incur other compliance costs. However, this may not be a concern given that the domestic 

manufacture, import and processing of C12-13 chloro alkanes for the uses subject to the SNUR have been 

phased out.

Costs in this report are estimated at the firm level and reflect the burden of a SNUR on the firms that 

make a submission. The potential hidden costs to the firms that do not make a submission are not 

quantified. EPA receives only a handful of SNUNs per year. The number of firms affected by not making 

submissions to EPA is not known; therefore, costs are not aggregated across the affected entities.

 

1 The IUR compiles production data from manufacturers and importers of certain chemical substances (including 

C12-13 chloro alkanes ) listed on the TSCA Chemical Substance Inventory. Sites are only required to submit IUR data 

if they manufacture or import more that 25,000 lbs of a chemical during the reporting year. The most recent year 

with data available was 2006.

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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) iii Economic and Policy Analysis Branch 

TABLE OF CONTENTS

CONTRIBUTORS.........................................................................................................................................i

ABSTRACT..................................................................................................................................................ii

1. INTRODUCTION ................................................................................................................................ 1

1.1 Background.................................................................................................................................1

Uses and Substitutes................................................................................................................... 1

Health Effects............................................................................................................................. 2

Environmental Effects................................................................................................................ 2

Current Manufacturing ............................................................................................................... 3

1.2 Statutory Authority ..................................................................................................................... 3

1.3 Summary of Methodology.......................................................................................................... 3

1.4 Organization of this Report ........................................................................................................ 3

2. INDUSTRY Compliance costs............................................................................................................. 5

2.1 Wage Rates.................................................................................................................................5

2.2 Unit Industry Compliance Costs.................................................................................................6

2.2.1 Rule Familiarization ......................................................................................................6

2.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup ................ 6

2.2.3 Form Completion and Submission Fee.......................................................................... 8

2.2.4 Recordkeeping............................................................................................................... 9

Recordkeeping for Companies that Do Not Submit a SNUN................................................... 10

2.2.5 Customer Notification .................................................................................................11

2.2.6 Import Certification .....................................................................................................11

2.2.7 Export Notification ...................................................................................................... 11

2.3 Industry Costs of SNUR, by Option (per Submission)............................................................. 13

2.4 Likelihood of a SNUN Submission .......................................................................................... 14

2.5 Potential for Subsequent Regulatory Action ............................................................................ 14

3. AGENCY COSTS............................................................................................................................... 16

3.1 Labor Rates for EPA Staff........................................................................................................ 16

3.2 SNUN Processing Costs........................................................................................................... 16

3.3 Export Notification Cost........................................................................................................... 19

4. Benefits............................................................................................................................................... 20

5. ADDITIONAL ANALYSES.............................................................................................................. 21

5.1 Regulatory Flexibility Act ........................................................................................................ 21

5.2 Unfunded Mandates Reform Act.............................................................................................. 21

5.3 Paperwork Reduction Act......................................................................................................... 21

5.4 Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations............................................................................... 22

5.5 Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks ......................................................................................................................................... 22

5.6 Executive Order 13132: Federalism ......................................................................................... 22

5.7 Executive Order 13175: Consultation and Coordination with Indian Tribal Governments .....22

5.8 Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

.................................................................................................................................................. 23

6. REFERENCES....................................................................................................................................24

A. INFLATORS AND WAGE RATES ..................................................................................................30

A.1 Derivation of Loaded Wage Rates............................................................................................ 30

A.2 Derivation of Inflation Factors .................................................................................................33

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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) iv Economic and Policy Analysis Branch 

LIST OF TABLES

Table 1: Loaded Industry Wage Rates, December 2011............................................................................... 6

Table 2: Rule Familiarization Burden and Cost for SNUR Submitters........................................................ 6

Table 3: CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup Burden and Cost for 

First-Time Submitters...................................................................................................................................8

Table 4: Industry Cost Estimate to Complete the SNUN Form....................................................................9

Table 5: Industry Cost Estimate to Complete and Submit the SNUN Form................................................. 9

Table 6: Annual Per-Chemical Costs of Recordkeeping Requirement for Companies that Choose not to 

Submit a SNUN .......................................................................................................................................... 10

Table 7: Derivation of Total Mailing Cost for 12 Notices.......................................................................... 12

Table 8: TSCA 12(b) Export Notification Cost per Notification................................................................ 13

Table 9: Compliance Options and Associated Costs Incurred by a Firm Due to the Final SNUR............. 14

Table 10: Derivation of Loaded Agency Wage Rates ................................................................................ 16

Table 11: Derivation of Inflation Factors for Agency Extramural Costs.................................................... 17

Table 12: Agency Costs for SNUN and Other Submission Review and Processing..................................18

Table 13: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2011$) ........................... 19

Table 14 : Detail of Labor Categories Used in the Analysis....................................................................... 30

Table 15: Derivation of Loaded Wage Rates.............................................................................................. 32

Table 16: Derivation of Inflation Factors ...................................................................................................34

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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) 1 Economic and Policy Analysis Branch 

1. INTRODUCTION

This report presents the U.S. Environmental Protection Agency (EPA), Office of Chemical Safety and 

Pollution Prevention’s (OCSSP’s) analysis of the potential costs incurred as a result of a final Significant

New Use Rule (SNUR) for the chemical alkanes, C12-13, chloro (C12-13 chloro alkanes, Chemical Abstracts 

Service Registry Number (CAS RN): 71011-12-6). C12-13 chloro alkanes is a short chained chlorinated 

paraffin (SCPP); a SCCP is defined as any chlorinated paraffin with a carbon chain length between C10

and C13. SNURs are proposed by EPA under the authority granted by Section 5(a)(2) of TSCA. The final 

SNUR will require persons to notify EPA at least 90 days before commencing the manufacture, import, or 

processing of C12-13 chloro alkanes. EPA promulgates a SNUR for a substance when potential uses could 

result in increased exposure to, or releases of, the substance which in turn, could present an unreasonable 

risk to health or the environment.

1.1 Background

As part of EPA’s efforts to enhance the existing chemicals program under TSCA, the Agency identified 

an initial list of widely recognized chemicals for the development of an Action Plan based on one or more 

of the following factors: presence in humans; persistent, bioaccumulative, and toxic (PBT) characteristics: 

use in consumer products; and production volume. SCCPs were selected because they are 

bioaccumulative in wildlife and humans, are persistent and transported globally in the environment, 

and toxic to aquatic organisms at low concentrations. The Action Plan summarized all readily available 

use, exposure, and hazard information for SCCPs, considered which authorities provided under TSCA 

and other statutes could be used to address potential concerns; and described various courses of actions 

available to EPA to address the concerns (EPA 2009c).

Uses and Substitutes

The largest use of SCCPs in the United States is as a component of lubricants and coolants in metal 

cutting and metal forming operations. The second-largest use is as both a secondary plasticizer and a 

flame retardant in plastics, especially polyvinyl chloride (PVC). Other minor domestic SCCP uses are as a 

plasticizer and a flame-retardant additive to a variety of products including: rubber formulations, paints 

and other coatings, and adhesives and sealants (CPIA, 2009). For safety reasons, other countries (those in 

the European Union and Canada) have allowed SCCPs to be used as a flame retardant in underground 

mining conveyor belts (rubber formulations) and fire retardants in dam sealants (ECHA 2008a). 

Medium chained chlorinated paraffins (MCCP; C14-17 alkyl chain) are alternatives to SCCPs for many 

applications. Based on their physical-chemical properties, MCCPs are also expected to be persistent in the 

environment and several field surveys have shown they are present in sediments and biota, demonstrating 

their release to and persistence in the environment. Field-measured bioaccumulation factors (BAFs) that 

are greater than 5000 and biomagnification factors (BMF) greater than 1 indicate that MCCPs are 

bioaccumulative in biota and can biomagnify in food chains (UNEP, 2009). MCCPs have toxicity to 

sensitive aquatic organisms that is similar to SCCPs. Canada has concluded that MCCPs are “toxic” as 

defined by the Canadian Environmental Protection Act (CEPA) (Government of Canada 2008). The 

European Union’s 2005 Risk Assessment Report and 2007 draft update conclude that there is a need for 

limiting the risks posed by certain uses of MCCPs in the production of PVC and metal cutting (EC, 2005, 

2007). 

Long-chained chlorinated paraffins (LCCP; generally C18 - 28) appear to have been used as alternatives 

to SCCPs in some of the more demanding metal working applications (HELCOM, 2002). LCCPs also 

appear to have potential as an alternative in leather, paints and coatings, sealants and rubber applications. 

LCCPs are expected to be persistent and bioaccumulative in the environment based on their physical-
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) 2 Economic and Policy Analysis Branch 

chemical properties and bioaccumulation modeling, respectively. Canada has concluded that LCCPs up to 

C20 are “toxic” as defined by CEPA (Government of Canada 2008). Canada has not made a 

determination of whether LCCPs greater that C20 are toxic. 

A number of other potential alternatives, e.g. nitroalkanes, alkyl phosphate and sulfonated fatty acid esters 

and vegetable oil based products, are available for specific applications. It is stated that these alternatives 

are considered less harmful than chlorinated paraffins (UNECE, 2006). These non-chlorinated paraffin 

alternatives are often more expensive and may require special handling. A UK estimated cost for 

completely converting SCCPs to non-SCCPs in metal working was predicted to be four million £ per year 

(IRTA, 2004). An analysis of costs conducted in California found that overall metal working processing 

costs were more expensive for the SCCP alternatives but including other associated costs (clean up and 

waste removal) made the non-SCCP alternatives competitive (IRTA, 2004).

Health Effects

Acute toxicity of SCCPs (C10-13) is very low (EC, 1999; UNEP, 2009). SCCPs may cause skin and eye 

irritation upon repeated application, but do not appear to induce skin sensitization (EC, 1999; UNEP, 

2009). There was no evidence of developmental effects in prenatal developmental toxicity studies in rats 

and rabbits (EC, 1999; UNEP, 2009). 

The liver, kidney and thyroid are major target organs in repeated-dose studies with rats and mice. When 

administered by gavage, chlorinated paraffins (C12, 60 percent chlorine) are carcinogenic in rats and mice 

of both sexes (NTP, 1986a; 2005). The underlying mechanisms for the carcinogenicity of SCCP in rats 

and mice are not clearly known. SCCPs were not mutagenic to bacteria with or without metabolic 

activation (NTP 1986a, b). There are some indications that the SCCP-induced kidney tumors in male rats 

are associated with alpha 2μ-globin accumulation in hyaline droplets, a mode of action unique to male 

rats and irrelevant to humans, but this could not be confirmed by immunocytochemical techniques. There 

are also data showing that the liver toxicity/carcinogenicity induced by SCCP is associated with 

peroxisome proliferation, whereas the thyroid effects are correlated to altered thyroid hormone 

homeostasis. A number of scientific working groups, including the International Agency for Research on 

Cancer (IARC), have concluded that liver tumors induced by peroxisome proliferators are not relevant to 

humans (IARC, 1990; Klaunig et al., 2003). Humans are expected to be much less sensitive to thyroid 

hormone perturbation than rats and mice. 

There is no experimental evidence using human data that demonstrates the carcinogenicity of SCCPs. In 

the 11th Report on Carcinogens, NCI lists chlorinated paraffins (C12, 60 percent chlorine) as reasonably 

anticipated to be human carcinogens based on sufficient evidence of carcinogenicity in experimental 

animals (NTP, 2005). They are classified by the IARC as Group 2B - possibly carcinogenic to humans 

based on sufficient evidence of carcinogenicity in experimental animals and mechanistic considerations 

(IARC, 1990).

Health Canada and Environment Canada have characterized all chlorinated paraffins (SCCPs, MCCPs 

and LCCPs) as “toxic” under CEPA (Government of Canada 2008). 

Environmental Effects

The primary hazard concern for SCCPs is ecotoxicity. SCCPs are highly toxic to aquatic 

invertebrates following acute (48-hr EC50 = 0.043 to 11 mg/L) and chronic (NOEC = 0.005 to 2 mg/L) 

exposures. In fish high toxicity is associated with chronic exposures, but not for acute exposures (96-hr 

LC50 = 300 to 10,000 mg/L and NOEC = 0.0096 to 0.05 mg/L). For aquatic plants, there is high toxicity 

associated with both acute and chronic exposures to SCCPs (96-hr EC50s range from 0.043 to 0.39 mg/L 

and NOEC ranges from 0.012 to 0.39 mg/L) (UNEP, 2009). 
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) 3 Economic and Policy Analysis Branch 

Both Health Canada and Environment Canada have characterized all chlorinated paraffins 

(SCCPs, MCCPs and LCCPs) as “toxic” under CEPA (Government of Canada 2008). Their 

assessment found that these SCCPs have or may have an immediate or long term harmful 

effect on the environment or its biological diversity; and that they are persistent, 

bioaccumulative, inherently toxic and present in the environment primarily as a result of 

human activity (Government of Canada 2008). 

Current Manufacturing

The current use of chlorinated paraffins (SCCP, MCCP, and LCCP) in the United States is on the order of 

150 million pounds per year. Production of short-chain and medium-chained chlorinated paraffins (C9 to 

C17) was 100 million pounds in 2007. A very small fraction of that number is attributable to import/export 

business. According to the Chlorinated Paraffins Industry Association, MCCPs represent the largest 

production and use of chlorinated paraffins in North America while SCCPs is only half that volume 

(CPIA, 2009). In the United States, Dover Chemical Corp. is the sole manufacturer of chlorinated 

paraffins and several companies import chlorinated paraffins according to 2006 IUR data (EPA, 2006). 

However, no 2006 IUR data has been reported for C12-13 chloro alkanes (CAS RN 71011-12-6) and EPA

found no additional evidence of any importation or manufacturing of the chemical. It therefore appears,

there is no current manufacture or importation of C12-13 chloro alkanes in the United States. 

1.2 Statutory Authority 

Section 5(a)(2) of TSCA (15 U.S.C. 2604(a)(2)) authorizes EPA to determine that a use of a chemical 

substance is a “significant new use.” EPA must make this determination by rule after considering all 

relevant factors, including those listed in TSCA section 5(a)(2). Once EPA determines that a use of a 

chemical substance is a significant new use, TSCA section 5(a)(1)(B) requires persons to submit a SNUN 

to EPA at least 90 days before manufacturing, importing, or processing the chemical substance for that 

use (15 U.S.C. 2604(a)(1)(B)).

The general SNUR provisions are found at 40 CFR Part 721, Subpart A.

1.3 Summary of Methodology

This analysis quantifies, to the extent possible, the costs of the final rule to society by identifying the 

costs to industry associated with performing the required reporting and recordkeeping activities, and the 

costs to EPA of administering the rule. Industry costs consist of rule familiarization; registration with the 

Central Data Exchange (CDX) electronic reporting tool; collection, compilation, and submission of 

required information for significant new uses of the subject chemicals; export notification; and 

recordkeeping. Agency costs include reviewing and processing the data received as a result of the rule. 

Data sources for this analysis include burden estimates derived from previous information collection 

requests and economic analyses for related rules, compensation data acquired from government 

publications, and supplementary market research.

In addition to estimated costs, this report qualitatively discusses the benefits of the final rule based on the 

value of the information it will provide.

1.4 Organization of this Report

The remainder of this report presents EPA’s economic analysis in support of the final rule. Chapter 2 

presents estimates of the costs incurred by manufacturers, importers, and/or processors under the SNUR 

options. Chapter 3 shows estimates of the government costs associated with the administration of the final

rule. Chapter 4 discusses the benefits of the final rule. Chapter 5 presents an analysis of other impacts, as 

required by various statutes and executive orders.
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) 4 Economic and Policy Analysis Branch 

Note that all dollar values in this analysis are reported in 2011 dollars, except for the U.S. Postal Service 

mailing rates, which were acquired in January 2012.
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) 5 Economic and Policy Analysis Branch 

2. INDUSTRY COMPLIANCE COSTS

The final SNUR discussed in this report specifies that significant new uses of C12-13 chloro alkanes be 

reported under section 5(a)(2)(A) of TSCA. A significant new use is defined as the manufacturing, 

importation, and/or processing of C12-13 chloro alkanes for any use. A firm intending to manufacture, 

import, and/or process C12-13chloro alkanes for any significant new use must submit a SNUN. 

Alternatively, a firm can decide not to manufacture, import, and/or process the chemical for a significant 

new use. The firm, therefore, has two options:

 Option 1: Submit a SNUN. A SNUN indicates to EPA that the firm would like to manufacture, 

import, and/or process the chemical for a significant new use, which, in this case, means the 

manufacturing, importing, and/or processing of this chemical for any use. The firm must submit the 

SNUN to EPA at least 90 days before it plans to commence the manufacture, import, and/or 

processing of the substance; the SNUN provides EPA with the opportunity to evaluate the intended 

use and, if necessary, to prohibit or limit that activity before it occurs. If EPA allows the manufacture, 

import, or processing of C12-13 chloro alkanes for the intended use, then the costs associated with this 

option are the costs of submitting the SNUN (including a user fee) plus, if there is any export of these 

products, the export notification costs that result from TSCA Section 12(b) requirements that are 

automatically triggered for chemicals regulated under TSCA Section 5 (see Section 2.2.7 for details).

Because the domestic manufacture, import and processing of C12-13 chloro alkanes for the uses subject 

to the SNUR have been phased out, EPA expects that no firms will choose this option.

 Option 2: Decide not to manufacture, import, and/or process the chemical. The firm may decide 

simply not to proceed to manufacture, import, and/or process the chemical. While this option avoids 

the costs of submitting a SNUN, it entails the ‘hidden’ cost of the profit that will be foregone as a 

result of not engaging in the commercial activity originally planned. Similarly, if the firm will have 

used a given amount of C12-13 chloro alkanes in the production of another product, and must substitute 

to a more costly substance, it will incur those additional “hidden” costs of production. However, these 

hidden costs are expected to be minimal, if not zero, because C12-13 chloro alkanes is not currently 

manufactured in the United States. If the firm elects to produce C12-13 chloro alkanes for research and 

development (R&D) purposes only (an exemption for R&D purposes is provided in 40 CFR 

§721.47), it may have costs associated with R&D recordkeeping.

Because the domestic manufacture, import and processing of C12-13 chloro alkanes for the uses subject to 

the SNUR have been phased out, EPA does not expect there to be compliance cost associated for either of 

the options. The remainder of this chapter estimates the quantified portion of costs associated with the 

final SNUR. Section 2.1 summarizes the wage rates used in this chapter. Section 2.2 provides the unit 

industry compliance costs, including the costs of rule familiarization, registration with the Central Data 

Exchange (CDX) electronic reporting tool, completing the SNUN form, submission fee, import 

certification, and export notification. Total costs under each option are presented in Section 2.3. 

2.1 Wage Rates

The final 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 burden hours by the wage rate for the 

corresponding labor category. This section presents the estimated wage rate in each labor category.

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 

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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) 6 Economic and Policy Analysis Branch 

labor category for December 2011 are provided by the Employer Costs for Employee Compensation 

(ECEC) Supplemental Tables available on the BLS website (BLS, 2012a). The loaded wage rate is $70.72

for managerial labor; $64.66 for technical labor; and $29.63 for clerical labor. Table 1 presents the data 

used to calculate the loaded wage rates for the three labor categories.

Table 1: Loaded Industry Wage Rates, December 2011

Labor 

Category Data Sources

Wage

(2011$)

Fringe 

Benefit

(2011$)

Fringes 

as % 

wage

Overhead % 

wage2

Fringe + 

overhead 

factor

Loaded 

Wages1

(2011$)

(a) (b) (c) 

=(b)/(a)

(d) (e)=(c)+

(d)+1

(f)=(a) x 

(e)

Managerial

BLS ECEC, Private 

Manufacturing industries, “Mgt, 

Business, and Financial”3

$43.01 $20.40 47.43% 17% 1.64 $70.72

Professional/

Technical

BLS ECEC, Private 

Manufacturing industries, 

“Professional and related“3

$38.48 $19.64 51.04% 17% 1.68 $64.66

Clerical

BLS ECEC, Private 

Manufacturing industries,

“Office and Administrative 

Support” 3

$17.69 $8.93 50.48% 17% 1.67 $29.63

1 Wage data are rounded to the closest pennies in this table.

2 An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory 

Program (EPA 2002b), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a).

3 Employer Costs for Employee Compensation Supplementary Tables: December 2011. US Bureau of Labor Statistics, March 14, 

2011- (BLS 2012a).

2.2 Unit Industry Compliance Costs

2.2.1 Rule Familiarization

The final rule requires submitters and their staff to become familiar with the SNUR and its various 

requirements. Rule familiarization is estimated to require 0.55 hours of technical labor and 0.27 hours of 

managerial labor, as described in the Economic Analysis of the Premanufacture Notification Electronic 

Reporting Final Rule (EPA, 2009a), which measures the costs of mandatory electronic reporting of 

SNUNs and other TSCA Section 5 notices. As shown in Table 2, the total labor cost associated with rule 

familiarization is estimated at $54.43. 

Table 2: Rule Familiarization Burden and Cost for SNUR Submitters

Reporting Activity

Clerical Labor (at 

$29.63/hour)

Technical Labor (at 

$64.66/hour)

Managerial Labor 

(at $70.72/hour)

Total Labor Cost

Burden

(hours)

Cost

(2011$)

Burden

(hours)

Cost

(2011$)

Burden

(hours)

Cost

(2011$)

Burden

(hours)

Cost

(2011$)

Rule Familiarization 0.00 $0.00 0.55 $35.56 0.27 $18.86 0.82 $54.43

Total 0.00 $0.00 0.55 $35.56 0.27 $18.86 0.82 $54.43

Source: BLS 2012a (labor rates); EPA 2009a (burden hours)

2.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup

The final SNUR requires submission of a SNUN for any firm that chooses to manufacture, import, and/or 

process a chemical for a significant new use. First-time submitters of any TSCA section 5 notice 

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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) 7 Economic and Policy Analysis Branch 

(including Premanufacture Notices (PMNs), SNUNs, Test Market Exemption (TME) applications, Low 

Volume Exemption (LVE) notices, Low Exposure/Low Release (LoREX) exemption notices, 

Biotechnology Notices for genetically modified microorganisms, Notices of Commencement of 

Manufacture or Import (NOCs), and support documents to Section 5 notices) are required to register their 

company and key users with the CDX reporting tool, deliver a CDX electronic signature to EPA, and 

establish and use a Pay.gov E-payment account.2 These activities are only required of first-time 

submitters of any Section 5 notice. These activities are estimated to require the following burden hours, 

based on the estimates presented in the Economic Analysis of the Premanufacture Notification Electronic 

Reporting Final Rule (EPA, 2009a):

 CDX registration: EPA estimates that companies will spend approximately 0.18 hours per employee 

to register with CDX, and that an average of four technical staff members and one manager will need 

to register for each company, totaling approximately 0.92 hours of burden per company.

 CDX electronic signature: EPA estimates that companies will spend 0.25 hours preparing, 

submitting, and filing an electronic signature agreement (Authentication of Identity) form to EPA per 

employee. This burden will apply to four technical staff members and one manager per company, 

totaling 1.25 hours of burden per company. In addition, EPA estimates that a manager will spend an 

additional 0.50 hours accessing, preparing, and submitting verification forms (Verification of 

Authorization) for all authorized submitters to EPA. The total burden incurred by companies 

submitting and then verifying electronic signature agreements is 1.75 hours. Note that this burden 

does not include any additional time required to contact EPA’s CDX help desk to notify a change of 

submitter status, should one occur. Filing the electronic signature agreement requires an additional 

mailing cost of $2.55 per company (including five $0.45 stamps3and five $0.06 business envelopes4).

 Payment via Pay.gov account: EPA estimates that one manager per company will spend 

approximately 0.13 hours setting up a Pay.gov ID account, logging into the system, finding the 

appropriate form, and filling it out. This burden does not include the time required to click ‘submit’ 

on the form and wait for payment processing.

As shown in Table 3, the labor cost consists of CDX registration, CDX electronic signature, and Pay.gov 

account setup by a first-time submitter. As noted above, an additional $2.55 in mailing cost per company 

is attributable to these activities, for a total cost of approximately $190 per company.

 

2 Although the final rule does not require submitters to establish and use a Pay.gov account, the burden estimates in 

this analysis are conservative insofar as to include the use of Pay.gov as a required activity.

3 Price for a stamp was taken from the U.S. Postal Service website on January 24, 2012. (See U.S. PS, 2012)

4 Price for an envelope was determined based on the per unit price of a regular business envelope. See “Staples® 

#10, Self-Sealing Envelopes, 500/Box." Available at: http://www.staples.com/ (Accessed 1/25/2012).

Deleted: Table 3
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Table 3: CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup Burden 

and Cost for First-Time Submitters

Reporting Activity

Clerical Labor (at 

$29.63/hour)

Technical Labor (at 

$64.66/hour)

Managerial Labor 

(at $70.72/hour) Total Cost

Burden

(hours)

Cost

(2011$)1

Burden

(hours)

Cost

(2011$)1

Burden

(hours)

Cost

(2011$)1

Burden

(hours)

Cost

(2011$)1

CDX Registration 0.00 $0.00 0.73 $47.42 0.18 $12.96 0.92 $60.38

CDX Electronic 

Signature 0.00 $0.00 1.00 $64.66 0.75 $53.04 1.75 $118

Mailing Cost $2.55

E-Payment (Pay.gov

ID) 0.00 $0.00 0.00 $0.00 0.13 $9.43 0.13 $9.43

Total 0.00 $0.00 1.73 $112 1.07 $75.43 2.80 $190

Notes: 

Costs may not equal labor wage rate times burden hours due to the rounded burden estimate presented in the table, 

unrounded estimates were used during the cost calculations. 

Source: BLS, 2012a (labor rates); EPA, 2009a (burden hours); USPS, 2010 (mailing cost)

2.2.3 Form Completion and Submission Fee

Respondents who choose to submit a SNUN are required to gather and submit information regarding the 

data elements identified in the applicable SNUN reporting form. The methodology and calculations used 

in this analysis assume that the employee responsible for collecting, filling out, and submitting the 

requested information has a reasonable level of familiarity with the company and knowledge of 

operations at the site. It is assumed that for most entities these tasks are similar to other employee duties 

that require familiarity with EPA, State, and other Federal agency requests for chemical information and 

do not require additional familiarization or training beyond the basic rule familiarization described above. 

In addition, this analysis focuses on the marginal costs of submitting information for the final rule and not 

the total costs for the company to comply with a range of other Federal and State environmental, health, 

and safety regulations or accounting requirements that rely on this type of information.

Estimates of the costs of completing a Significant New Use Notice (SNUN) form are based on the costs of 

completing a PMN submission, since the data requirements are the same and the same form is used for both. 

The PMN submission costs came from EPA's 1994 Regulatory Impact Analysis of Amendments to 

Regulations for TSCA Section 5 Premanufacture Notifications, which relied on industry estimates of the 

effort needed to collect and compile all data required for a PMN submission, prepare the form, submit the 

form and data to EPA, and maintain a file of the submission (EPA, 1994, Table III-2 and pages III-11, -

12, and -13). The 1994 estimates were based on a survey conducted by the Chemical Manufacturers 

Association, which became the American Chemistry Council. These burdens include “the time spent 

reading and becoming familiar with the form, gathering the required information and preparing the report, 

producing sanitized responses for items claimed as confidential business information, and maintaining a 

file of the submission” (EPA, 1994. p. III 11-13). The burden associated with SNUN submission and 

preparation has been adjusted to reflect burden reductions resulting from the 2009 final PMN Electronic 

Reporting (ePMN) Rule that requires the electronic submission of all TSCA section 5 notices. Electronic 

submission of SNUN forms is expected to remove all clerical burden and reduce the recordkeeping 

burden associated with preparing a SNUN (EPA, 2009a).5In addition, electronic submission is expected 

 

5 The Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009a) reported 

a 0.5 hour clerical and a 0.5 hour technical burden associated with recordkeeping in addition to the burden estimates 

from the 1994 RIA (EPA, 1994, p. III-14). These burden estimates (the 0.5 for clerical burden and 0.5 for technical 
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

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to generate an additional 0.18 hours of technical burden, for the completion of the User Fee Payment 

Identification Number and email address data elements on the electronic SNUN form.

SNUN form completion and electronic submission is estimated to require approximately 74 hours of 

technical labor and 18 hours of managerial labor (EPA, 2009a). Table 4 combines the estimated reporting 

burden and loaded wage rates for all three labor categories to estimate the per-SNUN cost of form 

completion. The labor cost incurred by a SNUN submission for both large and small business submitters 

is estimated at $6,071.

Table 4: Industry Cost Estimate to Complete the SNUN Form

Reporting Activity

Clerical Labor (at 

$29.63/hour)

Technical Labor (at 

$64.66/hour)

Managerial Labor 

(at $70.72/hour) Total Labor Cost

Burden

(hours)

Cost

(2011$)

Burden

(hours)

Cost

(2011$)1

Burden

(hours)

Cost

(2011$)1

Burden

(hours)

Cost

(2011$)1

Form Completion 0.00 $0.00 74.2 $4,798 18.00 $1,273 92.2 $6,071

Notes: 

Costs may not equal labor wage rate times burden hours due to the rounded burden estimate presented in the table, 

unrounded estimates were used during the cost calculations. 

Source: 

1 Loaded wages include fringe benefits and overhead. See Appendix A of this report for derivation. Wage rates presented in 

this table are rounded values; however, unrounded values are used to calculate total labor costs. For this reason, total labor 

costs may not equal the product of rounded values.

2 The estimate of no clerical burden is taken from the Economic Analysis of the Premanufacture Notice Electronic

Reporting Final Rule (EPA, 2009a, page 7)

3 Technical and managerial labor burden is from the PMN Amendments RIA (EPA, 1994, Table III-2). An additional eleven 

minutes (0.18 hours) of technical burden is estimated to complete the User Fee Payment Identification Number and Email 

Address data elements on the Electronic SNUN form (EPA, 2009a page 15).

In addition, each submitting large business must pay a $2,500 per-SNUN submission fee, and each 

submitting small business must pay a $100 per-SNUN submission fee. Table 5 adds the labor cost and 

submission fee to estimate the total cost of a SNUN submission. The total cost of a SNUN submission is 

$8,571 for large business submitters and $6,171 for small business submitters.

Table 5: Industry Cost Estimate to Complete and Submit the SNUN Form

Reporting Population Labor Cost Submission Fee Total Cost 

(2011

Large Business Submitters $6,071 $2,500 $8,571

Small Business Submitters $6,071 $100 $6,171

Source: EPA, 2009a.

2.2.4 Recordkeeping

Companies submitting a SNUN must, under 40 CFR §721.40, keep records of the information contained 

in the SNUN. Some EPA reports have assumed that SNUN recordkeeping hours will be five percent of 

 

burden) are based on the recordkeeping burden for polymer exceptions and not the recordkeeping burden associated 

with PMN submissions.

Therefore, for this analysis, the 0.5 hour for clerical labor and the 0.5 hour for technical labor were removed. It is 

important to note that for this analysis, clerical burden changes are not applicable because the entire clerical burden

is assumed to be eliminated under the electronic reporting requirements. In summary, we do not include the one 

hour recordkeeping burden (0.5 hour for clerical, 0.5 for technical) reported in the ePMN EA.

Deleted: Table 4

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SNUN submission hours, or about five to six hours.6 For this report, the SNUN recordkeeping hours were 

included in the SNUN submission hours (see Section 2.2.3) and the SNUN recordkeeping costs under 40 

CFR §721.40 were not separately estimated.7 

Recordkeeping for Companies that Do Not Submit a SNUN

If a firm that manufactures, imports or processes a substance subject to the final SNUR chooses not to 

submit a SNUN, they must keep records that document compliance with SNUR conditions for avoiding a 

Significant New Use. Such recordkeeping requirements essentially involve copying and filing relevant 

records, including those related to category of use. Records must be maintained for five years from the 

date of their creation (40 CFR 721.40). For firms that choose to not submit a SNUN, costs for compliance 

with the recordkeeping requirements are estimated to be five percent of the reporting burden for reporting 

information for a specific section of the SNUN form and are performed by clerical staff (EPA, 2005b, 

pages 10 and 14). EPA used the per-activity burden for reporting, human exposure, category of use and 

releases to the environment presented in the Information Collection Request (ICR) for TSCA Section 

5(a)(2) Significant New Use Rules for Existing Chemicals (Renewal) (EPA, 2005b, page 12). Any clerical 

burden associated with these activities was removed to reflect the burden reduction associated with 

electronic submissions (EPA, 2009a). 

The recordkeeping burden for a company that does not submit a SNUN is estimated at 0.15 hours and $9.70

and is derived in Table 6. 

Table 6: Annual Per-Chemical Costs of Recordkeeping Requirement for Companies that 

Choose not to Submit a SNUN 

Reporting 

Activity

Per Activity 

Burden (Hours)

% of Reporting 

Burden 

Attributed to 

Recordkeeping

Total Labor Cost (2011$)

Burden Cost

Category of Use1 3 5% 0.15 $9.70

Notes: For the category of use reporting activity, the burden is associated with technical labor. See Table 1 for the 

technical wage rate.

Source:

1 US EPA, 2005b Office of Pollution Prevention and Toxics Information Collection Request (ICR) for TSCA Section 

5(a)(2) Significant New Use Rules for Existing Chemicals (Renewal),page 13.

However, EPA believes the SCCPs subject to this SNUR are not used in the U.S. and therefore no 

manufacturers, processors, or importers will be affected. Therefore, recordkeeping for companies that do 

not submit a SNUN will not be necessary. 

 

6 For example, OPPT’s Information Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules 

for Existing Chemicals (Renewal), October 11, 2005, estimates SNUN recordkeeping costs at 5.67 hours (ICR 

118.08, page 10). 

7 SNUN submission costs estimated in Section 2.2.3 of this report were based on PMN submission costs from a 

1994 report, Regulatory Impact Analysis of Amendments to Regulations for TSC Section 5 Premanufacture 

Notifications (EPA, 1994). Page III-14 of the 1994 report refers to “the normal records kept with a PMN submission 

which are included in the estimates for submission costs.” Page III-12 identifies “maintaining a file of the 

submission” as part of the labor hours for the PMN reporting form. These statements imply that the 95 to 114 total 

hours for a PMN submission (page III-10 of EPA 1994) included recordkeeping hours.

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2.2.5 Customer Notification

Manufacturers, processors, and importers of chemicals subject to SNURs must notify recipients of such 

chemicals of the SNUR or verify that knowledge of the SNUR has been otherwise acquired by recipients, 

or that the recipients are unable to engage in significant new uses. Since it is not expected that all such 

entities will have complete knowledge of all uses of any products subject to a SNUR, and because filing a 

SNUN could require significantly more burden, it is assumed that manufacturers, processors, and 

importers will most often choose to notify their customers of SNUR regulatory activities. As this 

notification may be accomplished by simply annotating an MSDS, EPA estimates the associated burden 

to be about one hour of a technical employee's time or $64.66 per manufacturer, processor, or importer 

per chemical. However, EPA believes the SCCPs subject to this SNUR are not used in the U.S. and 

therefore no manufacturers, processors, or importers will be affected. Thus, customer notifications will 

not be necessary. 

2.2.6 Import Certification

In general, promulgation of a SNUR triggers a TSCA Section 13 import certification requirement and the 

corresponding regulations at 19 CFR §12.118 to 12.127 and 19 CFR §127.28 for all imports of the 

relevant chemical substances. Thus, any U.S. manufacturer, importer, or processor receiving an imported 

shipment of chemicals subject to the final SNUR will have to certify that all chemical substances in the 

shipment either comply with all applicable rules and orders under TSCA or that all chemical substances in 

the shipment are not subject to TSCA.8 The statement must be on or attached to a commercial invoice or 

entry document belonging to the imported shipment.

Import certification is fulfilled by checking a box on an invoice or entry document and EPA assumes that 

it generally imposes no additional burden or cost on the importer. Any potential burden associated with 

the submitter’s familiarization with this requirement is assumed to be included in the more general SNUR 

familiarization burden discussed above.

2.2.7 Export Notification

Under Section 12(b) of TSCA, exporters must notify EPA if they export or intend to export a chemical 

subject to various TSCA sections (40 CFR §707.60 through 75). For TSCA 5(a)(2) (the section under 

which EPA promulgates significant new use rules) and certain other TSCA sections, this is a one-time 

notification requirement9 per destination country for each exporter of a chemical substance. After 

receiving a notification from a firm, EPA notifies the importing country and the United States State 

Department (40 CFR §707.70). To calculate the burden associated with making a single export 

notification, EPA first estimated the average annual number of export notifications made by an exporter. 

EPA then derived the annual and per notification burden associated with preparing and submitting an 

export notification. 

 

8 The exact statements are as follows: For imports of chemical substances subject to TSCA, “I certify that all 

chemical substances in this shipment comply with all applicable rules or orders under TSCA and that I am not 

offering a chemical substance for entry in violation of TSCA or any applicable rule or order under TSCA.” For 

imports of chemical substances not subject to TSCA (e.g., pesticides), “I certify that all chemicals in this shipment 

are not subject to TSCA.” (40 CFR 707.20)

9 On November 14, 2006, EPA revised the export notification requirement for chemicals subject to TSCA §5(a)(2), 

5(b), 5(e)(1) and 5(e)(2) from an annual to a one-time requirement per destination country for each exporter 

(November 14, 2006, 71 FR 66234).
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Most underlying data in this section come from the (2009 TSCA Section 12(b) ICR), ICR No.: 0795.13

OMB Control Number 2070-0030 [Information Collection Request for] Notification of Chemical Exports 

- TSCA Section 12(b) Supporting Statement for Request for OMB Review under the Paperwork 

Reduction Act (EPA, 2009b).

Exporter Costs10

EPA’s 2009 TSCA Section 12(b) ICR estimated that the average exporter making notifications will make 

12 notifications per year.

11 This includes notifications resulting from SNURs and notifications resulting 

from other TSCA activities. Therefore, it is likely that an exporter will make less than 12 notifications per 

year as a result of this final SNUR. A notification is typically no more than one page per 

chemical/country combination, and one notification mailing often includes multiple chemicals and/or 

destination countries.12

The percent of notifications resulting from SNURs in general is unknown, and it is assumed that there 

will be no notifications from this rulemaking as there are no U.S. manufacturers. 

Estimated Submission (Mailing) Costs. Regulated companies will incur mailing costs for export 

notifications delivered to EPA. Notifications are assumed shipped via the U.S. Postal Service (U.S. PS) as 

first-class registered mail with a return receipt (U.S. PS, 2012). The estimated per-shipment and annual 

mailing costs incurred by individual submitters are detailed in Table 7.

Table 7: Derivation of Total Mailing Cost for 12 Notices

Dates that the rates were verified on United States Postal Service web site: January 2012

Postal services costs

Registered mail, regular, with $0 declared value $10.95

Return receipt, requested at time of mailing (receive by mail) $2.35

Postage, regular First Class, up to 1 ounce $0.45

Cost per export notice – Subtotal $13.75

x 12

Total Mailing Cost for 12 Notices 165

Source: Mailing rates are from the US Postal Service web site as of January 2012 (http://www.usps.com/prices/). The 

mailing method comes from the Economic Analysis of the Proposed Change to TSCA Section 12(b) Export Notification 

Requirements, November 2005 (EPA, 2005), as clarified in a later SNUR economic analysis (EPA, 2007a, Table 8). 

Compile and Maintain the List of Products. Since TSCA §12(b) information collection activity has been 

in place for twenty years, most respondents will have already developed a list of their products subject to 

TSCA §12(b) export notification. Respondents need only check for new regulations promulgated and any 

new products exported by the company. Updating the list is estimated to take an average of one hour of 

technical time, which may also include some proportion of legal time (EPA, 2009b). The total burden can 

 

10 Most underlying data in this section come from the 2009 TSCA Section 12(b) ICR, ICR No.: 0795.13 

[Information Collection Request for] Notification of Chemical Exports - TSCA Section 12(b) Supporting Statement 

for Request for OMB Review under the Paperwork Reduction Act (EPA 2009b), with updating for inflation.

11 EPA calculated the average number of export notifications per exporter in the 2009 TSCA Section 12(b) ICR

(EPA, 2009b) by dividing the estimated number of submitted notifications (3,500) by the estimated number of 

exporters (300).

12 Based on review by an EPA economist of notifications received under TSCA Sections 4, 5 and 6 over 

approximately three weeks in early 2010.

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vary from two hours per year up to two hours per month, depending on the number of products exported 

by the company and the number of their products subject to TSCA §12(b) (EPA, 2009b).

The number of submitters per year who report under TSCA §12(b) has varied over time, rising from 

around 160 in 1991 to over 460 in 2000, and declining since. In the most recent TSCA §12(b) ICR, EPA 

estimated that there will be approximately 300 submitters per year in near-future years (EPA, 2009b). Of 

these 300 submitters, EPA estimated that 200 companies were near the lower burden estimate of two

hours per year, and 100 companies were near the upper estimate of 24 hours per year. Compiling the list 

for all respondents was therefore estimated to take 2,800 hours (2 hours x 200 firms plus 24 hours x 100 

firms), or an average of about 9.3 hours of technical time per firm per year for 12 notifications per year 

(EPA, 2009b).

Write or Revise Export Notification. Companies that export chemicals subject to TSCA §12(b) reporting 

must prepare an export notification to send to EPA when export shipments are made. Time for initial 

preparation of the export notice may vary depending on whether the company has prior experience with 

this requirement. This step is estimated to take an average of one hour of technical time (which may also 

include some proportion of legal time) per firm per year for 12 notifications per year (EPA, 2009b).

Check Orders and Send Notifications. Companies that export chemicals subject to TSCA §12(b) reporting 

must check outgoing shipments against the list of their products described above. A form letter notifying 

EPA and providing the required data must be printed and mailed within the required time period. This 

process is estimated to take an average one half hour of clerical time per export notification or six hours 

for 12 notifications (EPA, 2009b).

The burdens and associated costs for each notification activity are provided in Table 8. EPA estimates 

that the burden associated with making one notification is approximately 1.4 hours and $84. 

Table 8: TSCA 12(b) Export Notification Cost per Notification

Technical Clerical Total

$/Hr Hours 2011$

3

$/Hr Hours 2011$

3 Hours 2011$3

Compile list $64.66 9.3 $601 -- -- -- 9.3 $601

Write letter $64.66 1 $65 -- -- -- 1 $65

Check order and send notice -- -- -- $29.63 6 $178 6 $178

Mailing cost1-- -- -- - $165

Total per average facility2 10.30 $666 6.00 $178 16.30 $1,008

Total per notification 0.86 $55.50 0.50 $14.81 1.36 $84.06

Notes:

1 Mailing costs reflect January 2012 USPS rates and can be found in Table 7.

2 An average facility submitting notifications is assumed to submit 12 export notifications per year.

3 Costs may not equal labor wage rate times burden hours due to the rounded burden estimate presented in the table, unrounded 

estimates were used during the cost calculations.

Source: ICR No.: 0795.13 [Information Collection Request for] Notification of Chemical Exports - TSCA Section 

12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction Act (EPA 2009b, p.10), 

and are updated to 2011 dollars. 

2.3 Industry Costs of SNUR, by Option (per Submission)

The number of firms affected that do not make submissions to EPA is not known; therefore, costs are not 

aggregated across the affected entities. Table 9 summarizes the per-company per-chemical costs to 

comply with the final rule amendment, as described in more detail in Section 2.2 above.

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Table 9: Compliance Options and Associated Costs Incurred by a Firm Due to the Final SNUR

Option1 Costs Quantified Costs per Chemical (2011)

2

1.

Electronic 

submission of a 

Significant New Use 

Notice (SNUN), 

indicating to EPA 

that the firm would 

like to manufacture, 

import, or process the 

chemical for a 

Significant New Use 

as defined in the 

SNUR.

Costs of electronically submitting

a SNUN, including rule 

familiarization, CDX registration 

(for companies that are first-time 

submitters), form completion, user 

fee, export notification cost (if 

relevant). Rarely, a firm may 

choose to conduct toxicity or fate 

testing to support the SNUN, but 

such testing is not required by law.

$54.43 rule familiarization cost; $8,571 

submission cost (including SNUN 

recordkeeping under 40 CFR §721.40 and fee 

$2,500 for large businesses). EPA usually 

receives well under ten SNUNs per year. 

Export notifications costs are estimated at 

$84.06 per notification; total cost per 

company will vary. First time submitters will 

incur $190 for CDX registration and 

associated activities. Companies 

manufacturing, importing, or processing a 

chemical currently used in commerce in the 

United States will incur a cost $64.66 for 

notifying consumers of SNUR regulatory 

activities. 

2.

Decide not to 

manufacture, import, 

or process the 

chemical for any nonexempt uses.

Cost of the profit foregone as a 

result of not engaging in the 

commercial activity originally 

planned (opportunity costs). Other 

costs include rule familiarization, 

and export notification costs. 

Opportunity costs are not quantified. Other 

costs include rule familiarization ($54.43), 

recordkeeping ($9.70), export notification 

costs ($84.06 per notification), and customer 

notification ($64.66) may apply.

Notes:

1 Firms may be subject to both options at once since submission of a SNUN results in profits foregone as a result 

of not manufacturing, importing, or processing the chemical.

2 Quantified costs are attributable to the SNUR only if a firm will not otherwise follow the specified practices.

Costs are detailed in Section 2.2.

3 EPA does not require the development of test data for submission of a SNUN, although a firm may submit test 

data already in its possession and/or describe any other available data. Because EPA does not require the 

development of test data, EPA assumes that no firms will incur testing costs as a result of the final SNUR.

2.4 Likelihood of a SNUN Submission

This analysis assumes that no entities are expected to submit a SNUN. EPA has, over the years, 

promulgated SNURs that cover a total of more than 1,000 chemicals. In response, the Agency receives 

only a handful of SNUNs per year. For example, the number of SNUNs received was six in Federal fiscal 

year (FY) 2007, eight in FY2008, seven in FY2009, two in FY2010, and ten in FY2011.13 In addition, 

because the domestic manufacture, import and processing of C12-13 chloro alkanes for the uses subject to 

the SNUR have been phased out (see Section 1.1), very few, if any, entities are expected to submit a 

SNUN. 

2.5 Potential for Subsequent Regulatory Action

The Agency recognizes that if submission of a SNUN does result from a SNUR, the Agency may take 

additional regulatory actions under TSCA. These additional regulatory actions might be necessary to 

further evaluate an intended new use and associated activities, or to prohibit or limit that activity before it 

occurs to prevent unreasonable risk of injury to human health or the environment. It is not known what 

 

13 Values based on US EPA’s PMN Gold (V1.1) record keeping system as of September 1, 2011 (EPA, 2011a).

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specific subsequent regulatory actions, if any, the Agency may determine are necessary after reviewing a 

SNUN. Any such actions are highly dependent on the circumstances surrounding the individual SNUN 

(e.g., available information and scientific understanding about the chemical and its risks at the time the 

SNUN is being reviewed). 

Should the Agency’s review of the SNUN result in further regulatory actions, the Agency would initiate 

and follow the appropriate procedures for taking those actions. Included in those procedures would be an 

assessment of the costs and benefits of those actions. 
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

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3. AGENCY COSTS

As described in the following sections, EPA’s costs to review and process SNUN submissions are 

assumed to be the same as EPA costs to review PMNs.

3.1 Labor Rates for EPA Staff

Agency labor costs are calculated based on annual Federal salaries for the Washington-Baltimore area 

published by the Office of Personnel Management effective January 2011 (OPM, 2011). EPA assumes 

that, on average, a federal GS-13, Step 5 full-time equivalent (FTE) will conduct its collection and 

administrative activities under the final rule.14 The average salary for a GS-13 Step 5 employee was 

$100,904 in 2011 without fringe benefits and overhead costs. In order to derive the fully loaded salary, 

EPA multiplied the annual salary by an assumed loading factor of 1.6 to reflect federal fringe benefits and 

overhead (EPA, 2009c), which results in a fully loaded annual salary of $161,446 (see Table 10). 

Dividing the fully loaded annual salary by 2,080 hours (i.e., the number of hours in a work year) yields an 

estimated hourly FTE wage rate of $77.62.

Fully loaded costs for Agency labor are shown in Table 10.

Table 10: Derivation of Loaded Agency Wage Rates

Labor 

Category

Data Source for Wage 

Information Date

Wage

Fringe 

Benefit

Fringes as 

% wage

Overhead 

as % wage

Fringe + 

overhead 

factor

Loaded 

Wages

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

EPA staff 

FTE

Annual federal staff cost: 

OPM WashingtonBaltimore-Northern 

Virginia, DC-MD-PAVA-WV, area, GS-13 

Step 1 pay rates a

Jan 

2011

$100,904

(annual)

--

[Included 

in 60% 

overhead]

60% b 1.60

$161,446

(annual)

$47.36 

(hourly)

$77.62

(hourly)

Notes:

a The Agency salary is the unloaded federal GS-13 Step 5 salary ($100,904 for 2011), from the OPM salary table for the 

Washington-Baltimore-Northern Virginia Locality Pay Area (OPM 2011). Hourly rates are based on annual salary divided by 

2,080 hours.

b The 60% fringes-and-overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) 

(EPA 1992, page 30, footnote 9).

3.2 SNUN Processing Costs

The list of review steps, estimates of extramural costs, and the percent of chemicals requiring a particular 

review step are derived from the costs for processing PMN submissions in Table VII-1 of a 1994 EPA 

report, Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture 

Notifications (EPA, 1994). The Agency burden associated with processing a PMN has been adjusted to 

reflect burden reductions resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that 

requires the electronic submission of all TSCA section 5 notices. Electronic submission of SNUN forms 

is expected to reduce Agency burden by 16.5 percent (EPA, 2009b, p.28).

 

14 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007) (EPA, 2007a), which covers PMN SNURs. 

Use of this grade level follows the approach introduced in EPA, 2007b. That report represented a change from an 

earlier PMN SNUR economic analysis (EPA, 2003), which used an average of GS-12 Step 1 and GS-12 Step 10 

salaries.

Deleted: Table 10

Deleted: Table 10
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

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For each review step, the “EPA staff” cost is calculated by multiplying the number of FTEs (in the first 

column) by the fully loaded hourly salary. This shows EPA staff cost for chemicals requiring the selected 

review step. 

The Extramural Cost column shows costs for contractor support and other outside purchases for 

chemicals requiring the selected review step, and is inflated from 1993 prices using the Bureau of Labor

Statistics (BLS) Employment Cost Index (ECI) data (BLS, 2012b). The ECI for total compensation (not 

seasonally adjusted) of private industry professional and related workers (Series ID CIU2010000120000I) 

is used because it is the only series with continuous data since 1985, and that includes professional and 

technical labor, which perform the majority of Agency extramural activities. Table 11 contains the 

derivation of inflation factors for Agency extramural costs.

Table 11: Derivation of Inflation Factors for Agency Extramural Costs

Item Inflation index source

Starting 

year

Index 

for 

starting 

year

(a)

Index 

for 

2011

(b)

Inflation 

factor

(b)/(a) 2

Agency Extramural costs 

White collar labor; 

equipment; supplies

BLS ECI, Total comp, Private 

industry, Professional and related, 

4

th Q [BLS 2012b]4

1993 67.0 115.7 1.73

Source:

Bureau of Labor Statistics. Employment Cost Index – Total Compensation: Professional and Related Private Industry, Not 

Seasonally Adjusted. (Series ID: CIU2010000120000I), extracted March 22, 20120 (BLS 2012b).

The ‘Percent of Cases column’ in Table 12 is a weighting factor applied to reflect the fact that not all 

chemicals require each review step. For example, in the PMN process, all chemicals require 

Administrative Prescreening, but not all chemicals require the intensive scrutiny of “Standard Review.” 

The three types of submissions resulting from a SNUR may have weighting factors that differ from each 

other and from the weighting factors for PMNs. Changes in weighting factors could cause actual review 

costs to be higher or lower than calculated here. For example, some SNUNs require little review because 

they are determined to be “invalid” – i.e. not required in the first place. However, often a SNUN may take 

more Agency time than a typical PMN because of factors such as the need to retrieve old PMN records 

from archives, and the likelihood that more data requiring EPA review are submitted with a SNUN than 

would be submitted on average with a PMN. Resources were not available to update the review hours to 

reflect the current review process or to tailor the cost estimates to SNUNs. Therefore, for this analysis, the 

review steps and weighting factors are assumed to be the same as those derived in 1994 for PMNs.

Values in the ‘Weighted Cost’ column are calculated by multiplying the un-weighted costs (EPA staff 

cost plus extramural costs) by the percentage of cases requiring this review step. Weighted costs are then 

multiplied by the burden reduction of 16.5 percent to account for burden savings generated electronic 

submission. This calculation yields total Agency costs of $5,066 per SNUN, for submission review and 

processing, as shown in Table 12

Deleted: Table 11

Deleted: Table 12

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Table 12: Agency Costs for SNUN and Other Submission Review and Processing

Review Steps

EPA staff (FTE) Cost Extramural Cost 2

Unweighted 

Cost

Pct. of 

Cases

Weighted 

Cost3

ePMN 

Burden 

Reduction4

Weighted Cost 

with ePMN 

Burden 

Reduction

FTE 

fraction

Cost per 

FTE 1

FTE Total 

($2011)

1993 

dollars

2011

dollars

(a) (b) (c)=(a)*(b) (d) (e) (f)=(c)+(e) (g) (h)=(f)*(g) (i) (j)=(h)*(1-(i))

Pre-notice consultation 0.0024 $161,446 $387.47 $4.00 $6.91 $394 41% $161.70 0.165 $135

Administrative prescreen/ 

notice receipt/user fee 0.0024 $161,446 $387.47 $92.00 $158.87 $546 100% $546.34 0.165 $456

CRSS (Chemical Review and 

Search Strategy) 0.0025 $161,446 $403.62 $268.00 $462.80 $866 100% $866.42 0.165 $723

SAT (Structure Activity 

Team) 0.0006 $161,446 $96.87 $14.00 $24.18 $121 100% $121.04 0.165 $101

Engineering/Exposure 0.0015 $161,446 $242.17 $56.00 $96.70 $339 100% $338.87 0.165 $283

Exposure/Fate 0.0008 $161,446 $129.16 $0.00 $0.00 $129 100% $129.16 0.165 $108 

Focus 0.0009 $161,446 $145.30 $23.00 $39.72 $185 100% $185.02 0.165 $154 

Standard Review Functions 0.0219 $161,446 $3,535.68 $511.00 $882.43 $4,418 29% $1,281.25 0.165 $1,070 

Division Directors Meeting 0.0129 $161,446 $2,082.66 $113.00 $195.14 $2,278 15% $341.67 0.165 $285 

Order 

Development/Negotiation 

Review

0.0171 $161,446 $2,760.73 $22.00 $37.99 $2,799 3% $83.96 0.165 $70 

Post Order Data Review 0.0886 $161,446 $14,304.15 $0.00 $0.00 $14,304 3% $429.12 0.165 $358 

Order Modification 0.2167 $161,446 $34,985.43 $0.00 $0.00 $34,985 3% $1,049.56 0.165 $876 

New Chemical SNUR 

Development 0.0277 $161,446 $4,472.07 $85.00 $146.78 $4,619 7% $323.32 0.165 $270 

Notices of Commencement 0.0012 $161,446 $193.74 $40.00 $69.07 $263 31% $81.47 0.165 $68 

FOIA (Freedom of 

Information Act) Requests 0.0333 $161,446 $5,376.17 $287.00 $495.61 $5,872 1% $58.72 0.165 $49 

CBI (Confidential Business 

Information) Substantiation 0.0004 $161,446 $64.58 $3.00 $5.18 $70 100% $69.76 0.165 $58

TOTAL $6,067 0.165 $5,066

Notes:

1 GS-13 Step 5 salaries loaded with benefits and overhead. See Table 10 for derivation.

2 Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated from 1993 prices using the factors presented in Table 

11. 

3 Weighted costs were calculated using unrounded unit cost estimates, so results may differ from calculations using the rounded values shown in this table. 

4 Electronic submission is expected to generate a cost savings of 16.5% to the Agency (EPA 2009b, p. 28).

Sources: FTEs per review step, 1993 extramural costs, and percents of cases are from EPA, 1994 Table VII-1, GS-13 salaries are from OPM 2011.

Formatted: Font: 9 pt

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Formatted: Font: 9 pt

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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) 19 Economic and Policy Analysis Branch 

3.3 Export Notification Cost

Under TSCA Section 12(b), exporters must notify EPA if they intend to export chemicals subject to 

SNURs, as described in Section 2.2.7. The Agency burden and cost due to TSCA §12(b) export 

notification results from three tasks. In the first task, EPA receives export notifications from companies 

that intend to export one of the chemicals subject to TSCA §12(b) (EPA, 2009b). In the second task, EPA 

staff prepares separate notification letters that are subsequently reviewed and delivered to importing 

countries, their embassies, or representatives, and to the importing country’s U.S. embassies (EPA, 

2009b). (See Table 6 for the cost of mailing one notification). The third task is comprises EPA staff 

responses to public inquiries and other TSCA 12(b) activities. The work of responding to non-routine 

requests for information and clarification from industry and importing countries, and of handling other 

tasks associated with the TSCA §12(b) program, was estimated to require roughly 400 hours per year 

(EPA, 2009b). Since the current rulemaking covers only a very small percent of the chemicals subject to 

TSCA 12(b) reporting, a very small percent of such activity will be attributable to the current rulemaking. 

Because it is unknown how many, if any, notifications EPA will receive or send as a result of the current 

rulemaking, the costs to the Agency are presented per activity. The estimated burden for the first two 

Agency activities is provided in Table 13. To estimate the Agency cost, hourly burdens are multiplied by 

the loaded wage rate of a GS-13, Step 5, which is derived in Table 10. 

Table 13: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2011$)

Agency Activity

Hours per 

Activity

FTE per 

Activity1

Loaded Mailing 

Cost

Total Agency Cost per 

Activity GS-13, Step 5 FTE 

Wage Rate

(a) (b) = (a)/2,080 (c) (d) (e) = ((b)*(c))+(d)

Process an incoming 

notification from an 

exporting company

0.10 0.000048 $161,446 $0.00 $7.76

Prepare and mail a 

notification to an 

importing country

0.50 0.000240 $161,446 $13.75 $52.56

Notes:

1 The burden associated with an Agency activity is the burden for the Agency to process one incoming 

notification, or to prepare and mail an outgoing notification 

Source: Table 10 of this report derives Agency labor costs. Mailing costs are from Table 7 of this report. Other 

burdens are from EPA 2009b, updated for inflation.

Deleted: Table 13

Deleted: Table 10

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4. BENEFITS

A SNUN submission provides EPA with the opportunity to evaluate the intended use and, if necessary, to 

prohibit or limit that activity before it occurs. It allows the Agency to take immediate action to mitigate an 

activity that the Agency deems harmful to the environment or human health. The final SNUR allows EPA 

to evaluate the use of, or exposure to these chemicals and allows the Agency to take preventive action to 

limit or prohibit any Significant New Use. 

EPA requires additional information to fulfill its mandate under TSCA to fully assess the risks posed by 

the production, sale, and use of C12-13 chloro alkanes in the United States. A SNUN submission provides 

EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity 

before it occurs. This is especially important in this case because C12-13 chloro alkanes has been found to 

be harmful to aquatic life, and there is no current US production or importation of the chemical. 

Therefore, the SNUN allows EPA to monitor any planned production or processing of the chemical and if 

necessary to continue to keep the chemical from being used in the United States. The final rule may also

restrict future production, exposure, and release of the chemical, as a company may choose to 

manufacture or process an alternative that is not subject to the SNUR, as opposed to submitting a SNUN. 

Quantification of the benefits of the final rule will require more specific information about each user’s use 

patterns and preferences as well as the changes in these patterns and preferences that will result from the 

additional information made available under the final rule. These data are not readily available and 

collecting such data will be cost-prohibitive.
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5. ADDITIONAL ANALYSES

This section presents additional analysis of other potential impacts of this rulemaking, as required under 

various statutes and executive orders.

5.1 Regulatory Flexibility Act

Pursuant to section 605(b) of the Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et seq.), the Agency 

hereby certifies that promulgation of this SNUR will not have a significant adverse economic impact on a 

substantial number of small entities. The rationale supporting this conclusion is as follows. The 

requirement to submit a SNUN applies to any person (including small or large entities) who intends to 

engage in any activity described in the rule as a significant new use. Where a use is new, by definition no 

small or large entities presently engage in such activities. Although some small entities may decide to 

manufacture or process a substance for the new use after the SNUR is promulgated, EPA receives very 

few SNUNs, and few of those are submitted by small entities. In response to the promulgation of SNURs 

covering over 1,000 chemical substances, the Agency receives only a handful of SNUNs per year. For 

example, the number of SNUNs was four in Federal fiscal year 2005, eight in FY2006, six in FY2007, 

eight in FY2008, seven in FY2009, two in 2010, and ten in 2011 (EPA, 2012), for an average of 6 per 

year from all SNURs. EPA has no reason to believe that this SNUR will alter the pattern of SNUN 

submissions that EPA has historically seen. In addition, the estimated reporting cost for submission of a 

SNUN is minimal regardless of the size of the firm, averaging about $8,600 including SNUN 

recordkeeping and reporting costs. The Agency currently offers some relief to certain small businesses 

with sales (including those of subsidiary/parent companies) of less than $40 million per year by reducing 

the SNUN submission fee from $2,500 to $100. This lower fee reduces the cost of submitting a SNUN to 

about $6,200 for smaller firms. During the six year period from 2005-2010, only three submitters selfidentified as small in their SNUN submission15 (EPA, 2012). EPA believes the cost of submitting a 

SNUN is relatively small compared to the cost of developing and marketing a chemical new to a firm and 

that the requirement to submit a SNUN generally does not have a significant economic impact. 

EPA believes that the potential economic impact of complying with a SNUR is not expected to be 

significant or adversely affect a substantial number of small entities.

5.2 Unfunded Mandates Reform Act

The final rule does not impose any enforceable duty, contain any unfunded mandate, or otherwise have any 

effect on small governments because none of the current producers of the subject chemicals are 

governments. Additionally, it is not expected that any governments will initiate production of these 

chemicals.

5.3 Paperwork Reduction Act

According to the Paperwork Reduction Act (PRA), 44 U.S.C. 3501 et seq., an Agency may not conduct or 

sponsor, and a person is not required to respond to a collection of information that requires OMB 

approval under the PRA, unless it has been approved by OMB and displays a currently valid OMB 

Control number. The OMB control numbers for EPA's regulations in title 40 of the CFR, after appearing 

in the Federal Register, are listed in 40 CFR, part 9, and included on the related collection instrument, or 

form, if applicable. The information collection requirements related to this action have already been 

approved by OMB pursuant to the PRA under OMB control numbers 2070-0038 (EPA ICR No. 1188)

and 2070-0030 (EPA ICR No. 0795).

If an entity were to submit a SNUN to the Agency, the annual burden is estimated to average 98.2 hours 

per response: 0.82 hours for rule familiarization (Section 2.2.1), 2.80 hours for CDX registration, CDX 

 

15 The three “small” submitters were identified by review of actual SNUN submissions from the years 2005-2010.
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

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electronic signature, and pay.gov account setup (Section 2.2.2), 92.2 hours for form completion, 

submission and recordkeeping under CFR §721.40 (Sections 2.2.3 and 2.2.4), 1 hour for consumer 

notifications (Section 2.2.5) and 1.36 hours for export notification (Section 2.2.7). The burdens for rule 

familiarization, CDX registration, CDX electronic signature, pay.gov account setup form completion, 

submission, and recordkeeping are approved under EPA ICR No. 1188 (OMB control number 2070-

0038). The burden for export notification is approved under EPA ICR No. 0795 (OMB control number 

2070-0030).

5.4 Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations

Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority Populations and 

Low Income Populations” (59 FR 7629, February 16, 1994), establishes federal executive policy on 

environmental justice. Its main provision directs federal agencies, to the greatest extent practicable and 

permitted by law, to make environmental justice part of their mission by identifying and addressing, as 

appropriate, disproportionately high and adverse human health or environmental effects of their programs, 

policies, and activities on minority populations and low-income populations in the United States.

The information collected under this final rule will assist EPA and others in determining the potential 

hazards and risks associated with various chemicals manufactured and used at high production volumes. 

Although not directly impacting environmental justice-related concerns, this information will enable the 

Agency to better protect human health and the environment, including in low-income and minority 

communities.

5.5 Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks

Executive Order 13045, Protection of Children from Environmental Health Risks and Safety Risks (62 FR 

19885, April 23, 1997), requires EPA to identify and assess environmental health and safety risks that may 

disproportionately affect children. This type of analysis is required for rules that will have an impact of 

$100 million or more only. The impact of this SNUR will be less than $100 million and therefore no 

analysis of such impacts on children is required.

5.6 Executive Order 13132: Federalism 

Executive Order 13132, entitled Federalism (64 FR 43255, August 10, 1999), requires EPA to develop an 

accountable process to ensure “meaningful and timely input by State and local officials in the 

development of regulatory policies that have federalism implications.” Policies that have federalism 

implications are defined in the Executive Order to include regulations that have “substantial direct effects 

on the States, on the relationship between the national government and the States, or on the distribution of 

power and responsibilities among the various levels of government” (64 FR 43255, August 10, 1999). 

The final rule establishes reporting and recordkeeping requirements that apply to manufacturers 

(including importers) and processors of certain chemicals. EPA has no information to indicate that any 

state or local government manufactures or processes the chemical substances covered by this action.

5.7 Executive Order 13175: Consultation and Coordination with Indian Tribal Governments 

Executive Order 13175 is Consultation and Coordination with Indian Tribal Governments (59 FR 22951, 

November 6, 2000). This rule does not have Tribal implications because EPA has no information to 

indicate that any tribal government manufactures or processes the chemical substances covered by this 

action.
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

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5.8 Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use 

This rule is not subject to Executive Order 13211, entitled Actions Concerning Regulations That 

Significantly Affect Energy Supply, Distribution, or Use (66 FR 28355, May 22, 2001), because this 

action is not expected to affect energy supply, distribution, or use.
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011-12-6) 24 Economic and Policy Analysis Branch 

6. REFERENCES 

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59 FR 22951, Consultation and Coordination with Indian Tribal Governments, Federal Register, Volume 

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62 FR 19885, Protection of Children from Environmental Health Risks and Safety Risks, Federal 

Register, Volume 62, April 23, 1997.

64 FR 43255, Federalism, Federal Register, Volume 65, August 10, 1999.

66 FR 28355, Actions Concerning Regulations that Significantly Affect Energy Supply, Distribution, or 

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Paraffins (SCCPs) and Other Chlorinated Paraffins Action Plan. Available at: 

http://www.epa.gov/opptintr/existingchemicals/pubs/actionplans/sccps_ap_2009_1230_final.pdf

Government of Canada. 2008. Order Adding Toxic Substances to Schedule 1 to the Canadian 

Environmental Protection Act, 1999. Canada Gazette. September 20, 2008, 142 (38).
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HELCOM. 2002. Helsinki Commission. Baltic Marine Environment Protection Commission. Project 

Team for the Implementation of the HELCOM Objective with regard to Hazardous Substances 

7th Meeting. March 11-13, 2002. Final Report.

IARC. 1990. International Agency for Research on Cancer. Monographs on the Evaluation of 

Carcinogenic Risks to Humans. Volume 48. Some Flame Retardants and Textile Chemicals,and 

Exposures in the Textile Manufacturing Industry Summary of Data Reported and Evaluation. 

World Health Organization: Paris, France.

Klaunig, J.E., Babich, M.A., Baetcke, K.P. Cook, J.C., Corton, J.C., David, R. M., DeLuca, J.G., Lai, 

D.Y., McKee, R. H., Peters, J.M., Roberts, R.A. and Fenner-Crisp, P.A. (2003). PPARα AgonistInduced Rodent Tumors: Modes of Action and Human Relevance. Crit. Rev. Toxicol. 33: 655-

780.

NTP. 1986a. National Toxicology Program. Department of Health and Human Services. Toxicology and 

Carcinogenesis Studies of Chlorinated Paraffins(C12, 60% Chlorine) in F344/N Rats and B6C3F1

Mice. May 1986. Available at: http://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr308.pdf. Accessed 

December 11, 2009.

NTP. 1986b. National Toxicology Program. Department of Health and Human Services. Toxicology and 

Carcinogenesis Studies of Chlorinated Paraffins(C23, 43% Chlorine) in F344/N Rats and B6C3F1

Mice. May 1986. Available at: http://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr305.pdf. Accessed 

December 11, 2009.

NTP. 2005. National Toxicology Program. Department of Health and Human Services. Report on 

Carcinogens, Eleventh Edition; Substance Profiles: Chlorinated Paraffins (C12, 60% Chlorine) 

CAS No. 108171-26-2. 2005. Available at: 

http://ntp.niehs.nih.gov/ntp/roc/eleventh/profiles/s034chlo.pdf. Accessed Dec 11, 2009.

OPM, 2011. Office of Personnel Management, Salary Table 2011-DCB, Washington-BaltimoreNorthern-Virginia, DC-MD-VA-WV-PA. Accessed from 

http://www.opm.gov/oca/11tables/pdf/DCB.pdf. 

Rawie, Carol. 2009. EPA Office of Pollution Prevention and Toxics. Personal communication with Tulika 

Narayan and Kimberly Wilson of Abt Associates via e-mail. February 5, 2009.

Sleemi, 2006. Fehimida Sleemi. U.S. Bureau of Labor Statistics, “Employment Cost Index Publication 

Plans”. Monthly Labor Review. Vol. 129, No. 4, April 2006. available at 

www.bls.gov/opub/mlr/2006/04/art2full.pdf

UNECE. 2006. United Nations Economic Commission for Europe. Short Chain Chlorinated Paraffins 

Track B Review for the UNECE LRTAP Task Force on Persistent Organic Pollutants – Final 

Report. May 2006.

UNEP. 2009. United Nations Environment Programme. Stockholm Convention on Persistent Organic 

Pollutants (POPs). Persistent Organic Pollutants Review Committee. Revised Draft Risk Profile: 

Short-Chained Chlorinated Paraffins. 9 July 2009. UNEP/POPS/POPRC.5/2. Available at: 

http://chm.pops.int/Convention/POPsReviewCommittee/hrPOPRCMeetings/POPRC5/POPRC5D

ocuments/tabid/592/language/en-US/Default.aspx. Accessed December 11, 2009.

U.S. Postal Service (U.S. PS). 2012. “Prices” <http://www.usps.com/prices/>. Accessed January 2012.
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Weinstein, 2004. Harriet G. Weinstein and Mark A. Loewenstein, U.S. Bureau of Labor Statistics. 

Comparing Current and Former Industry and Occupation ECEC Series. Originally posted August 

25, 2004 at http://www.bls.gov/opub/cwc/cm20040823ar01p1.htm
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APPENDIX A

INFLATORS AND WAGE RATES
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A. INFLATORS AND WAGE RATES

This appendix describes the derivation of the fully loaded labor rates and inflation factors used in 

calculating costs of labor, materials, and other inputs. Costs presented in this report are in 2011 dollars.

A.1 Derivation of Loaded Wage Rates 

Unit labor costs are calculated by adding fringe benefits and overhead to the wage or salary to derive a 

fully loaded labor cost. The basic method is described in Wage Rates for Economic Analysis of the Toxics 

Release Inventory Program (EPA, 2002b). The resulting loaded labor rates are given in Table 15. Costs 

are calculated for several labor categories: Managerial, Professional/Technical, Clerical, and EPA staff. 

In March 2004, BLS began using the North American Industry Classification System (NAICS) codes 

instead of the Standard Industrial Classification (SIC) System, and the Standard Occupational 

Classification (SOC) system instead of the Occupational Classification System (OCS). The following 

table shows the crosswalk between old and new occupational titles.

Table 14 : Detail of Labor Categories Used in the Analysis

EPAB Reports Labor Category 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: Employer Costs for Employee Compensation: Changes to NAICS and SOC, Table 2. ECEC Occupational 

Comparability between SOC and OCS (BLS, 2006a and Weinstein, 2004).

A.1.1 Derivation of Labor Rates for Managerial, Professional/Technical, Clerical, and 

Production Labor

Wages and fringe benefits for managerial, professional/technical, and clerical labor were taken from the 

Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation (ECEC) data,16 for 

December 2011, for manufacturing industries.17

The cost of fringe benefits such as paid leave and insurance, specific to each labor category, are taken 

from the same ECEC series. Fringe benefits as a percent of wages are calculated separately for each labor 

category. For example, for December 2011, the average wage rate for professional/technical18 labor was 

$38.48; the average fringe benefit was $19.64. Fringe benefits as a percent of wages were $19.64/$38.48, 

or approximately 51.0 percent.

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 economic analyses for two major 

 

16 This follows the approach introduced in Economic Analysis of Expedited Significant New Use Rules for 65 Chemical 

Substances: EPA Docket OPPT-2003-0063 (EPAB, 2007b). 

17 Employer Costs for Employee Compensation Supplementary Tables December 2011. (BLS, 2012a). This follows the approach 

introduced in EPAB, 2007a. Earlier PMN SNUR economic analyses, such as EPA, 2003, used ECEC data for “All Goods 

Producing” sectors (manufacturing, mining, and construction). However, the manufacturing sector data seem more relevant 

since the SNURs mainly affect the chemicals industry.

18 This follows terminology introduced in EPAB, 2007b. Earlier SNUR economic analyses 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, 2004).
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rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b), 

and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (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 2011 fully loaded wage for 

professional/technical labor is $38.48 × (1+0.5104 + 0.17) = $64.66.

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

15.

A.1.2 Derivation of Labor Rates for EPA Staff

Agency labor costs are calculated based on annual Federal salaries for the Washington-Baltimore area 

published by the Office of Personnel Management effective January 2011 (OPM, 2011). The average 

salary for one FTE staff member is estimated as the salary for a GS-13 Step 5 employee.19

Multiplying the annual pay by an assumed loading factor of 1.6 to reflect Federal fringe benefits and 

overhead, the loaded annual salary of EPA staff was calculated to be $161,446. 

The Agency loading factor is from an EPA guide, Instructions for Preparing Information Collection 

Requests (ICRs) (EPA, 1992, page 30, footnote 9). The 60 percent assumption was labeled “the benefits 

multiplication factor” in the EPA Guide, but has been used in many EPA Office of Pollution Prevention 

and Toxics ICRs to reflect both fringe benefits and overhead for Federal staff. For example, it was used in 

an August 2000 document supporting ICR No. 1139.06 (EPA, 2000), with the following explanation:

The annual costs per FTE are derived by multiplying the annual pay rate by 1.6 (the benefits 

multiplication factor). The multiplication factor used is recommended in EPA’s Office of Policy, 

Planning, and Evaluation’s Instructions for Preparing Information Collection Requests (ICRs) (June 1, 

1992). An EPA internal phone call between Carol Rawie (OPPT/EETD/RIB) and Carl Koch 

(OPPE/RMD/IMB) on May 3, 1994, indicated that the 1.6 factor included not only benefits but also 

overhead. (ICR No.1139.06)

 

19 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007), which covers PMN SNURs. Use of this grade level 

follows the approach introduced in EPAB, 2007a. That report represented a change from the earlier PMN SNUR economic 

analysis (EPA, 2003), which used an average of GS-12 Step 1 and GS-12 Step 10 salaries.
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Toxics

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Table 15: Derivation of Loaded Wage Rates

EPAB Labor 

Category Data Sources Date Wage Fringe 

Benefit

Fringes as 

% Wage

Overhead % 

Wage2

Fringe + 

Overhead 

Factor

Loaded Wages1

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

Managerial

BLS ECEC, Private Manufacturing 

industries, “Mgt, Business, and 

Financial”3

Dec-11 $43.01 $20.40 47.43% 17% 1.64 $70.72

Professional/

Technical

BLS ECEC, Private Manufacturing 

industries, “Professional and 

related“3

Dec-11 $38.48 $19.64 51.04% 17% 1.68 $64.66

Clerical

BLS ECEC, Private Manufacturing 

industries, “Office and 

Administrative Support” 3

Dec-11 $17.69 $8.93 50.48% 17% 1.67 $29.63

EPA staff 

FTE

Annual Federal staff cost: OPM 

Washington-Baltimore-Northern 

Virginia, DC-MD-PA-VA-WV, area, 

GS-13 Step 5 pay rates, with 60% 

overhead. 3

Jan-11 $48.51 --

[Included in 

60% 

overhead]

60% 1.6 $77.62

Notes:

1Wage data are rounded to the closest penny in this table; however, in calculations using these numbers for this report, unrounded values were used.

2An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b), and the Revised Economic 

Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a).

3 The salary is unloaded Federal GS-13 Step 5 salary for calendar 2011, from the Office of Personnel Management salary table for Washington-Baltimore-Northern Virginia (OPM, 

2011). The 60% fringes-and-overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (EPA, 1992, page 30, footnote 9).
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A.2 Derivation of Inflation Factors

Detailed information on the derivation of the inflation factors used is presented in Table 16. In 2006, the 

Bureau of Labor Statistics (BLS) made several changes to the Employment Cost Index. The changes are 

described on a BLS web page, “Change has come to the ECI,” (BLS, 2006c) and in several April 2006 

Monthly Labor Review articles posted on the BLS web site: “Changes affecting the Employment Cost 

Index: an overview” (Caroll, 2006); “Employment Cost Index Publication Plans” (Sleemi, 2006); and 

“Seasonal adjustment in the ECI and the conversion to NAICS and SOC” (Branch, 2006).

Under a mandate from OMB, BLS changed its classification of industries and occupations from the 

Standard Industrial Classification (SIC) and Occupational Classification System (OCS) to the North 

American Industry Classification System (NAICS) and Standard Occupational Classification (SOC) 

system. In 2006, BLS adjusted all ECI series to reflect this change. 

In addition to changing the industry and occupational classification systems, in 2006, BLS rebased the 

ECI from June 1989 = 100 to December 2005 = 100 for all current and historical non-seasonally adjusted 

series, including the NAICS and SIC based series. (Seasonally adjusted indices, including those in Table 

16 of this report, may not exactly equal 100 for December 2005 as a result of the seasonal adjustment. 

Seasonal adjustments are explained in Branch, 2006.) 

According to BLS, the official ECI for the years 1975-2005 is the SIC-OCS based series, and for 

subsequent years, the official ECI is the NAICS-SOC based series (Sleemi, 2006, p.8).20

“Starting year” indices in Table 16 continue to be SIC-OCS based. Current year indices are NAICS-SOC 

based. We use indices from both the NAICS-SOC and the SIC-OCS based ECI series because neither 

series spans the entire period over which testing and other costs need to be inflated. 

 

20 BLS has been publishing the NAICS-SOC based ECI series since March 2001 and it became official in March 2006. The SICOCS based series and NAICS-SOC series have different series ID numbers, even when they describe essentially the same 

population. For example the series ID for seasonally adjusted total compensation for all private industry workers is 

ECS10002I for the SIC-OCS series and CIS2010000000000I for the NAICS-SOC series. 

Deleted: Table 16

Deleted: Table 16

Deleted: Table 16
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Table 16: Derivation of Inflation Factors

Item Inflation Index Source1 Starting 

Year

Index for 

Starting Year 

(a)

Index for 

2011

(b)

Inflation 

Factor 

(b)/(a)2

Agency Extramural costs 

White collar labor; 

equipment; supplies

BLS ECI, Total comp, Private 

industry, Professional and 

related, 4th Q [BLS, 2012b]3

1993 67 115.7 1.727

Labels, placards etc. BLS CPI, All urban consumers, 

not SA. CUUR0000SA0, Annual 

[BLS, 2012c]

1997 160.5 224.939 1.401

File cabinet

Photocopies BLS CPI, All urban consumers, 

not SA. CUUR0000SA0, Annual 

[BLS, 2012c]

Record keeping materials 1988 118.3 224.939 1.901

Key: BLS = Bureau of Labor Statistics. CPI = Consumer Price Index. ECI = Employment Cost Index. SA = Seasonally Adjusted. Total 

Comp = Total Compensation (wages/salaries and benefits). 4th Q = Fourth Quarter. “ECS10002I” etc. refer to BLS series Ids. 

Notes:

1 In 2006, Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) series “were rebased to December 2005 = 100 from June 

1989 = 100.” The change is reflected in the indices in this table and explained on the BLS website, Employment Cost Index News 

Release Text: Employment Cost Index, March 2006 (BLS, 2006b). The Consumer Price Index (CPI) was not rebased. 

“Starting year” ECI indices are SIC-OCS based: Seasonally Adjusted (SA) ECS10002I for private industry All Workers, and not SA 

ECU11122I for private industry Professional and Related Workers. 

After 2006, ECI indices are NAICS-SOC based: Seasonally Adjusted (SA) CIS2010000000000I for private industry All Workers, and 

not SA CIU2010000120000I (B) for private industry Professional, and Related workers. 

2

Inflation factors are rounded; however, unrounded values were used in calculations.

3 Beginning with the report Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: EPA Docket 

OPPT-2009-0922 (EPA, 2011b) we began to use the not-seasonally adjusted CIU2010000120000I for private industry Professional, 

and Related workers, instead of SA CIS2010000W00000I for private industry white collar workers because BLS retired the “whitecollar” series.