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Supporting Statement for a Request for OMB Review under

the Paperwork Reduction Act

1. IDENTIFICATION OF THE INFORMATION COLLECTION

l(a) Title of the Information Collection

TITLE: Formaldehyde Emissions From Composite Wood Products, Thirdparty Certification Framework, Recordkeeping and Reporting –

Proposed Rule (RIN 2070-AJ44)

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

1(b) Short Characterization

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

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

hardwood plywood, particleboard and medium-density fiberboard and directs EPA to promulgate 

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

to promulgate implementing regulations related to a third-party certification system for 

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

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

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

entitled “Third-Party Certification Framework for the Formaldehyde Standards for Composite 

Wood Products Rule.” Additional information collection requests, such as those related to 

disclosure requirements for panel producers and product labeling requirements, will be covered 

later in a separate ICR. 

Some examples of proposed reporting and third-party reporting requirements include:

• Product accreditation bodies that wish to participate in the program must submit an 

application to become recognized by EPA. 

• Laboratory accreditation bodies that wish to participate in the program must submit an 

application to become recognized by EPA.

• Third-party certifiers that wish to participate in the program must submit an application 

for accreditation to a recognized product accreditation body and a recognized laboratory 

accreditation body.

• Recognized product accreditation bodies must submit an annual report to EPA on their 

accreditation activities. 

• Recognized laboratories accreditation bodies must submit an annual report to EPA on 

their accreditation activities. 

• TSCA Title VI accredited third-party certifiers must submit an annual report to their 

accreditation body or bodies (product accreditation body and laboratory accreditation 

body, if not the same entity) and to EPA on their TSCA Title VI accreditation activities. 
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Examples of proposed recordkeeping requirements would include:

• Recognized accreditation bodies must retain checklists and other records documenting 

compliance with the requirements for systems audits and on-site assessments of thirdparty certifiers for 3 years. 

• A TSCA Title VI accredited third-party certifier must retain a list of panel producers and 

their respective product types, including resins used, that it has certified. 

• A TSCA Title VI accredited third-party certifier must retain records on the results of 

inspections, audits, and emission tests conducted for and linked to each panel producer 

and product type. 

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

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

• A TSCA Title VI accredited third-party certifier must retain records on the methods and 

results for establishing test method correlations and equivalence.

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

Administrators, the Office of Enforcement and Compliance Assurance (OECA), and/or the 

Office of Chemical Safety and Pollution Prevention (OCSPP), as appropriate. Some of the 

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

information (CBI) submitted to EPA will be maintained by the Agency pursuant to TSCA § 14 

and 40 CFR Part 2. 

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

The reporting and recordkeeping requirements of this consolidated ICR are implemented 

under the authority of TSCA Title VI. TSCA Title VI directs EPA to promulgate regulations, 

including provisions relating to “third-party testing and certification” in “a manner that ensures 

compliance with the emission standards.” To meet its statutory obligations, EPA must obtain 

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

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

are carrying out their responsibilities diligently, impartially, and uniformly. The proposed 

regulations aim to ensure consistent application of the requirements of TSCA Title VI by using 

voluntary consensus standards as requirements, and by leveraging the expertise of international 

accreditation bodies.

High quality third-party certifiers are essential in ensuring that domestic and foreign 

composite wood panel producers supplying products to the U.S. have adequate quality assurance 

and quality control procedures, are adequately testing their products to determine that they are 

compliant, and are otherwise acting in manner that is consistent with the requirements of TSCA 

Title VI. The reporting and record maintenance requirements in this ICR would help ensure that 

all program participants remain qualified and are held accountable for their activities, and would 

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

composite wood products. 
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2(b) Use of the Data

EPA would use the information collected to evaluate the credentials of entities that wish 

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

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

VI accreditation and certification services. 

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non-Duplication 

TSCA Title VI assigns the responsibility for promulgating regulations that ensure 

compliance with the statutorily established emission standards for formaldehyde from composite 

wood products to the EPA Administrator. The information collection requirements addressed in 

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

respondents to report or maintain information on their accreditation or certification activities 

related to formaldehyde emissions from composite wood products. 

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

certification systems. However, because the third-party certification framework is necessarily 

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

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

evaluate their credentials, monitor their compliance with the program, determine the number of 

panel producers receiving certification services, and evaluate a panel producer’s compliance 

history. 

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

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

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

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

3(c) Consultations

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

Agency has consulted with the regulated community and the public. These consultations have 

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

regulated facilities. EPA has also consulted with the California Air Resources Board (CARB), 

which operates a similar third-party certification program for formaldehyde standards for 

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

Since EPA began its regulatory investigation into formaldehyde emissions from pressed 

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

EPA has met on numerous occasions with the composite wood panel and related industries. 

These meetings have been in the form of presentations at trade shows and industry association 
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conferences, and meetings with the Composite Panel Association (CPA), the Hardwood Plywood 

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

American Home Furnishings Alliance (AHFA), the Business and Institutional Furniture 

Manufacturer’s Association (BIFMA), and individual companies. EPA staff have, at the 

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

EPA convened a Small Business Advocacy Review Panel and hosted two panel outreach 

meetings with small entity representatives (SERs). Prior to each meeting, EPA distributed 

outreach materials to the SERs, and after each meeting the SERs were asked to provide written 

feedback on how EPA might reduce regulatory burden on small entities. The Panel received 

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

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

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

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

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

EPA intends to carry out further consultations and outreach with potentially regulated 

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

Supporting Statement as needed. 

3(d) Effects of Less Frequent Collection

EPA has judged that the reporting and recordkeeping requirements of the ICR are the 

minimum amount necessary to fulfill its statutory mandate to promulgate regulations on a thirdparty certification program that ensure compliance with the emission standards. Although the 

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

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

Likewise it cannot delegate its oversight duties to accreditation bodies. The reports and records 

in this ICR would allow EPA carry out its statutorily delegated roles in program design, 

enforcement, and oversight. EPA believes that requiring applications, annual reports, and certain 

one-time notifications from the accreditation bodies and third-party certifiers that wish to be 

recognized or accredited as program participants would allow EPA to effectively monitor the 

program. Annual reports and notifications that are triggered by specific occurrences will allow 

EPA to ensure compliance with the emission standards, as required by the statute. EPA believes 

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

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

distributed in commerce. 

3(e) General Guidelines

This information collection complies with the guidelines at 5 CFR 1320.5(d)(2). The 

exceptions to OMB’s Paperwork Reduction Act Guidelines, and the explanation of why such 

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

There are a number of provisions that would require reporting within a certain number of 

days of an occurrence of a specific event. For example, notice that an accredited third-party 
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certifier has failed to comply with any provision of this section must be provided to EPA within 

24 hours of the time the failure is identified. These reporting requirements are not triggered by 

the calendar (i.e., they are not required quarterly or at more frequent intervals). Therefore, the 

Agency does not believe that these provisions need special justification. Moreover, EPA believes 

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

change in circumstances could result in uncertified products being distributed in commerce, in 

violation of the statute. 

3(f) Confidentiality

EPA handles claims of confidentiality pursuant to established CBI procedures, as found at

Section 14 of TSCA and 40 CFR Part 2, and the Agency’s TSCA CBI Manual. CBI is also 

protected under the Freedom of Information Act (5 USC Section 525). 

Most of the information requested in the reporting requirements of these collections is not 

of a confidential nature.

3(g) Sensitive Questions

EPA asks no questions of a sensitive nature.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/NAICS Codes 

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

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

Third-party certifiers are independent entities that review products, processes or services 

to verify that a set of norms, criteria, claims, practices or standards are being met. In this case 

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

regulations and would require conformity with specified voluntary consensus standards. 

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

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

are themselves evaluated by their own international oversight bodies to ensure their compliance 

with voluntary consensus standards.

The following NAICS codes are relevant: 

• Engineering services (NAICS code 541330).

• Testing laboratories (NAICS code 541380).

• Administrative management and general management consulting services (NAICS code 

541611).

• All other professional, scientific, and technical services (NAICS code 541990).
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• All other support services (NAICS code 561990).

• Business associations (NAICS code 813910).

• Professional organizations (NAICS code 813920).

4(b) Information Requested

(i) Data Items

The information collection requirements are triggered when an entity desires to 

participate in the program either as an accrediting body or a third-party certifier. Entities that 

wish to participate in the program and offer services related to TSCA Title VI accreditation or 

certification must submit an application. Accreditation bodies would apply to be recognized 

through a recognition agreement with EPA. Third-party certifiers would then apply to an EPArecognized accreditation body to become TSCA Title VI accredited. 

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

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

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

would cease, and the record keeping requirements would lapse at the end of the record retention 

period. 

The proposed recordkeeping requirements and reporting requirements include:

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

accomplish the following reporting tasks: 

• Product accreditation bodies that wish to participate in the program must submit an 

application to become recognized by EPA via a recognition agreement. The application 

must include: 1) The name, address, telephone number, and email address of a primary 

contact; 2) Documentation of its International Accreditation Forum Inc., Multilateral 

Recognition Arrangement signatory status, or equivalent; 3) If not a domestic entity, the 

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

description of any other qualifications related to its experience in performing product 

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

required for applicants include ongoing conformance with International Organization for 

Standardization and International Electrotechnical Commission (ISO/IEC) 17011 

(including associated recordkeeping and reporting requirements) and demonstrating basic 

competence to perform accreditation activities for product certification according to 

ISO/IEC Guide 65.

 

• Laboratory accreditation bodies that wish to participate in the program must submit an 

application to become recognized by EPA via a recognition agreement. The application 

would include: 1) The name, address, telephone number, and email address of primary 

contact; 2) Documentation of International Laboratory Accreditation Cooperation Mutual 

Recognition Arrangement signatory status, or equivalent; 3) If not a domestic entity, the 

name and address of an agent for service located in the United States; and 4) a description 
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of any other qualifications related to the laboratory accreditation body’s experience in 

performing laboratory accreditation and inspection certification of conformity assessment 

bodies or third-party certifiers. Qualifications required for applicants include ongoing 

conformance with ISO/IEC 17011 (including associated record keeping and reporting 

requirements) and a demonstration of basic competence to perform accreditation 

activities for laboratory accreditation according to ISO/IEC 17025.

• Recognized product accreditation bodies would be required to submit an annual report to 

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

of systems audits and on-site assessments performed, and the results of accredited thirdparty certifier laboratory proficiency testing or inter-laboratory comparisons.

• Recognized laboratory accreditation bodies would be required to submit an annual report 

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

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

accredited third-party certifier laboratory proficiency testing or inter-laboratory 

comparisons.

• Recognized product accreditation bodies would be required to forward copies of thirdparty certifiers’ applications to EPA at the address identified in the recognition agreement

within 90 days of the date of receipt. 

• Recognized product accreditation bodies would be required to submit notice if it loses its 

status as a signatory to the International Accreditation Forum Inc. Multilateral 

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

business days of the date that the body receives notice of the loss of its signatory status. 

• Recognized laboratory accreditation bodies would be required to submit notice if it loses 

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

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

business days of the date that the body receives notice of the loss of its signatory status. 

• Recognized accreditation bodies would be required to submit notice when it accredits a 

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

accredited.

• Recognized accreditation bodies would be required to submit notice that an accredited 

third-party certifier has failed to comply with any provision of the regulation within 24 

hours of the time the accreditation body identifies the failure.

• A recognized accreditation body would be required to submit notice when it suspends or 

revokes a third-party certifier’s accreditation within 24 hours of the time that the 

suspension or revocation takes effect. 

• A recognized accreditation body would be required to submit notice of a decision to 

make changes in its organizational policies or management structure that could adversely 
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affect the third-party certifier accreditation program within 30 days of the decision to 

make the changes. 

• Recognized accreditation bodies would be required to provide checklists and other 

records documenting compliance with the requirements for systems audits and on-site 

assessments of third-party certifiers to EPA within 30 days of request. The records must 

be retained for 3 years. 

• TSCA Title VI accredited third-party certifiers would be required to supply the following 

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

and their respective product types, including resins used; 2) The results of inspections, 

audits, and emission tests conducted for and linked to each panel producer and product 

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

conditioning time and test results; and 4) The methods and results for establishing test 

method correlations and equivalence. These records must be maintained for 3 years. 

• If a third-party certifier approves an application for reduced testing, it must notify and 

forward copies of the application for reduced testing to EPA within 30 days. 

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

other than EPA as follows:

• Recognized product accreditation bodies would be required to provide a unique tracking 

number (i.e., third-party certified number) to every third-party-certifier it accredits. 

• Recognized laboratory accreditation bodies would be required, within 15 days of a 

request by a third-party certifier or their EPA-recognized product accreditation body, to 

forward copies of a third-party certifier’s laboratory application and accreditation 

documentation to the applicable EPA-recognized product accreditation body (if the 

laboratory accreditation body is not also recognized as a product accreditation body) at 

the address identified by the third-party certifier. 

• Third-party certifiers that wish to participate in the program must submit an application 

for accreditation to a recognized laboratory accreditation body and then to a recognized 

product accreditation body. The product accreditation body and laboratory accreditation 

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

concurrently. The application to the product accreditation would be required to include: 

1) The name, address, telephone number, and email address of primary contact; 2) If not 

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

States; 3) The type of composite wood products that the applicant intends to certify if 

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

experience or ability in product certification and complying with ISO/IEC Guide 65 

(including associated record keeping requirements); experience in the composite wood 

product industry with the specific product(s) the applicant intends to certify, and ability to 

inspect and properly train and supervise inspectors pursuant to ISO/IEC 17020 (including 

associated record keeping requirements). The application to the laboratory accreditation 
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would be required to include: 1) The name, address, telephone number, and email address 

of primary contact; 2) If not a domestic entity, the name and address of an agent for 

service located in the United States; 3) A description of the third-party certifier 

laboratory’s qualifications (including contract laboratories), including experience in 

performing or verifying formaldehyde testing on composite wood products, experience 

complying with ISO/IEC 17025 (including associated record keeping requirements), and 

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

correlation between test methods. 

• TSCA Title VI accredited third-party certifiers must provide their third-party certifier 

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

• TSCA Title VI accredited third-party certifiers must submit an annual report to their 

accreditation body or bodies (product accreditation body and laboratory accreditation 

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

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

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

range of formaldehyde emissions by panel producer, resin, and product type; 2) A list of 

any noncomplying products or events by a panel producer; 3) A list of laboratories and 

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

proficiency testing for the laboratories used by the certifier.

• TSCA Title VI accredited third-party certifiers would be required to inform their 

accreditation body or bodies (product accreditation body and laboratory accreditation 

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

procedures, or laboratories used by the certifier.

• Should a TSCA Title VI accredited third-party certifier withdraw from the program or 

lose its accreditation, it would be required to notify all panel producers that receive its 

TSCA Title VI accreditation services within 3 business days. 

• Should a recognized accreditation body be removed or withdraw from the program it 

must notify all third-party certifiers that receive its accreditation services within 5 

business days. 

• Third-party certifiers that receive applications from panel producers for reduced testing 

must act on those applications within 90 days. 

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

• Recognized accreditation bodies must retain checklists and other records documenting 

compliance with the requirements for systems audits and on-site assessments of thirdparty certifiers for 3 years. 

• A TSCA Title VI accredited third-party certifier must retain a list of panel producers that 

it has certified and their respective product types, including resins used, for 3 years. 
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• TSCA Title VI accredited third-party certifiers must retain records on the results of 

inspections, audits, and emission tests conducted for and linked to each panel producer 

and product type for 3 years. 

• A TSCA Title VI accredited third-party certifier must retain a list of laboratories that it 

uses, test methods, including test conditions and conditioning time and test results for 3 

years. 

• TSCA Title VI accredited third-party certifiers must retain records on the methods and 

results for establishing test method correlations and equivalence for 3 years. 

(ii) Respondent Activities

Typical respondents include accreditation bodies and third-party certifiers that wish to 

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

the rule and determine which provisions would be applicable to their operations; plan and modify 

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

process, compile, and review information for accuracy and appropriateness; and record, disclose, 

and/or report the required information. 

5. THE INFORMATION COLLECTION — AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

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

and recording data, maintaining files of submitted data, auditing and inspecting facilities, 

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

interpretations and developing rulemakings. EPA plans to publish certain information on the 

internet, including a list of accredited third-party certifiers and recognized accreditation bodies. 

EPA plans to continue/expand its review of the use of the Internet to facilitate the transfer of 

information from EPA to the public. More specific Agency activities are as follows: 

• Receive and evaluate applications from accreditation bodies that wish to 

participate in the program.

• Develop and enter into recognition agreements with qualified accreditation 

bodies.

• Supply a point of contact for each recognition agreement for accreditation bodies 

to consult with on implementation of the recognition agreement.

• Maintain a current and publically available list of recognized accreditation bodies 

and accredited third-party certifiers. 
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• Evaluate the annual reports from recognized accreditation bodies and TSCA Title 

VI accredited third-party certifiers. 

• Evaluate all notices received from accreditation bodies and third-party certifiers to 

determine whether further agency action is warranted. 

5(b) Collection Methodology and Management

The current proposal does not provide a required format for reports and notices. 

However, EPA is considering an electronic reporting requirement. If EPA finalizes a mandatory 

electronic reporting requirement all reports and notices covered by this action would be required 

to be submitted via that internet through EPA’s Central Data Exchange (CDX). The required use 

of CDX for submission of TSCA Title VI notices and reports would be consistent with the 

Government Paperwork Elimination Act (GPEA, Pub. L. 105-277), which requires that, when 

practicable, federal organizations use electronic forms, electronic filings, and electronic 

signatures to conduct official business with the public. EPA’s Cross-Media Electronic Reporting 

Regulation (CROMERR) (October 13, 2005; 70 FR 59848; FRL-7977-1) provides that any 

requirement in Title 40 of the Code of Federal Regulations to submit a report directly to EPA can 

be satisfied with an electronic submission that meets certain conditions once the Agency 

publishes a notice that electronic document submission is available for that requirement.

To register in CDX, the CDX registrant (also referred to as “Electronic Signature Holder” 

or “Public/Private Key Holder”) would download two forms: the Electronic Signature 

Agreement and the Verification of Company Authorizing Official form. Registration enables 

CDX to perform two important functions: authentication of identity and verification of 

authorization. Within the “Electronic Signature Agreement” form, the Authorized Official (AO) 

would agree to certain CDX security conditions. On the “Verification of Company Authorizing 

Official” form, the AO would designate himself/herself as the AO and attest to the completeness 

and accuracy of the submitted information. When these forms are received, EPA would activate 

the submitter's registration in CDX and sends him or her an e-mail notification. 

Most of the information requested in the reporting requirements of these collections is not 

of a confidential nature. Nonetheless, the any electronic reporting application would be designed 

to support TSCA Confidential Business Information needs by providing a secure environment 

that meets Federal standards. Users would be able to claim CBI for appropriate data fields. The 

electronic reporting application would use Transportation Layer Security (TLS) with 256-bit 

digital encryption, and the data would be encrypted at rest using a key that only a user knows. 

All data would remain encrypted until it is behind several EPA firewalls and within the EPA CBI 

LAN, and all encryption modules would be Federal Information Processing Standard (FIPS) 

140-2 compliant. Also, users would be required to have valid CDX credentials (user name and 

password combination) to access the application, and they would be required to know the 

answers to the 20-5-1 series of questions associated with a CDX account in order to submit data 

to the EPA.
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While EPA is not currently proposing an electronic reporting requirement, EPA believes 

the adoption of electronic communications may reduce the reporting burden on industry by 

reducing both the cost and the time required to review, edit and transmit data to the Agency. All 

information sent via CDX would be transmitted securely to protect CBI. Furthermore, if 

anything in the submission has been claimed CBI, a sanitized copy of the notice must be 

provided by the submitter. With electronic reporting, this could be done automatically during the 

submission process, eliminating the need for the submitter to do this manually. Electronic 

reporting would also allow submitters to share a draft notice within their company during the 

creation of a notice and to save a copy of the final file for future use. Appendix B provides mock 

ups illustrating a potential electronic reporting system for TSCA Title VI submissions.

The Agency would also benefit from receiving electronic submissions. Data systems

would be populated electronically, as oppose to manual data entry, reducing the potential for 

human error that exists when data are entered by hand. Agency personnel would also be able to 

communicate more efficiently with submitters electronically, compared to using mail.

5(c) Small Entity Flexibility

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

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

third-party certification program, regardless of size. EPA has elected to require equal disclosure 

by all participating accreditation bodies and third-party certifiers because the third-party 

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

of TSCA Title VI.

5(d) Collection Schedule

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

rather than by specific dates, as shown on Table 5-1.
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Table 5-1: Collection Requirements and Schedule

Ref. # Collection Requirement Collection Schedule 

1 Application to EPA from a product accreditation body When product accreditation 

body wishes to participate in 

the program and every 3 years 

thereafter for as long as it 

wishes to continue to 

participate 

2 Application to EPA from a laboratory accreditation body When laboratory accreditation 

body wishes to participate in 

the program and every 3 years 

thereafter for as long as it 

wishes to continue to 

participate

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

recognition agreement was 

signed 

4 Annual report to EPA from a laboratory accreditation 

body

Annually, on the month its 

recognition agreement was 

signed 

5 Copies of third-party certifiers’ applications forwarded 

from a recognized product accreditation body to EPA 

Within 90 days of receipt of 

those applications 

6 A recognized product accreditation bodies must submit 

notice if it loses its status as a signatory to the 

International Accreditation Forum Inc., Multilateral 

Recognition Arrangement (or membership in an 

equivalent organization)

Within 5 business days of 

being informed of loss of 

status 

7 A recognized laboratory accreditation bodies must submit 

notice if it loses its status as a signatory to the 

International Laboratory Accreditation Cooperation

Mutual Recognition Arrangement (or membership in an 

equivalent organization)

Within 5 business days of 

being informed of loss of 

status

8 A recognized accreditation body must submit notice when 

it accredits a third-party certifier 

Within 5 business days of the 

date that the certifier is 

accredited

9 A recognized accreditation body must submit notice that a 

TSCA Title VI accredited third-party certifier has failed 

to comply with any provision of the regulation

Within 24 hours of the time 

the accreditation body 

identifies the failure 

10 A recognized accreditation body must submit notice when 

it suspends or revokes a third-party certifier’s 

accreditation

Within 24 hours of the time 

that the suspension or 

revocation takes effect 
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Table 5-1: Collection Requirements and Schedule

Ref. # Collection Requirement Collection Schedule 

11 A recognized accreditation body must submit notice of a 

decision to make changes in its organizational policies or

management structure that could adversely affect the 

third-party certifier accreditation program

Within 30 days of the decision 

to make the changes

12 A recognized accreditation body must provide checklists 

and other records documenting compliance with the 

requirements for systems audits and on-site assessments 

of third-party certifiers to EPA 

Within 30 days of a request by 

EPA

13 A recognized product accreditation body must provide a 

unique tracking number to every third-party-certifier it 

accredits

At the time the third-party 

certifier receives its 

accreditation 

14 An accredited third-party certifier must supply the 

following records to EPA: 1) A list of panel producers 

and their respective product types, including resins used, 

that it has certified; 2) The results of inspections, audits, 

and emission tests conducted for and linked to each panel 

producer and product type; 3) A list of laboratories it 

uses, test methods, including test conditions and 

conditioning time and test results; and 4) The methods 

and results for establishing test method correlations and 

equivalence

Within 30 days of request by 

EPA

15 A recognized laboratory accreditation body must forward 

copies of a third-party certifier’s laboratory application 

and accreditation documentation to the applicable EPArecognized product accreditation body (if the product 

accreditation body is not also recognized as a laboratory 

accreditation body ) at the address identified by the thirdparty certifier

Within 15 days of a request by 

a third-party certifier or its 

EPA-recognized product 

accreditation body

16 A third-party certifier that wishes to participate in the 

program must submit an application for accreditation to a 

recognized laboratory accreditation body and then to a 

recognized product accreditation body 

When it desires to become 

accredited to perform TSCA 

Title VI certification services, 

and every three years 

thereafter for as long as it 

desires to continue providing 

TSCA Title VI certification 

services 

17 A TSCA Title VI accredited third-party certifier would be 

required to provide its third-party certifier number to any 

panel producer receiving its TSCA Title VI certification 

services 

When a panel producer begins 

receiving its services 

18 A TSCA Title VI accredited third-party certifier must 

submit an annual report to its accreditation body or bodies 

(product accreditation body and laboratory accreditation 

Annual, on anniversary of 

accreditation 
Page 15 of 105

Table 5-1: Collection Requirements and Schedule

Ref. # Collection Requirement Collection Schedule 

body, if not the same entity) and to EPA on its TSCA 

Title VI certification activities

19 A TSCA Title VI accredited third-party certifier must 

inform its accreditation body or bodies (product 

accreditation body and laboratory accreditation body) of 

any changes in the personnel qualifications, procedures, 

or laboratories used by the certifier

Within 30 days

20 Should a TSCA Title VI accredited third-party certifier 

withdraw from the program or lose its accreditation, it 

would be required to notify all panel producers that 

receive its TSCA Title VI accreditation services

Within 3 business days

21 Should a recognized accreditation body be removed or 

withdraw from the program it must notify all third-party 

certifiers that receive its accreditation services

Within 5 business days

22 Notify EPA of approval of an application for reduced 

testing forward copies of all approved applications for 

reduced testing to EPA 

Notification with 5 days of 

approval, 

Forward copy of application 

within 30 days of receipt 

23 Third-party certifiers must act on applications for reduced 

testing 

Within 90 days of receipt of a 

complete application

6. ESTIMATING BURDEN AND COST OF THE COLLECTION

This section estimates the incremental burden of the recordkeeping and reporting 

requirements for accreditation bodies (ABs) and third-party certifiers (TPCs) that wish to 

participate in the TSCA Title VI third-party certification program for composite wood products. 

The current proposal does not provide a required format for reports and notices, so the 

estimates in this section assume that reporting is done on paper. Since EPA is considering an 

electronic reporting requirement, Appendix A describes the incremental changes in burden and 

cost if EPA finalizes a mandatory electronic reporting requirement.

6(a) Estimating Respondent Burden

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

following information collection components of the third party certification framework:

 Accreditation Bodies:

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

o Application Submission: Submitting an application to enter into a recognition 

agreement with EPA;
Page 16 of 105

o Prepare a Recognition Agreement: If the application is approved, enter into a 

recognition agreement with EPA;

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

loss of signatory status; TPC application; TPC accreditation; TPC compliance 

failure; organization policy or management structure changes that could adversely 

affect accreditation program; and provide checklists and other records 

documenting compliance with systems audits and on-site assessments;

o TPC Notification: Provide TPCs with notifications if they withdraw or are 

removed from the program;

o Recordkeeping: Maintain records documenting TPC accreditation applications, 

and checklists and other records documenting compliance with systems audits and 

on-site assessments. Applications must be retained for 3 years from the date they 

were submitted; and

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

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

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

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

inter-laboratory comparisons.

 Third Party Certifiers: 

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

o Application Submission: submitting an application to the accrediting body;

o Obtain Accreditation: initially obtain accreditation (i.e., to demonstrate 

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

96 and experience correlating between test methods);

o Manufacturer Notifications and Recordkeeping: the annual cost of 

manufacturer notification and of maintaining records; and

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

other notifications to the accrediting body.

(i) Number of Respondents

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

signatories to the International Accreditation Forum, Inc. (IAF) or the International Laboratory 

Accreditation Cooperation (ILAC). Of the 8 domestic accrediting bodies, 4 were determined to 

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

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

TPCs. Based on the small business determinations for domestic accrediting bodies, it is 

estimated that 9 of the foreign accrediting bodies are small entities.

As shown in Exhibit 6-1, CARB has approved a total of 36 TPCs, 9 of which are located 

in the U.S. (although most U.S. TPCs provide services internationally). Of the 9 U.S. firms, 2

are classified as “small” based on the U.S. Small Business Administration’s size standards, 2 are 

classified as large, and the small business status could not be determined for the 5 remaining 

firms. Thus, it is estimated that half of all TPCs (both foreign and domestic) are small entities. 

It is assumed that there will be 9 domestic TPCs and 27 foreign TPCs in the TSCA Title VI 

program, the same as in the CARB program.
Page 17 of 105

Exhibit 6-1: Summary of CARB-Approved Third Party Certifiers

Country Where TPC is Located Number of TPCs

Australia 1

Austria 1

Belgium 1

China 5

Czech Republic 1

Denmark 1

France 1

Germany 4

Hong Kong 3

Indonesia 1

Italy 3

New Zealand 1

Poland 1

Spain 1

Sweden 1

Taiwan 1

United States 9

 Total 36

Source: California Air Resources Board. 2011. List of CARB Approved Third Party 

Certifiers.

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

Exhibit 6-2: Summary of Respondents

Respondent Type

Total 

Number of 

Respondents

Total Number

of Small 

Respondents

Domestic Accrediting Bodies 8 4

Foreign Accrediting Bodies 17 9

Domestic Third Party Certifiers 9 5

Foreign Third Party Certifiers 27 14

(ii) Burden Per Respondent

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

reporting burdens for accreditation bodies and third party certifiers, respectively. Exhibit 6-5

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

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

and for those that need to obtain an additional accreditation. The latter group will pay fees to an 

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

detail there. The recordkeeping and reporting requirements do not differ between TPCs that 

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

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

consistently.

Exhibit A-1 and Exhibit A-2 in Appendix A present the incremental changes in burden if 

EPA finalizes a mandatory electronic reporting requirement.
Page 18 of 105

Exhibit 6-3: Recordkeeping and Reporting Burden for Accreditation Bodies, by Activity

Activity1

Per Activity Burden Hours Number of 

Annual 

Activities

(d)

Total Burden 

(hours)

(e) = 

(d)*{(a)+(b)+(c)}

Clerical

(a) 

Technical

(b)

Managerial

(c) 

1. Rule Familiarization 0.00 5.00 5.00 1.00 10.0000

2. Application Submission 

Company Information (Name, Address, Telephone Number, and Email Address 

of Primary Contact)2 0.00 0.04 0.02 1.00 0.0600

Documentation of IAF MLA, ILAC MRA, or Equivalent Signatory Status2 0.00 0.04 0.02 1.00 0.0600

Description of Any Other Qualifications Related to Experience in Performing 

Accreditation of Conformity Assessment Bodies or Third Party Certifiers3 0.00 0.83 0.51 1.00 1.3400

3. Recognition agreement4 1.00 1.00 4.00 1.00 6.0000

4. EPA Notification

Loss of Status as a Signatory to the IAF MLA, ILAC MRA, or Equivalent 

Organization5 0.00 0.08 0.04 0.05 0.0060

Third Party Certifier Applications5 0.00 0.08 0.04 3.00 0.3600

Third Party Certifier Accreditation5 0.00 0.08 0.04 3.00 0.3600

Third Party Certifier Compliance Failure5 0.00 0.08 0.04 0.33 0.0396

Third Party Certifier Accreditation Suspension or Revocation (Product ABs) / 

Accredited Laboratory Compliance Failure (Laboratory ABs)5 0.00 0.08 0.04 0.33 0.0396

Change to Organizational Policy or Management Structure that Could Adversely 

Affect Accreditation Program5 0.00 0.08 0.04 0.20 0.0240

Checklists and Other Records Documenting Compliance with the Requirements 

for Systems Audits and On-site Assessment of Third Party Certifiers5 0.00 0.08 0.04 1.00 0.1200

Change in Name or Address of Domestic Agent (Foreign Entities Only)

5 0.00 0.08 0.04 0.50 0.0600

5. Third Party Certifier Notification

Unique Tracking Number2 0.00 0.04 0.02 3.00 0.1800

Withdraw from or be Removed from Program2 0.00 0.04 0.02 0.25 0.0150

6. Recordkeeping

Accreditation Applications6 0.75 1.50 0.75 1.00 3.0000

Checklists and Other Records Documenting Compliance with the Requirements 

for Systems Audits and On-site Assessment of Third Party Certifiers6 0.75 1.50 0.75 1.00 3.0000

7. Annual Report to EPA

Number of Third Party Certifier Applications Received7 0.25 0.50 0.25 1.00 1.0000

Number of Third Party Certifier Applications Approved and Denied7 0.25 0.50 0.25 1.00 1.0000

The Names and Contact Information of All Accredited Third Party Certifiers7 0.25 0.50 0.25 1.00 1.0000

Number and Locations of Systems Audits and On-site Assessments7 0.25 0.50 0.25 1.00 1.0000

Results of Accredited Third Party Certifier Laboratory Proficiency Testing or 

Inter-laboratory Comparisons7 0.25 0.50 0.25 1.00 1.0000
Page 19 of 105

Exhibit 6-3: Recordkeeping and Reporting Burden for Accreditation Bodies, by Activity

Activity1

Per Activity Burden Hours Number of 

Annual 

Activities

(d)

Total Burden 

(hours)

(e) = 

(d)*{(a)+(b)+(c)}

Clerical

(a) 

Technical

(b)

Managerial

(c) 

Domestic Total in First Year 29.6042

Foreign Total in First Year 29.6642

Domestic Total in Non-Reapplication Year (Year 2) 12.1442

Foreign Total in Non-Reapplications Year (Year 2) 12.2042

Domestic Total in Reapplication Year (Year 3) 19.6042

Foreign Total in Reapplication Year (Year 3) 19.6642

Notes: 1. Under the proposed rule, accreditation bodies are required to submit an application to renew their recognition agreement every 3 years. As a result, this analysis assumes that accreditation 

bodies incur application submission and recognition agreement preparation costs in the first year and subsequently every 3 years thereafter.

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

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

4. Based on conversations with accreditation bodies.

5. Based on the estimated burden associated with reporting "company information" (EPA 2011). Values have been doubled based on best professional judgment.

6. Based on the estimated burden associated with "recordkeeping" (EPA 2011). The rule requires that records be kept for 3 years that show the production volume, plant site, and site-limited status of 

each reported substance.

7. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011). Estimate based on best professional judgment.

Source: U.S. Environmental Protection Agency. 2011. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule Addendum to 

Partial Update of the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.
Page 20 of 105

Exhibit 6-4: Recordkeeping and Reporting Burden for Third Party Certifiers, by Activity

Activity1

Per Activity Burden Hours Number of 

Annual 

Activities

(d)

Total Burden 

(hours)

(e) = 

(d)*{(a)+(b)+(c)}

Clerical 

(a)

Technical 

(b)

Managerial 

(c)

1. Rule Familiarization 0.00 5.00 5.00 1.00 10.00

2. Product Accreditation Body Application Submission 

Company Information (Name, Address, Telephone Number, and Email Address 

of Primary Contact) and Type of Composite Wood Products Applicant Intends 

to Certify2

0.00 0.04 0.02 1.00 0.06

Description of TPC's Experience or Ability in Product Certification and 

Complying with ISO/IEC Guide 653 0.00 0.83 0.51 1.00 1.34

Description of TPC's Experience in the Composite Wood Product Industry with 

the Product(s) Intended to be Certified3 0.00 0.83 0.51 1.00 1.34

Description of TPC's Ability to Inspect and Properly Train and Supervise 

Inspectors Pursuant to ISO/IEC 170203 0.00 0.83 0.51 1.00 1.34

3. Laboratory Accreditation Body Application Submission

Company Information (Name, Address, Telephone Number, and Email Address 

of Primary Contact; if foreign, name and address of an agent for service located 

in the U.S.)2

0.00 0.04 0.02 1.00 0.06

Description of TPC's Experience in Performing or Verifying Formaldehyde 

Testing on Composite Wood Products3 0.00 0.83 0.51 1.00 1.34

Description of TPC's Experience Operating or Using Laboratories that Comply 

with ISO/IEC 170253 0.00 0.83 0.51 1.00 1.34

Description of TPC's Experience with Test Method ASTM E-1333-96 (2002) 

and Experience Evaluating Correlation between Test Methods3 0.00 0.83 0.51 1.00 1.34

4. Manufacturer Notification

Third Party Certifier Number2 0.00 0.04 0.02 1.00 0.06

Withdraw from Program or Lose Accreditation2 0.00 0.04 0.02 0.25 0.015

5. Recordkeeping

List of Manufacturers and their Product Types (including Resins Used) Certified 

by TPC4 0.75 1.50 0.75 1.00 3.00

Results of Inspections, Audits, and Emission Tests Conducted for Each 

Manufacturer and Product Type4 0.75 1.50 0.75 1.00 3.00

List of the TPC's Laboratories, Test Methods (including Test Conditions and 

Conditioning Time), and Test Results4 0.75 1.50 0.75 1.00 3.00

Methods and Results for Establishing Test Method Correlations and 

Equivalence4 0.75 1.50 0.75 1.00 3.00

List of Manufacturers and Products Approved for Reduced Testing4 0.75 1.50 0.75 1.00 3.00

6. Annual Report to Accreditation Bodies

List of Manufacturers and their Products Certified by the TPC during the 

Previous Year (including Resins Used, and the Average and Range of 0.25 0.50 0.25 1.00 1.00
Page 21 of 105

Exhibit 6-4: Recordkeeping and Reporting Burden for Third Party Certifiers, by Activity

Activity1

Per Activity Burden Hours Number of 

Annual 

Activities

(d)

Total Burden 

(hours)

(e) = 

(d)*{(a)+(b)+(c)}

Clerical 

(a)

Technical 

(b)

Managerial 

(c)

Formaldehyde Emissions by Manufacturer, Resin, and Product Type)5

List of Noncomplying Products or Events by Manufacturer5 0.25 0.50 0.25 1.00 1.00

List of Laboratories and Test Methods Used by the TPC5 0.25 0.50 0.25 1.00 1.00

Results of Inter-Laboratory Comparison or Proficiency Testing for the 

Laboratories Used by the TPC4 0.25 0.50 0.25 1.00 1.00

7. Accreditation Board Notification

Personnel Qualification Changes2 0.00 0.04 0.02 0.50 0.03

Procedure Changes2 0.00 0.04 0.02 0.50 0.03

Laboratory Changes2 0.00 0.04 0.02 0.50 0.03

8. EPA Notification

Change in Name or Address of Domestic Agent (Foreign TPCs Only)

2 0.00 0.04 0.02 0.50 0.03

Domestic Total in First Year 37.325

Foreign Total in First Year 37.355

Domestic Total in Non-Reapplication Year (Years 2 and 3) 19.165

Foreign Total in Non-Reapplications Year (Years 2 and 3) 19.195

Domestic Total in Reapplication Year (Year 4) 27.325

Foreign Total in Reapplication Year (Year 4) 27.355

Notes: 1. Under the proposed rule, TPCs are required to apply for re-accreditation every three years. As a result, application and accreditation costs are incurred every third year.

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

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

4. Based on the estimated burden associated with "recordkeeping" (EPA 2011). The rule requires that records be kept for 3 years that show the production volume, plant site, and site-limited 

status of each reported substance.

5. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011). Estimate based on best professional judgment.

Source: U.S. Environmental Protection Agency. 2011. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule 

Addendum to Partial Update of the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.
Page 22 of 105

6(b) Estimating Respondent Costs

Respondent costs are estimated by combining burden estimates from the previous section 

with loaded wage rates, and adding in materials costs. 

(i) Wage Rates

The fully loaded unit labor cost for managerial, professional/technical, and clerical labor 

in the regulated industry and for EPA staff is estimated by adding fringe benefits and overhead 

costs to the hourly wage or annual salary for each category following the method described in 

Wage Rates for Economic Analysis of the Toxics Release Inventory Program. This section 

describes the method employed to estimate the fully loaded unit labor costs for each labor 

category and presents the results of the analysis.

Exhibit 6-5: Total Burden by Firm Type

Firm Type Number of 

Firms

Burden Per Firm

(hours)

Total Burden

(hours)

Year 1

Domestic Accrediting Body 8 29.6042 237

Foreign Accrediting Body 17 29.6642 504

Domestic TPC obtaining one additional accreditation 3 37.3250 112

Domestic TPC with current accreditations 6 37.3250 224

Foreign TPC obtaining one additional accreditation 9 37.3550 336

Foreign TPC with current accreditations 18 37.3550 672

Year 2

Domestic Accrediting Body 8 12.1442 97

Foreign Accrediting Body 17 12.2042 207

Domestic TPC obtaining one additional accreditation 3 19.1650 57

Domestic TPC with current accreditations 6 19.1650 115

Foreign TPC obtaining one additional accreditation 9 19.1950 173

Foreign TPC with current accreditations 18 19.1950 346

Year 3

Domestic Accrediting Body 8 19.6042 157

Foreign Accrediting Body 17 19.6642 334

Domestic TPC obtaining one additional accreditation 3 19.165 57

Domestic TPC with current accreditations 6 19.165 115

Foreign TPC obtaining one additional accreditation 9 19.195 173

Foreign TPC with current accreditations 18 19.195 346

Three Year Average

Domestic Accrediting Body 8 20.4509 164

Foreign Accrediting Body 17 20.5109 349

Domestic TPC obtaining one additional accreditation 3 25.2183 76

Domestic TPC with current accreditations 6 25.2183 151

Foreign TPC obtaining one additional accreditation 9 25.2483 227

Foreign TPC with current accreditations 18 25.2483 454

All Entities 61 23.2951 1,421
Page 23 of 105

Labor categories used in the analysis correspond to the U.S. Bureau of Labor Statistics 

(BLS) Standard Occupational Classification (SOC) system. In March 2004, BLS began using the 

North American Industry Classification System (NAICS) instead of the Standard Industrial 

Classification (SIC) System, and the Standard Occupational Classification (SOC) system instead 

of the Occupational Classification System (OCS). Exhibit 6-6 summarizes the crosswalk 

between old and new occupational titles, and lists the SOC titles that correspond to the 

managerial, professional/technical, and clerical labor categories used in this analysis.

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

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

Managerial Executive, administrative, and 

managerial Management, business, and financial

Professional/Technical Professional specialty and technical Professional and related

Clerical Administrative support, including 

clerical Office and administrative support

Wages and fringe benefit data for managerial, professional/technical, and clerical labor 

are from the BLS Employer Costs for Employee Compensation (ECEC) historical data for 

December 2006 – March 2011.

1

The costs of fringe benefits such as paid leave and insurance, specific to each labor 

category, are taken from the same BLS report. Fringe benefits as a percentage of wages are 

calculated separately for each labor category. For example, for December 2010, the average 

wage rate for professional/technical labor was $36.57, and the average fringe benefit was 

$13.52.2 Therefore, fringe benefits as a percentage of wages were $13.52/$36.57, or 

approximately 37 percent (see Exhibit 6-7).

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

This approach is used for consistency with Office of Pollution Prevention and Toxics (OPPT) 

economic analyses for two major rulemakings: Wage Rates for Economic Analyses of the Toxics 

Release Inventory Program, June 2002, and the Revised Economic Analysis for the Amended 

Inventory Update Rule: Final Report. This overhead loading factor is added to the benefits 

loading factor, and the total is then applied to the base wage to derive the fully loaded wage. For 

example, the December 2010 fully loaded wage for professional/technical labor is $36.57 × (1+ 

0.37 + 0.17) = $56.31. 

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

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

historical data were the best alternative. In a phone conversation (February 11, 2009), a BLS employee could not 

identify a better data set to use.

2 Past analyses have used the term “technical” labor. Here the category is called “professional/technical” labor, to 

make clear how it relates to BLS categories. In 2004, BLS changed from the Occupational Classification System, 

OCS, to the Standard Occupational Classification system, SOC. In the process, the “Professional specialty and 

technical” category became the “Professional and related” category. However, the coverage of the old and new 

occupational groups is approximately the same. See the BLS article, “Comparing Current and Former Industry and 

Occupation ECEC Series” (Weinstein and Loewenstein, 2004).
Page 24 of 105

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

shown in Exhibit 6-7.

Exhibit 6-7: Derivation of Loaded Industry Wage Rates

Labor 

Category

Data Source for Wage 

Information Date

Wage Fringe 

Benefit

Fringes as 

% wage

Overhead as 

% wage a

Fringe + 

overhead factor

Loaded 

Wages

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

(a)*(e)

Clerical 

BLS ECEC, Private 

Professional and Business 

Services Industries, “Office 

and Administrative Support”b

Dec-10 $16.72 $6.09 36.42% 17% 1.53 $25.65

Professional/

Technical

BLS ECEC, Private 

Professional and Business 

Services Industries, 

“Professional and related“b

Dec-10 $36.57 $13.52 36.97% 17% 1.54 $56.31

Managerial 

BLS ECEC, Private 

Professional and Business 

Services Industries, “Mgt, 

Business, and Financial”b

Dec-10 $42.42 $17.15 40.43% 17% 1.57 $66.78

Notes:

a An overhead rate of 17% is used.

b Data for this occupational series found in U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Compensation: 

Supplementary Tables: Historical Data: December 2006 - March 2011.

(ii) Costs Per Respondent

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

and Exhibit 6-9. These labor costs were estimated by multiplying the respondent burdens in 

Exhibit 6-3 and Exhibit 6-4 by the loaded wage rates presented in Exhibit 6-7. In addition to 

these labor costs, some TPCs will incur non-labor costs associated with obtaining accreditation. 

The accreditation costs of TPCs will depend on whether they have the systems and equipment in 

place to satisfy the accreditation requirements or whether they will have to establish these. 

Based on telephone interviews, the cost of obtaining a single accreditation initially is about 

$20,000 to $30,000 for each quality system. This analysis uses the mid-point of the range, 

$25,000, as the cost estimate. The cost would be about three times that if the firm needed to be 

newly accredited for all three standards (Guide 65, 17020, and 17025). Based on discussions 

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

have accreditations in place and that one-third will need to obtain one additional accreditation. 

As a result, this analysis assumes that one-third of TPCs will incur a cost of $25,000 to obtain 

one additional accreditation, while two-thirds of TPCs will not incur any additional costs 

associated with obtaining and maintaining additional accreditations.

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

systems and testing certifications. Two respondents reported costs that ranged from $5,000 to 

$15,000 per year associated with maintaining certification, such as paying audit fees to their AB 

(typical accreditation lasts two years). Note that the systems and testing certifications for which 

the laboratories reported costs may cover more than the specific formaldehyde testing, and 

therefore these estimates may overstate costs if these labs would incur these costs even if they 

were not acting as TPCs under TSCA Title VI. However, to be conservative and not 

underestimate costs, it is assumed that laboratories do not incur these costs in the baseline. 
Page 25 of 105

Because the audits include tests other than formaldehyde, the analysis uses the low end of the 

costs reported as the annual reaccreditation cost, $5,000. As discussed above, based on 

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

will already be maintaining these accreditations and that one-third will be maintaining one 

additional accreditation. Thus, one-third of TPCs will incur a cost of $5,000 from maintaining 

an additional accreditation, while two-thirds of TPCs will not incur any additional costs 

associated with obtaining and maintaining additional accreditations. 

Exhibit A-1 and Exhibit A-2 in Appendix A present the incremental changes in cost if 

EPA finalizes a mandatory electronic reporting requirement.
Page 26 of 105

Exhibit 6-8: Recordkeeping and Reporting Labor Costs for Accreditation Bodies, by Activity (2010$)

Activity Estimated Annual 

Frequency1 Clerical Cost2 Technical Cost2 Managerial Cost2 Total Cost

1. Rule Familiarization 1 $0.00 $281.55 $333.90 $615 

2. Application Submission 

Company Information (Name, Address, Telephone Number, and Email 

Address of Primary Contact)3 1 $0.00 $2.25 $1.34 $3.59 

Documentation of IAF MLA, ILAC MRA, or Equivalent Signatory 

Status3 1 $0.00 $2.25 $1.34 $3.59 

Description of Any Other Qualifications Related to Experience in 

Performing Accreditation of Conformity Assessment Bodies or Third 

Party Certifiers4

1 $0.00 $46.74 $34.06 $80.80 

Application Submission Subtotal $88

3. Recognition agreement5 1 $25.65 $56.31 $267.12 $349 

4. EPA Notification

Loss of Status as a Signatory to the IAF MLA, ILAC MRA, or 

Equivalent Organization6 0.05 $0.00 $0.23 $0.13 $0.36 

Third Party Certifier Application6 3 $0.00 $13.51 $8.01 $21.53 

Third Party Certifier Accreditation6 3 $0.00 $13.51 $8.01 $21.53 

Third Party Certifier Compliance Failure6

0.33 $0.00 $1.49 $0.88 $2.37 

Third Party Certifier Accreditation Suspension or Revocation (Product 

ABs) / Accredited Laboratory Compliance Failure (Laboratory ABs)6 0.33 $0.00 $1.49 $0.88 $2.37 

Change to Organizational Policy or Management Structure that Could 

Adversely Affect Accreditation Program6 0.2 $0.00 $0.90 $0.53 $1.44 

Checklists and Other Records Documenting Compliance with the 

Requirements for Systems Audits and On-site Assessment of Third Party 

Certifiers6

1 $0.00 $4.50 $2.67 $7.18 

Change in Name or Address of Domestic Agent (Foreign Entities Only)

6 0.5 $0.00 $2.25 $1.34 $3.59 

EPA Notification Subtotal (Domestic) $57

EPA Notification Subtotal (Foreign) $60

5. Third Party Certifier Notification

Unique Tracking Number3 3 $0.00 $6.76 $4.01 $10.76 

Withdraw from or be Removed from Program3 0.25 $0.00 $0.56 $0.33 $0.90 

TPC Notification Subtotal $12

6. Recordkeeping

Accreditation Applications7 1 $19.24 $84.47 $50.09 $153.79 

Checklists and Other Records Documenting Compliance with the 

Requirements for Systems Audits and On-site Assessment of Third Party 

Certifiers7

1 $19.24 $84.47 $50.09 $153.79 

Recordkeeping Subtotal $308

7. Annual Report to EPA

Number of Third Party Certifier Applications Received8 1 $6.41 $28.16 $16.70 $51.26 
Page 27 of 105

Exhibit 6-8: Recordkeeping and Reporting Labor Costs for Accreditation Bodies, by Activity (2010$)

Activity Estimated Annual 

Frequency1 Clerical Cost2 Technical Cost2 Managerial Cost2 Total Cost

Number of Third Party Certifier Applications Approved and Denied8 1 $6.41 $28.16 $16.70 $51.26 

The Names and Contact Information of All Accredited Third Party 

Certifiers8 1 $6.41 $28.16 $16.70 $51.26 

Number and Locations of Systems Audits and On-site Assessments8 1 $6.41 $28.16 $16.70 $51.26 

Results of Accredited Third Party Certifier Laboratory Proficiency 

Testing or Inter-laboratory Comparisons8 1 $6.41 $28.16 $16.70 $51.26 

Annual Report Subtotal $256

Domestic Total in First Year $1,685 

Foreign Total in First Year $1,688 

Domestic Total in Non-Reapplication Year (Year 2) $633 

Foreign Total in Non-Reapplications Year (Year 2) $636 

Domestic Total in Reapplication Year (Year 3) $1,070 

Foreign Total in Reapplication Year (Year 3) $1,073 

Notes: 1. Based on best professional judgment and rule requirements. Under the proposed rule, accreditation bodies are required to submit an application to renew their recognition agreement every 3 

years. As a result, this analysis assumes that accreditation bodies incur application submission and recognition agreement preparation costs in the first year and subsequently every 3 years thereafter.

2. Based on Employer Costs for Employee Compensation wage and benefit data for private professional and business services industries (BLS 2011a). Clerical costs are estimated using data from the 

"office and administrative support" occupational group; technical costs are estimated using data from the "professional and related" occupational group; and managerial costs are estimated using data 

from the "management, business, and financial" occupational group.

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

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

5. Based on conversations with accreditation bodies.

6. Based on the estimated burden associated with reporting "company information" (EPA 2011a). Values have been doubled based on best professional judgment.

7. Based on the estimated burden associated with "recordkeeping" (EPA 2011a). The rule requires that records be kept for 3 years that show the production volume, plant site, and site-limited status of 

each reported substance.

8. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011a). Estimate based on best professional judgment.

Sources: (1) U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: Historical Data: December 2006 - March 2011, and (2) 

U.S. Environmental Protection Agency. 2011. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule Addendum to Partial 

Update of the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.
Page 28 of 105

Exhibit 6-9: Recordkeeping and Reporting Labor Costs for Third Party Certifiers, by Activity (2010$)

Activity Estimated Annual 

Frequency1 Clerical Cost2 Technical Cost2 Managerial Cost2 Total Cost

1. Rule Familiarization 1.00 $0.00 $281.55 $333.90 $615 

2. Product Accreditation Body Application Submission 

Company Information (Name, Address, Telephone Number, and 

Email Address of Primary Contact; if foreign, name and address 

of an agent for service located in the U.S.) and Type of 

Composite Wood Products Applicant Intends to Certify3

1.00 $0.00 $2.25 $1.34 $3.59 

Description of TPC's Experience or Ability in Product 

Certification and Complying with ISO/IEC Guide 654 1.00 $0.00 $46.74 $34.06 $80.80 

Description of TPC's Experience in the Composite Wood 

Product Industry with the Product(s) Intended to be Certified4 1.00 $0.00 $46.74 $34.06 $80.80 

Description of TPC's Ability to Inspect and Properly Train and 

Supervise Inspectors Pursuant to ISO/IEC 170204 1.00 $0.00 $46.74 $34.06 $80.80 

Product Accreditation Subtotal $246

3. Laboratory Accreditation Body Application Submission

Company Information (Name, Address, Telephone Number, and 

Email Address of Primary Contact; if foreign, name and address 

of an agent for service located in the U.S.)3

1.00 $0.00 $2.25 $1.34 $3.59 

Description of TPC's Experience in Performing or Verifying 

Formaldehyde Testing on Composite Wood Products4 1.00 $0.00 $46.74 $34.06 $80.80 

Description of TPC's Experience Operating or Using 

Laboratories that Comply with ISO/IEC 170254 1.00 $0.00 $46.74 $34.06 $80.80 

Description of TPC's Experience with Test Method ASTM E1333-96 (2002) and Experience Evaluating Correlation between 

Test Methods4

1.00 $0.00 $46.74 $34.06 $80.80 

Laboratory Accreditation Subtotal $246

4. Manufacturer Notification

Third Party Certifier Number3 1.00 $0.00 $2.25 $1.34 $3.59 

Withdraw from Program or Lose Accreditation3 0.25 $0.00 $0.56 $0.33 $0.90 

Manufacturer Notification Subtotal $4

5. Recordkeeping

List of Manufacturers and their Product Types (including Resins 

Used) Certified by TPC5 1.00 $19.24 $84.47 $50.09 $153.79 

Results of Inspections, Audits, and Emission Tests Conducted 

for Each Manufacturer and Product Type5 1.00 $19.24 $84.47 $50.09 $153.79 

List of the TPC's Laboratories, Test Methods (including Test 

Conditions and Conditioning Time), and Test Results5 1.00 $19.24 $84.47 $50.09 $153.79 

Methods and Results for Establishing Test Method Correlations 

and Equivalence5 1.00 $19.24 $84.47 $50.09 $153.79 

List of Manufacturers and Products Approved for Reduced 1.00 $19.24 $84.47 $50.09 $153.79 
Page 29 of 105

Exhibit 6-9: Recordkeeping and Reporting Labor Costs for Third Party Certifiers, by Activity (2010$)

Activity Estimated Annual 

Frequency1 Clerical Cost2 Technical Cost2 Managerial Cost2 Total Cost

Testing5

Recordkeeping Subtotal $769

6. Annual Report to Accreditation Bodies

List of Manufacturers and their Products Certified by the TPC 

during the Previous Year (including Resins Used, and the 

Average and Range of Formaldehyde Emissions by 

Manufacturer, Resin, and Product Type)6

1.00 $6.41 $28.16 $16.70 $51.26 

List of Noncomplying Products or Events by Manufacturer6 1.00 $6.41 $28.16 $16.70 $51.26 

List of Laboratories and Test Methods Used by the TPC6 1.00 $6.41 $28.16 $16.70 $51.26 

Results of Inter-Laboratory Comparison or Proficiency Testing 

for the Laboratories Used by the TPC6 1.00 $6.41 $28.16 $16.70 $51.26 

Annual Report to AB Subtotal $205

7. Accreditation Board Notification

Personnel Qualification Changes3 0.50 $0.00 $1.13 $0.67 $1.79 

Procedure Changes3 0.50 $0.00 $1.13 $0.67 $1.79 

Laboratory Changes3 0.50 $0.00 $1.13 $0.67 $1.79 

Accreditation Board Notification Subtotal $5

8. EPA Notification

Change in Name or Address of Domestic Agent (Foreign 

TPCs Only)

3 0.50 $0.00 $1.13 $0.67 $2

Domestic Total in First Year $2,090 

Foreign Total in First Year $2,092 

Domestic Total in Non-Reapplication Year (Years 2 and 3) $983 

Foreign Total in Non-Reapplications Year (Years 2 and 3) $985 

Domestic Total in Reapplication Year (Year 4) $1,475 

Foreign Total in Reapplication Year (Year 4) $1,477 

Notes: 1. Based on best professional judgment and rule requirements. Under the proposed rule, TPCs are required to apply for re-accreditation every three years. As a result, application and 

accreditation costs are incurred every third year.

2. Based on Employer Costs for Employee Compensation wage and benefit data for private professional and business services industries (BLS 2011a). Clerical costs are estimated using data from the 

"office and administrative support" occupational group; technical costs are estimated using data from the "professional and related" occupational group; and managerial costs are estimated using data

from the "management, business, and financial" occupational group.

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

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

5. Based on the estimated burden associated with "recordkeeping" (EPA 2011a). The rule requires that records be kept for 3 years that show the production volume, plant site, and site-limited status of 

each reported substance.

6. Estimated as one-third of the burden associated with "recordkeeping" (EPA 2011a). Estimate based on best professional judgment.

Sources: (1) U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: Historical Data: December 2006 - March 2011, and (2) 

U.S. Environmental Protection Agency. 2011. Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act: the Final Rule Addendum to Partial 

Update of the TSCA Section 8(b) TSCA Inventory Data Base, Production and Site Reports.
Page 30 of 105

(iii) Total Burden and Costs

Exhibit 6-10 presents a summary of the total burden and costs for this information 

collection request by the type of firm. The total burden and cost are calculated by multiplying 

the burdens and costs per firm by the number of affected firms.

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

Firm Type Number 

of Firms

Per Firm Burden and Cost Total Burden and Cost

Labor NonLabor 

Cost

Labor NonLabor 

Cost Hours Cost Hours Cost

Year 1

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

Foreign Accrediting Body 17 29.6642 $1,688 504 $28,696 

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

Domestic TPC with current accreditations 6 37.3250 $2,090 224 $12,540 

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

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

Year 2

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

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

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

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

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

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

Year 3

Domestic Accrediting Body 8 19.6042 $1,070 157 $8,560 

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

Domestic TPC obtaining one additional accreditation 3 19.165 $983 $5,000 57 $2,949 $15,000 

Domestic TPC with current accreditations 6 19.165 $983 115 $5,898 

Foreign TPC obtaining one additional accreditation 9 19.195 $985 $5,000 173 $8,865 $45,000 

Foreign TPC with current accreditations 18 19.195 $985 346 $17,730 

Three Year Average

Domestic Accrediting Body 8 20.4509 $1,129.33 164 $9,035 

Foreign Accrediting Body 17 20.5109 $1,132.33 349 $19,250 

Domestic TPC obtaining one additional accreditation 3 25.2183 $1,352.00 $11,667 76 $4,056 $35,000 

Domestic TPC with current accreditations 6 25.2183 $1,352.00 151 $8,112 

Foreign TPC obtaining one additional accreditation 9 25.2483 $1,354.00 $11,667 227 $12,186 $105,000 

Foreign TPC with current accreditations 18 25.2483 $1,354.00 454 $24,372 

All Entities 61 23.2945 $1,262.46 $2,295.08 1421 $77,010 $140,000 
Page 31 of 105

6(c) Estimating Agency Burden and Cost

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

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

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

regulatory interpretations. EPA anticipates that these activities will require the equivalent of one 

full-time employee (FTE) at Headquarters. Using the 2010 Washington/Baltimore area annual 

salary rate for a GS-13, Step 5 employee ($100,904), and multiplying by a loading factor of 1.6 

to reflect overhead and fringe benefits results in an estimated EPA cost of $161,446 per year. 

Section A.2 in Appendix A discusses the incremental changes in EPA cost if EPA 

finalizes a mandatory electronic reporting requirement.

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

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

Exhibit 6-11: Total Burden and Costs

Year 1 Year 2 Year 3 Average

Number of Respondents and

Responses 61 61 61 61

Total Burden Hours 2,085.64 995.38 1,181.88 1,421

Total Cost $417,470 $111,318 $122,243 $217,010 

EPA is considering an electronic reporting requirement for this information collection. 

Exhibit A-3 in Appendix A summarizes the incremental changes in bottom line burden and cost 

if EPA finalizes a mandatory electronic reporting requirement.

6(e) Reasons for Changes in Burden

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

6(f) Burden Statement

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

OMB Control No. xxxx-xxxx, is estimated to be 23.29 hours per response (i.e., 1,421 burden 

hours for an estimated 61 responses). According to the Paperwork Reduction Act, “burden” 

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

retain, or disclose or provide information to or for a Federal agency. For this collection it 

includes such activities as annual familiarization with requirements, recordkeeping, notification, 

and reporting requirements. An agency may not conduct or sponsor, and a person is not required 

to respond to, a collection of information unless it displays a currently valid OMB control 

number. The OMB control numbers for EPA’s regulations in title 40 of the CFR, after appearing 
Page 32 of 105

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

instrument or form, if applicable.

To comment on the Agency’s need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID No. EPA-HQ-OPPT-2011-0380. The docket is available for public viewing at the 

Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). The EPA/DC 

Public Reading Room is located in the EPA West Building, Room 3334, 1301 Constitution Ave., 

NW., Washington, DC. The EPA/DC Public Reading Room is open from 8:30 a.m. to 4:30 p.m., 

Monday through Friday, excluding legal holidays. The telephone number for the EPA/DC 

Public Reading Room is (202) 566-1744, and the telephone number for the Pollution Prevention 

and Toxics Docket is (202) 566-0280. An electronic version of the public docket is available 

through the Federal Docket Management System (FDMS) at www.regulations.gov. Use FDMS 

to submit or view public comments, access the index listing of the contents of the public docket, 

and to access those documents in the public docket that are available electronically. Once in the 

system, select “search,” then key in the docket ID number identified above. Also, you can send 

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please 

include the EPA Docket ID No. EPA-HQ-OPPT-2011-0380 and OMB control number 2070-

NEW in any correspondence.
Page 33 of 105

Appendix A – Incremental Impacts of Mandatory Electronic Reporting

EPA is considering requiring mandatory electronic reporting requirement for 

accreditation bodies and TPCs (both referred to here as respondents). If EPA adopts this 

requirement for the TPC rule, respondents would submit their notifications and reports to EPA 

using the Central Data Exchange (CDX). The changes in burden and costs for respondents and 

EPA are described below.

A.1 Burden and Costs of Electronic Reporting for Accreditation Bodies and TPCs

All respondents spend time in the first year to complete a subscriber agreement and 

register with CDX. Some respondents will spend time in subsequent years due to employee 

turnover or compromised electronic signatures. These burdens are offset by reductions in 

reporting and recordkeeping burden due to electronic reporting.

CDX users are assigned to one of two roles in the CDX system, an Authorizing Official 

or a Support Registrant.

Authorized Official (AO): The AO is the person legally responsible for the submission. The 

AO is typically a senior official for the respondent. The AO is the only user who can start a new 

form, or reopen a completed form to begin the amendment process, and is the only user who can 

electronically sign and submit a form. AOs can also assign Support Registrants to edit and 

complete forms on his or her behalf. AOs must submit a subscriber agreement to EPA, and 

register with CDX.

Support Registrants: A Support Registrant is a person designated by an AO to submit 

supporting documents on his or her behalf. Support Registrants can edit a submission that is 

created by the AO. Support Registrants are only allowed to edit submissions that the AO has 

granted him or her access. Support Registrants do not have any access rights to create or submit 

a form. Once the AO creates a form, they will provide the Support Registrant with a passphrase 

to access the submission and complete all sections of the form. Once the Support Registrant has 

finished completing the form, the AO will access the submission, review it, and submit it. 

Support Registrants must register with CDX, but do not need to submit a subscriber agreement to 

EPA.

This analysis uses a simplifying assumption that an average of five employees at each 

respondent will register with CDX: one manager (who will serve as AO) four technical staff 

members (who will serve as Support Registrants). 

First Year Burden for Accreditation Bodies and TPCs 

Respondents will incur electronic reporting costs in the first year to submit a subscriber 

agreement, register with CDX, and contact EPA’s CDX Help Desk.

Subscriber Agreement. An AO must complete a subscriber agreement in order to establish 

their identity and their relation to the entity for which they will submit electronic documents, as 
Page 34 of 105

well as to document a unique correlation with the device that will be used create their electronic 

signature. Users can comply with the subscriber agreement provisions in CDX either by 

submitting a paper subscriber agreement with a wet-ink signature, or by submitting an electronic 

signature agreement.

• Paper subscriber agreement. Preparing, submitting, and filing a paper subscriber agreement 

is estimated to require an average of 20 minutes of time per registrant (EPA 2011), which is 

assumed to be managerial time. 

• Electronic signature agreement. Preparing, submitting, and filing an electronic signature 

agreement is estimated to require an average of 15 minutes of time per registrant (EPA 

2011), which is assumed to be managerial time. 

CDX Registration. CDX users will need to register with CDX, which involves selecting a user 

name and password, providing contact information, and identifying the facility and the 

registrant’s role at the facility. This is estimated to take an average of 10 minutes per user (EPA 

2011). This results in an estimate that each respondent will spend 10 minutes of managerial time 

and 40 minutes of technical time to register with CDX. 

Help Desk. CDX users are assumed to spend an average of 4 minutes contacting EPA’s CDX 

Help Desk for technical support (EPA 2011), which results in an estimate of 4 minutes of 

managerial time and 16 minutes of technical time per respondent. 

Problem Resolution. Three percent of respondents each year are assumed to spend an average 

of one hour of technical time working with EPA’s CDX Help Desk to resolve problems 

involving their registrations or agreements (EPA 2011).

Subsequent Year Burden for Accreditation Bodies and TPCs

In subsequent years, respondents may incur electronic reporting costs due to employee 

turnover and compromised electronic signatures.

Employee Turnover. It is assumed that each year 10 percent of CDX users will be replaced by 

new employees, who will have to comply with the subscriber agreement and/or CDX registration 

requirements (EPA 2011). Thus, in subsequent years 10 percent of AOs will spend 15 to 20 

minutes of managerial time to complete a subscriber agreement. In addition, 10 percent of all 

users (both managerial and technical) will spend 10 minutes to register with CDX and 4 minutes 

contacting EPA’s CDX Help Desk.

Report Compromised Signature. Each year 1 percent of respondents are assumed to report a 

compromised or surrendered electronic signature, which requires the submittal of a new 

subscriber agreement (EPA 2011). This will entail 15 to 20 minutes of managerial time to 

prepare, submit, and file a new agreement, and 4 minutes of managerial time to contact EPA’s 

CDX Help Desk.
Page 35 of 105

Savings for Accreditation Bodies and TPCs

Electronic reporting is assumed to reduce the recordkeeping burden by 50 percent, and to 

eliminate the use of clerical time for reporting and recordkeeping (EPA 2009). For ABs, this is 

estimated to result in average savings of 3.75 hours of clerical time in the first year and 2.75 

hours in subsequent years, as well as 1 hour of technical time and 0.5 hours of managerial time in 

all years. For TPCs, this is estimated to result in average savings of 4.75 hours of clerical time, 

2.5 hours of technical time, and 1.25 hours of managerial time per year.

Electronic reporting also results in savings for respondents due to the following:

• The number of forms that need to be resubmitted because they are incomplete or invalid 

should be greatly reduced because forms cannot be submitted via CDX if any required fields 

are incomplete, or if the submission fails internal validation checks;

• All of the respondent’s relevant staff will be able to access the CDX forms easily and directly 

input their information, so the system will facilitate easier internal review by the respondent 

prior to submission;

• Filling out a form similar to one previously submitted will be faster with electronic reporting, 

as the respondent will already have an electronic copy of the earlier form to edit rather than 

having to fill out a new form; and

• All routine correspondence with the Agency (including submission of supporting documents) 

will be via CDX, which saves time and delivery costs and reduces delays in EPA’s review.

EPA has not estimated the value of these additional savings to respondents. 

Changes in Burden and Costs to Accreditation Bodies and TPCs due to Electronic Reporting 

As shown in Exhibit A-1, accreditation bodies would save 3.8 to 5.1 hours per year 

(equivalent to $99 to $177) depending on whether it is the initial year, reapplication year, or nonreapplication year. TPCs would save 7.0 to 8.4 hours per year (equivalent to $259 to $337) 

depending on whether it is the initial year, a reapplication year, or non-reapplication year, as 

shown in Exhibit A-2. 

As shown in Exhibit A-3, electronic reporting via CDX would reduce the total average 

burden of the rule to domestic and foreign respondents from 1,421 hours to 1,029 hours per year 

(a decrease of 392 hours). This decreases the cost of the rule from $217,010 to $203,334 per 

year, a savings of $14,666 per year. There are additional unquantified improvements in 

efficiency and higher data quality due to electronic reporting.
Page 36 of 105

Exhibit A-1: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Accrediting Body

Activity

Per Activity Burden Hours Number 

of 

Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr) Total

(a) (b) (c) (e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

1. CDX Electronic Reporting (First Year)

Electronic Subscriber Agreements 

(domestic firms) - - 0.250 1.00 0.250 - - $16.70 $16.70

Paper Subscriber Agreements 

(foreign firms) - - 0.330 1.00 0.330 - - $22.04 $22.04

CDX Registration - 0.670 0.170 1.00 0.840 - $37.73 $11.35 $49.08

Help Desk - 0.270 0.070 1.00 0.340 - $15.20 $4.67 $19.88

Problem Resolution - 1.000 - 0.03 0.030 - $1.69 - $1.69

Subtotal (domestic) 1.460 $87.00

Subtotal (foreign) 1.540 $93.00

2. CDX Electronic Reporting (Subsequent Years)

Electronic Subscriber Agreements 

(domestic firms) - - 0.250 0.10 0.025 - - $1.67 $1.67

Paper Subscriber Agreements 

(foreign firms) - - 0.330 0.10 0.033 - - $2.20 $2.20

CDX Registration - 0.670 0.170 0.10 0.084 - $3.77 $1.14 $4.91

Help Desk - 0.270 0.070 0.10 0.034 - $1.52 $0.47 $1.99

Report Compromised Signature 0.400 0.01 0.004 - - $0.27 $0.27

Subtotal (domestic) 0.147 $9.00

Subtotal (foreign) 0.155 $9.00

3. Recognition Agreement (1.000) - - 1.000 (1.000) $(25.65) - - ($26.00)

4. Recordkeeping

Accreditation Applications (0.750) (0.500) (0.250) 1.000 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)

Checklists and Other Records 

Documenting Compliance with the 

Requirements for Systems Audits 

and On-site Assessment of Third 

Party Certifiers

(0.750) (0.500) (0.250) 1.000 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)

Subtotal (3.000) ($128.00)

5. Annual Report to EPA

Number of Third Party Certifier 

Applications Received (0.250) - - 1.000 (0.250) $(6.41) - - $(6.41)

Number of Third Party Certifier 

Applications Approved and Denied (0.250) - - 1.000 (0.250) $(6.41) - - $(6.41)
Page 37 of 105

Exhibit A-1: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Accrediting Body

Activity

Per Activity Burden Hours Number 

of 

Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr) Total

(a) (b) (c) (e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

The Names and Contact 

Information of All Accredited Third 

Party Certifiers

(0.250) - - 1.000 (0.250) $(6.41) - - $(6.41)

Number and Locations of Systems 

Audits and On-site Assessments (0.250) - - 1.000 (0.250) $(6.41) - - $(6.41)

Results of Accredited Third Party 

Certifier Laboratory Proficiency 

Testing or Inter-laboratory 

Comparisons

(0.250) - - 1.000 (0.250) $(6.41) - - $(6.41)

Subtotal (1.250) $(32.00)

Domestic Total in First Year (3.790) ($99.00)

Foreign Total in First Year (3.710) ($93.00)

Domestic Total in Non-Reapplication 

Year (4.103) ($151.00)

Foreign Total in Non-Reapplications 

Year (4.095) ($151.00)

Domestic Total in Reapplication 

Year (5.103) ($177.00)

Foreign Total in Reapplications Year (5.095) ($177.00)
Page 38 of 105

Exhibit A-1: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Accrediting Body

Activity

Per Activity Burden Hours Number 

of 

Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Managerial Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr) Total

(a) (b) (c) (e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

Notes:

1. CDX Electronic Reporting (first year): 

• Electronic signature agreement. Preparing, submitting, and filing an electronic signature agreement is estimated to require an average of 15 minutes of time per respondent, 

which is assumed to be managerial time (EPA 2011). 

• Paper subscriber agreement. Preparing, submitting, and filing a paper subscriber agreement is estimated to require an average of 20 minutes of time per respondent, which is 

assumed to be managerial time (EPA 2011). 

• CDX Registration. CDX users will need to register with CDX, which involves selecting a user name and password, providing contact information, and identifying the 

facility and the registrant’s role at the facility. This is estimated to take an average of 10 minutes per user (EPA 2011). This results in an estimate that each respondent will 

spend 10 minutes of managerial time and 40 minutes of technical time to register with CDX. 

• Help Desk. CDX users are assumed to spend an average of 4 minutes contacting EPA’s CDX Help Desk for technical support (EPA 2011), which results in an estimate of 4 

minutes of managerial time and 16 minutes of technical time per respondent. 

• Problem Resolution. Three percent of respondents each year are assumed to spend an average of one hour of technical time working with EPA’s CDX Help Desk to resolve 

problems involving their registrations or agreements (EPA 2011).

2. CDX Electronic Reporting (subsequent years): 

• Employee Turnover. It is assumed that each year 10 percent of CDX users will be replaced by new employees, who will have to comply with the subscriber agreement 

and/or CDX registration requirements (EPA 2011). Thus, in subsequent years 10 percent of CDX users will spend 15 to 20 minutes of managerial time to complete a 

subscriber agreement. In addition, 10 percent of all CDX users (both managerial and technical) will spend 10 minutes to register with CDX and 4 minutes contacting EPA’s 

CDX Help Desk. 

• Report Compromised Signature. Each year 1 percent of respondents are assumed to report a compromised or surrendered electronic signature, which requires the submittal 

of a new subscriber agreement (EPA 2011). This will entail 15 to 20 minutes (20 assumed here) of managerial time to prepare, submit, and file a new agreement, and 4 

minutes of time to contact EPA’s CDX Help Desk.

3. Recognition Agreement 

• Electronic reporting is assumed to eliminate the use of clerical time for the recognition agreement.

4. Recordkeeping

• Electronic reporting is assumed to reduce the recordkeeping burden by 50 percent (EPA 2009). 

5. Annual Report to EPA

• Electronic reporting is assumed to reduce the recordkeeping burden by 50 percent (EPA 2009).

Sources: (1) U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: Historical Data: December 2006 - March 2011, 

(2) EPA 2011
Page 39 of 105

Exhibit A-2: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Third Party Certifier

Activity

Per Activity Burden Hours Number 

of Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Manageria

l

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr) Total

(a) (b) (c) (e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

1. CDX Electronic Reporting (First Year)

Electronic Subscriber 

Agreements (domestic firms) - - 0.250 1.00 0.250 - - $16.70 $16.70

Paper Subscriber Agreements 

(foreign firms) - - 0.330 1.00 0.330 - - $22.04 $22.04

CDX Registration - 0.670 0.170 1.00 0.840 - $37.73 $11.35 $49.08

Help Desk - 0.270 0.070 1.00 0.340 - $15.20 $4.67 $19.88

Problem Resolution - 1.000 - 0.03 0.030 - $1.69 $1.69

Subtotal (domestic) 1.460 $87.00

Subtotal (foreign) 1.540 $93.00

2. CDX Electronic Reporting (Subsequent Years)

Electronic Subscriber 

Agreements (domestic firms) - - 0.250 0.10 0.025 $0.00 $0.00 $1.67 $1.67

Paper Subscriber Agreements 

(foreign firms) - - 0.330 0.10 0.033 $0.00 $0.00 $2.20 $2.20

CDX Registration - 0.670 0.170 0.10 0.084 $0.00 $3.77 $1.14 $4.91

Help Desk - 0.270 0.070 0.10 0.034 $0.00 $1.52 $0.47 $1.99

Report Compromised Signature - - 0.400 0.01 0.004 $0.00 $0.00 $0.27 $0.27

Subtotal (domestic) 0.147 $9.00

Subtotal (foreign) 0.155 $9.00

3. Manufacturer Notification and Recordkeeping

List of Manufacturers and their 

Product Types (including 

Resins Used) Certified by TPC

(0.750) (0.500) (0.250) 1.00 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)

Results of Inspections, Audits, 

and Emission Tests Conducted 

for Each Manufacturer and 

Product Type

(0.750) (0.500) (0.250) 1.00 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)

List of the TPC's Laboratories, 

Test Methods (including Test 

Conditions and Conditioning 

Time), and Test Results

(0.750) (0.500) (0.250) 1.00 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)

Methods and Results for 

Establishing Test Method 

Correlations and Equivalence

(0.750) (0.500) (0.250) 1.00 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)
Page 40 of 105

Exhibit A-2: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Third Party Certifier

Activity

Per Activity Burden Hours Number 

of Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Manageria

l

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr) Total

(a) (b) (c) (e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

List of Manufacturers and 

Products Approved for Reduced 

Testing

(0.750) (0.500) (0.250) 1.00 (1.500) ($19.24) ($28.16) ($16.70) ($64.09)

Subtotal (7.500) ($320.00)

4. Annual Report and Notifications 

of Changes

List of Manufacturers and their 

Products Certified by the TPC 

during the Previous Year 

(including Resins Used, and the 

Average and Range of 

Formaldehyde Emissions by 

Manufacturer, Resin, and 

Product Type)

(0.250) - - 1.00 (0.250) $(6.41) - - $(6.41)

List of Noncomplying Products 

or Events by Manufacturer (0.250) - - 1.00 (0.250) $(6.41) - - $(6.41)

List of Laboratories and Test 

Methods Used by the TPC (0.250) - - 1.00 (0.250) $(6.41) - - $(6.41)

Results of Inter-Laboratory 

Comparison or Proficiency 

Testing for the Laboratories 

Used by the TPC

(0.250) - - 1.00 (0.250) $(6.41) - - $(6.41)

Subtotal (1.000) $(26.00)

Domestic Total in First Year (7.040) ($259.00)

Foreign Total in First Year (6.960) ($253.00)

Domestic Total in NonReapplication Year (8.353) ($337.00)

Foreign Total in NonReapplications Year (8.345) ($337.00)

Domestic Total in Reapplication 

Year (8.353) ($337.00)

Foreign Total in Reapplications 

Year (8.345) ($337.00)
Page 41 of 105

Exhibit A-2: Incremental Cost of Electronic Reporting Requirements: Burden and Cost Per Third Party Certifier

Activity

Per Activity Burden Hours Number 

of Annual 

Activities

(d)

Total Burden 

(hours)

Total Cost

Clerical Technical Manageria

l

Clerical

($25.65/hr)

Technical

($56.31/hr)

Managerial

($66.78/hr) Total

(a) (b) (c) (e) = 

(d)*{(a)+(b)+(c)} (f) (g) (h) (i)

Notes:

1. CDX Electronic Reporting (first year): 

• Electronic signature agreement. Preparing, submitting, and filing an electronic signature agreement is estimated to require an average of 15 minutes of time per registrant, 

which is assumed to be managerial time (EPA 2011). 

• Paper subscriber agreement. Preparing, submitting, and filing a paper subscriber agreement is estimated to require an average of 20 minutes of time per user, which is 

assumed to be managerial time (EPA 2011). 

• CDX Registration. CDX users will need to register with CDX, which involves selecting a user name and password, providing contact information, and identifying the 

facility and the registrant’s role at the facility. This is estimated to take an average of 10 minutes per registrant (EPA 2011). This results in an estimate that each 

respondent will spend 10 minutes of managerial time and 40 minutes of technical time to register with CDX. 

• Help Desk. CDX users are assumed to spend an average of 4 minutes contacting EPA’s CDX Help Desk for technical support (EPA 2011), which results in an estimate of 

4 minutes of managerial time and 16 minutes of technical time per respondent. 

• Problem Resolution. Three percent of respondents each year are assumed to spend an average of one hour of technical time working with EPA’s CDX Help Desk to 

resolve problems involving their registrations or agreements (EPA 2011).

2. CDX Electronic Reporting (subsequent years): 

• Employee Turnover. It is assumed that each year 10 percent of CDX users will be replaced by new employees, who will have to comply with the subscriber agreement 

and/or CDX registration requirements (EPA 2011). Thus, in subsequent years 10 percent of CDX users will spend 15 to 20 minutes of managerial time to complete a 

subscriber agreement. In addition, 10 percent of all registrants will spend 10 minutes to register with CDX and 4 minutes contacting EPA’s CDX Help Desk. Paper 

subscriber agreement. Preparing, submitting, and filing a paper subscriber agreement is estimated to require an average of 20 minutes of time per registrant (EPA 2011). 

This results in an estimate of 20 minutes of managerial time per respondent submitting a paper subscriber agreement. 

• Report Compromised Signature. Each year 1 percent of respondents are assumed to report a compromised or surrendered electronic signature, which requires the submittal 

of a new subscriber agreement (EPA 2011). This will entail 15 to 20 minutes (20 assumed here) of managerial time to prepare, submit, and file a new agreement, and 4 

minutes of time to contact EPA’s CDX Help Desk.

• Problem Resolution. Three percent of respondents each year are assumed to spend an average of one hour of technical time working with EPA’s CDX Help Desk to 

resolve problems involving their registrations or agreements (EPA 2011).

3. Recordkeeping

• Electronic reporting is assumed to reduce the recordkeeping burden by 50 percent (EPA 2009). 

4. Annual Report to Recordkeeping Bodies

• Electronic reporting is assumed to reduce the recordkeeping burden by 50 percent (EPA 2009).

Sources: (1) U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: Historical Data: December 2006 - March 

2011, (2) EPA 2011Sources: (1) U.S. Bureau of Labor Statistics. 2011. Employer Costs for Employee Compensation: Supplementary Tables: Historical Data: December 

2006 - March 2011, 
Page 42 of 105

Exhibit A-3: Total Bottom Line Burden and Costs (Foreign and Domestic)

Year 1 Year 2 Year 3 Average

Costs without Electronic Reporting Requirements

Number of Respondents and Responses 61 61 61 61

Total Burden Hours 2,085.64 995.38 1,181.88 1,421

Total Cost $417,470 $111,318 $122,243 $217,010 

Incremental Burden and Costs for Electronic Reporting Requirements

Number of Respondents and Responses 61 61 61 61

Total Burden Hours (344.67) (402.931) (427.93) (392)

Total Cost ($11,535) ($15,907) ($16,557) ($14,666)

Total Burden and Costs, Including Incremental Burden and Costs for Electronic Reporting Requirements

Number of Respondents and Responses 61 61 61 61

Total Burden Hours 1,740.97 592.44 753.94 1,029

Total Cost $405,935 $95,411 $105,686 $202,344 
Page 43 of 105

A.2 Costs of Electronic Reporting for EPA 

A portion of the cost that EPA incurs to operate the CDX system can be attributed to the 

TSCA Title VI program. These costs are described below.

CDX O&M – The cost of CDX operations and maintenance for TSCA Title VI electronic 

reporting is estimated to be approximately $3,000 per year.

CDX Application Support O&M – The cost of application support operations and maintenance 

(for Help Desk support, resolving technical problems, software maintenance and upgrades, etc.) 

for TSCA Title VI electronic reporting is estimated to be approximately $25,000 per year.

CDX Software Licensing Costs – EPA’s cost of software licensing attributable to TSCA Title 

VI is estimated to be approximately $6,000 per year.

CDX CBI LAN O&M – The cost attributable of operations and maintenance of EPA’s 

confidential business administration (CBI) local area network (LAN) attributable to TSCA Title 

VI is estimated to be approximately $15,000 per year.

EPA staff – Managing the CDX system related to the TSCA Title VI program is estimated to 

require approximately 0.1 FTE per year of EPA staff. Based on the 2010 Washington/Baltimore 

area annual salary rate for a GS-13, Step 5 employee ($100,904) and a loading factor of 1.6 for 

overhead and fringe benefits, the cost of the EPA staff needed to manage the CDX program 

attributable to the TSCA Title VI is estimated to be $16,145 per year. 

Overall, EPA’s cost for operating the CDX system that can be attributed to the TSCA Title VI 

program is estimated at $65,145 per year.

The use of electronic reporting and CDX also creates savings for EPA. It is expected to 

improve efficiency and lead to higher quality data being available more quickly to EPA. EPA 

typically keys or scans in the data from paper submissions, which can result in errors. 

Consequently, EPA must perform quality assurance checks on extracted and scanned 

information. When data is submitted electronically, the time required for EPA staff to review 

and process the information is reduced because manual data entry or processing is eliminated. 

Electronic reporting also improves data quality because it facilitates data correction and 

validation by highlighting fields with omitted or inconsistent data prior to submission. EPA has 

not estimated the value of these efficiencies and improvements in data quality.
Page 44 of 105

Appendix B – Mock-Ups for Potential TSCA Title VI Electronic Reporting Application 

B.1 Summary of the Electronic Reporting Application Under Consideration

The current proposed regulation does not provide a required format for reports and notices. 

However, EPA is considering an electronic reporting requirement. If the EPA finalizes a 

mandatory electronic reporting requirement all reports and notices covered by this action would 

be required to be submitted via that internet through the EPA’s Central Data Exchange (CDX). 

The EPA is requesting comment on a mandatory electronic reporting requirement for 

Accrediting Bodies (ABs) and Third-Party Certifiers (TPCs). In order to give regulated entities 

more information on which to base their comments, the EPA prepared mock-ups of a potential 

electronic reporting application. The mock-ups are in draft form and should be considered for 

illustrative purposes only. They contain two sections, an AB user interface which would be 

visible to participating laboratory and product ABs and the TPC user interface which would be 

visible to TSCA Title VI accredited TPCs.

These mock-ups are not complete in that they do not address all aspects of the EPA's proposed 

implementation of TSCA Title VI. To the extent that the EPA’s proposals change, conforming 

changes would be made to the data elements and other aspects of the electronic reporting 

application, should the EPA choose to implement a mandatory electronic reporting requirement. 

Should the EPA develop this electronic reporting application, the EPA would allow regulated

entities to participate in testing of the application and the EPA would provide training as 

necessary. 

B. Electronic Reporting and Confidential Business Information

The EPA believes that most of the information that would be collected under TSCA Title VI is 

not confidential in nature. Nonetheless, any electronic reporting application would be designed to 

support TSCA Confidential Business Information (CBI) needs by providing a secure 

environment that meets Federal standards. Users would be able to claim CBI for appropriate data 

fields. 

The draft mock-ups below contain CBI check boxes that illustrate how reporting entities would

submit CBI claims for particular data elements. In the proposal, the EPA is requesting comment 

on whether the data elements in the ABs’ and TPCs’ annual reports, and the required 

notifications should be reported into a publicly viewable database. EPA requests comment on 

whether such information might contain CBI, and if so, which data elements may be subject to 

CBI claims. EPA believes that data elements related to the type or formulation of a resin may be 

the subject of legitimate TSCA CBI claims. Notwithstanding the current placement of the CBI 

check boxes, the EPA would modify their placement to conform with the final rule, should the 

EPA finalize a mandatory electronic reporting requirement. 
Page 45 of 105

TSCA Title VI 

eReporting Application

Mock-Up Screen Shots
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Accrediting Body

User Interface

Mock-Up Screen Shots

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Accrediting Body 

Application for Recognition 

Agreement Form

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Third-Party Certifier

Accreditation Form

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Laboratory

Accreditation Form

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Accreditation Body

Annual Report Form

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Third-Party Certifier

User Interface

Mock-Up Screenshots

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Third-Party Certifier 

Identification Form

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Panel Producer Certification 

(Optional) Form

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Reduced Testing 

Approval Form
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Failed Quarterly

Test Form

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Third-Party Certifier

Annual Report Form

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Submission Screens

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Copy of Record

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