## Economic Analysis of the Final Significant New Use Rule for Alkanes, C 12

- 13 

## , chloro (CAS RN : 71011

- 12

- 6)

(EPA Docket EPA

- HQ

- OPPT

- 2010

- 0573)



### November 20

, 2014



## — Does not contain TSCA CBI

—

Prepared by:

Economic s and Policy Analysis Branch Chemistry, economics, and Sustainable Strategies Division

Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) i Economic and Policy Analysis Branch CONTRIBUTORS

The EPA analyst responsible for this report was Joe Callahan

. Analytical and draft preparation support was provided by Abt Associ ates Inc. under EPA Contract No. EP

- W

- 08

- 010.Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) ii Economic and Policy Analysis Branch ABSTRACT

This report estimates the costs of the U.S. Environmental Protection Agency (EPA)’s final Significant New Use Rule (SNUR) for the chemical a lkanes, C 12 - 13 , chloro ( C 12 - 13 chloro a lkanes

, Chemical Abs tracts Service Registry Number (CAS RN): 71011

- 12

- 6)

. C 12 - 13 chloro a lkanes, are short chained chlorinated paraffin s (SC C P s ); a n S CC P is defined as any chlorinated paraffin with a carbon chain length between

C 10 and C 13

.

The final SNUR applies to all manufacturing, import, and processing of C 12

- 13 chloro alkanes for any use. EPA found no evidence of any manufactur ing or importation into the United States of the chemical, and

n o data was reported in the 2006 Toxic Substances Control Act (TSCA ) Inventory Update Reporting (IUR) database for C 12

- 13 chloro alkanes (EPA 2006 a )

. 1 Because the domestic manufacture, import and processing o f C 12

- 13 chloro alkanes has been discontinued

, there is expected to be n o economic impact

from the final SNUR

.

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

, import, or processing of C 12

- 13 chloro alkanes for any significant new use as defined in the SNUR

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

. EPA is proposing the SNUR because of concerns regarding the environmental fate and the exposure pathways that lead to C 12

- 13 chloro alkanes presence in aquatic organisms

. Because C 12

- 13 chloro alkanes is not currently man ufactured in or imported into the United States it is important that EPA is notified if a company chooses to produce, import, or process C 12

- 13 chloro alkanes for any significant new use. The SNUN provides the Agency with an opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs

.

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

costs

. However, since no firms have been iden tified which import

, manufacture

, or process C 12

- 13 chloro

alkanes for any significant new uses, it is highly unlikely that any firm will incur this cost. EPA does not require the development of test data for submission of a SNUN, although a firm may submit test d ata already in its possession or describe any other available data. Because EPA does not require the development of test data , EPA assumes that no firms will incur testing costs as a result of the final SNUR

.

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

make a submission. By avoiding a significant new use , a firm can avo id submission and testing costs but may incur other compliance costs. However, this may not be a concern given th at the domestic manufacture, import and processing of C 12

- 13 chloro alkanes for the uses subject to the SNUR have been phased out

.

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

make a submission. The pote ntial hidden costs to the firms that do not make a submission are not quantified. EPA receives only a handful of SNUNs per yea r. T he number of firms affected by not making submissions to EPA is not known; therefore, costs are not aggregated across the affe cted entities.

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

C 12

- 13 chloro alkanes ) listed on the TSCA Chemical Substance Inventory

. Sites are only required to submit IUR data if they manufacture or import more that 25,000 lbs of a chemical during the reporting year . T he most recent year

with data available was 2006. Commented [WC1]: Check display of the footnote below. Part

seems to be cut off.Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) iii Economic and Policy Analysis Branch TABLE OF CONTENTS

CONTRIBUTORS

................................ ................................ ................................ ................................ ......... i

ABSTRACT

................................ ................................ ................................ ................................ .................. ii

1. INTRODUCTION

................................ ................................ ................................ ................................ 1

1.1 Background

................................ ................................ ................................ ................................ . 1

Uses and Substitutes

................................ ................................ ................................ ................... 1

Health Effects

................................ ................................ ................................ ............................. 2

Environmental Effects

................................ ................................ ................................ ................ 2

Current Manufacturing

................................ ................................ ................................ ............... 3

1.2 Statutory Authority

................................ ................................ ................................ ..................... 3

1.3 Summary of Methodology

................................ ................................ ................................ .......... 3

1.4 Organization of this Report

................................ ................................ ................................ ........ 3

2. INDUSTRY Compliance costs

................................ ................................ ................................ ............. 5

2.1 Wage Rates

................................ ................................ ................................ ................................ . 5

2.2 Unit Industry Compliance Costs

................................ ................................ ................................ . 6

2.2.1 Rule Familiarization

................................ ................................ ................................ ...... 6

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

................ 6

2.2.3 Form Completion and Submission Fee

................................ ................................ .......... 8

2.2.4 Recordkeeping

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

................................ ................... 10

2.2.5 C ustomer Notification

................................ ................................ ................................ . 11

2.2.6 Import Certification

................................ ................................ ................................ ..... 11

2. 2.7 Export Notification

................................ ................................ ................................ ...... 11

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

................................ ............................. 13

2.4 Likelihood of a SNUN Submission

................................ ................................ .......................... 14

2.5 Potential for Subsequent Regulatory Action

................................ ................................ ............ 14

3. AGENCY COSTS

................................ ................................ ................................ ............................... 16

3.1 Labor Rates for EPA Staff

................................ ................................ ................................ ........ 16

3.2 SNUN Processing Costs

................................ ................................ ................................ ........... 16

3.3 Export Notification Cost

................................ ................................ ................................ ........... 19

4. Benefits

................................ ................................ ................................ ................................ ............... 20

5. ADDITIONAL AN ALYSES

................................ ................................ ................................ .............. 21

5.1 Regulatory Flexibility Act

................................ ................................ ................................ ........ 21

5.2 Unfunded Mandates Reform Act

................................ ................................ .............................. 21

5.3 Paperwork Reduction Act

................................ ................................ ................................ ......... 21

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

- Income Populations

................................ ................................ ............... 22

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

Risks

................................ ................................ ................................ ................................ ......... 22

5.6 Executive Order 13132: Federalism

................................ ................................ ......................... 22

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

..... 22

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

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

6. REFERENCES

................................ ................................ ................................ ................................ .... 24

A. INFLATORS AND WAGE RATES

................................ ................................ ................................ .. 30

A.1 Derivation of Loaded Wage Rates

................................ ................................ ............................ 30

A.2 Derivation of Inflation Factors

................................ ................................ ................................ . 33 Deleted: 4

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Deleted: 32Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) iv Economic and Policy Analysis Branch LIST OF TABLES Table 1: Loaded Industry Wage Rates, December 2011

................................ ................................ ............... 6

Table 2: Rule Familiarization Burden and Cost for SNUR Submitters

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

First

- Time Submitters

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

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

................................ ................. 9

Table 6: Annual Per

- Chemical Costs of Recordkeeping Requirement for Companies that Choose not to
Submit a SNUN

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

................................ ................................ .......... 12

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

................................ ................................ 13

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

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

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

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

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

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

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

................................ ................................ .............................. 32

Table 16: Derivation of Inflation Factors

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Deleted: 33Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 1 Economic and Policy Analysis Branch 

### 1. INTRODUCTION

This report presents the U.S. Environmental Protection Age ncy (EPA), Office of Chemical Safety and Pollution Prevention’s (OCSSP’s ) a nalysis of the potential costs incurred as a result of a final Significant

New Use Rule (SNUR ) for the chemical alkanes, C 12 - 13 , chloro (C 12 - 13 chloro a lkanes

, Chemical Abstracts Service Registry Number (CAS RN): 71011

- 12

- 6). C 12

- 13 chloro alkanes is a short chained chlorinated paraffin (SCPP); a SCCP is defined as any chlorinated paraffin with a carbon chain length between C 10 and C 13

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

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

pr ocessing of C 12

- 13 chloro alkanes

. EPA promulgates a SNUR for a substance when potential uses c o uld result in increased exposure to

, or releases of

, the substance which in turn, could present an unr easonable

risk to health or the e nvironment

.

1.1 Background

As part of EPA’s efforts to enhance the existing chemicals program under TSCA , the Agency identified an initial list of widely recognized chemicals for the development of an Action P lan based on one or more of the following factors: presence in humans; persistent, bioaccumulative, and toxic (PBT) characteristics: use in consumer products; and production volume. SCCPs were selected because they 

### a re bioaccumulative in wildlife and humans, are persistent and transported globally in the environment, and toxic to aquatic organisms at low concentrations. The Action Plan summarized all readily available use, exposure, and hazard i nformation for SCCPs

, considered which authorities pro vided under TSCA

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

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

.

Uses and Substitutes

The largest use of SCCPs in the United States is as a comp onent of lubricants and coolants in metal cutting and metal forming operations. The second

- largest use is as both a secondary plasticizer and a flame retardant in plastics, especially p olyvinyl chloride (PVC). Other minor domestic SCCP uses are as a plasticizer and a flame

- retardant additive to a variety of products including: rubber formulations, paints and other coatings, and adhesives and sealants (CPIA, 2009). For safety reasons, other countries (tho se in the European Union and Canada) have allowed SCCPs to be used as a flame retardant in underground mining conveyor belts (rubber formulations) and fire retardants in dam sealants (ECHA 2008a).

Medium chained chlorinated paraffins (MCCP; C14

- 17 alkyl c hain) are alternatives to SCCPs for many applications. Based on their physical

- chemical properties, MCCPs are also expected to be persistent in the environment and several field surveys have shown they are present in sediments and biota, demonstrating

thei r release to and persistence in the environment. Field

- measured bioaccumulation factors (BAFs) that are greater than 5000 and biomagnification factors (BMF) greater than 1 indicate that MCCPs are bioaccumulative in biota and can biomagnify in food chains ( UNEP, 2009). MCCPs have toxicity to sensitive aquatic organisms that is similar to SCCPs. Canada has concluded that MCCPs are “toxic” as defined by the Canadian Environmental Protection Act (CEPA) (Government of Canada 2008). The European Union’s 2005 Risk Assessment Report and 2007 draft update conclude that there is a need for limiting the risks posed by certain uses of MCCPs in the production of PVC and metal cutting (EC, 2005, 2007).

Long

- chained chlorinated paraffins (LCCP; generally C18

- 28) appear to have been used as alternatives to SCCPs in some of the more demanding metal working applications (HELCOM, 2002). LCCPs also appear to have potential as an alternative in leather, paints and coatings, sealants and rubber applications. LCCPs are expected to be persistent and bioaccumulative in the environment based on their physical

-Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 2 Economic and Policy Analysis Branch chemical properties and bioaccumulation modeling, respectively. Canada has concluded that LCCPs up to C20 are “toxic” as defined by CEPA (Government of Canada 2008). Canada has not made a determination of whether LCCPs greater that C20 are toxic.

A number of other potential alternatives, e.g. nitroalkanes, alkyl phosphate and sulfonated fatty acid esters and vegetable oil based products, are available for specific applications. It is stated that these alternatives are considered less harmful than chlorinated paraffins (UNECE, 2006). These non

- chlorinated paraffin alternatives are often more expensive and may require special handling. A UK estimated cost for completely converting SCCPs to non

- SCCPs in metal working was predicted to be four million £ per year (IRTA, 2004). An analysis of costs conducted in California found that overall metal working processing costs were more expensive for the SCCP alternatives but including other associated costs (clean up and waste removal) made the non

- SCCP alternatives competitive (IRTA, 2004).

Health Effects

Acute toxicity of SCCPs (C 10

- 13 ) is very low (EC, 1999; UNEP, 2009). SCCPs may cause skin and eye irritation upon repeated application, b ut do not appear to induce skin sensitization (EC, 1999; UNEP, 2009). There was no evidence of developmental effects in prenatal developmental toxicity studies in rats and rabbits (EC, 1999; UNEP, 2009).

The liver, kidney and thyroid are major target orga ns in repeated

- dose studies with rats and mice. When administered by gavage, chlorinated paraffins (C 12 , 60 percent chlorine) are carcinogenic in rats and mice of both sexes (NTP, 1986a; 2005). The underlying mechanisms for the carcinogenicity of SCCP in r ats and mice are not clearly known. SCCPs were not mutagenic to bacteria with or without metabolic activation (NTP 1986a, b). There are some indications that the SCCP

- induced kidney tumors in male rats are associated with alpha 2μ

- globin accumulation in hy aline droplets, a mode of action unique to male rats and irrelevant to humans, but this could not be confirmed by immunocytochemical techniques. There are also data showing that the liver toxicity/carcinogenicity induced by SCCP is associated with peroxiso me proliferation, whereas the thyroid effects are correlated to altered thyroid hormone homeostasis. A number of scientific working groups, including the International Agency for Research on Cancer (IARC), have concluded that liver tumors induced by peroxi some proliferators are not relevant to

humans (IARC, 1990; Klaunig et al., 2003). Humans are expected to be much less sensitive to thyroid hormone perturbation than rats and mice.

There is no experimental evidence using human data that demonstrates the ca rcinogenicity of SCCPs. In the 11th Report on Carcinogens, NCI lists chlorinated paraffins (C 12 , 60 percent chlorine) as reasonably anticipated to be human carcinogens based on sufficient evidence of carcinogenicity in experimental animals (NTP, 2005). The y are classified by the IARC as Group 2B

- possibly carcinogenic to humans based on sufficient evidence of carcinogenicity in experimental animals and mechanistic considerations (IARC, 1990).

Health Canada and Environment Canada have characterized all chlo rinated paraffins (SCCPs, MCCPs and LCCPs) as “toxic” under CEPA (Government of Canada 2008).

Environmental E

ffects



### The primary hazard concern for SCCPs is ecotoxicity. SCCPs are highly toxic to aquatic invertebrates following acute (48

- hr EC50 = 0.043 to 11 mg/L) and chronic (NOEC = 0.005 to 2 mg/L) exposures. In fish high toxicity is associated with chronic exposures, but not for acute exposures (96

- hr LC50 = 300 to 10,000 mg/L and NOE C = 0.0096 to 0.05 mg/L). For aquatic plants, there is high toxicity associated with both acute and chronic exposures to SCCPs (96

- hr EC50s range from 0.043 to 0.39 mg/L and NOEC ranges from 0.012 to 0.39 mg/L) (UNEP, 2009).Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 3 Economic and Policy Analysis Branch Both Health Canada and Environment Canada have characterized all chlorinated paraffins (SCCPs, MCCPs and LCCPs) as “toxic” under CEPA (Government of Canada 2008 ). 

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

effect on the environment or its biological diversity; and that they are persistent, bioaccumulative, inherently toxic and present in the environment primarily as a result of human activity (Government of Canada 2008).

Current Manufacturing

The current use of chlorinated paraffi ns (SCCP, MCCP, and LCCP) in the United States is on the order of 150 million pounds per year. Production of short

- chain and medium

- chained chlorinated paraffins (C 9 to
C 17 ) was 100 million pounds in 2007. A very small fraction of that number is attributab le to import/export business. According to the Chlorinated Paraffins Industry Association, MCCPs represent the largest production and use of chlorinated paraffins in North America while SCCPs is only half that volume (CPIA, 2009). In the United States, Dov er Chemical Corp. is the sole manufacturer of chlorinated paraffins and several companies import chlorinated paraffins according to 2006 IUR data (EPA, 2006).
However, n o 2006 IUR data has been reported for C 12

- 13 chloro alkanes (CAS RN 71011

- 12

- 6) and EPA found no additional evidence of any importation or manufacturing of the chemical. I t therefo re appears
, there is no current manufacture or importation of C 12

- 13 chloro alkanes in the United States

.

1.2 Statutory Authority

Section 5(a)(2) of TSCA (15 U.S.C. 2604(a)(2)) authorizes EPA to determine that a use of a chemical substance is a “significant new use.” EPA must make this determination by rule after considering all relevant factors, including those listed in TSCA section 5(a)(2). Once EPA determines that a use of a chemical substance is a significant new use, TSCA section 5(a)(1)(B) requires persons to submit a SNUN to EPA at least 90 days before manufacturing, importing, or processing the chemical substance for that use (15 U.S.C. 2604(a)(1)(B)).

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

1.3 Summary of Methodology

This analysis quantifies, to the extent possible, the costs of the final rule to society by identifying the costs to industry associated with performing the required repor ting and recordkeeping activities, and the costs to EPA of administering the rule. Industry costs consist of rule familiarization; registration with the Central Data Exchange (CDX) electronic reporting tool; collection, compilation, and submission of requi red information for significant new uses of the subject chemicals; export notification; and recordkeeping. Agency costs include reviewing and processing the data received as a result of the rule. Data sources for this analysis include burden estimates deri ved from previous information collection requests and economic analyses for related rules, compensation data acquired from government publications, and supplementary market research.

In addition to estimated costs, this report qualitatively discusses the b enefits of the final rule based on the value of the information it will provide.

1.4 Organization of this Report

The remainder of this report presents EPA’s economic analysis in support of the final rule. Chapter 2 presents estimates of the costs incurred by m anufacturers, importers, and/or processors under the SNUR options. Chapter 3 shows estimates of the government costs associated with the administration of the final

rule

. Chapter 4 discusses the benefits of the final rule. Chapter 5 presents an analysis of other impacts, as required by various statutes and executive orders.Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 4 Economic and Policy Analysis Branch Note that all dollar values in this analysis are reported in 20 11 dollars , except for the U.S. Postal S ervice mailing rates, which were acquired in January 2012.Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 5 Economic and Policy Analysis Branch 

### 2. INDUSTRY COMPLIANCE COSTS

The final SNUR discussed in this report spe cifies that significant new use s of C 12

- 13 chloro alkanes be reported under section 5(a)( 2 )(A) of TSCA . A significant new use is defined as the manufactur ing

, import ation , and/or process ing of C 12

- 13 chloro alkanes for any use

. A firm intending to manufacture, import, and/or process C 12

- 13 chloro alkanes for any significant new use must submit a SNUN. Alternatively, a firm can decide not to manufacture, import, and/or process th e chemical for a significant

new use

. The firm

, there fore

, has two options:

 Option 1: Submit a SNUN

. A SNUN indicates to EPA that the firm would like to manufacture, import, and/or process the chemical for a significant new use , which, in this case, means the

manufactur ing , importing, and/or processing of this chemical for any use

. The firm must submit the SNUN to EPA at least 90 days before it plans to commence the manufacture, import, and/or processing of the substance; the SNUN provides EPA with the opportunity to evaluate the intended use and, if necess ary, to prohibit or limit that activity before it occurs. If EPA allows the manufacture, import, or processing of C 12

- 13 chloro alkanes for the intended use

, then the costs associated with this option are the costs of submitting the SNUN (including a user fee) plus

, if there is any export of these products

, the export notification costs that result from TSCA Section 12(b) requirements that are automatically triggered for chemicals regulated under TSCA Section 5 (see Section 2.2.7 for details)

. Because the domestic manufacture, import and processing of C 12

- 13 chloro alkanes for the uses subject to the SNUR have been phased out

, EPA expects that no firms will choose this option.

 Option 2: Decide not to manu facture, import, and/or process the chemical

. The firm may decide simply not to proceed to manufacture, import, and/or process the chemical. While this option avoids the costs of submitting a SNUN, it e ntails the ‘hidden’ cost of the profit that will be foregone as a result of not engaging in the commercial activity originally planned. Similarly, if the firm will have used a given amount of C 12

- 13 chloro alkanes in the production of another product, and must substitute to a more costly substance, it will incur those additional “ hidden ” costs of production. However, these hidden costs are expected to be minimal , if not zero, because C 12

- 13 chloro alkanes is not currently

manufactured in the United States

. If the firm elects to produce C 12

- 13 chloro alkanes for research and development (R&D) purposes only ( an exemption for R&D purposes is provided in 40 CFR §721.47), it may have costs associated with R&D recordkeeping.

Because the domestic manufacture, import and processing of C 12

- 13 chloro alkanes for the uses subject to the SNUR have been phased out

, EPA does not expect there to be compliance cost associated for either of the options. The remainder of this chapter esti mates the quantified portion of costs as sociated with the

final SNUR

. Section 2.1 summarizes the wage rates used in this chapter. Section 2.2 provides the unit industry compliance costs, including the costs of rule familiarization, registration with the Central Data Exchange ( CDX ) electronic reporting tool, co mpleting the SNUN form, submission fee, import certification, and export notification. Total costs under each option are presented in Section 2.3

.

2.1 Wage Rates

The final rule involves activities that may require efforts by employees in three labor classifications: managerial, technical, and clerical. Costs for each activity are calculated by estimating the labor hours required in each labor catego ry and multiplying t hose burden hours by the wage rate for the corresponding labor category. This section presents the estimated wage rate in each labor category.

Loaded wage rates for managerial, technical, and clerical personnel are derived by combining data on wages and f

ringe benefits with estimates of overhead rates, following the methodology described in Wage Rates for Economic Analysis of the Toxics Release Inventory Program (EPA, 2002b). Wage data for each Deleted: 2.1Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 6 Economic and Policy Analysis Branch labor category for December 2011 are provided by the Employer Costs for Employee Compensation (ECEC) Supplemental Tables available on the BLS website (BLS, 201 2 a). The loaded wage rate is $ 70.72 for managerial labor; $ 64.66 for technical labor; and $ 29.63 for clerical labor. Table 1 presents the data used to calculate the loaded wage rates for the three labor categories.

Table 1 : Loaded Industry Wage Rates, December 20 11

Labor Category Data Sources Wage (20 11 $) Fringe

Benefit (20 11 $) Fringes

as %

wage Over

head %

wage 2 Fringe +

overhead

factor Loaded

Wages 1
(20 11 $)

(a) (b) (c)

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

(d)+1 (f)=(a) x

(e)

Managerial BLS ECEC , Private

Manufacturing industries

, “Mgt, Business, and Financial” 3 $ 43.01 $ 20.40 47.43 % 17% 1.64 $70.72

Professional/

Technical BLS ECEC , Private

Manufacturing industries

, “Professional and related“ 3 $3 8.48 $1 9.64 51.04 % 17% 1.6 8 $ 64.66

Clerical BLS ECEC , Private

Manufacturing industries,
“Office and Administrative Support” 3 $ 17.69 $8.93 50.48 % 17% 1.67 $29.63

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

2 An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory Program ( EPA 2002b ), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report ( EPA, 2002a ).

3 Employer Costs for Employee Compensation Supplementary Tables: December 20 11

. US Bureau of Labor Statistics, March 1 4

, 20 1 1

- (BLS 20 1 2 a ).

2.2 Unit Industry Compliance Costs



### 2.2.1 Rule Familiarization

The final rule requires submitters and their staff to become familiar with the SNUR and its various requirements. Rule familiarization is estimated to require 0.55 hours of technical labor and 0.27 hours of managerial labor, as described in the Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009a), which measures the costs of mandatory electronic reporting of

SNUNs and other TSCA Section 5 notices. As shown in Table 2

, the total labor cost associated with rule

familiarization is estimated at $ 54.43

.

Table 2 : Rule Familiarization Burden and Cost for SNUR Submitters

Reporting Activity Clerical Labor (at $2 9.63 /hour) Technical Labor (at

$ 64.66 /hour) Managerial Labor

(at $ 70.72 /hour) Total Labor Cost

Burden (hours) Cost

(20 11 $) Burden

(hours) Cost

(20 11 $) Burden

(hours) Cost

(20 11 $) Burden

(hours) Cost

(20 11 $)

Rule Familiarization 0.00 $0.00 0.55 $ 35.56 0.27 $18. 86 0.82 $5 4.43

Total 0.00 $0.00 0.55 $3 5.56 0.27 $18. 86 0.82 $5 4.43

Source : BLS 201 2 a (labor rates) ; EPA 2009a (burden hours)



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

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

process a chemical for a significant new use

. F irst

- time submitters of any TSCA section 5 notice Deleted: Table 1

Deleted: Table 2Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 7 Economic and Policy Analysis Branch (including Premanufacture Notices ( PMNs), SNUNs, Test Market Exemption (TME) applications, Low Volume Exemption (LVE) notices, Low Exposure/Low Release (LoREX) exemption notices, Biotechnology Notices for genetically modified microorganisms, Notices of Commencement of Manufacture or Import (NOCs), and support docume nts to Section 5 notices ) are required to register their company and key users with the CDX reporting tool, deliver a CDX electronic signature to EPA, and establish and use a Pay.gov E

- payment account. 2 These activities are only required of first

- time

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

, based on the estimates presented in the Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009a):

 CDX registratio n: EPA estimates that companies will spend approximately 0.18 hours per employee to register with CDX, and that an average of four technical staff members and one manager will need to register for each company, totaling approximately 0.92 hours of burden p er company.

 CDX electronic signature: EPA estimates that companies will spend 0.25 hours preparing, submitting, and filing an electronic signature agreement (Authentication of Identity) form to EPA per employee. This burden will apply to four technical sta ff members and one manager per company, totaling 1.25 hours of burden per company. In addition, EPA estimates that a manager will spend an additional 0.50 hours accessing, preparing, and submitting verification forms (Verification of Authorization) for all authorized submitters to EPA. The total burden incurred by companies submitting and then verifying electronic signature agreemen ts is 1.75 hours. Note that this burden does not include any additional time required to contact EPA’s CDX help desk to notify a change of submitter status, should one occur. Filing the electronic signature agreement requires an additional mailing cost of $2.55 per company (including five $0.45 stamps 3 and five $0.06 business envelopes 4 ).

 Payment via Pay.gov account: EPA estimates that one manager per company will spend approximately 0.13 hours setting up a Pay.gov ID account, logging into the system, find ing the appropriate form, and filling it out. This burden does not include the time required to click ‘submit’ on the form and wait for payment processing.

As shown in Table 3

, the labor cost consists of CDX registration, CDX electronic signature, and Pay.gov account setup by a first

- time submitter

. As noted above, an additional $ 2.55 in mailing cost per company is attributable to these activities, for a total cost of a pproximately $ 190 per company.

2 Although the final rule does not requi re submitters to establish and use a Pay.gov account, the burden estimates in this analysis are conservative insofar as to include the use of Pay.gov as a required activity.

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

4 Price for an envelope was determined based on the per unit price of a regular business envelope. See “ Staples® #10, Self

- Sealing Envelopes, 500/Box." Available at: http://www.staples.com/ (Accessed 1/25/2012). Deleted: Table 3Economic Analysis of SNUR for Alkanes, C 12

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- 6) 8 Economic and Policy Analysis Branch Table 3 : CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup Burden

and Cost for First

- Time Submitters

Reporting Activity Clerical Labor (at $2 9.63 /hour) Technical Labor (at

$ 64.66 /hour) Managerial Labor

(at $ 70.72 /hour) Total Cost

Burden (hours) Cost

(20 11 $) 1 Burden

(hours) Cost

(20 11 $) 1 Burden

(hours) Cost

(20 11 $) 1 Burden

(hours) Cost

(20 11 $) 1 CDX Registration 0.00 $0.00 0.73 $4 7.42 0.18 $12.96 0.92 $60.38

CDX Electronic Signature 0.00 $0.00 1.00 $ 64.66 0.75 $5 3.04 1.75 $1 18

Mailing Cost $2. 55

E

- Payment ( Pay.gov ID) 0.00 $0.00 0.00 $0.00 0.13 $9. 43 0.13 $9. 43

Total 0.00 $0.00 1.73 $1 12 1.07 $7 5.43 2.80 $1 90

Notes: Costs may not equal labor wage rate times burden hours due to the rounded burden estimate presented in the table, unrounded estimates were used during the cost calculations.

Source : BLS, 201 2 a (labor rates) ; EPA, 2009a (burden hours); USPS, 2010 (mailing cost)



### 2.2.3 Form C ompletion and Submission Fee

Respondents who choose to submit a SNUN are required to gather and submit information regarding the data elements identified in the applicable SNUN reporting form. The methodology and calculations used in this analysis assume t hat the employee responsible for collecting, filling out, and submitting the requested information has a reasonable level of familiarity with the company and knowledge of operations at the site. It is assumed that for most entities these tasks are similar to other employee duties that require familiarity with EPA, State, and other Federal agency requests for chemical information and do not require additional familiarization or training beyond the basic rule familiarization described above. In addition, this analysis focuses on the marginal costs of submitting information for the final rule and not the total costs for the company to comply with a range of other Federal and State environmental, health, and safety regulations or accounting requirements that rel y on this type of information.

Estimates of the costs of completing a Significant New Use Notice (SNUN) form are based on the costs of completing a PMN submission, since the data requirements are the same and the same form is used for both.

The PMN submiss ion costs came from EPA's 1994 Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications, which relied on industry estimates of the effort needed to collect and compile all data required for a PMN submission, prepare the form, submit the form and data to EPA, and maintain a file of the submission (EPA, 1994, Table III

- 2 and pages III

- 11,

- 12, a nd

- 13). The 1994 estimates were based on a survey conducted by the Chemical Manufacturers Association, which became the American Chemistry Council. These burdens include “the time spent reading and becoming familiar with the form, gathering the required i nformation and preparing the report, producing sanitized responses for items claimed as confidential business information, and maintaining a file of the submission” (EPA, 1994. p. III 11

- 13). The burden associated with SNUN submission and preparation has b een adjusted to reflect burden reductions resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that requires the electronic submission of all TSCA section 5 notices. Electronic submission of SNUN forms is expected to remove all clerical burde n and reduce the recordkeeping burden associated with preparing a SNUN (EPA, 2009a). 5 In addition, electronic submission is expected

5 The Economic Ana lysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009a) reported a 0.5 hour clerical and a 0.5 hour technical burden associated with recordkeeping in addition to the burden estimates from the 1994 RIA (EPA, 1994, p. III

- 14). T hese burden estimates (the 0.5 for clerical burden and 0.5 for technicalEconomic Analysis of SNUR for Alkanes, C 12

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- 6) 9 Economic and Policy Analysis Branch to generate an additional 0.18 hours of technical burden, for the completion of the User Fee Payment

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

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

technical labor and 18 hours of managerial labor (EPA, 2009a). Table 4 combines the estimated reporting burden and loaded wage rates for all three labor categories to estimate the per

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

is estimated at $ 6,071

.

Table 4 : Industry Cost Estimate to Complete the SNUN Form

Reporting Activity Clerical Labor (at $ 29.63 /hour) Technical Labor (at

$ 64.66 /hour) Managerial Labor

(at $ 70.72 /hour) Total Labor Cost

Burden (hours) Cost

(20 11 $) Burden

(hours) Cost

(20 11 $) 1 Burden

(hours) Cost

(20 11 $) 1 Burden

(hours) Cost

(20 11 $) 1 Form Completion 0.00 $0.00 7 4.2 $ 4,798 18.00 $1,2 73 9 2.2 $ 6

, 071

Notes: Costs may not equal labor wage rate times burden hours due to the rounded burden estimate presented in the table, unrounded estimates were used during the cost calculations.

Source :

1 Loaded wages include fringe benefits and overhead. See Appendix A of this report for derivation. Wage rates presented in this table are rounded values; however, unrounded values are used to calculate total labor costs. For this reason, total labor costs may not equal the product of rounded values.

2 The estimate of no clerical burden is t aken from the Economic Analysis of the Premanufacture Notice Electronic Reporting Final Rule (EPA, 2009a, page 7)

3 T echnical and managerial labor burden is from the PMN Amendments RIA (EPA, 1994, Table III

- 2). An additional eleven minutes (0.18 hours) of technical burden is estimated to complete the User Fee Payment Identification Number and Email Address data elements on the Electronic SNUN form (EPA, 2009a page 15).

In addition, each submitting large business must pay a $2,500 per

- SNUN submission fee, a nd each submitting small business must pay a $100 per

- SNUN submission fee. Table 5 adds the labor cost and

submission fee to estimate the total cost of a SNUN submiss ion. The total cost of a SNUN submission is $ 8,571 for large business submitters and $ 6,171 for small business submitters.

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

Reporting Population Labor Cost Submission Fee Total Cost (20 11 Large Business Submitters $ 6,071 $2,500 $8, 571

Small Business Submitters $ 6

, 071 $100 $ 6

, 171

Source : EPA, 2009a

.



### 2.2.4 Recordkeeping

Companies submitting a SNUN must, under 40 CFR §721.40, keep records of the information contained in the SNUN. Some EPA reports have assumed that SNUN recordkeeping hours will be five percent of

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

with PMN submissions. Therefore, for this analysis, the 0.5 hour for clerical labor and the 0.5 hour for technical labor were removed. It is important to note that for this analysis, clerical burden changes are not applicable because the entire clerical burden

is assumed to be eliminated under the electronic reporting requirements . In summary, we do not include the one hour recordkeeping burden (0.5 hour for clerical, 0.5 for technical) reported in the ePMN EA. Deleted: Table 4

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- 6) 10 Economic and Policy Analysis Branch SNUN submission hours, or about five to six hours. 6 For this report, the SNUN recordkeeping hours were included in the SNUN submission hours (see Section 2.2.3 ) and the SNUN recordkeeping costs under 40 CFR §7 21.40 were not separately estimated. 7

Recordkeeping for Companies t hat D o N ot Submit a SNUN

If a firm that manufactures, imports or processes a substance subject to the final SNUR chooses not to submit a SNUN, they must keep records that document compliance with SNUR conditions for avoiding a Significant New Use. Such recordkeeping requirements essentially involve copying and filing relevant records, including those related to category of use. Records must be maintained for five years from the date of their creation (40 CFR 721.40). For firms that choose to not submit a SNUN, costs for compliance with the recordkeeping requirements are estimated to be five percent of the report ing burden for reporting information for a specific section of the SNUN form and are performed by clerical staff (EPA, 2005b, pages 10 and 14). EPA used the per

- activity burden for reporting, human exposure, category of use and

releases to the environment presented in the Information Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules for Existing Chemicals (Renewal) (EPA, 2005b, page 12). Any clerical

burden associated with these activities was removed to reflect the burden reductio n associated with electronic submissions (EPA, 2009a).

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

and is derived in Table 6

.

Table 6 : Annual Per

- Chemical Costs of Recordkeeping Requirement for Companies that

Choose not to Submit a SNUN

Reporting Activity Per Activity

Burden (Hours) % of Reporting

Burden

Attributed to Recordkeeping Total Labor Cost (2011$)

Burden Cost

Category of Use 1 3 5% 0.15 $9.70

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

Source :

1 US EPA, 2005b Office of Pollution Prevention and Toxics Information Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules for Existing Chemicals (Renewal), page 13.

However

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

manufacturer s , processor s , o r importer s will be affected. Therefore, recordkeeping for companies that do not submit a SNUN will not be necessary.

6 For example, OPPT’s Information Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules for Existing Chemicals (Renewal), October 11, 2005, estimates SNUN recordkeeping costs at 5.67 hours (ICR 118.08, page 10).

7 SNUN submission costs estimated in Section 2.2.3 of this report were based on PMN submission costs from a 1994 report, Regulatory Impact Analysis of Amendments to Regulations for TSC Section 5 Premanufacture Notifications ( EPA , 1994)

. Page III

- 14 of the 1994 report refers to “the normal records kept with a PMN submission which are included in the estimates for submission costs.” Page III

- 12 identifies “maintaining a file of the submission” as part of the labor hours for the PMN reporting form. T hese statements imply that the 95 to 114 total hours for a PMN submission (page III

- 10 of EPA 1994) included recordkeeping hours. Formatted: Body Text Char Deleted: 2.2.3

Formatted: Font color: Auto Deleted: Table 6

Formatted: Font: Times New Roman, 9 pt

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- 6) 11 Economic and Policy Analysis Branch 

### 2.2.5 C ustomer Notification

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

chemicals o f the SNUR or verify that knowledge of the SNUR has been otherwise acquired by recipients, or that the recipients are unable to engage in significant new uses. Since it is not expected that all such

entities will have complete knowledge of all uses of any products subject to a SNUR, and because filing a SNUN could require significantly more burden, it is assumed that manufacturers, processors, and importers will most often choose to notify their customers of SNUR regulatory activities. As this notification may be accomplished by simply annotating an MSDS, EPA estimates the associated burden to be about one hour of a technical employee's time or $64.66 per manufac turer, processor, or importer per chemical. H owever
, EPA believes the SCCPs subject to this SNUR are no t used in the U.S. and

therefor e no manufacturer s , processor s , or importer s will be affected. Thus , customer notifications will not be necessary.



### 2.2.6 Impor t Certification

In general, promulgation of a SNUR triggers a TSCA Section 13 import certification requirement and the corresponding regulations at 19 CFR §12.118 to 12.127 and 19 CFR §127.28 for all imports of the relevant chemical substances. Thus, any U .S. manufacturer, importer, or processor receiving an imported shipment of chemicals subject to the final SNUR will have to certify that all chemical substances in the shipment either comply with all applicable rules and orders under TSCA or that all chemi cal substances in the shipment are not subject to TSCA. 8 The statement must be on or attached to a commercial invoice or entry document belonging to the imported shipment.

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

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

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

familiarization burden dis cussed above.



### 2.2.7 Export Notification

Under Section 12(b) of TSCA, exporters must notify EPA if they export or intend to export a chemical subject to various TSCA sections (40 CFR §707.60 through 75). For TSCA 5(a)(2) (the section under which EPA promulgates significant new use rules) and certain other TSCA sections, this is a one

- time notification requirement 9 per destination country for each exporter of a chemical substance. After receiving a notification from a firm, EPA notifies the importing country and t he United States State Department (40 CFR §707.70). To calculate the burden associated with making a single export notification, EPA first estimated the average annual number of export notifications made by an exporter. EPA then derived the annual and per notification burden associated with preparing and submitting an export notification.

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

chemical substa nces in this shipment comply with all applicable rules or orders under TSCA and that I am not offering a chemical substance for entry in violation of TSCA or any applicable rule or order under TSCA.” For imports of chemical substances not subject to TSCA ( e.g., pesticides), “I certify that all chemicals in this shipment are not subject to TSCA.” ( 40 CFR 707.20 )

9 On November 14, 2006, EPA revised the export notification requirement for chemicals subject to TSCA §5(a)(2), 5(b), 5(e)(1) and 5(e)(2) from an an nual to a one

- time requirement per destination country for each exporter (November 14, 2006, 71 FR 66234).Economic Analysis of SNUR for Alkanes, C 12

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- 6) 12 Economic and Policy Analysis Branch Most underlying data in this section come from t he (2009 TSCA Section 12(b) ICR), ICR No.: 0795.13

OMB Control Number 2070

- 0030 [Information Collection Request for] Notification of Chemical Exports

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

Reduction Act (EPA, 2009b)

. Exporter Costs 10

E PA’s 2009 TSCA Section 12(b) ICR estimated that the average exporter making notificati ons will make 12 notifications per year

. 11 This includes notifications resulting from SNURs and notifications resulting from other TSCA activities. Therefore, it is likely that an exporter will make less than 12 notifications per year as a result of this f

inal SNUR. A notification is typically no more than one page per chemical/country combination, and one notification mailing often includes multiple chemicals and/or

destination countries. 12

The percent of notifications resulting from SNURs in general is un known, and it is assumed that there will be no notifications from this rulemaking as there are no U.S. manufacturers.

Estimated Submission (Mailing ) Costs

. Regulated companies will incur mailing costs for export notifications delivered to EPA. Notifications are assumed shipped via the U.S. Postal Service (U

. S

. PS) as

first

- class registered mail with a return receipt (U

. S

. PS, 20 12 ). The estimated per

- shipment and annual mailing cost s incurred by individual submitters are detailed in Table 7

.

Table 7 : Derivation of Total Mailing Cost for 12 Notices

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

Postal services costs
Registered mail, regular, with $0 declared value $10. 95
Return receipt, requested at time of mailing (receive by mail) $2.3 5

Postage, regular First Class, up to 1 ounce $0.4 5

Cost per export notice

– Subtotal $13. 75

x 12

Total Mailing Cost for 12 Notices 165

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

. The mailing method comes from the Economic Analysis of the Proposed Change to TSCA Section 12(b) Export Notification Requirements , November 2005 ( EPA, 2005), as clarified in a later SNUR economic analysis ( EPA, 2007 a , Table 8 ).

Compile and Maintain the List of Products

. Since TSCA §12(b) information collection activity has been in place for twenty years, most respondents will have already developed a list of their products subject to TSCA §12(b) export notification. Respondents need only check for new re gulations promulgated and any new products exported by the company. Updating the list is estimated to take an average of one hour of technical time, which may also include some proportion of legal time (EPA, 2009b) . The total burden can

10 Most underlying data in this section come from the 2009 TSCA Section 12(b) ICR, ICR No.: 0795.13 [Information Collection Request for] Notification of Chemical Exports

- TSCA Section 12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction Act (EPA 2009b), with updating for inflation.

11 EPA calculated the average number of export notifications per exporter in the 2009 TSCA Section 12(b) ICR (EPA, 2009b) by dividing the estimated number of submitted notifications (3,500) by the estimated number of exporters (300 ).

12 Based on review by an EPA economist of notifications received under TSCA Sections 4, 5 and 6 over approximately three weeks in early 2010. Formatted: Font color: Auto

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- 6) 13 Economic and Policy Analysis Branch vary from two hours per year up to two hou rs per month, depending on the number of products exported by the company and the number of their products subject to TSCA §12(b) (EPA, 2009b).

The number of submitters per year who report under TSCA §12(b) has varied over time, risi ng from around 160 in 1991 to over 460 in 2000, and declining since. In the most recent TSCA §12(b) ICR, EPA

estimated that there will be approximately 300 submitters per year in near

- future years (EPA, 2009b ). Of these 300 submitters, EPA estimated that 2 00 companies were near the lower burden estimate of two hours per year, and 100 companies were near the upper estimate of 24 hours per year. Compiling the list for all respondents was therefore estimated to take 2,800 hours (2 hours x 200 firms plus 24 hou rs x 100 firms), or an average of about 9.3 hours of technical time per firm per year for 12 notifications per year (EPA, 2009b ).

Write or Revise Export Notification

. Companies that export chemicals subject to TSCA §12(b) reporting

must prepare an export n otification to send to EPA when export shipments are made. Time for initial preparation of the export notice may vary depending on whether the company has prior experience with this requirement. This step is estimated to take an average of one hour of tech nical time (which may also include some proportion of legal time) per firm per year for 12 notifications per year (EPA, 2009b ).

Check Orders and Send Notifications

. Companies that export chemicals subject to TSCA §12(b) reporting must check outgoing shipme nts against the list of their products described above. A form letter notifying EPA and providing the required data must be printed and mailed within the required time period. This process is estimated to take an average one half hour of clerical time per export notification or six hours for 12 notifications (EPA, 2009b).

The burdens and associated costs for each notification activity are provided in Table 8 . EPA estimates that the burden associated with making one notification is approximately 1.4 hours and $ 84

.

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

Technical Clerical Total

$/Hr Hours 20 11 $ 3 $/Hr Hours 20 11 $ 3 Hours 20 11 $ 3

Compile list $ 64.66 9.3 $ 601

-- -- -- 9.3 $601

Write letter $ 64.66 1 $ 65

-- -- -- 1 $ 65

Check order and send notice

-- -- -- $ 29.63 6 $178 6 $178

Mailing cost 1

-- -- -- - $1 65 Total per average facility 2 10.30 $666 6.00 $178 16.30 $1,008
Total per n otification 0.86 $5 5.50 0.50 $14. 81 1.36 $84.06

Notes:

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

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

3 Costs may not equal labor wage rate times burden hours due to the rounded burden estimate presented in the table, unrounded estimates were used during the cost calculations.

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

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

, and are updated to 2011 dollars.

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

The number of firms affected that do not make submissions to EPA is not known; therefore, costs are not aggregated across the affected entities. Table 9 summarizes th e per

- company per

- chemical costs to comply with the final rule amendment, as described in more detail in S ection 2. 2 above

. Formatted: Font color: Auto Deleted: Table 8

Formatted: Font: 10 pt, Font color: Auto Deleted: Table 7

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- 6) 14 Economic and Policy Analysis Branch Table 9 : Compli ance Options and Associated Costs Incurred by a Firm Due to the Final SNUR

Option 1 Costs Quantified Costs per Chemical (20 11 ) 2

1. Electronic

s ubmi ssion of a Significant New Use Notice (SNUN), indicating to EPA

that the firm would like to manufacture, import, or process the

chemical for a Significant New Use

as defined in the

SNUR

. Costs of e lectronically submitting

a SNUN, including rule familiarization, CD X registration (for companies that are first

- time submitters), form completion

, user fee, export notification cost (if relevant). Rarely, a firm may choose to conduct toxicity or fate testing to support the SNUN, but such testing is not required by law

. $ 54.43 rule familiarization cost; $8,571 submission cost (including SNUN recordkeeping under 40 CFR §721.40 and fee $2,500 for large businesses). EPA usually receives well under ten SNUNs per year. Export notifications costs are estimated at $84.06 per noti fication; total cost per company will vary. First time submitters will incur $190 for CDX registration and associated activities. Companies manufacturing, importing, or processing a chemical currently used in commerce in the

United States will incur a cost $64.66 for notifying consumers of SNUR regulatory

activities

.

2. Decide not to manufacture, import, or process the

chemical for any non

exempt uses. Cost of the profit foregone as a

result of not engaging in the commercial activity originally planned (o pportunity costs) . Other

costs include rule familiarization, and export notification costs. Opportunity costs are not quantified. Other costs include rule familiarization ($54.43), recordkeeping ($9.70), export notification costs ($84.06 per notification), and customer notification ($64.66) may apply.

Notes:

1 Firms may be subject to both options at once since submission of a SNUN results in profits foregone as a result of not manufacturing, importing, or processing the chemical.

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

Costs are detailed in Section 2.2

. 3 EPA does not require the development of test data for submission of a SNUN, although a firm may submit test data already in its possession and/or describe any other available data. Because EPA does not require the development of test data, EPA assumes that no firm s will incur testing costs as a result of the final SNUR

.

2.4 Likelihood of a SNUN Submission

This analysis assumes that no entities are expected to submit a SNUN. EPA has, over the years, promulgated SNURs that cover a total of more than 1,000 chemicals. In response, the Agency receives only a handful of SNUNs per year. For example, the number of SNUNs received was six in Fed eral fiscal year (FY) 2007, eight in FY2008, seven in FY2009 , two in FY2010, and ten in FY2011. 13 In addition,

b ecause the domestic manufacture, import and processing of C 12

- 13 chloro alkanes for the uses subject to the SNUR have been phased out (see S ectio n 1.1 ), very few, if any, entities are expected to submit a

SNUN.

2.5 Potential for Subsequent Regulatory Action

The Agency recognizes that if submiss ion of a SNUN does result from a SNUR, the Agency may take additional regulatory actions under TSCA. These additional regulatory actions might be necessary to further evaluate an intended new use and associated activities, or to prohibit or limit that acti vity before it occurs to prevent unreasonable risk of injury to human health or the environment. It is not known what

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

. Formatted: Font: 10 pt

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- 6) 15 Economic and Policy Analysis Branch specific subsequent regulatory actions, if any, the Agency may determine are necessary after reviewing a SNUN. Any such actions are highly dependent on the circumstances surrounding the individual SNUN (e.g., available information and scientific understanding about the chemical and its risks at the time the SNUN is being reviewed).

Should the Agency’s review of the SNUN result in further re gulatory actions, the Agency would initiate and follow the appropriate procedures for taking those actions. Included in those procedures would be an

assessment of the costs and benefits of those actions.Economic Analysis of SNUR for Alkanes, C 12

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- 6) 16 Economic and Policy Analysis Branch 

### 3. AGENCY COSTS

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

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

3.1 Labor Rates for EPA Staff

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

- Baltimore area published by the Office of Personnel Management effective January 2011 (OPM, 20 11 ). EPA assumes that, on average, a federal GS

- 13, Step 5 full

- time equival ent (FTE) will conduct its collection and

administrative activities under the final rule. 14 The average salary for a GS

- 13 Step 5 employee was $100,904 in 2011 without fringe benefits and overhead costs. In order to derive the fully loaded salary,

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

overhead (EPA, 2009c) , which results in a fully loaded annual salary of $161,446 (see Table 10 ). Dividing the fully loaded annual salary by 2,080 hours (i.e., the number of hours in a work year) yields an

estimated hourly FTE wage rate of $77.62.

Fully loaded costs for Agency labor are shown in Table 10

.

Table 10 : Derivation of Loaded Agency Wage Rates

Labor Category Data Source for Wage

Information Date Wage Fringe

Benefit Fringes as

% wage Overhead

as % wage Fringe +

overhead

factor Loaded

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

EPA staff

FTE Annual federal staff cost:

OPM Washington

Baltimore

- Northern Virginia, DC

- MD

- PA

VA

- WV, area, GS

- 13 Step 1 pay rates a Jan

2011 $ 100,904 (annual)

-- [Included

in 60% overhead] 60% b 1.60 $1 61

, 446 (annual)

$47.36 (hourly) $7 7.62 (hourly)

Notes :

a The Agency salary is the unloaded federal GS

- 13 Step 5 salary ($ 100,904 for 20 11 ), from the OPM salary table for the Washington

- Baltimore

- Northern Virginia Locality Pay Area ( OPM 20 11 )

. Hourly rates are based on annual salary divided by 2,080 hours.

b The 60% fringes

- and

- overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) ( EPA 1992 , page 30, footnote 9).

3.2 SNUN Processing Costs

The list of review steps, estimates of extramural costs, and the percent of chemicals requiring a particular review step are derived from the costs for processing PMN submissions in Table VII

- 1 of a 1994 EPA report, Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications (EPA, 1994 ). The Agency burden associated with processing a PMN has been adjusted to reflect burden reductions resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that requires the electronic submission of all TSCA section 5 notices. Electronic submissi on of SNUN forms is expected to reduce Agency burden by 16.5 percent (EPA, 2009b, p.28 ).

14 The GS

- 13 S tep 5 is consistent with ICR No. 0574.14 (12/18/2007) ( EPA, 2007a ), which covers PMN SNURs. Use of this grade level follows the approach introduced in EPA , 2007b . That report represented a change from an earlier PMN SNUR economic analysis ( EPA, 2003 ), whic h used an average of GS

- 12 Step 1 and GS

- 12 Step 10

salaries. Deleted: Table 10

Deleted: Table 10Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 17 Economic and Policy Analysis Branch For each review step, the “EPA staff” cost is calculated by multiplying the number of FTEs (in the first column) by the fully loaded hourly salary . This shows EPA staf f cost for chemicals requiring the selected review step.

The Extramural Cost column shows costs for contractor support and other outside purchases for chemicals requiring the selected review step , and is inflated from 1993 prices using the Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) data (BLS, 2012b ). The ECI for total compensation (not seasonally adjusted) of private industry professional and related workers (Series ID CIU2010000120000I)

is used be cause it is the only series with continuo us data since 1985, and that includes professional and technical labor, which perform the majority of Agency extramural activities

. Table 11 contains the derivation of inflation factors for Agency extramural costs.

Table 11 : Derivation of Inflation Factors for Agency Extramural Costs

Item Inflation index source Starting

year Index

for starting

year (a) Index

for

20 11 (b) Inflation

factor (b)/(a) 2

Agency Extramural costs White collar labor; equipment; supplies BLS ECI, Total comp, Private industry, Professional and related

, 4 th Q [BLS 201 2b ] 4 1993 67.0 115.7 1.73

Source:

Bureau of Labor Statistics

. Employment Cost Index

– Total Compensation: Professional and Related Private Industry, Not Seasonally Adjusted. (Series ID: CIU2010000120000I) , extracted March 22, 2012 0 (BLS 201 2 b).

The ‘ Percent of Cases column ’ in Table 12 is a weighting factor applied to reflect the fact that not all chemicals require each review step. For example, in the PMN process, all chemicals require Administrative Prescreening, but not all chemicals require the intensive scrutiny of “Standard Review.” The three types of submissions resulting from a SNUR may have weighting factors that differ from each other and from the weighting factors for PMNs. Changes in weighting factors could caus e actual review costs to be higher or lower than calculated here. For example, some SNUNs require little review because they are determined to be “invalid”

– i.e. not required in the first place. However, often a SNUN may take more Agency time than a typic al PMN because of factors such as the need to retrieve old PMN records from archives, and the likelihood that more data requiring EPA review are submitted with a SNUN than would be submitted on average with a PMN. Resources were not available to update the review hours to reflect the current review process or to tailor the cost estimates to SNUNs. Therefore, for this analysis, the review steps and weighting factors are assumed to be the same as those derived in 1994 for PMNs.

Values in t he ‘ Weighted Cost ’ column are calculated by multiplying the un

- weight ed c osts (EPA staff cost plus extramural costs) by the percentage of cases requiring this review step. Weighted costs are then multiplied by the burden reduction of 16.5 percent to account for burden savings generated electronic submission. This calculation yields total Agency costs of $ 5,066 per SNUN, for submission review and processing, as shown in Table 12 Deleted: Table 11

Deleted: Table 12

Deleted: Table 12Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 18 Economic and Policy Analysis Branch 

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

Review Steps EPA staff (FTE) Cost Extramural Cost 2 Unweighted

Cost Pct. of

Cases Weighted

Cost 3 ePMN

Burden

Reduction 4 Weighted Cost

with ePMN

Burden

Reduction FTE

fraction Cost per

FTE 1 FTE Total

($20 11 ) 1993

dollars 20 11

dollars

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

- (i))

Pre

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

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

CRSS (Chemical Review and Search Strategy) 0.0025 $ 161,446 $ 403.62 $268.00 $462.80 $866 100% $866.42 0.165 $723

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

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

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

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

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

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

Order Development/Negotiation

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

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

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

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

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

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

CBI (Confidential Business Information) Substantiation 0.0004 $ 161,446 $ 64.58 $3.00 $ 5.18 $ 70 100% $6 9.76 0.165 $5 8

TOTAL $ 6,067 0.165 $ 5,066

Notes:

1 GS

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

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

11

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

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

Sources: FTEs per review step, 1993 extramural costs, and percents of cases are from EPA, 1994 Table VII

- 1, GS

- 13 salaries are from OPM 20 11

. Formatted: Font: 9 pt

Deleted: Table 10

Formatted: Font: 9 pt

Deleted: Table 11Economic Analysis of SNUR for Alkanes, C 12

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(CAS RN): 71011

- 12

- 6) 19 Economic and Policy Analysis Branch 3.3 Export Notification Cost

Under TSCA Section 12(b), exporters must notify EPA if they intend to export chemicals subject to SNURs, as described in Section 2.2.7 . The Agency burden and cost due to TSCA §12(b) export

notification result s from three tasks. In the first task, EPA receives export notifications from companies that intend to export one of the chemicals subject to TSCA §12 (b) (EPA, 2009b ). In the second task, EPA staff prepares separate notification letters that are subsequently reviewed and delivered to importing countries, their embassies, or representatives, and to the importing country’s U

. S

. embassies (EPA,

2009b ). (See Table 6 for the cost of mailing one notification). The third task is comprise s EPA staff responses to public inquiries and other TSCA 12(b) activities. The work of responding to non

- routine requests for information and clarification from industry a nd importing countries, and of handling other tasks associated with the TSCA §12(b) program, was estimated to require roughly 400 hours per year (EPA, 2009 b). Since the current rulemaking covers only a very small percent of the chemicals subject to

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

Because it is unknown how many, if any, notifications EPA will receive or send as a result of the current rulemaking, the costs to the Agency are presente d per activity. The estimated burden for the first two Agency activities is provided in Table 13 . To estimate the Agency cost, hourly burdens are mult iplied by the loaded wage rate of a GS

- 13, Step 5, which is derive d in Table 10

.

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

Agency Activity Hours per Activity FTE per

Activity 1 Loaded Mailing

Cost Total Agency Cost per

Activity GS

- 13, Step 5 FTE Wage Rate (a) (b) = (a)/2,080 (c) (d) (e) = ((b)*(c))+(d)

Process an incoming

notification from an exporting compan y 0.1 0 0.000048 $1 61,446 $0.00 $ 7.76

P repare and mail a

notification to an importing countr y 0.5 0 0.000240 $1 61,446 $13.75 $ 5 2.56

Notes :

1 The burden associated with an Agency activity is the burden for the Agency to process one incoming notification, or to prepare and mail an outgoing notification

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

burdens a re from EPA 2009 b , updated for inflation. Deleted: Table 13

Deleted: Table 10

Formatted: Font: Times New Roman, 10 pt Deleted: Table 10

Formatted: Font: Times New Roman, 10 pt, Font color:

Auto Deleted: Table 7Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 20 Economic and Policy Analysis Branch 

### 4. BENEFITS

A SNUN submission provides EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs. It allows the Agency to take immediate action to mitigate an activity that the Agency deems harmful to the environment or human health. The final SNUR allows EPA to evaluate the use of, or exposure to these chemicals and allow s the Agency to take preventive action to limit or prohibit any Significant New Use.

EPA r equires additional information to fulfill its mandate under TSCA to fully assess the risks posed by the production, sale, and use of C 12

- 13 chloro alkanes in the United States. A SNUN submission provides EPA with the opportunity to evaluate the intended us e and, if necessary, to prohibit or limit that activity

before it occurs. This is especially important in this case because C 12

- 13 chloro alkanes has been found to be harmful to aquatic life

, and there is no current US production or importation of the chem ical. Therefore, the SNUN allows EPA to monitor any planned production or processing of the chemical and if

necessary to continue to keep the chemical from being used in the United States. T he final rule may also restrict future production, exposu re, and r elease of the chemical , as a company may choose to

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

Quantification of the benefits of the final rule will require more specific information about each u ser’s use patterns and preferences as well as the changes in these patterns and preferences that will result from the

additional information made available under the final rule. These data are not readily available and collecting such data will be cost

- pro hibitive.Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 21 Economic and Policy Analysis Branch 

### 5. ADDITIONAL ANALYSES

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

various statutes and executive orders.

5.1 Regulatory Flexibility Act Pursuant to section 605(b) of the Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et seq .), the Agency hereby certifies that promulgation of this SNUR will not have a significant adverse economic impact on a

substantial number of small entities. The rationa le supporting this conclusion is as follows. The requirement to submit a SNUN applies to any person (including small or large entities) who intends to engage in any activity described in the rule as a significant new use. Where a use is new, by definition no small or large entities presently eng age in such activities. Although some small entities may decide to manufacture or process a substance for the new use after the SNUR is promulgated, EPA receives very few SNUNs, and few of those are submitted by smal l entities. In response to the promulgation of SNURs covering over 1

, 000 chemical substances, the Agency receives only a handful of SNUNs per year. For example, the number of SNUNs was four in Federal fiscal year 2005, eight in FY2006, six in FY2007, eigh t in FY2008, seven in FY2009, two in 2010, and ten in 2011 (EPA, 2012), for an average of 6 per year from all SNURs. EPA has no reason to believe that this SNUR will alter the pattern of SNUN submissions that EPA has historically seen. In addition, the est imated reporting cost for submission of a SNUN is minimal regardless of the size of the firm, averaging about $8, 6 00 including SNUN recordkeeping and reporting costs. The Agency currently offers some relief to certain small businesses

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

the SNUN submission fee from $2,500 to $100. This lower fee reduces the cost of submitting a SNUN to about $ 6,200 for smaller firms. During the six year period from 2005

- 2 010, only three submitters self

identified as small in their SNUN submission 15 (EPA, 2012). EPA believes the cost of submitting a

SNUN is relatively small compared to the cost of developing and marketing a chemical new to a firm and that the requirement to submit a SNUN generally does not have a signific ant economic impact.

EPA believes that the potential economic impact of complying with a SNUR is not expected to be significant or adversely affect a substantial number of small entities

.

5.2 Unfunded Mandates Reform Act

The final rule does not impose any enforceable duty, contain any unfunded mandate, or otherwise have any effect on small governments because none of the current producers of the subject chemicals are governments. Additionally, it is not expecte d that any governments will initiate production of these

chemicals.

5.3 Paperwork Reduction Act

According to the Paperwork Reduction Act (PRA), 44 U.S.C. 3501 et seq., an Agency may not conduct or sponsor, and a person is not required to respond to a collectio n of information that requires OMB approval under the PRA, unless it has been approved by OMB and displays a currently valid OMB

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

in the Federal Register

, are listed in 40 CFR, part 9, and included on the related collection instrument, or form, if applicable. The information collection requirements related to this action have already been approved by OMB pursuant to the PRA under OMB control number s 2070

- 003 8 (EPA ICR No. 1188)

and 2070

- 0030 (EPA ICR No. 0795).

If an entity were to submit a SNUN to the Agency, the annual burden is estimated to average 98.2 hours per response: 0.82 hours for rule familiarization ( Section 2.2.1 ), 2.80 hours for CDX registration, CDX

15 The three “small” submitters were identified by review of actual SNUN submissions from the years 2005

- 2010.Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 22 Economic and Policy Analysis Branch electronic signature, and pay.gov account setup ( Section 2.2.2 ), 92.2 hours for form completion, submission and recordkeeping under CFR §721.40 (Sections 2.2.3 and 2.2.4 ), 1 hour for consumer notifications (Section 2.2.5 ) and 1.36 hours for export notification (Sectio n 2.2.7 ). The burdens for rule familiarization, CDX registration, CDX electronic signature, pay.gov account setup form completion, submission, and recordkeeping ar e approved under EPA ICR No. 1188 (OMB control number 2070

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

2070

- 0030).

5.4 Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Popu lations and Low

- Income Populations

Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority Populations and Low Income Populations” (59 FR 7629, February 16, 1994), establishes federal executive policy on environmental justice. Its main provision directs federal agencies, to the greatest extent practicable and permitted by law, to make environmental justice part of their mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or env ironmental effects of their programs, policies, and activities on minority populations and low

- income populations in the United States.

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

hazards and risk s associated with various chemicals manufactured and used at high production volumes. Although not directly impacting environmental justice

- related concerns, this information will enable the Agency to better protect human health and the environment, includ ing in low

- income and minority

communities.

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

Risks

Executive Order 13045, Protection of Children from Environmental Health Risks and Safety Risks (62 FR 19885, April 23, 1997), requires EPA to identify and assess environmental health and safety risks that may disproportionately affect children. This type of analysis is required for rules that will have an impact of $100 million or more only. The impact of this SNUR wil l be less than $100 million and therefore no analysis of such impacts on children is required

.

5.6 Executive Order 13132: Federalism

Executive Order 13132, entitled Federalism (64 FR 43255, August 10, 1999), requires EPA to develop an accountable process to ensure “meaningful and timely input by State and local officials in the development of regulatory policies that have federalism implications.” Policies that have federalism implications are defined in the E xecutive Order to include regulations that have “substantial direct effects on the States, on the relationship between the national government and the States, or on the distribution of power and responsibilities among the various levels of government” (64 FR 43255, August 10, 1999).

The final rule establishes reporting and recordkeeping requirements that apply to manufacturers (including importers) and processors of certain chemicals. EPA has no information to indicate that any state or local government ma nufactures or processes the chemical substances covered by this action.

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

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

, November 6, 2000). This rule does not have Tribal implications because EPA has no information to indicate that any tribal government manufactures or processes the chemical substances covered by this

action

.Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 23 Economic and Policy Analysis Branch 5.8 Executive Order 13211: Actions that Significan tly Affect Energy Supply, Distribution, or Use

This rule is not subject to Executive Order 13211, entitled Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution, or Use (66 FR 28355, May 22, 2001), because this action is not expected to affect energy supply, distribution, or use

.Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 24 Economic and Policy Analysis Branch 

### 6. REFERENCES

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– Total Compensation: Professional and Related Private Industry, Not Seasonally Adjusted. (Series ID: CIU2010000120000I (B)), extracted March 22, 2012. Available at: http:/data.bls.gov/cgi

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OPPTS/EPA B.)

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2000.Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

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- 6) 26 Economic and Policy Analysis Branch EPA, 2002a U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Revised Economic Analysis for the Amended Inventory Update Rule: Final Report. Washington, DC. August 2002.

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

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. Washington, DC, 2003. Available in docket E PA

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November 2005

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- HQ

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8

- 0017 at : http://www.regulations.gov

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EPA, 2006a. Inventory Update Reporting (IUR): Non

- Confidential 2006 TSCA Inventory Update Rule (IUR) Records . Available at: http://cfpub.epa.gov/iursearch/index.cfm?s=chem . Accessed April

9

, 2009.

EPA, 2007a. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis

Branch. Economic Analysis of Expedited Signific ant New Use Rules for 38 Chemical Substances (EPA Docket OPPT

- 2006

- 0898 ), August 17, 2007.

EPA, 2007b. U.S. EPA, Office of Pollution Prevention and Toxics

, ICR No. 0574.14. [Information Collection Request for] Pre

- Manufacture Review Reporting and Exemption Requirements for New Chemical Substances and Significant New Use Reporting Requirements for Chemical Substances: Supporting Statement for a Request for OMB Review under The Paperwork

Reduction Act , December 6, 2007.

EPA, 2009a. U.S. EPA, Office of Pollut ion Prevention and Toxics, Economic and Policy Analysis

Branch . Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule

. (EPA

- HQ

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- 0296) . July 13, 2009.

EPA, 2009b. U.S. EPA, Office of Pollution Prevention and Toxics. ICR No.: 0795.13 [Information Collection Request for] Notification of Chemical Exports

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

. Available at http://ww w.regulations.gov

. Accessed March 6, 2009.

EPA, 2009c. U.S. EPA, Office of Chemical Safety and Pollution Prevention. Short

- Chained Chlorinated Paraffins (SCCPs) and Other Chlorinated Paraffins Action Plan. Available at: http://www.epa.gov/opptintr/existingchemicals/pubs/actionplans/sccps_ap_2009_1230_final.pdf

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En vironmental Protection Act, 1999

. Canada Gazette

. September 20, 2008, 142 (38).Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

- 12

- 6) 27 Economic and Policy Analysis Branch HELCOM. 2002. Helsinki Commission. Baltic Marine Environment Protection Commission. Project Team for the Implementation of the HELCOM Objective with regard to Hazardous Substances 7th Meeting. March 11

- 13, 2002. Final Report.

IARC. 1990. International Agency for Research on Cancer. Monographs on the Evaluation of Carcinogenic Risks to Humans. Volume 48. Some Flame Retardants and Textile Chemicals,and Exposures in the Tex tile Manufacturing Industry Summary of Data Reported and Evaluation. World Health Organization: Paris, France.

Klaunig, J.E., Babich, M.A., Baetcke, K.P. Cook, J.C., Corton, J.C., David, R. M., DeLuca, J.G., Lai, D.Y., McKee, R. H., Peters, J.M., Roberts, R.A. and Fenner

- Crisp, P.A. (2003). PPARα Agonist

Induced Rodent Tumors: Modes of Action and Human Relevance

. Crit. Rev. Toxicol . 33: 655

- 780. NTP. 1986a. National Toxicology Program. Department of Health and Human Services. Toxicology and Carcinogenesis Studies of Chlorinated Paraffins(C 12 , 60% Chlorine) in F344/N Rats and B6C3F 1 Mice. May 1986. Available at: http://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr308.pdf

. A ccessed

Dec ember 11, 2009

.

NTP. 1986b. National Toxicology Program. Department of Health an d Human Services. Toxicology and Carcinogenesis Studies of Chlorinated Paraffins(C 23 , 43% Chlorine) in F344/N Rats and B6C3F 1 Mice. May 1986. Available at: http://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr305.pdf

. A ccessed

Dec ember 11, 2009.

NTP. 2005. National Toxicology Program. Department of Health and Human Services. Report on Carcinogens, Eleventh Edition; Substance Profiles: Chlorinated Paraffins (C 12 , 60% Chlorine)

CAS No. 108171

- 26

- 2. 2005. Available at: http://ntp.niehs.nih.gov/ntp/ro c/eleventh/profiles/s034chlo.pdf

. A ccessed Dec 11, 2009

.

OPM, 2011. Office of Personnel Management, Salary Table 2011

- DCB, Washington

- Baltimore

Northern

- Virginia, DC

- MD

- VA

- WV

- PA. Accessed from http://www.opm.gov/oca/11tables/pdf/DCB.pdf.

Rawie, Carol. 2 009. EPA Office of Pollution Prevention and Toxics. Personal communication with Tulika Narayan and Kimberly Wilson of Abt Associates via e

- mail. February 5, 2009.

Sleemi, 2006. Fehimida Sleemi. U.S. Bureau of Labor Statistics, “Employment Cost Index Publi cation Plans”. Monthly Labor Review. Vol. 129, No. 4, April 2006. available at www.bls.gov/opub/mlr/2006/04/art2full.pdf

UNECE. 2006. United Nations Economic Commission for Europe. Short Chain Chlorinated Paraffins Track B Review for the UNECE LRTAP Task F orce on Persistent Organic Pollutants

– Final Report . May 2006.

UNEP. 2009. United Nations Environment Programme. Stockholm Convention on Persistent Organic Pollutants (POPs). Persistent Organic Pollutants Review Committee. Revised Draft Risk Profile:

Short

- Chained Chlorinated Paraffins . 9 July 2009. UNEP/POPS/POPRC.5/2. Available at: http://chm.pops.int/Convention/POPsReviewCommittee/hrPOPRCMeetings/POPRC5/POPRC5D ocuments/tabid/592/language/en

- US/Default.aspx

. A ccessed December 11, 2009

.

U.S. Postal S ervice (U.S. PS). 201 2 . “Prices” < http://www.usps.com/prices/ >. Accessed January 2012

.Economic Analysis of SNUR for Alkanes, C 12

- 13 , chloro U.S. EPA Office of Pollution Prevention and Toxics

(CAS RN): 71011

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- 6) 28 Economic and Policy Analysis Branch Weinstein, 2004. Harriet G. Weinstein and Mark A. Loewenstein, U.S. Bureau of Labor Statistics.

C omparing Current and Former Industry and Occupation ECEC Series. Originally posted August 25, 2004 at h ttp://www.bls.gov/opub/cwc/cm20040823ar01p1.htmEconomic Analysis of SNUR for Alkanes, C 12

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- 6) 29 Economic and Policy Analysis Branch APPENDIX A

INFLATORS AND WAGE RATESEconomic Analysis of SNUR for Alkanes, C 12

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- 6) 30 Economic and Policy Analysis Branch 

### A. INFLATORS AND WAGE R ATES

This appe ndix describes the derivation of the fully loaded labor rates and inflation factors used in calculating costs of labor, materials, and other inputs. Costs presented in this report are in 2011 dollars

.

A.1 Derivation of Loaded Wage Rates

Unit labor costs a re calculated by adding fringe benefits and overhead to the wage or salary to derive a fully loaded labor cost. The basic method is described in Wage Rates for Economic Analysis of the Toxics Release Inventory Program (EPA, 2002b). The resulting loaded lab or rates are given in Table 15 . Costs are calculated for several labor categories: Managerial, Professional/Technical, Clerical, and EPA staff.

In March 2004, BLS began using the North American Industry Classification System (NAICS) codes instead of the Standard Industrial Classification (SIC) System, and the Standard Occupational Classification (SOC) system instead of the Occupational Classification System (OCS). T he following table shows the crosswalk between old and new occupational titles

.

Table 14 : Detail of Labor Categories Used in the Analysis

EPAB Reports Labor Category BLS Old Title (OCS) BLS New Title (SOC)

Managerial Executive, administrative, and managerial Management, business, and

financial

Professional/Technical Professional specialty and technical Professional and related

Clerical Administrative support, including

clerical Office and administrative support

Source: Employer Costs for Employee Compensation: Changes to NAICS and SOC, Table 2 . ECEC Occupational Comparability between SOC and OCS (BLS, 2006a and Weinstein, 2004 )

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

Production Labor

Wages and fringe benefits for managerial, professional/technical, and clerical labor were taken from the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation (ECEC) data, 16 for

December 2011 , for manufacturing indu stries. 17

The cost of fringe benefits such as paid leave and insurance, specific to each labor category, are taken from the same ECEC series. Fringe benefits as a percent of wages are calculated separately for each labor category. For example, for December 2011 , the average wage rate for professional/technical 18 labor was $ 38.48 ; the average fringe benefit was $ 19.64 . Fringe benefits as a percent of wages were $ 19.64 /$ 38.48

, or approximately 51.0 percent.

An additional loading factor of 17 percent is applied to wages to account for overhead. This approach is used for consistency with Office of Pollution Prevention and Toxics economic analyses for two major

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

Substances: EPA Docket OPPT

- 2003

- 0063 (EPAB, 2007 b )

. 17 Employer Costs for Employee Compensation Supplementary Tables December 2011

. (BLS, 2012 a)

. This follows the approach introduced in EPAB, 2007a. Earlier PMN SNUR economic analyses, such as EPA, 2003 , used ECEC data for “All Goods Producing” sectors (manufacturing, mining, and construction)

. However, the manufacturing sector data seem more relevan t since the SNURs mainly affect the chemicals industry.

18 This follows terminology introduced in EPAB, 2007 b . Earlier SNUR economic analyses used the term “technical” labor. Here the category is called “professional/technical” labor, to make clear how it r elates 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 relat ed” category

. However, the coverage of

the old and new occupational groups is approximately the same

. See the BLS article, C omparing Current and Former Industry

and Occupation ECEC Series (Weinstein, 2004).Economic Analysis of SNUR for Alkanes, C 12

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- 6) 31 Economic and Policy Analysis Branch rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b),

and t he Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a). This overhead loading factor is added to the benefits loading factor, and the total is then applied to the base wage to derive the fully loaded wage. For example , the December 2011 fully loaded wage for professional/technical labor is $ 38.48 × (1+0. 5104 + 0.17) = $ 64.66

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

15

.

A.1. 2 Derivation of Labor Rates for EPA Staff

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

- Baltimore area published by the Office of Personnel Manage ment effective January 201 1 (OPM, 201 1 ). The average salary for one FTE staff member is estimated as the salary for a GS

- 13 Step 5 employee. 19

Multiplying the annual pay by an assumed loading factor of 1.6 to reflect Federal fringe benefits and overhead, t he loaded annual salary of EPA staff was calculated to be $161,446.

The Agency loading factor is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (EPA, 1992, page 30, footnote 9). The 60 percent assumption was labeled “ the benefits multiplication factor” in the EPA Guide, but has been used in many EPA Office of Pollution Prevention and Toxics ICRs to reflect both fringe benefits and overhead for Federal staff. For example, it was used in an August 2000 document supportin g ICR No. 1139.06 (EPA, 2000), with the following explanation:

The annual costs per FTE are derived by multiplying the annual pay rate by 1.6 (the benefits multiplication factor). The multiplication factor used is recommended in EPA’s Office of Policy,

Pla nning, and Evaluation’s Instructions for Preparing Information Collection Requests (ICRs) (June 1, 1992). An EPA internal phone call between Carol Rawie (OPPT/EETD/RIB) and Carl Koch (OPPE/RMD/IMB) on May 3, 1994, indicated that the 1.6 factor included not o nly benefits but also

overhead. (ICR No.1139.06)

19 The GS

- 13 Step 5 is consistent with ICR No. 057 4.14 (12/18/2007), which covers PMN SNURs. Use of this grade level follows the approach introduced in EPAB, 2007a. That report represented a change from the earlier PMN SNUR economic analysis (EPA, 2003), which used an average of GS

- 12 Step 1 and GS

- 12 Ste p 10 salaries.Economic Analysis of SNUR for Alkanes, C 12

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- 6) 32 Economic and Policy Analysis Branch 

### Table 15 : Derivation of Loaded Wage Rates

EPAB Labor Category Data Sources Date Wage Fringe

Benefit Fringes as

% W age Over

head %

W age 2 Fringe +

Overhead

Factor Loaded Wages 1

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

Managerial BLS ECEC , Private Manufacturing

industries

, “Mgt, Business, and

Financial” 3 Dec

- 11 $43.01 $20.40 47.43% 17% 1.64 $70.72

Professional/

Technical BLS ECEC , Private Manufacturing

industries , “Professional and

related“ 3 Dec

- 11 $38.48 $19.64 51.04% 17% 1.68 $64.66

Clerical BLS ECEC , Private Manufacturing

industries, “Office and Administrative Support” 3 Dec

- 11 $17.69 $8.93 50.48% 17% 1.67 $29.63

EPA staff

FTE Annual Federal staff cost: OPM

Washington

- Baltimore

- Northern Virginia, DC

- MD

- PA

- VA

- WV, area,

GS

- 13 Step 5 pay rates, with 60%

overhead. 3 Jan

- 11 $48.51

-- [Included in

60% overhead] 60% 1.6 $77.62

Notes:

1 Wage data ar e rounded to the closest penny in this table; however, in calculations using these numbers for this report, unrounded values were used.

2 An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory Program ( EPA, 2002b ), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002 a ).

3 The salary is unloaded Federal GS

- 13 Step 5 salary for calendar 20 11 , from the Office of Personnel Management salary table for Washington

- Baltimore

- Nort hern Virginia (OPM,

20 11 )

. The 60% fringes

- and

- overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) ( EPA, 1992 , page 30, footnote 9).Economic Analysis of SNUR for Alkanes, C 12

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- 6) 33 Economic and Policy Analysis Branch A.2 Derivation of Inflation Factors

Detailed information on the derivation of the inflation factors used is presented in Table 16 . In 2006, the Bureau of Labor Statistics (BLS) made several changes to the Employ ment Cost Index. The changes are described on a BLS web page, “Change has come to the ECI,” (BLS, 2006c ) and in several April 2006 Monthly Labor Review articles posted on the BLS web site: “Changes affecting the Employment Cost Index: an overview” (Caroll

, 2006 ); “Employment Cost Index Publication Plans” ( Sleemi, 2006 ); and “Seasonal adjustment in the ECI and the conversion to NAICS and SOC” ( Branch, 2006 ).

Under a mandate from OMB, BLS changed its classifica tion of industries and occupations from the

Stand ard Industrial Classification (SIC) and Occupational Classification System (OCS) to the North American Industry Classification System (NAICS) and Standard Occupational Classification (SOC) system. In 2006, BLS adjusted all ECI series to reflect this change

. In addition to changing the industry and occupational classification systems, in 2006, BLS rebased the

ECI from June 1989 = 100 to December 2005 = 100 for all current and historical non

- seasonally adjusted series, including the NAICS and SIC based serie s. (Seasonally adjusted indices, including those in Table

16 of this report, may not exactly equal 100 for December 2005 as a result of the seasonal adjustment.

Seaso nal adjustments are explained in Branch, 2006.)

According to BLS, the official ECI for the years 1975

- 2005 is the SIC

- OCS based series, and for subsequent years, the official ECI is the NAICS

- SOC based series (Sleemi, 2006, p.8). 20

“Starting year” indices in Table 16 continue to be SIC

- OCS based. Current year indices are NAICS

- SOC

based. We use indices from both the NAICS

- SOC and the SIC

- OCS based ECI series because n either series spans the entire period over which testing and other costs need to be inflated.

20 BLS has been publishing the NAICS

- SOC based ECI series since March 2001 and it became official in March 2006. The SIC

OCS based series and NAICS

- SOC series have different series ID numbers, even when they describe essentially the same population. For example the series ID for seasonally adjusted total compensation for all private industry workers is

ECS10002I for the SIC

- OCS series and CIS2010000000000I for the NAICS

- SOC series

. Deleted: Table 16

Deleted: Table 16

Deleted: Table 16Economic Analysis of SNUR for Alkanes, C 12

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- 6) 34 Economic and Policy Analysis Branch Table 16 : Derivation of Inflation Factors

Item Inflation Index Source 1 Starting

Y ear Index for Starting Year (a) Index for

20 11 (b) Inflation

F actor (b)/(a) 2

Agency Extramural costs White collar labor; equipment; supplies BLS ECI, Total comp, Private industry, Professional and

related , 4th Q [BLS, 2012b] 3 1993 67 115.7 1.727

Labels, placards etc. BLS CPI, All urban consumers,

not SA. CUUR0000SA0, Annual [BLS, 2012c] 1997 160.5 224.939 1.401

File cabinet

Photocopies BLS CPI, All urban consumers, not SA. CUUR0000SA0, Annual [BLS, 2012c] 1988 118.3 224.939 1.901 Record keeping materials

Key: BLS = Bureau of Labor Statistics. CPI = Consumer Price Index. ECI = Employment Cost Index. SA = Seasonally Adjusted. Total Comp = Total Compensation (wages/salaries and benefits). 4th Q = Fourth Quarter. “ECS10002I” etc. refer to BLS series Ids.

Notes:

1 In 2006, Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) series “were rebased to December 2005 = 100 from June 1989 = 100.” The change is reflected in the indices in this table and explained on the BLS website, Employment Cost Index News

R elease Text: Employment Cost Index, March 2006 (BLS, 2006b). The Consumer Price Index (CPI) was not rebased.

“Starting year” ECI indices are SIC

- OCS based: Seasonally Adjusted (SA) ECS10002I for private industry All Workers, and not SA

ECU11122I for priva te industry Professional and Related Workers.

After 2006, ECI indices are NAICS

- SOC based: Seasonally Adjusted (SA) CIS2010000000000I for private industry All Workers, and not SA CIU2010000120000I (B) for private industry Professional, and Related workers

.

2 Inflation factors are rounded; however, unrounded values were used in calculations.

3 Beginning with the report Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: EPA Docket

OPPT

- 2009

- 0922 (EPA, 2011b) we began to use the not

- seasonally adjusted CIU2010000120000I for private industry Professional, and Related workers, instead of SA CIS2010000W00000I for private industry white collar workers because BLS retired the “white

collar” series.