1

Economic Analysis of the Significant New Use Rule

for Seven Ethylene Glycol Ethers (Glymes)

(EPA DOCKET EPA-HQ-OPPT-2009-0767)

RIN 2070-AJ52

—Does not contain TSCA CBI—

Prepared by:

Economic and Policy Analysis Branch

Economics, Exposure and Technology Division

Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460
i

Contributors

The EPA analyst responsible for this report was Nishkam Agarwal. Analytical and draft 

preparation support was provided by Abt Associates Inc. under EPA Contract No. EP-W-08-010.
ii

Executive Summary

This report estimates the costs of the Significant New Use Rule (SNUR) that applies to seven

chemicals, collectively known as ethylene glycol ethers (also known as glymes). The specific 

ethylene glycol ethers subject to the SNUR are monoethylene glycol dimethyl ether 

(monoglyme), diethylene glycol dimethyl ether (diglyme), ethylene glycol diethyl ether 

(ethylglyme), diethylene glycol diethyl ether (ethyldiglyme), triethylene glycol dimethyl ether 

(triglyme), diethylene glycol dibutyl ether (butyldiglyme), and triethylene glycol dibutyl ether 

(butyltriglyme). 

A significant new use is defined as any use in a consumer product for three of the ethylene glycol 

ethers, any use in a consumer product except for certain ongoing consumer uses for three ethylene 

glycol ethers, and any uses (consumer or non-consumer) for one of the ethylene glycol ethers. 

Table ES - 1 contains the significant new uses of the seven chemicals. 

Table ES - 1: Significant New Uses of the Seven Ethylene Glycol Ethers

CAS RN Common Name Significant New Use

110-71-4 Monoglyme Any use in a consumer product 

111-96-6 Diglyme Any use in a consumer product

629-14-1 Ethylgyme Any use in a consumer product

112-36-7 Ethyldiglyme 

Any use in a consumer product except as a component of 

inks, coatings and adhesives, or consumer paint/graffiti 

removers

112-49-2 Triglyme 

Any use in a consumer product, except as a solvent in 

consumer adhesives, in brake fluid, as a component of 

consumer paint/graffiti removers, and in consumer paints 

112-73-2 Butyldiglyme Any use in a consumer product except as a component in 

inks, coatings and adhesives, or soldering compounds

63512-36-7 Butyltriglyme Any use of the chemical

All consumer uses that are exempted from the SNUR are confirmed ongoing uses of these 

chemicals in consumer products. A “consumer product” is defined as: “a chemical substance that 

is directly, or as part of a mixture, sold or made available to consumers for their use in or around 

a permanent or temporary household or residence, in or around a school, or in recreation.” To 

identify the confirmed ongoing consumer uses, as well as potential industrial uses, the U.S. 

Environmental Protection Agency (EPA) relied on the TSCA Inventory Update Reporting (IUR) 

information and Chemical Data Reporting (CDR) information combined with direct 

communications with manufacturers, and comments from industry. 

Ethylene glycol ethers are used mostly as industrial solvents, reaction solvents, or processing 

aids, but they have been used in some consumer products. EPA is promulgating the SNUR 

because the agency has concerns for ethylene glycol ethers based on toxicity data for a subset of 

the chemical substances, including reproductive and/or developmental toxicity, genotoxicity and 

adverse blood effects, and believes that individuals could suffer adverse effects from their use. 

EPA remains concerned about the additional ethylene glycol ethers based on a consideration of 

structure-activity relationships, toxicity data and use information. A firm intending to 

manufacture or process any of these seven ethylene glycol ethers for any significant new use 
iii

(described in Section 2.2) would be required to submit a Significant New Use Notice (SNUN), 

incurring an estimated submission cost of $8,589 per chemical1. 

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

manufacture or processing of ethylene glycol ethers for any significant new use as described in 

the SNUR. 

To submit this SNUN, a firm incurs a modest submission cost. EPA does not require the 

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

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

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

SNUR. 

In addition to the firms that make a SNUN submission, the SNUR may also affect firms that do 

not make a submission. By avoiding a significant new use, a firm can avoid submission and 

testing costs but may incur other compliance costs. The firm may also incur “hidden” costs; for 

example, it could forego profitable opportunities to use the chemical in an application that would 

be a significant new use or limit production volume to avoid a significant new use. 

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

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

receives only a handful of SNUNs per year due to SNURs. However, the number of firms 

affected by not making submissions to EPA is not known; therefore, costs are not aggregated 

across the affected entities.

 

1 For small businesses, the estimated cost is $6,089 to complete and submit a SNUN. See section 3.2.3for 

details.
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Table of Contents

Contributors...................................................................................................................................... i

Executive Summary ........................................................................................................................ ii

1 Introduction............................................................................................................................. 1

1.1 Statutory Authority and Significant New Uses under the Final SNUR......................... 1

1.2 Summary of Methodology ............................................................................................. 1

1.3 Organization of this Report............................................................................................ 2

2 Chemical Uses and Potentially Affected Industries................................................................ 3

2.1 Uses of the Seven Subject Ethylene Glycol Ethers........................................................ 4

2.2 Consumer Uses Excluded by the SNUR........................................................................ 6

2.3 Potentially Affected Industries....................................................................................... 6

3 Industry Compliance Costs..................................................................................................... 8

3.1 Wage Rates .................................................................................................................... 8

3.2 Unit Industry Compliance Costs.................................................................................... 9

3.2.1 Rule Familiarization.............................................................................................. 9

3.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup...... 10

3.2.3 Form Completion and Submission Fee ............................................................... 11

3.2.4 Recordkeeping for Companies Choosing to Submit a SNUN............................. 12

3.2.5 Recordkeeping for Companies that do not Submit a SNUN............................... 13

3.2.6 Customer Notification ......................................................................................... 13

3.2.7 Import Certification............................................................................................. 14

3.2.8 Export Notification.............................................................................................. 14

3.3 Summary of Per Submission Costs, by Option............................................................ 17

3.4 Likelihood of SNUN Submission ................................................................................ 18

3.5 Potential for Subsequent Regulatory Actions.............................................................. 18

4 Agency Costs........................................................................................................................ 20

4.1 Labor Rates for EPA Staff ........................................................................................... 20

4.2 SNUN Processing Costs............................................................................................... 20

4.3 Export Notification Cost .............................................................................................. 23

5 Benefits................................................................................................................................. 24

6 Additional Analyses.............................................................................................................. 25

6.1 Regulatory Flexibility Act ........................................................................................... 25

6.2 Unfunded Mandates Reform Act (UMRA).................................................................. 25

6.3 Paperwork Reduction Act (PRA)................................................................................. 25

6.4 Executive Order 13132, Federalism............................................................................. 26

6.5 Executive Order 12898, Environmental Justice........................................................... 26

6.6 Executive Order 13045, Protection of Children........................................................... 26

6.7 Executive Order 13175, Tribal Governments.............................................................. 26

6.8 Executive Order 13211, Energy Supply, Distribution, or Use..................................... 27

6.9 Executive Order 13563, Improving Regulation and Regulatory Review .................... 27

7 References............................................................................................................................. 28

Appendix A: Inflators and Wage Rates......................................................................................... 33
v

List of Tables

Table ES - 1: Significant New Uses of the 14 Ethylene Glycol Ethers........................................... ii

Table 1: CAS Number and Common Name for Ethylene Glycol Ethers Covered by the 

SNUR.................................................................................................................................. 4

Table 2: Excluded Consumer Uses by Chemical................................................................ 6

Table 3: Industries Potentially affected by the SNUR, by NAICS Code ........................... 7

Table 4: Loaded Industry Wage Rates, December 2012 .................................................... 9

Table 5: Rule Familiarization Burden and Cost for SNUR Submitters............................ 10

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

Burden and Cost for First-Time Submitters...................................................................... 11

Table 7: Industry Cost Estimate to Complete the SNUN Form........................................ 12

Table 8: Industry Cost Estimate to Complete and Submit the SNUN Form .................... 12

Table 9: Annual Per-Chemical Costs of Recordkeeping Requirement for Companies that 

Choose not to Submit a SNUN......................................................................................... 13

Table 10: Derivation of Total Mailing Cost for 12 Notices.............................................. 15

Table 11: TSCA 12(b) Export Notification Cost per Notification ................................... 17

Table 12: Compliance Options and Associated Costs Incurred by a Firm Due to the 

SNUR................................................................................................................................ 18

Table 13: Derivation of Loaded Agency Wage Rates...................................................... 20

Table 14: Derivation of Inflation Factors for Agency Extramural Costs ......................... 21

Table 15: Agency Costs for SNUN and Other Submission Review and Processing........ 22

Table 16: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2012$). 23

Table A-1: Derivation of Loaded Wage Rates ................................................................. 35

Table A-2: Derivation of Inflation Factors....................................................................... 37
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1 Introduction

Ethylene glycol ethers are clear, colorless, liquid ethers that are primarily used as solvents or processing 

aids in a wide variety of industrial applications. Ethylene glycol ethers are polar aprotic in nature, 

miscible in water, and hydrocarbon type solvents (Cheremisinoff, 2003). These properties make them 

excellent solvents for organic and inorganic compounds and polymers (Clariant, 2008). In addition, they 

are chemically stable in a wide pH range and may be used in several high-temperature applications 

(Clariant, 2008). 

This report estimates the costs of the Significant New Use Rule (SNUR) that applies to seven ethylene 

glycol ethers. The specific ethylene glycol ethers subject to the SNUR are: monoglyme, diglyme, 

ethylglyme, ethyldiglyme, triglyme, butyldiglyme, and butyltriglyme. 

1.1 Statutory Authority and Significant New Uses under the Final SNUR

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 or processing the chemical substance for that use (15 U.S.C. 

2604(a)(1)(B)).The general SNUR provisions are found at 40 CFR Part 721, Subpart A.

EPA may promulgate a SNUR for a substance when potential use could result in significant changes in 

human exposure or environmental release levels and/or that concern exists about the substance’s health or 

environmental effects (40 CFR §721.170). According to TSCA Section 5(a)(2), the determination that a 

chemical use qualifies as a significant new use must consider all relevant factors, including:

 The projected volume of manufacturing and processing of the chemical substance;

 The extent to which a use changes the type or form of exposure of human beings or the 

environment to a chemical substance;

 The extent to which a use increases the magnitude and duration of exposure of human 

beings or the environment to a chemical substance; and

 The reasonably anticipated manner and methods of manufacturing, processing, 

distribution in commerce, and disposal of a chemical substance.

1.2 Summary of Methodology

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

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

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

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

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

Agency costs include reviewing and processing the data received as a result of the rule. Data sources for 

this analysis include burden estimates derived from previous information collection requests and 

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

supplementary market research to produce an estimate of the universe of affected entities and measure the 

impact of the final rule on small entities.

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

the information it will provide. The benefits analysis was undertaken to address the implicit call for costbenefit balancing contained in TSCA, as well as the requirements of Executive Order 12866.
2

1.3 Organization of this Report

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

contains information on the consumer and industrial uses of the seven chemicals. Chapter 3 presents 

estimates of the industry costs to comply with the final rule, and Chapter 4 provides estimates of the 

government costs associated with the administration of the final rule. Chapter 5 addresses the benefits of 

the final rule. Several additional impact analyses are presented in Chapter 6, including: small entity 

impact analysis, as mandated by the Regulatory Flexibility Act (RFA); a burden hour analysis that

responds to the requirements of the Paperwork Reduction Act (PRA); an analysis of unfunded mandates 

that pertains to the Unfunded Mandates Reform Act (UMRA); an analysis of environmental justice 

implications that addresses the requirements of Executive Order 12898; and an analysis of children’s 

health pertinent to Executive Order 13045. 

Note that all dollar amounts in this analysis are reported in 2012 dollars.
3

2 Chemical Uses and Potentially Affected Industries

The specific ethylene glycol ethers subject to the final SNUR are: monoglyme, diglyme, ethylglyme, 

ethyldiglyme, triglyme, butyldiglyme, and butyltriglyme. For the purposes of this SNUR, a significant 

new use is defined as any use in a consumer product for three of the ethylene glycol ethers (monoglyme, 

diglyme and ethylglyme), and any use in a consumer product except for certain ongoing consumer uses 

for three of the ethylene glycol ethers (ethyldiglyme, triglyme, andbutyldiglyme). For the remaining 

ethylene glycol ether (butyltriglyme), a significant new use is defined as any use (consumer or nonconsumer) of the chemical substance. 

To identify the ongoing consumer uses of these ethylene glycol ethers, as well as potential industrial uses 

of these ethylene glycol ethers, EPA used information reported under the 2006 Inventory Update 

Reporting (IUR) rule and 2012 Chemical Data Reporting (CDR) rule, contacted manufacturers, searched 

business periodicals, searched other available sources, and reviewed industry comments submitted for the 

proposed rule. All uses exempted from the final SNUR are confirmed ongoing uses of these chemicals in 

consumer products. A “consumer product” is defined as: “a chemical substance that is directly, or as part 

of a mixture, sold or made available to consumers for their use in or around a permanent or temporary 

household or residence, in or around a school, or in recreation.” To identify these confirmed uses, EPA 

relied on the IUR and CDR information combined with direct communications with manufacturers. In the 

proposal, EPA distinguished confirmed uses from unconfirmed (reported) uses. Confirmed uses were 

discussed with an industry contact or were provided as comments in response to the proposed SNUR, and 

unconfirmed uses were only identified in chemical dictionaries and other comparable reference materials. 

Some uses that were listed in the proposed rule were not confirmed with industry contacts or in public 

comments to the proposed SNUR as consumer uses, thus they do not appear in the final rule. While these 

products may have some consumer uses, it is likely that they are limited to hobbyists or other marginal 

sets of users. These uses are therefore regarded as primarily industrial or commercial.

Table 1 lists the CAS number, synonym, and Chemical Abstract Index name for the seven ethylene glycol 

ethers subject to the SNUR. 
4

Table 1: CAS Number and Common Name for Ethylene Glycol Ethers Covered by the 

SNUR

CAS 

Number Common Name Chemical Abstract Index Name

Chemicals with Consumer Use as the Significant New Use

110-71-4 Monoglyme or Monoethylene glycol dimethyl 

ether Ethane, 1,2-dimethoxy

111-96-6 Diglyme or Diethylene glycol dimethyl ether Ethane, 1,l'-oxybis[2-methoxy

629-14-1 Ethylene glycol diethyl ether Ethane, 1,2-diethoxy

112-36-7 Ethyldiglyme or Diethylene glycol diethyl ether Ethane, 1,l'-oxybis[2-ethoxy112-49-2 Triglyme or Triethylene glycol dimethyl ether 2, 5, 8, 11-Tetraoxadodecane 

112-73-2 Butyldiglyme or Diethylene glycol dibutyl ether Butane, 1,1'-(oxybis(2,1-ethanediyloxy)]bis

Chemical with Any Use as the Significant New Use

63512-36-7 Butyltriglyme or Triethylene glycol dibutyl 

ether 

5, 8, 11, 14-Tetraoxaoctadecane 

Source: Chemical Abstract Service (CAS)

2.1 Uses of the Seven Subject Ethylene Glycol Ethers 

Monoglyme (CASRN 110-71-4) has no confirmed consumer uses as EPA has determined that ethylene 

glycol ethers as an electrolyte solvent (1 to 5 percent) in sealed lithium ion batteries is not considered a 

consumer use (ERG, 2009a). However sources have confirmed this chemical may have non-consumer 

uses; monoglyme is reported to be included in a process to treat aluminum surfaces to ensure surfaces are 

less reactive (Clariant, 2008). Monoglyme is also reportedly used in the inner and outer layer etching of 

printed circuit board manufacturing (Score Card, 2005); in reactions with strong bases (Ferro, 2009); in 

mixtures where solvent separation and recovery is necessary; as an inert special solvent for certain organo 

metallic reactions (Clariant, 2008); and as a solvent for oligo- and polysaccharides; and in sugar and 

carbohydrate chemistry (Clariant, 2008). Monoglyme has confirmed non-consumer uses as a solvent in 

pharmaceutical production (ERG, 2009a) and the manufacturing process of anti-HIV drugs (Clariant, 

2012a). Monoglyme is also confirmed to be used in the automotive industry for wheel and tire assembly, 

electrolysis fluids, and the valve in tire-pressure monitoring systems and tires, but it is primarily used by 

industry (AAM, 2011; Association of Global Automakers, 2011).

Diglyme (CASRN 111-96-6) has no confirmed consumer uses (Novolyte, 2011). Sources suggested that it 

may have been used as a solvent in printing inks for consumer products, but this use could not be 

confirmed (ERG, 2009a; PNEAC, 1996). Other sources indicate that there may be non-consumer uses of 

diglyme as a solvent in the production of pharmaceutical products (ERG, 2009a), in the production of the 

instrument cluster in automobiles (AAM, 2011), and as a process component in anti-AIDS drugs (ERG, 

2009b). Unconfirmed uses for diglyme under the commercial/consumer category of the 2006 IUR include 

use in automotive care products, paints and coatings2, and adhesives and sealants (EPA, 2006b). Diglyme 

has other unconfirmed, non-consumer uses as a solvent for lithium aluminum hydride and sodium 

borohydride reductions, and in brake fluids (Ferro, 2009).

While EPA has been unable to confirm through the 2006 IUR, 2012 CDR and company contact that there 

are any uses of ethylglyme (CASRN 629-14-1) in a consumer product, there have been unconfirmed 

 

2 The American Coatings Association (ACA) claimed that glymes are not used in the paints and coatings industry in 

its comments on the proposed SNUR (ACA, 2011).
5

consumer uses of ethylglyme as a solvent in consumer paint production (Ash, 2009), as an adhesive 

solvent and polycarbonate swelling agent (Ferro, 2009), in the preparation of “other” polishes and related 

products (Score Card, 2005), as a solvent for ester gum, shellac and some resins and oils, as a reaction 

medium for organic synthesis, and as a solvent and diluent for detergent and dye solvents in non-grainraising stains (HSDB, 2009a).

3 Ethylglyme is confirmed to be used in the automotive industry for the 

composition of audio assembly, electronic component head unit assembly, and the varistor, but it is 

primarily used by industry (AAM, 2011; Association of Global Automakers, 2011). 

Triglyme (CASRN 112-49-2) has confirmed consumer uses as a process solvent in consumer adhesives, 

and as a component in paint/graffiti removers (ERG, 2009b and ERG, 2009a), as a component in brake 

fluid (NIH, 2013), and as a solvent in paint composition (Yamaguchi et al, 1999; ERG, 2009a).4

Confirmed non-consumer uses include as a binding agent in porcelain powders and as a reaction solvent 

for the manufacture of sodium cyanide (ERG, 2009a). Unconfirmed non-consumer uses include as a 

selective solvent for methylation reactions (Clariant, 2012b), use by the automotive industry in the unit 

assembly in the front suspension and carbon ink (AAM, 2011; Association of Global Automakers, 2011). 

Ethyldiglyme (CASRN 112-36-7) has confirmed consumer uses in paint and graffiti removers (Novolyte, 

2011), coatings and adhesives (Novolyte, 2011 and AAM, 2011), and consumer inks (Novolyte, 2011). 

There is also an unconfirmed consumer use in paint and paint varnishes (Score Card, 2005). Confirmed

non-consumer uses include use in automobile receiver assembly radio with navigation display production, 

electronic switches, and silver paste for integrated circuits mounted on plastic circuit boards, display, 

combination meter, or other (AAM, 2011); as a solvent for sealants for navigation touch panels, ink for 

lenses, and audio assembly for automobiles (AAM, 2011); and in electronic parts, glues and sealants, and 

solvents in carbon ink for automobiles (Association of Global Automakers, 2011). It has unconfirmed 

non-consumer uses as a high-boiling solvent for nitrocellulose, resins, and lacquers; as a solubilizer in 

organic synthesis (Ash, 2009); and as a solvent in the production of plastic resins, compounds, and rubber 

chemicals (HSDB, 2009b).

Butyldiglyme (CASRN 112-73-2) has confirmed uses as a component in consumer inks, adhesives, 

coatings, and soldering compounds (Novolyte, 2011). Confirmed non-consumer uses include use as a 

solvent for conductive printing ink and in the production of printed circuit etchants (ERG, 2009a); and 

use by the automotive industry for the control assembly for lift gate power, headlamp assembly, the 

instrument cluster, differential pressure sensor assembly, packaging material, raw materials of ceramics 

for tuners, electrical conduction silver paste in thermal wires, insulation glass (AMM, 2011), dielectric 

substances, and glues and sealants (Association of Global Automakers, 2011). Reported non-consumer 

uses include use in the preparation of and reaction with Grignard reagents, and use in metal extractions 

(Clariant, 2008). 

Butyltriglyme (CASRN 63512-36-7) has no confirmed or reported consumer uses. There were no 

confirmed non-consumer uses, but there was a 1992 reference that the chemical was reportedly used as a 

scrubbing liquid in the removal or recycling of various components of gas streams (Schiller and 

Gmehling, 1992). There was also a 1967 reference to use in the production of methacrylic acid (LONZA 

AG, 1967). It is unknown if butyltriglyme is still used in these applications. 

Unidentified ethylene glycol ethers were reported as being used by the aerospace industry for surface 

preparation of plastics, adhesive bonding applications, specialty coatings, and structural and sound 

dampening foams (Boeing, 2011).

 

3 Novolyte claimed that there are no consumer uses for ethylglyme in its comments on the proposed SNUR 

(Novolyte, 2011).

4 The American Coatings Association (ACA) claimed that ethylene glycol ethers are not used in the paints and 

coatings industry in its comments on the proposed SNUR (ACA, 2011).
6

2.2 Consumer Uses Excluded by the SNUR 

As mentioned above, the SNUR applies to all uses (both consumer and non-consumer uses) of one

ethylene glycol ether, all consumer uses of two ethylene glycol ethers, and all consumer uses of four 

ethylene glycol ethers, with the exception of the specific excluded consumer uses listed in Table 2. It is 

important to note that each excluded consumer use is only for a specific ethylene glycol ether. For 

example, the excluded use as a component of paint/graffiti removers is only an excluded consumer use for 

ethyldiglyme. It is a significant new use for all other ethylene glycol ethers; therefore, the use of any other 

ethylene glycol ether as a component of paint/graffiti removers would be subject to the SNUR. 

Of the seven ethylene glycol ethers, four have no excluded consumer uses: monoglyme, diglyme, 

ethylglyme, and butyltriglyme. Three ethylene glycol ethers have excluded consumer uses: ethyldiglyme,

triglyme, and butyldiglyme (Table 2). 

Table 2: Excluded Consumer Uses by Chemical

Chemical CAS RN Excluded Consumer Uses

Ethyldiglyme 112-36-7

As a component of consumer inks, coatings and adhesives, and 

paint/graffiti removers

Triglyme 112-49-2

As a solvent in consumer adhesives, in brake fluid, as a component of 

consumer paint/graffiti removers, and in consumer paints

Butyldiglyme 112-73-2

As a component of consumer inks, coatings and adhesives, and 

soldering compounds

Notes:

Source: Novolyte Technologies, 2008a-d; ERG, 2009a; ERG, 2009b; NIH 2013; Novolyte, 2011, Yamaguchi 

et al, 1999 and EPA 2013.

 Excluded Consumer Uses for Ethyldiglyme: Ethyldiglyme is used in coatings and 

adhesives manufacturing (Score Card, 2005, AAM, 2011, and Novolyte, 2011). It is also 

used as a solvent in printing inks (Ash, 1996) and in consumer paint and graffiti removers 

(Novolyte, 2011).

 Excluded Consumer Uses for Triglyme: Triglyme is used in consumer adhesives, 

paint/graffiti removers (ERG, 2009b and ERG, 2009a), in brake fluid (NIH, 2013), and in 

consumer paint (Yamaguchi et al, 1999; ERG, 2009a). 

 Excluded Consumer Uses for Butyldiglyme: Butyldiglyme is used in consumer inks, 

adhesives, and coatings, and soldering compounds (Novolyte, 2011).

2.3 Potentially Affected Industries 

EPA may promulgate a SNUR for a substance when potential use could result in significant changes in 

human exposure or environmental release levels and/or that concern exists about the substance’s health or 

environmental effects (40 CFR §721.170). In contrast to Premanufacture Notification (PMN) 

requirements, which apply mainly to manufacturers (40 CFR §720.22), the SNUR can also apply to 

processors, as well as to manufacturers (40 CFR §721.5). 

This SNUR will require manufacturers and processors to notify EPA at least 90 days before commencing 

the manufacture or processing of any of the seven ethylene glycol ethers for any uses not excluded in the 

SNUR (see Section 1.2). 
7

Table 3 provides summary information on the industries potentially affected by this SNUR. Note that the 

table is not intended to be entirely comprehensive; rather it provides a sample of the potentially affected 

industries for illustration purposes. 

Table 3: Industries Potentially affected by the SNUR, by NAICS Code

NAICS Name Description

Primary Manufacturers of Ethylene glycol ethers

325199 

All Other Basic 

Organic 

Chemical 

Manufacturing 

This U.S. industry comprises establishments primarily engaged in 

manufacturing basic organic chemical products (except aromatic 

petrochemicals, industrial gases, synthetic organic dyes and pigments, 

gum and wood chemicals, cyclic crudes and intermediates, and ethyl 

alcohol). 

Industries Using Ethylene glycol ethers

325910 Printing Ink 

Manufacturing 

This industry comprises establishments primarily engaged in 

manufacturing printing and inkjet inks and inkjet cartridges. 

325510 Paint and Coating 

Manufacturing 

This industry comprises establishments primarily engaged in (1) mixing 

pigments, solvents, and binders into paints and other coatings, such as 

stains, varnishes, lacquers, enamels, shellacs, and water repellent 

coatings for concrete and masonry, and/or (2) manufacturing allied 

paint products, such as putties, paint and varnish removers, paint brush 

cleaners, and frit. 

325520 Adhesive 

Manufacturing 

This industry comprises establishments primarily engaged in 

manufacturing adhesives, glues, and caulking compounds. 

336340 

Motor Vehicle 

Brake System 

Manufacturing 

This industry comprises establishments primarily engaged in 

manufacturing and/or rebuilding motor vehicle brake systems and 

related components. 

Source: DOC, 2003, U.S. Department of Commerce, Census Bureau, “2002 NAICS Definitions.”
8

3 Industry Compliance Costs 

The SNUR discussed in this report specifies that any manufacture or processing of the chemicals for a 

designated significant new use will require reporting under section 5(a)(1)(A) of TSCA. Therefore, a firm 

intending to manufacture and/or process any of these chemicals for these applications must submit a 

SNUN. Alternatively, a firm can decide not to manufacture and/or process these chemicals or to 

manufacture and/or process these chemicals in such a way that it is not considered a significant new use. 

The firm, therefore, has two options: 

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

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

processing any one of the seven ethylene glycol ethers for purposes that are not excluded (see 

Table 2 for a list of exclusions by chemical). The firm must submit the SNUN to EPA at least 90 

days before it plans to commence the manufacture and/or processing of the new use of the 

substance; the SNUN provides EPA with the opportunity to evaluate the intended use and, if 

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

processing of any of the seven chemicals for a significant new 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 chemicals, 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 3.2.8 for details).

 Option 2: Comply with SNUR limits (not manufacture and/or process a new use of the 

chemical). The firm may simply decide to not manufacture and/or process any one of the seven

listed ethylene glycol ethers for a significant new use. While this option avoids the costs of 

submitting a SNUN, it may entail the “hidden” cost of the foregone profit as a result of not 

engaging in the commercial activity originally planned, and may involve substituting one of the 

subject chemicals for another, more costly substance. If the firm elects to produce the chemical 

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. In addition, if the 

firm exports any existing stockpiles of the chemicals, it will incur the export notification costs.

The firm may also pursue this option temporarily by complying with SNUR restrictions while 

also pursuing Option 1. Due to the uncertainty related to this option, and EPA’s expectation that 

affected entities will select Option 1; the costs of Option 2 are not fully quantified in this report.

The remainder of this chapter estimates the quantified portion of costs associated with the SNUR for these 

uses of the subject chemicals. Section 3.1 summarizes the wage rates used in this chapter. Section 3.2

provides the unit industry compliance costs, including the costs of rule familiarization, registration with 

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

import certification, and export notification. Total costs under each option are presented in Section 3.3. 

3.1 Wage Rates

The final rule involves activities that may require efforts by employees in three labor classifications: 

managerial, technical, and clerical. Costs for each activity are calculated by estimating the labor hours 

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

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

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

wages and fringe benefits with estimates of overhead rates, following the methodology described in Wage 

Rates for Economic Analysis of the Toxics Release Inventory Program (EPA, 2002b). Wage data for each 
9

labor category in December 2012 are provided by the Employer Costs for Employee Compensation 

(ECEC) Supplemental Tables available on the BLS website (BLS, 2013a). The loaded wage rate is $72.87

for managerial labor; $64.38 for technical labor; and $29.51 for clerical labor. Table 4 presents the basic 

data used to calculate the loaded wage rates for all three categories of labor. Appendix A: provides more 

information on the wage rates and inflators used in this analysis.

Table 4: Loaded Industry Wage Rates, December 2012

Labor 

Category Data Sources Date

Wage

(2012$)

Fringe 

Benefit

(2012$)

Fringes 

as % 

wage

Overhead 

% 

wage2

Fringe + 

overhead 

factor

Loaded 

Wages1

(2012$)

(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

Dec12 $43.95 $21.45 48.81% 17% 1.66 $72.87

Professional/

Technical

BLS ECEC, Private 

Manufacturing 

industries, “Professional 

and related“3

Dec12 $38.53 $19.30 50.09% 17% 1.67 $64.38

Clerical

BLS ECEC, Private 

Manufacturing 

industries, “Office and 

Administrative Support”

3

Dec12 $17.64 $8.87 50.28% 17% 1.67 $29.51

Notes:

1 Wage data are rounded to the closest pennies 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, 2002a).

3 Employer Costs for Employee Compensation Supplementary Tables December 2012, U.S. Bureau of Labor Statistics, March 18, 

2013 (BLS, 2013a).

3.2 Unit Industry Compliance Costs

3.2.1 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, 2009b), which measures the costs of mandatory electronic reporting of 

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

familiarization is $54.84.
10

Table 5: Rule Familiarization Burden and Cost for SNUR Submitters

Reporting 

Activity

Clerical Labor 

(at $29.51/hour)

Technical Labor (at 

$64.38/hour)

Managerial Labor 

(at $72.87 hour)

Total Labor Cost 

(2012 dollars)

Burden Cost Burden Cost Burden Cost Burden Cost

Rule 

Familiarization 0.00 $0.00 0.55 $35.41 0.27 $19.43 0.82 $54.84

Note:

Costs may not equal labor wage rate times burden hours as shown, due to rounding. Unrounded estimates were used during 

the actual cost calculations. 

Source: See Table 4; EPA, 2009b.

3.2.2 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 and/or process 

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

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

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

Notices for genetically modified microorganisms, Notices of Commencement of Manufacture or Import 

(NOCs), and support documents to Section 5 notices) must 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 Epayment account.5 These activities are only required of first-time submitters of any Section 5 notice. 

These activities are estimated to require the following burdens, based on the estimates presented in the 

Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009b):

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

employee to register with CDX, and that an average of four technical staff members and one 

manager will need to register for each company, totaling approximately 0.92 hours of burden per

company.

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

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

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

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

will spend an additional 0.50 hours accessing, preparing, and submitting verification forms 

(Verification of Authorization) for all authorized submitters to EPA. The total burden incurred by 

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

this burden does not include any additional time required to contact EPA’s CDX help desk to 

notify a change of submitter status, should one occur. 

Filing the electronic signature agreement may be done either through mail or electronically. EPA 

believes the cost of electronic filing to be negligible, and the cost of a paper filing via the US 

Postal Service to be $2.60 per company (including five $0.46 stamps and five $0.06 business 

envelopes).

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

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

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

‘submit’ on the form and wait for payment processing.

 

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

analysis are conservative insofar as to include the use of Pay.gov as a required activity.
11

As shown in Table 6, the labor cost associated with CDX registration, CDX electronic signature, and 

Pay.gov account setup by a first-time submitter is $189. As noted above, an additional $2.60 in mailing 

cost per company is attributable to these activities, for a total cost of approximately $192 per company.

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

Cost for First-Time Submitters

Reporting Activity

Clerical Labor 

(at $29.51/hour)

Technical Labor 

(at $64.38/hour)

Managerial Labor 

(at $72.87/hour)

Total Labor Cost

(2012 dollars)

Burden Cost Burde

n

Cost Burde

n

Cost Burden Cost

CDX Registration 0.00 $0.00 0.73 $47.21 0.18 $13.36 0.92 $60.57 

CDX Electronic 

Signature 0.00 $0.00 1 $64.38 0.75 $54.65 1.75 $119.03 

Mailing Cost $2.60 

E-Payment (Pay.gov ID) 0.00 $0.00 0.00 $0.00 0.13 $9.71 0.13 $9.71 

Total 0.00 $0.00 1.73 $112 1.07 $77.72 2.80 $192

Note:

Costs may not equal labor wage rate times burden hours as shown, due to rounding. Unrounded estimates were used during 

the actual cost calculations. 

Source: See Table 4; EPA, 2009b.

3.2.3 Form Completion and Submission Fee

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

submission of SNUN forms is expected to remove all clerical burden and reduce the recordkeeping 
12

burden associated with preparing a SNUN (EPA, 2009b).6In addition, electronic submission is expected 

to generate and 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, 2009b). Table 7 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 $6,089.

Table 7: Industry Cost Estimate to Complete the SNUN Form

Reporting 

Activity

Clerical Labor 

(at $29.51/hour)

Technical Labor 

(at $64.38/hour)

Managerial Labor 

(at $72.87/hour)

Total Labor Cost

(2012 Dollars)

Burden Cost Burden Cost Burden Cost Burden Cost

Form 

Completio

n

0.00 $0.00 74.20 $4,777 18.00 $1,312 92.2 $6,089 

Note:

Costs may not equal labor wage rate multiplied by burden hours as shown, due to rounding.

Source: 

Loaded wages include fringe benefits and overhead. See Table 4 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.

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

Final Rule (EPA, 2009b, page 7)

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

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

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

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

submitting small business must pay a $100 per-SNUN submission fee. Table 8 adds the labor cost and 

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

$8,589 for large business submitters and $6,189 for small business submitters.

Table 8: Industry Cost Estimate to Complete and Submit the SNUN Form

Reporting Population Labor Cost Submission Fee

Total Cost

(2012 Dollars)

Large Business Submitters $6,089 $2,500 $8,589 

Small Business Submitters $6,089 $100 $6,189 

Source: Table 7; EPA, 1994

3.2.4 Recordkeeping for Companies Choosing to Submit a SNUN

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 would be five percent of 

 

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

estimates 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, which include the burden for recordkeeping (EPA, 1994, p. III-14). These burden 

estimates are based on the recordkeeping burden for polymer exceptions and not the recordkeeping burden 

associated with PMN submissions. Therefore, for this analysis we assume that any reduction in recordkeeping 

burden is captured in the reduction of the clerical burden, and we do not consider the one hour recordkeeping burden 

from the ePMN EA in order to avoid double counting.
13

SNUN submission hours, or about five to six hours.7 For this report, the SNUN recordkeeping hours were 

included in the SNUN submission hours (see Section 3.2.3) and the SNUN recordkeeping costs under 40 

CFR §721.40 were not separately estimated.8 

3.2.5 Recordkeeping for Companies that do not Submit a SNUN

If a firm that manufactures or processes a substance subject to the SNUR chooses not to submit a SNUN, 

they must keep records that document compliance with SNUR conditions for avoiding a Significant New 

Use. Such recordkeeping requirements essentially involve copying and filing relevant records, including 

those related to: category of use. Records must be maintained for five years from the date of their creation 

(40 CFR 721.40). For firms that choose to not submit a SNUN, costs for compliance with the 

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

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

pages 10 and 14). EPA used the per-activity burden for reporting category of use presented in the 

Information Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules for Existing 

Chemicals (Renewal) (EPA, 2005b, page 12). Any clerical burden associated with these activities was 

removed to reflect the burden reduction associated with electronic submissions (EPA, 2009a). 

The total recordkeeping burden for a company that does not submit a SNUN is estimated to be 0.15 hours 

and $9.66, and is derived in Table 9. 

Table 9: Annual Per-Chemical Costs of Recordkeeping Requirement for Companies that Choose 

not to Submit a SNUN

Reporting Activity 

Total Burden 

Associated 

per Activity

(Hours)

Percent of 

Reporting Burden 

Attributed to 

Recordkeeping

Recordkeeping Burden

(hours) (2012$)

Category of use1 3 5% 0.15 $9.66 

Source: 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)

3.2.6 Customer Notification

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

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

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

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

could require significantly more burden, it is assumed that manufacturers and processors 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 $64.38 per manufacturer or processor per chemical.

 

7 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 15).

8 SNUN submission costs estimated in Section 3.2.3 of this report were based on PMN submission costs from a 

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

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

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

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

hours for a PMN submission (page III-10 of EPA 1994) included recordkeeping hours.
14

3.2.7 Import Certification

In general, promulgation of a final 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 or processor receiving an imported 

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

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

the shipment are not subject to TSCA.9 The statement must be on or attached to a commercial invoice or 

entry document belonging to the imported shipment.

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

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

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

familiarization burden discussed above.

3.2.8 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 requirement10 per destination country for each exporter of a chemical substance. After 

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

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

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

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

export notification. 

EPA estimated the average burden associated with making a single notification, but did not estimate 

either the total number of exporters of a SNUR chemical or the number of notifications per SNUR 

chemical. This is because the SNURs apply to a variety of different chemicals with a variety of unrelated 

uses, manufacturers, and processors, making it impractical within the resources available for this report to 

assess the potential number of exporters and importing countries per chemical. 

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

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

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

Reduction Act (EPA, 2009c).

 

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

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

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

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

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

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

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

(November 14, 2006, 71 FR 66234).
15

Estimated Number of Annual Export Notifications per Exporter

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

12 notifications per year.

11 This includes notifications resulting from SNURs and notifications resulting 

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

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

combination, and one notification mailing often includes multiple chemicals and/or destination countries.12

The percent of notifications resulting from SNURs in general is unknown, and it is also unknown how 

many notifications may result from this rulemaking, as not all manufacturers may choose to export a 

chemical, or they may make several notifications for a single chemical. 

Exporter Costs

The 2009 TSCA Section 12(b) ICR (EPA, 2009b, page 11, Table 3), estimated the annual export 

notification cost for an exporter under the one-time export notification requirement. These costs include 

the cost to the exporter of compiling a list of their products that are subject to TSCA Section 12(b) 

requirements, writing or revising an export notification letter to EPA, checking the outgoing shipments, 

and sending the notification letters with the associated shipping costs.

The per-notification cost was calculated based on the average burden per firm. Exporters who make a 

larger number of notifications per year may benefit from economies of scale and have lower costs per 

notification; conversely firms making fewer notifications may have a higher cost per notification.

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 (USPS) as 

first-class registered mail with a return receipt (USPS, 2013). The estimated per-shipment and annual 

mailing costs incurred by individual submitters are detailed in Table 10.

Table 10: Derivation of Total Mailing Cost for 12 Notices

Postal Service Cost

Registered mail, regular, with $0 declared value $11.20

Return receipt, requested at time of mailing (receive by mail) $2.55

Postage, regular First Class, up to 1 ounce $0.46

Cost per export notice - Subtotal $14.21

× 12

Total Mailing Cost for 12 Notices $171

Source: Mailing rates are from the US Postal Service web site as of April 2013 (https://www.usps.com/ship/servicechart.htm). The mailing method comes from the Economic Analysis of the Proposed Change to TSCA Section 12(b) Export 

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

8).

Note: Calculations may be rounded.

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 

 

11EPA 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.
16

subject to TSCA §12(b) export notification. Respondents need only check for new regulations 

promulgated and any new products exported by the company. Updating the list is estimated to take an 

average of one hour of technical time, which may also include some proportion of legal time (EPA, 

2009c). The total burden can vary from two hours per year up to two hours per month, depending on the 

number of products exported by the company and the number of their products subject to TSCA §12(b) 

(EPA, 2009c).

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

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

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

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

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

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

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

(EPA, 2009c).

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

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

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

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

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

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

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

notifying EPA and providing the required data must be printed and mailed within the required time 

period. This process is estimated to take an average one half hour of clerical time per export notification 

or six hours for 12 notifications (EPA, 2009c).

The burdens and associated costs for each notification activity are provided in Table 11. EPA estimates 

that the burden associated with making one notification is approximately 1.36 hours and $84.58. 
17

Table 11: TSCA 12(b) Export Notification Cost per Notification

Technical Clerical Total

$/Hr Hours 2012$ $/Hr Hours 2012$ Hours 2012$

Compile list $64.38 9.3 $599 -- -- -- 9.3 $599 

Write letter $64.38 1 $64 -- -- -- 1 $64 

Check order and send 

notice -- -- -- $29.51 6 $177 6 $177 

Mailing cost1-- -- -- -- -- -- -- $171

Total per average facility2`

10.30 $663 6.00 $177 16.30 $1,010.

69

Total per Notification $0.86 $55.26 0.50 $14.76 1.36 $84.22

Notes:

Costs may not equal labor wage rate times burden hours as shown due to rounding. Unrounded estimates were used during the 

actual cost calculations. 

1 Mailing costs reflect April 2013 USPS rates and can be found in Table 10.

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

Source: Appendix A of this report derives technical and clerical hourly labor costs. Other costs are from 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, 2009c, p.10), and are updated to 2012 dollars. 

3.3 Summary of Per Submission Costs, by Option

The number of firms affected by not making submissions to EPA is not known; therefore, costs are not 

aggregated across the affected entities. The following table summarizes the costs to comply with the rule 

amendment, as described in more detail in section 3.2 above.
18

Table 12: Compliance Options and Associated Costs Incurred by a Firm Due to the SNUR

Option1 Costs Quantified Costs per Chemical (2012$)2

1.

Electronic 

submission of a 

Significant New Use 

Notice (SNUN), 

indicating to EPA 

that the firm would 

like to manufacture

or process the 

chemical for a 

Significant New Use 

as defined in the 

SNUR.

Costs of submitting a SNUN, 

including rule familiarization, 

CDX registration (for 

companies that are first-time 

submitters), form completion,

user fee, export notification, 

and any test costs.

$54.84 rule familiarization cost; $8,589 submission cost 

(including SNUN recordkeeping and fee $2,500 for large 

businesses). EPA usually receives well under ten SNUNs 

per year. Export notifications costs are estimated at $84.22

per notification; total cost per company will vary. First 

time submitters would incur $191.91 for CDX registration 

and associated activities. Companies manufacturing or 

processing a chemical currently used in commerce in the 

United States will incur a cost $64.38 for notifying 

consumers of SNUR regulatory activities. 

2.

Manufacture or 

process in a way that 

avoids a Significant 

New Use.

Cost of the profit foregone as 

a result of not engaging in the 

commercial activity originally 

planned (opportunity costs), 

recordkeeping, and export 

notification costs. 

Opportunity costs are not quantified. Other costs include 

rule familiarization ($54.84), recordkeeping ($9.66), and 

export notification costs ($84.22 per notification) may 

apply. Recordkeeping costs include costs for use type and 

marketing and production volume. 

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

or processing the chemical.

2 Quantified costs are attributable to the SNUR only if a firm would not otherwise follow the specified practices. Costs are detailed in 

Section 3.2.

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

possession and/or describe any other available data. Because EPA does not require the development of test data, EPA assumes that no 

firms will incur testing costs as a result of the SNUR.

3.4 Likelihood of SNUN Submission

This analysis assumes that very few entities are expected to submit a SNUN. EPA has, over the years, 

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

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

year (FY) 2007, and eight in FY2008, seven in FY2009, two in FY2010, and ten in FY201113. In addition, 

as discussed in Chapter 2, current consumer uses are excluded; thus, all of the chemicals subject to this 

rule are currently not being used for any significant new use. This suggests that it is unlikely that a firm 

will submit a SNUN.

3.5 Potential for Subsequent Regulatory Actions 

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

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

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

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

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 

 

13 Count of SNUN Submissions as tracked in EPA’s Confidential Business Information Tracking System (CBITS). 

February, 2012 (EPA, 2012).
19

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

SNUN is being reviewed). 

Should the Agency’s review of the SNUN result in further regulatory actions, the Agency will 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. 
20

4 Agency Costs

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

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

4.1 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 2012 (OPM, 2012). EPA assumes 

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

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

$100,904 in 2012 without fringe benefits and overhead costs. In order to derive the fully loaded salary, 

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

overhead (EPA, 2009d), which results in a fully loaded annual salary of $161,446 (see Table 13). 

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

hourly FTE wage rate of $77.62.

Fully loaded costs for Agency labor are shown in Table 13.

Table 13: 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-BaltimoreNorthern Virginia, DC-MDPA-VA-WV, area, GS-13 

Step 5 pay rates, with 60% 

overheads a.

Jan 

2012

$100,904

(annual)

--

[Included 

in 60% 

overhead]

60% b 1.60

$161,446.40

(annual)

$48.51

(hourly)

$77.62

(hourly)

Notes:

a The Agency salary is the unloaded federal GS-13 Step 5 salary ($100,904 for 2012),from the OPM salary table for the 

Washington-Baltimore-Northern Virginia Locality Pay Area (OPM, 2012). 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, 2009d).

4.2 SNUN Processing Costs 

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

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

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

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

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

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

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

 

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

grade level follows the approach introduced in EPA, 2007b. That report represented a change from an earlier PMN SNUR 

economic analysis (EPA, 2003), which used an average of GS-12 Step 1 and GS-12 Step 10 salaries.
21

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

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

review step. 

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

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

Statistics (BLS) Employment Cost Index (ECI) data (BLS, 2013b). The not seasonally adjusted ECI for 

total compensation of private industry professional and related workers (Series ID CIU2010000120000I) 

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

technical labor, which perform the majority of Agency extramural activities. Table 14 contains the 

derivation of inflation factors for Agency extramural costs.

Table 14: Derivation of Inflation Factors for Agency Extramural Costs

Item Inflation Index Source1 Starting 

year

Index for 

starting 

year

(a)

Index 

for 

2012

(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 , 2013b]3

1993 67.0 117.7 1.76

Notes:

1

In 2006, Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) series “were rebased to December 2005 = 100 

from June 1989 = 100.” The change is reflected in the indices in this table and explained on the BLS website, Employment 

Cost Index News Release Text: Employment Cost Index, March 2006 (BLS, 2006b). The Consumer Price Index (CPI) was 

not rebased.

2 Inflation factors are rounded to three decimal places in this table, but calculations in this report use the unrounded values. 

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

Docket OPPT-2009-0922 (EPA, 2011), 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.

Source: Bureau of Labor Statistics (BLS), 2013b. Employment Cost Index Historical Listing Continuous Occupational and 

Industry Series September 1975 – March 2013. Accessed May 22, 2013 from http://bls.gov/web/eci/ecicois.pdf. 

The Percent of Cases column in Table 15 is a weighting factor applied to reflect the fact that not all 

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

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

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

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

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

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

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

from archives, and the likelihood that more data requiring EPA review is 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.

The Weighted Cost column is calculated by multiplying the un-weighted Costs (EPA staff cost plus 

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

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

This calculation yields total Agency costs of $5,086, per SNUN, for submission review and processing, as 

shown in Table 15.
22

Table 15: Agency Costs for SNUN and Other Submission Review and Processing

Review Steps

EPA staff (FTE) Cost Extramural Cost 2

Unweighted 

Cost

Pct. of 

Cases

Weighted 

Cost3

ePMN 

Burden 

Reduction4

Weighted 

Cost with 

ePMN 

Burden 

Reduction

FTE 

fraction

Cost per 

FTE 1

FTE Total 

($2012)

1993 

dollars

2012

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 $4.00 $7.04 $395 41% $161.76 0.165 $135 

Administrative prescreen/ 

notice receipt/user fee 0.0024 $161,446 $387 $92.00 $161.92 $550 100% $549.78 0.165 $459 

CRSS (Chemical Review and 

Search Strategy) 0.0025 $161,446 $404 $268.00 $471.68 $876 100% $876.42 0.165 $732 

SAT (Structure Activity Team) 0.0006 $161,446 $96.87 $14.00 $24.64 $122 100% $121.57 0.165 $102 

Engineering/Exposure 0.0015 $161,446 $242 $56.00 $98.56 $341 100% $340.96 0.165 $285 

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

Focus 0.0009 $161,446 $145 $23.00 $40.48 $186 100% $185.88 0.165 $155 

Standard Review Functions 0.0219 $161,446 $3,536 $511.00 $899.36 $4,437 29% $1,286.78 0.165 $1,074 

Division Directors Meeting 0.0129 $161,446 $2,083 $113.00 $198.88 $2,282 15% $342.30 0.165 $286 

Order 

Development/Negotiation 

Review

0.0171 $161,446 $2,761 $22.00

$38.72 $2,800 3% $83.99 0.165 $70 

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

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

New Chemical SNUR 

Development 0.0277 $161,446 $4,472 $85.00 $149.60 $4,622 7% $323.54 0.165 $270 

Notices of Commencement 0.0012 $161,446 $194 $40.00 $70.40 $264 31% $81.93 0.165 $68 

FOIA (Freedom of Information 

Act) Requests 0.0333 $161,446 $5,376 $287.00 $505.12 $5,882 1% $58.82 0.165 $49 

CBI (Confidential Business 

Information) Substantiation 0.0004 $161,446 $64.58 $3.00 $5.28 $70 100% $69.87 0.165 $58 

TOTAL $6,091 $5,086 

Notes:

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

2 Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated from 1993 prices using Table 14. 

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

4 Electronic submission is expected to generate a cost savings of 16.5% to the Agency (EPA 2009c, 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, 2012.
23

4.3 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 3.2.8. The Agency burden and cost due to TSCA §12(b) export 

notification result 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, 2009c). 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 US embassies (EPA, 2009c). 

(See Table 10 for the cost of mailing one notification). The third task is comprised of EPA staff responses 

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

information and clarification from industry and importing countries, and of handling other tasks 

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

2009c). Since the current rulemaking covers only a very small percent of the chemicals subject to TSCA 

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

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

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

activities is provided in Table 16. To estimate the Agency cost, hourly burdens are multiplied by the 

loaded wage rate of a GS-13, Step 5, which is derived in Table 16. 

Table 16: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2012$)

Agency Activity

Hours per 

Activity

FTE per 

Activity1

Loaded Mailing 

Cost

Total Agency Cost 

per Activity GS-13, Step 5 

FTE Wage Rate

(a) (b) = 

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

Process an incoming 

notification from an 

exporting company

0.1 0.00005 $161,446 $0.00 $7.76 

Prepare and mail a 

notification to an 

importing country

0.5 0.00024 $161,446 $14.21 $53.02 

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: Appendix A of this report derives Agency labor costs. Mailing costs are from Table 10 of this report. Other burdens 

are from 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 2009c), updated for inflation.
24

5 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. 

EPA is concerned about the reproductive and/or developmental toxicity, genotoxicity and adverse blood 

effects of certain ethylene glycol ethers and believes that individuals could suffer adverse effects from 

their use. In addition, based on a consideration of structure, along with toxicity and use information, EPA 

remains concerned about additional structurally similar ethylene glycol ethers the might be anticipated to 

show similar toxicity. EPA further believes that the use of any of these chemical substances in consumer 

products, beyond the limited, on-going current uses, could significantly increase the magnitude and 

duration of exposure to humans and the environment over that which would otherwise exist and that such 

increase should not occur without opportunity for EPA review. The SNUR allows EPA to address the 

potential health effects that may result from exposures to the chemicals in consumer products, by 

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

to limit or prohibit any Significant New Use. EPA also expects that the rule may restrict future uses or 

exposure to the chemicals, as a company may choose to modify planned uses for a chemical in such a way 

that does not trigger a SNUR, as opposed to submitting a SNUN. Therefore, the SNUR may limit future 

exposure to the chemicals. 
25

6 Additional Analyses

6.1 Regulatory Flexibility Act 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

EPA believes that the potential economic impact of complying with a SNUR to be minimal, and will not 

adversely affect a substantial number of small entities

6.2 Unfunded Mandates Reform Act (UMRA)

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

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

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

chemicals.

6.3 Paperwork Reduction Act (PRA)

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

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

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

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

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

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

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

This action does not impose any burden requiring additional OMB approval. If an entity were to submit a 

 

15 The three “small” submitters were identified by review of actual SNUN submissions from the years 2005-2010.
26

SNUN to the Agency, the annual burden is estimated to average 97.66 hours per response: 0.82 hours for 

rule familiarization (Section 3.2.1), 2.80 hours for CDX registration, CDX electronic signature, and 

pay.gov account setup (Section 3.2.2), 92.2 hours for form completion, submission and recordkeeping 

(Sections 3.2.3), 1 hour for consumer notifications (Section 3.2.6) and 1.36 hours for export notification 

(Section 3.2.8).

6.4 Executive Order 13132, Federalism

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

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

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

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

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

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

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

of certain chemicals. EPA has no information to indicate that any state or local government manufactures 

or processes the chemical substances covered by this action.

6.5 Executive Order 12898, Environmental Justice

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

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

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

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

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

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

The information collected under this rule, if finalized, will assist EPA and others in determining the 

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

volumes. Although not directly impacting environmental justice-related concerns, this information will 

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

minority communities.

6.6 Executive Order 13045, Protection of Children

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

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

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

impact of $100 million or more only. The impact of this SNUR will be less than $100 million and 

therefore no analysis of such impacts on children is required.

6.7 Executive Order 13175, 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.
27

6.8 Executive Order 13211, 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.

6.9 Executive Order 13563, Improving Regulation and Regulatory Review 

Executive Order 13563, Improving Regulation and Regulatory Review (76 FR 3821, January 21, 2011), 

requires EPA to base regulations on the best available science, allow for public participation and the open 

exchange of ideas, promote predictability and reduce uncertainty, identify and use the best, most 

innovative, and least burdensome tools for achieving regulatory ends, consider both the costs and benefits 

qualitatively and quantitatively and ensure regulations are accessible, consistent, written in plain 

language, and easy to understand.

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

processors of certain chemicals. Consistent with EO 13563, this document qualitatively and quantitatively 

describes both the costs and benefits of the rule as well as the underlying data used in the analyses. EPA 

chose the best available data to analyze the costs and benefits described in this document and the best 

analytic approaches given the available data and other constraints.
28

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Use, Federal Register, Volume 66, May 22, 2001. 

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30

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DC, 2003. Available in docket EPA-HQ-OPPTS2002-0078 at http://www.regulations.gov. 

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by Chemical, including Manufacturing, Processing and Use Information 

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No.: 2070-0014 [Information Collection Request for] Pre-Manufacture Review Reporting and 

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the Paperwork Reduction Act, December 6, 2007.

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Economic Analysis of Expedited Significant New Use Rules for 65 Chemical Substances (EPA Docket 

OPPT-2003-0063), December 4, 2006 (Revised March 12, 2007).

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Economic Analysis of Expedited Significant New Use Rules for 38 Chemical Substances (EPA Docket 

OPPT-2006-0898), August 17, 2007

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(EPA-HQ-OPPT-2008-0296). July 13, 2009.

EPA, 2009b. U.S. EPA, Office of Pollution Prevention and Toxics. EPA ICR No.: 0795.13 OMB Control 

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

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Act. March 6, 2009 at http://www.regulations.gov.

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Handbook EPA’s Guide to Writing Information Collection Requests under the Paperwork Reduction 

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at: http://www.epa.gov/oppt/pfoa/pubs/pfoainfo.html (Accessed August 24, 2009).

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System (CBITS). February, 2012.

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Database. 2013.
31

ERG, 2009a. Personal Communication between Eastern Research Group (ERG) and Joe Valcho, 

Novolyte Technologies. June 2009. 

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33

Appendix A: Inflators and Wage Rates

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

calculating costs of labor, materials, and other inputs. Costs for this report are for year-end 2012

A.1 Derivation of Loaded Wage Rates 

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

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

Release Inventory Program (EPA, 2002b). The resulting loaded labor rates are given in Table A-1. Costs 

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

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

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

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

table shows the crosswalk between old and new occupational titles. 

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, clerical and production labor were taken 

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

for December, for manufacturing industries.17

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

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

category. For example, for December 2012, the average wage rate for professional/technical18 labor was 

$38.53; the average fringe benefit was $19.30. Fringe benefits as a percent of wages were $19.30/$38.53, 

or approximately 50.1 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, 2007a). 

17 ECEC Supplemental Tables December 2012 (BLS, 2013a). This follows the approach introduced in EPAB, 2007a. Earlier 

PMN SNUR economic analyses, such as EPA, 2003, used ECEC data for “All Goods Producing” sectors (manufacturing, 

mining, and construction). However, the manufacturing sector data seem more relevant since the SNURs mainly affect the 

chemicals industry.

18 This follows terminology introduced in EPAB, 2007a. Earlier SNUR economic analyses used the term “technical” labor. Here 

the category is called “professional/technical” labor, to make clear how it relates to BLS categories. In 2004, BLS changed 

from the Occupational Classification System, OCS, to the Standard Occupational Classification system, SOC. In the process, 

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

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

and Occupation ECEC Series (Weinstein, 2004).
34

rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b), 

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

This overhead loading factor is added to the benefits loading factor, and the total is then applied to the 

base wage to derive the fully loaded wage. For example, the December 2012 fully loaded wage for 

professional/technical labor is $38.53 × (1+0.5009 + 0.17) = $64.38.

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

shown in Table A-1.

A.1.3 Derivation of Labor Rates for EPA Staff

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

published by the Office of Personnel Management effective January 2012 (OPM, 2012). The average 

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

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

overhead, the loaded annual salary of EPA staff was calculated to be $161,446. 

The Agency loading factor is from an EPA guide, Instructions for Preparing Information Collection 

Requests (ICRs) (EPA, 1992, page 30, footnote 9). The 60 percent assumption was labeled “the benefits 

multiplication factor” in the EPA Guide, but has been used in many EPA Office of Pollution Prevention 

and Toxics ICRs to reflect both fringe benefits and overhead for Federal staff. For example, it was used in 

an August 2000 document supporting ICR No. 1139.06 (EPA, 2000), with the following explanation:

“The annual costs per FTE are derived by multiplying the annual pay rate by 1.6 (the benefits 

multiplication factor). The multiplication factor used is recommended in EPA’s Office of Policy, 

Planning, and Evaluation’s Instructions for Preparing Information Collection Requests (ICRs)

(June 1, 1992). An EPA internal phone call between Carol Rawie (OPPT/EETD/RIB) and Carl 

Koch (OPPE/RMD/IMB) on May 3, 1994, indicated that the 1.6 factor included not only benefits 

but also overhead.” (ICR No.1139.06)

 

19 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007), which covers PMN SNURs. Use of this grade level 

follows the approach introduced in EPAB, 2007a. That report represented a change from the earlier PMN SNUR economic 

analysis (EPA, 2003), which used an average of GS-12 Step 1 and GS-12 Step 10 salaries.
35

Table A-1: Derivation of Loaded Wage Rates

EPAB 

Labor 

Category

Data Sources Date Wage Fringe 

Benefit

Fringes as % 

Wage

Overhead % 

Wage2

Fringe + 

Overhead 

Factor

Loaded Wages1

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

Managerial

BLS ECEC, Private Manufacturing 

industries, “Mgt, Business, and 

Financial”3

Dec-12 $43.95 $21.45 48.81% 17% 1.66 $72.87

Professional/

Technical

BLS ECEC, Private Manufacturing 

industries, “Professional and 

related“3

Dec-12 $38.53 $19.30 50.09% 17% 1.67 $64.38

Clerical

BLS ECEC, Private Manufacturing 

industries, “Office and 

Administrative Support”3

Dec-12 $17.64 $8.87 50.28% 17% 1.67 $29.51

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.4

Jan-12 $100,904

(annual) --

[Included in 

60% 

overhead]

60% 1.6 $161,446.40

(annual)

Notes:

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

2An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b), and the Revised Economic 

Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a).

3 Employer Costs for Employee Compensation Supplementary Tables December 2012, U.S. Bureau of Labor Statistics, March 18, 2013 (BLS, 2013a).

43The Federal salary is the unloaded Federal GS-13 Step 5 salary ($100,904) for 2012, from the Office of Personnel Management salary table for Washington-Baltimore-Northern 

Virginia (OPM, 2012). The 60% fringes-and-overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (EPA, 1992, page 30, footnote 9).
36

A.2 Derivation of Inflation Factors

Complete information on the derivation of the inflation factors used is given in Table A-2. In 2006, the 

Bureau of Labor Statistics (BLS) made several changes to the Employment Cost Index. The changes are 

described on a BLS web page, “Change has come to the ECI,” (BLS, 2006c) and in several April 2006 

Monthly Labor Review articles posted on the BLS web site: “Changes affecting the Employment Cost 

Index: an overview” (Caroll, 2006); “Employment Cost Index Publication Plans” (Sleemi, 2006); and 

“Seasonal adjustment in the ECI and the conversion to NAICS and SOC” (Branch, 2006).

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

Standard Industrial Classification (SIC) and Occupational Classification System (OCS) to the North 

American Industry Classification System (NAICS) and Standard Occupational Classification (SOC) 

system. In 2006, BLS adjusted all ECI series to reflect this change. 

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

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

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

A-2 of this report, may not exactly equal 100 for December 2005 as a result of the seasonal adjustment. 

Seasonal adjustments are explained in Branch, 2006.) 

According to BLS, the official ECI for the years 1975-2005 is the SIC-OCS based series, and for 

subsequent years, the official ECI is the NAICS-SOC based series (Sleemi, 2006, p.8).20

“Starting year” indices in Table A-2 continue to be SIC-OCS based. Current year indices are NAICSSOC based. We use indices from both the NAICS-SOC and the SIC-OCS based ECI series because 

neither series spans the entire period over which testing and other costs need to be inflated. 

 

20 BLS has been publishing the NIACS-SOC based ECI series since March 2001 and it became official in March 2006. The SICOCS based series and NAICS-SOC series have different series ID numbers, even when they describe essentially the same 

population. For example the series ID for seasonally adjusted total compensation for all private industry workers is 

ECS10002I for the SIC-OCS series and CIS2010000000000I for the NAICS-SOC series. 
37

Table A-2: Derivation of Inflation Factors

Item Inflation Index Source1 Starting 

Year

Index for 

Starting Year 

(a)

Index for 

2012

(b)

Inflation 

Factor 

(b)/(a)2

Export notification

BLS ECI, ,Total comp, Private 

industry, Professional and 

related, 4th Q [BLS, 2013b ]

3

1992 64.9 118.2 1.821

Agency Extramural costs 

White collar labor; 

equipment; supplies

BLS ECI, Total comp, Private 

industry, Professional and 

related, 4th Q [BLS, 2013b]

3

1993 67 118.2 1.76

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

not SA. CUUR0000SA0, Annual 

[BLS, 2013a]

1997 160.5 229.594 1.430

File cabinet

Photocopies BLS CPI, All urban consumers, 

not SA. CUUR0000SA0, Annual 

[BLS, 2013a]

Record keeping materials 1988 118.3 229.594 1.941

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. 

Notes:

1 In 2006, Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) series “were rebased to December 2005 = 100 from June 

1989 = 100.” The change is reflected in the indices in this table and explained on the BLS website, Employment Cost Index News 

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

“Starting year” ECI indices are SIC-OCS based: Seasonally Adjusted (SA) ECS10002I for private industry All Workers, and not SA 

ECU11122I for private industry Professional and Related Workers. 

After 2006, ECI indices are NAICS-SOC based: Seasonally Adjusted (SA) CIS2010000000000I for private industry All Workers, and

not SA CIU2010000120000I (B) for private industry Professional, and Related workers. 

2

Inflation factors are rounded to three decimal places in this table, but calculations in this report use the unrounded values. BLS CPI 

values were published with one decimal place through 2006 and with three decimal places after that.

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

OPPT-2009-0922 (EPA, 2011) 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.