1



# Economic Analysis o f the Significant New Use Rule
f or 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 20460i 

## Contributors

The EPA analyst responsible for this report was Nishkam Aga r wal . 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)

, d iethylene glycol dimethyl ether ( diglyme )

, e thylene glycol diethyl ether ( ethylglyme )

, d iethylene glycol diethyl ether ( ethyldiglyme )

, t riethylene glycol dimethyl ether ( triglyme )

, d iethylene glycol dibutyl ether ( butyldiglyme ) , and t riethylene glycol dibutyl ether ( butyltriglyme )

. A signifi cant ne w 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 ex cept 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, coati ngs 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 confi rmed 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
communicatio ns 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 fr om their use.
EPA remains concerned about the additional ethylene glycol ethers b ased 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 useiii

(described in Section 2.2 ) would be required to submit a Significant New Use Notice (SNUN), incurring an estimate d submission cost of $ 8,589 per chemical 1

.

The SNUR w ill 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 n ot 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 signific ant 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 3.2.3 for
details.iv 

## 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 Glyco l 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

................................ ................................ ......................... 33v 

## List of Tables

Table ES

- 1: Significant New Uses of the 14 Ethylene Glycol Ether s

................................ ........... 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

................................ ................................ ....... 371 

## 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 chemic ally 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 eth ers 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 dete rmine 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 reas onably 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 identifyi ng 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 repor ting 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. D ata 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 e stimate of the universe of affected entities and measure the impact of the final rule on small entities.

In addition to costs, t his report qualitatively discusses the benefits of the final rule based on the value of the information it will provide. The ben efits analysis was undertaken to address the implicit call for cost

benefit 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 supp ort 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 cost s 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 th e 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 a n analysis of children’s
health pertinent to Executive Order 13045.

Note that all dollar amounts in this analysis are reported in 20 1 2 dollars.3



## 2 Chemical Uses and Potent ial ly Affected Industries

The specific ethylene glycol ether s 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 ethe rs ( 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, and butyl d iglyme ). For the remaining ethylene glycol ether (butyltriglyme), a significant new use is defined as any use (consumer or non

consumer) 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 ether s , 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 subm itted 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 availab le 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 manuf acturers. In the proposal, EPA distinguished confirmed uses from unconfirmed (reported) uses . C onfirmed 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 rul e . 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 Ether s 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

- ethoxy

112

- 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 Ether s

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). H owever sources have confirmed this chemical may have non

- consumer

use s; monoglyme is reported to be inclu ded 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 C ard, 2005); in reactions with strong ba ses (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). M onoglyme has confirmed non

- consumer uses as a solvent in pharmaceutical production (ERG, 2009a) and the manufacturing process of anti

- HIV drugs (Clariant,
2012 a ) . Monoglyme is also confirmed to be used in the automotive industry for whee l 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 (Novoly te, 2011). Sources suggested that it

may have been use d 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 u ses for diglyme under the commercial/consumer catego ry of the 2006 IUR include use in automotive care products, paints and coatings 2 , and adhesives and sealants (EPA, 2006b). Diglyme
has other unconfirmed, non

- consumer use s 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 ha ve been unconfirmed

2 The American Coatings Association (ACA) claimed t hat glymes are not used in the paints and coatings industry in its comments on the proposed SNUR (ACA, 2011).5

consumer use s 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

- grain

raising 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).

T riglyme (CASRN 112

- 49

- 2) has confirmed consumer uses as a process solvent in consumer adhesives,
and as a component in paint/ graffiti remov ers (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, 2012 b ) , use by the automotive industry in the unit

as sembly 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, 2 011), 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,
electroni c 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 use s 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 compou nds (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 seal ants ( 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)

. T here 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 ether s 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 A ssociation (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 co nsumer 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 ether s , four have no excluded consumer uses: monoglyme, diglyme, ethylglyme, and butyltriglyme. Three ethylene glycol ether s 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
solder ing 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 C ard, 2005

, AAM, 2011 , and Novolyte, 2011 ) . It is also
used as a s olvent in printing inks (Ash, 1996 ) and in consumer paint and graffiti removers (Novolyte, 2011)

.

 Excluded Consumer Uses for Triglyme: Tr i glyme is used in consumer adhesives, paint/ graffiti remov ers (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 exis ts 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 manufactur ers (40 CFR §721.5).

This SNUR w ill 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 E thylene 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 E thylene 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 requir e reporting under section 5(a)(1)(A) of TSCA

. Therefore, a firm intending to manufacture and/or process any of th ese chemical s for these applications must submit a
SNUN

. Alternatively, a firm can decide not to manufacture and/or process th e s e chemical s 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 SNU N 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

s ubject 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 wi th the SNUR for these
uses of the subject chemicals

. Section 3.1 summarize s 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

, complet ing the SNUN form

, submission fee

, import certification, and export notification

. Total costs under each option are presented in Sectio n 3.3

.



### 3.1 Wage Rates

The final ru le 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 bur dens 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 I nventory Program (EPA, 2002b). Wage data for each9

labor category in December 201 2 are provided by the Employer Costs for Employee Compensation (ECEC) Supplemental Tables available on the BLS website (BLS, 201 3 a ). The loaded wage rate is $ 7 2. 87 for manageri al 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 t hree 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 201 2

Labor Category Data Sources Date Wage (201 2 $) Fringe

Benefit ( 2012$ ) Fringes

as %

wage Over

head
%

wage 2 Fringe +
overhead
factor Loaded

Wages 1 ( 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 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

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 Ame nded 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 Analys is 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 (201 2 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

. F irst

- 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 S ection 5 notices ) must register their company and key users with the CDX reporting tool, deliver a CDX electronic signature to EPA, and establish a nd use a Pay.gov E

payment account. 5 These activities are only required of first

- time submitters of any S ection 5 notice

. These activities are estimated to require the following burdens, based on the estimates presented in the Economic Analysis of the Prem anufacture 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 a uthorized 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 Servic e to be $2. 60 per company (including five $0.4 6 stamps and five $0.0 6 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 $18 9 . 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

(201 2 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 marg inal 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 199 4 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
f orm 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 recordkeeping12

burden associated with preparing a SNUN (EPA, 2009b ). 6 In 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 (201 2 D ollars )

Burden Cost Burden Cost Burden Cost Burden Cost

Form Completio

n 0.00 $0.00 74.20 $4,777 18.00 $1,31 2 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; h owever, 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 smal l business submitters.

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

Reporting Population Labor Cost Submission Fee Total Cost (201 2 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 repor ts have assumed that SNUN recordkeeping hours would be five percent of

6 The Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009 a )
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) . T hese burden
estimates are based on the recordkeeping bur den 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 o ne 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 relevan t 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 esti mated 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 i n 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 associate d 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 Activi ty (Hours) Percent of

Reporting Burden
Attributed to Recordkeeping Recordkeeping Burden

(hours) (201 2 $)

Category of use 1 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 acco mplished 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 SNU N recordkeeping costs at 5.67 hours (ICR 118.08, page 1 5 ).

8 SNUN submission costs estimated in Section 3.2.3 of this report were based on PMN subm ission 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 T SCA 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.

I mport 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 impo rter. 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
notifi cation requirement 10 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 associate d 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 d ifferent chemicals with a variety of unrelated uses, manufacture r s, 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 t he ( 2009 TSCA Section 12(b) ICR )

, ICR No.: 0795.13
OMB Control Number 2070

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

- TSCA Section 12(b) Supporting Statement for Request for OMB Review under the Paperwork
Reduction Act (EPA, 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
offe ring 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 CF R 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 t han 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 notificat ions 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 annu al 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 e xport 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 mai ling 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, 201 3 ). The estimated per

- shipment and annual mailing costs incurred by in dividual submitters are detailed in Table 10

.

Table 10 : Derivation of Total Mailing Cost for 12 Notices

Postal S ervice Cost Registered mail, regular, with $0 declared value $1 1

. 20 Return receipt, requested at time of mailing (receive by mail) $2. 5 5
Postage, regular First Class, up to 1 ounce $0.4 6
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 201 3 ( https://www.usps.com/ship/service

chart.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

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

12 Based on review by an E PA 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 hou rs per month, depending on the number of products exported by the company and the number of their products subject to TSCA §12(b) (EPA, 2009c ).

The number of submitters per year who report under TSCA §12(b) has varied over time, rising from
around 160 in 1 991 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 aver age 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 exper ience 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. C ompanies 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 tim e 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 $8 4

. 58

.17

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

Technical Clerical Total $/Hr Hours 201 2 $ $/Hr Hours 201 2 $ Hours 201 2 $ 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 cost 1

-- -- -- -- -- -- -- $ 171 Total per average facility 2` 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

. 2 An 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 cos ts. 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 201 2 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

Option 1 Costs Quantified Costs per Chemical ( 20 12 $) 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 Sign ificant
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 famili arization ($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 manufa cturing 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 fir m 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 t hat 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 exampl e, 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 FY2011 13 . 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 determi ne 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 rev iewed).

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 201 2 (OPM, 201 2 ). EPA assumes that, on average, a federal GS

- 13, Step 5 full

- time equivalent (FTE) will conduct its collection and

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

- 13 Step 5 employee was $100,904 in 201 2 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 annu al 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
hourl y FTE wage rate of $77.62.

Fully loaded costs for Agency labor are shown in Table 13

.

Table 13 : Derivation of Loaded Agency Wa ge Rates

Labor Category Data Source for Wage

Information Date Wage Fringe
Benefit Fringes

as %

wage Overhead

as %

wage Fringe +

overhead
factor Loaded

Wages

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

EPA staff

FTE Annual Federal staff cost: OPM Washington

- Baltimore

Northern Virginia, DC

- MD

PA

- VA

- WV, area, GS

- 13 Step 5 pay rates, with 60%
overheads a

. Jan

201 2 $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 201 2 ),from the OPM salary table for the Washington

- Baltimore

- Northern Virginia Locality Pay Area (OPM, 201 2 ). 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 perc ent 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 s ubmission 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 L abor Statistics (BLS) Employment Cost Index (ECI) data (BLS, 201 3 b ). T he not seasonal ly adjusted E CI 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 Source 1 Starting

year Index for

starting

year (a) Index

for
20 1 2 (b) Inflation
factor (b)/(a) 2

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

, 4 th Q [BLS , 201 3 b] 3 1993 67.0 11 7

. 7 1. 7 6

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 Rel ease 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, ins tead of SA CIS2010000W00000I for private industry white collar workers because BL S 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 caus e actual review costs to be higher or lower than calculated here. For example, some SNUNs require little review because they are determined to be “invalid”

– i.e. not required in the first place. However, often a SNUN may take more Agency time than a typic al PMN because of factors such as the need to retrieve old PMN records from archives, and the likelihood that more data requiring EPA review 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 $5,0 86 , 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

Cost 3 ePMN

Burden
Reduction 4 Weighted

Cost with
ePMN
Burden
Reduction FTE
fraction Cost per

FTE 1 FTE Total

($20 1 2 ) 1993

dollars 201 2

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 $6,0 91 $5,0 8 6

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

4 Electronic submission is expected to generate a cost savings of 16.5% to the Agency (EPA 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, 201 2

.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 th e 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 U S embassies (EPA, 2009c ). (See Table 10 for the cost of mailing one notification). The third task is comprised of EPA staff responses to public inquiri es 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 roughl y 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 derive d in Table 16

.

Table 16 : TSCA 12(b) Export Notification Cost: Agency Burden per Activity (201 2 $)

Agency Activity Hours per

Activity FTE per

Activity 1 Loaded Mailing
Cost Total Agency Cost

per Activity GS

- 13, Step 5 FTE Wage Rate

(a) (b) =

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

Process an incoming
notification from an exporting 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 ether s 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 ether s the might be anticipated to show similar toxicity

. EPA further believes that the use of any of these che mical 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 occu r 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 t ake 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 i n 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

.2 5 

## 6 Additional Analys es

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 t o 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 ent ities 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 subst ances, 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
th e 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 self

identified as small in their SNUN submission 15 (EPA, 201 2). 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 th e 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
chemical s.



### 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 c ollection 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 burde n 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 9 7 .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 E xecutive Order to include regulations that have “substantial direct effects on the States, on the relationship between the national government and the States, or on the distribution of power and responsibilities among the various levels of government” (64 FR 43255, August 10, 1999).

The 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), establish es 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, d isproportionately 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 assi st 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 Ag ency 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 1 9885, 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 t his 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, Novembe r 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, distribut ion, 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 le ast 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 d ata 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 

## 7 References

15 U.S.C. 272, National Technology Transfer and Advancement Act of 1995 (NTTAA), Public Law 104

– 113, Section 12(d).

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, Part 707, Title 40, July 1,
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, Part 720, Title 40, July 1, 2003.

40 CFR 721, Significant New Use of Chemical Substances , Code of Federal Regulations

, Part 721, Title
40 , July 1, 2003.

59 FR 7629, Federal Actions to Address Environmental Justice in Minority Populations and Low

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62 FR 19885, Protection of Children from Environmental Health Risks and Safety Risks, Federal Register, Volume 62, April 23, 1997.

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

66 FR 28355, Actions Concerning Regulations that Significantly Affect Energy Supply, Distribution, or
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, Volume 71, November 14, 2006. Available in docket EPA

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BLS, 2013 b

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

. BLS, 2013 b . Bureau of Labor Statistics. Employment Cost Index

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

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Clariant, 2008. “Ethyle ne glycols,mono and dialkyl glycol ethers.” Available at: http://www.glymes.com/C125691A003596E5/vwLookupDownloads/Functional%20Flui ds_Etylenglykole.pdf/$FILE/Functional%20Fluids_Etylenglykole.pdf.

Clariant 2012 a . “Monoglyme.” Accessed July 24, 2012 from http://www.glymes.clariant.com/C12576720021BF8F/vwWebPagesByID/DC511A8F2C8F16DDC12
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.
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. Washington, DC: U.S. EPA/OPPT/EETD/RIB, September 9, 1994. (OTS/RIB later became OPPTS/EPAB.)

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Branch. Wage Rates for Economic Analysis of the Toxics Release Inventory Program. Washington, DC, June 10, 2002.

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- 0898), August 17, 2007

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

. (EPA

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- 2008

- 0296). July 13, 2009.

EPA, 2009b. U.S. EPA, Office of Pollution Prevention and Toxics. EPA ICR No.: 0795.13 OMB Control
Number 207

0

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

- TSCA Section 12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction
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. EPA, 2009c. U.S. EPA, Office of Environmental Information, Collection Strategies Division, ICR
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## Appendix A: I nflators 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 Sys tem (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 cos t 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 201 2 , the averag e wage rate for professional/technical 18 labor was $ 3 8

. 5 3 ; the average fringe benefit was $ 1 9

. 30

. Fringe benefits as a percent of wages were $ 1 9. 30 /$ 3 8

. 5 3

, or approximately 50.1 percent.

An additional loading factor of 17 percent is applied to wages to acco unt 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, 2013 a)

. This follows the approach introduced in EPAB, 2007a. Earlier
PMN SNUR eco nomic 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 t erminology 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 Cla ssification 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, C omparing 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 Econo mic 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 2 01 2 fully loaded wage for professional/technical labor is $ 38.53 × (1+0.5 009 + 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 201 2 (OPM, 201 2 )

. 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 gu ide, 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 Over

head % Wage 2 Fringe +

Overhead
Factor Loaded Wages 1

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

Managerial BLS ECEC , Private Manufacturing

industries

, “Mgt, Business, and
Financial” 3 Dec

- 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:

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

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

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

4 3 The Federal salary is the unloaded Federal GS

- 13 Step 5 salary ($100,904) for 201 2 , from the Office of Personnel Management salary table for Washington

- Baltimore

- Northern Virginia (OPM, 201 2 ). 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 ) a nd in several April 2006 Monthly Labor Review articles posted on the BLS web site: “Changes affecting the Employment Cost Index: an overview” (Caroll

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

Under a mandate from OMB, BLS changed its classifica tion of industries and occupations from the 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 t he
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 fo r 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 NAICS

SOC based

. We use indices from both the NAICS

- SOC and the SIC

- OCS based ECI series because neither series spans the entire period over which testing and other cos ts need to be inflated.

20 BLS has been publishing the NIACS

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

OCS based series and NAICS

- SOC series have different series ID numbers, even when they describe essentially the same population. For example the series ID for seasonally adjusted total co mpensation 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 Source 1 Starting
Year Index for Starting Year (a) Index for

20 1 2 (b) Inflation

Factor (b)/(a) 2

Export notification BLS ECI, ,Total comp, Private industry, Professional and
related , 4 th Q [BLS, 201 3 b ] 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 , 4 th Q [BLS, 201 3 b ] 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

, 201 3a ] 1988 118.3 229.594 1.941 Record keeping materials

Key: BLS = Bureau of Labor Statistics. CPI = Consumer Price Index. ECI = Employment Cost Index. SA = Seasonally Adjusted. Total Comp = Total Compensation (wages/salaries and benefits)

. 4th Q = Fourth Quarter.
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
Relea se 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 P rofessional, 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, 201 1 ) we began to use the not

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

- collar”
series

.