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INFORMATION COLLECTION REQUEST (ICR)

SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

STRATOSPHERIC OZONE PROTECTION

1. Identification of Information Collection

a) Title: Significant New Alternatives Policy (SNAP) Program Final Rulemaking under Title VI of 

the Clean Air Act Amendments of 1990 (OMB Control Number: 2060-0226)

b) Short Characterization

Title VI of the Clean Air Act Amendments of 1990 (the Act) implements the obligation of the 

United States under the Montreal Protocol on Substances that Deplete the Ozone Layer to 

phase out the use of ozone-depleting substances. Section 612 of the Act requires the U.S. 

Environmental Protection Agency (EPA) to develop a program for evaluating alternatives to 

ozone-depleting substances. This program is known as the Significant New Alternatives Policy 

(SNAP) program. The five major provisions of Section 612 are:

Rulemaking: Section 612(c) requires EPA to enact rules making it unlawful to replace any Class 

I or II substance with any substitute that the Administrator determines may present adverse 

effects to human health or the environment where an alternative has been identified that (1) 

reduces the overall risk to human health and the environment, and (2) is currently or potentially 

available.

Listing of Unacceptable/Acceptable Substitutes: Section 612(c) also requires EPA to publish a 

list of the substitutes prohibited for specific uses. EPA must publish a corresponding list of 

acceptable alternatives for specific uses as well.

Petition Process: Section 612(d) grants the right for any person to petition EPA to add or delete 

a substance from the lists published in accordance with Section 612(c). EPA has 90 days to 

grant or deny a petition.

90-day Notification: Section 612(e) authorizes EPA to require any person who produces a 

chemical substitute for a Class I substance to notify EPA not less than 90 days before the new 

or existing chemicals are introduced into interstate commerce for significant new uses as 

substitutes for a Class I substance. The producer must also provide EPA with all unpublished 

health and safety studies on such substitutes.

 Clearinghouse: Section 612(b)(4) requires EPA to set up a public clearinghouse of alternative 

chemicals, product substitutes, and alternative manufacturing processes that are available for 

products and manufacturing processes which use Class I and II substances.

EPA issued regulations on March 18, 1994, in 59 FR 13043, which are codified at 40 Code of 

Federal Regulations (CFR) Part 82, Subpart G (Section 82.170 et seq.), establishing the SNAP 

program. EPA’s major activities in the SNAP program are to review proposed substitutes based 

on the risk-assessment criteria and the procedures set forth in the regulations, and to publish 

(and update) lists of acceptable and unacceptable substitutes by end use categories.
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The information required for collection under the SNAP regulations is described below in 

Section 4 of this statement, and is currently approved by OMB for use through August 30, 2014.

2. Need for and Use of the Collection 

a) Authority for the Collection

Information required to be collected under the SNAP program is intended to fulfill the general 

mandate in Section 612(c) that states the Administrator shall promulgate rules providing that it

shall be unlawful to replace any class I or class II substance with any substitute substance 

which the Administrator determines may present adverse effects to human health or the 

environment, where the Administrator has identified an alternative to such replacement that (1) 

reduces the overall risk to human health and the environment; and (2) is currently or potentially 

available. Section 612 (42 U.S.C. 7671k) is attached as Appendix B, and EPA’s implementing 

regulations (40 CFR Part 82, Subpart G, Sect. 82.170 et seq.) are attached as Appendix C.

b) Use/Users of the Data

EPA's Stratospheric Protection Division (SPD) uses the information submitted to evaluate the 

health and environmental effects of proposed alternatives for industrial and commercial uses 

that have historically used Class I and Class II ozone-depleting substances. 

3. Non-duplication, Consultations, and Other Collection Criteria 

a) Non-duplication

The specific information requested by this notice is not currently collected by EPA or any other 

government agency. According to the United Nations Environment Programme (UNEP) report, 

Environmental Effects of Ozone Depletion and its Interactions with Climate Change: 2010 

Assessment, EPA’s SNAP program is the only national program in the world designed to 

evaluate alternatives to ozone-depleting substances, and as such, represents the most 

comprehensive and accessible resource for information on alternatives.

Use of the Toxic Substances Control Act (TSCA) SNAP Addendum form (described in section 

4(b) of this statement) will ensure that companies participating in the TSCA Pre-Manufacture 

Notice (PMN) program will not duplicate their data in reporting to the SNAP program. 

b) Public Notice Required Prior to ICR Submission to OMB

In compliance with the 1995 Paperwork Reduction Act (PRA), EPA sought public comments for 

a 60-day period prior to submitting the ICR renewal package to OMB. These comments, which

are used partly to determine realistic burden estimates for respondents, must be considered 

when completing the Supporting Statement that is submitted to OMB.

The announcement of a public comment period for this renewal ICR was published in the 

Federal Register on March 24, 2014 (79 FR 15994). EPA sought public comments, pursuant to 

5 CFR 1320.8(d), on the previous burden estimates being sought by the Agency. EPA received 

no comments.

c) Consultations
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In preparing to renew this information collection request, EPA consulted with fewer than nine 

actual or potential respondents to discuss estimated burden hours and costs associated with 

this information collection request. The respondents with whom EPA consulted are from various 

industries, companies, and organizations that have recently reported to the SNAP program.

They include Mary Koban of DuPont and Charlie Hon of True Manufacturing. 

d) Effects of Less Frequent Collection

The SNAP program has minimized the number of reporting and recordkeeping requirements as 

much as possible by requiring only a one-time application, and a one-time recordkeeping of 

documents submitted to EPA.

e) General Guidelines 

This rule does not exceed any of the guidelines, except for records retention for more than 3 

years. Retention periods for the two SNAP recordkeeping requirements (described below in 

section 4(b) of this statement) are not specified in Title VI of the Act or in the SNAP regulations, 

but EPA requires retention of these records for five years for enforcement purposes, pursuant to 

statutory authority under 28 U.S.C. Section 2462, the applicable statute of limitations. Sec. 2462 

states:

Except as otherwise provided by Act of Congress, an action, suit or proceeding for the 

enforcement of any civil fine, penalty, or forfeiture, pecuniary or otherwise, shall not be 

entertained unless commenced within five years from the date when the claim first accrued 

if, within the same period, the offender or the property is found within the United States in 

order that proper service may be made thereon.

f) Confidentiality 

Measures to protect confidentiality of information collected under the SNAP program are based 

on EPA’s confidentiality regulations (40 CFR 2.201 et seq., or Subpart B.) SNAP regulations (at 

40 CFR 82.182) describe these measures, which are also mentioned on the front page of each 

of the SNAP forms. Each form mentions basic information about asserting confidentiality claims, 

and also instructs the submitter to read the Instruction Manual, which contains more detailed 

discussion of the procedures for confidentiality claims. (See pages 7-9 of the Instruction Manual, 

which, as described in section 4(b), is attached as Appendix F). These procedures are 

described briefly below.

Submitters may designate all or portions of their forms or petitions as confidential. EPA requires 

the submitters to substantiate their claim of confidentiality. The submitter is advised that, under 

Section 114(c) of the Act, emissions data may not be claimed as confidential. The submitter is 

also advised that there are further instances, described in the provisions of 40 CFR Part 2, 

Subpart B, in which confidential assertions may be reopened or denied even when 

confidentiality claims are initially received. The submitter will be contacted as part of such an 

evaluation process. If required substantiation is not provided along with the submission of 

information claimed as confidential, EPA may make the information available to the public 

without further notice. The submitter must provide one copy of the submission which contains 

no information claimed as confidential. The non-confidential submission will be put in the public 

docket.
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If toxicity or health and safety studies are listed as confidential, this information cannot be 

maintained as confidential where such data are also submitted under TSCA or the Federal 

Insecticide, Fungicide and Rodenticide Act (FIFRA) to the extent that confidential treatment is 

prohibited under those statutes. However, information in a toxicity study that is not health and 

safety data and is not relevant to the effects of a substance on human health and the 

environment, e.g., discussion of process information, or proprietary blends, can be maintained 

as confidential subject to 40 CFR Part 2, Subpart B.

Information submitted as part of a joint submission to either SNAP/TSCA or SNAP/FIFRA must 

adhere to the security provisions of the program offices implementing these statutes. For such 

submissions, the SNAP handling of such notices will follow the security provisions under these 

statutes.

g) Sensitive Questions

This section does not apply because the SNAP regulations and the associated information 

collection request do not seek information of a sensitive nature.

4. The Respondents and the Information Requested 

a) Respondents

Respondents for reporting requirements, as well as for the recordkeeping requirement for the 

exemption for small volume use, include manufacturers, importers, formulators and processors

of substitutes for ozone-depleting substances. Principally, these respondents are in the 

following major categories of industry groups, by Standard Industry Code (SIC) and North 

American Industry Classification System (NAICS):

Manufacturers, Chemicals and Allied Products

Industry SIC NAICS

Plastics materials and 

synthetics

282 325211 

Soap, cleaners, and toilet 

goods

284 325611 

Paints and allied products 285 32551 

Industrial organic chemicals 286 325191 

Miscellaneous chemical 

products

289 325998 

Manufacturers, Rubber and Misc. Plastics Products

Industry SIC NAICS

Plastics foam products 3086 32615

Wholesale Trade- Nondurable Goods

Industry SIC NAICS

Chemicals and allied products 516 42261 

Miscellaneous nondurable 

products

519 42299 
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Respondents for the recordkeeping requirement for substitutes acceptable subject to use 

conditions or narrowed use limits include end users of the substitutes in the following industrial 

sectors:

Construction- Special Trade Contractors

Industry SIC NAICS

Plumbing, heating, and airconditioning171 23511

Manufacturing- Industrial Machinery & Equipment

Industry SIC NAICS

Computer and office 

equipment

357 334111 , 333313 

Refrigeration and service 

machinery

358 333415 

Manufacturing- Electronic & Other Electric Equipment

Industry SIC NAICS

Electric distribution equipment 361 335311 

Electric industrial apparatus 362 335312 

Communications equipment 366 33421 

Electronic components and 

accessories

367 334411 

Manufacturing- Transportation Equipment

Industry SIC NAICS

Automobile manufacturing 371 336111

Aircraft and parts 372 336412

Ship and boat building and 

repairing

373 336611

Manufacturing- Instruments & Related Products

Industry SIC NAICS

Search and navigation 

equipment

381 334511 

Medical instruments and 

supplies

384 339112 

Ophthalmic goods 385 339115 

Services

Industry SIC NAICS

Services to buildings 734 56179 

Computer and data

processing services

737 541511

Refrigeration service and 

repair

7623 811412, 81131 

b) Information Requested 
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i) Data Items (including recordkeeping requirements):

To simplify and expedite the submission and review of SNAP notices, EPA has developed the 

following forms and an instruction manual:

- SNAP Information Notice (Appendix D)

- TSCA/SNAP Addendum (Appendix E)

- Instructions for the SNAP Program Information Notice and TSCA/SNAP 

Addendum (Appendix F)

The SNAP Information Notice is the form used in most submissions to give notice of a 

respondent’s plans to introduce a proposed substitute into the marketplace. The TSCA/SNAP 

Addendum is an abbreviated SNAP form for submissions in situations where there is joint 

statutory review between the TSCA New Chemicals (Pre-Manufacture Notice) program and the 

SNAP program. The full SNAP Information Notice should be used in the case of a joint review 

with EPA’s Pesticides program under FIFRA. A petition to add a substitute to the list of 

acceptable substitutes should include the same information that is requested in the SNAP 

Information Notice. The instruction manual provides further information for a respondent 

preparing any of these submissions.

The forms were developed to minimize the reporting burden for the submitter; however, their 

use is optional. Respondents with more efficient means of submitting the information are 

encouraged to use them. EPA has based the estimated respondent burden and cost on the use 

of the recommended forms; to the extent a respondent uses more efficient means to submit the 

data, the estimates contained in this analysis may overestimate the respondent burden and 

cost. 

1. SNAP Information Notice/ Petition Data Items: Reference: Sections 82.176(a), 82.178, 

82.180(a)(5), 82.184(c)

The information requested on the SNAP Information Notice includes the following data items:

Name and description of the substitute. To the extent possible, the substitute should be 

identified by its (1) commercial name, (2) chemical name, (3) trade name(s), (4) generic name, 

(5) identification numbers (e.g., CAS registry, NIOSH RTECS, EPA hazardous waste, OHMTADS, DOT/UN/NA/IMCO shipping, HSDB, NCI), (6) chemical formula, and (7) chemical 

structure.

Physical and chemical information. Key properties that should be included to characterize the 

substitute such as: molecular weight; physical state; melting point; boiling point; density; odor 

threshold; solubility; partition coefficients (Log Kow, Log Koc); and vapor pressure.

Substitute applications. Identification of the end-uses and applications in which the substitutes 

are likely to be used is required. It is essential to provide a complete list of potential uses as the 

substitute listing required by section 612(c) is specific to end-use.

Process description. For each application identified, EPA is requesting available descriptive 

data on processing, including in-place pollution controls. Such information will be helpful in 

characterizing workplace and environmental releases and exposures.
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Ozone depletion potential. The predicted ozone depletion potential (ODP) of substitute 

chemicals is requested. The submitter should also provide sufficient supporting documentation--

either a citation or the background information used to develop the ODP. For purposes of 

calculating ODP, EPA recommends the methodology used in the most recent Scientific 

Assessment of Ozone Depletion, which was prepared for the United Nations Environment 

Programme. 

Global warming potential. EPA requests readily available data on the global warming potential 

(GWP) and atmospheric lifetime of the substitute. EPA requests that all GWPs be referenced to 

CO2 using the methodology recommended by the 2007 assessment report from the 

Intergovernmental Panel for Climate Change (IPCC). To the extent that data is available, EPA 

also considers indirect effects. Indirect effects explicitly consider the impact on global warming 

arising from changes in energy consumption associated with the use of a substitute (e.g., an 

alternative refrigerant). This latter measure can be identified as changes in energy efficiency or 

demand relative to the substitute being replaced.

Toxicity data. Information on toxicity from acute and chronic exposure to a substitute chemical, 

its impurities, and its degradation products on any organism (e.g., humans, mammals, fish, 

wildlife, and plants) is required for some submissions. For mammals, EPA requests a minimum 

submission of the following tests to characterize substitute risks: a range-finding study, and a 

28-day subchronic repeated dose study in an appropriate rodent species. For substitutes that 

are being evaluated as fire suppressants, refrigerants, or aerosols, a cardiotoxicity study, 

usually performed on a dog, may be required. Additional mammalian toxicity tests will be 

identified based on the substitute and application being evaluated. To sufficiently characterize 

aquatic toxicity concerns, both acute and chronic toxicity test results for a variety of species may 

be required. EPA may requires a minimum data set as described in "Guidelines for Deriving 

Numerical National Water Quality Criteria for the Protection of Aquatic Organisms and their 

Uses," which is available through the National Technical Information Service (#PB 85-227049).

Other relevant information and data summaries, such as the Material Safety Data Sheets, 

should also be submitted. Submission of the actual toxicity studies is most beneficial; however, 

it is not necessary to submit these reports if they have been supplied to EPA as part of other 

regulatory submissions. To assist in locating these studies, the submitter must provide a 

sufficiently clear citation to ensure that these studies can be located by EPA in a timely fashion.

EPA requires that submitters providing information on new chemicals for joint review under 

TSCA and SNAP adhere to the TSCA minimum testing requirements described in TSCA section 

5.

Environmental Fate and Transport. Where available, information must be submitted on the 

environmental fate and transport of substitutes. Such data shall include information on 

bioaccumulation, biodegradation, adsorption, volatility, transformation, and other data necessary 

to characterize movement and reaction of substitutes in the environment.

Flammability. Data on the flammability of a substitute chemical or mixture are required.

Specifically, data on flash point and flammability limits are needed, as well as information on the 

procedures used for determining the flammability limits. For substitutes that will be used in 

consumer applications, documentation of testing results conducted by independent laboratories 

(e.g., Underwriters Laboratories) should be submitted where appropriate. Detail on any 

suggested abatement techniques to minimize the risks associated with the use of flammable 

substances or blends should also be provided. EPA recognizes that many promising 

alternatives may be considered marginally flammable, but can be used safely and effectively.

The information requested on this topic will help EPA make a balanced decision regarding the 
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use of a flammable alternative.

Exposure data. The submitter should provide extant modeling or monitoring data on exposures 

associated with the manufacture, formulation, transport, and use of a substitute. Descriptive 

process information for each substitute application, as requested above, will be used to develop 

exposure estimates where measured exposure data are not readily available. Depending on the 

application, exposure profiles will be scenarios in which release, and subsequent exposure 

could potentially occur. This could include workers, consumers, and the general population.

Environmental release data. Available data on emissions from the substitute application and 

equipment, as well as pollutant releases or discharge to all environmental media (ambient air, 

surface water, hazardous/solid waste), are needed to complete the risk characterization.

Submitters should provide information on release locations, if known. Any information on 

pollution controls used or that could be used in association with the substitute (e.g., emissions 

reduction technologies, wastewater treatment, and treatment of hazardous waste) and the costs 

of such technology are also requested.

Replacement ratio for a chemical substitute. EPA is requesting information on the replacement 

ratio for a chemical substitute versus the Class I or II substances being replaced. For example, 

in the case of a degreasing agent, how much more or less of the substitute chemical is needed?

This will have an impact on the estimated incremental cost and environmental effects 

associated with use of the substitute.

Required changes in technology. Detail on the changes in technology needed to use the 

alternative is requested. Such information should include a description of whether the substitute 

can be used in existing equipment-- with or without some retrofit--or in new equipment. Data on 

the cost (capital and operating) and estimated life of the technology modifications should also 

be submitted. These economic data are used to understand the near-term potential of using an 

alternative.

Cost of substitute. EPA is requesting data on the expected average cost of the alternative. The 

cost of the substitute can be expressed, for example, in terms of $/pound (for a chemical 

substitute) or as incremental capital and operating costs associated with a retrofit or new 

equipment. In addition, information is needed on the expected equipment lifetime for an 

alternative technology. Other critical cost considerations should be identified, as appropriate.

Availability of substitute. EPA needs to understand the extent to which a substitute is already 

commercially available or the expected date at which it may become available. The timing of 

availability is an important factor in assessing the overall health and environmental impacts of 

the substitute.

Anticipated market share. Data on the anticipated near-term and long-term (over the next five 

years) nationwide substitute sales (not just those of the submitter) is requested. This information 

can be presented in several ways, for example; number of units/products to be produced; or 

pounds of substitute sold. This information is required to assess the potential impacts related to 

total consumption and environmental releases.

Applicable regulations under other environmental statutes. The submitter is requested to 

provide information on whether the substitute(s) are regulated under other statutory authorities, 

in particular the Clean Water Act, Safe Drinking Water Act, the Resource Conservation and 
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Recovery Act, FIFRA, TSCA, and other titles under the CAA. EPA will evaluate substitutes 

under the SNAP program subject to these existing regulatory constraints.

Information already submitted to EPA. Individuals may have already submitted information 

being requested in the SNAP program notice to EPA as part of past regulatory and informationgathering activities. If such a situation exists, and to minimize reporting burden, the submitter 

should provide the following information to help locate the data already maintained at EPA: type 

of information submitted; the date of submission; the name of the EPA office to which the data 

were sent; description of the regulatory program; and a document-control number, if assigned 

(e.g., a PMN number). If the submitter cannot provide references to data sent previously to 

EPA, he or she should include all requested information in the SNAP notice. 

Information already available in the literature. If any of the data needed to complete the SNAP 

program notice are available in the literature, the submitter should provide EPA with references 

for such information. Failure to provide EPA with sufficient citation, however, will delay review of 

the notice. Additionally, submitters are encouraged to provide copies of any literature to 

expedite review, particularly if the citation is from a source not readily available to EPA 

researchers. Any references from sources in foreign languages should be translated.

Notification of additional information. If critical new information becomes available during the 

review period that may influence EPA’s evaluation of a substitute, the submitter must notify EPA 

of the existence of such information within 10 days of learning of such data. The submitter must 

also inform EPA of new studies underway, even if the results will not be available within the 

review period.

2. TSCA/SNAP Addendum Form Data Items: Reference: Sections 82.176(a), 82.178, 

82.180(a)(5)

EPA has identified only a few additional data elements, beyond those already required by the 

Premanufacture Notice (PMN) form that would need to be included for review under the SNAP 

program. For this reason, the added burden to respondent from the SNAP program, above that 

already required by the New Chemicals (PMN) program, is very small.

The additional data elements in the TSCA/SNAP Addendum include: 

- The ozone-depletion potential, 

- The global-warming potential,

- Explicit quantification of the cost of using the substitute and information on when the substitute 

is expected to be available (including the chemical replacement data, chemical cost data, 

incremental equipment expenditures needed to use the substitute, and information on the cost 

implications resulting from changes in energy consumption), and 

- Flammability properties and documentation of testing results regarding the flammability of 

substitutes.

- Information related to compatibility of new refrigerants in refrigeration and air conditioning

equipment (e.g., compressor oil).

If critical new information becomes available during the review period that may influence EPA’s 

evaluation of a substitute, the submitter must notify EPA of the existence of such information 

within 10 days of learning of such data. The submitter must also inform EPA of new studies 

underway, even if the results will not be available within the review period.
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3. Notification for Test Marketing Activity Data Items Reference: Section 82.176(b)(5)

Uses of substitutes for the sole purpose of test marketing are exempt from requirements for 

submitting a SNAP Information Notice or equivalent until 90 days prior to the introduction of 

such substitutes for full-scale commercial sale in interstate commerce. Persons taking 

advantage of this exemption are, however, required to notify EPA in writing that they are 

conducting test marketing 30 days prior to the commencement of such marketing. Notification 

shall include the following data items:

- Name of the substitute

- Volume used in the test marketing

- Intended sector and end uses

- Expected duration of the test marketing period

4. Recordkeeping for Substitutes Acceptable Subject to Use Conditions or Subject to Narrowed 

Use Limits Data Items Reference: Section 82.180(b)(2) and (b)(3)

If a substitute is listed by EPA, in a decision on a SNAP information notice, TSCA/SNAP 

addendum, or petition, as acceptable subject to narrowed use limits, end users intending to use 

the substitute must determine that other alternatives are not technically feasible. For some 

substitutes listed as acceptable subject to narrowed use limits, the end user needs to perform 

an assessment that other alternatives are not technically feasible due to safety, performance, or 

technical reasons. Such end users must document the results of their evaluation and retain the 

results on file for the purpose of demonstrating compliance. This documentation shall include 

the following data items:

- Descriptions of substitutes examined and rejected 

- Processes or products in which the substitute is needed

- Reason for rejection of other alternatives, e.g., performance, technical or safety standards

- The anticipated date other substitutes will be available and projected time for switching to 

other available substitutes.

Respondents are required to maintain these records for five years. See section 3(d) of this 

statement for the justification for this length of time.

In addition, some substitutes subject to use conditions may have specific recordkeeping 

requirements imposed through a use conditions (e.g., requirement to keep records of failure 

mode and effects analysis when introducing certain automotive refrigerants, or compliance with 

UL or other industry standards). Many of these are one-time requirements, rather than annual.

In many cases, keeping these records are consistent with common industry practices.

Respondents are required to maintain these records for three years.

5. Recordkeeping for Small Volume Use Exemption Data Items Reference: Section 82.176(b)(3)

Within the eight principal SNAP sectors, persons introducing a substitute whose expected 

volume of use amounts to less than 10,000 pounds per year within a SNAP sector are exempt 

from notification requirements. Persons taking advantage of this exemption for small uses must 

maintain documentation for each substitute describing how the substitute meets this small use 

definition. This documentation must include the following data item:

- Annual production and sales information by sector
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Respondents are required to maintain these records for five years. See section 3(d) of this 

statement for the justification for this length of time.

ii) Respondent Activities

There are five types of respondent reporting and recordkeeping activities required pursuant to 

Section 612 of the Act and the SNAP regulations promulgated thereunder, 40 CFR Sections 

82.170- 82.184:

Reporting: SNAP Information Notice/ Petition

This includes the following types of activities:

- Pre-submittal contact with EPA.

- Prepare and submit notice or petition to EPA.

- Respond to EPA requests for additional information and/or notify EPA of additional information 

as it becomes available.

Reporting: TSCA/SNAP Addendum

This includes the following types of activities:

- Pre-submittal contact with EPA.

- Prepare and submit form to EPA.

- Respond to EPA requests for additional information and/or notify EPA of additional information 

as it becomes available.

Reporting: Notification for Test Marketing Activity

- Compile information, and prepare and submit letter to EPA with the information.

Recordkeeping: Substitutes Acceptable Subject to Use Conditions or Narrowed Use Limits

- Assess other acceptable alternative substitutes (for substitutes that are acceptable subject to 

narrowed use limits).

- Compile and prepare record of assessment or other records as required by use conditions.

Recordkeeping: Small Volume Uses

- Assess sector sales.

- Compile and prepare record of sector sales.

5. The Information Collected - Agency Activities, Collection Methodology and Information 

Management.

a) Agency Activities

EPA activities associated with reviewing SNAP submissions consist of the following:
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Pre-submittal contact with respondent

- Send forms and instructions to potential respondents.

- Answer questions regarding the completion of SNAP program forms and the need to submit a 

SNAP notice.

Review and communication regarding submission

- Assign tracking number to SNAP notice or petition.

- Review SNAP notice or petition for sufficiency of information provided, send letter of receipt, 

and notify submitter if additional information is required.

- Review requests for confidentiality and provide appropriate protection.

- Review SNAP notice or petition, and notify submitter of decision.

- Review TSCA/SNAP Addendum in detail, coordinate with TSCA office, and notify submitter of 

decision.

- Prepare and evaluate EPA-initiated changes to the SNAP determinations.

Administrative operations

- Maintain administrative tracking system for all submissions.

- Maintain technical clearinghouse to help users identify acceptable substitutes that are listed 

under SNAP.

- Prepare and publish in the Federal Register periodic notices and rulemakings to inform the 

public of any changes to the SNAP lists and of all pending determinations.

b) Collection Methodology and Management 

EPA collects information through respondents’ submission of a SNAP Information Notice, a 

TSCA/SNAP Addendum, or a petition. In each case, the collection methodology is the same.

EPA has 90 days from receipt of a complete submission to respond to the filing, and EPA must 

publish its decisions in these submissions in its periodic Federal Register notices and 

rulemakings.

The 90-day review period will not commence until EPA judges the submission complete, 

although manufacturers of a new substitute may introduce the substitute into interstate 

commerce 90 days after EPA receives a submission if EPA has not already rendered an 

unacceptability determination. Once the 90-day review period has begun, EPA may determine 

that additional data are necessary, or the submitter may notify EPA of additional information 

which has become available and may influence EPA’s evaluation of the proposed substitute. In 

either case, EPA may contact the submitter to explore extending or suspending the review 

period, depending on the type of data and the stage of review. Thus, the 90-day review period 

begins on the date a complete submission is received by EPA, and it ends 90 days thereafter, 

unless EPA and the submitter have agreed to another date.

To help reduce the burden of preparing a SNAP submission, the SNAP Information Notice and 

the TSCA/SNAP Addendum are available online in a fillable format. EPA encourages submitters 

to mail or courier electronic versions of submissions and supporting documents on CD or USB 

device. Paper submissions will also be accepted. EPA will check data quality of each 

submission during its review of the data in each submission.

To help respondents reduce the burden of gathering information to prepare a SNAP submission, 

EPA has established an electronic clearinghouse of useful information about the SNAP 
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program, including updated lists of acceptable and unacceptable substitutes. In addition, the 

online dockets associated with SNAP notices and rulemakings, available at regulations.gov,

provide examples of submissions of various types.

c) Small Entity Flexibility

Submission of a complete notice to EPA 90 days before introducing a new substitute into 

commerce is required by statute, regardless of the size of the submitter. The information 

requested in the SNAP program is necessary for EPA to evaluate the proposed substitute 

chemicals which will be listed as acceptable, acceptable subject to use conditions or narrowed 

use limits, or unacceptable, depending on the evaluations. The SNAP program has directed the 

burden on manufacturers and formulators, rather than the end user, which greatly reduces the 

potential burden on small entities.

Additionally, SNAP reporting requirements provide an exemption for persons introducing a 

substitute whose expected volume of use amounts to less than 10,000 pounds per year within a 

SNAP industrial sector. This exemption reduces the potential burden on small entities, although 

such persons are subject to a recordkeeping requirement documenting their qualification for this 

exemption.

d) Collection Schedule

The initial SNAP regulations were promulgated March 18, 1994, and collection of information as 

required therein commenced on that date. EPA accepts and reviews SNAP submissions as 

respondents provide them to EPA.

6. Estimating the Burden and Cost of Collection

a) Estimating Respondent Burden and Costs

b) Estimating Respondent Costs

The following tables (6A/B-1 through 6A/B-5) present estimates of annual respondent burden 

hours and costs for each of the respondent activities described in section 4(b)(ii), with 

explanations of the assumptions made in each table.

Exhibit 6A/B-1: SNAP Information Notice/Petition: Annual Respondent Burden and Cost

The following table shows estimates of respondent burden hours and costs for the first set of 

activities listed above in section 4(b)(ii). In making these estimates, relied on its experience in 

twenty years of implementing the SNAP program and its consultations with respondents, and 

made the following assumptions:

- The average number of inquiries about filing a SNAP Information Notice or petition is

estimated to be 14 per year, while the number of submissions is estimated to be 12. The 

number of CBI requests is 83% of the 12 submittals. The number of filings for which additional 

information is required is 83% of the 12 submittals.

- Estimated start-up cost is based on the cost of required toxicological data which, in 15% of 

SNAP filings, is a one-time event incurred for the sole purpose of fulfilling SNAP requirements.

EPA estimates the cost of such data ranges from $30,000 to $350,000, with more than half of 

respondents required to submit these data incurring such costs in an amount equal to or less 

than $75,000. EPA multiplied a weighted average of these costs ($133,610) by 0.15 to get an 
14

estimated average start-up cost of $20,040 which represents the cost distributed among all 

respondents. EPA calculated the annualized cost per respondent by using 20 years as the 

useful life of the chemical for which data was collected and 7% as the discount value.

- Labor cost of $72.43 represents an average hourly rate of pay, including overhead and 

benefits, for a professional in the chemical manufacturing subsector.

- There is no annual operating and maintenance cost associated with this reporting requirement.

Table 6A/B-1: SNAP INFORMATION NOTICE / PETITION

(A) Hours 

per Year 

per 

Response

(B) Labor 

Cost 

(@72/hr) 

per Resp. 

per Year

(C) 

Annualized 

Startup Cost 

per 

Resp.

(D) No. 

of 

Resp.

(E)Total 

Hrs/Year 

(All 

Resp.) 

(A*D)

(F) Total

Annualized 

Cost per 

Year (All 

Resp.) 

(C*D)

(G) Total 

Labor 

Cost per 

Year (All 

Resp.) 

(B*D)

(H) Total 

Cost per 

Year (All 

Resp.) 

(F+G)

a) Pre-submittal contact with EPA

Obtain form and instructions

from EPA 0.75 $54 $0 14 10.5 $0 $761 $761 

Review form and instructions

from EPA 3 $217 14 42 $3,042 $3,042 

Identify chemical and 

applications 9 $652 $0 14 126 $0 $9,126 $9,126 

b) Prepare and submit form to EPA

Collect data for form 70 $5,070 $1,900 12 840 $22,800 $60,841 $83,641 

Prepare notification form 12 $869 $0 12 144 $0 $10,430 $10,430 

Prepare non-confidential 

version of form if CBI is 

declared (83%)

3 $217 $0 10 30 $0 $2,173 $2,173 

c) Respond to EPA requests for add’l information and/or notify EPA of add’l. information

Communicate with EPA 7 $507 $0 10 70 $0 $5,070 $5,070 

Collect data 58 $4,201 $0 10 580 $0 $42,009 $42,009 

Prepare data to send to EPA 3 $217 $0 10 30 $0 $2,173 $2,173 

 Subtotals 165.75 $12,005 $1,900 36 1823.25 $22,800 $135,625 $158,425 

Exhibit 6A/B-2: TSCA/SNAP ADDENDUM: Annual Respondent Burden and Cost

The following table shows estimates of respondent burden hours and costs for the second set of 

activities listed above in section 4(b)(ii). In making these estimates, EPA relied on its experience 

in twenty years of implementing the SNAP program and its consultations with respondents, and 

made the following assumptions:

- Three inquiries per year come in regarding a TSCA/SNAP Addendum. EPA receives three

submittals per year. Three CBI claims come from those three submittals. Additional information 

is usually required from the submitter.
15

- Labor cost of $72.43 represents an average hourly rate of pay, including overhead and 

benefits, for a professional in the chemical manufacturing subsector.

-There is no start-up or operating and maintenance cost associated with the TSCA/SNAP 

Addendum.

Table 6A/B-2: TSCA/SNAP Addendum

(A) 

Hours/ 

Year 

Resp.

(B) Labor Cost 

(@ $72/hr) per 

Resp. per Year

(C) No. 

of Resp.

(D)Total 

Hrs/Year (All 

Resp.)

(A*C)

(E) Total 

Labor Cost 

per Year (All 

Resp.)

(B*C)

a) Pre-submittal contact with EPA

Obtain form and instructions from EPA 0.5 $36 3 1.5 $109 

Review form and instructions from EPA 3 $217 3 9 $652 

Identify chemical and applications 0.5 $36 3 1.5 $109 

b) Prepare and submit form to EPA

Collect data for form 20 $1,449 3 60 $4,346 

Prepare notification form 5 $362 3 15 $1,086 

Prepare non-confidential version of form if 

CBI is declared 1 $72 3 3 $217 

c) Respond to EPA requests for add’l information and/or notify EPA of add’l. information

Communicate with EPA 1 $72 3 3 $217 

Collect data 3 $217 3 9 $652 

Prepare data to send to EPA 1 $72 3 3 $217 

 Subtotals 36 $2,535 3 105 $7,605 

Exhibit 6A/B-3: Notification for Test Marketing Activity: Annual Respondent Burden and 

Cost (3)

The following table shows estimates of respondent burden hours and costs for the third set of 

activities listed above in section 4(b)(ii). In making these estimates, EPA relied on its experience 

in twenty years of implementing the SNAP program and its consultations with respondents, and 

made the following assumptions:

- The number of notifications for test marketing activity is three per year, and the number of 

hours per notification is one.

- Labor cost of $72.43 represents an average hourly rate of pay, including overhead and 

benefits, for a professional in the chemical manufacturing subsector.

- There is no start-up or operating and maintenance cost associated with the notification.

Table 6A/B-3: Notification for Test Marketing Activity
16

(A) Hours/ 

Year Resp.

(B) Labor Cost 

(@ $72/hr) per 

Resp. per Year

(C) No. of 

Resp.

(D)Total 

Hrs/Year (All 

Resp.)

(A*C)

(E) Total Labor 

Cost per Year (All 

Resp.)

(B*C)

a) Compile information and 

prepare letter

1 $72 3 3 $217 

Subtotal 1 $72 3 3 $217 

Exhibit 6A/B-4: Recordkeeping for Substitutes Acceptable Subject to Use Conditions or

Narrowed Used Limits: Annual Respondent Burden and Cost (4)

The following table shows estimates of respondent burden hours and costs for the fourth set of 

activities listed above in section 4(b)(ii). In making these estimates, EPA relied on its experience 

in twenty years of implementing the SNAP program and its consultations with respondents, and 

made the following assumptions:

- The number of recordkeeping collections is expected to decrease by 20% to 160 per year.

Each collection is a one-time occurrence. Users of restricted alternatives may periodically 

reevaluate alternatives available.

- Labor cost of $72.43 represents an average hourly rate of pay, including overhead and 

benefits, for a professional in the chemical manufacturing subsector.

- There is no start-up cost associated with the recordkeeping collection.

- Annual operating and maintenance cost represents an estimate of cost of storage space for 

keeping the records.

Table 6A/B-4: Recordkeeping for Substitutes Acceptable Subject to Use Conditions or 

Narrowed Used Limits

(A) 

Hrs/ 

Year 

Resp.

(B) Labor 

Cost (@ 

$72/

hr) per 

Resp.

per Year

(C) 

Annualized 

O&M 

Cost per 

Resp.

(D) 

No. 

of 

Resp.

(E)Total 

Hrs/Year 

(All 

Resp.)

(A*D)

(F) Total 

Annualized 

Cost per Year 

(All Resp.)

(C*D)

(G) Total 

Labor Cost 

per Year 

(All Resp.)

(B*D)

(H) Total

Cost per 

Year (All 

Resp.)

(F+G)

a) Assessment of other 

acceptable 

alternatives 25 $1,811 $0 160 4,000 $0 $289,720 $289,720 

b) Compile information 

and prepare 

recordkeeping 2 $145 $1 160 320 $160 $23,178 $23,338 

Subtotal 27 $1,956 $1 160 4,320 $160 $312,898 $313,058 

Exhibit 6A/B-5: Recordkeeping for Small Volume Uses: Annual Respondent Burden and 

Cost (5)
17

The following table shows estimates of respondent burden hours and costs for the fifth set of 

activities listed above in section 4(b)(ii). In making these estimates, EPA relied on its experience 

in twenty years of implementing the SNAP program and its consultations with respondents, and 

made the following assumptions:

- The number of recordkeeping collections is 10 per year, and each collection is a one-time 

occurrence.

- Labor cost of $72.43 represents an average hourly rate of pay, including overhead and 

benefits, for a professional in the chemical manufacturing subsector.

- There is no start-up cost associated with the recordkeeping collection.

- Annual operating and maintenance cost represents an estimate of cost of storage space, filing 

materials and other associated, non-labor costs for keeping the records.

Table 6A/B-5: Recordkeeping for Small Volume Uses: Annual Respondent Burden and 

Cost

(A) 

Hours/ 

Year 

Resp.

(B) Labor 

Cost (@ 

$72/

hr) per 

Resp.

per Year

(C) 

Annualized 

O&M 

Cost per 

Resp.

(D) No. 

of 

Resp.

(E)Total 

Hrs/Year 

(All Resp.)

(A*D)

(F)

Total 

Annualized 

Cost per 

Year (All 

Resp.)

(C*D)

(G) Total 

Labor Cost 

per Year 

(All Resp.)

(B*D)

(H) Total 

Cost per 

Year (All 

Resp.)

(F+G)

a) Assessment of 

sector sales

10 $724 $0 10 100 $0 $7,243 $7,243 

b) Compile 

information and 

prepare 

recordkeeping

2 $145 $1 10 20 $10 $1,449 $1,459 

Subtotal 12 $869 $1 10 120 $10 $8,692 $8,702 

c) Estimating Agency Burden and Costs

Exhibit 6C-1: Annual Agency Burden and Costs

The following table shows estimates of EPA burden hours and costs (including the cost of 

contractor services) for the activities listed in section 5 above. In making these estimates, EPA 

made the following assumptions:

- The number of occurrences is based on the number of inquiries and submittals by respondents 

estimated above in tables 6A-1 and 6A-2.

- Labor cost is based on the 2014 hourly rate for a GS 12/Step 2 employee based in 

Washington, DC ($37.44; annual salary $78,142), multiplied by the standard government 

benefits multiplication factor of 1.6, resulting in a final hourly rate of $59.72.

1

- The cost of contractor services in the two circumstances noted in the chart is based on a 

percentage of the total annual cost to SPD for the contractor’s charges under the respective 

2014 contracts. The percentage in each case represents an estimate of the time spent by the 

 

1

http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2014/DCB_h.pdf
18

contractor on SNAP issues as distinguished from other SPD issues not related to SNAP. The 

hourly rate of $190 represents the average rate charged per hour for the activities addressed in 

Table 6C1.

Table 6C1: EPA burden hours and costs

(A) No. of 

Occurrences

(B) No. of 

Hours per 

Occurrence

(C) Total 

no. of 

Hours per 

Year 

(A*B)

(D) Labor 

Cost (@ 

$59.72/hr) 

per Year 

(C*$59.72)

(E) Cost of 

Contract 

Services (@ 

$190/hr)per 

Year

(C*$190)

(F) Total 

Cost per 

Year

(D+E)

1) Pre-submittal contact w/ respondent

Send forms/ guidance to 

potential submitters 14 0.1 1.4 $84 n/a $84

Answer questions re potential 

submissions 14 1 14 $836 n/a $836

2) Review & communication re submission

Process SNAP submission: 

assign tracking number to 

submission, send notice of 

receipt 12 0.2 2.4 $143 n/a $143

Review CBI requests and 

protect as appropriate 10 0.2 2 $119 n/a $119

Review submission or add'l info 

in detail and notify submitter if 

add'l info is required or if 

complete 22 60 1320 $78,844 n/a $78,844

Contractor assistance in 

reviewing submissions and 

additional information 20 60 1200 n/a $228,000 $228,000

Process TSCA/SNAP Addendum 

submission: assign tracking 

number, send notice of receipt, 

review CBI requests and 

protect as appropriate 3 0.4 1.2 $72 n/a $72

Review TSCA/SNAP Addendum 

in detail and notify submitter if 

add'l info is required or if 

complete

3 40 120 $7,168 n/a $7,168

Contractor assistance in 

reviewing TSCA/SNAP 

Addendum submissions and 

additional information (@ 

$190/per hr) 3 50 150 n/a $28,500 $28,500
19

Prepare and evaluate EPAinitiated changes to 

determinations 2 40 80 $4,778 n/a $4,778

3) Administrative operations

Maintain system of tracking 

submissions 50 0.3 15 $896 n/a $896

Maintain clearinghouse to help 

users 3 10 30 $1,792 n/a $1,792

Contractor assistance for 

clearinghouse(@ $99/per hr) 0 0 0 $0 0 $0

Prepare FR notices and rulemakings re changes to SNAP 

lists based on submissions 4 100 400 $23,892 n/a $23,892

Subtotal 96 varies 3,336 $118,624 $256,500 $375,124

d) Estimating the Respondent Universe and Total Burden and Costs See the tables in 

section 6(a) and 6(b) for these estimates.

e) Bottom Line Burden Hours and Cost Tables

Exhibit 6E-1: Information Collection Activity: Total Estimated Respondent Burden and 

Cost Summary

Table 6E1: Total Estimated Respondent Burden and Cost Summary

No. of 

Responses 

per year

Total Hours 

per Year

Total Labor 

Cost per 

Year @$72

Total 

Annualized 

Start-up 

Costs

Total 

Annualized 

O&M Costs

Total 

Annualized 

Costs

SNAP Information Notice/ 

Petition

36 1,823 $135,625 $22,800 $0 $158,425 

TSCA/SNAP Addendum 3 105 $7,605 $0 $0 $7,605 

Notification for test 

marketing activity 3 3 $217 $0 $0 $217 

Recordkeeping for 

Substitutes Acceptable 

Subject to Use Conditions or 

Narrowed Use Limits 160 4,320 $312,898 $0 $160 $313,058 

Recordkeeping for Small 

Volume Uses 10 120 $8,692 $0 $10 $8,702 

Totals

212 6,371 $465,037 $22,800 $170 $488,007 
20

Exhibit 6E-2: Total Estimated Agency Burden and Cost Summary

Table 6E2: Total Estimated Agency Burden and Cost Summary

No. of 

Activities

Total Hours 

per Year 

Total Labor 

Govt Hours 

per Year

Total 

Annual 

Govt Labor 

Cost 

Cost of 

Contract 

Services per 

Year

Total Cost 

per Year

Pre-submittal contact with 

respondents 14 15 15 $920 $0 $920

Review and communicate re 

submissions (SNAP and 

PMN/SNAP Addendum) 25 2,876 1,526 $91,124 $256,500 $347,624

Administrative operations 57 445 445 $26,580 $0 $26,580

Totals 96 3,336 1,986 $118,624 $256,500 $375,124

f) Reasons for Change in Burden

The total number of respondent burden hours requested annually (Exhibit 6E-1) for this 

information collection has decreased from 6,683 hours in 2010 to 6,371 hours in 2014. The 

SNAP burden hours have been decreasing since 2000, starting at 10,363 hours and decreasing

to 8,972 hours in 2004, 8,204 hours in 2007, 6,683 hours in 2010, and 6,371 hours in 2014. The 

decrease is due to several factors, explained below. 

The number of SNAP Information Notice submissions each year is expected to increase from an 

average of 7 per year in the previous ICR to an average of 12 per year during the next 3 years.

In 2013 the Agency received 8 new SNAP submissions, while in the first 8 months of 2014 

alone, the Agency received 12 submissions. Many of the recent SNAP submissions, and those 

anticipated over the next three years, are for chemicals previously found acceptable for other 

SNAP applications, or for blends of alternatives already found acceptable. While the number of 

submissions is expected to increase, the burden of developing supporting information for the 

majority of these submissions is expected to decrease because it is easier to find and review 

information for substitutes that have been reviewed previously.

The SNAP submission forms have been revised to improve usability and ease burden on 

submitters by clarifying the information necessary for review based on the specific sector(s) and 

end-use(s) being pursued, and by eliminating redundancy. Improving the quality of incoming 

submissions decreases the burden for both respondents and EPA by allowing for EPA to 

complete its review more quickly, and reducing the amount of additional information and 

clarifications requested of the respondents in order to complete the submission. Also, the 

Agency encourages the submission of electronic files via mail services, reducing burden hours 

placed on respondents and the Agency for processing. These improvements will allow

submissions to be found complete faster, resulting in the inclusion of alternatives in Agency 

notices or rules sooner, and thus allowing products to enter the market faster. Improving the

clarity of information necessary for review within the forms will also decrease the burden of presubmission communications.

 

There is a 20% reduction in the number of respondents responsible for recordkeeping for 

substitutes acceptable subject to use conditions and narrowed use limits. This reduction is 
21

expected because the increased availability of alternatives decreases the need for industry to 

use alternatives previously listed as acceptable subject to narrowed use limits. There is also a 

reduction of contractor services for administrative support of the SNAP program. EPA staff 

complete an increasing proportion of clearinghouse maintenance and updates, rather than using 

contractor services.

g) Burden Statement

Exhibits 6A/B-1 through 6A/B-5 present the average annual respondent burden for each person 

subject to SNAP reporting and recordkeeping requirements. For persons filing a SNAP 

Information Notice or petition, the reporting burden is estimated to average about 165 hours per 

year. For persons filing a TSCA/SNAP Addendum, the reporting burden is estimated to average 

36 hours per year. For persons filing a notification of test marketing activity, the reporting burden 

is estimated to average 1 hour per year. For persons keeping records of use of a substitute 

subject to use conditions or narrowed use limits, the recordkeeping burden is estimated to 

average 27 hours per year. For persons keeping records of a small volume use, the 

recordkeeping burden is estimated to average 12 hours per year.

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

maintain, retain, or disclose or provide information to or for a Federal agency. This includes the 

time needed to review instructions; develop, acquire, install, and utilize technology and systems 

for the purposes of collecting, validating, and verifying information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the 

collection of information; and transmit or otherwise disclose the information. An agency may not 

conduct or sponsor, and a person is not required to respond to, a collection of information 

unless it displays a currently valid OMB control number. The OMB control numbers for EPA’s 

regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

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

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

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

ID No. EPA-HQ-OAR-2004-0077, which is available for online viewing at www.regulations.gov, 

or in person viewing at the Air and Radiation Docket and Information Center in the EPA Docket 

Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The 

EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through 

Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-

1744, and the telephone number for the OAR Docket is (202) 566-1742. An electronic version of 

the public docket is available at www.regulations.gov. This site can be used to submit or view 

public comments, access the index listing of the contents of the public docket, and to access 

those documents in the public docket that are available electronically. You can also send 

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

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

include the EPA Docket ID No. EPA–HQ–OAR–2004-0077 and OMB control number 2060-

0226 in any correspondence.

Appendices

A- Draft FR notice announcing request for ICR renewal

B- Text of Section 612 of the Clean Air Act as amended in1990

C- Text of SNAP Regulations, 40 CFR Part 82, Subpart G 

D- SNAP Information Notice (EPA Form 1265-14)
22

E- TSCA/SNAP Addendum (EPA Form 1265-14)

F- Instructions for the SNAP Program Information Notice and TSCA/SNAP Addendum (EPA 

Form 1265-14)