Economic Analysis of the Proposed Significant New Use Rule for MercuryContaining Barometers, Manometers, Hygrometers, and Psychrometers 

(EPA Docket EPA-HQ-OPPT-2010-0630)

November 8, 2010

—Does not contain TSCA CBI—

Prepared by:

Economic and Policy Analysis Branch

Economics, Exposure and Technology Division

Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460
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CONTRIBUTORS

The EPA analyst responsible for this report was Timothy Lehman. Analytical and draft preparation 

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

2 This report estimates the costs of the U.S. Environmental Protection Agency (EPA)’s proposed 

3 Significant New Use Rule (SNUR) that applies to the significant new use of elemental mercury (CAS 

7439-97-6) in three mercury-containing products 1) barometers, 2) hygrometers/psychrometers,

1

4 and 3) 

manometers.25 Not included in this proposed SNUR is mercury use in portable, battery-powered, motor6 aspirated psychrometers containing less than 7 grams of elemental mercury because these type of 

7 psychrometers are currently manufactured. 

8 The proposed SNUR applies to all manufacturing, import, and processing of elemental mercury for use in

9 these three mercury-containing products (excluding the specified psychrometers). The three mercury10 containing products subject to the proposed SNUR are believed to no longer be manufactured in or 

11 imported into the United States and are considered “legacy products” by the Interstate Mercury Education 

12 and Reduction Clearinghouse (IMERC). Legacy products are defined by IMERC as products that are not 

sold as new, but may still be in use, resold as used or antique, or stored in homes or businesses.313 All three 

14 products currently have viable and cost-effective substitutes. Because the three mercury-containing 

15 products subject to the proposed SNUR are not manufactured, and feasible mercury-free alternatives are 

16 widely available, there is expected to be no economic impact as a result of the proposed SNUR.

17 The three mercury-containing products subject to the proposed SNUR are all applications of barometers,

18 manometers and hygrometers/psychrometers (excluding the specified psychrometers). All three products

19 subject to the proposed SNUR currently have effective and economically feasible substitutes, and are no 

longer manufactured in United States.

4

20 Manometers are used to measure air, gas, and liquid pressure, in 

21 the automotive, dairy, and heating, ventilating, and air conditioning (HVAC) industries. There are viable 

22 mercury-free alternatives for almost all uses of manometers, including digital manometers, bourdon tube 

23 manometers, aneroid manometers, and hydrostatic gauges. Barometers are instruments used to measure 

24 atmospheric pressure. Current alternatives for barometers include aneroid barometers, electronic 

25 barometers, and other liquid-based barometers. Hygrometers/psychrometers are used to measure the 

26 moisture content, or humidity, of air or gas. There are two available and widely used alternatives to 

27 hygrometers/psychrometers: spirit-filled products and digital products.

28 The proposed SNUR would require persons to notify EPA at least 90 days before commencing the 

29 manufacture, import, or processing of elemental mercury for any significant new use as described in the 

30 SNUR. A firm intending to engage in these activities would be required to submit a Significant New Use 

31 Notice (SNUN). EPA is proposing the SNUR because of health and environmental concerns about 

32 mercury use. Because the three specified mercury-containing products subject to the proposed SNUR are

33 not currently manufactured in the United States, it is important that EPA is notified if a company chooses 

34 to produce, import, or process elemental mercury for use in any of these products. The SNUN provides 

35 EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity 

36 before it occurs.

37 To submit this SNUN, a firm incurs a modest submission cost of $8,143, and potentially other minor 

38 costs. However, because no firms are currently importing, manufacturing, or processing elemental

39 mercury for any significant new uses, it is highly unlikely that any firm will incur this cost. EPA does not 

 

1

Psychrometers are the most common type of hygrometer; while they function similarly, they have historically been 

used in different applications and so have different naming conventions. See Section 2 for more details.

2 Because EPA cannot regulate articles containing a chemical under TSCA Section 5, the SNUR applies to 

elemental mercury used in these products. EPA will not be notified if there is import of mercury-containing 

barometers, hygrometers, or manometers.

3 These devices may still be in use, resold in the aftermarket, or stored in homes and businesses. 

4

Portable, battery-powered, motor-aspirated psychrometers containing less than 7 grams of elemental mercury

continue to be manufactured in the United States, and are not subject to the proposed SNUR.
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40 require the development of test data for submission of a SNUN, although a firm may submit test data 

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

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

43 SNUR.

44 In addition to the firms that make a SNUN submission, the proposed SNUR may also impact firms that do 

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

46 but may incur other compliance costs. However, this may not be a concern given that there are no current 

47 manufacturers of these three products.

48

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

50 submission. 

51
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52 TABLE OF CONTENTS

53

54 CONTRIBUTORS.........................................................................................................................................i

55 ABSTRACT...................................................................................................................................................i

56 LIST OF TABLES.......................................................................................................................................iv

57 1. INTRODUCTION ................................................................................................................................1

58 1.1 Statutory Authority.....................................................................................................................1

59 1.2 Summary of Methodology..........................................................................................................1

60 1.3 Organization of this Report ........................................................................................................1

61 2. POTENTIALLY AFFECTED ENTITIES............................................................................................2

62 2.1 Historic Uses of and Alternatives to Mercury-Containing Barometers, 

63 Hygrometers/Psychrometers, and Manometers..........................................................................2

64 Barometers..................................................................................................................................2

65 Hygrometers/Psychrometers.......................................................................................................3

66 Manometers................................................................................................................................3

67 2.2 Potentially Affected Entities.......................................................................................................3

68 Barometers..................................................................................................................................4

69 Hygrometers/Psychrometers.......................................................................................................4

70 Manometers................................................................................................................................4

71 3. INDUSTRY COMPLIANCE COSTS ..................................................................................................5

72 3.1 Wage Rates.................................................................................................................................6

73 3.2 Unit Industry Compliance Costs.................................................................................................6

74 3.2.1 Rule Familiarization ......................................................................................................6

75 3.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup................7

76 3.2.3 Form Completion and Submission Fee..........................................................................8

77 3.2.4 Import Certification .......................................................................................................9

78 3.2.5 Export Notification........................................................................................................9

79 3.3 Industry Costs of SNUR, by Option (per Submission).............................................................12

80 3.4 Likelihood of a SNUN Submission ..........................................................................................13

81 3.5 Potential for Subsequent Regulatory Action ............................................................................13

82 4. AGENCY COSTS...............................................................................................................................14

83 4.1 Labor Rates for EPA Staff........................................................................................................14

84 4.2 SNUN Processing Costs...........................................................................................................15

85 4.3 Export Notification Cost...........................................................................................................18

86 5. ADDITIONAL ANALYSES..............................................................................................................19

87 5.1 Small Entity Impacts.................................................................................................................19

88 5.2 Unfunded Mandates..................................................................................................................19

89 5.3 Paperwork Reduction Act.........................................................................................................19

90 5.4 Technical Standards..................................................................................................................20

91 5.5 Regulatory Planning and Review .............................................................................................20

92 5.6 Environmental Justice...............................................................................................................20

93 5.7 Protection of Children...............................................................................................................20

94 5.8 Federalism ................................................................................................................................20

95 5.9 Tribal Governments..................................................................................................................20

96 5.10 Effect on Energy Supply, Distribution, or Use.........................................................................20

97 6. REFERENCES....................................................................................................................................22

98

99
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100 LIST OF TABLES

101 Table 1: Loaded Industry Wage Rates, December 2009...............................................................................6

102 Table 2: Rule Familiarization Burden and Cost for SNUR Submitters........................................................7

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

104 First-Time Submitters...................................................................................................................................7

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

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

107 Table 6: Derivation of Total Mailing Cost for 12 Notices..........................................................................11

108 Table 7: TSCA 12(b) Export Notification Cost per Notification................................................................11

109 Table 8: Compliance Options and Associated Costs Incurred by a Firm Due to the Proposed SNUR......13

110 Table 9: Derivation of Loaded Agency Wage Rates ..................................................................................15

111 Table 10: Derivation of Inflation Factors for Agency Extramural Costs....................................................16

112 Table 11: Agency Costs for SNUN and Other Submission Review and Processing..................................17

113 Table 12: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2009$)...........................18

114
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115 1. INTRODUCTION

116 This report presents the U.S. Environmental Protection Agency (EPA), Office of Pollution Prevention and 

117 Toxics’ (OPPT’s) analysis of the potential costs incurred as a result a proposed Significant New Use Rule 

118 (SNUR) that addresses the use of elemental mercury (CAS 7439-97-6) in three products: 1) barometers,

119 2) hygrometers/psychrometers, and 3) manometers. Portable, battery-powered, motor-aspirated 

120 psychrometers containing less than 7 grams of elemental mercury continue to be manufactured in the 

121 United States, and are not subject to the proposed SNUR. SNURs are proposed by EPA under the 

122 authority granted by Section 5(a)(2) of the Toxic Substances Control Act (TSCA). The proposed SNUR 

123 would require persons to notify EPA at least 90 days before commencing the manufacture, import, or 

124 processing of elemental mercury for manometers, barometers and hygrometers/psychrometers (excluding 

125 the specified psychrometers). EPA promulgates a SNUR for a substance when potential uses could result 

126 in increased exposure to or releases of the substance and in turn, could present an unreasonable risk to 

127 health or the environment.

128 1.1 Statutory Authority 

129 Section 5(a)(2) of TSCA (15 U.S.C. 2604(a)(2)) authorizes EPA to determine that a use of a chemical substance 

130 is a “significant new use.” EPA must make this determination by rule after considering all relevant factors, 

131 including those listed in TSCA section 5(a)(2). Once EPA determines that a use of a chemical substance is a 

132 significant new use, TSCA section 5(a)(1)(B) requires persons to submit a Significant New Use Notice (SNUN)

133 to EPA at least 90 days before manufacturing, importing, or processing the chemical substance for that use (15 

134 U.S.C. 2604(a)(1)(B)).

135

136 The general SNUR provisions are found at 40 CFR Part 721, Subpart A.

137

138 1.2 Summary of Methodology

139

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

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

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

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

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

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

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

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

148 supplementary market research.

149

150 1.3 Organization of this Report

151 The remainder of this report provides EPA’s economic analysis in support of the proposed rule. The chemical 

152 substances and industry sectors potentially affected are characterized in Chapter 2. Chapter 3 contains estimates 

153 of the industry cost of complying with the proposed rule, and Chapter 4 shows estimates of the government 

154 costs associated with the administration of the proposed rule. Chapter 5 presents additional impact analyses.

155

156 Note that all dollar amounts in this analysis are reported in December 2009 dollars. 
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157

158 2. POTENTIALLY AFFECTED ENTITIES 

159 The proposed SNUR applies to all manufacturing, import, and processing of elemental mercury for use in 

160 mercury-containing barometers, manometers, and hygrometers/psychrometers (excluding portable, battery161 powered, motor-aspirated psychrometers containing less than 7 grams of elemental mercury). None of the three 

162 mercury-containing products subject to the proposed SNUR are believed to be manufactured, imported, or 

process in the United States,

5

163 and are considered “legacy products” by the Interstate Mercury Education and 

Reduction Clearinghouse (IMERC).6164 Legacy products are defined by IMERC as products that are not sold as 

165 new, but may still be in use, resold as used or antique, or stored in homes or businesses. 

166

167 The following sections describe the specific historic uses of each of the three specified mercury168 containing products, the substitutes for each product, and the potentially affected industry sectors. 

169 Because the manufacture of the three mercury-containing products subject to the proposed SNUR has 

170 ceased in the United States, we assume that there is no import of elemental mercury for these uses. 

171 2.1 Historic Uses of and Alternatives to Mercury-Containing Barometers, 

172 Hygrometers/Psychrometers, and Manometers

173 Barometers

174 Barometers are instruments used to measure atmospheric pressure, and consist of a long cylindrical tube, 

175 typically closed at one end, with a mercury-filled reservoir at the base. The weight of mercury creates a 

176 vacuum at the top of the tube, and the mercury adjusts until the pressure inside the reservoir equals atmospheric 

177 pressure. Rising mercury indicates increasing air pressure while dropping mercury indicates decreasing air 

178 pressure (IMERC, 2010b, 2009b and Maine DEP, 2003). Historically, barometers have primarily been used in 

weather forecasting applications (IMERC 2008c).7179 Additional uses include scientific demonstration in schools 

180 and non-mercury device calibration (IMERC, 2007, DEPA, 2006). A mercury barometer contains between 400 

181 and 620 grams of mercury (IMERC, 2010b).

182

183 Alternatives to mercury-containing barometers include aneroid barometers, electronic barometers (which 

184 use vibrating cylinder air pressure transducers, electronic resistance or capacitance), and other liquidbased (water or eco-celli) barometers.8

185

 

5 However, it is possible that these three may still be in use, resold as used or antique, or stored in homes or 

businesses. 

6

IMERC requires that all companies planning to sell mercury-containing products under the jurisdiction of its 

member states (California, Connecticut, Illinois, Louisiana, Maine, Massachusetts, Minnesota, New Hampshire, 

New Jersey, New York, North Carolina, Rhode Island, Vermont, and Washington) submit a notification to the 

clearinghouse every three years. However, because IMERC does not cover all states, its totals may not represent the 

entire universe. The only exception to this finding is mercury-containing psychrometers for which we found one 

manufacturer (Belfort, 2010).

7 Electronic instruments connected are now commonly used to take barometric readings (Columbia Encyclopedia 

2010).

8

Since water is lighter than mercury, it moves a greater distance in response to a given pressure change. As a result, 

the water barometers are large, bulky, and thus, seldom used (Maine DEP, 2003). Eco-celli barometers use a nontoxic silicon-based fluid in conjunction with a gas, and leverage the compressibility of gas in relation to gravity. 

Since changes in temperature can cause the liquid to expand, a thermometer is attached so that the necessary 

adjustments can be made to the scale (IMERC, 2007).
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186 Hygrometers/Psychrometers

187 Hygrometers are used to measure the moisture content, or humidity, of air or gas. A psychrometer, the 

188 most common type of hygrometer, uses two mercury-added thermometers, one with a wetted base, and 

189 one with a dry base. Hygrometers and psychrometers function similarly but have historically been used 

190 in different applications: hygrometers are used for cigar and tobacco humidors, or in residential settings 

191 where humidity is monitored to prevent the growth of mildew or dust mites; psychrometers are used by 

192 atmospheric scientists and weather enthusiasts (IMERC, 2010a). Mercury-added 

193 hygrometers/psychrometers contain between 3 and 7 grams of mercury (Environment Canada, 2004). 

194 There are two types of alternatives to mercury-added hygrometers/psychrometers that are readily 

195 available and widely used: spirit-filled products, which use methyl alcohol or citrus oil thermometers and

196 provide results with comparable accuracy to mercury-added thermometers; and digital products, which 

197 use electronic sensors to measure humidity changes and, when calibrated properly, provide as accurate 

198 results as mercury products (Maine DEP, 2003, IMERC, 2010b).

199 EPA found sufficient information to conclude that only one type of mercury-containing 

200 hygrometer/psychrometer is manufactured in or imported into the United States. Portable, battery201 powered, motor-aspirated psychrometers containing less than 7 grams of elemental mercury continue to 

be manufactured in the United States.9202 EPA is considering whether risk management or other actions 

203 would be appropriate for the one type of psychrometer that is still in use. 

204 Manometers

205 Manometers are used to measure air, gas, and liquid pressure. While these instruments come in a variety 

206 of shapes and sizes, the most common mercury manometer design is a U-shaped tube. One end is left 

207 open to the atmosphere; the other is exposed or connected to the source being measured. If the pressure 

208 measured is higher than atmospheric pressure, the liquid moves toward the open end of the tube. If the 

209 pressure measured is lower, it moves away from the open end. The difference between the levels of 

210 mercury provides a reading relative to atmospheric pressure. Historical manometer uses include vacuum 

pressure measurement in natural gas pipelines,10 211 dairy cow milking systems (“dairy manometers”), the 

212 automotive industry, and the heating, ventilation, and air conditioning (HVAC) industry. Depending on 

213 the application, the amount of mercury in a manometer may range from 30 to 525 grams (IMERC, 2010b, 

VT Agricultural Agency, 2001; WI DNR, 2007).11 214

215 There are viable mercury-free alternatives for almost all uses of manometers. There are several mercury216 free technologies in the dairy industry (digital manometers, bourdon tube manometers, and aneroid 

217 manometers), automobile industry (hydrostatic gauges) and the heating, ventilation and air conditioning 

218 (HVAC) industry (hydrostatic gauges and bourdon tube manometers).

219 2.2 Potentially Affected Entities

220 Because the three mercury-containing products subject to the proposed SNUR are believed to no longer 

221 be manufactured in or imported into the United States, there are likely to be no entities affected by the 

222 proposed SNUR. The following summarizes the research undertaken as part of this decision-making 

223 process.

 

9 A phone conversation with a customer service representative at the Belfort Instrument Company on April 27, 2010 

confirmed the manufacture of at least one model of mercury-containing psychrometer (Belfort, 2010). 

10 Based on information that use of mercury in natural gas manometers has ceased, on September 11, 2009 EPA has 

proposed a TSCA §5(a)(2) significant new use rule (SNUR), requiring persons to notify EPA 90 days prior to 

manufacture, import, or processing of elemental mercury for natural gas manometers, except when the articles are in 

service as of the effective date of the final rule (EPA, 2009a).

11 Natural gas manometers may contain several kilograms of mercury (Schleifstein, 2007).
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224 Barometers

225 Princo Instruments, the sole barometer manufacturer reporting use of mercury to IMERC in 2001 and 

226 2004, phased-out manufacturing mercury-added measuring products in January, 2007 (IMERC, 2010b). 

227 Internet queries did not identify any current manufacturer of mercury-added barometers. This research 

suggests that the manufacture of mercury-containing barometers has been phased out.12 228

229 Hygrometers/Psychrometers

230 IMERC reports that the quantity of mercury sold in hygrometers/psychrometers decreased from 0.0018 

231 metric tons in 2001 to 0.0009 metric tons in 2007; however, the 2007 value actually equals zero because 

232 IMERC categorizes “other measuring equipment” with hygrometers/psychrometers, and both 

233 manufacturers who reported sales of mercury-containing hygrometers/psychrometers to IMERC in either 

234 2001 or 2004 (Princo Instruments, Inc. and Taylor Precision Products L.P.) have reported that they have 

phased out the use of mercury (IMERC, 2010b).

13 235

236 Manometers

237 All manufacturers who had reported historical manufacture of mercury-containing manometers to IMERC

in either 2001 or 2004 have since phased out use of mercury in their products (IMERC, 2010b).14 238 Phone 

239 conversations with five additional companies (Ashcroft Inc., Dwyer Instruments, Dynisco Instruments, S 

240 J Electro Systems, Inc., and McMaster-Carr) identified through 1) online queries for pressure 

measurement devices, and 2) a search of Dun & Bradstreet database under the relevant NAICS code15 241

242 indicated that none made or sold mercury-containing manometers (Ashcroft Inc., 2010; Dwyer 

243 Instruments, 2010; Dynisco Instruments, 2010; S J Electro Systems, Inc.; and McMaster-Carr, 2010). As

244 a result, EPA believes that manufacturing of mercury-containing manometers have been phased-out.

245

246

 

12 Barometers may still be found in secondary markets; in fact, some state bans provide exemptions for antique 

barometers. 

13 A phone conversation with a customer service representative at the Belfort Instrument Company on April 27, 

2010 confirmed the manufacture of at least one model of mercury-containing psychrometers, therefore these were 

excluded from the SNUR (Belfort, 2010).13

14 Scientific Glass & Instruments, which reported the sale of mercury-containing manometers to IMERC in 2001 and 

2004, reported to IMERC that they only produce the glass component and do not fill the manometer with mercury.

15 NAICS 334512: Automatic Environmental Control Manufacturing for Residential, Commercial, and Appliance 

Use.
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247 3. INDUSTRY COMPLIANCE COSTS

248 The proposed SNUR discussed in this report specifies that significant new uses of mercury that require 

249 reporting under section 5(a)(2)(A) of TSCA include the manufacture, import, or processing of elemental 

250 mercury for use in: 1) barometers, 2) manometers, and 3) hygrometers/psychrometers. Not included in 

251 this proposed SNUR is mercury use in portable, battery-powered, motor-aspirated psychrometers 

containing less than 7 grams of elemental mercury because they are currently manufactured.16 252 Therefore,

253 a firm intending to manufacture, import, and/or process elemental mercury for the previously specified 

254 products, must submit a SNUN. Alternatively, a firm can decide not to manufacture, import, and/or 

255 process the chemical for a significant new use. The firm, therefore, has two options:

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

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

258 manufacture, importing, and/or processing of this chemical or articles containing the chemicals. The 

259 firm must submit the SNUN to EPA at least 90 days before it plans to commence the manufacture, 

260 import, and/or processing of the substance; the SNUN provides EPA with the opportunity to evaluate 

261 the intended use and, if necessary, to prohibit or limit that activity before it occurs. If EPA allows the 

262 manufacture, import, or processing of mercury for use in the three products subject to the proposed 

263 SNUR, then the costs associated with this option are the costs of submitting the SNUN (including a 

264 user fee) plus, if there is any export of these products, the export notification costs that result from 

265 TSCA Section 12(b) requirements that are automatically triggered for chemicals regulated under 

266 TSCA Section 5 (see Section 3.2.5 for details). Because the three products subject to the proposed 

267 SNUR are not currently manufactured or imported into the United States, EPA expects that no firms

268 will choose this option. 

269

270  Option 2: Decide not to manufacture, import, and/or process the chemical. The firm may simply 

271 decide to not manufacture, import, or process mercury for use in the three products subject to the 

272 proposed SNUR. While this option avoids the costs of submitting a SNUN, it entails the “hidden”

273 cost of the foregone profit as a result of not engaging in the commercial activity originally planned.

274 Similarly, if the firm would have used a given amount of mercury for use in the production of one of 

275 the three products subject to the proposed SNUR, it may substitute mercury with a more costly 

276 substance and will incur those additional “hidden” costs of production. However, these hidden costs 

277 are expected to be minimal, if not zero, because the manufacture of the mercury-containing products

278 subject to the proposed SNUR has phased out, and firms have begun to produce substitutes for the

279 products prior to the proposed SNUR. If the firm elects to produce mercury for use in the three

280 products subject to the proposed SNUR for research and development (R&D) purposes only (an 

281 exemption for R&D purposes is provided in 40 CFR §721.47), it may have costs associated with 

282 R&D recordkeeping. In addition, if the firm exports any existing stockpiles of the specified mercury283 containing products, it will incur the export notification costs (see Section 3.2.5 for details). 

284

285 Since the products subject to the proposed SNUR are not currently manufactured in the United States, 

286 EPA does not expect there to be compliance cost associated for either of the options. The remainder of 

287 this chapter estimates the quantified portion of costs associated with the proposed SNUR for these uses of 

288 the elemental mercury. Section 3.1 summarizes the wage rates used in this chapter. Section 3.2 provides 

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

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

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

292

 

16 A phone conversation with a customer service representative at the Belfort Instrument Company on April 27, 2010 

confirmed the manufacture of at least one model of mercury-containing psychrometer (Belfort, 2010). 
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293 3.1 Wage Rates

294

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

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

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

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

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

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

301 “Wage Rates for Economic Analysis of the Toxics Release Inventory Program” (EPA, 2002b). Wage 

302 data for each labor category in December 2009 are provided by the Employer Costs for Employee 

303 Compensation (ECEC) Supplemental Tables available on the BLS website (BLS, 2010a). The loaded 

304 wage rate for managerial labor is $68.24; for technical labor, $59.49; and for clerical labor, $28.31. Table 

305 1 presents the basic data used to calculate the loaded wage rates for all three categories of labor.

306

Table 1: Loaded Industry Wage Rates, December 2009

Labor 

Category Data Sources

Wage

(2009$)

Fringe 

Benefit

(2009$)

Fringes 

as % 

wage

Overhead % 

wage2

Fringe + 

overhead 

factor

Loaded 

Wages1

(2009$)

(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

$42.36 $18.68 44.10% 17% 1.61 $68.24

Professional/

Technical

BLS ECEC, Private 

Manufacturing industries, 

“Professional and related“3

$35.96 $17.42 48.44% 17% 1.65 $59.49

Clerical

BLS ECEC, Private 

Manufacturing industries,

“Office and Administrative 

Support” 3

$17.21 $8.17 47.47% 17% 1.64 $28.31

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

2 An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory 

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

2002a).

3 Employer Costs for Employee Compensation Supplementary Tables: December 2009. US Bureau of Labor Statistics, March 

10, 201- (BLS, 2010a).

307

308 3.2 Unit Industry Compliance Costs

309

310 3.2.1 Rule Familiarization

311

312 The proposed rule requires submitters and their staff to become familiar with the SNUR and its various 

313 requirements. The per company burden associated with rule familiarization is approximately 0.55 hours 

314 of technical labor and 0.27 hours of managerial labor, as described in the Economic Analysis of the 

315 Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009b). As shown in Table 2 the 

316 total labor cost associated with rule familiarization by a first-time reporter is $50.92.

317
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Table 2: Rule Familiarization Burden and Cost for SNUR Submitters

Reporting Activity

Clerical Labor (at 

$28.31/hour)

Technical Labor (at 

$59.49/hour)

Managerial Labor 

(at $68.24/hour)

Total Labor Cost

Burden

(hours)

Cost

(2009$)

Burden

(hours)

Cost

(2009$)

Burden

(hours)

Cost

(2009$)

Burden

(hours)

Cost

(2009$)

Rule Familiarization 0.00 $0.00 0.55 $32.72 0.27 $18.20 0.82 $50.92

Total 0.00 $0.00 0.55 $32.72 0.27 $18.20 0.82 $50.92

Source: BLS, 2010a (labor rates); EPA, 2009b (burden hours)

318

319 3.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup

320

321 The proposed SNUR requires first-time submitters (that is, those companies who have not submitted 

322 information to EPA through CDX before) to register their company and key users with the CDX reporting 

tool, deliver a CDX electronic signature to EPA, and establish and use a Pay.gov E-payment account..

17.

323 

324 These activities are only required of first-time submitters (companies already registered with CDX would 

325 not need to re-register for the purposes of complying with the proposed SNUR). The burdens associated 

326 with these activities were estimated in the Economic Analysis of the Premanufacture Notification 

327 Electronic Reporting Final Rule (EPA, 2009b) and are described in more detail below:

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

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

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

331 company.

332

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

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

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

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

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

338 forms (Verification of Authorization) for all authorized submitters to EPA. The total burden 

339 incurred by companies submitting and then verifying electronic signature agreements is 1.75 

340 hours. Note that this burden does not include any additional time required to contact EPA’s CDX 

341 help desk to notify a change of submitter status, should one occur. 

342

343 Filing the electronic signature agreement requires an additional mailing cost of $2.30 per 

344 company (including five $0.44 stamps and five $0.02 business envelopes) (USPS, 2010).

345

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

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

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

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

350

351 As shown in Table 3, the cost associated with CDX registration, CDX electronic signature, and Pay.gov 

352 account setup is $178.21, and this cost is only incurred by a first-time submitter.

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

and Cost for First-Time Submitters

 

17 Although the proposed rule does not specifically 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.
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 8 Economic and Policy Analysis Branch

Reporting Activity

Clerical Labor (at 

$28.31/hour)

Technical Labor (at 

$59.49/hour)

Managerial Labor 

(at $68.24/hour) Total Cost

Burden

(hours)

Cost

(2009$)

Burden

(hours)

Cost

(2009$)

Burden

(hours)

Cost

(2009$)

Burden

(hours)

Cost

(2009$)

CDX Registration 0.00 $0.00 0.73 $43.63 0.18 $12.51 0.92 $56.13

CDX Electronic 

Signature 0.00 $0.00 1.00 $59.49 0.75 $51.18 1.75 $110.67

Mailing Cost $2.30

E-Payment (Pay.gov

ID) 0.00 $0.00 0.00 $0.00 0.13 $9.10 0.13 $9.10

Total 0.00 $0.00 1.73 $103.12 1.07 $72.79 2.80 $178.21

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

353

354 3.2.3 Form Completion and Submission Fee

355

356 Respondents are required to gather and submit information regarding the data elements identified in the

357 applicable SNUN reporting form. The methodology and calculations used in this analysis assume that the 

358 employee responsible for collecting, filling out, and submitting the requested information has a 

359 reasonable level of familiarity with the company and knowledge of operations at the site. It is assumed 

360 that for most entities these tasks are similar to other employee duties that require familiarity with EPA, 

361 State, and other Federal agency requests for chemical information and do not require additional 

362 familiarization or training beyond the basic rule familiarization described above. In addition, this analysis 

363 focuses on the marginal costs of submitting information for the proposed rule and not the total costs for 

364 the company to comply with a range of other Federal and State environmental, health, and safety 

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

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

367 of completing a Premanufacture Notification (PMN) submission, since the data requirements are the same 

368 and the same form is used for both. The PMN submission costs are based on EPA's 1994 Regulatory 

369 Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications and the 

370 updates to this estimates in 2009 (EPA, 2009b). The original 1994 estimates relied on industry estimates 

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

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

373 III-11, -12, and -13). The 1994 estimates were based on a survey conducted by the Chemical 

374 Manufacturers Association (CMA, 1991), which became the American Chemistry Council. These 

375 burdens “include the time spent reading and becoming familiar with the form, gathering the required 

376 information and preparing the report, producing sanitized responses for items claimed as confidential 

377 business information, and maintaining a file of the submission” (EPA, 1994. p. III 11-13). The burden 

378 associated with SNUN submission and preparation has been adjusted to reflect burden reductions 

379 resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that requires the electronic 

380 submission of all TSCA section 5 notices. Electronic submission of SNUN forms is expected to remove 

381 all clerical burden associated with preparing a SNUN (EPA, 2009b).

382

383 SNUN form completion and electronic submission is estimated to require 74.20 hours of technical labor 

384 and 18.00 hours of managerial labor (EPA, 2009b). Table 4 combines the estimated reporting burden and 

385 loaded wage rates for all three labor categories to estimate the per-SNUN cost of form completion. The 

386 labor cost incurred by a SNUN submission for both large and small business submitters is $5,643.

387

Table 4: Industry Cost Estimate to Complete the SNUN Form
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 9 Economic and Policy Analysis Branch

Reporting Activity

Clerical Labor (at 

$28.31/hour)

Technical Labor (at 

$59.49/hour)

Managerial Labor 

(at $68.24/hour) Total Labor Cost

Burden

(hours)

Cost

(2009$)

Burden

(hours)

Cost

(2009$)

Burden

(hours)

Cost

(2009$)

Burden

(hours)

Cost

(2009$)

Form Completion 0.00 $0.00 74.20 $4,414 18.00 $1,228 92.20 $5,643

Source: BLS, 2010a (labor rates); EPA, 2009b (burden hours)

388

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

390 submitting small business must pay a $100 per-SNUN submission fee. Table 5 adds the labor cost and 

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

392 $8,143 for large business submitters and $5,743 for small business submitters.

393

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

Reporting Population Labor Cost Submission Fee Total Cost 

(2009$)

Large Business Submitters $5,643 $2,500 $8,143

Small Business Submitters $5,643 $100 $5,743

Source: EPA, 2009b.

394

395 3.2.4 Import Certification

396

397 In general, promulgation of a final SNUR triggers a TSCA Section 13 import certification requirement 

398 and the corresponding regulations at 19 CFR 12.118 to 12.127 and 19 CFR 127.28 for all imports of the 

399 relevant chemical substances. Thus, any U.S. manufacturer, importer, or processor receiving an imported 

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

401 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.18 402 The statement must be on or attached to a 

403 commercial invoice or entry document belonging to the imported shipment.

404 In practice, import certification is fulfilled by checking a box on an invoice or entry document and 

405 generally imposes no additional burden or cost on the importer (EPA, 2009c). Any potential burden 

406 associated with a submitter’s familiarization with this requirement is assumed to be included in the more 

407 general SNUR familiarization burden discussed above.

408

409 3.2.5 Export Notification

410

411 Under Section 12(b) of TSCA, exporters must notify EPA if they export or intend to export a chemical or 

412 an article subject to various TSCA sections (40 CFR §707.60 through 75). For TSCA 5(a)(2) (the section 

413 under which EPA promulgates significant new use rules) and certain other TSCA sections, this is a onetime notification requirement19 414 per destination country for each exporter of a chemical substance. After 

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

416 Department (40 CFR §707.70). To calculate the burden associated with making export notifications, EPA 

 

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

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

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

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

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

19 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). 
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 10 Economic and Policy Analysis Branch

417 first estimated the average annual number of export notifications made by an exporter. EPA then derived 

418 the annual and per notification burden associated with preparing and submitting an export notification. 

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

420 total number of exporters of elemental mercury for the uses subject to the SNUR, or the number of 

421 notifications per specified mercury-containing product. It is also important to note that the Mercury 

422 Export Ban Act of 2008 will forbid export of elemental mercury from the United States beginning in 

423 2013. Therefore, beyond 2013, there will be no export notification costs related to export of elemental 

424 mercury for these uses; the only cost would be if there is import of mercury-containing barometers, 

425 manometers and/or hygrometers/psychrometers. 

426

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

428 [Information Collection Request for] Notification of Chemical Exports - TSCA Section 12(b) Supporting 

429 Statement for Request for OMB Review under the Paperwork Reduction Act (EPA, 2009c), with updating 

430 for inflation. 

431

432 Exporter Costs

433

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

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

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

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

438 and sending the notification letters with the associated shipping costs. 

439 The per-notification cost was calculated based on the assumption that the average exporter makes 12 

notifications per year.

20 440 Exporters making more notifications per year may benefit from economies of 

441 scale and have lower costs per notification; those making fewer notifications may have higher costs per 

442 notification.

443 Estimated Submission (Mailing) Costs. Regulated companies will incur mailing costs for export 

444 notifications delivered to EPA. Notifications are assumed shipped via the U.S. Postal Service (USPS) as 

445 first-class registered mail with a return receipt (USPS, 2010). The estimated per-shipment and annual 

446 mailing costs incurred by individual submitters are detailed in Table 6.

447

 

20 EPA calculated the average number of export notifications per exporter in the 2009 TSCA Section 12(b) ICR

(EPA, 2009d) by dividing the estimated number of submitted notifications (3,500) by the estimated number of 

exporters (300).
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 11 Economic and Policy Analysis Branch

Table 6: Derivation of Total Mailing Cost for 12 Notices

Dates that the rates were verified on United States Postal Service web site: April 2010

Postal services costs

Registered mail, regular, with $0 declared value $10.60

Return receipt, requested at time of mailing (receive by mail) $2.30

Postage, regular First Class, up to 1 ounce $0.44

Cost per export notice – Subtotal $13.34

Source: Mailing rates are from the US Postal Service web site as of April 2010 (http://www.usps.com/prices/). The mailing 

method comes from the Economic Analysis of the Proposed Change to TSCA Section 12(b) Export Notification 

Requirements, November 2005 (EPA, 2005), as clarified in a later SNUR economic analysis (EPA, 2007a, Table 8). 

448

449 Compile and Maintain the List of Products. Since TSCA §12(b) information collection activity has been 

450 in place for twenty years, most respondents will have already developed a list of their products subject to 

451 TSCA §12(b) export notification. Respondents need only check for new regulations promulgated and any 

452 new products exported by the company. Updating the list is estimated to take an average of one hour of 

453 technical time, which may also include some proportion of legal time (EPA, 2009c). The total burden can 

454 vary from two hours per year up to two hours per month, depending on the number of products exported 

455 by the company and the number of their products subject to TSCA §12(b) (EPA, 2009c).

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

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

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

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

460 include some proportion of legal time) per firm per year for 12 notifications per year, or 0.08 hours per 

461 notification (EPA, 2009c).

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

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

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

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

466 (EPA, 2009c). 

467 The burdens and associated costs for each notification activity are provided in Table 7 below. 

468

Table 7: TSCA 12(b) Export Notification Cost per Notification

Technical Clerical Total

$/Hr Hours 2009$ $/Hr Hours 2009$ 2009$ Hours

Compile list $59.49 0.78 $46.08 -- -- -- $46.08 0.78

Write letter $59.49 0.08 $4.96 -- -- -- $4.96 0.08

Check order and send 

notice -- -- -- $28.31 0.50 $14.17 $14.17 0.50

Mailing cost1-- -- -- $13.34 -

Total per notification 0.86 $51.04 0.50 $14.15 $78.54 1.36
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 12 Economic and Policy Analysis Branch

Table 7: TSCA 12(b) Export Notification Cost per Notification

Technical Clerical Total

$/Hr Hours 2009$ $/Hr Hours 2009$ 2009$ Hours

Notes:

1 Mailing costs reflect April 2010 USPS rates and can be found in Table 6.

2

Per notification costs are based on an average facility submitting notifications, that is assumed to submit 12 export 

notifications per year.

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

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

and are updated to 2009 dollars. 

469

470 3.3 Industry Costs of SNUR, by Option (per Submission)

471

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

473 aggregated across the affected entities. Table 8 summarizes the costs to comply with the proposed rule, 

474 as described in more detail in section 3.2 above.
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 13 Economic and Policy Analysis Branch

Table 8: Compliance Options and Associated Costs Incurred by a Firm Due to the Proposed SNUR

Option1 Costs Quantified Costs per Chemical (2008$)2

1. Submit a 

SNUN.

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, 

$50.92 rule familiarization cost; $8,143 submission cost 

(including SNUN recordkeeping and $2,500 fee). EPA 

usually receives well under ten SNUNs per year. Based on 

review of recent SNUNs, it appears that firms rarely 

conduct toxicity or fate testing to support a SNUN (such 

testing would be voluntary).3 Export notifications costs are 

estimated at $78.56 per notification; total cost per company 

will vary. First time submitters would incur $178 for CDX 

registration and associated activities.

2.

Decide not to 

manufacture, 

import, or 

process the 

chemical.

Cost of the profit foregone as 

a result of not engaging in the 

commercial activity originally 

planned, and recordkeeping 

costs only if manufacturing 

for research and development.

Costs not quantified. Rule familiarization and export 

notification costs may apply.

Notes:

1

Firms may be subject to both options at once since submission of a SNUN results in profits foregone as a result of 

not manufacturing, importing, or processing the chemical.

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

Costs are detailed in Section 3.2.

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

already in its possession and/or describe any other available data. Because EPA does not require the development of 

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

475

476 3.4 Likelihood of a SNUN Submission

477

478 EPA believes that the use of elemental mercury for manufacturing the specified mercury-containing 

products has been phased out in the United States (see section 2.2).

21 479 Therefore, very few, if any, entities

480 are expected to submit a SNUN. 

481

482 3.5 Potential for Subsequent Regulatory Action

483 EPA recognizes that if submission of a SNUN does result from the proposed SNUR, the Agency may 

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

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

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

487 specific subsequent regulatory actions, if any, the Agency may determine are necessary after reviewing a 

488 SNUN. Any such actions are highly dependent on the circumstances surrounding the individual SNUN 

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

490 SNUN is being reviewed). 

491 Should EPA’s review of the SNUN result in further regulatory actions, the Agency will initiate and 

492 follow the appropriate procedures for taking those actions. Included in those procedures would be an 

493 assessment of the costs and benefits of those actions.

494

 

21 These products may still be in use, resold in the aftermarket, or stored in homes and businesses, but these 

activities are not subject to the SNUR. 
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 14 Economic and Policy Analysis Branch

495

496 4. AGENCY COSTS

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

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

499 4.1 Labor Rates for EPA Staff

500

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

502 published by the Office of Personnel Management effective January 2009 (OPM, 2009). EPA assumes 

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

administrative activities under the proposed rule. 22 504 The average salary for a GS-13 Step 5 employee was 

505 $98,518 in 2009 without fringe benefits and overhead costs. In order to derive the fully loaded salary, 

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

507 overhead, which results in a fully loaded annual salary of $157,629 (see Table 9). Dividing the fully 

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

509 compensation wage rate of $75.78.

510 The Agency loading factor of 1.6 is from an EPA guide entitled Instructions for Preparing Information 

511 Collection Requests (ICRs) (EPA, 1992, page 30, footnote 9). The 60 percent assumption was labeled 

512 “the benefits multiplication factor” in the EPA guide, but has been used in many EPA OPPT ICRs to 

513 reflect both fringe benefits and overhead for federal staff. For example, it was used in a document 

514 supporting EPA ICR No. 1139.06 (EPA, 2000), with the following explanation:

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

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

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

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

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

520 but also overhead.

521

522 Fully loaded costs for Agency labor are shown in Table 9.

 

22 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007) (EPA, 2007b), 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.
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 15 Economic and Policy Analysis Branch

523

Table 9: Derivation of Loaded Agency Wage Rates

Labor 

Category

Data Source for Wage 

Information Date

Wage

Fringe 

Benefit

Fringes as 

% wage

Overhead 

as % wage

Fringe + 

overhead 

factor

Loaded 

Wages

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

EPA staff 

FTE

Annual federal staff cost: 

OPM WashingtonBaltimore-Northern 

Virginia, DC-MD-PAVA-WV, area, GS-13 

Step 1 pay rates a

Dec09

$98,518 

(annual)

--

[Included 

in 60% 

overhead]

60% b1.60

$157,629 

(annual)

$47.36 

(hourly)

$75.78 

(hourly)

Notes:

a The Agency salary is the unloaded federal GS-13 Step 5 salary ($98,518 for 2009), from the OPM salary table for the 

Washington-Baltimore-Northern Virginia Locality Pay Area (OPM, 2009). Hourly rates are based on annual salary divided by 

2,080 hours.

b The 60% fringes-and-overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) 

(EPA, 1992, page 30, footnote 9).

524

525 4.2 SNUN Processing Costs

526

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

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

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

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

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

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

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

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

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

536 review step. 

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

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

539 Statistics (BLS) Employment Cost Index (ECI) data (BLS, 2010b). The not seasonally adjusted ECI for 

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

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

542 technical labor, which perform the majority of Agency extramural activities. Table 10, below contains 

543 the derivation of inflation factors for Agency extramural costs.
Economic Analysis of SNUR for Three U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products 16 Economic and Policy Analysis Branch

Table 10: Derivation of Inflation Factors for Agency Extramural Costs

Item Inflation index source Starting 

year

Index for 

starting 

year

(a)

Index 

for 

2009

(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 2010d] 4

1993 67.0 111.4 1.663

Source:

Bureau of Labor Statistics. Employment Cost Index – Total Compensation: Professional and Related Private Industry, Not 

Seasonally Adjusted. (Series ID: CIU2010000120000I), extracted April 12, 2010 (BLS, 2010b).

544

545 The Percent of Cases column in Table 11 is a weighting factor applied to reflect the fact that not all 

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

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

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

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

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

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

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

553 records from archives, and the likelihood that more data requiring EPA review is submitted with a SNUN 

554 than would be submitted on average with a PMN. Resources were not available to update the review 

555 hours to reflect the current review process or to tailor the cost estimates to SNUNs. Therefore, for this 

556 analysis, the review steps and weighting factors are assumed to be the same as those derived in 1994 for 

557 PMNs.

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

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

560 multiplied by the burden reduction of 16.5 percent to account for burden savings generated electronic 

561 submission. This calculation yields total Agency costs of $4,934, per SNUN, for submission review and 

562 processing, as shown in Table 11.
Economic Analysis of SNUR for Three 17 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

Table 11: Agency Costs for SNUN and Other Submission Review and Processing

Review Steps

EPA staff (FTE) Cost Extramural Cost 2

Unweighted 

Cost

Pct. of 

Cases

Weighted 

Cost3

ePMN 

Burden 

Reduction4

Weighted Cost 

with ePMN 

Burden Reduction

FTE 

fraction

Cost per 

FTE 1

FTE Total 

($2009)

1993 

dollars

2009 

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 $157,629 $378 $4.00 $6.65 $385 41% $158 0.165 $132

Administrative prescreen/ 

notice receipt/user fee 0.0024 $157,629 $378 $92.00 $152.97 $531 100% $531 0.165 $444

CRSS (Chemical Review and 

Search Strategy) 0.0025 $157,629 $394 $268.00 $445.60 $840 100% $840 0.165 $701

SAT (Structure Activity 

Team)

0.0006 $157,629 $95 $14.00 $23.28 $118 100% $118 0.165 $98

Engineering/Exposure 0.0015 $157,629 $236 $56.00 $93.11 $330 100% $330 0.165 $275

Exposure/Fate 0.0008 $157,629 $126 $0.00 $0.00 $126 100% $126 0.165 $105

Focus 0.0009 $157,629 $142 $23.00 $38.24 $180 100% $180 0.165 $150

Standard Review Functions 0.0219 $157,629 $3,452 $511.00 $849.63 $4,302 29% $1,247 0.165 $1,042

Division Directors Meeting 0.0129 $157,629 $2,033 $113.00 $187.88 $2,221 15% $333 0.165 $278

Order 

Development/Negotiation

Review

0.0171 $157,629 $2,695 $22.00 $36.58 $2,732 3% $82 0.165 $68

Post Order Data Review 0.0886 $157,629 $13,966 $0.00 $0.00 $13,966 3% $419 0.165 $350

Order Modification 0.2167 $157,629 $34,158 $0.00 $0.00 $34,158 3% $1,025 0.165 $856

New Chemical SNUR 

Development 0.0277 $157,629 $4,366 $85.00 $141.33 $4,508 7% $316 0.165 $263

Notices of Commencement 0.0012 $157,629 $189 $40.00 $66.51 $256 31% $79 0.165 $66

FOIA (Freedom of 

Information Act) Requests 0.0333 $157,629 $5,249 $287.00 $477.19 $5,726 1% $57 0.165 $48

CBI (Confidential Business 

Information) Substantiation 0.0004 $157,629 $63 $3.00 $4.99 $68 100% $68 0.165 $57

TOTAL $5,909 0.165 $4,934 

Notes:

1 GS-13 Step 5 salaries loaded with benefits and overhead. See Table 9 for derivation.

2 Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated from 1993 prices using {insert reference]. 

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

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

Sources: FTEs per review step, 1993 extramural costs, and percents of cases are from EPA, 1994 Table VII-1, GS-13 salaries are from OPM, 2009.
Economic Analysis of SNUR for Three 18 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

563 4.3 Export Notification Cost

564 The Agency burden and cost due to TSCA §12(b) export notification result from three tasks. In the first 

565 task, EPA receives export notifications from companies that intend to export one of the chemicals subject 

566 to TSCA §12(b) (EPA, 2009c). In the second task, EPA staff prepares separate notification letters that are 

567 subsequently reviewed and delivered to importing countries, their embassies, or representatives, and to 

568 the importing country’s US embassies (EPA, 2009c). (See Table 6 for the cost of mailing one 

569 notification). The third task is comprised of EPA staff responses to public inquiries and other TSCA 

570 12(b) activities. The work of responding to non-routine requests for information and clarification from 

571 industry and importing countries, and of handling other tasks associated with the TSCA §12(b) program, 

572 was estimated to require roughly 400 hours per year (EPA, 2009c). Since the current rulemaking covers 

573 only one chemical subject to TSCA 12(b) reporting for a minimal number of uses, a very small percent of 

574 such activity will be attributable to the current rulemaking.

575 Because the manufacture of mercury-containing products subject to the proposed SNUR is phased out, 

576 EPA does not expect to receive or send any export notifications. Nevertheless, should there be any 

577 notifications as a result of the current rulemaking, the costs to the Agency are presented per activity. The 

578 burden for the first two Agency activities is provided in Table 12 below. To estimate the Agency cost, 

579 hourly burdens are multiplied by the loaded wage rate of a GS-13, Step 5, which is derived in Table 9. 

580

Table 12: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2009$)

Agency Activity

Hours per 

Activity

FTE per 

Activity1

Loaded Mailing 

Cost

Total Agency Cost per 

Activity GS-13, Step 5 FTE 

Wage Rate

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

Process an incoming 

notification from an 

exporting company

0.10 0.000048 $157,629 $0.00 $7.58

Prepare and mail a 

notification to an 

importing country

0.50 0.000240 $157,629 $13.34 $51.23

Notes:

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

and mail an outgoing notification 

Source: Table 9 of this report derives Agency labor costs. Mailing costs are from Table 6 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.

581

582

583
Economic Analysis of SNUR for Three 19 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

584

585 5. ADDITIONAL ANALYSES

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

587 various statutes and executive orders.

588 5.1 Small Entity Impacts

589

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

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

592 a substantial number of small entities. The rationale supporting this conclusion is as follows. A SNUR 

593 applies to any person (including small or large entities) who intends to engage in any activity described in 

594 the rule as a "significant new use." By definition of the word "new," and based on all information 

595 currently available to EPA, it appears that no small or large entities presently engage in such activity. 

596 Since this proposed SNUR would require a person who intends to engage in such activity in the future to 

597 first notify EPA by submitting a SNUN, no economic impact will occur unless someone files a SNUN to 

598 pursue a significant new use in the future or forgoes profits by avoiding or delaying the significant new 

599 use. Although some small entities may decide to conduct such activities in the future, EPA cannot 

600 presently determine how many, if any, there may be. However, EPA's experience to date is that, in 

601 response to the promulgation of over 1,000 SNURs, the Agency receives on average only 5 notices per 

602 year. Of those SNUNs submitted, only one appears to be from a small entity in response to any SNUR. 

603 Therefore, EPA believes that the potential economic impact of complying with a SNUR is not expected to 

604 be significant or adversely impact a substantial number of small entities. In a SNUR that published as a 

605 final rule on August 8, 1997 (62 FR 42690)(FRL-5735-4), the Agency presented its general determination 

606 that proposed and final SNURs are not expected to have a significant economic impact on a substantial 

607 number of small entities, which was provided to the Chief Counsel for Advocacy of the Small Business 

608 Administration.

609

610 5.2 Unfunded Mandates

611

612 Based on EPA's experience with proposing and finalizing SNURs, State, local, and Tribal governments 

613 have not been impacted by these rulemakings, and EPA does not have any reason to believe that any 

614 State, local, or Tribal government would be impacted by this rulemaking. As such, EPA has determined 

615 that this regulatory action would not impose any enforceable duty, contain any unfunded mandate, or 

616 otherwise have any effect on small governments subject to the requirements of sections 202, 203, 204, or 

617 205 of the Unfunded Mandates Reform Act of 1995 (UMRA) (2 U.S.C. 1531-1538).

618

619 5.3 Paperwork Reduction Act

620

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

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

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

624 control number. The OMB control numbers for certain EPA regulations in title 40 of the CFR, after 

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

626 instrument, or form, if applicable. 

627

628 The information collection requirements related to this action have already been approved by OMB 

629 pursuant to the PRA under OMB control number 2070-0038 (EPA ICR No. 1188). This action does not 

630 impose any burden requiring additional OMB approval. If an entity were to submit a SNUN to the 

631 Agency, the annual burden is estimated to average 97 hours per response. This burden estimate includes 
Economic Analysis of SNUR for Three 20 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

632 the time needed to review instructions, search existing data sources, gather and maintain the data needed, 

633 and complete, review, and submit the required SNUN. 

634

635 5.4 Technical Standards

636

637 Because this action does not involve any technical standards; section 12(d) of the National Technology 

638 Transfer and Advancement Act of 1995 (NTTAA), Public Law 104-113, Section 12(d) (15 U.S.C. 272 

639 note), does not apply to this action.

640 5.5 Regulatory Planning and Review

641

642 Under Executive Order 12866, entitled Regulatory Planning and Review (58 FR 51735, October 4, 1993), 

643 the Office of Management and Budget (OMB) has determined that this action is a "significant regulatory 

644 action," because it may raise novel legal or policy issues arising out of legal mandates, the President’s 

645 priorities, or the principles set forth in the Executive Order. Accordingly, EPA submitted this action to 

646 OMB for review under Executive Order 12866 and any changes made in response to OMB 

647 recommendations have been documented in the docket for this action as required by section 6(a)(3)(E) of 

648 the Executive Order. 

649

650 5.6 Environmental Justice 

651

652 This action does not entail special considerations of environmental justice related issues as delineated by 

653 Executive Order 12898, entitled Federal Actions to Address Environmental Justice in Minority 

654 Populations and Low-Income Populations (59 FR 7629, February 16, 1994).

655 5.7 Protection of Children

656

657 EPA interprets Executive Order 13045, entitled Protection of Children from Environmental Health Risks 

658 and Safety Risks (62 FR 19885, April 23, 1997), as applying only to those regulatory actions that concern 

659 health or safety risks, such that the analysis required under section 5-501 of the Executive Order has the 

660 potential to influence the regulation. This action is not subject to Executive Order 13045 because it does 

661 not establish an environmental standard intended to mitigate health or safety risks.

662 5.8 Federalism 

663

664 This action will not have federalism implications because it is not expected to have a substantial direct 

665 effect on States, on the relationship between the national government and the States, or on the distribution 

666 of power and responsibilities among the various levels of government, as specified in Executive Order 

667 13132, entitled Federalism (64 FR 43255, August 10, 1999).

668 5.9 Tribal Governments 

669

670 This action will not have tribal implications as specified in Executive Order 13175, entitled Consultation 

671 and Coordination with Indian Tribal Governments (65 FR 67249, November 9, 2000). This action is not 

672 expected to have substantial direct effects on Indian Tribes, will not significantly or uniquely affect the 

673 communities of Indian Tribal governments, and does not involve or impose any requirements that affect 

674 Indian Tribes. Thus, Executive Order 13175 does not apply to this action. 

675

676 5.10 Effect on Energy Supply, Distribution, or Use 

677

678 This action is not a “significant energy action” as defined in Executive Order 13211, entitled Actions 

679 Concerning Regulations That Significantly Affect Energy Supply, Distribution, or Use (66 FR 28355, 
Economic Analysis of SNUR for Three 21 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

680 May 22, 2001), because this action is not likely to have a significant adverse affect on the supply, 

681 distribution, or use of energy.
Economic Analysis of SNUR for Three 22 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

682

683 6. REFERENCES 

684

685 15 U.S.C. 272, National Technology Transfer and Advancement Act of 1995 (NTTAA), Public Law 104–

686 113, Section 12(d).

687

688 19 CFR 12, Customs Duties: Special Classes of Merchandise, Code of Federal Regulations, Part 12, Title 

689 19, August 1, 1983.

690

691 40 CFR 707, Chemical Imports and Exports, Code of Federal Regulations, Part 707, Title 40, July 1, 

692 2003.

693

694 40 CFR 720, Premanufacture Notification, Code of Federal Regulations, Part 720, Title 40, July 1, 2003.

695

696 40 CFR 721, Significant New Use of Chemical Substances, Code of Federal Regulations, Part 721, Title 

697 40, July 1, 2003.

698

699 59 FR 7629, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income 

700 Populations, Federal Register, Volume 59, February 16, 1994.

701

702 59 FR 22951, Consultation and Coordination with Indian Tribal Governments, Federal Register, Volume 

703 59, November 6, 2000.

704

705 62 FR 19885, Protection of Children from Environmental Health Risks and Safety Risks, Federal 

706 Register, Volume 62, April 23, 1997.

707

708 64 FR 43255, Federalism, Federal Register, Volume 65, August 10, 1999.

709

710 66 FR 28355, Actions Concerning Regulations that Significantly Affect Energy Supply, Distribution, or 

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

712

713 71 FR 66234, Export Notification; Change to Reporting Requirements, Final Rule, Federal Register, 

714 Volume 71, November 14, 2006. Available in docket EPA-HQ-OPPT-2005-0058 at 

715 http://www.regulations.gov.

716

717 Ashcroft Inc. 2010. Phone conversation between Jacob Grindal (Abt Associates) and Customer Service 

718 Representative (Ashcroft Inc.). June 23, 2010.

719

720 Belfort, 2010. Phone conversation between Jacob Grindal (Abt Associates) and Customer Service 

721 Representative (Belfort Instrument Company). April 27, 2010.

722

723 BLS, 2010a. U.S. Bureau of Labor Statistics. “Employer Costs for Employee Compensation 

724 Supplementary Tables December 2009”. (March 10, 2010) at 

725 http://www.bls.gov/ncs/ect/sp/ecsuptc13.pdf. (Note: The BLS report title and content is updated

726 periodically to include more recent data, on the same website.) 

727
Economic Analysis of SNUR for Three 23 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

728 BLS, 2010b. Bureau of Labor Statistics. Employment Cost Index – Total Compensation: Professional and 

729 Related Private Industry, Not Seasonally Adjusted. (Series ID: CIU2010000120000I), extracted 

730 April 12, 2010.

731

732 CMA, 1991. Chemical Manufacturers Association. Responses to Questions on Burden Associated with 

733 PMN Submissions. Distributed by the Chemical Manufacturers Association, Washington, DC.

734

735 Columbia Encyclopedia. 2010. “Barometer.” Available at: http://www.answers.com/topic/barometer

736

737 DEPA, 2006. Danish Environmental Protection Agency “Alternatives to Mercury-Containing Measuring 

738 Devices.” 2006 Available at: 

739 http://www2.mst.dk/common/Udgivramme/Frame.asp?http://www2.mst.dk/udgiv/publications/20

740 06/87-7052-133-6/html/helepubl_eng.htm

741 Dwyer Instruments. 2010. Phone conversation between Tulika Narayan (Abt Associates) and two 

742 Technical Representatives. May 24, 2010.

743 Dynisco Instruments. 2010. Phone conversation between Jacob Grindal (Abt Associates) and Brady 

744 Davison (Regional Manager, Dynisco Instruments). June 23, 2010.

745 EPA, 1992. U.S. EPA, Office of Policy, Planning, and Evaluation. Instructions for Preparing Information 

746 Collection Requests (ICRs). Washington, DC, June 1, 1992.

747

748 EPA, 1994. US EPA, Office of Toxic Substances, Regulatory Impacts Branch. Regulatory Impact 

749 Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications.

750 Washington, DC: U.S. EPA/OPPT/EETD/RIB, September 9, 1994. (OTS/RIB later became 

751 OPPTS/EPAB.)

752

753 EPA, 2000. U.S. EPA, Office of Pollution Prevention and Toxics, ICR No. 1139.06. [Information 

754 Collection Request for] TSCA Existing Chemical Test Rules, Consent Orders, Test Rule 

755 Exemptions, and Voluntary Test Data Submissions: Supporting Statement for Request for OMB

756 Review under the Paperwork Reduction Act. Attachment 5, Wage Rates Estimation, August 29, 

757 2000.

758

759 EPA, 2002a U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. 

760 Revised Economic Analysis for the Amended Inventory Update Rule: Final Report. Washington, 

761 DC. August 2002.

762

763 EPA, 2002b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis 

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

765 Washington, DC, June 10, 2002.

766

767 EPA, 2003. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. 

768 Economic Analysis of Expedited Significant New Use Rules for 65 Chemical Substances.

769 Washington, DC, 2003. Available in docket EPA-HQ-OPPTS-2002-0078 at 

770 http://www.regulations.gov.

771 EPA, 2005. Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Economic 

772 Analysis of the Proposed Change to TSCA Section 12(b) Export Notification Requirements, 

773 November 2005, available from the Federal Docket Management System as EPA-HQ-OPPT774 2005-005 8-0017 at http://www.regulations.gov.
Economic Analysis of SNUR for Three 24 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

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

776 Branch. Economic Analysis of Expedited Significant New Use Rules for 38 Chemical 

777 Substances (EPA Docket OPPT-2006-0898), August 17, 2007.

778 EPA, 2007b. U.S. EPA, Office of Pollution Prevention and Toxics, ICR No. 0574.14. [Information 

779 Collection Request for] Pre-Manufacture Review Reporting and Exemption Requirements for 

780 New Chemical Substances and Significant New Use Reporting Requirements for Chemical 

781 Substances: Supporting Statement for a Request for OMB Review under The Paperwork 

782 Reduction Act, December 6, 2007.

783

784 EPA 2009a. U.S. EPA, Office of Pollution Prevention and Toxics, Polybrominated Diphenyl Ethers 

785 (PBDEs) Action Plan. December 30, 2009 at 

786 http://www.epa.gov/oppt/existingchemicals/pubs/pbdes_ap_2009_1230_final.pdf.

787

788 EPA, 2009b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis 

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

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

791

792 EPA, 2009c. U.S. EPA, Office of Pollution Prevention and Toxics. ICR No.: 0795.13 [Information 

793 Collection Request for] Notification of Chemical Exports - TSCA Section 12(b) Supporting 

794 Statement for Request for OMB Review under the Paperwork Reduction Act. March 6, 2009 at

795 http://www.regulations.gov.

796

797 EPA, 2010 [expected]. U.S. EPA, U.S. EPA, Office of Pollution Prevention and Toxics, Economic and 

798 Policy Analysis Branch. Economic Analysis of Expedited Significant New Use Rules for 25 

799 Chemical Substances. (EPA-HQ-OPPT-2009-0922). Not yet published.

800

801 Environment Canada, 2004. “Mercury and the Environment: Sources of Mercury: Mercury-containing 

802 Products.” Available at: http://www.ec.gc.ca/MERCURY/SM/EN/sm-mcp.cfm#HD.

803 IMERC, 2007. Interstate Mercury Education and Reduction Clearinghouse. “Mercury Use in School 

804 Classrooms: Summary and Assessment of Non-Mercury Alternatives.” 2007 Available at:

805 http://www.newmoa.org/prevention/mercury/schools/MercuryAlternativesReport.pdf

806 IMERC, 2008a Interstate Mercury Education and Reduction Clearinghouse “Trends in Mercury Use in 

807 Products: Summary of the Interstate Mercury Education and Reduction Clearinghouse (IMERC) 

808 Mercury-Added Products Database.” 2008. Available at: 

809 http://www.newmoa.org/prevention/mercury/imerc/pubs/reports.cfm

810 IMERC, 2010a Interstate Mercury Education and Reduction Clearinghouse (IMERC). 2010a. “Mercury 

811 Legacy Products: Commercial Products: Measuring Devices.” Available at: 

812 http://www.newmoa.org/prevention/mercury/projects/legacy/measdev.cfm.

813 IMERC, 2010b Interstate Mercury Education and Reduction Clearinghouse (IMERC). . “IMERC Fact 

814 Sheet: Mercury Use in Measuring Devices.” 2010. Available at: 

815 http://www.newmoa.org/prevention/mercury/imerc/factsheets/measuring_devices.cfm.

816 Maine DEP, 2003. Maine Department of Environmental Protection. “An Investigation of Alternatives to 

817 Mercury-Containing Products.” Lowell Center for Sustainable Production. Prepared by Galligan, 

818 Catherine; Morose, Gregory; and Jim Giordani. 2003. Available at: 

819 http://www.sustainableproduction.org/downloads/An%20Investigation%20Hg.pdf.
Economic Analysis of SNUR for Three 25 U.S. EPA Office of Pollution Prevention and Toxics

Mercury Legacy Products Economic and Policy Analysis Branch

820 McMaster-Carr. Phone conversation between Jacob Grindal (Abt Associates) and Customer Service 

821 Representative (S J Electro Systems, Inc.). June 23, 2010.

822 OPM, 2009. Office of Personnel Management, Salary Table 2009-DCB, Washington BaltimoreNorthern 

823 Virginia, DC-MD-PA-VA-WV. Accessed from http://www.opm.gov/oca/09tables/pdf/DCB.pdf. 

824

825 Rawie, Carol. 2009. EPA Office of Pollution Prevention and Toxics. Personal communication with Tulika 

826 Narayan and Kimberly Wilson of Abt Associates via e-mail. February 5, 2009.

827

828 S J Electro Systems, Inc. Phone conversation between Jacob Grindal (Abt Associates) and Customer 

829 Service Representative (S J Electro Systems, Inc.). June 23, 2010.

830 U.S. SBA. 2010. Table of Small Business Size Standards Matched to North American Industry 

831 Classification System Codes. Available at: 

832 http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf

833 USPS, 2010. U.S. Postal Service Mailing and postage rates. <http://www.usps.com/prices>. (Accessed 23

834 April 2010).

835 Vermont Agriculture Agency. 2001. Mercury Manometer Replacement Program Update. Available at: 

836 http://www.vermontagriculture.com/2001report.htm.

837 Wisconsin Department of Natural Resources (WI DNR). 2007. Mercury Reduction Program: Dairy 

838 Farms. Available at: http://www.dnr.state.wi.us/org/caer/cea/mercury/program.htm.

839

840

841

842

843

844