### gysn;r 3



# Economic Analysis of Expedited Significant New Use Rules
for 25 Chemical Substances

(EPA DOCKET EPA-HQ-OPPT-2009-0922)



# May 12, 2010

—Does not contain TSCA CBI—

Prepared by:

Economic and Policy Analysis Branch Economics, Exposure and Technology Division

Office of Pollution Prevention and Toxics Office of Chemical Safety and Pollution Prevention U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460

### CONTRIBUTORS

The EPA analyst responsible for this report was Carol Rawie. An alytical and draft preparation support was provided by Abt Associates In c. under EPA Contract No. EP-W08-010.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 i May 12, 2010

### ABSTRACT

This Economic Analysis estimates the poten tial costs of Significant New Use Rules (SNURs) covering 25 chemicals that have been the subject of TSCA premanufacture notices (PMNs). The SNURs are being published under the rulemaking docket number EPA-HQOPPT-2009-0922 as direct final rules. The SNURs define “Significant New Uses” that trigger EPA notice requirements. To submit a Si gnificant New Use Notice or request a SNUR modification, a firm incurs a modest submission cost, plus costs of any additional data generated to support the submission. By avoiding a Signi ficant New Use, a firm can avoid submission costs, but may incur other compliance costs. Fo r example, it may incu r costs of restricting chemical releases to water or preventing worker exposure.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 ii May 12, 2010

### TABLE OF CONTENTS

CONTRIBUTORS ........................................................................................................................... i

ABSTRACT

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

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

1.0 .............................................................................................................. 1 INTRODUCTION

2.0 ........................ 5 COSTS OF A SIGNIFICANT NEW USE RULE (SNUR), BY OPTION

2.1 ........................................................................... 5 Comply with SNUR Limits (Option 1)

2.2 ........................................ 12 Request Modification or Revo cation of a SNUR (Option 2)

2.3 ............................................................................................. 15 Submit SNUN (Option 3)

2.4 ........................................................... 18 Request Equivalency Determination (Option 4)

2.5 ................................................................ 18 Decide Not to Produce Chemical (Option 5)

2.6 .............................................................................. 18 Summary of Costs for Each Option

3.0 ................................................................................ 21 EXPORT NOTIFICATION COSTS

3.1 ...................................................... 21 Estimated Number of An nual Export Notifications

3.2 ............................................................................................................... 22 Exporter Costs

4.0 ............................................................................................................ 25 AGENCY COSTS

4.1 ............................................................................................... 25 SNUN Processing Costs

4.2 ........................................................................ 25 Export Notification Processing Burden

5.0 ............................................................................................ 27 ADDITIONAL ANALYSES

5.1 ................................................................................. 27 Regulatory Flexibility Act (RFA)

5.2 .................................................................. 28 Unfunded Mandates Reform Act (UMRA)

5.3 .................................................................................. 28 Paperwork Reduction Act (PRA)

5.4 .......................................... 28 Executive Order 12866, Regulatory Planning and Review

5.5 ............................................................................. 28 Executive Order 13132, Federalism

5.6 ............................................................ 29 Executive Order 12898, Environmental Justice

5.7 ........................................................... 29 Executive Order 13045, Protection of Children

5.8 ............................................................... 29 Executive Order 13175, Tribal Governments

5.9 ..................................... 29 Executive Order 13211, Energy Supply, Distribution, or Use

APPENDIX A ................................... A-1 LIST OF PMNs AND THEIR CHEMICAL NAMES

APPENDIX B .............................................................. B-1 INFLATORS AND WAGE RATES

B.1 .............................................................................. B-1 Derivation of Loaded Wage Rates

B.2 .................................................................................... B-5 Derivation of Inflation Factors

APPENDIX C

............................................... C-1 COSTS OF HAZARD COMMUNICATION, PROTECTION IN THE WORKPLACE, AND RECORDKEEPING REQUIREMENTS

C.1 ....................................................... C-1 Modifying the Hazard Communication Program

C.2 ........................................................................................ C-6 Protection in the Workplace

C.3 .......................................................................................................... C-19 Recordkeeping

APPENDIX D .................................................................................... D-1 COSTS OF TESTING

D.1 ...................................................................................................... D-1 Testing Guidelines

D.2 .............................................................................................. D-7 Test Costs by Guideline

D.3 ....................................................................................... D-11 Testing Costs by Chemical

APPENDIX E ...................................E-1 COSTS FOR SNUN, AND OTHER SUBMISSIONS

APPENDIX F ...........................................................................................F-1 AGENCY COSTS

APPENDIX G ............................................................................................... G-1 REFERENCES

Economic Analysis of Expedited SNUR s, Docket OPPT-2009-0922 iii May 12, 2010

### LIST OF TABLES

Table 1 Compliance Options and Associated Costs Incurred by a Firm due to SNUR .................. 3

Table 2 Production and Use Restrictions/Requirements ................................................................ 6

Table 3 Annual Costs of Hazar d Communication Requirements ................................................... 7 Table 5 Sample Costs of Workplace Protection ........................................................................... 10 Table 6 Annual Costs of Recordkeeping Requirements (40 CFR §721.125) ............................... 12 Table 7 Sample Costs of Recommended Testing ......................................................................... 13 Table 8 Costs of Requirement to Modify/Revoke SNUR or Submit SNUN ................................ 15 Table 9: Derivation of Total Mailing Cost for 12 Notices ............................................................ 22 Table 10: TSCA 12(b) Export Notification Co st: Annual Burden per Respondent Facility ........ 24 Table 11: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2009$) ............. 26

Table A-1 PMNs and Chemical Names Re ferenced in this Economic Analysis ....................... A-1 Table B-1 Derivation of Loaded Wage Rates ............................................................................. B-4

Table B-2 Derivation of Industrial H ygienist Wage Rate (NAICS 31, 32, 33) .......................... B-5
Table B-3 Derivation of Inflation Factors .................................................................................. B-7 Table C-1 Annual Costs of Labeling for Di stribution in Commerce [40 CFR §721.72(b)(2)] .. C-3 Table C-2 Annual Costs of Labeling fo r Use in Workplace [40 CFR §721.72(b)(1)] ............... C-4

Table C-3 Annual Costs for Material Safety Data Sh eets (MSDSs) [40 CFR §721.72(c)] ........ C-5 Table C-4 Annual Costs for Employee Tr aining, Per Chemical [40 CFR §721.72(d)] .............. C-5

Table C-5 Annual Costs for Dermal Pr otection Selection [40 CFR §721.63(a)(1)] .................. C-6 Table C-6 Annual Costs of Imperm eability Testing [40 CFR §721.63(a)(3)] ........................... C-8 Table C-7 Annual Cost of Gloves [40 CFR §721.63(a)(2)(i)] .................................................... C-9

Table C-8 Annual Cost of Protectiv e Eyewear [40 CFR §721.63(a)(2)(iii)] ............................. C-9

Table C-9 Annual Cost of Protec tive Clothing [40 CFR §721.63(a)(2)] ................................. C-10

Table C-10 Crosswalk Between SNUR Text a nd Respirator Types at 40 CFR §721.63(a)(5) C-12

Table C-11 Annual Per-Chemical Costs for Respiratory Protection [40 CFR §721.63(a)(4)] . C-14 Table C-12 Respirator Prices and Average Costs in 1997, by NIOSH Type ........................... C-16 Table C-13 Recordkeeping Estimates from Kearney 1988a and 1988b ................................... C-21

Table C-14 Annual Per-Chemical Costs of Recordkeeping Requirement [40 CFR 721.125] . C-23

Table D-1 Cost Estimates for Test Guidelines Cited in SNURs ................................................ D-3

Table D-2 Default Parameters fo r Species, Route, and Study Type .......................................... D-8 Table D-3 Persistent Bioaccumulative Toxic (PBT) Tiered Testing Requirements ................. D-10 Table E-1 Burden for SNUN, Request to Mo dify SNUR, or Equivalency Determination .........E-2 Table F-1 Agency Costs for SNUN and Other Submission Review and Processing ..................F-3

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 iv May 12, 2010

### 1.0 INTRODUCTION

This report presents the U.S. Environmen tal Protection Agency (EPA), Office of Chemical Safety and Pollution Prevention (OCSPP’s) analysis of the potential costs incurred as a result of direct final Significant New Use Ru les (SNURs) being promulgated for 25 chemical substances which have gone through premanufacture no tice (PMN) review. 1 

### The SNURs are being published under the rulemaking docket number OPPT-2009-0922. Appendix A lists the generic or specific chemical name and CAS number (if non-confidential) for each PMN.

EPA may promulgate a SNUR for a substance wh en 1) the substance is the subject of a section 5(e) Consent Order (40 CFR §721.160) or 2) the Agency determines that activities other than those described in the PMN may result in significant changes in human exposure or

environmental release levels and/or that conc ern exists about the s ubstance’s health or environmental effects (40 CFR §721.170). In co ntrast to PMN requirements, which apply mainly to manufacturers and importers (T SCA § 5(a)(1)(A), 40 CFR §720.22), the SNUR applies to processors as well as to manufactur ers and importers (TSCA § 5(a)(1)(B), 40 CFR §721.5).

Each substance analyzed here was the subj ect of at least one premanufacture notice submitted under the Toxic Substances Control Act (TSCA), and is now being regulated as a result of PMN review. For the current rulemaking, 24 of the 25 chemicals have commenced commercial manufacture or import and so are listed on the TSCA Inventory; they are no longer "new" chemicals. For chemicals in this type of rulemaking, SNUR requirements are sometimes based on past Consent Orders entered into w ith a PMN or SNUN submitter under TSCA Section 5(e). For the current rulemaki ng, SNUR requirements for 1 of the 25 substances are based on prior Consent Orders.

EPA promulgates a signi ficant new use rule (SNUR) to designate specific activities involving the chemical substance that EPA has determined constitute a "significant new use." No person may manufacture or process a chemical su bstance for a significant new use, unless they submit a significant new use notice (SNUN) to EPA at least 90 days in advance. Examples of typical "significant new uses" that can trigger the requirement to submit a SNUN (if EPA has promulgated a SNUR applying these require ments to a specific chemical) include:

• Domestic manufacture in the United States

• Manufacture of a particular aggregate or annual volume

• Use other than that specified in the PMN

1 This report covers chemicals that went through PMN review and are part of an expedited rulemaking. The relevant Office of Management and Budget Information Collection Request number is ICR No. 0574 (OMB Control Number 2070-0012). EPA also promulgates SNURs through conventional rulemaking that are covered by ICR No. 1188 (OMB Control Number 2070-0038).

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 1 May 12, 2010

### • Releases to water resulting in a surface water concentration exceeding a specified

amount

• Handling the chemical without employing specified personal protective equipment (e.g., gloves, goggles, respirators) or hazard communication (haz-comm) measures (e.g., label, MSDS, worker training)

If EPA does not promulgate a SNUR for a given chemical, then these requirements would not apply (unless they apply to a PMN submitter via a §5(e) Consent Order). If EPA has promulgated a SNUR containing these types of significant new use designations, as long as the person does not engage (nor intend to engage) in any activities defined by the SNUR as a significant new use, then that person may proceed to handle the chemical without submitting a SNUN.

The options available to a firm considering th e manufacture, import, and/or processing of a chemical covered under a SNUR, and the type s of associated costs to the firm, are

summarized in Table 1

. Table 1 summarizes the costs associated with each option, other than the export notification costs that are discussed separately in Section 3.

Table 1 and later tables list vari ous costs. However, often such costs may be incurred

for reasons other than the SNUR. The co sts of avoiding a Significant New Use are attributable to the SNUR only if, in the absence of the SNUR, the firm would have adopted a different approach. For example, a SNUR may define any use other than that described in the PMN as a Significant New Use. If the PMN submitter would have

conformed to the uses described in the PMN even without the SNUR, then any associated costs of adhering to the PMN uses would not be due to the SNUR. Costs to a PMN submitter of practices required by a TSCA Section 5(e) Consent Order would be attributable to the Consent Order, not the S NUR. If a processor would have workers wear gloves even without SNUR requirements, then the gloves costs would not be attributable

to the SNUR. The costs in Table 1 are attributable to the SNUR only if the firm adopts a different approach due to th e Significant New Use Rule.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 2 May 12, 2010

### Table 1 Compliance Options and Associated Costs Incurred by a Firm due to SNUR

Option 1 Costs Quantified Costs per Chemical (2009$) 2

1 Manufacture, import, or process in a way that avoids a Significant New Use, such as limiting water releases, engaging in PMN uses only, importing only, limiting volumes, providing workplace protection, or providing hazard

communications. All SNUR chemicals require ongoing recordkeeping. In addition, many SNUR chemicals may involve costs of complying with water release restrictions and foregoing non-PMN uses; these costs were not quantified for this report. Costs for worker protection and hazard communication apply to relatively few chemicals, but are quantified. Typically, annual costs for recordkeeping are under $1,129.

For the few SNUR chemicals where these apply, annual costs for worker protection may be $35,648 or more and for haz-comm are $1,022

2 Submit a request for

modification or revocation of the SNUR (§721.185). Costs of submitting a request for modification or revocation, including costs of developing supporting data (e.g., testing, if needed). $5,601 submission cost plus any testing costs. 3 EPA receives very few such requests, typically 0-3 per

year. 3 Electronic submission of a Significant New Use Notice (SNUN), indicating to EPA that

the firm would like to manufacture, import, or process the chemical for a Significant

New Use as defined in the

SNUR. Costs of electroni cally submitting a SNUN (including SNUN recordkeeping and user fee 4 ) plus ongoing recordkeeping. Rarely, a firm may choose to conduct toxicity or fate testing to support the SNUN, but such testing is not required by law. $8,101 electronic submission cost (including SNUN recordkeeping and $2,500 fee) 4,5 plus ongoing recordkeeping costs of under $1,129 EPA usually receives well under ten SNUNs in a 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).

4 Petition EPA for an equivalency

determination to consider alternative controls to prevent release or exposure that are equivalent to those identified in the SNUR (§721.30). Costs of submitting an electronic request for equivalency determination. $ 5,601 one-time electronic

submission cost.

5 Do not manufacture, import, or process the subs tance except for R&D (the R&D exemption is covered in 40 CFR §721.47). Cost of profits foregone due to delaying or avoiding commercial activity that would otherwise be pursued. R&D recordkeeping costs if

manufacture for R&D. Costs not quantified.

Notes: Section numbers refer to 40 CFR §721 (in the Code of Federal Regulations). Costs come from Table 3 through Table 8

. 1 Firms may follow multiple Options simultaneously

2 Quantified costs are attributable to the SNUR Significant New Use definition only if a firm would not otherwise follow the specified practices. $35,648 is the annual cost for dermal protection selection; impermeability testing, heavy-duty gloves, and a lower-cost respirator (see Table 5 ). Some firms may have export notification costs (see Section 3 of this report).

3 See Appendix D for costs of individual test s recommended in current and recent SNURs.

4 EPA charges a nominal flat fee of $2,500 for a PMN or SNUN submission.

5 SNUR chemicals not on the TSCA Inventory are “new” ch emicals requiring a PMN, so some firms may need to make a submission before commercial production or import, even in the absence of a SNUR (see Section 2.3 of this report).

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 3 May 12, 2010

### In previous economic analyses of SNUR s, EPA identified those requirements under Subparts A, B, C, and D of 40 CFR §721 that may indirectly impose costs on manufacturers, importers, and processors of PMN substances (e.g., EPA, 1989). So me of these costs, such as providing personal protective equipment unde r §721.63, were estimated in earlier SNUR economic analyses and are presented as part of th is analysis. Resources were not available to quantify other costs, such as for limiting releases to water, avoiding uses not listed in the PMN, or keeping production below a specified level; they are described only qualitatively.

It was not feasible within available resources to aggregate costs, or to estimate how often costs are actually incurred as a result of SNURs, except for costs of SNUN submissions.

The remainder of this report estimates the quantified portion of costs potentially

associated with SNURs such as those included in this rulemaking. Section 2 presents estimates of the costs that could be incurred by manuf acturers, importers, and/or processors under the SNUR options in Table 1 . Section 3 addresses ex port notification costs. Section 4 addresses costs to EPA of administering the SNURs, while S ection 5 presents an analysis of other impacts, as required by various statutes and executive orders. Appendix B provides the wage rates and inflators used in this analysis. Other appendi ces give cost estimation details and references.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 4 May 12, 2010

### 2.0 COSTS OF A SIGNIFICANT NEW USE RULE (SNUR), BY OPTION

A SNUR specifies requirements a firm must meet if it choose s to manufacture, import, or process a PMN chemical without engaging in a Significant New Use that would trigger notification to EPA. A SNUR also requires recordkeeping for anyone manufacturing, importing, or processing the SNUR chemical. A SNUR r ecommends testing, but do es not require testing. EPA rarely receives results of tests performed specifically to support a SNUN

. Table 1 sets forth possible responses to a SNUR. A firm may select more than one course of action. For example, it may produce in a way that avoids a Significant New Use, while simultaneously submitting a Significant New Use Notice for a proposed new us e. These options are described below along

with their costs.

2.1 Comply with SNUR Limits (Option 1)

A firm can avoid engaging in a Significan t New Use and submitting a SNUN by meeting all applicable SNUR requirements. The firm may also pursue this option temporarily by complying with SNUR restrictions while al so pursuing other options such as making a submission to EPA. If it does avoid engaging in a Significant New Use (and if the chemical is on the TSCA Inventory or if the firm has already submitted a PMN), no notice to EPA is required. 2 

### Table 2 below shows the types of requirements a firm must meet to avoid engaging in a Significant New Use.

The Significant New Use designation in a SNUR fo r a specific chemical reflects either the use

scenario described in the PMN for that chemical (what the submitter was already planning to do) or the requirements in the 5(e) Consent Order resulting from the PMN submission. Thus, it is likely that the typical PMN submitter will incur no added costs of complying with the SNUR requirements so as to avoid a Significant New Use. However, if there is any export of these chemicals, there will be export notification costs that result fro m TSCA Section 12 (b) requirements that are automatically triggered for chemicals regulated under TSCA Section 5 (see

Section 3.0 for details).

2 Under the Toxic Substances Control Act § 3(9), if a chemical is not on the TSCA Inventory, it is a “new chemical.” Prior to manufacture or import of a new chemical for genera l commercial use, a notice mu st be filed with EPA under Section 5(a)(1)(A) of TSCA (40 CFR §720.3 and 40 CFR §720.22).

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 5 May 12, 2010

### Table 2 Production and Use Restrictions/Requirements

40 CFR Reference (Code of Federal

Regulations) Restriction/Requirement No. of Chemicals

Affected 1 Sample Costs Per

Chemical

(2009$)

§721.63 Workpl ace protection 7 $11,838 to $35,648 2

§721.72 Hazard communication 2 $1,022
Industrial Commercial, and Cons umer Activities (§721.80) §721.80(a, b, c) Enclosed use only 0 Not quantified §721.80(d, e) Use at site only 0 Not quantified
§721.80(f) Import only (do not manufacture) 1 Not quantified
§721.80(g, h, i) Use only as intermediate 1 Not quantified

§721.80(j, k) Engage only in uses listed in PMN or Consent

Order 3 Not quantified

§721.80(l, m, n, o) Limits non-industrial uses 0 Not quantified
§721.80(p, q, s, t) Limit production volume 2 Not quantified
§721.80(r, u) Volume-triggered testing 0 Not quantified
§721.80(v, w, x, y) Restricts physical form of chemical 2 Not quantified
Disposal, water release, recordkeeping
§721.85 Disposal 1 Not quantified
§721.90 Limit releases to water 17 Not quantified

§721.125 3 Recordkeeping for all manufacturers, importers, and processors 25 Up to $1,129

Notes:

1 Some chemicals have more than one type of restriction.

2 $11,838, is the annual cost for dermal protection selection and heavy duty gloves. $35,648 is the annual cost for dermal protection selection; heavy duty gloves, impermeability testing/evaluation of manufacturer specifications, and a lower-cost respirator (see Table 5 ).

3 This excludes SNUN recordkeeping under §721.40. See the recordkeeping discussion in Appendix C.

Source : Costs are summarized in Table 3

, Table 4 , and Table 6 , and derived in Appendix C.



### The costs of meeting the haz-comm, pr otective equipment, and recordkeeping requirements are quantified for this report. Appe ndix C presents a more detailed derivation of these costs. The export notificati on costs are summarized in Section 3.0 . Complying with requirements to avoid a Significan t New Use also may result in additional costs that affect a significant number of the chemicals, such as costs associated with limiting re leases to water, that were not quantified for this report; thes e costs are also summarized below.

Hazard Communication

Requirements. Each SNUR may require firms that manufacture, import, or process one of the PMN substances to implement a haz-comm program for the applicable chemical, or else submit a SNUN. For purposes of the economic anal ysis, it is assumed that each facility has in place a haz-comm program consistent with th at required by OSHA’s Hazard Communication standard (29 CFR 1910; November 25, 1983). Much of the haz-comm cost methodology used in this analysis came fr om a 1989 EPA report, Economic Analysis of Final Significant New Use

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 6 May 12, 2010

### Rules: General Provisions for New Chemical Followup (EPA, 1989). The cost estimates provided here are for one chemical produced at one site assumed to have 25 exposed workers and roughly a 10,000 kilogram annual shipment vol ume. Higher volumes would increase costs, although not necessarily proportionately. The majo r elements of a haz-comm program that could apply to a SNUR chemical, based on the requirements in §721.72, are:

• Revision of the existing written haz-comm pr ogram to incorporate information about the chemical [§721.72(a)];

• Creation of labels and application of labe ls to containers used for distributing the chemical in commerce [§721.72(b)];

• Creation of labels or signage and posting of hazard data in areas of the facility where the chemical is used or stored [§721.72(b)];

• Creation and distribution of material safety data sheet s (MSDSs) [§721.72(c)]; and

• Employee awareness training on where and how the chemical is used, the hazards associated and availability of hazard info rmation about the chemical, and protective equipment and other measures in place to reduce and minimize exposure to the chemical [§721.72(d)].

Costs. The annual costs of compliance with the haz-comm requirements for PMN substances subject to haz-co mm requirements appear in Table 3 . Further, the costs are for substances with full haz-comm requiremen ts, and may overstate haz-comm costs for substances with partial requirements. A ppendix C gives the detailed cost derivation.

Table 3 Annual Costs of Hazard Communication Requirements

Cost Requirement (2009$) 1,2 Hours

Update written program $190 4
Labeling Distribution in commerce $132 0.5 Use in the workplace $365 1.5
MSDS preparation $130 2.25 Employee training $204 6.75

TOTAL $1,022 15

Notes:

1 Figures are rounded to whole dollars. Substances not subject to all of these requirements may have lower costs. See

Table C-1 through Table C-4 , and section C.1.1 for derivations.

2 Hourly labor costs are derived in Table B-1

.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 7 May 12, 2010

### Protection in the Workplace

Requirements. Under 40 CFR §721.63, manufacturers, importers, or processors must comply with worker protection requirements as specified in the SNUR on the regulated chemical, or else submit a SNUN. The core co mponents of the worker protection requirements include provision of personal protective equipm ent (PPE) such as gloves, goggles, protective clothing, and respirators.

In some cases, EPA specifies the type of PPE required. In other cases, EPA requires adequate dermal protection but doe s not specify particular PPE. Instead, it requires the employer to evaluate worker exposure conditions and haza rds, and select appropriate PPE. Generally the employer is also required to determine that de rmal PPE is impervious to the PMN substance by one or both of the following methods: (1) perfor m impermeability testing on the PPE under the expected conditions of exposure, and/or (2) rely on equipment manufacturers' specifications. Employers not already providing adequate dermal protection would need to do so.

Costs. Annual costs for worker protection items are shown in Table 4 below. The derivation of the sample minimum and maximum annual costs for worker protection is found in

Table 5 . The costs of worker protection were originally estimated in an 1989 EPA report, Economic Analysis of Final Significant New Use Rules: General Provisions for New Chemical Follow-Up (EPA, 1989), as a range of costs, dependi ng on the assumed number of worker-days of exposure. This report uses the high end of the assumptions about worker-day exposure, updated to adjust for inflation. The estimates are for one chemical at one site with 25 exposed workers; actual costs would vary with the number of workers. Appendix C gives the detailed cost

derivation.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 8 May 12, 2010

### Table 4 Annual Costs of Workplace Protection Requirement

Personal Protective Equipment an d Requirement Citation at 40 CFR Unit Cost (2009$) 1 Quantity Required 1 Total Annual

Cost 2 (2009$)

Dermal Protection Selection §721.63(a)(1)

10 hours industrial hygienist (IH) time $47.62 10 $476

Impermeability Testing §721.63(a)(3)
Impermeability Test $1,274 1 $1,274

Evaluation of Manufact urer's Specifications $190 1 $190

Gloves §721.63(a)(2)(i)
Standard (disposable) $0.57 6,250 $3,592
Heavy-duty butyl $45.45 250 $11,362

Protective clothing §721.63(a)(2)
[ii] - Full-body (coverall with hood) $81.80 75 $6,135
[iv] - Coverall (no hood) $48.45 75 $3,634

Eyewear §721.63(a)(2)(iii)
Standard goggles $5.41 75 $406

Heavy-duty goggles $8.09 75 $607

Respirator Types 3

Supplied-air respirator operated in pressure demand or continuous flow mode and equipped with a tight -fitting full facepiece. [simila r to §721.6 3(a)(5)(ii)] $1,075 25 $26,868

Supplied-air respirator operated in pressure demand or continuous flow mode and equipped with a hood or helmet or tight-f itting facepiece (either half- or full-face). [similar to §721.63( a)(5)(iii)] $1,246 25 $31,150

Air-purifying respirator equipped with a tight-fitting full facepiece and High Efficiency Particulate Air (HEPA) f ilters.[similar to §721.63(a)(5)(iv)] $894 25 $22,345

Air-purifying, tight-fitting respirator (e ither half- or full-face) equipped with N100 (if aerosols absent), R100, or P100 filters. [similar to §721.63(a)(5)(iv)] $894 25 $22,345

Powered air-purifying, tight-fitting full-face respirator equipped with N100 (if oil aerosols absent), R100, or P100 filters. [similar to §721.63(a)(5)(v)] $3,211 25 $80,283

Powered air-purifying respirator eq uipped with a tight-fitting facepiece (either half- or full-face) and HEPA filters. [similar to §721.63(a)(5)(v)] $3,211 25 $80,283

Powered air-purifying respirator equipped with a loose-fitting hood or helmet and High Efficiency Particulate Air (HEPA) filters. [similar to §721.63(a)(5)(vi)] $2,499 25 $62,487

Notes:

1 Quantities assume: 1) 25 workers exposed 250 days per year; 2) standard gloves replaced daily and heavy-duty gloves replaced every 25 days; 3) respirator units replaced annually and cartridge sets repl aced every five days (50 cartridges sets per year); 4) goggles and protective clothing replaced three times yearly.

2 Total annual costs were calculated using unrounded unit cost estimates, and may not equal the product of the rounded

estimates shown in this table.

3 This table lists respirator choices that typically would sati sfy SNUR requirements for a particular chemical, for current and recent SNURs. Future SNURs may list different choices. The citations in brackets refer to respirator types listed at 40 CFR. While the SNURs no longer reference the §721.63(a)( 5) categories, costs in this analysis are based on costs estimated in 1997 for the §721.63(a)(5) categories. See Table C-10 for the crosswalk between respirator types in SNURs and in this table. The respirator “unit cost” is per worker. Total respirator costs include costs of the respirator plus the costs of any add-on items such as hoods, helmets, cartridges, filters, and caps, if these items are required for a particular respirator.

Source: Appendix C, Tables Table C-5 through Table C-11

.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 9 May 12, 2010Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 10 May 12, 2010 

### The costs of purchasing protec tive equipment are derived in Appendix C, and have been annualized based on the assumptions listed above regarding their use and lifetime in the workplace. Costs for evaluating hazards when PPE is not specified in the SNUR are based on estimates of the reasonable time required for a sa fety professional to perform such evaluations. Costs for conducting impermeability testing are ba sed on consultation with PPE vendors, as described in Appendix C. Table 4 summarizes the annual costs asso ciated with protection in the workplace, including the PPE itself, as well as selecting required dermal protection, and performing impermeability testing and/or evaluating manufacturer's information.

Table 5 shows a sample of the minimum a nd maximum annual cost of workplace protection, assuming 25 workers who are exposed for 250 hours per year. The minimum cost includes the cost of heavy-duty butyl gloves, and 10 hours of an industrial hygienist’s time for dermal protection selection. The maximum cost is includes the cost of gloves, dermal protection, impermeability testing, and the annual co st of the least expensive respirator and

filters for 25 workers.

Table 5 Sample Costs of Workplace Protection

Cost Element Annual Cost (2009$)

Example #1: Gloves and Dermal Protection Selection
Heavy-duty butyl Gloves $11,362

Dermal Protection Selection $476 Total per site with 25 workers $11,838 Example #2: Gloves , Testing, and Respirator Heavy-duty butyl Gloves $11,362

Dermal Protection Selection $476 Impermeability Test $1,274

Evaluation of Manufactur er's Specifications $190 Least Cost Respirator $22,345 Total per site with 25 workers $35,648

Source : Table 4



### In cases where the SNUR specifies the type of protective gear, the estimates assume workers would not otherwise wear adequate protec tive equipment. To the extent that workers would otherwise be adequately protected (as a result of the company's own safety program related to other chemical hazards, or to comply with OSHA's PPE standards), these costs may be

an overestimate of the actual costs.

In some cases, the SNUR requires dermal prot ection but does not sp ecify any particular gear, allowing regulated companies to make that determination. Table 4 shows costs of assessing needs and demonstrating impermeability. These cost estimates would reflect a situation where the dermal protection is already in place but the manufacturer must demonstrate that it is adequate. If companies also have to purchase additional protective gear, incremental

costs attributable to the SNUR would include the added items. For example, if a firm already providing gloves and goggles determined that it would have to add protective clothing to avoidEconomic Analysis of Expedited SNURs, Docket OPPT-2009-0922 11 May 12, 2010 

### engaging in a Significant New Use, this would in crease costs even if particular protective clothing is not specified in the SNUR.

Recordkeeping

Requirements. Under 40 CFR §721.40, recordkeepi ng is required for SNUN submitters. This recordkeeping cost was included in the SNUN submission cost and is not separately

estimated here. 3



### In addition, the SNURs specify recordkeeping requirements for manufacturers, importers, and processors, by identifying paragraphs select ed from 40 CFR §721.125(a) through (k). These recordkeeping requirements apply even if the fi rm does not engage in a reportable New Use or make a submission to EPA, so long as it manufactur es, imports, or proce sses the chemical. The recordkeeping requirements vary by chemical. Fo r example, only chemicals that must establish a Hazard Communications program to avoid a Si gnificant New Use would be required to keep records documenting their haz-comm program. (For firms producing under the R&D exemption, R&D recordkeeping would be needed. R&D recor dkeeping costs were not estimated for this report.)

SNUR recordkeeping requirements essentia lly involve copying and filing relevant records, including those related to manufacturin g, importing, or processing volumes; shipment amounts and customer information; clothing impermeability determinations; the hazard communication program incl uding labels and MSDS copies; co mpliance with disposal and water discharge limitations; and/or compliance with rest rictions on volumes, nature of manufacture or use, or on the chemical’s physical form (powder, liquid etc.).

Costs. Annual costs for compliance with 40 CFR §721.125 recordkeeping requirements are low, but do potentially apply to all SNUR ch emicals, and the recordkeeping could continue for years. Costs are presented in Table 6 and derived in Appendix C. They are estimated for one chemical at one site, and include technical and clerical labor time, photocopying charges, and costs for records storage.

Table 6 summarizes recordkeeping costs by requirement at 40 CFR §721.125. The totals

in Table 6 provide the cost if all recordkeeping requirements in paragraphs §721.125 (a) through (k) were required; this would seldom, if ever, be the case for a single chemical.

3 For example, OPPT’s Informat ion Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules for Existing Chemicals (Renewal), October 11, 2005, estimated SNUN recordkeeping costs at 5.67 hours (EPA, 2005, page 12).Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 12 May 12, 2010 

### Table 6 Annual Costs of Recordkeeping Requirements (40 CFR §721.125)

40CFR §721.1252 Cost Element Cost (2009$) 1 Hours

(a)(b)(c) Volumes & sales/transfer data $319 7.11

(d)(e) Protective clothing [§721.63] and impermeability [§721.63(a)(3)] $13.17 0.29

(f) Haz com program [§721.72] $165 3.67 (g) Label copies [§721.72(b)] $3.29 0.07
(h) MSDS copies [§721.72(c)] $3.29 0.07
(i) Use limitations compliance [§721.80] $165 3.67 (j) Disposal compliance [§721.80] $395 8.80
(k) Water discharge compliance [§721.90] $65.85 1.47

TOTAL $1,129 25.15

Notes:

1 Recordkeeping applies to all SNUR chemicals. This table does not cover recordkeeping for SNUN submissions. See Appendix C Table C-14 for derivations.



### PMN uses, production volume limits, import- only, releases to water and disposal

Several types of costs that may be incurred by complying with the significant new use designations are not quantified in this report.

Release to water, disposal, and other use rest rictions may result in costs not quantified for this report. For example:

• A producer could incur costs of determining whether discharges to water would constitute a Significant New Use and of li miting releases in order to avoid the Significant New Use.

• Keeping production volume below specified li mits to avoid a Signi ficant New Use could result in a decrease in prof its; a potential “hidden” cost. A firm producing for sale may

have to restrict its sales of the chemical. If the chemical is for internal use, it may have

to substitute to a less cost-effective chemical.

• Similarly, avoiding uses not liste d in the original PMN could re sult in “hidden” costs of foregone profits if the firm cannot market the chemical for certain applications. If the

firm wants to use the chemical for internal use, it may have to substitute to other chemicals or technologies that cost more or have lesser performance resulting in higher production costs.

• Importing could be costlier than ma nufacturing a PMN substance in the

United States.

2.2 Request Modification or Revoc ation of a SNUR (Option 2)

Under 40 CFR §721.185, EPA may modify or revoke a SNUR upon review of a submittal from a manufacturer, im porter, or processor. Conseq uently, the second option for aEconomic Analysis of Expedited SNURs, Docket OPPT-2009-0922 13 May 12, 2010 

### firm is to request modification or revocati on of the SNUR. According to New Chemical Program records, EPA receives few modify/revok e requests (typically 0-3 per year) due to

SNURs.

This option may have some or all of the following associated costs:

• One-time costs of testing to develop health a nd environmental effects data for a chemical subject to the SNUR;

• One-time costs of submitting a request for modification or revocation;

• Ongoing costs of complying with SNUR restri ctions (Option 1 in this report) or of avoiding production while the m odification request is being processed (Option 5). The firm may also incur costs of complying w ith any SNUR restrictions that are not ultimately revoked or may incur hidden costs of avoiding production altogether.

These costs are discussed below.

Costs of Developing and Submitting Testing Data

40 CFR §721.185(b)(1) requires that a modi fication request include “information sufficient to support the request.” For each PMN substance, the SNUR identifies health, ecological, and/or fate/transport/ transformation testing that woul d help characterize the risks associated with the substance. However, there is no requirement for a requester to perform the recommended tests or even to perform testing at all. It is possi ble that some of the recommended tests, or other tests, would be performed by the submitter to support a request for

modification and revocation of a SNUR. For in formational purposes, costs for various tests recommended in SNURs over the years are listed in Appendix D. If no additional testing is performed to support a modification request, costs may be similar to costs of a SNUN – discussed

later in this section – minus the user fee.

Table 7 below provides an example of potential costs if a firm were to perform a standard set of basic ecotoxicity tests to support a request to modify or revoke a SNUR.

Table 7 Sample Costs of Recommended Testing

Estimated Cost Test Guideline Test description (2009$)

Ecotoxicity Base Set

OPPTS 850.5400 Algal Toxicity, Tiers I and II $17,414

OPPTS 850.1010 Daphnid Acute Toxicity $14,981

OPPTS 850.1075 Fish Acute Toxicity $20,645
Sample TOTAL Testing Cost: $53,040

Notes:

1 Costs are from Table D-1Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 14 May 12, 2010 

### Costs for Submitting a Request for Modi fication or Revocation of a SNUR

The costs associated with submitting a request for modification and revocation of a SNUR (or of submitting a SNUN) are estimated to be similar to the costs for preparing a PMN submission, except that there is no user fee for the modify/revoke request. In its Regulatory Impact Analysis for the amendments to the PMN regulations, EPA relied on industry estimates of the effort needed to collect and compile all data required for a paper PMN submission, prepare the form, submit the form and data to EPA, and maintain a file of the su bmission (EPA, 1994, pages III- 11 through III-13, and Appendix B). These estimates, based on five responses to a 1991 survey conducted by the Chemical Manuf acturers Association, indicate that the average effort required to prep are and submit a paper PMN form is between 95 and 114 hours.

On January 6, 2010, EPA published the final Electronic Reporting (ePMN) Rule that requires the electronic submission of all TSCA Section 5 notices.( 75 FR 773) Electronic submission of



### PMN and SNUN forms is expected to remove all clerical burden associated with preparing a 

### PMN or

SNUN , between 12 and 13 hours. This will reduce the burden associated with SNUN submission and preparation from between 95 and 114 hours to 

### between 83 and 100 hours (EPA, 2009. p. 15). 4 

### The ePMN Rule also requires electronic submission of re quests for equivalency determination. The ePMN Rule does not require electronic submission of request s to modify or revoke a SNUR for a conventional chemical (75 FR 773). However, for simplicity, th is analysis uses the reduced cost of an electronic PMN for both a request for an equivalency determ ination and for a request for modification or

revocation of a SNUR.



### This analysis uses the average of the estimat ed hours for each step, resulting in the cost

shown in Table 8 . The costs associated with these labor time estimates are derived in Appendix E.

Other Costs

EPA’s review of the submitter's request may cause dela ys in the start of manufacturing or processing activities. Such de lays could cause the company to forego opportunities to earn profits for the duration of the review period. Alternatively, the submitte r may elect to produce

under the constraints of the SNUR during the review period, so as to avoid a Significant New Use. EPA may not revoke all SNUR provisions as a result of the request. If the company is allowed to continue production a nd chooses to do so, it would bear costs of complying with any

SNUR restrictions that are not revoked. Costs of complying with SNUR restrictions pending

EPA modification or revocation were discussed under Option 1.

4 Prior to this report, Economic Analysis of Expedited Significant New Use Rules for 2 5 Chemical Substances: EPA

Docket OPPT-2009-092 2, all burdens were based upon paper submission estimates from the 1994 RIA (EPA, 1994). The ePMN final rule was promulgated January 6, 2010 ( 

### 75 FR 773)

.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 15 May 12, 2010 

### Table 8 Costs of Requirement to Modify/Revoke SNUR or Submit SNUN

Request to Modify/Revoke SNUR (Option 2) (2009$) Submit a SNUN (Option 3)

(2009$) Request Equivalency

Determination

(Option 4)

(2009$)

Costs of preparing submission (105 labor hours) $5,601 $5,601 $5,601

User fees NONE $2,500 NONE

TOTAL $5,601 $8,101 $5,601

Test Costs Sometimes Rarely

Notes:
Figures are rounded to whole dollars (see Appendix E, Table E-1 , for derivation). Costs include recordkeeping in support of the submission.



### Total Costs for Option 2

The total costs associated with requesti ng a modification or revocation of a SNUR include the costs of generating ne w supporting data plus the admini strative cost of preparing the

submission.

2.3 Submit SNUN (Option 3)

Under 40 CFR §721.5, manufacturers, importers , or processors who would like to undertake a Significant New Use of a substance listed in a SNUR are required to submit a Significant New Use Notice (SNUN) at least 90 days before the firm plans to commence the manufacture, import, or processing of the substa nce. For example, they could submit a SNUN if they wish to produce above the volume limit listed in the SNUR for a given chemical, since any production beyond that volume would be defined as a Significant New Use.

The SNUN provides EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs. Th e notice form used to submit a

SNUN is the same as that fo r a PMN, and the costs of subm itting a SNUN are estimated based

on the costs incurred to submit a PMN.

This option could have the following costs:

• One-time costs of the SNUN and $2,500 user fee. (However, in some cases, a notification may be needed for reasons ot her than the SNUR; see the “SNUR ‘New’ Chemicals” discussion below.)

• Ongoing costs of complying with SNUR restrictions to avoid engaging in a Significant New Use (Option 1 in this re port) or of avoidi ng production while the SNUN is being processed (Option 5); cost s of recordkeeping, and of complying with any restrictions resul ting from the SNUN review.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 16 May 12, 2010 

### • Rarely, the SNUN submitter may elect to perform some of the testing recommended in the SNUR as a way to characterize effects of a chemical. These tests are not mandatory, and firms do not usually conduct testing to support a SNUN, so any such costs are likely to be zero or low.

This observation is based on an analysis of the 18 SNUNs submitted over a three-year period, from 2005 through 2007. A list of human health tests submitted to EPA with PMNs

and SNUNs was also available from a confiden tial database maintained by EPA’s Office of

Pollution Prevention and Toxics Risk Assessm ent Division. Only one SNUN described toxicity or environmental fate testing that seem ed reasonably likely to have been performed to support a SNUN. In that case, two relatively lo w-cost tests (fish acute toxicity and daphnid acute toxicity) may have been conducted to s upport a SNUN, although it is also possible that the testing was done for some other reason not apparent in the SNUN itself.

A substantial portion of the SNUNs did provide or reference test results. However, in almost all cases, the testing appeared to have been conducted for reason s other than a SNUR. For example, the SNUN might include laboratory reports that had already been submitted for a

PMN for the same chemical.

SNUR “New” Chemicals

If a SNUR chemical is not on the TSCA Inventory and a potential manufacturer or importer has not yet filed a PMN, submission cost s may be incurred but are not attributable to

the SNUR.

All SNUR chemicals in this rulemaking were the subject of at least one PMN. For PMN

chemicals to be added to the TSCA Inve ntory, manufacturing (or import) must have commenced, with notification to EPA through a Notice of Commencement, or NOC. Thus, SNUR chemicals not yet in commercial ma nufacture (or import) are not on the TSCA Inventory. They legally remain “new” chemicals subject to PMN requirements.

For “new” chemicals, firms wh o have not yet submitted a PM N must notify EPA 90 days before manufacturing/importing the chemical for commercial purposes. This submission is still designated a PMN but may contain information de monstrating the submitter intends to engage in a significant new use. Either way, the firm uses the same submission form and provides the data listed at 40 CFR §720.45. Consequently, for this special situation, th e submission cost is incurred due to PMN requirements, not due to the SNUR. (See EPA's 1997 Chemistry Assistance Manual for Premanufac ture Notification Submitters for an overview of New Chemicals requirements [EPA, 1997]).

Advance Compliance Exemption

Another option available to firms before the S NUR is promulgated is to seek an advance compliance exemption under 40 CFR §721.45(h). The submission cost for this option is the same as that for a SNUN, but by negotiating an advance complian ce agreement with EPA a firmEconomic Analysis of Expedited SNURs, Docket OPPT-2009-0922 17 May 12, 2010 

### might diminish any loss of profits due to delay. This option is not available after the SNUR is promulgated.

Costs for Submitting a SNUN

As with Option 2 above (Request Modificati on or Revocation of a SNUR), the costs for submitting a SNUN are estimated to be equivalent to the costs of completing a PMN submission.

If the SNUN is submitted at the same time as a request to modify a SNUR (Option 2), the added cost would be less than shown here due to overlap in information in the two submissions. Table 8 shows the costs of preparing a SNUN; details are in Appendix E.

Potential for Subsequent Regulatory Actions

The Agency recognizes that if submission of a SNUN does result from a SNUR, the Agency may take additional regulatory actions un der TSCA. These additional regulatory actions might be necessary to further evaluate an inte nded new use and associated activities, or to prohibit or limit that activity befo re it occurs to prevent unreas onable risk of injury to human

health or the environment. It is not known wh at specific subsequent regulatory actions, if any, the Agency may determine are ne cessary after reviewi ng a SNUN. Any such actions are highly dependent on the circumstances surrounding the individual SNUN (e.g., available information and scientific understanding about the chemical and its risks at the time the SNUN is being reviewed).

Should the Agency’s review of the SNUN result in further regulatory actions, the Agency will initiate and follow the appropriate procedur es for taking those actions. Included in those procedures would be an assessment of th e costs and benefits of those actions.

Subsequent regulatory action may be a Consent Order under TSCA Section 5(e).

Assessments of costs and benefits for a Cons ent Order would be limited, similar to those supporting PMN reviews leading to Consent Orders, in contrast to the in-depth benefit-cost analyses prepared under some other TSCA Sections.

The description above was adapted from text in Economic Analysis of the Significant New Use Rule for Chloranil , January 8, 2008, Section 2.4; and Economic Analysis of the Final Significant New Use Rule for 183 Perfluoroalkyl Sulfonates , August 20, 2007, Section 3.4. Both reports are from the U.S. EPA Office of Po llution Prevention and Toxics, Economic and Policy Analysis Branch. The nature of the follow-up regulatory action and benefit/cost analysis may

differ between SNUNs for newer chemicals submitte d as a result of a direct final rulemaking such as this one, and SNUNs for older chemical s such as chloranil and most perfluoroalkyl

sulfonates.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 18 May 12, 2010 

### 2.4 Request Equivalency Dete rmination (Option 4)

Under 40 CFR §721.30, EPA may review appl ications from facilities who propose alternative methods of controlling or preventing exposures or releases to those specified in the SNUR. In these cases, EPA evaluates the alternativ es using an abbreviated review process. As

shown in Table 8 , the costs of submitting an equivalency determination request are expected to be the same as those for submitting a SNUN except that no user fee is required.

For this option the EPA review period is 45 days compared to 90 days for a SNUN, therefore any potential loss of pr ofits due to delays may be le ss than for a SNUN under Option 3.

In addition to the costs of submitting the equivalency determination request, each submitter will also incur costs to develop data to support the request. However, total costs of the equivalency option should be no mo re than the costs of complying with controls in the SNUR to avoid a significant new use -- for example, c ontrols related to workplace protection or environmental release. Otherwise, presumably there would be no incentive for the submitter to choose this alternative. Finally, to produce the chemical following EPA review, the submitter

would incur costs from recordk eeping and from any re strictions not waived (see Option 1).

2.5 Decide Not to Produce Chemical (Option 5)

Some firms may find that the costs of meeting the SNUR requirements and/or restrictions (Option 1) or preparing a SNUN or other s ubmission (Options 2, 3, or 4) are financially

unattractive. In these cases, the firm could choose not to manufacture, import, or process the

PMN substance.

While this option avoids the costs of meeting the specifications in the SNUR or submitting a request for some alternative, it entails the “hidden” cost of the profit that will be foregone as a result of not engaging in the comme rcial activity originally planned. For example, if the firm does not produce the SNUR substan ce, then it will forego the profit it would have achieved by producing it. That fo regone profit is a potential “hidden” cost of Option 5. Similarly, if the firm would have used the S NUR substance in the production of another product and must substitute to a more costly substance, it will incur those additional costs of production. If the firm elects to produce for R&D purposes only, it may have costs associated with R&D recordkeeping attributable to the SNUR.

Firms that exercise option 5 may still incur export notification cost s, if they export any existing stockpiles of the product. Th is cost is quantified in Section 3.0 below.

2.6 Summary of Costs for Each Option

Table 1 , above, gave an overview of compliance options. Table 3 through Table 6 summarized the quantified portion of potential costs of either following restrictions to avoid engaging in a Significant New Use, or of making a submission to EPA. Table 7 presented sample testing costs. Costs are for one chemical at one site, and – where volume is relevant – areEconomic Analysis of Expedited SNURs, Docket OPPT-2009-0922 19 May 12, 2010 

### based on standard assumptions that include 25 e xposed workers per site and, for haz-comm costs, annual shipments of about 10,000 kilograms per site. Costs are not otherwise adjusted for the nature of the chemical or process, volume, loca tion, or other firm-specific or chemical-specific

factors.

As mentioned above, costs are estimated for one chemical at one site, not for aggregate production. Resources were not ava ilable to estimate aggregate co sts. Among other things, it is not known how many firms are affected by the S NURs. EPA receives a handful of Significant New Use Notices per year due to SNURs. However, if a SNUR chemical is on the TSCA Inventory, a firm may use the chemical in a wa y that avoids a Signifi cant New Use (Option 1),

and never make a submission. It is not known how many firms are affected but do not make a submission. Also, it is not known whether firms avoid the chemical altogether specifically due

to the SNUR. 

### However, at least for the years immedi ately following SNUR promulgation, these numbers are likely to be small. This is because the chemicals in this type of SNUR rulemaking are still relatively new – as Append ix A indicates, most were su bmitted to EPA as PMNs in the past four Federal fiscal years – and, in additi on, often have confidential chemical identities.

• For firms manufacturing, importing, or processi ng within SNUR restrictions to avoid a Significant New Use (Option 1), quantifiable costs can range from about one thousand dollars (if the only added cost is for recor dkeeping) to over $35,000 per chemical if the firm must add worker protection measures such as gloves, protective clothing, and respirators that it would not otherwise use . Most chemicals are also subject to costs that could be significant but are not quantified in this report, such as restrictio ns on releases to water or on other aspects of use.

• For submissions to EPA (Options 2, 3, and 4) , the basic one-time submission cost is estimated at $5,601, including recordkeeping fo r the submission. For the SNUN (Option 3), EPA also collects a $2,500 fee.

• One objective of the rule is that EPA will be able to regulate prospective manufacturers, importers, or processors of a listed chemical substance before the described significant

new use of that chemical substance occurs , provided that regulation is warranted pursuant to TSCA sections 5( e), 5(f), 6 or 7. Consequent ly, after submitting a SNUN, the firm may need to comply with restrictions as a result of the SNUN review process, possibly leading to further cost s similar to those in Option 1.

• Rarely firms may choose to perform toxicity and/or environmental fate testing to support a SNUN (Option 3). Such testing is not mandatory. Costs for such testing are expected to be zero for most SNUNs and expected to be low for the few SNUNs for which a submitter might voluntarily perform such testing.

• Companies that might have manufactured, im ported, or processed a chemical in the absence of the SNUR may incur “hidden” costs, such as loss of profits from delayed or foregone sales, if they avoid the chemical a ltogether (Option 5). These costs were not quantified.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 20 May 12, 2010 

### • Companies may incur costs from more than one Option, for example if they temporarily produce in conformance with SNUR restri ctions while submitting a SNUN and waiting the required 90 days plus any extensions.

For some firms, costs may be attributable to EPA’s New Chemicals review process, but not to the SNUR itself. For example, a fi rm may already be bound by a TSCA Section 5(e) Consent Order following review of its PMN, so that the SNUR based on the 5(e) order imposes no added costs for that firm. As another example, in rulemakings where a SNUR chemical is not on the TSCA Inventory, firms that have not ye t submitted a PMN must s ubmit one to EPA before commercial production/import, w ith or without the SNUR (s ee Section 2.3, SNUR “New” Chemicals).

If the SNUR reflects the PMN use scenari o, and the PMN submitter would stick to the PMN uses even in the absence of a SNUR, th en there would be no added costs for the PMN submitter attributable to the SNUR. Also, firm s may also incur worker protection, haz-comm

and other costs for reasons other than the S NUR, so that SNUR requirements may impose no

added costs. 5



### .

5 Earlier SNUR economic analyses calcu lated possible haz-comm, worker protection, testing, and other costs for each PMN chemical (EPA, 2007b, Tables 9, 10, D-4). The chemi cal-specific tables were dropped from a later SNUR economic analysis (EPA, 2007c). They reflected SNUR requirements and “recommended” testing, but were not otherwise tailored to the particular situation, and so were unreliable predictors of actual SNUR costs.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 21 May 12, 2010 

### 3.0 EXPORT NOTIFICATION COSTS

Under Section 12(b) of TSCA, exporters must notify EPA if they export or intend to export a chemical subject to various TS CA sections (40 CFR §707.60 through 75). For TSCA 5(a)(2) (the section under which EPA pr omulgates significant new use rules) and certain other TSCA sections, this is a one-time notification requirement 6 

### per destination country for each exporter of a chem ical substance. After receiving a notification from a firm, EPA notifies the importing country and the United States State Department (40 CFR §707.70). To calculate the burden associated with making export notifications, EPA first estimated the average annual numbe r of export notifications made by an exporter, in Section

3.1 . EPA then derived the annual and per notific ation burden associated with preparing and submitting an export notification, in Section 3.2

. 7



### EPA estimated the average burden associated with making a single notification, but did not estimate either the total number of expor ters of a SNUR chemical or the number of notifications per SNUR ch emical. This is because the SNUR s apply to a variety of different chemicals with a variety of unrelated us es, manufactures, and processors, making it impractical within the resources available for this report to assess the potential number of exporters and importing countries per chemical.

Most underlying data in th is section come from t he 2009 TSCA Section 12(b) ICR, ICR No.: 0795.13 [Information Collection Request for] Notification of Chemical Exports - TSCA Section 12(b) Supporting Statement for Reque st for OMB Review under the Paperwork

Reduction Act (EPA, 2009b), with updating for inflation.

3.1 Estimated Number of Annual Expo rt Notifications per Exporter

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

. 8 

### This includes notific ations resulting from

SNURs and notifications resulting from other TSCA activities. A notification is typically no more than one page per chemical/country combination, and one notification mailing often includes multiple chemicals and/or destination countries. 9

6 On November 14, 2006, EPA revised the export notifica tion 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).

7 Beginning with this report ( Economic Analysis of Expedited Significant New Use Rules for 2 5 Chemical

Substances: EPA Docket OPPT-2009-0922 ), the cost per notification is presente d as well as the cost for the average submitter making export notifications.

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

9 Based on review by an EPA economist of notifications received under TSCA Sections 4, 5 and 6 over approximately three weeks in early 2010.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 22 May 12, 2010 

### The percent of notifications due to PMN SNURs is unknown, and it is also unknown how many notifications may result from this rulema king, as not all manufact urers may choose to export a chemical, or they may make seve ral notifications for a single chemical.

3.2 Exporter Costs

The 2009 TSCA Section 12(b) ICR (EPA, 2009b, page 11, Table 3), estimated the annual export notification cost for an exporter under the one-time expor t notification requirement. These costs include the cost to the exporter of comp iling a list of their produc ts that are subject to TSCA Section 12(b) requirements, writing or re vising an export notifica tion letter to EPA, checking the outgoing shipments, and sending the notification letters with the associated shipping costs

The 

### per-notification cost was calculated based on the average burden per firm making notifications . Exporters making more notifications per year may benefit from economies of scale and have lower costs per notific ation; those making fewer notific ations may have higher costs per notification.

Estimated Submission (Mailing) Costs

Regulated companies will incur mailing costs fo r export notifications delivered to EPA. Notifications are assumed shipped via the U.S. Po stal Service (USPS) as first-class registered mail with a return receipt (USPS, 2009). The estimated per-shipment and annual mailing costs incurred by individual submitters are detailed in Table 9

.

Table 9: 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

× 12

Total Mailing Cost for 12 Notices $160.08

Source: Mailing rates are from the US Postal Service web site as of April 2010 (http://www.usps.com/prices/). Th e mailing method comes from the Economic Analysis of the Proposed Change to TSCA Section 12(b) Export Notification Requirements, November 2005 (EPA, 2005a), as clarified in a later SNUR economic analysis (EPA, 2007c, Table 8).



### Compile and Maintain the List of Products

Since TSCA §12(b) information collection activity has been in place for twenty years, most respondents will have alr eady developed a list of their products subject to TSCA §12(b) export notification. Respondents need only check for new regulations promulgated and any new products exported by the company. Updating the list is estimated to take an average of one hourEconomic Analysis of Expedited SNURs, Docket OPPT-2009-0922 23 May 12, 2010 

### of technical time, which may also include some proportion of legal time (EPA, 2009b). The total burden can vary from two hours per year up to two hours per month, depending on the number of products exported by the company and the number of their products subject to TSCA §12(b) (EPA, 2009b).

The number of submitters per year who report under TSCA §12(b) has varied over time, rising from around 160 in 1991 to over 460 in 2000, and declining since. In the most recent TSCA §12(b) ICR, EPA estimated there would be approximately 300 submitters per year in near-future years (EPA, 2009b). Of these 300 submitters, EPA estimated that 200 companies

were near the lower burden estimate of 2 hours per year, and 100 companies were near the upper estimate of 24 hours per year. Compiling the list for all respondents was therefore estimated to take 2,800 hours (2 hours x 200 firms plus 24 hour s x 100 firms), or an average of about 9.3 hours of technical time per firm per year for 12 notifications per year (EPA, 2009b).

Write or Revise Export Notification

Companies that export chemicals subject to TSCA §12(b) reporting must prepare an export notification to send to EPA when export sh ipments are made. Time for initial preparation of the export notice may vary depending on whethe r the company has prior experience with this requirement. This step is estimated to take an average of one hour of t echnical time (which may also include some proportion of le gal time) per firm per year for 12 notifications per year (EPA, 2009b).

Check Orders and Send Notifications

Companies that export chemicals subject to TSCA §12(b) reporting must check outgoing shipments against the list of their products described above. A form letter notifying EPA and providing the required data must be printed and mailed within the required time period. This process is estimated to take an average one half hour of clerical time per export notification or 6 hours for 12 notifications (EPA, 2009b).

The burdens and associated costs for each notification activity are provided in Table 10 below.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 24 May 12, 2010 

### Table 10: TSCA 12(b) Export Notifi cation Cost per Notification

Technical Clerical Total

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

Compile list $59.49 9.3 $553

-- -- -- $553 9.3

Write letter $59.49 1 $59.49

-- -- -- $59.49 1

Check order and send

notice -- -- -- $28.31 6 $170 $170 6

Mailing cost 1

-- -- -- $160

- Total per facility 2` 10.3 $613 6 $170 $943 16.3 Total per Notification 0.86 $51.06 0.50 $14.15 $78.56 1.36

Notes:

1 Mailing costs reflect April 2010 USPS rates and can be found in Table 9.

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

Source: Appendix B of this report derives technical and clerical hourly labor costs. Other costs are from ICR No.: 0795.13 [Information Collection Request for] Notification of Chemical Exports - TSCA Section 12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction Act (EPA, 2009b, p.10), and are updated to

2009 dollars.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 25 May 12, 2010 

### 4.0 AGENCY COSTS

This SNUR is expected to generate Agency costs for both SNUN review and processing, and export notification processing. Because it is unknown how many SNUNs and export

notifications will be submitted as a result of this rulemaking, all Agency costs are estimated at the per-case level and are not aggregated to estimate the total Agency burden. Section 4.1 describes the burden to the Agency of review ing and processing a single SNUN submission.

Section 4.2 derives the Agency burden of processi ng and reviewing export notifications.

4.1 SNUN Processing Costs

EPA’s costs to review and pr ocess industry submissions (S NUNs, requests to modify or revoke the SNUR, and requests for equivalency dete rminations) are assumed to be the same as

EPA costs to review PMNs. These costs are es timated at $4,934 per case, as shown in Appendix F. The required Agency steps, full-time equivalent (FTE) staff needs, and extramural costs such as for contractor support are de rived in Appendix F from EPA's an alysis of the Agency costs of processing PMN submissions (EPA, 1994 and EPA, 2009a ), with adjustments to reflect inflation, a 16.5 percent cost savings resulting from the ePMN rule (EPA, 2009a, p. 28), and changes in Agency staff grade levels 10 

### . The original EPA analysis used a range of salaries, but this analysis uses one typical salary.

The PMN costs reflect estimates made in 1994, in Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications (EPA, 1994). The average cost to review a SNUN may be different from that estimated for PMNs, both because of differences between PMNs and SNUNs, and b ecause the PMN review hours may have changed

since 1994. Resources were not av ailable to re-estimate costs fo r SNUNs. See Appendix F for

details.

4.2 Export Notification Processing Burden

Under TSCA Section 12(b), exporters must notify EPA if they intend to export chemicals subject to SNURs, as described in Section 3 above. Th e Agency burden and cost due to TSCA §12(b) export

notification result from three tasks. 

### In the first task, EPA receives export notifications from companies that intend to export one of the chemicals subject to TSCA §12(b) (EPA, 2009b). In the second task, EPA staff prepares separate notif ication letters that are subsequently reviewed and delivered to importing countries, their emba ssies, or representatives, and to the importing country’s US embassies (EPA, 2009b). (See Table 9 for the cost of mailing one notification). The third task is comprised of EPA staff res ponses to public inquiries and other TSCA 12(b) activities. The work of responding to non-routine requests for information and clarification from

10 Prior to this report, Economic Analysis of Expedited Significant New Use Rules for 2 5 Chemical Substances: EPA

Docket OPPT-2009-092 2, all burdens were based upon 1994 paper submission estimates. This is the first report to consider the burden reductions resulting from electronic su bmission of SNUN forms, as required in the Final ePMN rule, published January 6, 2010 ( 

### 75 FR 773 ).Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 26 May 12, 2010 

### industry and importing countries, an d of handling other tasks asso ciated with the TSCA §12(b) program, was estimated to require roughly 400 hour s per year (EPA, 2009b). Since the current rulemaking covers only a very small percent of the chemicals subject to TSCA 12(b) reporting, a very small percent of such activity will be attributable to the current rulemaking.

Because it is unknown how many, if any, notif ications EPA will r eceive or send as a result of the current rulemaking, the costs to the Agency are presented per activity. 11 

### The burden for the first two Agency activities is provided in Table 11 below. To estimate the Agency cost, hourly burdens are multiplied by the loaded wage rate of a GS-13, Step 5, which is derived in Appendix B

.

Table 11: TSCA 12(b) Export Notification Co st: Agency Burden per Activity (2009$)

Loaded Hours per

Activity FTE per Activity 1 GS-13, Step 5 FTE Wage Rate Mailing

Cost Total Agency Cost per Activity Agency Activity

(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 w ith an Agency activity is the burden for the Agency to process one incoming notification, or to prepare and mail an outgoing notification

Source: Appendix A of this report derives Agency labor costs. Mailing costs are from Table 9 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 2009b), updated for inflation.

11 Beginning with this report ( Economic Analysis of Expedited Significant New Use Rules for 2 5 Chemical

Substances: EPA Docket OPPT-2009-0922 ), the Agency cost per activity is presented, and not the entire Agency costs resulting from export notifications.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 27 May 12, 2010 

### 5.0 ADDITIONAL ANALYSES

This section presents additional analysis of other potential impacts of this rulemaking, as required under various statutes and executive orders.

5.1 Regulatory Flexibility Act (RFA)

The Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et. seq.), as amended by the Small Business Regulatory Enforcement Fairness Act, requi res regulators to consider the impact of regulations on small entities, in particular small busin esses. EPA's experience to date is that, in response to the promulgation of SNURS coveri ng over 1,000 chemicals, the Agency receives only a handful of notices per year. For example, the number of SNUNs was 4 in Federal fiscal year in 2005, 8 in FY2006, 6 in FY2007, 8 in FY2008, and 7 in FY2009. 12 

### During this five-year period, three small entities submitted a SNUN. 13 

### The criteria for 'small business' was that the company checked the box on the PMN form, page 2, stating that it was a small business for the purpose of paying the $100 fee instead of the normal fee.

This leaves open the question of how many small businesses are affected but do not submit SNUNs. For example, businesses may change their behavior in order to use a chemical in a manner that avoids triggering Significant New Use notification requirements, and make no

submission to EPA. Data and resources were not available to estimate the number of such small businesses affected by the current rule. However, a 1989 analysis suggested that few small businesses would be affected by SNURs fo r chemicals that have undergone PMN review. The 1989 report estimated that 9 percent of firms subject to SNURs would be small businesses, based on the portion of PMN submitters who were small businesses (EPA, 1989). The

threshold to be considered a “small business” was $40 million in sales, whic h is consistent with the definition used at 40 CFR §700.43 to set PMN fees.

Past bona fide 

### submissions also suggest that few firms other than possibly some PMN

submitters will be affected. 14 

### EPA has received few bona fides 

### indicating interest in manufacturing or importing chemical s subject to past SNURs. EP A also has received few public comments during rulemaking on SNURs covering PMN chemicals. For example, a SNUR published in the spring of 2003 covering 62 chem icals resulted in industry comments on only three PMNs, none from small businesses (EPA, 2003b).

It remains possible that some small businesse s are affected by S NURs without EPA being aware, for example if the firms have made no su bmissions or comments to EPA. However, even

12 February 5, 2009 email from Carol Rawie, EPA Office of Pollution Prevention and T oxics, to Tulika Narayan and Kimberly Wilson, Abt Associates, and counts of S NUN submissions that had been assigned an identifying number by EPA. The counts include both “valid” and “invalid” SNUNs. SNUN numbering is according to Federal fiscal year, ending September 30.

13 February 5, 2009 email from Carol Rawi e, EPA Office of Pollution Prevention and Toxics to Tulika Narayan and Kimberly Wilson, Abt Associates and reviews of SNUN su bmissions on April 8, 2010 by Abt staff.

14 Bona fides are submitted to EPA by manufacturers and importers to determine a chemical's TSCA Chemical Inventory and regulatory statusEconomic Analysis of Expedited SNURs, Docket OPPT-2009-0922 28 May 12, 2010 

### if a small business were interested in supplying a SNUR chemical, the SNUR's impact on profits is generally expected to be minor. For example, the firm may have a small expense of keeping records and/or of changing wor kplace practices to comply with restrictions. If modifying practices would be overly costly, the sma ll business may instead forego production, thus sacrificing profits. The lost profits, if any, were not quantified for this report, but EPA expects

them to be low. This is because SNUR chemical s are unlikely to be central to a firm’s business because they are relatively new and few compar ed to the many thousands of chemicals on the TSCA Inventory.

Based on these considerations and on the lim ited data available, EPA expects that any compliance with a SNUR w ill not have a significant economic impact on a substantial number of

small entities.

5.2 Unfunded Mandates Reform Act (UMRA)

EPA has determined that this regulatory action does not impose any enforceable duty, contain any unfunded mandate, or otherwise have any effect on small governments subject to the requirements of sections 202, 203, 204, or 205 of the Unfunded Mandates Reform Act of 1995 (Public Law 104-4).

5.3 Paperwork Reduction Act (PRA)

According to the Paperwork Reduction Act (PRA), 44 USC 3501 et seq., an agency may not conduct or sponsor, and a pers on is not required to respond, to a collection of information that requires Office of Management and Budge t (OMB) approval under the PRA, unless it has been approved by OMB and displays a currently valid OMB control number. The information collection requirements related to this action ha ve already been approved by OMB pursuant to the PRA under OMB control number 2070-0012 (EPA, 2007a). This action does not impose any additional burden requiring OMB approval.

5.4 Executive Order 12866, Regulatory Planning and Review

Executive Order 12866, Regulatory Planning and Review, requires OMB review for rules with an impact on the economy of $100 million or more, or with any other potential significant impact. OMB has previously determined that these types of SNURs are not a “significant regulatory action” that w ould require OMB review under this Executive Order.

5.5 Executive Order 13132, Federalism

Executive Order 13132, Federalism (64 FR 43255, August 10, 1999), requires EPA to develop an accountable process to ensure “m eaningful and timely i nput by State and local officials in the development of regulatory policies that have fe deralism implications.” This

action will not have a substantial direct effect on States, on the relations hip between the national government and the States, or on the distributi on of power and responsibilities among the various levels of government, as specified in Execu tive Order 13132, entitled Federalism (64 FR 43255, August 10, 1999).Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 29 May 12, 2010 

### 5.6 Executive Order 12898, Environmental Justice

This action does not involve special considera tions of environmental justice related issues as required by Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations (59 FR 7629, February 16, 1994).

5.7 Executive Order 13045, Pr otection of Children

Executive Order 13045, Protection of Children from En vironmental Health Risks and Safety Risks (62 FR 19885, April 27, 1997), requires EPA to iden tify and assess environmental health and safety risks that may disproportionately affect childre n. This type of analysis is required for rules that will have an impact of $100 million or more only. The impact of these
SNURs will be less than $100 millio n and therefore no analysis of such impacts on children is required.

5.8 Executive Order 13175, Tribal Governments

Executive Order 13175 is Consultation and Coordination with Indian Tribal

Governments (59 FR 22951, November 6, 2000). This rule does not have Tribal implications because it is not expected to have substa ntial direct effects on Indian Tribes.

5.9 Executive Order 13211, Energy Supply, Distribution, or Use

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

### APPENDIX A

LIST OF PMNs AND THEIR CHEMICAL NAMES

### APPENDIX A LIST OF PMNs AND THEIR CHEMICAL NAMES

Table A-1 PMNs and Chemical Names Referenced in this Economic Analysis

No PMN 1 CAS RN 2 Name 2

1 P-04-269 182442-95-1 Cobalt lithium manganese nickel oxide

2 P-08-701 Not available. Benzoic acid, 4-chloro-2- [( substituted)azo]-, strontiu m salt (1:1) (generic).

3 P-08-742 14518-69-5 Phosphonium, tetrabutyl-, hydroxide (1:1).

4 P-08-754 Not available. Aryloxyacrylate (generic).

5 P-09-4 1067881-45-1 Formaldehyde, polymer with 1,3-benzenediol and 1,1'- methylenebis[isocyanatobenzene]

6 P-09-19 21544-03-6. 4-Cyclohexene-1,2-dicarboxylic acid, 1,2-bis(2-oxiranylmethyl) ester.

7 P-09-38 173904-11-5 1,3-Cyclohexanedimethanamine, N1,N3-bis(2-methylpropylidene)-

8 P-09-71 1005516-89-1 Amines, di-C11-14-isoalkyl, C13-rich

9 P-09-120 Not available. Epoxy terminated, hydrolyzed trialkoxysilane and glycidyl ether of phenolformaldehyde resin (generic)

10 P-09-130 1002761-12-7 Soybean oil, epoxidized, reaction products with diethanolamine.

11 P-09-172 84962-05-0 Octadecanoic acid, reaction products with diethylenetriamine and urea, acetates

12 P-09-241 705265-31-2. 1,2-Ethanediol, reaction products with epichlorohydrin.

13 P-09-253 Not available. Polyether poly ester copolymer phosphate (generic).

14 P-09-286 Not available. Poly(oxyalkylenediyl), α -substituted carbomonocycle- ω -substituted carbomonocycle (generic).

15 P-09-385 7384-80-7. Benzenepropanol, .beta.-methyl16 P-09-411 903876-45-9. 2-Propenoic acid, 3-(5,5,6-trimethylbicyclo[2.2.1]hept-2-yl)cyclohexyl ester.

17 P-09-426 Not available. Branched and linear alcohols (generic).

18 P-09-436 Not available. 2-Propenoic acid, 2-methyl-, C12-15-bran ched and linear alkyl esters, telomers with Alkyl 2-[[(alkylthio)thioxomet hyl]thio]-2-alkanoate, aminoalkyl methacrylate and alkyl methacrylate, te rt-Bu 2-ethylhexanoperoxoate-initiated (generic).

19 P-09-451 Not available. Butanamide,N-[substituted phenyl]-[(a lkoxynitroph enyl)diazenyl]-3-oxo- (generic).

20 P-09-478 Not available. Phosphoric acid, polymer with cycloaliphatic diglycidyl ether, alkylethers (generic).

21 P-09-542 13049-88-2 3-No nen-1-ol, 1-acetate, (3Z)-

22 P-09-581 Not available. Styrenyl surface treated manganese ferrite (generic).

23 P-09-582 Not available. Styrenyl surface treated mang anese ferrite with acrylic ester polymer (generic).

24 P-10-9 Not available. Diglycidylaniline (generic).

25 P-10-14 Not available. Quino[2,3-b] acridine-7,14-dione, 2,9-dichloro-5,12-dihydro [4-[[2-(sulfooxy) ethyl] substituted] phenyl]-, sodium salt (1:1) (generic).

Key: PMN = Premanufacture Notice. CAS RN = Chemical Abstract Service Registry Number.

Notes:

1 The PMN number reflects the Federal Fiscal Year and sequence of submission. For example, those starting “P-07” were submitted in the twelve months ending September 31, 2007.

2 If a CAS RN is identified as “Not available” and/or the chemical name is indicated to be “generic” than the chemical identity is indicated to be

confidential.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 - May 12, 2010 A-1

### APPENDIX B

INFLATORS AND WAGE RATES

### APPENDIX B INFLATORS AND WAGE RATES

This appendix describes the derivation of the fully lo aded labor rates and inflation factors used in calculating costs of labor, materials, and other inputs. Costs for this report are for year-end 2008.



### B.1 Derivation of Loaded Wage Rates

Unit labor costs are calculated by adding fringe benefits a nd overhead to the wage or salary to derive a fully loaded labor cost. The basic method is described in Wage Rates for Economic Analysis of the Toxics Release Inventory Program (EPA, 2002b). The resulting loaded labor rates are given in Table B-1 . Costs are calculated for several labor categories: Managerial, Professional/ Techni cal, Clerical, Production Worker s, Industrial Hygienists, and

EPA staff.

In March 2004, BLS began using the North American Industry Classification System (NAICS) codes instead of the Standard Industrial Classification (SIC) System, and the Standard Occupational Classification (SOC) system instead of the Occupational Classification System (OCS). The following table shows the crossw alk between old and ne w occupational titles.

EPAB Reports Labor Category BLS Ol d Title (OCS) BLS New Title (SOC)

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

financial

Professional/Technical Professional specialty and technical Professional and related

Clerical Administrative support, including

clerical Office and administrative support

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



### B.1.1 Derivation of Labor Rates for Manageri al, Professional/Technical, Clerical,

and Production Labor

Wages and fringe benefits for managerial, professional/technical, clerical and production

labor were taken from the Bur eau of Labor Statistics (BLS) Employer Costs for Employee Compensation (ECEC) data, 15 

### for December, for manufacturing industries. 16

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

Chemical Substances: EPA Docket OPPT-2003-0063 (EPA, 2007b). In earlier PMN SNUR economic analyses, such as EPA, 2003a, wage rates for production workers came from the BLS National Employment, Hours, and Earnings, Average Hourly Earnings of Production Workers, while fringe benefits were taken from the ECEC data. Here, as in EPA, 2007b, both wages and fringes for production workers come from ECEC data, for better consistency with the method of estimating labor costs for other labor categories.

16 Employer Costs for Employee Compensatio n Supplementary Tables December 2009. (BLS, 2010a). This follows the approach introduced in EPA, 2007b. Earlier PMN SNUR economic analyses, such as EPA, 2003a, used ECEC data for “All Goods Producing” sectors (manufacturing, mining, and construction). However, the manufacturing sector data seem more relevant since the SNURs mainly affect the chemicals industry.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 B-1 May 12, 2010

### The cost of fringe benefits such as paid leave and insurance, specific to each labor category, are taken from the same ECEC series. Fringe benefits as a percent of wages are calculated separately for each labor category. For example, for December 2009, the average wage rate for professional/technical 17 

### labor was $35.96; the averag e fringe benefit was $17.42. Fringe benefits as a percent of wages were $17.42/$35.96, or approximately 48.4 percent.

An additional loading factor of 17 percent is applied to wages to account for overhead. This approach is used for consistency with O ffice of Pollution Prevention and Toxics economic analyses for two major rulemakings: Wage Rates for Economic Analys es of the Toxics Release Inventory Program (EPA, 2002b), and the Revised Economic Analys is for the Amended Inventory Update Rule: Final Report (EPA, 2002a). This overhead lo ading factor is added to the benefits loading factor, and the to tal is then applied to the base wage to derive the fully loaded wage. For example, the December 2009 fully load ed wage for professional/technical labor is $35.96 × (1+0.4844 + 0.17) = $59.49.

Fully loaded costs for managerial, clerical, and production labor ar e calculated in a similar manner, as shown in Table B-1

.

B.1.2 Derivation of Labor Rates for Industrial Hygienists

For industrial hygienists, wages were based on another BLS data series, Occupational Employment Statistics [OES], National Industry -Specific Occupational Employment and Wage

Estimates. OES data were used because ECEC data were not available for very specific occupations. However, the OES data covers only wages, not fringe benefits. Therefore, the Industrial Hygienist fringe benefits continue to be based on ECEC data. 18



### The wage rate for Industrial Hygienists is a weighted average of the hourly mean wage

for Occupational Health and Safety Specialists, Standard Occupational Classification (SOC) 29- 9011, and Occupational Health and Safety Technicians, SOC 29-9012, in Manufacturing. The wage rate for each occupation was weighted by employment for the occupation. The North American Industry Classificati on System (NAICS) codes for Manufacturing are 31, 32, and 33 (BLS, 2005). The calcula tions are shown in Table B-2

.

As with other labor categor ies, the fringe benefits factor came from the BLS Employer Costs for Employee Compensation Supplementary Tables December 2009 (BLS, 2010a). Benefits for “professional specialty and techni cal” occupations were used, and loaded wages

17 This follows terminology introduced in EPA, 2007b. Ea rlier SNUR economic analyses used the term “technical” labor. Here the category is called “professional/technical” la bor, to make clear how it relates to BLS categories. In 2004, BLS changed from the Occupational Classification System, OCS, to the Standard Occupational Classification system, SOC. In the process, the “P rofessional specialty and technical” category became the “Professional and related” category. However, the coverage of the old and new occupational groups is approximately the same. See the BLS article, C omparing Current and Former Industry and Occupation ECEC Series (Weinstein, 2004 ).

18 This follows the approach for calculating Industry Hygi enist wages introduced in EPA, 2007b and is a change from the method used in earlier PMN SNUR economic reports such as EPA, 2003a, which used data from a 1997 professional journal salary survey.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 B-2 May 12, 2010Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 B-3 May 12, 2010 

### were calculated as for other types of labor. An additional loading factor of 17 percent of wages was applied for overhead. Ca lculations are shown in Table B-1

.

B.1.3 Derivation of Labor Rates for EPA Staff Agency labor costs are calculated based on a nnual Federal salaries for the WashingtonBaltimore area published by the Office of Personnel Management effective January 2009 (OPM, 2009). The average salary for one Full Time Equivale nt (FTE) staff is estimated as the salary for a GS-13 Step 5 employee. 19



### Multiplying the annual pay by an assumed loading factor of 1.6 to reflect Federal fringe benefits and overhead, the loaded annual salary of EPA staff was calculated to be $150,440.

The Agency loading factor is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (EPA, 1992, page 30, footnote 9). The 60 percent assumption was labeled “the benefits multiplication factor” in the EPA Guide, but has been used in many EPA

Office of Pollution Prevention and T oxics ICRs to reflect both fringe benefits and overhead for Federal staff. For example, it was used in an August 2000 document supporting ICR No. 1139.06 (EPA, 2000), with the following explanation:

“The annual costs per FTE are derived by multiplying the annual pay rate by 1.6 (the benefits multiplication factor). The multiplication factor used is

recommended in EPA's Office of Policy, Planning, and Evaluation's Instructions for Preparing Information Collection Requests (ICRs) (June 1, 1992). An EPA internal phone call between Carol Ra wie (OPPT/EETD/RIB) and Carl Koch (OPPE/RMD/IMB) on May 3, 1994, indicat ed that the 1.6 factor included not only benefits but also overhead.” (EPA, 2000)

19 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18 /2007) (EPA, 2007a), which covers PMN SNURs. Use of this grade level follows the approach introduc ed in EPA, 2007b. That report represente d a change from an earlier PMN SNUR economic analysis (EPA, 2003a), whic h used an average of GS-12 Step 1 and GS-12 Step 10 salaries.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922B-4May 12, 2010Table B-1 Derivation of Loaded Wage RatesWageFringeBenefitFringes as% wageOver-head %wage2Fringe +overheadfactorLoadedWages1EPAB LaborCategoryData SourcesDate(a)(b)(c) =(b)/(a)(d)(e)=(c)+(d)+1(f)=(a) x (e)ManagerialBLSECEC, PrivateManufacturingindustries,“Mgt, Business, andFinancial”3Dec-09$42.36$18.6844.10%17%1.61$68.24Professional/TechnicalBLSECEC, PrivateManufacturingindustries, “Professional andrelated“3Dec-09$35.96$17.4248.44%17%1.65$59.49ClericalBLSECEC, PrivateManufacturingindustries,“Office andAdministrative Support”3Dec-09$17.21$8.1747.47%17%1.64$28.31ProductionWorkerBLSECEC, PrivateManufacturingindustries, “Production, transport,and material moving.”3Dec-09$16.35$8.7753.64%17%1.71$27.90IndustrialHygienistWage: BLS OES Occupat. Employ.and Wages,forManufacturing(NAICS 31, 32, 33), average of wagesforOccup. Health/ Safety Specialists(SOC 29-9011) andOccup.Health/Safety Technicians(SOC 29-9012), weighted by employment.4Fringes: BLSECEC, PrivateManufacturing industries,“Professional and related”3Wage:May-08Fringe:Dec-09$28.78--48.44%17%1.65$47.62Dec-09$98,518(annual)--[Includedin 60%overhead]60%1.6$157,629EPA staffFTEAnnual Federal staff cost: OPMWashington-Baltimore-NorthernVirginia, DC-MD-PA-VA-WV, area,GS-13 Step 5 pay rates, with 60%overhead.5(annual)Notes:1Wage data are rounded to the closest penniesin this table; however, in calculationsusing these numbers for this report, unrounded values were used.2An overhead rate of 17% was used based on assumptions inWage Rates for Economic Analyses ofthe Toxics Release Inventory Program(EPA, 2002b), and theRevisedEconomic Analysis for the AmendedInventory Update Rule: Final Report(EPA, 2002a).3Employer Costs for Employee Compensation Supplementary Tables: December 2009.US Bureau of Labor Statistics, March 10, 201- (BLS, 2010).4Employment and unweighted wages are from BLSOccupational Employment Statistics (National Industry-Specific Employmentand Wage Estimates),May 2008.5The salary is unloaded Federal GS-13 Step5 salary for calendar 2009, from the Officeof Personnel Management salary table forWashington-Baltimore-Northern Virginia(OPM, 2009). The 60% fringes-and-overhead rate is from an EPA guide,Instructions for Preparing Information Collection Requests (ICRs)(EPA, 1992, page 30, footnote 9).

### Table B-2 Derivation of Industrial Hygienist Wage Rate (NAICS 31, 32, 33)

Employment Mean hourly wage Weight Weighted

Wage 1 Occupation Title (SOC code)

(a) (b) (c) (d)=(c) X (b)

Occupational Health & Safety Specialists (29-9011) 7,520 $30.03 0.836 $25.09

Occupational Health & Safety Technicians (29-9012) 1,480 $22.45 0.164 $3.69

Industrial Hygienist (w eighted average) 9,000

-- 1 $28.78

Notes:

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

Source: Employment and unweighted wages are for manufacturing (NAICS 31, 32, 33) from BLS Occupational Employment Statistics (Occupational Employment and Wages) , for May 2008 (BLS, 2 009). The most recent published OES data when this report was prepared in April, 2010, was for May 2008.



### B.2 Derivation of Inflation Factors

Costs of equipment and supplies were infl ated using the Consumer Price Index – All Urban Consumers; wages were inflated using the appropriate Employment Cost Index (ECI). Where both labor and equipment/supp lies were involved, we used the inflation factor corresponding to the dominant cost category 20 

### . For example, test costs include a mix of labor, equipment, and supplies. Assumi ng that the largest component of test costs comes from labor, we used the ECI for pr ivate industry, all workers. Complete

information on the derivation of the in flation factors used is given in Table B-3 below.

In 2006, the Bureau of Labor Statistics (BLS) made several changes to the Employment Cost Index. The changes ar e described on a BLS web page, “Change has come to the ECI,” (BLS, 2006c) and in several April 2006 Monthly Labor Review articles posted on the BLS web site: “Changes affecting the Employment Cost Index: an overview” (Caroll 2006); “Employment Cost Index Pub lication Plans” (Sleemi, 2006); and “Seasonal adjustment in the ECI and the convers ion to NAICS and SOC” (Branch, 2006).

Under a mandate from OMB, BLS change d its classification of industries and occupations from the Standard Industrial Clas sification (SIC) and Occ upational Classification System (OCS) to the North American Industry Classification System (NAICS) and Standard Occupational Classification (SOC) system. In 2006, BLS adjusted all ECI se ries to reflect this change.

20 Prior SNUR economic analyses used the seasonally adjusted E CI for the total compensation

, private industry white collar workers (Series ID CIS2010000W00000I) to inflate export notification and Agency extramural cost. However, in 2008 B LS retired both the “white-collar” and “blu e-collar” series (BLS, 2008, p. BLS-45) . Therefore beginning with this report

, Economic Analysis of Expedited Significant New Use Rules for 2 5 Chemical Substances:

EPA Docket OPPT-2009-092 2

, the “white-collar” series was replaced with the not seasonally adjusted E CI for total compensation of private industry professional and related workers (Series ID CIU2010000120000I ). The

“ professional and related workers ” series was chosen because it is the only series with continuou s data since 1985, and the majority of export notification and Agency extramural activities are performed by professional and technical

labor.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 B-5 May 12, 2010

### In addition to changing the industry and o ccupational classification systems, in 2006,

BLS rebased the ECI from June 1989 = 100 to December 2005 = 100 for all current and historical non-seasonally adju sted series, including the NAICS and SIC based series. (Seasonally adjusted indices, includ ing those in Table B-3 of this report, may not exactly equal 100 for December 2005 as a result of the seasonal adjustment. Seasonal adjustments are explained in Branch, 2006.)

According to BLS, the official ECI for th e years 1975-2005 is the SIC-OCS based series, and for subsequent years, the official ECI is the NAICS-SOC based series (Sleemi, 2006, p.8). 21



### “Starting year” indices in Tabl e B-3 continue to be SIC-SOC based. Current year indices

are NAICS-SOC based. We use indices from both the NAICS-SOC and the SIC-OCS based ECI series because neither series spans the entire period over which testing and other costs need to be

inflated.

21 BLS has been publishing the NIACS-SOC ba sed ECI series since March 2001 and it be came official in March 2006. The SICOCS based series and NAICS-SOC series ha ve different series ID numbers, even wh en they describe essentially the same population. For example the series ID fo r seasonally adjusted total compensation for all private industry workers is ECS10002I

for the SIC-OCS series and CIS2010000000000I for the NAICS-SOC series



### .

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 B-6 May 12, 2010

### Table B-3 Derivation of Inflation Factors

Item Inflation index source 1 Starting

year Index for starting

year (a) Index

for

2009

(b) Inflation

factor (b)/(a) 2

Chemical testing (toxicity, ecological effects etc.) BLS ECI, SA, Total comp, Private industry , All Workers , 4 th Q [BLS 2006d and 2010c] varies varies 110.4 varies

White collar/other labor mix; equipment; supplies. Example for test costed in 1993 1993 66.5 110.4 1.660

Tests were first costed out in various years, depending on the test; inflation factors vary depending original cost date. Example for test costed in 2000 2000 83.8 110.4 1.317

Impermeability testing of gloves and other gear 3 BLS ECI, SA, Total comp, Private industry , All Workers , 4 th Q [BLS 2006d and 2010c] 1997 74.9 110.4 1.474

Export notification BLS ECI, ,Total comp, Private industry, Professional and related , 4 th
Q [BLS 2010d] 4 1992 64.9 111.4 1.716

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

Labels, placards, gloves, eyewear, clothing, respirators, file cabinet BLS CPI, All urban consumers, not SA. CUUR0000SA0, Annual [BLS 2010b] 1997 160.5 214.537 1.337

Photocopies Record keeping materials BLS CPI, All urban consumers, not SA. CUUR0000SA0, Annual [BLS 2010b] 1988 118.3 214.537 1.813

Notes:

1 In 2006, Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) series “were rebased to December 2005 = 100 from June 1989 = 100.” The change is reflected in the i ndices in this table and explained on the BLS website, Employment Cost Index News Release Text: Employment Cost Index, March 2006 (BLS, 2006b). The Consumer Price Index (CPI) was not rebased.

“Starting year” ECI indices are SIC-OCS based: Seasonally Adju sted (SA) ECS10002I for private industry All Workers, and not SA ECU11122I for private industry Professional and Related Workers.

After 2006, ECI indices are NAICS-SOC based: Seasonally Ad justed (SA) CIS2010000000000I for private industry All Workers,

and not SA CIU2010000120000I (B ) for private industry Professional, and Related workers.

. 2 Inflation factors are rounded to three decimal places in this table, but calculations in this report use the unrounded values. BLS CPI values were published with one decimal place through 2006 and with th ree decimal places after that.

3 We began using the ECI for Private Industry All Workers in EPA, 2007b, to better reflect the labor mix for impermeability testing.

Earlier PMN SNUR economic analyses used the EC I for Private Industry White Collar Workers.

4 Beginning with this report ( Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: EPA Docket

OPPT-2009-0922 ) we began to use the not-seasonally adjusted CIU2010000120000I for private industry Professional, and Related workers, instead of S A CIS2010000W00000I for private industry white collar workers because BLS retired the “white-collar” series.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 B-7 May 12, 2010

### APPENDIX C

COSTS OF HAZARD COMMUNICATION, PR OTECTION IN TH E WORKPLACE, AND RECORDKEEPING REQUIREMENTS

### APPENDIX C COSTS OF HAZARD COMMUNICAT ION, PROTECTI ON IN THE WORKPLACE, AND RECORDKEEPING REQUIREMENTS

Section 2.1 of the main text of this report discusses costs of worker protection, hazard communication (haz-comm), and recordkeeping for SN URs. This appendix presents dollar costs and labor hours of these requirements, for one ch emical at one site. Some requirements listed here may not be cited in the current rulemaking, but have been cited in past SNUR rulemakings.

The haz-comm costs reflect th e annual costs of updating th e written program, labeling for chemical distribution and storage, creating and di stributing material safety data sheets (MSDS), and employee training. The personal protective equipment (PPE) costs reflect the annualized costs of providing required equipment (i.e., glov es, goggles, clothing, or re spirators), assessing dermal protection needs associated with the chemical, and performing required impermeability testing, and/or evaluating manufacturer’s inform ation. Finally, the annual recordkeeping costs include labor, photocopying, a nd record storage costs.

To estimate the costs of haz-comm, worker protection, and recordkeeping requirements, a number of assumptions were made, based on th e original EPA analysis for generic SNUR provisions, Economic Analysis of Final Significant Ne w Use Rule: General Provisions for New Chemical Followup (EPA, 1989). In that report, EPA estim ated that the number of workers exposed to any one substance would range from 10 to 25, and that a worker potentially would be exposed to a substance for a minimum of 50 days per year to a maximum of 250 days per year. The current analysis uses the high ends of those two ranges. Thus, each site is assumed to have 25 chemically-exposed workers requiring training and/or protective equipment, with each of them assumed to be exposed for 250 days per year.

Labor costs are derived from the United States Bureau of Labor Statistics sources as described in Appendix B. Mate rial costs were primarily obtained from a national safety equipment supply house catalog (LSS, 1997) and ar e inflated as described in Appendix B.

Costs of haz-comm, workplace protection, and recordkeeping are discussed in Sections C.1, C.2, and C.3, respectively. Table 4 and Table 6 in the main text summarize these costs by SNUR requirement.

C.1 Modifying the Hazard Communication Program

As mentioned in Section 2.1, it is assumed that each facility has in place a haz-comm program consistent with that required by OSHA’s Hazard Communication standard (29 CFR 1910; November 25, 1983), so that costs attributable to the S NUR are costs of adding one chemical to the program. Much of the haz- comm methodology and assumptions came from the EPA report, Economic Analysis of Final Significant New Use Rules: General Provisions for New Chemical Followup (EPA, 1989), which in turn reli ed partly on the 1983 OSHA study, Final Regulatory Impact and Regulatory Flexibility An alyses of the Hazard Communication Standard OSHA, 1983).

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-1 May 12, 2010

### It was assumed that the haz-comm costs would be incurred each year. For example, there

would be worker turnover and need for refreshe r training, the MSDS would need revision due to changing information, placards would wear out (EPA, 1989). To the extent that some steps would not need repeating each year, costs coul d be lower than estimated here. The hazard

communication costs summarized in Table 3 above are detailed here.

C.1.1 Updating the Written Program

If the SNUR cites 40 CFR §721.72(a), then to avoid engaging in a Significant New Use, which would trigger other SNUR requirements, manufacturers must update their written hazcomm program to incorporate information about th e chemical. The written part of the program

includes data and information about hazardous chem icals present in the workplace, the hazards associated with such chemicals, procedures for employees who routinely work with or around such chemicals, procedures for non-routine task s that may involve exposure (e.g., tank cleaning), and personal protective equipment requirements wh en working with or around such chemicals.

While material safety data sheets may provide much of the information needed to update the written haz-comm program, many employers may perform a more detailed assessment of exposure risks associated with the chemical a nd develop more site-specific procedures for workers potentially exposed to such chemicals. For purposes of the economic analysis, EPA assumes that each employer will engage the servi ces of a professional industrial hygienist (IH),

either in-house or on a consulti ng basis, for four hours to perfor m such an assessment. Loaded hourly rates for IH services we re calculated based on Bureau of Labor Statistics data, as

described in tables B-1 and B-2. Costs for th e written haz-comm program , in 2009 dollars, are as

follows 22



### 4 hours Industrial Hygienist time × $47.62 per hour = $190

The estimates of IH hours to update the pr ogram come from a 1998 EPA report (EPA, 1998).

C.1.2 Labeling

If the SNUR cites 40 CFR §721.72(b), then to avoid engaging in a Significant New Use,

manufacturers must ensure that co ntainers used to distribute the PMN substance in commerce are labeled with the necessary hazardous substance warn ings and procedures. In addition, containers used in the workplace must bear similar labels or, alternatively, the employer must provide equivalent signage, operating pr ocedures, or other written ma terial to communicate hazard information to workers. The cost of providing such labeling was estimat ed in a 1989 EPA report (EPA, 1989) and has been updated here using more recent cost information.

Standard formats are assumed to be used fo r creating labels or other signage, and the information required for the labels is assumed to be already available from the MSDS for the chemical (see below).

22 Figures presented here are rounded.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-2 May 12, 2010

### C.1.2.1 Chemicals Distributed in Commerce

For chemicals distributed in commerce, the labeling process is assumed to require 0.5 hours of technical labor time per chemical to compile label information. It is assumed to require 480 labels per chemical. The assumption of 480 labels per chemical is from a 1989 EPA report (EPA, 1989), and is based on the assumption that, on average, each chemical is shipped twice monthly to 20 customers. This is consistent with roughly 10,000 kilograms of chemical per year shipped in 40 five-gallon c ontainers per month (EPA, 1989). 23



### Technical labor is fully loaded with fri nge benefits and overhead, as described in Appendix B. Labeling materials costs were obt ained from a national safety equipment supply house catalog (LSS, 1997) and were inflated as described in Appendix B. The resulting costs of labeling for chemicals distributed in commerce, pe r chemical substance at one site, are shown in

Table C-1

.

Table C-1 Annual Costs of Labeling for Distribution in Commerce [40 CFR §721.72(b)(2)]

Cost Element Unit Cost (1997 Dollars) Inflation Factor Unit Cost (2009 Dollars) Hours Total

Cost

0.5 hours technical time

-- -- $59.49 per hour 0.5 $30

480 labels $0.16 per label 1.337 $0.21 per label

-- $103

TOTAL 0.5 $132

Note: Total costs were calculated using unrounded unit cost values and inflation factors (see Appendix B), so results may differ from calculations using the rounded values shown in this table.

Source: 1997 label cost, EPAB 1998, LSS 1997; cost elements, quantities, RIB 1989; inflators, labor, Table B-1 and

Table B-3

.



### C.1.2.2 Chemicals Used in the Workplac e

Workplace labeling requirements are costed by assuming the facility purchases six large (14" × 10") signs, priced at $38 .30 each in 1997 dollars (LSS, 1997; EPA, 1998). Costs of these signs were inflated as describe d in Appendix B. These signs will be mounted in areas where the chemicals are used or formulated. For example, a placard might be posted at each of six vessels: a mixing tank, a reactor, two se parators, and two storage vessels (EPA, 1989). The labeling process is also assumed to require 0.5 hours of technical time to compile label information and 10 minutes of production worker time to post each placard. Technical labor costs include wages, fringe benefits, and overhead, as described in Appendix B.

23 Data on PMN notices suggest that some PMN submitters expected to produce less than 10,000 kilograms per year of the SNUR chemicals, but many expected to produce much more. It is not known whether volumes listed in the PMNs were realized in practice. Production volumes of secondary suppliers affected by th e SNUR are also unknown. Annual volumes significantly greater than 10,000 kg could lead to higher haz-comm costs than those estimated here.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-3 May 12, 2010

### The resulting per chemical, per site costs of labeling for chemicals in the workplace are

shown in Table C-2

.

Table C-2 Annual Costs of Labeling for Use in Workplace [40 CFR §721.72(b)(1)]

Cost Element Unit Cost (1997 Dollars) Inflation

Factor Unit Cost (2009 Dollars) Hours Total

Cost

0.5 hours technical time

-- -- $59.49 per hour 0.5 $29.75

6 labels or placards (14" x 10") $38.30 per item 1.337 $51.19 per item

-- $307

10 minutes per label/placard production worker time -- -- $27.90 per hour 1.0 $27.90

TOTAL 1.5 $365

Note: Total costs were calculated using unrounded unit cost values and inflation factors (see Appendix B), so results may differ from calculations using the rounded values shown in this table.

Source: 1997 placard cost, EPA, 1998, LSS, 1997; cost elemen ts and quantities, EPA, 1989 ; inflators and labor unit

costs, Table B-1 and Table B-3

.



### C.1.3 Preparing Material Safety Data Sheet (MSDS) Information

If the SNUR cites 40 CFR §721.72(c), then to avoid engaging in a Significant New Use, each facility is required to create, post, and di stribute material safety data sheets (MSDSs). Based on estimates in OSHA 1983, the 1989 EPA report (EPA, 1989) has estimated that creation of an MSDS for a chemical substance require s 2.0 hours of technica l labor time and 0.25 hours of clerical time. Further, EPA assumes that the manufacturer provides 20 copies of the MSDS to customers and retains 20 copies for use onsite, for a total of 40 copies (EPA, 1989). The loaded hourly wage rates and the inflator used in estimating unit photocopy costs are derived in Appendix B. The resulting cost of MSDS preparation is shown in Table C-3

.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-4 May 12, 2010

### Table C-3 Annual Costs for Material Safety Data Sheets (MSDSs) [40 CFR §721.72(c)]

Cost Element Unit Cost (1988 Dollars) Inflation

Factor Unit Cost (2009 Dollars) Hours Total

Cost

2.0 hours technical

time -- -- $59.49 per hour 2 $119

0.25 hours clerical

time -- -- $28.31 per hour 0.25 $7.08

40 copies $0.05 1.813 $0.09 per copy -- $3.63

TOTAL 2.25 $130

Note: Total costs were calculated using unrounded unit cost values and inflation factors (see Appendix B), so results may differ from calculations using the rounded values shown in this table.

Source: Cost elements, quantities, and 1988 copy co st, RIB 1989; inflators and labor unit costs, Table B-1 and Table B3 

### C.1.4 Employee Training

The final required component of the haz-co mm program is employee training, based on 40 CFR §721.72(d). The 1989 EPA report, Economic Analysis of Final Significant New Use Rules: General Provisions for New Chemical Follow-up (EPA, 1989), assumes that a training program currently is in place, but the existing pr ogram must be modified to add new information pertaining to the PMN substance. Subsequent ly, the training program must be expanded to include such material each time the training course is presented. Costs of modifying the program and presenting the modified program are mainly labor costs for the trainer and the trainees.

Inserting the new information about the PMN substance into the training program and conducting the revised training is assumed to require 0.5 hours of the trainer’s time. An additional 0.25 hours per trainee is estimated to be required, and an average of 25 affected workers is assumed per facility (EPA, 1989). If additional production workers needed to be trained, for example because they might come into contact with the chemical due to spills or leaks, training costs could be highe r than estimated here (EPA, 1989).

Labor rates for training are based on the loaded rates derived in Appendix B for chemical technicians and chemical industry production worker s. The total cost of the employee training requirement is shown in Table C-4

.

Table C-4 Annual Costs for Employee Trai ning, Per Chemical [40 CFR §721.72(d)]

Cost Element Unit Cost (2009 Dollars) Hours Total Cost

0.5 hours technical time (trainer) $59.49 per hour 0.5 $29.75
0.25 hours per production employee X average of 25 workers per plant = 6.25 hours $27.90 per hour 6.25 $174

TOTAL 6.75 $204

Note: Total costs were calculated using unrounded values from (see Appendix B), so results may differ from calculations using the rounded values shown in this table.

Source: Cost elements and quantities, EPA, 1989; labor unit costs, Table B-1

.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-5 May 12, 2010

### C.2 Protection in the Workplace

The following section estimates costs of a ssessing needs for dermal protection and evaluating protective gear for impermeability, as we ll as the costs of glove s, goggles, protective clothing, and respirators.

C.2.1 Dermal Protection Selection

If the SNUR cites 40 CFR §721.63(a)(1), then to avoid engaging in a Significant New Use, the employer must ensure that each person who is likely to experience dermal exposure to a PMN chemical, must be provided with and is re quired to wear personal protective equipment (e.g., gloves) that will prevent dermal exposure to the substance. The equipment must be selected and used in accordance with 29 CFR § § 1910.132 and 1910.133 (promulgated by the Occupational Safety and Health Administration, OSHA). The se lection and administration of this dermal protection is estimated to require 10 hours labor by an industrial hygienist, annually (EPA, 1999). The wage rate of the hygienist wa s calculated as described in Appendix B. The cost calculations for the dermal protec tion selection requirement are given in Table C-5 . This covers only costs of selecting the dermal protect ion needed, not costs of the items themselves. For costs of purchasing dermal protective items , see the sections below on costs of gloves, eyewear, and clothing.

Table C-5 Annual Costs for Dermal Protection Selection [40 CFR §721.63(a)(1)]

Cost Element Unit Cost (2009 Dollars) Hours Total Cost 1

10 hours industrial hygienist (IH) time $47.62 per hour 10 $476

Notes: Total costs were calculated using unrounded values (see Appendix B), so results may differ from calculations using

the rounded values shown in this table.

Source: Labor rates, Table B-1 ; cost elements and quantities, EPA, 1999.



### C.2.2 Impermeability Testing

As part of the workplace protection requi rements specified under 40 CFR §721.63(a)(3), to avoid engaging in a Significant New Use, the SNUR may require that employers demonstrate that each item of protective equipment provided (e.g., gloves) provides an impervious barrier, to protect employees from dermal exposure. Re quirements outlined in §721.63(a)(3) are provided in two parts, §721 .63(a)(3)(i) and (ii). The empl oyer may use a combination of (i) testing and/or (ii) evaluating manufacturer specifications . The following discussion is based on the Economic Analysis of Expedited Significant Ne w Use Rules for 168 Chemical Substances and Background Support Document for Economic Analysis of Significant New Use Rules (EPA, 1998) and assumes that the manufacturer uses both testing and evaluation of manufacturer specifications. The analysis assumes that costs are incurred annually.

The first step, described at 40 CFR §721.63(a)(3)(i), is to perform actual impermeability testing. To determine the costs of imperm eability testing compliance, Best Manufacturing

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-6 May 12, 2010

### Company, a leading manufacturer and tester of chemical resistant articles, was consulted (Best, 1997).

As described in EPA, 1998, Best used one of two methodologies for impermeability testing. In the first method, chemical samples were submitted to Best with a specific article to be tested for impermeability. This method was chea per, costing $200 per chemical, but the burden of finding an appropriate article of protection lay with the chemic al manufacturer. In the second method, the chemical manufacturer simply submitted chemical samples to Best, who in turn determined the most appropriate product, even if a competitor manufactured the product. This method was more costly at $800 per chemical.

The second method of impermeability testing is favored in this analysis for several reasons. First, the burden of finding and submitting an article of protection is shifted from the chemical manufacturer to the testing company, who would have greater experience in Personal Protective Equipment (PPE) selection. Second, should the article submitted fail the impermeability test, other articles may have to be submitted until satisfactory test results are obtained. Furthermore, substanc es subject to SNURs may include new and/or rare chemicals, which may have undiscovered or unknown properties. This uncertainty may impede chemical manufacturers’ ability to effectively submit appropriate PPE arti cles for testing. Finally, the first method is essentially a pass-fail test. If an article passes the impermeability test, then it is acceptable. In the second met hod, several articles may be test ed and compared, and, while one or more acceptable articles may re sult, the most impermea ble article is always determined for the

chemical. To obtain the best 

### article rather than merely a sati sfactory article of protection, the second method of testing is more appropriate. Fo r these reasons, unit costs of $800 per chemical (1997 dollars) are assumed for impermeability testi ng. The cost of the impermeability testing is assumed to be driven by labor costs of the comp any performing the testing, thus test costs were inflated with an Employment Cost Index as desc ribed in Appendix B. The administration of this test would also require two hours of industrial hygienis t labor (EPA, 1999).

The second step to compliance with th e workplace protection requirements at §721.63 (a)(3)(ii) is the evaluation of specifications from the ma nufacturer or supplier of the protective equipment. This requirement helps ensure that the protective equipment will be impervious to the PMN chemical(s). The evalua tion of manufacturer sp ecifications requires

an estimated four hours of industrial hygienist labor.

Annual costs of the impermeability tes ting requirements are presented in Table C-6

.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-7 May 12, 2010

### Table C-6 Annual Costs of Impermeability Testing [40 CFR §721.63(a)(3)]

Cost Element Unit Cost (1997 Dollars) Inflation

Factor Unit Cost (2009 Dollars) Hours Total Cost 1

Impermeability Testing [§721.63(a)(3)(i)]

Impermeability Test $800 per chemical 1.474 $1,179 per chemical $1,179

$47.62 per hour 2 $95.24 Industrial Hygienist time

Subtotal 2 $1,274

Evaluation of Manufacturer's Specifications [§721.63(a)(3)(ii)]

$47.62 per hour 4 $190 Industrial Hygienist time

Subtotal 4 $190

TOTAL 6 $1,465

Notes:

1 Total costs were calculated using unrounded unit cost values and inflation factors (see Appendix B), so results may differ from calculations using the rounded values shown in this table.

Source: 1997 costs, Best, 1997; cost elements and quantities, EPA, 1998 and EPA, 1999; inflators and labor rates,

Table B-1 through Table B-3

.



### C.2.3 Gloves

If the SNUR cites 40 CFR §721.63(a)(2)(i), then gloves must be worn to avoid engaging in a Significant New Use. Gloves may also be acquired as a result of the dermal protection selection at §721.63 (a)( 1). If standard, disposable medical-grade gloves are used, they are assumed to be worn and discarded by the worker following each day of exposure. Each site is assumed to have 25 workers, each of them exposed 250 days per year. This reflects the high-side assumptions in EPA, 1989 (page 25 ) for the number of workers and exposure days. Each pair was estimated to cost $0.43 in 1997 (LSS, 1997); the cost has been inflated as described in Appendix B. Total annual costs of providing disposable gloves are developed by applying the assumptions above regarding the nu mber of workers exposed (25 per site) and frequency of replacement (one pair per worker per day of exposure H 

### 250 days of exposure per year). For some chemicals, heavy-duty gloves may be used. They are generally not disposed of daily, but are more expensive. The estimated costs of glove s purchased in compliance with SNUR Personal Protective Equipment requirements are presented below in Table C-7 . The cost estimates for each chemical assume that the more expensive heavy-duty gloves are used in cases where the SNUR explicitly requires gloves.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-8 May 12, 2010

### Table C-7 Annual Cost of Gloves [40 CFR §721.63(a)(2)(i)]

Cost Element Unit Cost ($1997 per pair) Inflation

Factor Unit Cost ($2009 per pair) Number

of Pairs Required 1 Total Cost ($2009) 2

Disposable nitrile gloves (replaced daily) $0.43 1.337 $0.57 6,250 $3,592

Heavy duty butyl gloves (replaced every 25 work days) $34.00 1.337 $45.45 250 $11,362

Notes:

1 The analysis assumes that 25 work ers who are exposed 250 days/year replace disposable gloves daily and replace heavy duty gloves every 25 work days.

2 Total costs were calculated using unrounded unit cost values and inflation factors ( Table B-3 ), so results may differ from calculations using the rounded values shown in this table.

Source: 1997 item costs, LSS, 1997; item type and quantity, EPA, 1998; inflator, Table B-3

.



### C.2.4 Eyewear

If the SNUR cites 40 CFR § 721.63(a)(2)(iii), then to avoid engaging in a Significant New Use, employer must provide eye protection. Eye protection may also be ac quired as a result of the dermal protection selection at §721.63 (a)( 1). Protective goggles are expected to be used at a rate of one set per worker and replaced every f our months. Each site is assumed to have 25 workers, each of them exposed 250 days per year . The SNUR may not specify the exact type of eyewear required. OSHA guidelines in 29 CFR § 1910.133 (b)( 1), however, state that protective eye and face devices purchased af ter July 5, 1994 shall comply with ANSI Z87.1- 1989. To determine the cost of goggles that meet this standard, EPA consulted with eyewear specialists at equipment supplier LSS. A sta ndard pair of goggles that meets the ANSI Z87.1- 1989 specification was priced at $4.05 per pa ir in 1997 (LSS, 1997; RIB, 1998). A price estimate for a heavy-duty pair of goggles compliant with the ANSI standard is also included in

Table C-8

.

The cost estimates for each chemical assu me that the more expensive heavy-duty goggles are used in cases where the SNUR explicitly requires goggles. Costs of protective eyewear were inflated as described in Appendix B and are presented in Table C-8 below.

Table C-8 Annual Cost of Protective Eyewear [40 CFR §721.63(a)(2)(iii)]

Cost Element Unit Cost ($1997 per pair) Inflation

Factor Unit Cost (2009$ per pair) Number

of Pairs Required 1 Total

Cost 2

Standard Goggles $4.05 1.337 $5.41 75 $406

Heavy duty chemical-splash/impact goggles $6.05 1.337 $8.09 75 $607

Notes:

1 The analysis assumes 25 workers re placing goggles three times per year.

2 Total costs were calculated using unrounded unit cost values and inflation factors (see Appendix B), so results may differ from calculations using the rounded values shown in this table.

Source: 1997 item costs, LSS, 1997; item type and quantity, EPA, 1998; Inflator, Table B-3

.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-9 May 12, 2010

### C.2.5 Clothing

Costs for a standard coverall clothing set, estimated at $36.25 in 1997 (LSS, 1997), were

inflated as described in Appendix B and are shown in Table C-9 below. Costs for full-body protective clothing are based on the coverall clothing set with 

### a hood (LSS, 1997) as shown in

Table C-9

.

If the SNUR cites 40 CFR §721.63(a)(2)(ii) or (iv), then to avoid engaging in a Significant New Use, employers must provide protective clot hing. Protective clothing may also be acquired as a result of the dermal protection select ion at §721.63(a)(1). Protective clothing, (a)(2)(iv), and full-body chem ical resistant clothing, (a)(2)(ii ), are assumed to last four

months. Each site is assumed to have 25 wo rkers, each of them exposed 250 days per year.

Table C-9 shows estimated costs, after inflating as described in Appendix B, for a standard coverall clothing set that cost $36.25 in 1997 (LSS, 1997) and for full-body protective clothing – the coverall clothing set with 

### a hood – costing $61.20 in 1997 (LSS, 1997).

Table C-9 Annual Cost of Protective Clothing [40 CFR §721.63(a)(2)]

Cost Element Unit Cost ($1997 per set) Inflation

Factor Unit Cost (2009$ per set) Number Required 1 Total Cost 2

Coverall with hood [full-body clothing] §721.63(a)(2)(ii) $61.20 1.337 $81.80 75 $6,135

Coverall §721.63(a)(2)(iv) $36.25 1.337 $48.45 75 $3,634

Notes:

1 The analysis assumes 25 workers re placing coverall three times per year.

2 Totals were calculated using unrounded unit cost values and inflation factors (see Table B-3 ), so results may differ from calculations using the rounded values shown in this table.

Source: 1997 item costs, LSS, 1997; item type and quantity, EPA, 1998; inflation factor, Table B-3

.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-10 May 12, 2010

### C.2.6 Respirators

For some PMN chemicals, to avoid enga ging in a Significant New Use, the SNUR requires either the use of re spirators or compliance with a New Chemical Exposure Limit (NCEL). Both requirements differ by chemical. 18 24 

### For costing purposes, this analysis assumes that respirators are used. Earlier, PMN SNUR s referenced specific pa ragraphs at 40 CFR §721.63 (a)(5) that identified fifteen types of NI OSH-approved respirator units. However, with rulemaking docket OPPT-2003-0063 (EPA, 2007b), PM N SNURs began to describe respirator choices directly. Costs of the SNUR respirator choices were estimated based on the costs of the respirator in §721.63 (a)(5) that appeared to best match the SNUR descriptions.

24 EPA’s website at http://www.epa.gov/oppt/newchems/pubs/ncelmain.htm explains that in Consent Orders and subsequent SNURs, EPA can require respirators unle ss workplace air measurements show that air-borne concentrations of the chemical are below a New Chemical Exposure Limit established by EPA to protect health. NCEL provisions are modeled after Occupational Safety and Health Administration Permissible Exposure Limits (PELs), and also cover sampling and analytical methods, monitoring, respiratory protection, and recordkeeping.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-11 May 12, 2010

### Table C-10 Crosswalk Between SNUR Text a nd Respirator Types at 40 CFR §721.63(a)(5)

Respirator types at 40 CFR §721.63 (a)(5) 1 Requirement Stated in SNUR (exact SNUR wording may differ)

(ii) Category 19C Type C supplied-air respirator operated in pressure demand or continuous flow mode and equipped with a tight-fitting facepiece.

Some SNURs may specify “full” facepiece

Some SNURs may specify “or other positive pressure

mode” Supplied-air respirator oper ated in pressure demandor continuous flow mode and equipped with a tightfitting full facepiece.

Supplied-air respirator oper ated in pressure demand or other positive pressure mode and equipped with a tight-fitting full facepiece

(iii) Category 19C Type C supplied-air respirator operated in pressure demand or continuous flow mode and equipped

with a hood or helmet or tight-fitting facepiece.

Some SNURs may specify “half” or “full” facepiece. Supplied-air respirator oper ated in pressure demand or continuous flow mode and equipped with a hood or helmet or tight-fitting facepiece (either half- or full-face).

(iv) Category 21C air-purifying respirator equipped with a full facepiece and high effici ency particulate filters.

Some SNURs may specify a “half" or "full" facepiece.

Some SNURs may specify “if oil aerosols absent” or other

restrictions related to oil aerosols. Air-purifying respirator equipped with a tight-fitting full facepiece and High Effi ciency Particulate Air (HEPA) filters.

Air-purifying, tight-fitting respirator equipped with N100 (if oil aerosols absent), R100, or P100 filters (either half- or full-face).

Air-purifying, tight-fitting re spirator (either half- or full-face) equipped with N100 (if oil aerosols absent), R100 (restricted use when oil aerosols present), or P100 (appropriate when oil aerosols present) filters.

Air purifying, tight-fitti ng full-face respirator equipped with the appropriate combination cartridges tested and approved for the gas/vaporsubstance (i.e., organic vapor, acid gas, or substancespecific cartridge), with a particulate filter (N100 if oil aerosols are absent, R100, or P100).

(v) Category 21C powered air-purifying respirator equipped with a tight-fitting facepiece and high efficiency particulate

filters.

Some SNURs may specify a “half" or "full" facepiece. Powered air-purifying, tight-fitting full-face respirator equipped with N100 (if oil aerosols absent), R100, or P100 filters.

Powered air-purifying respirator equipped with a tight-fitting facepiece (either half- or full-face) and

HEPA filters.

(vi) Category 21C powered air-purifying respirator equipped with a loose-fitting hood or helmet and high efficiency particulate filters. Powered air-purifying respirator equipped with a loose-fitting hood or helmet and High Efficiency Particulate Air (HEPA) filters.

Notes:

1 The table specifies respirator types at 40 CFR §721.63 (a)(5) that are most similar to the equipment described in the SNUR text for the current and recent SNUR rulemakings. Any significant differences between the specified respirator type at 40 CFR §721.63 (a)(5) and the SNUR text respirator type are noted in italics.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-12 May 12, 2010E conomic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-13 May 12, 2010 

### Table C-11 gives average costs of various respirator types, both as originally estimated in 1997 and after applying inflation f actors from Table B-3. It also estimates costs per plant site for a ch emical requiring respirators.

The respirators specified in the SNURs are typically comprised of a respirator unit and any number of the following: special cartr idges (such as high efficiency particulate filters, organic vapor cartridges, and paint, lacquer, and enamel filters), hoods or helmets, and filter caps. The costs for each site of providing respirator s to chemically-exposed workers,

shown in Table 4 of Section 2 of the repor t, are calculated based on the assumptions stated there, that (1) there are 25 chemically-exposed workers requiring protective equipment, (2) respirators are replaced once a year, and (3) cartridges (and cartridge filters and caps) are replaced at a rate of one pair (two cartridges) every five of the 250 days that workers are exposed, or 50 times per year. For example, for the respirator type described at 40 CFR §721.63(a)(5)(xv), the annual cost per worker in 1997 dollars would be as follows:

$10.83 per respirator + ($8.94 per cartridge × 50 cartridges/year) = $457.83 per worker.

The 1997 cost was adjusted for inflation as shown in Table C-11

. Typically a SNUR describes more than one type of respirator, but only one type of respirator is needed to comply with the workplace protection requirements.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922C-14May 12, 2010Table C-11 Annual Per-Chemical Costs forRespiratory Protection [40 CFR §721.63(a)(4)]Annual Average Costs(1997 Dollars)Annual Average Costs(2009 Dollars)1§721.63(a)(5)par.NIOSH approval type at 40 CFR §721.63 (a)(5)(See Table C-10 for cross-walk to respirators in SNUR)RespiratorUnitCartridgeSetPerWorker2InflationFactorAnnual PerWorkerAnnual Per Site(25 workers)3(i)19C Type C Supplied-air with full facepiece$804$0.00$8041.337$1,075$26,868(ii)19C Type C Supplied-airwith tight-fitting facepiece$804$0.00$8041.337$1,075$26,868(iii)19C Type C Supplied-airwith hood or helmetor tight-fitting facepiece$932$0.00$9321.337$1,246$31,150(iv)21C Air-purifying with full facepiece andhigh efficiency particulate filters(HEPAs)$181$9.76$6691.337$894$22,345(v)21C Powered air-purifying (PAPR) with tight fitting facepiece and HEPAs$627$35.50$2,4021.337$3,211$80,283(vi)21C PAPR with loose hood or helmet and HEPAs$525$26.89$1,8701.337$2,499$62,487(vii)21C Air-purifying with HEPA and disposable respirators$12.53$7.00$3631.337$485$12,115(viii)23C air-purifying with full facepieceand combination cartridges approvedfor paints, lacquers and enamels (PLE)$192$15.71$9781.337$1,307$32,666(ix)23C PAPR with tight-fitting facepieceand combination cartridges approvedPLE$627$35.50$2,4021.337$3,211$80,283(x)23C PAPR with loose-fitting hood or helmet and combination cartridges forPLE$525$26.88$1,8691.337$2,499$62,471(xi)23C Air-purifying with combination cartridges for PLE, includingdisposable respirators$14.30$8.90$4591.337$614$15,348(xii)23C Air-purifying with full-facepieceand organic gas/vapor cartridges$192$10.47$7161.337$956$23,911(xiii)23C PAPR with tight-fitting facepieceand organic gas/vapor cartridges$826$41.15$2,8841.337$3,855$96,371(xiv)23C PAPR with a loose-fitting hood or helmet and organic gas/vaporcartridges$640$41.15$2,6971.337$3,605$90,136(xv)23C Air-purifying with organic gas/vapor cartridges, including disposablecartridges$10.83$8.94$4581.337$612$15,299Notes:1Annual average costs were inflated asdescribed inTable B-3.2“Respirator unit” costs include both the respirator and any required add-ons such as hoods and helmets. A “cartridge set” includes two cartridges and any filters or capsrequired. Assumes cartridge sets are replaced every five days(50 times during 250 exposure days) so that each worker requiresone respirator unit and 50 cartridge sets peryear.3Totals were estimated from unrounded unit costs and inflation factors, so results may differ from calculations using the rounded values shown in this table.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-15 May 12, 2010 

### Table C-12 shows how the average costs per NIOS H-type respirator were calculated, based on prices of respirators lis ted in a 1997 catalog. To calculate the cost of respirators that meet the NIOSH criteria, the prices of all units in the supplier cat alog (LSS, 1997) that meet each NIOSH criteria were averaged. Costs of additiona l items such as hoods, helmets, cartridges, and filter caps were also obtained. These are added to th e cost of the basic respirator unit if they are required under the SNUR regulation and if the unit does not already in clude the item. For example, §721.63(a)(5)(x) requires a hood or helmet. One model in the catalog that satisfies the requirement already includes a hood, while anot her unit requires that a separate hood be purchased. The cost of the hood was added to th e unit cost and the combined cost was then averaged with the model with integrated hood.

Many respirator specifications also require cartridges. The costs of the cartridges listed in LSS (1997) were averaged for the correspondi ng requirements. In some instances, certain cartridges or filters require a secondary cartridge to function properly (e.g. , some paint, lacquer and enamel filters required the organic vapors cartridges and filter retainer caps). These additional items were priced and added to the cost for the basic cartridge before averages were

taken.

Some cartridge prices were unavailable fr om LSS (1997). For instance, §721.63(a)(5)(ix) and (x) require a powered air-purifying respirator (PAPR) with a paint, lacquer and enamel cartridge. The only cartridges available for these models of respirators in LSS (1997) are HEPA cartridges. In these cases the costs of a paint, lacquer, and enamel cartr idge are assumed to be the same as for a HEPA cartridge.

The 1997 purchase costs of the varying types of respiratory protective equipment are

shown in Table C-12

.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-16 May 12, 2010 

### Table C-12 Respirator Prices and Average Costs in 1997, by NIOSH Type

40CFR 1997 Average Cost 2

§ 721.63

(a)(5) NIOSH Type Catalog

Item

Number Description 1 1997

Cost Respirator

Unit Cartrid g e Set
19C Type C Supplied-air with full facepiece $804

--
7A-24506 Allegro Economical Full- Face Airline Kits, p144 $758.95 (i)

7A-32366 311Survivair Supplied Air Respirator Kits, p144 $849.10 19C Type C Supplied-air with tight-fitting facepiece $80

-- 7A-24506 Allegro Economical Full- Face Airline Kits, p144 $758.95 (ii)

7A-32366 Survivair Supplied Air Respirator Kits, p144 $849.10
19C Type C Supplied-air with hood or helmet or tight-fitting facepiece $932

-- (iii) 7A-29363 Allegro Hood Systems, p144 $932.15

21C Air-purifying with full fa cepiece and high efficiency particulate filters (HEPAs) $181 $10

7A-9838 North Full-Face Respirator, p114 $210.10

7A-7122 North HEPA Cartridge, p115 $11.15

7A-12338 Willson Fu ll-Face Silicone Respirat or, p116 $215.10

7A-7526 Willson HEPA Cartridge, p117 $11.75

7A-10516 3M 7800 Fu ll-Facepiece Respirator , p118 $202.10

7A-11839 3M HEPA Cartridge, p118 $7.00

7A-33446 Pro-Tech Full-Face Respirator, p122 $106.45

7A-3070-1 Pro-Tech HEPA Cartridge, p123 $9.87

7A-3195 Willson 1600/1700 Se ries Full-Face Respirators, p124 $215.10

7A-3202 Willson HEPA Cartridge, p125 $12.50

7A-23959 AO7Star Fu ll-Face Respirator (Silicone), p126 $203.25

7A-9940 AO7Star HEPA Cartridge, p127 $9.44

7A-24158 MSA Advantage 1000 Full- Face Respirator, p1 34 $112.60 (iv)

7A-29946 MSA HEPA Cartridge, p134 $6.60
21C Powered air-purifying (PAPR) with ti ght fitting facepiece and HEPAs $627 $36

7A-13599 3M Face-Mounted PAPR System, p142 $720.00

7A-13601 3M HEPA Replacement Cartridge, p142 $36.50

7A-32505 RACAL Powerflow PAPR, p142 $534.90 (v)

7A-11936 RACAL Replacement Cartridge, p142 $34.50

21C PAPR with loose hood or helmet and HEPAs $525 $27

7A-32506 RACAL Air-Mate PAPR 12, p143 $411.05

7A-24505 RACAL HEPA Replacemen t Cartridge, p143 $24.65

7A-32477 RACAL Breathe-Easy HEPA Cartridges and Turbo Unit, p141 $548.50

7A-12838 RACAL HEPA Repl acement Cartridge $29.12 (vi)

7A-12840 RACAL Breathe-Easy 10 Tyvek Hood, p140 $91.30
21C Air-purifying with HEPA and disposable respirators $13 $7

7A-15255 3M 6000 Series Low-Maintenance Respirator, p135 $10.90

7A-12518P 3M Adaptor, p135 $1.63 (vii)

7A-11839 3M HEPA Cartridge, p135 $7.00Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-17 May 12, 2010 40CFR 1997 Average Cost 2

§ 721.63

(a)(5) NIOSH Type Catalog

Item

Number Description 1 1997

Cost Respirator

Unit Cartrid g e Set
23C air-purifying with full facepiece and combination cartridges approved for

p aints, lacquers and enamels (PLE) $192 $16

7A-9838 North Full-Face Respirator, p114 $210.10

7A-7117 North Organic Vapors Cartridge, p115 $10.50

7A-7125 North Paint Spray/Mists Prefilter, p115 $2.38

7A-7125-2 North Filter Covers, p115 $4.35

7A-12338 Willson Fu ll-Face Silicone Respirat or, p116 $215.10

7A-7527 Willson Organic Vapors Cartridge, p117 $10.25

7A-7531 Willson Dusts/Mists/Pe sticides/Paint Spray Prefilter, p117 $2.52

7A-7532 Willson Retainer Caps, p117 $4.00

7A-10516 3M 7800 Fu ll-Facepiece Respirator , p118 $202.10

7A-9279 3M Organic Vapors Cartridge, p119 $8.91

7A-9284 3M Paint Spray Prefilter, p119 $2.37

7A-9292 3M Retainer Caps, p119 $3.90

7A-33446 Pro-Tech Full-Face Respirator, p122 $106.45

7A-955-4 Pro-Tech Organic Vapors Cartridge, p123 $9.27

7A-9605 Pro-Tech Paint Sp ray Prefilter, p123 $1.95

7A-3195 Willson 1600/1700 Se ries Full-Face Respirators, p124 $215.10

7A-3197 Willson Organic Vapors Cartridge, p125 $11.22

7A-3203 Willson Pesticides/Paint Spray Prefilter, p125 $3.36

7A-3858 Willson Retainer Caps, p125 $4.27

7A-23959 AO7Star Fu ll-Face Respirator (Silicone), p126 $203.25

7A-9935 AO7Star Organic Vapors Cartridge, p127 $8.76

7A-10043 AO7Star Dusts/Mists/Paint Spray Prefilter, p127 $3.07 (viii)

7A-10044 AO7Star Retainer Clips, p 127 $3.20
23C PAPR with tight-fitting facepiece and comb ination cartridges approved PLE $627 $36

7A-13599 3M Face-Mounted PAPR System, p142 $720.00

--- Paint, Lacquer, Enamel Cartridge 3 $36.50

7A-32505 RACAL Powerflow PAPR, p142 $534.90 (ix)

--- Paint, Lacquer, Enamel Cartridge 3 $34.50
23C PAPR with loose-fitting hood or helmet an d combination cartridges for PLE $525 $27

7A-32506 RACAL Air-Mate PAPR 12, p143 $411.05

--- Paint, Lacquer, Enamel Cartridge 3 $24.65

7A-32477 RACAL Breathe-Easy HEPA Cartridges and Turbo Unit, p141 $548.50

7A-12840 RACAL Breathe-Easy 10 Tyvek Hood, p140 $91.30 (x)

--- Paint, Lacquer, Enamel Cartridge 3 $29.10 23C Air-purifying with combination cartridges for PLE, including disposable respirators $14 $9

7A-12711 Willson Freedom 2000 Series Organic Vapors Respirator, p136 $17.85

7A-7531 Willson Dusts/Mists/Paint Spray/Pesticides Prefilter, p136 $2.52 (xi)

7A-13509 Willson Retainer Caps, p136 $2.03Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-18 May 12, 2010 40CFR 1997 Average Cost 2

§ 721.63

(a)(5) NIOSH Type Catalog

Item

Number Description 1 1997

Cost Respirator

Unit Cartrid g e Set

7A-33826 Moldex 8000 Series Half-Mask Respirator, p139 $10.75

7A-22751 Moldex Organic Vapors Cartridge, p139 $8.03

7A-22753 Moldex Paint Spray/Pe sticides Prefilter, p139 $2.56

7A-22754 Moldex Retainer Caps, p139 $2.65
23C Air-purifying with fu ll-facepiece and organic gas/ vapor cartridges $192 $10

7A-9838 North Full-Face Respirator, p114 $210.10

7A-7117 North Organic Vapors Cartridge, p115 $10.50

7A-12338 Willson Fu ll-Face Silicone Respirat or, p116 $215.10

7A-7527 Willson Organic Vapors Cartridge, p117 $10.25

7A-10516 3M 7800 Fu ll-Facepiece Respirator , p118 $202.10

7A-9279 3M Organic Vapors Cartridge, p119 $8.91

7A-9292 3M Retainer Caps, p119 $3.90

7A-33446 Pro-Tech Full-Face Respirator, p122 $106.45

7A-955-4 Pro-Tech Organic Vapors Cartridge, p123 $9.27

7A-3195 Willson 1600/1700 Se ries Full-Face Respirators, p124 $215.10

7A-3197 Willson Organic Vapors Cartridge, p125 $11.22

7A-23959 AO7Star Fu ll-Face Respirator (Silicone), p126 $203.25 (xii)

7A-9935 AO7Star Organic Vapors Cartridge, p127 $8.76
23C PAPR with tight-fitting facepiece and or ganic gas/vapor cartridges $826 $41

7A-32473 RACAL Breathe-Easy Organic Vapors and Turbo Unit, p141 $548.50

7A-12844 RACAL Breathe-Easy 7 Full Face, p140 $277.90 (xiii)

7A-12830 RACAL Organic Vapors Replacement Cartridges, p141 $41.15

23C PAPR with a loose-fitting hood or helmet and organic gas /vapor cartridges $640 $41

7A-32473 RACAL Breathe-Easy Organic Vapors and Turbo Unit, p141 $548.50

7A-12840 RACAL Breathe-Easy 10 Tyvek Hood, p140 $91.30 (xiv)

7A-12830 RACAL Organic Vapors Replacement Cartridges, p141 $41.15

23C Air-purifying with organic gas/vapor cartridges, including disposable cartridges $11 $9

7A-15255 3M 6000 Series Low-Maintenance Respirator, p135 $10.90

7A-15256 3M Organic Vapors Cartridge, p135 $9.85

7A-33826 Moldex 8000 Series Half-Mask Respirator, p139 $10.75 (xv)

7A-22751 Moldex Organic Vapors Cartridge, p139 $8.03

Notes:

1 See Table C-10 for the cross-walk between respirator types in the SNUR and in this table .

2 Average costs presented in this table are rounded to the nearest dollar figure, so results may differ from calculations using the rounded values shown in this table.

3 Paint, lacquer and enamel (PLE) cartridges for PAPR s were not listed in the catalog. The costs for PLE cartridges are assumed to be the same as HEPA cartridges.

Source: LSS 1997; EPAB 1999Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-19 May 12, 2010 

### C.3 Recordkeeping

There are two main types of recordkeeping re quirements for the substances listed in the current SNURs: those for companies submitting a SNUN, and those for all companies that manufacture, import or process SNUR-regulated substances, regardless of whether they have

made a submission to EPA.

SNUN submitters

Companies submitting a SNUN must keep records under 40 CFR §721.40. Some EPA reports have assumed that SNUN recordkeeping hours would be 5 percent of SNUN submission hours, or about 5 to 6 hours. 25 

### Other EPA reports have estima ted that electronic submission of SNUNs is expected to reduce the recordkeeping burden to a pproximately 1 hour (EPA, 2009a, p. 16) For this report, the SNUN recordkeeping hours were included in the SNUN submission hours (see Appendix E) and the SNUN recordke eping cost was not separately estimated. 26



### All manufacturers, importers, and processors

Whether or not they submit a SNUN, firms that manufacture, import, or process the SNUR substance must keep records based on 40 CFR §721.125(a) throug h (k), to document compliance with SNUR conditions for avoiding a Significant New Use. (For firms producing under the R&D exemption, R&D recordkeeping w ould be needed. R&D recordkeeping costs were not estimated for this report.)

Recordkeeping requirements vary between PMN chemicals, reflecting differences in

SNUR restrictions. For all chemicals in the current SNURs, manufact urers, importers, and processors must keep record s on quantities supplied or purchased under 40 CFR §721.125(a), (b), and (c). For chemicals with water disc harge restrictions, companies must keep records concerning water discharge compliance, under §721.125(k). For chemicals with other use restrictions, or for those few chemicals w ith workplace protection or hazard communication restrictions, companies must keep records under other 40CFR §721.125 paragraphs, to document compliance.

All recordkeeping requirements essentially involve copying and filing relevant records, including those related to: manufacturing, impor ting, or processing volumes; shipment amounts and customer information; clothing impermeability determinations; the hazard communication

25 For example, OPPT’s Information Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules for Existing Chemicals (Renewal), October 11, 2005, estimates SNUN reco rdkeeping costs at 5.67 hours (EPA 2005, page 12).

26 SNUN submission costs estimated in Appendix E of this report were based on PMN submission costs from a 1994
report, Regulatory Impact Analysis of Amendments to Regu lations for TSC Section 5 Premanufacture Notifications (EPA, 1994). Page III-14 of the 1994 report refers to “the normal records kept with a PMN submission which are included in the estimates for submission costs.” Page III-12 identifies “maintaining a file of the submission” as part of the labor hours for the PMN reporting form. These statements imply that the 95 to 114 total hours for a PMN submission (page III-10 of RIB 1994) included recordkeeping hours.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-20 May 12, 2010 

### program including labels and MSDS copies; comp liance with other use restrictions; and/or compliance with disposal and release to water lim itations. Records must be maintained for five years from the date of their creation.

Costs for compliance with the recordkeeping requirements for substances subject to a SNUR are based on the approach in Economic Analysis of Final Significant New Use Rules: General Provisions for New Chemical Followup (EPA, 1989) which in turn was based on Recordkeeping Costs for a Generic SNUR , prepared for EPA in 1988 by Kearney/Centaur (Kearney, 1988a). These reports drew on recordkeeping costs es timated for the Comprehensive Assessment Information Rule, CAIR. Industry re cordkeeping costs for CAIR compliance were estimated in reports Kearney prepared for EPA, including Estimated Cost of the Final Comprehensive Assessment Information Rule , June 1, 1988 (Kearney, 1988b, pages 63 to 65).

This report uses the basic Kearney (1988a and 1988b) esti mates and assumptions to estimate recordkeeping costs for SNUR requirements. 27 

### Unlike Kearney (1988a), this report presents costs for each §721.125 recordkeeping require ment separately. This report also avoids minor rounding errors by cal culating from unrounded data. However, the underlying methodology is identical to the Kearney 1988a/RIB 1989 reports, resulting in identical costs per chemical except for differences due to inflat ion and rounding. The paragraphs that follow describe estimates and assumptions used from Kearney (1988a and 1988b).

Cost per page

Recordkeeping costs are based on cost per page . Kearney (1988a) assumes that the ratios of labor hours to page count for each labor categor y, file drawer space to page count, and cost of miscellaneous supplies such as folders and labels to page count, are the same as the per-page ratios estimated for EPA’s Comprehensive Assessment and Reporting Rule. The CAIR estimates are given in the 1988 report, Estimated Cost of the Final Comprehensive Assessment Information Rule , June 1, 1988, page 65 (Kearney, 1988b). Table C-13 summarizes estimates from Kearney 1988a and the CAIR report (Kearn ey, 1988b). It also shows the derivation of costs from these estimates, after in flation. The method is as follows:

• 

### Technical labor was estimated at 1 hour for 750 pages in the CAIR report (Kearney, 1988b, page 65), or .00133 hours per page. The analysis estimates a cost per hour and per page using fully lo aded labor rates from Table B-1

.

• 

### Clerical labor was estimated at 10 hours for 750 pages in the CAIR report (Kearney, 1988b, page 65), or .01333 hours per page. The analysis estimates a cost per hour and per page using fully lo aded labor rates from Table B-1

.

• 

### The photocopying cost from Kearney 1988a ( $0.05 per page) was inflated using an

inflation factor from Table B-3

.

27 This report follows the method in Economic Analysis of Expedited Significant New Use Rules for 65 Chemical Substances (EPA Docket OPPT-2003-0063) , (EPA, 2007b), which used the Kearney data to calculate the cost breakdown by recordkeeping requirement.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-21 May 12, 2010 • 

### File space for CAIR was estimated at 1⁄4 of a four-drawer file cabinet for 750 pages (Kearney, 1988b, page 65) or 0.000333 of a cabinet per page. A standard, four-drawer, full-suspension file cabinet was priced from a national office products supplier at $195 in 1997 (BT Office Products, 1997; Item #LGM-2 02401; EPA, 1998). This results in $0.065 per page cost for file space, before in flation ($195 × 0.25 file cabinet/750 pages). The cost per page was inflated using an inflation factor from Table B-3

.

• 

### Miscellaneous materials costs were estimated at $10.00 for 750 pages in the CAIR report (Kearney, 1988b, page 65), or $0.0133/page before inflation. This cost per page was inflated using an in flation factor from Table B-3

.

Table C-13 Recordkeeping Estimates from Kearney 1988a and 1988b

Kearney Estimates for CAIR Rule (1988b) Adjusted for inflation Per page cost - 2009$ Labor Costs

Hours CAIR Pages Hours Per Page Cost Per

Hour Cost Per Page

Technical 1 750 0.00133 $59.49 $0.0793

Clerical 10 750 0.01333 $28.31 $0.3774

Total Labor 0.01467 $0.4567

Kearney Estimates for CAIR Rule (1988a) Adjusted for inflation Per page cost - 2009$ Materials Costs

Estimate CAIR Pages Cost Per Page Inflation

Factor Cost Per Page

Photocopying $0.05 [1988 dollars] 1 $0.050 1.813 $0.0907

File Cabinet 1/4 of cabinet priced at $195 [1997 dollars] 750 $0.065 1.337 $0.0869

Misc. Materials $10 total [1988 dollars] 750 $0.013 1.813 $0.0242

Total Materials 0.1283 $0.2017

Total Cost per Page (Labor & Materials) $0.6585

Notes: Per-page labor hours and materials costs were originally estimated in Kearney 1988b for the CAIR rule. The CAIR per-page costs were then used to estimate SNUR recordkeeping per-page costs in Kearney 1988a. This clarifies the method by which the original CAIR per-page co sts and hours were calculated. It also adjusts costs for inflation using labor rates from Table B-1 and inflation factors from Table B-3

.



### Pages per chemical at one site

In order to estimate recordkeeping costs, th e analysis multiplies the costs per page for each recordkeeping element estimated in Table C-13 by the number of pages required for each SNUR recordkeeping requirement at 40 CFR §7 21.125 as estimated by Kearney (1998a). The Kearney data was used by EPA in its original expedited-SNUR economic analysis (EPA, 1989). For example, maintaining MSDS copies as required at §721.125(h) would require 5 pages. The following estimates from Kearney (1988a) are also used:Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-22 May 12, 2010 • 

### Manufacture and import volume, and sales and tr ansfer data require 485 pages of records per year. This reflects 40 invoices per m onth (see haz-comm Section C.1 above), 480 for

sales/transfer and 5 for manuf acturer/import (Kearney, 1988a, p.11).

• 

### Disposal compliance records, if required, co ver items such as wa ste production, shipping manifests, permits, and transfer receipts. The 600 disposal compliance pages assume 50 pages per month (Kearney, 1988a, p.11).

(This report uses slightly different terminology from EPA, 1989: “Protective clothing” instead of “protective gloves,” “haz-comm” in stead of “employee information and training.” Recordkeeping for “impermeability determination” was not separately costed out in EPA, 1989. This report assumes it is included under “protective clothing” recordkeeping.)

Cost per chemical

Table C-14 shows annual recordkeeping activities at one site for one SNUR chemical, by CFR requirement. If all recordkeeping requi rements at 40 CFR §721.125 applied to a single chemical, there would be costs for 2.3 hours of technical time, 23 hours of clerical time, 1,715 photocopies, approximately one-half of a four-d rawer file cabinet, and other miscellaneous materials such as folders. However, in reality, few if any chemicals will have all of the recordkeeping requirements listed in Table C-14 . Recordkeeping costs would be lower for chemicals with relatively few SN UR restrictions because fewer pages would be needed to document SNUR compliance.

Table C-14 does not include costs of recordkeepi ng resulting from a SNUN submission;

those costs were included in the SNUN submission cost.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 C-23 May 12, 2010 

### Table C-14 Annual Per-Chemical Costs of Recordkeeping Requirement [40 CFR 721.125]

40CFR §721.125 2 Requirement Pages 3 Labor and materials cost 1

(2009$) Hours

(a) Per Page (b) Per Chemical (c)=(a)*(b) Per Page (d) Per Chemical (e)=(a)*(d) (a)(b)(c) Volumes & sales/transfer data 485 $0.6585 $319 0.01467 7.11 (d)(e) Protective clothing [§721.63] and impermeability [§721.63(a)(3)] 20 $0.6585 $13.17 0.01467 0.29 (f) Haz-comm program [§721.72] 250 $0.6585 $165 0.01467 3.67 (g) Label copies [§721.72(b)] 5 $0.6585 $3.29 0.01467 0.07 (h) MSDS copies [§721.72(c)] 5 $0.6585 $3.29 0.01467 0.07 (i) Use limitations compliance [§721.80] 250 $0.6585 $165 0.01467 3.67 (j) Disposal compliance [§721.80] 600 $0.6585 $395 0.01467 8.80 (k) Release to water compliance [§721.90] 100 $0.6585 $65.85 0.01467 1.47

TOTAL 1,715 $0.6585 $1,129 0.01467 25.15

Notes:

1 This table multiplies cost per page estimates from Table C-13 by the number of pages estimated for each recordkeeping cost element. (This table does not include recordkeeping for SNUN submissions required by 40 CFR §721.40.) Total costs are calculated from unrounded values and may not equal the sum and/or product of

rounded values.

2 40 CFR 721.125(a) through (k) list recordkeeping that may be specified in the SNUR. The recordkeeping specified depends on which 40 CFR §721 provisions [in brackets] were used by the SNUR to define reportable New Uses (§721.63, §721.72, §721.80, an d/or §721.90). Few if any SNUR chemicals would require all of the recordkeeping costs listed above since few if any chemicals are subject to all of the requirements (a) through (k).

3 Pages count estimates for each SNUR requirement are from Kearney, 1988a.

### APPENDIX D

COSTS OF TESTINGEconomic Analysis of Expedited SNURs, Docket OPPT-2009-0922 D-1 May 12, 2010 

### APPENDIX D COSTS OF TESTING

EPA recognizes that TSCA Section 5 does not require developing any particular test data before submission of a Significant New Use Noti ce. Persons are required only to submit test data in their possession or control and to desc ribe any other data know n to or reasonably ascertainable by them. (Upon review of a SNUN , the Agency has the authority to require appropriate testing, but that is a cost of regulatory follow-up, not of the SNUN submission itself.) For informational purposes, the SNURs desc ribe tests recommended by EPA to provide

sufficient information to evaluate the chemical substance. However, as was explained in the

discussion of SNUNs earlier in this report, it appears that fi rms rarely elect to do these recommended tests to support a SNUN, and esp ecially not the higher-cost tests. For informational purposes, this appendix presents es timated costs for testing often recommended for chemicals that have been the subject of PMNs and are subject to Significant New Use Rules (SNURs).

D.1 Testing Guidelines

In the SNURs, EPA identifies a set of tests for each PMN chemical that can be used by firms making Significant New Use Notice or other submissions to EPA to characterize risks of

the chemical. The tests are recommended in th e SNUR, not mandatory. They are identified by guideline numbers which can be used to look up published test protocols. Table D-1 lists test guidelines cited in the current and recent SNUR rulemakings, and their associated costs, Table

D-2 presents certain assumptions used in the analysis, and Table D-3 presents Persistent Bioaccumulative Toxic (PBT) tiered testing requirem ents. The types of guidelines are described

below.

• 

### OPPTS Harmonized . Most SNUR tests are identif ied by their OPPTS number from

the series of OPPTS Harmonized Test Guidelines and OPPTS harmonized public drafts not yet promulgated as OPPTS guide lines. These guidelines blended testing guidance from OPPT (published in the Code of Federal Regulations), EPA's Office of Pesticide Programs, the Organization fo r Economic Cooperation and Development (OECD), and other sources. The harmonized guidelines fall into several categories, including the following:

Series 835--Fate, Transport and Transformation Test Guidelines Series 850--Ecological E ffects Test Guidelines

Series 870--Health Effects Test Guidelines

They are available electronically on EPA’ s website (EPA, 2006). Cross-references for health effects guidelines ar e listed at 63 FR 41847, August 5, 1998.E conomic Analysis of Expedited SNURs, Docket OPPT-2009-0922 D-2 May 12, 2010 • 

### CFR . SNUR tests may also come from the Code of Federal Regulations, identified for example as “40 CFR 799.9370” or just “ 799.9370.” In addition, in costing out test guidelines, this report sometimes uses cost s for a CFR guideline when costs have not been developed for the equivalent OPPT S harmonized guideline. 40 CFR parts 795 through 798 include pre-harmonization test gu idelines, typically updated before 1990. 40 CFR part 799 includes more recent TSCA test guidelines, based on harmonized test guidelines. (63 FR 41845, August 5, 1998).

• 

### OECD . A few SNUR tests are identified by their OECD number. The OECD guidelines may have OPPTS equivalents. For example, OECD 407 28-Day Oral Toxicity in Rats is essentia lly equivalent to OPPTS 870.3050.

• 

### PBT Category . For some chemicals, the SNUR cites tiered testing according to a testing strategy published in the Federal Register (FR), Category for Persistent, Bioaccumulative, and Toxic New Chemical Substances, November 4, 1999 (64 FR 60194), which in turn refers to a number of tests by OPPTS or OECD guideline

number.

• 

### ASTM, NTIS, and other sources . Test guidelines may also come from the American Society for Testing and Mate rials (for example, ASTM D2035-80 Modified Coagulation-flocculation Jar Te st of Water) (www.astm.org) or other sources. The guideline for a neurotoxicit y functional observational battery, NTIS PB 91-154617, is available from the National Technical Information Service (www.ntis.gov).Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922D-3May 12, 2010Table D-1 Cost Estimates for Test Guidelines Cited in SNURsGuidelineTestSpeciesRoute/MethodCost2009$Product properties830.6315FlammabilityNANA$7295830.7050 (796.1050/OECD101)Absorption in Aqueous Solution: ultraviolet/visiblespectraNANA$1,642830.7200 (OECD 102)Melting Point / Melting RangeNA8-test average$1,647830.7550 (OECD 107)Partition Coefficient (n-Octanol/Water)NAShake FlaskMethod$8,020830.7560 (796.1720)Partition Coefficient (n-Oct/Water)NAGenerator Column$4,062830.7570 (796.1570)Partition Coefficient (n-Oct/Water)NALiquidChromatography$2,954830.7840 (OECD 105)Water SolubilityNAFlask Method$7,023830.7860 (796.1860)Water Solubility: Column Generator MethodNAGenerator Column$21,101Karel Vershueren Handbook,odor and taste testOdor and taste test (in Handbook of EnvironmentalData on Organic Chemicals, by Karel Vershueren,4thEd,Vol. 1, Page 22)NANA*Fate, Transport, Transformation835.1110Activated Sludge Sorption IsothermNANA$12,121835.1220Sediment and Soil Adsorption/Desorption IsothermNANA$29,648835.2110Hydrolysis as a Function of pHNANA$58,251835.2130Hydrolysis as a Function of pH and TemperatureNANA*835.2210 (796.3700)Photolysis in Aqueous Solution in SunlightNANA$116,525835.3100 (796.3100)Aerobic Aquatic BiodegradationNANA$15,997835.3110ReadyBiodegradationNAAverage of sixmethods$6,056+835.3120Sealed-Vessel CO2 Production TestNANA$7,751835.3170Shake Flask Die-Away TestNANA$50,967835.3180Sediment/Water Microcosm BiodegradationNAFlow-through$133,269835.3200 (796.3360)Inherent Biodegradation: Modified Zahn-WellensNANA*835.3220Porous Pot TestNANA$50,049835.3400Anaerobic Biodegradabilityof Organic ChemicalsNANA$12,304Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922D-4May 12, 2010Guideline Test SpeciesRoute/MethodCost2009$835.5045 (OECD 302A)Inherent Biodegradability: Modified SCAS TestNANA$14,217835.5270 (795.7000)Sunlight Photolysis in Waters ContainingDissolved Humic Substances(Indirect PhotolysisScreening Test)NANA$24,577D2035-80 (ASTM D 2035-80)Standard Practice for Coagulation-Flocculation JarTest of WaterNANA$4,245OECD 303ASimulation Test - Aerobic Sewage Treatment, withmeasurement of loss of the parentNANA*OECD 307Aerobic and Anaerobic Transformation in SoilNAFlow-through$280,343OECD 307Aerobic and Anaerobic Transformation in SoilNABio-meter typeflasks$265,007OECD 308Anaerobic transformation in aquatic sedimentsystemsNANA*OECD 309Aerobic mineralisation in surface waterNANA*OECD 311 (835.3400)Anaerobic biodegradability of organic compoundsin digested sludgeNANA*OECD TG 310CO2in Sealed Vessels – Headspace TestNANA*Ecological Effects850.1000Special Considerations for Conducting AquaticLaboratory StudiesNANA*850.1010 (797.1300)Daphnid Acute ToxicityDaphnidFlow-through$14,981850.1010 (797.1300)Daphnid Acute ToxicityDaphnidStatic$14,783850.1075 (797.1400)Fish Acute ToxicityFathead MinnowFlow-through$20,645850.1075 (797.1400)Fish Acute ToxicityNAStatic$16,721850.1085Fish Acute Toxicity Test mitigated by humic acidFathead MinnowStatic$17,430850.1300Daphnid Chronic Toxicity TestDaphnidFlow-through$42,884850.1400Fish Early Life Stage ToxicityRainbow TroutFlow-through$68,428850.1400Fish Early Life Stage ToxicityFathead MinnowFlow-through$46,259850.1730Fish BCFFathead MinnowFlow-through$75,830850.1925Site-Specific Aquatic Microcosm TestNANA*850.1950Field testing for Aquatic Organisms3NANA*OECD 218(795.1350/850.1790)Chironomid Sediment ToxicityMidgeFlow-through$104,321Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922D-5May 12, 2010Guideline Test SpeciesRoute/MethodCost2009$850.5400Algal Toxicity, Tiers I and II4-speciesaverageNA$17,414Health Effects870.1100Acute Oral ToxicityRatsGavage$8,296870.1300AcuteInhalationToxicityRats4Inhalation$25,671870.310090-Day Oral ToxicityRatsGavage$152,212870.34651Subchronic Inhalation ToxicityRatsInhalation$420,750870.3250Subchronic Dermal Toxicity - 90 daysRatsDermal$161,568870.3465 (mod)Subchronic Inhalation Toxicity (w/ 60 dayrecovery group)RatsInhalation$244,360870.3465 (OECD 413)1Subchronic Inhalation Toxicity (90-dayexposure/180-day retention)RatsInhalation$426,936870.3700Prenatal Developmental Toxicity {2 species}RatsGavage$124,635870.3800Reproduction/Fertility Effects (2-GenerationReproduction)RatsGavage$657,928870.4200Carcinogenicity {2 species} (24 months)RatsGavage$990,274870.4200Carcinogenicity {2 species}RatsInhalation$1,249,662870.5100Bacterial reverse mutation testNADirect plate$13,644870.5265Salmonella typhimurium Reverse Mutation Assay(Ames Test)NAAverage of directplate and Azoreduction$12,963870.5395In Vivo Mammalian Bone Marrow CytogeneticsTests: Erythrocyte Micronucleus Assay (Averageof 1 and 3 day dosings)MiceGavage (Average of1 and 3 day)$21,983870.5395In Vivo Mammalian Bone Marrow CytogeneticsTests: Erythrocyte Micronucleus Assay (Averageof 1 and 3 day dosings)MiceIntravenous (Twotest average)$21,983870.5550Unscheduled DNA Synthesis in Mammalian Cellsin CultureRat HepatocytesNA$22,701870.6100Delayed Neurotoxicity of OrganophosphorusSubstances (Acute)HensGavage(Acute)$38,812870.6100Delayed Neurotoxicity of OrganophosphorusSubstances (Subchronic 28-day)HensGavage(Subchronic)$76,987Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922D-6May 12, 2010Guideline Test SpeciesRoute/MethodCost2009$870.6200Neurotoxicity Screening Battery (Acute)RatsGavage$121,285870.7800ImmunotoxicityRatsGavage$87,708ASTM D F739 -91 (ASTMD F739)2Standard Test Method for Resistance of ProtectiveClothing Materials to Permeation by Liquids orGases Under Conditions of Continuous ContactNAAverage (Gases andLiquids)$14,813OECD 404 (870.2500)Acute Dermal IrritationRabbitsDermal$5,905OECD 405 (870.2400)Acute Eye IrritationRabbitsEye$5,905OECD 407 (870.3050)Repeated dose 28-day oral toxicity study in rodentsRatsGavage (28 Days)$84,831+OECD 412Repeated Dose Inhalation Toxicity (28-Day Study)RatsInhalation (28Days)$129,015OECD 421 (870.3550)Reproduction/developmental toxicity screeningtestsRatsGavage$67,588OECD 422 (870.3650)Combined RepeatedDose Study withReproductive/Developmental Toxicity ScreenRatsGavage$137,964OECD 422 (mod)Combined RepeatedDose Study withReproductive/Developmental Toxicity Screen (90days w/ histopathology)RatsGavage$239,892OECD 425Acute Oral toxicity: Up-and-down ProcedureRatsGavage$5,967Notes:* Indicates this cost has not been calculated for this report.+Indicates that EPA, EPAB staffestimated this test costin fall of 2009 and it is more recent that the other EPA, OPPTS EPAB test cost estimates presented in the table, themajority of which wereestimated prior to 1990.1For some PMNs, recommended testing under guideline 870.3465 would involve an additional 3month recovery group, as well as other evaluation beyond the standardrequirements in the test guideline. These activities would raise testing cost substantially.2The recommended testing for some PMN chemicals may include a glove permeation testfollowing ASTM F739 and F1194-99 guidelines.ASTM F1194-99 is a standard guidefor documenting the results of chemical permeation tests (seewww.astm.org). The additional costs of following ASTM F1194-99 (average of gases and liquids) were notestimated for this report.3Costs for field testing will be site-specific, with a wide range of actual costs.A report from EPA's Office of Pesticide Programs estimated an average test cost of $600,000 forguideline 850.1950, for simulated or actual field testing for aquatic organisms (EPA, 2008a, Appendix C).4Performing the test on species other than rats may change the test costs. For example, testing on rabbits is likely to increase costs.5Test cost is from a Eurofins Product Safety Laboratory 2009 price schedule publishedon the company website athttp://www.productsafetylabs.com/media/645697/price%20schedule-2009%20revised.pdf . and isinflated using the inflation factorsderived in Table B-3Source:EPA OPPTS Economic and Policy Analysis Branch cost estimates. Many costs were estimated in the 1990s or earlier. All have been inflated (seeTable B-1andTableB-3for inflation index). Dollar costs include $3,971 or $9,644 for analytical method validation; where applicable (see text). Species and route or method may be specified in SNURsor may be unspecifiedbut assumed in this table for costing purposes.

### D.2 Test Costs by Guideline

Table D-1 gives dollar cost for each test, based on assumptions and adjustments

discussed below. This section describes the development of individual test costs.

EPA’s Office of Pollution Prevention a nd Toxics, Economic and Analysis Branch, regularly develops cost estimates of test gu idelines to support TSCA rule development. Estimates are based on assumptions about specie s, route of administration, study duration, and other aspects of methodology. Costs are calculated based on costs of labor, materials, and equipment needed to perform testing, with ove rhead and fee. Many of the test costs were developed in the 1990s. Test costs have been in flated using Employment Cost Index inflators from the Bureau of Labor Statistics (see Appendi x B). However, generally they have not been updated to reflect subsequent chan ges in laboratory technologies.

Testing laboratories perform analytical method validation to ensure that proper dose concentrations are used in toxicity studies (EPA , 2005a, p. 3-9). This analysis assumes that for health effects tests (e.g. 870 series guidelines), tests of up to 90 days in duration have method validation costs of $3,500, and longer-term tests have validation costs of $8,500 in 2004 dollars. Using the inflation rates found in Appendix B, validation costs are $3,924 and $9,531 in 2008 dollars. For simplicity, the method validation cost for ecological effects tests (e.g. 850 series guidelines) was assumed to be $3,924 for each test.

In cases where costs have not been estimated for the specified guideline, EPA uses the cost from an approximately e quivalent guideline (listed in Table D-1 and Table D-3 in parentheses). Many of these equivalents are listed in the Federal Register at 63 FR 41847, August 5, 1998. In some cases the test protocol itself states that it is essentially equivalent to another test upon which it was based. Sometimes judgment was needed to select the closest equivalent(s)

.

In some cases, EPA has not costed out the te st for the species, route, duration, and/or other method listed in the SNUR, or the SNUR sp ecifies a guideline but does not specify these details. In such cases, EPA has made the adju stments described below. The adjustments were

selected based on discussions with EPA scie ntists and on SNUR language, published test guidelines, assumptions underlying the cost estimate s in EPAB's test cost database, EPA review and Consent Order history for specific PMNs, or other sources.

Default Parameters

Costs for many of the guidelines have been estimated for different combinations of species, route, length of study and other aspects of methodology, but in some cases the SNUR may not specify all of these variables. Wher e this occurs, EPA has used certain default parameters, listed in Table D-2

.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 D-7 May 12, 2010

### Table D-2 Default Parameters fo r Species, Route, and Study Type

Variable Default

Species Mammals

Fish

Invertebrates Algae Rats
Fathead minnow 1
Daphnids [Four species -- see text]

Route/Method Mammalian

Fish

Invertebrates Gavage Flow-through Flow-through

Notes:

1 For guideline 850.1400 tests also in PBT tier tests, rainbow trout is the default species. (See PBT discussion below.)



### SNUR Testing Tiers

A SNUR may recommend tiered testing. In su ch cases, costs are lower if only the firsttier tests are performed, and higher if all tests listed for the chem ical are performed. Testing is “tiered” if later tests are contingent on the re sults of earlier tests, a nd/or if some tests are contingent on the firm reaching a certain chemical volume or time limit. Some tiers are explicit in the SNUR text; others result because the S NUR references the tiered PBT Category testing

described at 64 FR 60194.

Test Cost Assumptions and Comments

This section explains treatment of certain te sts listed in this or past SNUR rulemakings.

• 

### A SNUR may recommend algal acute toxic ity testing according to OPPTS Guideline 850.5400. This guideline has been previously costed by EPA for four separate algal species ( Navicula pelliculosa, Skeletonema costatum, Anabaena flos-aquae, and Selenastrum capricornutum ). If a SNUR does not specify the algal species to be used, the average costs of the four algal species tests are used.

• 

### For OPPTS test guideline 835.3100 (Aerobic Aquatic Biodegra dation), a SNUR may call for an additional analytical methodology to identify the isononyl phenol degradation product, which may be a substant ial add-on to the basic cost. Table D-1 gives costs for

835.3100 but not for the extended test.

• 

### A SNUR may recommend a “modified” vers ion of ASTM test guideline D2035-80 (Coagulation-Flocculation Jar Test of Water). Table D-1 gives costs for D2035-80 but not for the additional analytical methodology.

• 

### For test guideline OECD 422 (Combined Repeated Dose Oral Toxicity with Reproductive/ Developmental Toxicity Sc reening), a SNUR may recommend extended histopathology. Although the OECD 422 prot ocol does include hi stopathology, it is possible that extending the hist opathology would increase the cost beyond that shown in

Table D-1

.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 D-8 May 12, 2010• 

### A SNUR may recommend two variations of test guideline OECD 218 (Chironomid Sediment Toxicity), one usi ng the acute portion of the sedi ment and the other using the chronic portion. Costs were not determined fo r these two variants. The cost of the test performed on midge under flow th rough conditions was used for both.

• 

### A SNUR may recommend “a fish acute toxici ty test, freshwater and marine (OPPTS 850.1075 test guideline)”. “Freshwater and marine” refers to the name of the test, not the number of species required by EPA. The cost estimates assume only one species is used.

Persistent Bioaccumulative Toxic (PBT) tiered testing

A SNUR may cite tiered testing for Pe rsistent Bioaccumulative Toxic chemical substances (PBTs) according to the testing strategy in EPA’s New Chemicals Program PBT Category document, published in the Federal Register notice, Category for Persistent, Bioaccumulative, and Toxic New Chemical Substances, November 4, 1999, at 64 FR 60194.

In 64 FR 60194, there are three ti ers of testing. The results of Tier 1 determine whether Tier 2 testing is needed and the results of Tier 2 testing determine whether Tier 3 testing is

needed. Table D-3 lists the tests in the PB T category document. These tests are also listed in

Table D-1

.

To obtain a cost estimate for SNURs that ci te PBT Category testing (64 FR 60194), costs

of individual tests from 64 FR 60194 would have to be added up as appropriate, depending on the specific SNUR language. The test list w ould also need to be adjusted to avoid double counting tests listed in the SNUR both explicitly by guideline nu mber, and implicitly due to their inclusion in PBT Category tiers.

Other assumptions related to PB T testing are described below:

• 

### The PBT category tests at 64 FR 60194 specify rainbow trout as the species for the chronic fish toxicity test, 850.1400. For S NURs that recommend PBT Category testing, 850.1400 costs would be based on using rai nbow trout. If 850.1400 is recommended without PBT testing, costs would be based on using fathead minnows.

• 

### For PBT Tier 1 ready biodegradability tests, firms may either choose among six methods in test guideline 835.3110 or follow test guideline 835.3120. The cost of 835.3110 is calculated as the average cost of its six possible methods. Th e cost estimates assume an equal chance of using either 835.3110 or 835.3120.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 D-9 May 12, 2010

### Table D-3 Persistent Bioaccumulative Toxic (PBT) Tiered Testing Requirements

PBT

Tier Guideline Test Cost 2009$

1 OPPTS 830.7560*

-orOPPTS 830.7570* Partition Coefficient (n-Oct/Water), Generator Column method

-orPartition Coefficient (n-Oct/Water), Liquid Chromatography method Average $4,062

$2,954 $3,508

1 OPPTS 835.2110 Hydrolysis as a Function of pH $58,251

1 OPPTS 835.3110

-orOPPTS 835.3120 Ready Biodegradability (choose one of 6 methods; cost is average of the 6)

-or- [Ready biodegradability] Sealed-vessel CO 2 Production Test Average $6,056

$7,751 $6,903

2 OPPTS 835.3170 Shake-flask Die-away Test [measures biodegradability] $50,976

2 OPPTS 850.1730 Fish Bioconcentration $75,830

3 OPPTS 835.3180 Sediment/Water Microcosm Biodegradation $133,269

3 40CFR 797.1330

or 850.1300** Daphnid Chronic Toxicity Test $42,884

3 40CFR 797.1600

or 850.1400** Fish Early Life Stage Toxicity (in rainbow trout) $68,428

3 OECD 422 Combined Repeated Dose Oral Toxicity with Reproductive/ Developmental Toxicity Screening (in rats) $137,964

Total cost, all tiers (assuming all tests a re conducted) $578,004

Source: 64 FR 60194, Category for Persistent, Bioaccumulati ve, and Toxic New Chemical Substances , November 4, 1999, at http://www.epa.gov/EPA-TOX/1999/November/Day-04/t28888.htm . Tests costs are from Table D-1

.

*The PBT FR notice cites 830.7560 and 830.7570. This ta ble used costs for similar tests 796.1720 and 796.1570, respectively. Tests 830.7550 (Partition Coefficient using Shake Flask method) and “the new ‘slow-stir’ method currently under development by the OECD” are also mentioned as options for determining the Oct/Water partition coefficient, in the PBT FR notice Response to Comments but not in the main Testing Strategy discussion.

** PBT FR notice cites both tests as equivalents. This table uses costs for 850.1300 and 850.1400 since they were costed out more recently by EPA.

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 D-10 May 12, 2010

### D.3 Testing Costs by Chemical

Test costs attributable to a SNUN are likely to be much lower than the costs that would be implied by adding up costs of all of the testi ng recommended in the SNUR for that chemical, and usually are zero. 28 

### See the main text of this report for a discussion of testing.

28 A prior SNUR economic analysis calculated chemical -specific test costs (EPA , 2007b, Table D-4). The chemical-specific table was drop ped from a later SNUR economic analysis (EPA, 2007c).

Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 D-11 May 12, 2010

### APPENDIX E

COSTS FOR SNUN AND OTHER SUBMISSIONSEconomic Analysis of Expedited SNURs, Docket OPPT-2009-0922 E-1 May 12, 2010 

### APPENDIX E COSTS FOR SNUN, AND OTHER SUBMISSIONS

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

used for both. The PMN submission costs came from EPA's 1994 Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications, which relied on industry estimates of the effort needed to collect and compile all data required for a PMN submission, prepare the form, submit the form and data to EPA, and maintain a file of the submission (EPA, 1994, Table III-2 and pages III-11, -12, and -13). The 1994 estimates we re based on a survey conducted by the Chemical Manufacturers Association (CMA, 1991), which becam e the American Chemistry Council. The burden associated with PMN submission and preparation has b een adjusted to reflect burden reductions resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that requires the electronic submission of all

TSCA section 5 notices. 29 

### Electronic submission of SNUN forms is expected to remove all clerical burden associated with preparing a SNUN (EPA, 2009a , p.7). In addition electronic submission is expected reduce all recordkeeping burden associated with SNUN submissions by fifty percent. Because, the recordkeeping burden for PMNs was not estimated separately, for the purposes of this report we assume this burden reduction is captured in the removal of all clerical burden. 30



### In the 1994 EPA report, the average effort requi red to prepare and submit a PMN was 95 to 114

hours. This burden is reduced to 83 to 100 hours after accounting for the ePMN savings (EPA, 2009a). This included recordkeeping for the submission, but th e recordkeeping cost was not broken out. For this analysis, the costs of a preparing a SNUN were deri ved using the averages of the hours for each type of labor from the 1994 report, after adjusting for the ePMN savings. The method of calculating hourly loaded labor costs is described in Appendix B

As shown in Table E-1 , the cost of submitting a request to m odify or revoke a SNUR is the same as the cost for an equivalency determination. Th e cost of submitting a SNUN is $2,500 higher due to

EPA's notification user fee.

29 Prior to this report, Economic Analysis of Expedited Significant New Use Rules for 2 5 Chemical Substances: EPA

Docket OPPT-2009-092 2, all burdens were based upon 1994 paper submission estimates. This is the first report to consider the burden reductions resulting from electronic submission of SNUN forms.

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

estimates a 0.5 hour clerical and a 0.5 hour technical burd en associated with recordkeeping in addition to the burden estimates from the 1994 RIA, which include the burden for recordkeeping (EPA, 1994, p. III-14). These burden

estimates are based on the recordk eeping burden for polyme r exceptions and not the recordkeeping burden

associated with PMN submissions. Ther efore, for this analysis we assume that any reduction in recordkeeping burden is captured in the reduction of th e clerical burden, and we do not consid er the one hour r ecordkeeping burden from the ePMN EA to avoid double counting.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 E-2 May 12, 2010 

### Table E-1 Burden for SNUN, Request to Mo dify SNUR, or Equivalency Determination

Total Labor Cost (loaded wage X hours)

Labor Category Hours Range Average

Hours Loaded Wage

Rate 1 (2009$) Request to Modify

SNUR (Option 2) SNUN (Option 3) Equivalency Determination (Option 4)

Clerical 2 0 0 $28.31 $0 $0 $0

Technical 3 67 - 80 73.5 $59.49 $4,373 $4,373 $4,373

Managerial 3 16 - 20 18 $68.24 $1,228 $1,228 $1,228

Subtotal 83 - 100 92 $5,601 $5,601 $5,601
User fees (SNUN only) $0 $2,500 $0

TOTAL $5,601 $8,101 $5,601

Notes:

1 Loaded wages include fringe benefits and ov erhead. See Appendix B of this report for derivation. Wage rates presented in this table are rounded values; however, unr ounded values are used to calc ulate total labor costs. For this reason, total labor costs may not equal the product of rounded values.

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

Final Rule (EPA, 2009a, page 7)

3 Hours range for each technical and ma nagerial labor is from the PMN Am endments RIA (EPA, 1994, Table III-2)



### In addition to submission costs, there may be testing costs if the submitter believes performing the tests will help its submission. EPA believes such testing costs are ze ro for most SNUNs, as explained in the discussion of SNUNs in the main text of this report.

The Agency may also take additional regu latory actions after submission of a SNUN, such as a TSCA Section 5(e) Consent Order. The subsequent regulatory action would involve a limited assessment of benefits and costs comparable to such assessments for regulation following

PMN review. Follow on restrictions could invo lve worker protection, hazard communication, or testing triggered by reaching a specified produc tion volume, among other possibilities. These costs are discussed in Appendix C (worker pr otection, hazard communication) and Appendix D (testing). Other possible rest rictions have not been cost ed out for this analysis.

### APPENDIX F

AGENCY COSTSEconomic Analysis of Expedited SNURs, Docket OPPT-2009-0922 F-1 May 12, 2010 

### APPENDIX F AGENCY COSTS

EPA submission review costs are presented in Table F-1. Costs to review and process industry submissions – SNUNs, requests to m odify a SNUR, and requests for equivalency

determination – are assumed to be si milar to EPA costs to review PMNs. 31



### The list of review steps, estimates of staff-year full-time equivalents (FTEs), estimates of extramural costs, and the percent of chemicals requir ing a particular review st ep are derived from the costs for processing PMN submissions in Table VII-1 of a 1994 EPA report, Regulatory Impact Analysis of Amendments to Regulations fo r TSCA Section 5 Premanufacture Notifications (EPA, 1994). The Agency burden associated with processi ng a SNUN has been adjusted to reflect burden reductions resulting from the 2009 final PMN Electro nic Reporting (ePMN) Ru le that requires the

electronic submission of a ll TSCA section 5 notices. 32 

### The ePMN rule affects SNUN submissions and requests for equivalency determination, but not requests to modify or revoke a SNUR. However, for simplicity, this analysis continues to assume that Agency per-submission costs are the same for all three types of submissions. Electronic submi ssion of SNUN forms is expected to reduce Agency burden by 16.5 percent (EPA, 2009a, p.28).

The GS levels used for Agency staff reflect the judgment of Agency staff familiar with the PMN/SNUN review process. The salary of a Fu ll Time Equivalent EPA staff was calculated using GS-13 Step 5 salary data (OPM, 2009). The original PMN cost estimates were for GS 12 and were presented as low and high estimates, based on the most junior (Step 1) and th e most senior (Step 10) GS-12 pay rates, respectively. However, this an alysis uses the higher GS-13 staff level and, for simplicity, a single intermediate pay rate (Step 5) within that GS le vel. A loading factor of 1.6 was applied to the salary to reflect fringe benefits and overhead (EPA, 1992). The loaded salary

calculations are descri bed in Appendix B.

For each review step, the “EPA staff” cost is calculated by multiplying the number of FTEs (in the first column) by the fully loaded average sa lary. This shows EPA staff cost for chemicals requiring the selected review step.

The Extramural Cost column shows costs for co ntractor support and ot her outside purchases for chemicals requiring the selected review step, inflated from 1993 prices, as explained in Appendix

B

. The Percent of Cases is a weigh ting factor applied to reflect th e fact that not all chemicals require each review step. For example, in the PMN process, all chemicals require Administrative

31 For an overview of the PMN review process, see the Chemistry Assistance Manual for Premanufacture Notification Submitters, EPA, 1997.

32 Prior to this report, Economic Analysis of Expedited Significant New Use Rules for 2 5 Chemical Substances: EPA

Docket OPPT-2009-092 2, all burdens were based upon 1994 paper submission estimates. This is the first report to consider the burden reductions resulting from electronic submission of SNUN forms and requests for equivalency

determination.E conomic Analysis of Expedited SNURs, Docket OPPT-2009-0922 F-2 May 12, 2010 

### Prescreening, but not all chemical s require the intensive scrutiny of “Standard Review.” The three types of submissions resulting from a SNUR may ha ve weighting factors that differ from each other and from the weighting factors for PMNs. Change s in weighting factors c ould cause actual review costs to be higher or lower than calculated here. For example, some SNUNs require little review because they are determined to be “invalid” – i.e. not required in the first place. However, often a SNUN may take more Agency time than a typical PMN because of factors such as the need to retrieve old PMN records from archives, and the likelihood that more data requiring EPA review is

submitted with a SNUN than would be submitted on average with a PMN. Resources were not available to update the review hour s to reflect the current review process or to tailor the cost estimates to SNUNs. Therefore, for this anal ysis, the review steps and weighting factors are

assumed to be the same as those derived in 1994 for PMNs.

The Weighted Cost column is calculated by multiplying the Unweighted Costs (EPA staff cost plus extramural costs) by the percentage of ca ses requiring this review step. Weighted costs are then multiplied by the burden reduction of 16.5 pe rcent to account for burden savings generated

electronic submission. This calc ulation yields total Agency co sts for submission review and processing shown in Table F-1.Economic Analysis of Expedited SNURs, Docket OPPT-2009-0922 F-3May 12, 2010Table F-1 Agency Costs for SNUN and Other Submission Review and ProcessingEPA staff (FTE) CostExtramural Cost2FTEfractionCost perFTE1FTE Total($2007)1993dollars2007dollarsUnweightedCostPct. ofCasesWeightedCost3ePMNBurdenReduction4Weighted Costwith ePMNBurden ReductionReview Steps(a)(b)(c)=(a)*(b)(d)(e)(f)=(c)+(e)(g)(h)=(f)*(g)(i)(j)=(h)*(1-(i))Pre-notice consultation0.0024$157,629$378$4.00$6.65$38541%$1580.165$132Administrative prescreen/notice receipt/user fee0.0024$157,629$378$92.00$152.97$531100%$5310.165$444CRSS (Chemical Review andSearch Strategy)0.0025$157,629$394$268.00$445.60$840100%$8400.165$701SAT (Structure Activity Team)0.0006$157,629$95$14.00$23.28$118100%$1180.165$98Engineering/Exposure0.0015$157,629$236$56.00$93.11$330100%$3300.165$275Exposure/Fate0.0008$157,629$126$0.00$0.00$126100%$1260.165$105Focus0.0009$157,629$142$23.00$38.24$180100%$1800.165$150Standard Review Functions0.0219$157,629$3,452$511.00$849.63$4,30229%$1,2470.165$1,042Division Directors Meeting0.0129$157,629$2,033$113.00$187.88$2,22115%$3330.165$278OrderDevelopment/NegotiationReview0.0171$157,629$2,695$22.00$36.58$2,7323%$820.165$68Post Order Data Review0.0886$157,629$13,966$0.00$0.00$13,9663%$4190.165$350Order Modification0.2167$157,629$34,158$0.00$0.00$34,1583%$1,0250.165$856New Chemical SNURDevelopment0.0277$157,629$4,366$85.00$141.33$4,5087%$3160.165$263Notices of Commencement0.0012$157,629$189$40.00$66.51$25631%$790.165$66FOIA (Freedom of InformationAct) Requests0.0333$157,629$5,249$287.00$477.19$5,7261%$570.165$48CBI (Confidential BusinessInformation) Substantiation0.0004$157,629$63$3.00$4.99$68100%$680.165$57TOTAL$5,9090.165$4,934Notes:1GS-13 Step 5 salaries loaded with benefits and overhead. SeeTable B-1derivation.2Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated from 1993 prices as described in Appendix B.3Weighted costs were calculated using unrounded unit cost estimates, soresults may differ from calculations using the rounded values shown in this table.4Electronic submission is expected togenerate a cost savings of 16.5% to the Agency (EPA 2009a, 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.

### APPENDIX G

REFERENCESEconomic Analysis of Expedited SNURs, Docket OPPT-2008-0922 G-1 May 12, 2010 

### APPENDIX G REFERENCES

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