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Supporting Statement for a Request for OMB Review under

The Paperwork Reduction Act

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Title: Partial Update of the TSCA Section 8(b) Inventory Data Base, 

Production and Site Reports

EPA ICR No.: 1884.07 OMB Control No.: 2070-0162

1(b) Short Characterization

This document provides the estimated burden hours and costs associated with the 

information collection activities of the Chemical Data Reporting (CDR) program, previously 

known as the Inventory Update Reporting (IUR) program, under the Toxic Substances Control 

Act (TSCA). Under TSCA section 8(a) (15 USC 2607), the Environmental Protection Agency

(EPA) is authorized to collect certain information on chemical substances manufactured or 

processed in the United States. In addition, under TSCA section 8(b), the Agency is required to 

compile and keep current, via periodic inquiry, the TSCA Inventory of Chemical Substances 

(TSCA Inventory). The TSCA Inventory is a listing of chemical substances manufactured, 

imported, and processed for commercial purposes in the United States. The Office of Pollution 

Prevention and Toxics (OPPT) has used the CDR to update the basic chemical substance 

production information for selected larger volume chemical substances on the TSCA Inventory

seven times, beginning in 1986, and to collect additional information relating to the manufacture, 

processing, and use of those chemical substances, beginning in 2006. 

Prior to the 2012 collection, EPA implemented various amendments1to the IUR in order 

to clarify the reporting requirements, improve the quality and utility of the data submitted, better 

match data collected with the Agency’s overall information needs, and where possible, reduce 

the paperwork burden on both regulated entities and EPA. Manufacturers (including importers) 

are required to use e-CDRweb (the Agency-provided reporting tool) to submit a completed Form 

U (EPA Form 7740-8; see Attachment 3) electronically via the Internet. (See 

epa.gov/iur/pubs/guidance/aboutsub.html for information on the use of e-CDRweb.) The 2016

CDR includes manufacturing, processing, and use exposure-related data elements, including the 

volume of the chemical substance used on the reporting site; the volume of the chemical 

substance directly exported; and whether the chemical substance is being recycled, 

remanufactured, reprocessed or reused. Amendments that are implemented for the first time 

during the 2016 CDR include production volumes for each year since the last principal reporting 

year; modifications to reporting thresholds, including thresholds for processing and use; and 

 

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The final rule titled “TSCA Inventory Update Chemical Data Reporting Modifications.” was published on 

August 16, 2011. See 76 FR 158.

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INFORM is a nonprofit environmental research organization.
 

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reduction of the 25,000 lb reporting threshold to 2,500 lb for certain chemical substances that are 

the subject to particular TSCA rules and/or orders.

OPPT will use the CDR data in its chemical substance risk-management efforts. 

Individual sites manufacturing (including importing) chemical substances will submit the 

required information. The information will be stored electronically for reference by EPA staff 

and others. Within the constraints of confidentiality claims, the information will be made public 

through the Agency’s CDR website (epa.gov/cdr). Further discussion of how the information is 

used, stored, and collected is included in this document.

The collection is expected to involve an average of approximately 4,289 respondents at 

an annual cost of $41 million. The details of the paperwork burden and cost estimates are 

discussed in this document.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Under TSCA, EPA is required to identify, assess, and control risks of injury to human 

health and the environment posed by commercial chemicals. Under TSCA section 8(b), EPA is 

required to compile and keep current a complete list of chemical substances manufactured or 

processed in the United States. TSCA section 8(a) authorizes the Administrator to promulgate 

rules to provide for the maintenance and collection of records from manufacturers, importers, 

and processors of commercial chemical substances. Sections 8(a)(1) and (2) of TSCA also 

authorize the Agency to collect information on the chemical manufacturing and importing 

industry. EPA possesses broad discretion in determining the information to be reported under 

TSCA section 8(a). The CDR rule was codified at 40 CFR 711. Previously known as the IUR 

rule and codified at 40 CFR 710, EPA changed the name and certain reporting requirements 

through the IUR Modifications; Chemical Data Reporting final rule published August 16, 2011, 

76 FR 158. Copies of the relevant sections of TSCA and of the Code of Federal Regulations 

(CFR) are attached (see Attachments 1 and 2).

Table 1 contains examples of the type of information TSCA authorizes EPA to collect, 

although it is not all currently being collected. EPA possesses broad discretion in determining 

the information to be reported under TSCA section 8(a).
 

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Table 1. Examples of Chemical-specific Information EPA is Authorized to Collect 

Under Section 8(a) of the Toxic Substances Control Act

1. Common or trade name, chemical identity, and molecular structure of each chemical substance or mixture 

for which reports are required.

2. Categories or proposed categories of use for each substance or mixture reported.

3. The total amount of each substance and mixture manufactured or processed and each of its categories of 

use; reasonable estimates of the total amount to be manufactured or processed and each of its categories 

of use.

4. A description of the byproducts resulting from the manufacture, processing, use, or disposal of each such 

substance or mixture.

5. All existing data concerning the environmental and health effects of such substances or mixtures.

6. The number of individuals exposed, and reasonable estimates of the number who will be exposed, to such 

substances or mixtures in their places of employment and the duration of such exposure.

7. The manner or method of disposal, and in any subsequent report on such substance or mixture, any 

change in the manner or method.

The CDR provides basic exposure-related manufacturing, processing and use information 

used by EPA and others in a wide range of Agency activities. Because exposure is a key

component of risk, the CDR exposure-related information will allow OPPT to screen chemical

substances based on the potential for risk in order to protect human health and the environment, 

as required by TSCA. The exposure-related data on manufacturing, processing, and use will 

potentially allow the Agency and others to avoid more burdensome regulatory requirements. 

These enhanced data will allow EPA to conduct a more effective and efficient screening level 

review of chemical substances to identify candidates for further evaluation. 

2(b) Practical Utility/Users of the Data

The CDR information collection is the only mechanism through which EPA can collect 

basic information on commercial chemical substances listed on the TSCA Inventory, including 

production volume and other manufacturing (including importing), processing, and use 

exposure-related data. This information collection is necessary because these data are not 

otherwise available. Examples of how EPA will use the information it is collecting include:

(1) U.S. Parent company identification information: These data are collected to identify

the parent company responsible for the data. EPA will require reporting of company 

identification information associated with the location of the company, and will clarify

that the company information is to be for the U.S. parent company associated with the 

reporting plant site. These data will help ensure the company information is consistently

provided. 

(2) Plant site identification information: Collected to identify the physical site where the 

manufacturing and import takes place, these data can assist EPA in estimating human and 

environmental exposure and to identify specific plant site operators in order to be able to 
 

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communicate with them. As such, this information is sought for purposes related to 

regulatory activities under TSCA sections 4, 6 and 8.

(3) Chemical identification information: This information is necessary for EPA to 

properly identify the chemical.

(4) Manufacturing-related information for each chemical, including whether the chemical 

is manufactured or imported, its reporting of production volumes for each of the years 

since the last principal reporting year, the production volume of a manufactured 

(including imported) chemical substance used at the reporting site, the production volume 

directly exported and not domestically processed or used, the number of workers 

reasonably likely to be exposed to the chemical, its maximum concentration, and its 

physical form(s) and related percent production volume, and whether a manufactured 

(including imported) chemical substance, such as a byproduct, is being recycled, 

remanufactured, reprocessed, or reused: These data are used to determine exposure 

potential based on manufacturing scenarios.

(5) Industrial processing and use data, including types of industrial use and associated 

industrial sector (IS) codes, industrial function, estimated number of sites, estimated 

associated percent production volume, and estimated numbers of workers reasonably 

likely to be exposed: These data are used to determine exposure potential based on 

industrial processing and use, including related environmental releases. 

(6) Commercial and consumer end-use exposure data, including categories of products, 

the maximum concentration in each category, an indication of consumer or commercial 

use, the number of commercial workers and whether the chemical is used in products 

intended for children, and the percentage production volume associated with the use: 

These data will be used to determine exposure potential based on consumer or 

commercial populations.

These data will also be used in other ways, such as in chemical substance exposure and 

risk screening, testing and/or priority setting, and exposure estimation required by the 

Interagency Testing Committee (ITC) under TSCA section 4; for EPA monitoring activities of 

newly manufactured substances that have completed PMN review under TSCA section 5(a); to 

support the development of TSCA regulations under section 6; and to measure potential human 

and environmental exposure under TSCA section 8(e). Each data element corresponds to a data 

point necessary for basic risk-screening.

Information secured through the CDR collections is increasingly used by a wide variety 

of governmental and non-governmental users. Consistent with Congress’s intent that TSCA data 

be used to facilitate any government public health and environment efforts, CDR data have been 

used by EPA’s Office of Water, Office of Solid Waste and Emergency Response, and Office of 

Air and Radiation to identify and characterize particular chemical substances. Non-confidential 

CDR data are incorporated into a number of databases and products maintained by organizations 
 

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including Right-To-Know-Net and INFORM2. CDR data were used to identify chemicals of 

particular concern for the National Institutes of Health. Non-confidential CDR data were also 

released to selected states to help them identify facilities manufacturing suspected endocrine 

disrupters. 

Under TSCA, EPA has an obligation to protect human health and the environment from 

unreasonable risks associated with chemicals under its jurisdiction. In order to evaluate potential 

chemical risks, EPA has determined that a portion of the chemicals on the TSCA Inventory

currently warrant the continued collection of manufacturing information, and processing and use 

information. Data reported under the CDR will enhance the capabilities of the Agency and other 

Federal agencies to ensure risk management actions are taken on chemical substances posing the 

most concern. More in-depth reporting of the processing and use data, more careful

consideration of the need for confidentiality claims, and adjustments to the specific data elements

will better support a robust risk assessment and management program. By enhancing the data 

supplied to Agency risk-screening programs, EPA expects to more effectively and expeditiously

identify and address potential risks posed by chemical substances and provide improved access 

and information to the public.

EPA will also use the information submitted through the 2016 collection to update the 

Agency’s comprehensive chemical manufacturing, exposure, and use database, maintained as 

part of the Manage Toxic Substances (MTS) system. CDR data prior to the 2006 collection are 

maintained in a series of databases known as the Chemical Update System (CUS). The MTS 

CDR data, combined with CUS and the Chemicals in Commerce Information System (CICIS)

database, serves as a primary source of information about the chemical industry for EPA, as well 

as other Federal Agencies. The MTS CDR data provide information about the chemical 

substances used, where they are produced, how much is produced or imported, and how they are 

processed and used. The chemical industry is dynamic, as demonstrated by the approximately 30 

percent change in chemical substances reported from one CDR submission period to the next; 

therefore continual updating of the database is essential.

Data Uses

Data generated by the CDR are used in a wide variety of programs fundamental to 

fulfilling the Agency’s TSCA statutory mandate. EPA’s primary use of these data is to identify

priority TSCA chemicals for more detailed information gathering, risk assessment, and risk 

management, and to develop targeted programs to protect human health and the environment. 

Screening chemical risks generally requires a combination of both hazard and exposure 

information. The CDR manufacturing, processing, and use exposure-related data, compiled into 

a searchable database format, enable EPA and others to more readily screen chemicals for 

potential exposure and risk. These reviews allow EPA and others to better prioritize chemicals 

to identify those warranting more detailed assessments, and to reprioritize chemicals of lower 

concern for review. Current and potential uses of these data by EPA and others are discussed 

below. Note that these examples are illustrative, not exhaustive. Programs using the CDR data 

range from the more traditional existing chemicals risk screening efforts, such as the Existing 

 

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INFORM is a nonprofit environmental research organization.
 

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Chemicals Action Plans to voluntary programs, such as Design for the Environment (DfE), to 

individual requests for analysis of chemicals not specifically associated with a particular 

program. The Agency anticipates that, as was true even for the basic production data reported 

under previous collections, new uses of current CDR data by EPA and by others will continually

emerge and cannot be predicted at this time.

The New Chemicals Program’s PMN review process provides an excellent example of 

how CDR data can assist EPA in protecting human health and the natural environment. EPA 

uses exposure-related data from PMNs to generate screening-level risk assessments for 

regulatory decision making under TSCA section 5. Using this information in combination with 

technical references and other research, EPA is able to estimate the number of manufacturers 

who may use a new substance. EPA also is able to estimate releases of the new substance from 

processing and from product manufacturing, resulting in estimated environmental concentrations 

of the new substance due to its release and estimated general population exposures to a new 

substance. EPA also uses the information on processing and use in combination with data and 

modeling to estimate the numbers of workers and consumers who may be exposed to a new 

substance, and their estimated exposures to a new substance. Based on the estimated hazards of 

a new substance, it is determined whether the exposures to the new substance estimated for 

potentially-exposed workers, general population, consumers, and aquatic species fall below 

levels of concern. A similar process for existing chemicals is now possible with the CDR data.

Current Uses of the 2012 CDR Data 

 The Agency’s process to identify priority chemicals for review uses the CDR data both 

for determining the initial chemicals on which to focus, and to screen those chemicals to 

identify the candidates for priority review. The 2012 IUR data is essential to the 

prioritization of these chemicals, providing the screening level exposure-related data 

necessary for the initial priority determination. 

 The CDR data provides EPA with the ability to access and initiate appropriate action on 

over 6,750 existing chemicals which have production volumes of 25,000 pounds per year. 

The Agency expects to develop overviews for priority chemicals that summarize 

available hazard, exposure, and use information on chemicals; outline the risks that each 

chemical may present; and identify the specific steps the Agency is taking to address 

those concerns. 

 The TSCA Interagency Testing Committee (ITC) has requested CDR data to identify

chemicals as candidates to recommend for further testing or information reporting. In 

this process, the ITC eliminates many chemicals for which the ITC does not recommend 

further testing. The ITC has fourteen (14) U.S. Government member organizations: the 

Agency for Toxic Substances and Disease Registry (ATSDR), Council on Environmental 

Quality (CEQ), Consumer Product Safety Commission (CPSC), Department of 

Agriculture (USDA), Department of Defense (DOD), Food and Drug Administration 

(FDA), Department of the Interior (DOI), EPA, Department of Commerce (DOC), 

National Cancer Institute (NCI), National Institute of Environmental Health Sciences 

(NIEHS), National Institute for Occupational Safety and Health (NIOSH), National 
 

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Science Foundation (NSF), and Occupational Safety and Health Administration (OSHA). 

The ITC will use the CDR information to refine its selection of chemicals for testing, 

information reporting, or another recommendation. 

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Non-Duplication

The data included in this information collection (i.e., production volume, chemical 

manufacture, exposure, and use data) are not otherwise comprehensively or systematically

collected at the national level. There are a variety of sources for pieces of the information, but 

the sources are either incomplete or incompatible. For instance, information currently available 

at both the federal and state levels is collected to support specific federal and state programs, 

initiatives, or regulatory actions. As an example, under EPCRA sections 311 and 312, states 

collect data on the maximum and average amount of a chemical onsite for the purposes of 

emergency response planning. This information does not substitute for the annual volume of a 

chemical and is not available for use in a national-level screening program.

In the past, EPA explored a wide variety of public data sources, as demonstrated by the 

following three documents: Inventory Update Reporting Rule (IUR) Amendments Technical 

Support Document: Exposure-Related Data Useful for Chemical Risk Screening (EPA 1996a), 

Revised Economic Analysis of the Amended Inventory Update Reporting Rule (EPA 2002a), and 

A Review of Existing Exposure-Related Data Sources and Approaches to Screening Chemicals: 

A Response to CMA (EPA 1999). These documents contain extensive discussions of chemical 

information collections and conclude that the information collected in the CDR program is not 

available elsewhere. EPA has spent considerable effort and resources evaluating other data 

sources that could potentially provide the accurate and up-to-date information that the Agency

needs. A primary consideration, as mandated by TSCA, was to not subject industry to 

unnecessary or duplicative reporting. The information sought under the CDR is not accessible to 

EPA through other means. Although some useful data exist in some sources, the data are 

insufficient due to a lack of scope, currency, and detail. Without the CDR, EPA cannot update 

the TSCA Inventory as required by law, and remains unable to efficiently screen potential risks 

posed by a large number of chemicals on the TSCA Inventory.

One mechanism in particular received scrutiny from EPA as an alternative to the current 

CDR: the TSCA Preliminary Assessment Information Reporting (PAIR) rule (40 CFR part 712). 

However, PAIR would not be an efficient or cost-effective way to compile a database to allow 

the large-scale risk screening of chemicals on the TSCA Inventory. Although PAIR is a useful 

data collection tool when one or a small group of chemicals is targeted for risk assessment, it is 

limited when collecting information on a large number of chemicals. Additionally, the PAIR 

rule has fewer, less definitive data elements than the CDR, is a one-time collection versus the 

five year collection cycle of the CDR, and will not provide data sufficient to meet the goals of 

the CDR. Use of PAIR only implies that EPA should continue to set risk-screening priorities 

based on hazard and production volume alone, or in response to requests from others. This 
 

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approach greatly hinders EPA’s ability to make effective and efficient risk management 

decisions.

EPA continues to use existing data sources and information sets. However, the existing 

sources are generally best used when conducting a more detailed risk assessment of a specific 

chemical of concern, rather than preliminary risk screening of a large set of chemicals. The 2006 

and later CDR submissions provide a consistent set of screening-level exposure data that allow 

EPA to better identify on a relative basis the chemicals of highest priority for further risk 

evaluation. EPA uses the CDR data to identify those specific chemicals that are of potential 

concern and need follow up assessment. 

The CDR focuses on information specific to the manufacture and use of chemicals, 

including exposure potentials during various activities; this information is not available 

elsewhere. One past source of data, NIOSH’s National Occupational Exposure Survey (NOES), 

represented a valuable source of data concerning the number of exposed workers. NOES was 

completed in 1981 and is now recognized as being significantly dated. Furthermore, information 

regarding chemical use has never been collected in a systematic manner.

3(b) Public Notice Required Prior to ICR Submission to OMB

Prior to submission to OMB, this ICR will be made available to the public for comment 

through a Federal Register notice. The public will have 60 days to provide comments. Any

comments received will be given consideration when completing the supporting statement that is 

submitted to OMB.

3(c) Consultations

Under 5 CFR 1320.8(d)(1) OMB requires agencies to consult with potential ICR 

respondents and data users about specific aspects of ICRs before submitting an original or 

renewal ICR to OMB for review and approval. In accordance with this regulation, EPA will 

pursue additional consultations with interested parties during the development of the renewal of 

this collection.

3(d) Effects of Less Frequent Collection

EPA returned the reporting frequency to every four years when promulgating the 2011 

Chemical Data Reporting rule (see 76 FR 158), which was the frequency in effect from 1986 to 

2006. In an effort to reduce the reporting burden associated with the 2003 amendments, EPA had 

changed the reporting frequency to every five years. While the less frequent reporting does 

reduce burden, EPA now believes that reporting every five years does not provide data 

sufficiently current to meet Agency and public needs and now considers every four years to be 

the minimum acceptable frequency. In addition, the CDR Modifications proposed rule requested 

comment on even more frequent reporting. Comments from industry representatives led EPA to 

believe that more frequent reporting creates efficiencies, both for the respondent and for EPA. 

With more frequent reporting, companies will be able to establish standard systems and practices 

to collect the required information. 
 

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The Agency needs to be able to make accurate chemical substance risk management 

decisions in a timely and cost effective manner, especially because alternative data sources do 

not exist for these data. The effect of less frequent collection of these data is to diminish 

significantly the Agency’s ability to understand the chemical industry and monitor the 

production levels of chemical substances manufactured (including imported) in the United 

States. As described above, the CDR data demonstrate that chemical industry product lines and 

manufacturing in the United States change substantially from one submission period to the next. 

The Agency needs up-to-date information in order to fulfill its mandate to keep the TSCA 

Inventory current under section 8(b) of TSCA; collecting the data every five years means the 

Agency is working with data which are potentially six or more years old, and therefore, cannot 

be considered current. 

Less frequent collection could result in EPA using outdated information in its decision 

making. For example, changing market conditions, batch processing, or the development of new 

uses for the chemical substance can cause production volumes or chemical substance uses to 

change from one year to the next. Companies buy and sell plant sites, and the chemical 

substances produced at a site can change. Based on past CDR reporting, the Agency would be 

working with the CDR data which approximately 30 percent of the chemical substances known 

to be in commerce at volumes of 25,000 lb or more may not actually be in commerce at those 

levels. 

3(e) General Guidelines

This collection does not exceed any of the Paperwork Reduction Act guidelines at 5 CFR 

1320.6, with the exceptions listed below.

The record retention period of this collection is five years, exceeding the PRA maximum 

of three years. This is necessary to ensure companies retain records long enough to facilitate 

completion of Form U in the next collection, which is in four years, and to allow EPA’s 

enforcement activities to cover two CDR reporting cycles.

Confidential Business Information (CBI) claims limit access to the CDR data, especially 

by the general public. EPA recognizes that some information submitted to the Agency is 

legitimately business confidential; because of this, EPA’s review of CBI data is an inherently 

governmental function that EPA must perform to protect human health and the environment.

 

3(f) Confidentiality

Respondents may claim information submitted to EPA under this rule as confidential if 

such information would reveal the submitters’ trade secrets or proprietary information as defined 

by TSCA section 14 and existing TSCA regulations. EPA has long-established procedures for 

handling, storing, processing and disposing of TSCA confidential information. Transfers of this 

information to other governmental agencies can only be accomplished if the other agency agrees 

to adhere to all TSCA confidentiality provisions. EPA will maintain standard CBI procedures to 
 

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protect any confidential, trade secret, or proprietary information from disclosure in accordance 

with EPA’s confidentiality regulation, 40 CFR Part 2, Subpart B.

3(g) Sensitive Questions

This collection does not include questions of a sensitive nature.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondent NAICS Codes

The regulated community consists of companies manufacturing or importing chemicals 

listed on the TSCA Inventory and regulated under TSCA section 8. In general, the industry

segments that compose the regulated community for the rule are those that produce or import 

organic and inorganic chemicals. Most respondents previously reported information under the 

CDR. Due to the past experience the Agency has had with respondents to the CDR, it is 

anticipated that the majority of the respondents affected by this collection activity are from the 

following North American Industrial Classification System (NAICS) code categories:

325 - Chemical Manufacturing (including importing)

324 - Petroleum and Coal Product Manufacturing (including importing)

The subsectors identified above represent the designation of sites that likely would be 

subject to CDR reporting. However, activities at these sites may vary, making identification of 

the regulated community more difficult. For example, NAICS codes reflect a site’s primary

activity, omitting substantial participation a company may have in other industry activities. 

Second, NAICS codes assigned by U.S. parent companies reflect the parent company’s primary

activity, even though many U.S. parent companies are primarily holding companies with small 

subsidiaries. Each of these small subsidiaries may belong in a completely different industry 

classification based on its own primary activity. Information on U.S. parent company NAICS 

codes does not provide a very accurate characterization of the types of sites subject to reporting, 

and facilities that do not fall under these categories must still report if they meet the reporting 

criteria.

Generally, TSCA section 8 excludes small manufacturers (including importers) from 

reporting. EPA defines small manufacturers (including importers) for purposes of CDR and 

certain other reporting in 40 CFR 704.3.

In addition to the anticipated respondents listed above, manufacturers (including 

importers) of byproducts are required to report under the CDR rule. Byproduct manufacturers 

(including importers) may be listed under a different primary activity for a site, such as NAICS 

codes 22, 322, 331, and 3344; e.g., utilities, paper manufacturing, primary metal manufacturing, 

and semiconductor and other electronic component manufacturing. For purposes of the CDR, a 

byproduct is a chemical substance produced without a separate commercial intent during the 

manufacture, processing, use or disposal of another chemical substance or mixture (40 CFR 
 

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704.3). Such a chemical substance, like any other manufactured chemical substance, is subject to 

CDR reporting if it is manufactured, is listed in EPA’s Master Inventory File, is not otherwise 

excluded from reporting, and its manufacturer is not specifically exempted from CDR reporting 

requirements. For instance, a manufacturer (including importer) that uses a chemical substance in 

the production of an article may produce a byproduct substance that is chemically different from 

the starting substance; the manufacturer (including importer) therefore may incur reporting 

obligations under the CDR for that byproduct. While some manufacturers (including importers) 

of byproducts may not have reported to the CDR in the past, they should be aware now of their 

reporting obligations under the CDR rule. 

4(b) Information Requested

(i) Data items

The CDR data elements are primarily related to or indicative of three components of 

exposure. These components are: (1) the number of ecosystems or size of human populations 

potentially exposed, (2) the potential exposures or concentrations experienced by the 

environment or humans, and (3) the frequency and duration of potential exposures. The data 

enhances EPA’s ability to evaluate each of these components of exposure. Respondents are 

required to submit known or reasonably ascertainable information.

Using e-CDRweb to create an electronic version of Form U, respondents report the data 

elements as follows:

 Certification. Company Official must certify by signature and date that to the best of 

their knowledge and belief 1) all information entered on Form U has been completed in 

compliance with the regulatory requirements; and 2) that the confidentiality statements 

on Form U are true and correct.

 U.S. Parent Company and Technical Contact Information. U.S. parent company name 

and Dun and Bradstreet number; Technical Contact name, phone number, mailing 

address, and email address.

 Plant Site Identification. Plant Site name, Dun and Bradstreet number, and street address 

(including county).

 Chemical Identification. Specific chemical name and CAS registry or accession number, 

as applicable, for chemicals with reporting year, site-specific production volume of 

25,000 pounds or more. The reporting threshold is reduced to 2,500 pounds for chemical 

substances that are the subject of a rule proposed or promulgated under TSCA section 

5(a)(2), 5(b)(4), or 6, the subject of an order issued under TSCA section 5(e) or 5(f), or 

the subject of relief that has been granted under a civil action under TSCA section 5 or 7.

 Manufacturing Information. The production volume for each of the years since the last 

principal reporting year; the volume of the reported chemical substance used at the 

reporting site; whether an imported chemical substance is physically at the reporting site; 
 

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the production volume directly exported and not domestically processed or used; whether 

a manufactured (including imported) chemical substance, such as a byproduct, is being 

recycled, reused, reprocessed, or remanufactured; the number of workers reasonably

likely to be exposed (in ranges); the maximum concentration of chemical (in ranges); and 

the physical form of chemical with associated percent production volume.

 Processing and Use Information. Up to 10 unique combinations of type of process or use 

(code), Industrial Sector (IS) code associated with specific combination, and industrial 

function category. For each unique combination, the percentage of respondent’s 

production volume, number of processing and use sites (in ranges), and number of 

reasonably likely to be exposed workers (in ranges).

 Commercial and Consumer Use Data. Commercial/consumer use category whether a 

chemical is intended for use in children’s products, percentages of respondent’s 

production volume in each commercial/consumer use category, and maximum 

concentration of chemical in each commercial/consumer use category (in ranges).

(ii) Respondent Activities

A representative respondent would engage in the following activities:

(i) Compliance Determination -- Determine whether reporting is required for a chemical 

manufactured at a particular site, based on the production volume thresholds and the 

applicability of certain reporting exemptions;

(ii) Rule Familiarization -- Become familiar with the full requirements of the rule, which 

entails reading the rule, understanding the various reporting and administrative 

requirements, and determining the manner in which reporting requirements will be met 

for each chemical;

(iii) CDX Registration Activities -- The CDR rule requires electronic reporting, and therefore 

requires that all submitters complete the CDX registration process. As part of registering 

with CDX, each submitter will provide identifying information that will comprise all or 

most of the information requested in Part I of Form U. This information will then be prepopulated whenever the submitter prepares a partial or full report; 

(iv) Prepare and Submit Report, and Maintain Records- Partial Report -- Compile the 

required information, determine the CBI status of information and fulfill appropriate 

substantiation measures, and use e-CDRweb to complete and submit only Parts I and II 

(and Part IV, if a joint submission) of Form U for chemical substances specifically listed 

in the regulation for which there is a partial reporting exemption. Retain all records 

related to the submission for five years after the submission period; and

(v) Prepare and Submit Report, and Maintain Records- Full Report -- Compile the required 

information, determine the CBI status of information and fulfill appropriate 

substantiation requirements, and use e-CDRweb to complete and submit Parts I, II, and 
 

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III for chemical substances manufactured (including imported) in volumes of 25,000 lb or 

more (or 2,500 lb or more, if applicable), and Part IV, if a joint submission, of Form U. 

Retain all records related to the submission for five years after the submission period.

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY AND INFORMATION MANAGEMENT

5(a) Agency Activities

The activities routinely conducted by EPA related to the processing, analysis and storage 

of the information collected under this rule include the following:

 review and verify forms as they are received

 answer respondent’s questions and provide any necessary assistance

 process submissions for inclusion in CDR database

 review requests for confidentiality in the submissions

 maintain the database

 distribute the data

5(b) Collection Methodology and Management

The next CDR collection will occur in 2016. All manufacturers (including importers), 

except for those defined as “small manufacturers” by EPA’s regulations, are required to submit 

information on every substance subject to the 2011 CDR rule that they manufacture (including 

import) in quantities that meet or exceed the CDR thresholds. The collection will occur every

four years.

(i) Collection Methodology

All manufacturers (including importers) of subject chemicals are required to report under 

the CDR rule. Submitters are required to submit information associated with this data collection 

electronically via the Internet using e-CDRweb and CDX. Potential reporters are notified of the 

need to report in three ways: (1) EPA publishes a Federal Register notice, (2) email notices are 

sent to previous CDR submitters, and (3) articles are published in the trade press. Reporting 

materials, including a non-submission version of the e-CDRweb reporting tool and a variety of 

guidance documents (Instruction Manual, Q&As, Case Studies), are available on the EPA’s CDR

website. Submitters can also obtain the reporting materials from the TSCA Hotline.

Information quality and validation begins with the e-CDRweb reporting tool, which is 

programmed to help the submitter provide the information required, in the correct format as 

required by the CDR rule. Use of e-CDRweb will eliminate many of the problems with incorrect 

chemical substance identifications experienced in the past by providing a current listing of the 

TSCA Inventory chemicals and their associated identification numbers. Other respondentgenerated errors, such as incorrect codes, have also been eliminated due to the use of techniques 
 

14

such as drop-down menus, restrictions on the specific information that can be entered, and errorchecking algorithms. 

Mandatory CDR reporting via the Internet is the most efficient collection method for 

submitters and EPA. Submitters receive almost immediate notification that EPA has received 

their submission, and EPA is able to upload the information directly into the CDR database, 

which improves the efficiency of EPA’s data receipt and processing activities. This collection 

method also eliminates the introduction of errors by avoiding the need to scan or key-enter data 

submitted on paper or CD. Additional validations have been programmed into the data-entry

system to further ensure the quality of the data. 

To aid persons subject to this information collection, the Agency’s TSCA and CDX 

Hotlines are available to answer questions regarding the CDR requirements or submission 

process. When Hotline staff is unable to answer questions, the submitter is referred to OPPT’s 

Information Management Division (IMD) or Chemical Control Division (CCD), as appropriate. 

Other Divisions within OPPT or OEI are used as necessary. 

(ii) Data Management

This section describes the Agency tasks required for efficiently processing submissions 

under the CDR. The tasks for which the Agency is responsible are presented under four main 

categories: database systems development, guidance document development, Form U processing, 

and additional tasks. The task descriptions presented below generally do not change from 

collection to collection.

CDR data is stored in a database managed by the Agency. Once updated, the database is 

then available to EPA technical reviewers for export into their various analytical modeling 

systems and databases. The CDR database is also available for quick screening and other direct 

uses. The Agency makes publicly available as much information as possible, within the confines 

of protecting CBI.

 Database Systems Development and Maintenance -- The Agency is responsible for 

having adequate information systems in place to support the CUS database that serves as 

the primary data storage medium for CDR collections. File servers with appropriate 

backup are used to contain the CDR databases. Following the 2006 IUR collection, EPA 

updated the technology used to store the data, storing it in a larger Manage Toxic 

Substances (MTS) database. In addition, CDR data are tracked via the correspondence 

tracking system utilized by the Confidential Business Information Tracking System 

(CBITS) located within the Confidential Business Information Center (CBIC).

 Guidance Document Development -- The Agency is responsible for developing guidance 

to assist reporters in complying with CDR requirements. The guidance documents 

usually are developed by a contractor with oversight by Agency personnel.

 Form U Processing -- The Agency is responsible for handling processing of CDR Form U

submissions. This includes developing standard operating procedures and documentation 
 

15

for all stages in the CDR document life cycle, document receipt and tracking, data input, 

quality control, file and database maintenance, information security, CBI aggregation 

policy, data dissemination, and staff training. For the 2012 CDR submission period, EPA 

developed new processes to receive CDR submissions over the Internet, using the 

Agency’s Central Data Exchange (CDX) system; these systems apply for the 2016 CDR. 

 Additional Activities -- The Agency develops various supporting documents associated 

with the reporting tool and makes them available on the Internet. In addition, the Agency

is responsible for providing the TSCA Hotline with standardized responses for frequently 

asked questions; preparing mailings, mailing lists, and labels; and developing outgoing 

information materials.

5(c) Small Entity Flexibility

Ample flexibility is provided. This regulation affects only businesses -- governmental 

jurisdictions and not-for-profit organizations are not required to take any action. Small 

manufacturers (including importers), in accordance with TSCA section 8(b) (40 CFR sections 

710.29 and 710.28), are exempt and therefore are generally not subject to any of the reporting or 

recordkeeping requirements. A manufacturer (including importer) is considered a small business 

if (1) the firm’s total annual sales when combined with those of its parent company (if any) are 

less than $40 million for the reporting period and (2) its total production and/or importation of 

the chemical substances, mixture or category, for the reporting period, does not exceed 100,000 

pounds (45,000 kilograms) at an individual site owned and controlled by the firm. The 

Economic Analysis for the Final Inventory Reporting Modifications Rule determined that the 

impact on these companies is, on average, significantly less than 1% of revenues (EPA 2011). 

5(d) Collection Schedule

The submission period shall be from June 1, 2016 to September 30, 2016. The 

submission period/schedule follows the requirements of 40 CFR 711.20.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section presents the burden and cost estimates incurred by all affected entities as a 

result of the CDR rule, and covers the period from 2012 to 2015. Therefore, it provides burden 

and cost estimates for the information collection corresponding to the 2016 reporting cycle. 

Although reporting occurs only once per reporting cycle (once every four years), EPA believes 

that rule compliance and data collection activities, and thus, costs and burdens, are incurred over 

the course of the reporting cycle. Therefore, for purposes of this analysis, the burden and cost for 

one reporting cycle are averaged over the number of years in the reporting cycle and are 

presented here as average annual figures. All costs are presented in year 2010 dollars. The CDR

requires reporting on a “per site” basis rather than a “per company” basis. Therefore, each site

which is subject to the CDR rule is considered a respondent and will submit one Form U 

containing one or more chemical-specific reports. EPA estimates that 4,289 respondents will 

respond in the 2016 reporting cycle.
 

16

Burden and cost calculations are based on the assumption that EPA will receive an 

average of 30,287 full reports and 648 partial reports in the 2016 reporting cycle. Each report is 

for a single chemical/site combination. Each site is expected to submit an average of 7.06 full 

reports and 0.15 partial reports in the reporting cycle. The average burden per respondent, which 

is one site, is estimated to be 600 hours per cycle, or 150 hours annually over the three year 

period from 2012 through 2015. This is higher than the burden estimated for the currently

approved ICR (EPA ICR No. 1884.05), due to an adjustment in reporting requirement criteria, 

including additional data requirements and modifications to reporting thresholds.

6(a) Estimating Respondent Burden

For the 2016 reporting cycle, each manufacturing site (including importers) must submit 

a Form U if the site meets or exceeds the 25,000 lb threshold for at least one chemical substance

in any calendar year since the last principal reporting year. For purposes of the ICR, one 

manufacturing site is equivalent to one respondent. Form U contains four Parts. Part I contains 

basic site identification information and must be completed by all sites. Part II contains 

manufacturing data (production volumes, etc.) specific to each chemical substance, which also 

must be completed by all sites. Together, Part I and Part II are considered a “partial report.” Part 

III contains processing and use information and is to be completed for all chemical substances

unless the chemical substance is specifically exempted from the requirement to do so. Part IV 

contains secondary company identification information and specific information identifying a 

chemical substance. Part IV is completed only by a secondary respondent (see Section 2(b)). For 

purposes of this analysis, burden and costs associated with Part IV are considered part of the 

burden and costs estimates of Part I (respondent identification) and the beginning of Part II 

(chemical identification), and therefore were not separately calculated. Together, Parts I, II, and 

III (and Part IV, when applicable) are considered a “full report.” One report is submitted for each 

unique chemical substance/site combination; that is, a site must complete a separate report for 

each applicable chemical substance, but Part I of Form U is completed and submitted only once 

per site. EPA anticipates that Part I will be completed automatically when respondents register

with CDX. 

To comply with the regulation, manufacturers (including importers) must complete the 

activities listed in Table 2. Table 2 also provides a cross-walk of the related Information 

Collection that corresponds to each activity.
 

17

Table 2: Cross-Walk between Industry Activities and Related Information Collections (ICs)

Activity Description Related IC(s)

Compliance 

Determination

Site staff must determine whether reporting is 

required for a chemical substance manufactured 

(including imported) at a particular site, based on the 

chemical substance’s production volume and the 

applicability of certain reporting exemptions.

Compliance Determination

Rule 

Familiarization

Site staff must familiarize themselves with the 

requirements of the rule. Staff from sites that 

reported previously must become familiar with new 

requirements, and staff from sites new to reporting 

must become familiar with all requirements. This 

entails reading the rule, understanding the various 

reporting and administrative requirements, and 

determining the manner in which the reporting 

requirements will be met.

Rule Familiarization

CDX Registration Before submitting Form U, all respondents must 

register with CDX. In addition, respondents must

complete an Electronic Signature Agreement form, 

which is signed, dated, and either submitted 

electronically or mailed back to EPA.

CDX Registration Activities

Preparation of 

Reports

Site staff must collect all of the required information 

and complete partial and/or full reports using a Form 

U report form, for each of the reportable chemical

substances at that site. The information must be 

reviewed, and submitted to EPA. This task involves 

any research necessary to identify the correct 

information to report, the act of completing Form U 

(technical and clerical burden), and managerial 

review. Once Form U is completed, company staff 

must submit it electronically to EPA via CDX.

Prepare and Submit Report, and 

Maintain Records –

Partial Report

Prepare and Submit Report, and 

Maintain Records –

Full Report

Recordkeeping Respondents must keep records supporting their 

submissions for five years.

Prepare and Submit Report, and 

Maintain Records –

Partial Report 

Prepare and Submit Report, and 

Maintain Records –

Full Report

Burden estimates were derived originally from a survey conducted by EPA in 1996 

(under OMB Control No. 2070-0034) to assess the potential burden associated with the IUR, as 

amended at that time. The survey was distributed to previous CDR respondents selected from the 

CDR database. Burden estimates were updated for a 2005 amendment to the rule as described in 

Economic Analysis of IUR Modifications Final Rule (EPA, 2005)3. Burden estimates for new 

reporting elements in the 2011 final rule were derived as described in the Economic Analysis for 

the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a).

 

3 The economic analysis for the 2005 Amendments assumed a 15 percent reduction in burden for the completion of 

Part III because submitters were no longer required to report use and downstream processing information for 

exports.
 

18

Table 3 illustrates the burden for a typical respondent on a per-activity basis, including 

time required to complete each section of Form U. CDR reporting for all respondents occurs 

within a required timeframe (once every four years). The three years covered by this ICR 

renewal (2012 through 2015) will occur during the 2016 reporting cycle. Therefore, burden hour 

estimates for this period (Table 3) are based on the “future” reporting cycle burdens as calculated 

in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule

(EPA, 2011a). (The economic analysis also estimated costs for the “current” (2012) reporting 

cycle).EPA estimates the total industry burden for completing and submitting one partial report 

to be 28.39 hours, and the estimated burden for completing and submitting one full report to be 

94.02 hours. Each site is expected to submit an average of 7.06 full reports and 0.15 partial 

reports in the 2016 reporting cycle. 

EPA calculated burden estimates for each element of Form U individually, using the 

1996 survey results, economic analyses for other rules with similar requirements (such as the 

Premanufacture Notification Electronic Reporting final rule), and EPA’s best professional 

judgment. More detailed information on the derivation of these estimates is found in the 

Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 

2011a).
 

19

Table 3: Total Industry Burden, by Activity

Activity

Clerical Burden 

(hours)

Technical Burden

(hours)

Managerial 

Burden

(hours)

Total Burden

(hours)

(a) (b) (c) (d) = (a)+(b)+(c)

PREPARATION OF REPORT 

Part I. Site Identification Information

Certification 0.00 0.85 1.01 1.86

Company Information (U.S. Parent Company Name, D&B Number, 

Mailing Address, Technical Contact, Technical Contact Mailing 

Address)

0.00 0.01 0.004 0.01

Plant Site Identification (Site Name, D&B Number, Mailing Address) 0.00 0.01 0.004 0.02

Total for Part I 0.00 0.87 1.02 1.89

Part II. Manufacturing Information

Site-Limited, Activity, Production Volume (lb) (2015) 0.00 1.82 0.45 2.27

Chemical Substance Identification Upfront CBI Substantiation 0.00 1.16 0.61 1.77

Plant Site Upfront Substantiation 0.00 0.66 0.41 1.07

Total Number of Workers 0.00 1.14 0.47 1.61

Maximum Concentration, Physical Form, Percent Volume of

Production 0.00 2.23 0.86 3.09

Production Volume for Each of the Years since Last Principal 

Reporting Year (2012 - 2014) 0.00 2.46 0.60 3.07

Production Volume Used On-Site 0.00 0.16 0.04 0.20

Whether Imported Chemical Substance is Physically at Reporting 

Site 0.00 0.09 0.02 0.11

Volume Exported 0.00 0.82 0.20 1.02

Whether a Chemical Substance is to be Recycled, Remanufactured, 

Reprocessed or Reused. 0.00 0.09 0.02 0.11

Total for Part II 0.00 10.65 3.68 14.33

Part III. Processing and Use Information

Upfront Substantiation for Processing and Use Information 

CBI Claims 0.00 0.43 0.21 0.64

Industrial Processing and Use Exposure-Related Data

Determination of Applicability 0.00 0.81 0.23 1.03

Industrial Function Category 0.00 3.53 1.65 5.18

Sector 0.00 0.75 0.32 1.06
 

20

Activity

Clerical Burden 

(hours)

Technical Burden

(hours)

Managerial 

Burden

(hours)

Total Burden

(hours)

(a) (b) (c) (d) = (a)+(b)+(c)

Percent of Production Volume 0.00 8.00 4.22 12.22

Total Number of Processing and Use Sites 0.00 7.31 2.82 10.13

Total Number of Potentially Exposed Workers 0.00 12.34 3.06 15.41

Consumer and Commercial Use Exposure-Related Data

Determination of Applicability 0.00 0.75 0.20 0.95

Identification of Production Category/Use by Children 0.00 0.67 0.20 0.87

Percent of Production Volume 0.00 1.01 0.36 1.37

Maximum Concentration by Category 0.00 1.09 0.28 1.36

Number of Commercial Workers Reasonably Likely to be 

Exposed 0.00 12.34 3.06 15.41

Total for Part III 0.00 49.03 16.60 65.63

COMPLIANCE DETERMINATION 

Compliance Determination 0.00 2.50 0.00 2.50

RULE FAMILIARIZATION 

Rule Familiarization 0.00 2.00 2.00 4.00

CDX REGISTRATION ACTIVITIES 

CDX Registration 0.00 0.73 0.18 0.92

CDX Electronic Signature Agreement 0.00 1.00 0.75 1.75

Total for CDX Registration Activities 0.00 1.73 0.93 2.67

RECORDKEEPING

Recordkeeping 0.75 1.50 0.75 3.00

TOTAL BURDEN 

Burden for one Partial Report (Parts I, II, Compliance Determination, 

Rule Familiarization, Recordkeeping and CDX Registration Activities)

0.75 17.52 7.45 28.39

Burden for one Full Report (Parts I, II, III, Compliance Determination, 

Rule Familiarization, Recordkeeping and CDX Registration Activities)

0.75 66.54 24.05 94.02

Note: Totals may not sum due to rounding.

Source: Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a).
 

21

6(b) Estimating Submitter Cost

EPA multiplied burden estimates by standard wage rates for managerial, technical, and 

clerical levels developed from information published by the Bureau of Labor Statistics (BLS) 

and a method outlined in the document Wage Rates for Economic Analyses of the Toxics Release 

Inventory Program (EPA, 2002b). Wage data for the three occupational categories was gathered 

for manufacturing industries from Employer Costs for Employee Compensation Supplementary 

Tables: Historical Data December 2006 – December 2010 (BLS, 2011a).

The cost of fringe benefits, such as health insurance and vacation, is taken for each labor 

category from the same ECEC series. Following the methodology outlined in EPA 2002b, fringe 

benefits are calculated as a percentage of total wages for each category. EPA added 17 percent to 

the wages in each category to account for overhead, based on information provided by the 

chemical industry and chemical industry trade associations in the Revised Economic Analysis for 

the Amended Inventory Update Rule: Final Report (EPA, 2002a). The wages for each of the 

three categories were then multiplied by benefits and overhead factors to estimate loaded, annual 

salaries in year 2010 dollars. Table 4 contains the loaded wage rates for the managerial, technical 

and clerical occupation categories. 

Table 4: Derivation of Loaded Wage Rates for the Private Manufacturing Sector in 2010$

Wage1

Fringe 

Benefits1

Fringes as % 

of Wage

Overhead % 

of Wage2

Fringe + 

Overhead 

Factor

Loaded Wages

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

Clerical $17.36 $8.67 48.37% 17% 1.67 $28.98

Technical $36.93 $18.50 47.58% 17% 1.67 $61.71

Managerial $42.82 $19.64 45.03% 17% 1.63 $69.74 

1 Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006 –

December 2010, US Bureau of Labor Statistics, March 2011 (BLS, 2011a).

2 An overhead rate of 17 percent was estimated based on industry data gathered for the Revised Economic Analysis 

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

Table 5 contains the cost per activity of completing Form U for one respondent in the 

2016 reporting cycle. Burden hours presented in Table 4 were multiplied by the corresponding 

loaded wage rage in Table 5. EPA estimates the total cost for completing and submitting one 

partial report in future reporting cycles is $1,794 and the cost for completing and submitting one 

full report is $5,978. More information on the derivation of these costs is found in the IUR EA 

(EPA, 2011a).
 

22

Table 5: Total Industry Cost, by Activity, Future Reporting Cycles

Activity

Clerical Cost

(2010$)

Technical Cost 

(2010$)

Managerial 

Cost

(2010$)

Total Cost

(2010$)

(a) (b) (c) (d) = (a)+(b)+(c)

PREPARATION OF REPORT 

Part I. Site Identification Information

Certification $0.00 $52.45 $70.44 $122.89 

Company Information (U.S. Parent Company Name, D&B Number, 

Mailing Address, Technical Contact, Technical Contact Mailing 

Address) $0.00 $0.49 $0.28 $0.77 

Plant Site Identification (Site Name, D&B Number, Mailing Address) $0.00 $0.74 $0.28 $1.02 

Total for Part I $0.00 $53.69 $70.99 $124.68 

Part II. Manufacturing Information

Site-Limited, Activity, Production Volume (lb) (2015) $0.00 $112.56 $31.24 $143.80 

Chemical Identification Upfront CBI Substantiation $0.00 $71.58 $42.68 $114.26 

Plant Site Upfront Substantiation $0.00 $40.97 $28.45 $69.43 

Total Number of Workers $0.00 $70.59 $32.64 $103.23 

Maximum Concentration, Physical Form, Percent Volume of 

Production $0.00 $137.73 $59.70 $197.43 

Production Volume for Each of the Years since Last Principal 

Reporting Year (2012 - 2014) $0.00 $151.95 $42.18 $194.13 

Production Volume Used On-Site $0.00 $9.83 $2.73 $12.55 

Whether Imported Chemical Substance is Physically at Reporting 

Site $0.00 $5.63 $1.56 $7.19 

Volume Exported $0.00 $50.65 $14.06 $64.71 

Whether a Chemical Substance is to be Recycled, Remanufactured, 

Reprocessed or Reused $0.00 $5.63 $1.56 $7.19 

Total for Part II $0.00 $657.12 $256.80 $913.92 

Part III. Processing and Use Information

Upfront Substantiation for Processing and Use Information 

CBI Claims $0.00 $26.35 $14.64 $40.98 

Industrial Processing and Use Exposure-Related Data

Determination of Applicability $0.00 $26.35 $15.89 $42.23 
 

23

Activity

Clerical Cost

(2010$)

Technical Cost 

(2010$)

Managerial 

Cost

(2010$)

Total Cost

(2010$)

(a) (b) (c) (d) = (a)+(b)+(c)

Industrial Function Category $0.00 $0.00 $115.24 $115.24 

Sector $0.00 $49.72 $22.05 $71.78 

Percent of Production Volume $0.00 $217.95 $294.26 $512.21 

Total Number of Processing and Use Sites $0.00 $46.16 $196.57 $242.73 

Total Number of Potentially Exposed Workers $0.00 $493.68 $213.64 $707.32 

Consumer and Commercial Use Exposure-Related Data

Determination of Applicability $0.00 $49.72 $13.99 $63.71 

Identification of Production Category/Use by Children $0.00 $217.95 $13.75 $231.71 

Percent of Production Volume $0.00 $46.16 $25.13 $71.29 

Maximum Concentration by Category $0.00 $493.68 $19.21 $512.88 

Number of Commercial Workers Reasonably Likely to be 

Exposed $0.00 $451.30 $213.64 $664.94 

Total for Part III $0.00 $3,025.27 $1,158.00 $4,183.27 

COMPLIANCE DETERMINATION 

Compliance Determination $0.00 $154.27 $0.00 $154.27

RULE FAMILIARIZATION 

Rule Familiarization $0.00 $123.42 $139.48 $262.90

CDX REGISTRATION ACTIVITIES

CDX Registration $0.00 $45.25 $12.79 $58.04 

CDX Electronic Signature Agreement $0.00 $61.71 $52.30 $114.01 

Total for CDX Registration Activities $0.00 $106.96 $65.09 $172.05

RECORDKEEPING

Recordkeeping $21.74 $92.56 $52.30 $166.60 

TOTAL COST

Cost for one Partial Report (Parts I, II, Compliance Determination, 

Rule Familiarization, Recordkeeping and CDX Registration Activities)

$21.74 $1,188.01 $584.67 $1,794.42 

Cost for one Full Report (Parts I, II, III, Compliance Determination, 

Rule Familiarization, Recordkeeping and CDX Registration Activities)

$21.74 $4,213.28 $1,742.67 $5,977.69 

Note: Totals may not sum due to rounding.

Source: Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a).
24

6(c) Estimating Agency Burden and Cost

EPA is responsible for the following activities associated with administering the CDR

rule: 

 Document receipt and tracking;

 Data entry and quality control of data entry;

 Backup systems operation;

 Data processing;

 Systems development; 

 Contract oversight and management;

 Publication and printing of forms and materials; and 

 Operation of the TSCA Hotline to handle CDR-related calls. 

Costs related to EPA activities that involve using the data are not included. 

EPA Staff Activities

Of the tasks listed above, Agency personnel are responsible for (1) quality control of data 

entry; and (2) data processing, systems development, and contract oversight and management. 

Contractors perform the other activities, as described below.

EPA estimates the total burden of completing Agency tasks to be one full-time equivalent 

at the GS 13 level for data processing, systems development, and contract oversight and 

management, per-reporting cycle. An estimated 0.193 FTEs are needed at the GS 12 level for 

quality control of data entry in this reporting cycle. Calculations of the Agency burden are 

presented in Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications 

Rule (EPA, 2011).

EPA labor costs are based on annual federal wage rates published by the Office of 

Personnel Management for the Washington-Baltimore-Northern Virginia, DC-MD- VA-WV-PA

locality pay area for 2010 (OPM, 2010). Wages are presented in terms of GS-level and step. 

Based on previous IUR economics analyses, a Step 3 is assumed for all FTEs (EPA, 2002a and 

EPA, 2005). Following the methodology outlined in Economic Analysis for the Amended 

Inventory Update Rule: Final Report (EPA, 2002a), EPA added 58 percent to the wage rate to 

account for fringe benefits and overhead costs. 

Error! Reference source not found.

Table 6 shows the loaded wage rates for Agency staff at the GS-12 Step 3, and GS-13 

Step 3 levels.
25

Table 6: Derivation of Loaded Agency Wage Rates (2010$)

Pay Grade Annual 

Salary

Overhead and Fringe 

Benefits 

(% of wages)

Overhead and Fringe 

Benefit Cost Total 

GS 12 Step 3 79,864 58% $46,321 $126,185 

GS 13 Step 3 $94,969 58% $55,082 $150,051

Source: The unloaded Federal salary for 2010 is from the Office of Personnel Management salary 

table for Washington-Baltimore-Northern Virginia (OPM, 2010). 

Table 7 contains the burden and cost per report for all EPA staff activities in the reporting 

cycle. The activities performed by the GS-13 level staff member, including systems 

development, and contract oversight and management, are fixed costs and are not dependent on 

the number of reports submitted to EPA. Therefore, the total burden for systems development 

and contract oversight is one FTE at the GS-13 level, with a cost of $150,051 in the 2016 

reporting cycle. Quality control of data entry is performed by the GS-12 level staff member and 

is dependent on the number of reports received. The burden for quality control of data is 

approximately 0.000011 FTE per report. The total cost per-report is approximately $1.35. The 

burden and cost of processing each data element in Form U are derived in the Economic Analysis 

for the Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a). EPA 

multiplied the burdens by the number of data elements in each section to estimate the total cost 

and burden of processing each Form U. For more detail on the derivation of these burdens, see 

the IUR EA (EPA, 2011a).

Table 7: EPA Staff Burden and Cost of Processing One Report 

Activity

Agency Burden 

per Activity 

(FTE)

Agency Burden 

per Activity

(hours)

Agency Cost 

per Activity

(2010$)

GS-12 Step 3 per-Report Burden

Quality Control of Data for Part I 0.0000048 0.0100 $0.62 

Quality Control of Data for Part II 0.0000026 0.0054 $0.34 

Quality Control of Data for Part III 0.0000030 0.0063 $0.39 

Total GS-12 Burden, per report 0.0000105 0.0218 $1.35 

GS-13 Step 3 Fixed Cost Burden

Systems development, and contract 

oversight and management 1 2,080 $150,051 

Total GS-13 Burden, per 

reporting cycle 1 2,080 $150,051 

Note: Costs may not exactly equal FTE times the wage rates in Table 6 due to rounding.

Contractor Activities

Agency costs also include payment for extramural tasks completed by contractors (this 

category includes costs to EPA, but not burden hours). Contractor activities include document 

receipt, tracking, data entry, maintaining backup systems, printing and publishing forms and 

materials, and managing the TSCA Hotline. With the exception of document receipt, tracking, 

and data entry, all contractor costs are fixed and are not dependent on the number of reports 

received. 
26

As presented in Table 8, EPA calculated the cost estimate per report for document 

receipt, tracking, and data entry (variable costs), $0.66, by starting with the cost estimated in the 

2011 ICR, and updated for inflation. To calculate the inflated the post-amendment cost attributed 

to contractor staff, EPA followed the approach outlined in the 2011 Economic Analysis for the 

Final Inventory Update Reporting (IUR) Modifications Rule (EPA, 2011a) that estimates 

variables contractor staff costs as a portion of all data management costs. 

All fixed costs are taken from the last published ICR and were inflated from 2008 to 2010

dollars with an inflation factor calculated using the Employment Cost Index (ECI), seasonally

adjusted, for white-collar occupations in private industry (BLS, 2011b).

Table 8: Cost of Contractor Activities

Activity Annual Cost 

2008$

Inflation 

Factor Annual Cost 2010$

Variable Costs

Document receipt, tracking, and data 

entry for Part I $0.09 n/a $0.10 

Document receipt, tracking, and data 

entry for Part II $0.26 n/a $0.26 

Document receipt, tracking, and data 

entry for Part III $0.30 n/a $0.30 

Total Cost of Document receipt, 

tracking, and data entry, per full 

report

$0.65 n/a $0.66 

Fixed Costs

Maintaining and Operating Back Up 

Systems $59,145 1.03 n/a

Printing and Publishing Forms and 

Materials $5,525 1.03 n/a

Managing the TSCA Hotline $44,694 1.03 n/a

Total Fixed Cost $109,365 n/a n/a

6(d) Bottom-Line Industry Burden and Cost Estimates

This section describes the estimated total social paperwork burden and cost of the CDR

rule, including the final amendments. The next CDR submission period will occur in 2016.

Although reporting occurs only once per reporting cycle (once every four years), EPA believes 

rule compliance and data collection activities, and thus, costs and burdens, are incurred over the 

course of the reporting cycle. Therefore, for purposes of this analysis, the burden and cost for 

one reporting cycle are averaged over the number of years in the reporting cycle and are 

presented here as average annual figures. This supporting statement is for the three-year period

from 2012 through 2015; therefore, average annual figures for each of these three years are 

presented below.
27

Respondent tally

EPA calculated the numbers of sites and reports submitted based on submission 

information from the December 2008 version of the IUR database, which includes data from the 

most recent (2006) IUR collection. The EPA IUR database contains information collected under 

the IUR for previous submission periods and was used to generate estimates of expected reports 

for the 2016 reporting cycle. In this reporting cycle, EPA expects 4,289 sites to submit 30,287 

full reports and 648 partial reports for a total of 30,935 reports (98 percent and two percent of all 

reports, respectively).

Total Industry Burden and Cost. EPA estimates the total industry burden for this 

reporting cycle, including both current baseline burden and the burden resulting from the final 

amendments, to be 2.57 million hours. Given that this data collection will occur every four years, 

EPA estimates the annual industry burden for each year to be 642,823 hours. As presented in 

Table 9, EPA estimates the total cost to industry would be $163 million, or an annual cost of 

$40.8 million.
28

Table 9: Estimated Annual Respondent Burden and Cost 

Activity

Total 

Burden 

per 

Activity 

(hours)

Total 

Number of 

Units

Total Cost per 

Activity

(2010$)

Total Burden

per Reporting Cycle

(hours)

Total Cost 

per 

Reporting 

Cycle (2010$)

Annual Burden 

(hours) Annual Cost (2010$)

Compliance 

Determination

(per Site)

2.50 4,289 Sites $154.27 10,723 $661,665 2,681 $165,416

Rule 

Familiarization

(per Site)

4.00 4,289 Sites $262.90 17,156 $1,127,557 4,289 $281,889

CDX 

Registration 

Activities (per 

Site)

2.67 4,289 Sites $172.05 11,437 $737,926 2,859 $184,481

Part I 

Preparation

(per Site)

1.89 4,289 Sites $124.68 8,098 $534,756 2,024 $133,689

Partial Report 

Preparation

(Part II, per 

Report)

14.33 648 Partial 

Reports $913.92 9,287 $592,221 2,322 $148,055

Full Report 

Preparation

(Part II and 

Part III, per 

Report)

79.96 30,287 Full 

Reports $4,931.84 2,421,786 $154,378,510 605,447 $38,594,627

Recordkeeping

(per Report) 3.00 30,935

Reports $166.60 92,805 $5,153,851 23,201 $1,288,463

Total Industry Burden and Cost 2,571,291 $163,186,486 642,823 $40,796,621

Note: Totals may not sum due to rounding 
29

Average Burden and Cost per Site. As shown in Table 10, the Agency estimates 

the typical respondent burden for this information collection activity to be 600 hours. 

Given that a collection would occur once every four years under the final rule, the 

average annual burden for each cycle would be 150 hours. These burden estimates

assume each site will submit an average of 7.06 full reports and 0.15 partial reports in

future reporting cycles. 

Table 10: Average Burden per Site 

Activity

Burden Hours

Total 

Hours 

per 

Activity

Reports 

per 

Average 

Site

Total 

Burden 

(hours 

per 

average 

site)

Annual 

Burden 

(hours per 

average 

site)

Managerial Technical Clerical 

Rule 

Familiarization. 

Compliance 

Determination, 

CDX 

Registration 

Activities and 

Part I 

Preparation 

(per site)

3.95 7.10 0.00 11.05 1.00 11.05 2.76

Partial Report 

Preparation 

(Part II, per 

Report)

3.68 10.65 0.00 14.33 0.15 2.17 0.54

Full Report 

Preparation 

(Part II and 

Part III, per 

Report)

20.29 59.67 0.00 79.96 7.06 564.65 141

Recordkeeping 

(per Report) 0.75 1.50 0.75 3.00 7.21 21.64 5.41

Total Hours 600 150

Note: Totals may not calculate due to rounding of unit burden estimates

Table 11 presents the average cost per site, by activity, for a CDR respondent. 

EPA estimates the average site will submit 7.06 full reports and 0.15 partial reports and 

incur a total cost of $38,048 during the reporting cycle ($9,512 annually) for Form U 

completion and submission.
30

Table 11: Average Cost per Site 

Activity

Cost

(2010$)

Total 

Cost per 

Activity

Reports 

per 

Average 

Site

Total Cost 

(2010$ per 

average 

site)

Annual 

Cost 

(2010$ 

per 

average 

site)

Managerial Technical Clerical 

Rule 

Familiarization. 

Compliance 

Determination, 

CDX Registration 

Activities and Part 

I Preparation 

(per site)

$276 $438 $0.00 $714 1.00 $714 $178

Partial Report 

Preparation (Part 

II, per Report)

$257 $657 $0.00 $914 0.15 $138 $34.52

Full Report 

Preparation (Part 

II and Part III, per 

Report)

$1,415 $3,682 $0.00 $5,097 7.06 $35,994 $8,999

Recordkeeping

(per Report) $52.30 $92.56 $21.74 $167 7.21 $1,202 $300

Total Cost $38,048 $9,512

Note: Totals may not calculate due to rounding of unit burden estimates
31

Table 12 presents the annual burden hours for the ICR period (2012 –2015), 

organized by information collection for CDR respondents. 

Table 12: Annual Information Collection Tally for ICR Reporting Period (2012- 2015)

Information 

Collection

No. of 

Respondents

No. of 

Responses / 

Respondent

Responses 

Subtotal

Annual 

Burden 

Hours per 

Response

Annual

Burden 

Hours 

Subtotal

Compliance 

Determination 4,289 1 4,289 0.63 2,681

Rule Familiarization 4,289 1 4,289 1.00 4,289

CDX Registration 

Activities 4,289 1 4,289 0.67 2,859

 CDX Registration 4,289 1 4,289 0.23 983

 ESA 4,289 1 4,289 0.44 1,876

Prepare Part I, Form U 4,289 1 4,289 0.47 2,024

Prepare and Submit

Report, and Maintain 

Records – Partial 

Report

4,289 0.15 648 4.33 2,808

 Part II, Form U 4,289 0.15 648 3.58 2,322

 Recordkeeping 4,289 0.15 648 0.75 486

Prepare and Submit 

Report, and Maintain 

Records - Full Report

4,289 7.06 30,287 20.74 628,162

 Parts II and III,

Form U 4,289 7.06 30,287 19.99 605,447

 Recordkeeping 4,289 7.06 30,287 0.75 22,715

Some burden estimate subtotals may not calculate due to rounding of unit burden estimates 
32

Table 13 presents the total burden hours for the ICR period (2012 –2015), 

organized by information collection, for CDR respondents. 

Table 13: Total Information Collection Tally for ICR Reporting Period (2012- 2015)

Information 

Collection

No. of 

Respondents

No. of 

Responses / 

Respondent

Responses 

Subtotal

Total Burden 

Hours per 

Response

Total 

Burden 

Hours 

Subtotal

Compliance 

Determination 4,289 1 4,289 1.88 8,042

Rule Familiarization 4,289 1 4,289 3.00 12,867

CDX Registration 

Activities 4,289 1 4,289 2.00 8,578

 CDX Registration 4,289 1 4,289 0.69 2,949

 ESA 4,289 1 4,289 1.31 5,629

Prepare Part I, Form U 4,289 1 4,289 1.42 6,073

Prepare and Submit

Report, and Maintain 

Records – Partial 

Report

4,289 0.15 648 13.00 8,423

 Part II, Form U 4,289 0.15 648 10.75 6,965

 Recordkeeping 4,289 0.15 648 2.25 1,458

Prepare and Submit 

Report, and Maintain 

Records - Full Report

4,289 7.06 30,287 62.22 1,884,485

 Parts II and III,

Form U 4,289 7.06 30,287 59.97 1,816,340

 Recordkeeping 4,289 7.06 30,287 2.25 68,146

Some burden estimate subtotals may not calculate due to rounding of unit burden estimates 

Agency Tally

Table 14 presents the Agency costs associated with the CDR rule. EPA multiplied 

the costs per report by the total number of Parts I, II, and III to calculate the total burden 

and cost associated with the number of reports EPA expects to be submitted. The burden 

is 0.193 FTE and the cost is $42,881 for variable cost activities. The burden and cost of 

the fixed cost activities remains unchanged by the number of reports submitted; the total 

fixed burden is one FTE per reporting cycle and the cost is $262,701. The total Agency

burden is 1.19 FTEs. The estimated total cost incurred by the Agency, $305,582, was 

calculated by summing the Agency staff and contractor activities.
33

Table14: Total Cost and Burden of Agency Activities 

Activity Staff

Form

U 

Section

Total 

Burden 

per 

Activity 

(FTE)

Total 

Number 

of Units

Total 

Cost per 

Activity

(2010$)

Total 

Burden 

(FTE)

Total Cost 

(2010$)

Variable Burdens and Costs

Document 

receipt, 

tracking, and 

data entry

Contractor

Part I N/A 4,289 

Sites $0.10 N/A $419 

Part II N/A 30,935 

Part IIs $0.26 N/A $7,930 

Part III N/A 30,287 

Part IIIs $0.30 N/A $9,430 

Quality 

Control of 

Data

EPA 

Employee

(GS-12 

Step 3)

Part I 0.0000048 4,289 

Sites $0.62 0.021 $2,646 

Part II 0.0000026 30,935 

Part IIs $0.34 0.081 $10,258 

Part III 0.0000030 30,287 

Part IIIs $0.39 0.092 $12,198 

Total Variable Cost and Burden 0.193 $42,881 

Fixed Burdens and Costs

Data 

Processing, 

Systems 

Development, 

and Contract 

Oversight and 

Management

EPA 

Employee

(GS-13 

Step 3)

N/A N/A N/A N/A 1.000 $150,051

Maintaining 

and Operating 

Back Up 

Systems

Contractor N/A N/A N/A N/A N/A $60,921

Printing and 

Publishing 

Forms and 

Materials

Contractor N/A N/A N/A N/A N/A $5,691

Managing the 

TSCA Hotline Contractor N/A N/A N/A N/A N/A $46,037

Total Fixed Cost and Burden 1 $262,701

Total Agency Cost and Burden 1.19 $305,582

6(e) Reasons for Change in Burden

There is a decrease of 16,920 hours (from 659,743 hours to 642,823 hours) in the 

total estimated respondent burden compared with that identified in the ICR currently 

approved by OMB. This decrease reflects changes resulting from updates to the number 

of affected sites and the number of responses per site, and adjusting burden estimates to 

capture burden reductions resulting from experiences with past reporting, as summarized 

in Table 15. More details on the changes are outlined below. The decrease is an 

adjustment.
34

Changes

The previous currently approved ICR (EPA ICR No. 1884.05) covered two 

reporting cycles; 2012 and 2016, and used a weighted average to estimate the number of 

sites and the number reports per site. The current request covers only the 2016 reporting 

cycle and therefore uses only the number of sites and reports per site for 2016, as derived 

in the Economic Analysis for the Final Inventory Update Reporting (IUR) Modifications 

Rule (EPA, 2011a).

Because the previous ICR covered two reporting cycles, a weighted average of 

first-year burden estimates and future-year burden estimates was used. However, because 

this ICR only covers the 2016 cycle, only the lower future-year burden estimates as 

derived in the Economic Analysis for the Final Inventory Update Reporting (IUR) 

Modifications Rule (EPA, 2011a) were used. EPA expects the majority of sites to be 

familiar with CDR reporting requirements and have some data readily available from 

previous reporting, thus reducing the per-report burden of reporting.

All costs were inflated from 2008$ to 2010$, which slightly increased the costs 

associated with the rule. EPA estimates that approximately $1.31 million of the total cost 

increase of $11.66 million is attributed to inflation.

Table 15: Total Estimate of Annual Burden Hours and Annualized Cost Comparisons

Annual Burden Hours Annual Cost

Current OMB Inventory 659,743 $40,254,393

Change in Burden due to 

Adjustments -16,920 $542,228

Change in Burden due to 

Program Changes 0 $0

Total Change in Burden -16,920 $542,228

Total Burden 642,823 $40,796,621

6(f) Burden Statement

The annual public burden for this collection of information, which is approved 

under OMB Control No. 2070-0162, is estimated to average about 40.1 hours per 

response. Burden is defined in 5 CFR 1320.3(b). An agency may not conduct or sponsor, 

and a person is not required to respond to, a collection of information unless it displays a 

currently valid OMB control number. The OMB control number for this information 

collection appears above. The OMB control numbers for EPA's regulations in title 40 of 

the CFR, after appearing in the Federal Register when approved, are listed in 40 CFR 

Part 9, are displayed either by publication in the Federal Register or by other appropriate 

means, such as on the related collection instrument or form, if applicable. The display of 

OMB control numbers in certain EPA regulations is consolidated in 40 CFR Part 9.

To comment on the Agency’s need for this information, the accuracy of the 

provided burden estimates, and any suggested methods for minimizing respondent 
35

burden, including the use of automated collection techniques, EPA has established a 

public docket for this ICR under Docket ID No. EPA-HQ-OPPT-2011-0709. The docket 

is available for public viewing at the Pollution Prevention and Toxics Docket in the EPA 

Docket Center (EPA/DC). The EPA/DC Public Reading Room is located in the EPA 

West Building, Room 3334, 1301 Constitution Ave., NW., Washington, DC. The 

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

Friday, excluding legal holidays. The telephone number for the EPA/DC Public Reading 

Room is (202) 566-1744, and the telephone number for the Pollution Prevention and 

Toxics Docket is (202) 566-0280. An electronic version of the public docket is available 

through the Federal Docket Management System (FDMS) at www.regulations.gov. Use 

FDMS to submit or view public comments, access the index listing of the contents of the 

public docket, and to access those documents in the public docket that are available 

electronically. Once in the system, select “search,” then key in the docket ID number 

identified above. Also, you can send comments to the Office of Information and 

Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket 

ID No. EPA-HQ-OPPT-2011-0709 and OMB control number 2070-0162 in any

correspondence.
36

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BLS 2009. U.S. Bureau of Labor Statistics. Employer Costs for Employee Compensation 

Supplementary Tables: Historical Data December 2006 – December 2008. (March12, 

2009) http://www.bls.gov/ncs/ect/sp/ecsuphst.pdf.

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

Analysis Branch. Economic Analysis for the Amended Inventory Update Rule: Final 

Report (EPA-HQ-OPPT-2002-0054-0260). August 2002.

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

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

Program. June 10, 2002.

EPA, 2005. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy

Analysis Branch. Economic Analysis of IUR Modifications Final Rule (EPA-HQ 

OPPT 2004-0106-0055). July 2005. 

EPA, 2006. US EPA, Office of Pollution Prevention and Toxics, Instructions for 

Reporting for the 2006 Partial Updating of the TSCA Chemical Inventory Database. 

Nov. 2006. Available at http://www.epa.gov/iur/pubs/2006_inst_tsca_cheminv.pdf.

EPA, 2007. U.S. EPA, Office of Environmental Information. A Business Case Analysis of 

EPA’s Central Data Exchange. March, 2007. 

EPA, 2008a. ICR No. 1884.04. [Information Collection Request for] Partial Update of the 

TSCA Section 8(b) Inventory Data Base, Production and Site Report Supporting 

Statement for a Request for OMB Review under the Paperwork Reduction Act. 

September 5, 2008. EPA-HQ-OPPT-2008-0504-0002.

EPA, 2008b. U.S. EPA, Office of Pollution Prevention and Toxics, Information 

Management Division, 2006 IUR Database Statistics for IUR Modifications Rule. 

Washington, DC. December 17, 2008.

EPA, 2009a. U.S. EPA, Office of Pollution Prevention and Toxics. TSCA Section 4 

Federal Register Enforceable Consent Agreements.

http://www.epa.gov/oppt/chemtest/pubs/4eca.html. Washington, DC. Updated 

October 1, 2009.

EPA, 2009b. U.S. EPA, Office of Pollution Prevention and Toxics, Sunset Dates of 

Chemicals Subject to Final TSCA Section 4 and Related 12(b) Actions, Modified on 

September 1, 2009. http://www.epa.gov/oppt/chemtest/pubs/sunset.html. Washington, 

DC. Updated September 1, 2009.

EPA, 2010. TSCA Section 5 Premanufacture and Significant New Use Notification 

Electronic Reporting; Revisions to Notification Regulations; Final rule. Federal 

Register (75 FR 773-790), January 6, 2010) 
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EPA, 2011a. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy

Analysis Branch. Economic Analysis for the Final Inventory Update Reporting (IUR) 

Modifications Rule. June, 2011. EPA-HQ-OPPT-2009-0817.

EPA, 2011b. ICR No. 1884.05. [Information Collection Request for] Partial Update of 

the TSCA Section 8(b) Inventory Data Base, Production and Site Report Supporting 

Statement for a Request for OMB Review under the Paperwork Reduction Act. June, 

2011. EPA-HQ-OPPT-2009-0817.

OPM, 2008. Office of Personnel Management, Salary Table 2008-DCB, Washington BaltimoreNorthern Virginia, DC-MD-PA-VA-WV. Accessed from 

http://www.opm.gov/oca/08tables/pdf/DCB.pdf.
38

ATTACHMENTS TO THE SUPPORTING STATEMENT

These attachments are available in the electronic docket at www.regulations.gov, under 

Docket ID No. EPA-HQ-OPPT-2011-0709. 

Attachment 1 Toxic Substances Control Act Section 8(b) (15 USC 2607(b))

Attachment 2 40 CFR 711 - TSCA Chemical Data Reporting Requirements

Attachment 3 EPA Form 7740-8, IUR Form U