July 2010 

Supporting Statement for a Request for OMB Review under 

The Paperwork Reduction Act 

1. Identification of the Information Collection 

 1(a) Title of the Information Collection 

Title: Proposed Rule Addendum to Partial Update of the TSCA Section 8(b) 

Inventory Data Base, Production and Site Reports 

EPA ICR No.: 1884.05 OMB Control No.: 2070-0162 

1(b) Short Characterization/Abstract 

 

The following information collection request (ICR) addendum addresses the paperwork 

requirements contained in a proposed rule (RIN 2070-AJ43) that would amend the information 

collection activities of the Inventory Update Reporting (IUR) program under the Toxic 

Substances Control Act (TSCA) (40 CFR Part 710). Under TSCA section 8(a) (15 USC 2607), 

the Environmental Protection Agency (EPA) is authorized to collect certain information on 

chemicals 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 Inventory of 

Chemical Substances in Commerce (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 IUR to update 

the basic chemical production information for selected larger volume chemicals in the TSCA 

Inventory six times (every four years), beginning in 1986, and to collect additional information 

relating to the manufacture, processing, and use of those chemicals, beginning in 2006. 

EPA is proposing to amend the current IUR requirements 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) would be required to 

use e-IURweb (the Agency-provided reporting tool) to submit a completed Form U (EPA Form 

7740-8) electronically via the Internet. As proposed, the 2011 IUR would include additional 

manufacturing, processing, and use exposure-related data elements, including the volume of the 

chemical used on the reporting site; the volume of the chemical directly exported; whether the 

chemical is being recycled, remanufactured, reprocessed, reused, or reworked; and the 

production volumes for the previous years since the last principal reporting year. Additional 

amendments to the 2011 IUR would include changes to the reporting frequency from every five 

years to every four years; modifications to the method used to determine whether a manufacture 

(including importer) is subject to IUR reporting for reporting cycles subsequent to the 2011 

reporting cycle; modifications to reporting thresholds, including eliminating the upper threshold; 

revisions to industrial classifications used; revisions to the list of commercial and consumer 

product categories; and modifications to situations in which confidentiality may be claimed and 

to the process for making such claims. 

Page 1 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

Page 2 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

 OPPT will use the updated IUR data in its chemical risk-management efforts. Individual 

sites manufacturing, including importing, chemicals 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 

IUR website (www.epa.gov/iur). 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 4,221 respondents at 

an annual cost of $40.3 million during the ICR addendum period. 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 chemicals. 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 IUR rule currently is codified at 40 CFR 710. EPA is proposing to move the IUR rule 

to a new Part at 40 CFR 711. 

EPA is proposing now to modify the IUR rule1 to meet four primary goals: (1) to tailor 

the information collected to better meet the Agency’s overall information needs; (2) to increase 

its ability to effectively provide public access to the information; (3) to obtain new and updated 

information relating to potential exposures to a subset of chemical substances listed on the TSCA 

Inventory; and (4) to improve the usefulness of the information reported. EPA believes requiring 

electronic reporting; collecting comprehensive information for most reported chemicals; and 

adjusting the specific reported information, the frequency the information is reported, and 

confidential business information (CBI) claim requirements would accomplish these goals.

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

used by EPA and others in a wide range of Agency activities. EPA’s efforts to use the 2006 IUR 

data have identified areas where further improvements are needed to improve risk-screening 

capabilities. Screening level data need not be precise, but should be accurate and reliable enough 

for the Agency to develop screening-level exposure assessments. The 2011 IUR would provide 

more detailed information needed to better understand and interpret the IUR data, further 

enhancing the Agency’s ability to identify, screen, and manage potential chemical risks. Because 

exposure is a key component of risk, the IUR exposure-related information would allow OPPT to 

screen chemicals 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 

 

1

 The proposed rule is titled “TSCA Inventory Update Modifications.” 
July 2010 

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

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

review of chemicals to identify candidates for further evaluation. 

2(b) Practical Utility/Users of the Data 

 The proposed modifications associated with reporting methods and changes to the 

reporting software would ensure the information reported to EPA is accurate and in compliance 

with the IUR requirements. 

e-IURweb Reporting Software 

Beginning with the 2011 submission period, EPA is proposing to require electronic 

reporting for all IUR submissions, including joint submissions and amendments. Persons 

submitting information under the IUR rule would be required to use e-IURweb, the Agencyprovided, web-based software to complete Form U (the IUR reporting form). The information 

would be submitted electronically via the Internet, through EPA’s Central Data Exchange 

(CDX). Users of CDX are required to register with the system, including submitting an 

authorized signature agreement to EPA. 

The 2011 submission process will be similar to that available for the 2006 IUR, when 

EPA provided an opportunity for IUR respondents to send their reports electronically, through 

CDX, on a voluntary basis. Approximately one-third of the 2006 submissions were filed through 

CDX, using the 2006 e-IUR downloadable software. The elimination of paper-based submissions 

in favor of electronic reporting, including the use of e-IURweb, is expected to greatly improve 

the reporting process, both for EPA and for manufacturers (including importers). 

The 2011 e-IURweb would feature several improved capabilities over the 2006 e-IUR 

software. These improvements include an enhanced validation system, which would alert users 

when a required field on the form is either missing information or contains certain kinds of 

potentially incorrect information. EPA expects other updates to include automated chemical 

identity checks, automated company and site identity checks, and the facilitation of joint 

submissions and amendments. 

Electronic submission would also ensure that IUR data would have completed a basic 

validation check, could be quickly incorporated into a database and ready for immediate Agency 

use, and would eliminate subsequent data entry errors which occurred with paper submissions.

Furthermore, EPA believes the mandatory use of e-IURweb and CDX would reduce the 

reporting burden on industry by reducing both the cost and the time required to review, edit and 

transmit data to the Agency. 

 CDX Registration 

Each IUR submission must have an associated authorized official. The authorized official 

signs the certification statement and submits the IUR report via CDX.. During the 2006 IUR, 

respondents were required to complete an electronic signature agreement (ESA) and to submit 

Page 3 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

the agreement in hard copy with a wet ink signature to EPA in order to complete the CDX 

registration. For 2011 IUR reports, EPA is modifying the 2006 ESA to identify more clearly the 

individual(s) required to sign the agreement. To register in CDX, the CDX registrant (also 

referred to as “Electronic Signature Holder”) would download two forms: the Electronic 

Signature Agreement and the Verification of Company Authorizing Official. For identity 

authentication, the registrant would complete the ESA, sign and date it, have the form notarized, 

and mail it to EPA. The Verification of Company Authorizing Official form requires the 

signature of an immediate supervisor or witnessing official verifying that the registrant is the 

person who should sign their name in the certification statement box on Form U. Once EPA 

receives both forms, EPA would activate the registrant’s CDX account and send a notification 

via email. 

 Respondents may need or desire to have more than one individual complete an electronic 

signature agreement, so that other individuals can add information to an original IUR 

submission. Persons submitting supplemental information for an IUR submission on behalf of a 

company would need to register with CDX by signing an ESA and Verification of Support 

Submitter form. The Verification of Support Submitter form requires the signature of an 

immediate supervisor or witnessing official from the company and anyone he/she authorizes to 

submit additional information. The company official can authorize an unlimited number of 

support respondents, but will have to complete a form for each support respondent. Support 

respondents can work with an unlimited number of company officials, but will need an 

agreement with each company official (even if the company officials work at the same 

company). A support respondent may be an employee of the company, an outside consultant for 

the company, or an authorized representative agent for the company. While this individual would 

not be able to sign the certification statement required for the initial IUR submission, he or she 

would be able to provide additional information, if needed, using CDX. For 2006 and prior IUR 

submissions, respondents were not able to provide additional information electronically. 

Data Elements for IUR Submissions 

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

basic information on commercial chemicals listed on the TSCA Inventory of Chemical 

Substances, 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. EPA would use the information it is proposing to collect in the 

following ways: 

(1) Parent company identification information: Company identification information is 

collected already by the current IUR. EPA is proposing to require reporting of additional 

company identification information associated with the location of the company, and is 

clarifying that the company information is to be for the ultimate domestic parent 

company associated with the reporting plant site. These data would help ensure the 

company information is consistently provided. 

(2) Manufacturing-related information: 

Page 4 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

• The production volume for each of the years since the last principal reporting 

year: The one-year snapshot of production volume provided by the current 

IUR does not provide an accurate picture of the chemicals in commerce, and 

may provide an erroneous view of the exposure scenarios associated with a 

particular chemical substance. The high turn-over of reported chemicals from 

one submission period to the next indicates a dynamic, changing industry. 

EPA has received comments from industry concerning the year-to-year 

changes that occur for chemical production that may affect IUR reporting. 

EPA would use these data for chemical manufacturing, and processing and 

use trend analyses; and for the assessment of the effectiveness of Agency and 

public programs, among other uses. 

• The production volume of a manufactured (including imported) chemical 

substance used at the reporting site: This data element would replace the data 

element indicating that a chemical is site-limited. This new data element 

identifies whether a chemical is used by the reporting site. A domestically 

manufactured chemical would be identified as a site-limited chemical (or that 

a portion of the chemical is site-limited). An imported chemical would be 

identified as used by the importer. This information is related to potential 

exposures associated with the on-site volumes, and would provide the Agency 

with more accurate information for exposure assessments and other data 

analyses. 

• Whether an imported chemical is physically at the reporting site: This data 

element would enable the Agency and others to better assess manufacturingrelated potential exposures, thereby enabling more accurate information for 

screening-level analyses and other uses of the IUR data. 

• The production volume directly exported and not domestically processed or 

used: This data element would allow EPA to better identify the completeness 

of the reported processing and use information, by indicating the proportion of 

the production volume potentially covered by the reported processing and use 

information. IUR processing and use information is required only for 

domestic use situations, and is not required for any volumes directly exported. 

• Whether a manufactured (including imported) chemical, such as a byproduct, 

is being recycled, remanufactured, reprocessed, reused, or reworked: This 

data element would provide valuable information for Agency and public 

programs that encourage industry to find uses for wastes rather than disposing 

of the wastes, such as in a landfill. 

These data would also be used in other ways, such as in chemical 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 

Page 5 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

to measure potential human and environmental exposure under TSCA section 8(e). Each 

data element would correspond to a data point necessary for basic risk-screening. 

Under the current IUR rule, only manufacturers (including importers) of larger-volume 

chemicals are required to report processing and use information. As proposed, respondents 

would be required to report processing and use information for all reported chemical substances, 

regardless of production volume, unless the chemical substance is partially exempt. This 

proposed change provides exposure-related processing and use information to EPA and others 

for moderate-volume chemicals, enabling the Agency to address such chemicals in the same 

manner as the higher-volume chemicals. 

(3) Industrial processing and use data: This proposal does not add any industrial 

processing and use data elements. The industrial function categories would be revised to 

better identify the functions of the chemical substances. The North American Industrial 

Classification System (NAICS) codes would be replaced with industrial sector (IS) codes. 

The IS codes reduce the number of choices available to the respondent, thus streamlining 

the reporting process and making the data easier to use. 

(4) Consumer and commercial end-use exposure data: EPA is proposing to add two data 

elements: an indication of consumer or commercial use and the number of commercial 

workers. These data would be used to determine exposure potential based on consumer or 

commercial populations. These two populations are very different from each other, and 

the ability to distinguish uses between the two enables better exposure-based screening of 

the chemical. The number of commercial workers is needed to better assess the size of 

the commercial population. In addition, the product categories would be revised to better 

identify the uses of the chemical substances. 

Special Considerations for Joint Respondents

In certain situations IUR respondents currently are allowed to report the IUR information 

jointly with the supplier of the chemical substance for which the respondent is reporting. For 

example, importers may not know the specific chemical identity of the imported Inventory 

substance because the foreign supplier chooses to keep the information confidential. In addition, 

a manufacturer may not know the specific chemical identity of the substance being manufactured 

because the supplier of a reactant used to manufacture the substance chooses to keep the 

information confidential. In such situations, the manufacturer (including importer) is still 

responsible for ensuring that the IUR information is submitted to EPA and may do so by 

submitting a joint report. For example, in the case of an imported substance, the U.S. importer, as 

the primary respondent, completes the majority of the required information on Form U, and 

provides a trade name in Part II.2.A.4 to identify the chemical substance. The primary 

respondent then contacts the foreign supplier, who is the secondary respondent, to notify them of 

the need to report the specific chemical identity information directly to EPA in the joint 

submission section (Part IV) of Form U, using the e-IURweb reporting software. 

For 2006 and prior IUR submissions, respondents were not able to submit joint reports 

electronically. EPA has added Part IV to Form U to accommodate joint submissions. Because 

Page 6 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

signatures are required by each party of a joint submission, they must each register with CDX, 

complete their own sections on Form U, and submit their own sections of the same report 

electronically to EPA. The secondary respondent will not be able to access the information 

provided by the primary respondent and vice versa. The reporting tool will match both 

submissions based upon company and chemical information provided by the manufacturer 

(including importer), acting as a primary respondent, and by the supplier, acting as a secondary 

respondent. EPA will also use the identifying number assigned to the primary respondent during 

CDX registration to link the joint reports in an internal database. The information provided by 

the primary and secondary respondents will be saved and combined as one joint submission. 

EPA will process the joint submission once all Form Us are received and matched by the 

Agency. 

This information collection would allow EPA to connect submissions from the primary 

respondent and secondary respondent and to request clarification from the secondary respondent 

if needed. The data EPA proposes to collect would be utilized in the following ways: 

(1) Joint Submission Information (primary respondent only): The primary respondent 

provides only a trade name or other designation to identify the chemical substance 

being reported. Therefore, the requested data are needed by the Agency to identify the 

chemical substance correctly and provide the company name and complete mailing 

address of the secondary respondent. 

(2) Secondary Company Identification Information: These data would identify the 

secondary respondent’s company name and the complete mailing address of the 

company. The information provided would help ensure that the company information 

is provided consistently, and would be used to associate the secondary respondent’s 

company with the primary respondent’s company and site plant. 

(3) Technical Contact Information: The company’s technical contact information would 

provide EPA with the name and complete mailing address of the person who would 

be able to answer questions EPA may have about the reported chemical substance. 

(4) Primary Company Identification Information: These data would provide the primary 

respondent’s parent company name and the complete address of the company to help 

ensure that the company information is provided consistently, and would be used to 

associate the primary respondent’s company and site plant with the secondary 

respondent’s company. 

(5) Trade Product Identification Information: These data would identify the primary 

respondent’s company name, site name, and site address, as well as the CAS Registry 

Number, the appropriate specific chemical identities, and product composition. These 

data are needed by EPA to combine the secondary respondent’s chemical-specific 

information with the primary respondent’s information to result in a complete IUR 

submission. 

Page 7 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

Page 8 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

Information secured through the IUR collections is used increasingly 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, IUR 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 

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

including Right-To-Know-Net and INFORM2

. IUR data were used to identify chemicals of 

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

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

disrupters. 

 

Data reported under the 2011 IUR would enhance the capabilities of the Agency and 

other Federal agencies to ensure risk management actions are taken on chemicals 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 

would 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 chemicals and provide improved access and 

information to the public. 

 EPA would also use the information submitted through the 2011 collection to update the 

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

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

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

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 IUR data provide information about the chemicals 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 chemicals reported from one IUR submission period to the next; therefore continual 

updating of the database is essential. 

 

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 processing and use data) are not collected comprehensively or 

systematically at the national level. There are a variety of sources for certain data elements, but 

the sources are either incomplete or incompatible. 

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

 

2

 INFORM is a nonprofit environmental research organization.
July 2010 

The proposed rulemaking serves as the public notice for this ICR. Interested parties 

should submit comments referencing Docket ID No. EPA-HQ-OPPT-2009-0187 to the address 

listed at the end of this document. Responses will be taken into account in developing the final 

rulemaking. 

3(c) Consultations 

In addition to the public notice and comment period, OMB regulations, at 5 CFR 

1320.8(d)(1), require agencies to consult with potential ICR respondents and data users about 

specific aspects of an ICR before the agency submits the ICR to OMB for review and approval. 

In accordance with this regulation, EPA will solicit consultation feedback from nine potential 

respondents and data users with respect to this final rule ICR. 

3(d) Effects of Less Frequent Collection 

EPA is proposing to return the reporting frequency to every four years, 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, a review of the 2006 IUR reporting has revealed 

an approximately 30 percent change in the chemicals that are reported from one submission 

period to the next. 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 IUR Modifications proposed rule requests 

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

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

EPA. With more frequent reporting, companies would be able to establish standard systems and 

practices to collect the required information. 

 The Agency needs to be able to make accurate chemical 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 

chemicals manufactured (including imported) in the United States. As described above, the IUR 

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 can cause production volumes or chemical uses to change from one year to 

the next. Companies buy and sell plant sites, and the chemicals produced at a site can change. 

Based on past IUR reporting, the Agency would be working with the IUR 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. 

Page 9 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

 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, as specified in 40 CFR 710.57, 

exceeding the PRA maximum of three years. This is necessary to ensure companies retain 

records long enough to facilitate completion of Form U (EPA Form 7740-8) in the next 

collection, which is in four years (as proposed), and to allow EPA’s enforcement activities to 

overlap two IUR reporting cycles. 

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

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

confidential business information; 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 reported to EPA under this rule as confidential if 

such information would reveal the respondents’ 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 be made only if the other 

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

procedures to 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) Respondents/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 

IUR. The Agency’s previous experience with IUR collections has shown 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) 

Page 10 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

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

subject to IUR 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 selected by parent companies reflect the parent company’s primary activity, even 

though many 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 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 IUR and 

certain other reporting in 40 CFR 704.3. 

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

importers) of byproducts may be required to report under the IUR 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 IUR, 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 

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

IUR 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 IUR 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 IUR for that byproduct. While some manufacturers (including importers) 

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

reporting obligations under the IUR rule. 

4(b) Information Requested 

(i) Data elements, including record keeping requirements 

 The IUR data elements are 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 human or environmental exposure concentrations, 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 certain known or 

reasonably ascertainable manufacturing, processing, and use exposure-related information. For 

the 2006 IUR, respondents were required to submit the processing and use information to the 

extent it was readily obtainable; the IUR Modifications rule proposes to standardize all of the 

Page 11 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

submitted information to the single “known to or reasonably ascertainable by” reporting 

standard. 

Using e-IURweb, individuals would report the proposed data elements as follows (the 

following list identifies new or revised data elements and does not address the full data 

requirements): 

• Authorized Company Official’s e-mail Address. The e-mail address of the company 

official authorized to sign and submit the IUR Form U.

• Parent Company Name and Address. The name and mailing address of the ultimate 

domestic parent company. The requirement that the ultimate parent company reported 

be the ultimate domestic parent company is part of the IUR Modifications proposal; 

the parent company name is already required by the IUR. This is not a new 

requirement; rather the change better identifies the correct company name.

• 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 is physically at the reporting site; the 

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

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

recycled, reused, reprocessed, remanufactured, or reworked.

• Processing and Use Information. For the 2006 IUR, only those manufacturers 

(including importers) of chemicals with production volumes of 300,000 lb. or more 

were required to report processing and use information. The IUR Modifications rule 

proposes to require respondents to report this information for all reported chemicals, 

unless the chemical is specifically partially exempted. 

• Industrial Processing and Use Data. For the 2006 IUR, respondents were able to 

select up to 10 unique combinations of the type of process or use (code), NAICS code 

associated with the industrial use, and industrial function category. The IUR 

Modifications rule proposes to revise the list of industrial function categories and to 

replace the NAICS codes with Industrial Sectors.

• Consumer and Commercial Use Data. For the 2006 IUR, respondents were able to 

select up to 10 consumer and commercial product categories. The IUR Modifications 

rule proposes to revise the list of consumer and commercial product categories. The 

respondent must indicate whether the use is consumer, commercial or both, and, if 

commercial, the number of reasonably likely to be exposed commercial workers must 

be reported as a range. 

 

Page 12 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

 Joint Submissions 

 Joint submissions are allowed only in those instances where a supplier will not disclose to 

the respondent the specific chemical name of the imported Inventory substance or of a reactant 

used to manufacture the Inventory substance. This may happen, for instance, when a company is 

importing a mixture under a trade name, and the foreign manufacturer does not want to reveal 

the components in the mixture. (See Special Considerations for Joint Respondents in section 2b, 

above) Proposed changes to the IUR would make it easier for respondents to use electronic 

reporting for both the primary and the secondary portions of a joint submission. In addition to 

signing the certification statement and completing Parts I, II, and III, primary respondents would 

report on proposed data elements in Part II, Blocks 2.A.4 through 2.A.10, on Form U as follows 

(see Attachment A): 

• Joint Submission Information. Trade name of the chemical substance being reported, 

secondary company name, and complete mailing address (city, state, zip code, and 

country (if applicable)). 

 Secondary respondents would register with CDX and request to submit a joint report by 

selecting “Joint submission-as secondary respondent” on the main page of the e-IURweb 

reporting tool. They would provide the primary company’s information and the trade product 

name, supplied to them by the primary respondent, to gain access to the Form U containing 

information specific to the trade product name. After the secondary respondent is granted access 

to the form, it would report on proposed data elements in Part IV on Form U as follows (see 

Attachment A): 

• Certification. The company official must certify by signature and date that to the best 

of his/her knowledge and belief: 1) all information entered on Form U has been 

completed in compliance with the regulatory requirements; and 2) any confidentiality 

claims are true and correct as to that information for which they have been asserted. 

• Secondary Company Information. The secondary company name and complete 

mailing address (city, state, zip code, and country (if applicable)). 

• Secondary Technical Contact Information. The technical contact name, phone 

number, complete mailing address (city, state, zip code, and country (if applicable)), and 

email address. 

• Primary Company Information. The primary company name, site name, and complete 

mailing address ((city, state, and zip code). 

• Trade Product Information. The trade product name, chemical name, CAS Registry 

Number, ID code, and percentage of each chemical component of a trade product. 

 (ii) Respondent Activities/Information Collections (ICs) 

Page 13 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

 EPA identified the following ICs in the currently-approved ICR (EPA ICR No. 1884.04) 

for activities that respondents would complete when complying with the existing rule: 

• Compliance Determination; 

• Rule Familiarization; 

• Report Preparation and Submission – Partial Reports; 

• Report Preparation and Submission - Full Reports; and 

• Recordkeeping. 

As a result of this proposed rule, EPA would include a new IC addressing the initial 

paperwork activities a company would need to complete in order to be able to submit reports 

electronically through CDX. EPA also would incorporate recordkeeping activities into the ICs 

that address the preparation and submission of partial and full reports, rather than include them 

as a stand-alone IC (see Table 1). 

Table 1: Information Collections (ICs) for IUR Reporting 

Information 

Collection 

Description 

Compliance 

Determination 

Determine whether reporting is required for a chemical manufactured 

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

production volume and the applicability of certain reporting exemptions. 

The proposed rule would modify the method used to determine whether a 

manufacturer (including importer) is subject to IUR reporting. Reporting 

would be required if the production volume of a chemical substance met 

or exceeded the 25,000 lb. threshold in the 2010 principal reporting year 

for the 2011 submission period, and in any calendar year since the last 

the last principal reporting year in future reporting cycles 

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. 

CDX Registration 

Activities 

The proposed rule would require electronic reporting, and therefore 

would require that all respondents complete the CDX registration 

process. As part of registering with CDX, each respondent would provide 

identifying information that would comprise all or most of the 

information requested in Part I of Form U (EPA Form 7740-8). This 

information will then be pre-populated whenever the respondent prepares 

a partial or full report. 

In order to submit electronically to EPA via CDX, the respondent’s 

authorized official, who will be signing and submitting the site’s IUR 

Form U, must register with CDX and must submit an Electronic 

Signature Agreement (ESA) and a Verification of Company Authorizing 

Official form. This is the same process required for electronic 

Page 14 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

submissions for the 2006 IUR. 

Once the registration process is completed, the registered individual 

would receive a case number and be able to access the e-IURweb 

reporting software. 

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 eIURweb to complete and submit only Parts I and II (and Part IV, if a joint 

submission) of Form U (EPA Form 7740-8) for chemicals specifically 

listed in the proposed regulation for which there is a partial reporting 

exemption. Retain all records related to the submission for five years 

after the submission period. 

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-IURweb to complete and submit Parts I, II, and III (and Part IV, if a 

joint submission) of Form U (EPA Form 7740-8) for all reportable 

chemical substances. 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 questions and provide any necessary assistance; 

• Process submissions for inclusion in IUR database; 

• Review requests for confidentiality in the submissions; 

• Maintain the database; and 

• Distribute the data. 

5(b) Collection Methodology and Management 

 The next IUR collection will occur in 2011. 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 this proposed rule that they manufacture (including 

import) in quantities that meet or exceed the IUR thresholds. As proposed, the collection would 

occur every four years. 

 (i) Collection Methodology

Page 15 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

 Respondents would be required to submit information associated with this data collection 

electronically via the Internet using e-IURweb and CDX. The 2006 IUR allowed and encouraged 

electronic reporting, thus providing both respondents and the Agency the opportunity to test an 

electronic reporting system. Comments from respondents and lessons learned from the collection 

of paper, CD, and electronic submissions were used to develop the 2011 collection methodology. 

Some of the changes to this methodology are regulatory and are included in the IUR 

Modifications proposal; others are process-oriented or internal to EPA or the respondent. 

 Potential respondents would be notified of the need to report in three ways: (1) EPA 

plans to publish a Federal Register notice, (2) email notices will be sent to previous IUR 

respondents, and (3) articles will be published in the trade press. Reporting materials, including a 

non-submission version of the e-IURweb reporting software and a variety of guidance 

documents (Instruction Manual, Q&As, Case Studies), will be available on EPA’s IUR website. 

Respondents also can obtain these materials from the TSCA Hotline. Respondents obtain the 

submission version of the e-IURweb reporting software as part of the CDX registration process, 

as described in section 4 of this document. 

 As proposed, EPA will receive all IUR submissions electronically. The CDX registration 

process, required for all respondents, would provide a case number which the respondent would 

use to identify its submission and which the Agency would use to track any additional 

information or changes related to that submission. EPA believes this is an improvement over the 

2006 IUR, which resulted in the generation of several identifying numbers by either the 

respondent or EPA. 

Information quality and validation begins with the e-IURweb reporting tool, which will 

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

required by the IUR rule. Use of e-IURweb will eliminate many of the problems with incorrect 

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

Inventory chemicals and their associated identification numbers. Other respondent-generated 

errors, such as incorrect codes, will also be eliminated due to the use of techniques such as dropdown menus, restrictions on the specific information that can be entered, and error-checking 

algorithms. 

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

respondents and EPA. Respondents receive almost immediate notification that EPA has received 

their submission, and EPA is able to upload the information directly into the IUR 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 will be 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 IUR requirements or submission 

process. When Hotline staff are unable to answer questions, the respondent 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. 

Page 16 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

(ii) Data Management

 This section describes the Agency tasks required for efficiently processing submissions 

under the IUR. 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. 

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

database is then available to EPA technical reviewers to search or export into their various 

analytical modeling systems and databases. The IUR 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 database that serves as the 

primary data storage medium for IUR collections. File servers with appropriate backup 

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

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

(MTS) database. In addition, IUR 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 respondents in complying with IUR requirements. The guidance documents 

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

• Form U Processing -- The Agency is responsible for processing IUR Form U 

submissions. This includes developing standard operating procedures and documentation 

for all stages in the IUR 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 2011 IUR submission period, EPA 

will develop new processes to receive IUR submissions over the Internet, using CDX. 

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

with the reporting software 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 

 The current IUR regulation provides ample flexibility to small entities. This regulation 

affects only businesses -- governmental jurisdictions and not-for-profit organizations are not 

Page 17 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

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 submission 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 Proposed Inventory Update Reporting 

Modifications Rule determined that the impact on these companies is, on average, significantly 

less than one percent of revenues (EPA 2009). 

5(d) Collection Schedule 

 The submission period shall be from June 1, 2011 to September 30, 2011. This 

submission period/schedule follows the requirements of 40 CFR 710.53 (proposed 40 CFR 

711.19). 

Federal Register Notice February 2011 

Send out e-mail to 2006 IUR e-mailing list 

with instructions describing how to obtain the 

reporting form 

March 2011 

Public Outreach efforts: articles in industry 

press, meetings with regulated community, and 

information on the IUR website 

March 2011 

Open period for submitting 2011 IUR Forms June 1 - September 30, 2011 

6. Estimating the Burden and Cost of the Collection 

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

result of the proposed IUR rule amendments. This addendum to the supporting statement covers 

the years 2011, 2012, and 2013. Therefore, it provides burden and cost estimates for the 

information collection corresponding to the 2011 reporting cycle (which is the first submission 

after the proposed amendments to the IUR rule are finalized), and also for the information 

collection corresponding to the next reporting cycle, for which respondents will be preparing 

during 2012 and 2013. Even though reporting occurs only once per reporting cycle (once every 

five years for the 2011 cycle and, as proposed, every four years in the future), 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 2008 dollars. The IUR 

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

considered a respondent and is likely to submit one Form U containing one or more chemicalspecific reports. EPA estimates that a total of 4,085 respondents will respond to this information 

Page 18 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

collection in the 2011 reporting cycle, and 4,289 respondents will respond in future reporting 

cycles. 

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

average of 29,253 full reports and 618 partial reports during the first reporting cycle, and 30,716 

full reports and 649 partial reports in future reporting cycles. Each report is for a single 

chemical/site combination. Each site is expected to submit an average of 7.16 full reports and 

0.15 partial reports. The average burden per respondent, which is one site, is estimated to be 792 

hours for the 2011 reporting cycle, or 158 hours annually over a five-year cycle. For future fouryear reporting cycles, the average burden per respondent is estimated to be 615 hours per cycle, 

or 154 hours annually, over a four-year cycle. Given that this ICR addendum covers a time 

period that spans both the first and a future reporting cycle, the average annual burden over the 

three year period of 2011 through 2013 is 155 hours. This is higher than the burden estimated for 

the currently approved ICR) (EPA ICR No. 1884.04, due to both program changes and an 

adjustment in reporting requirement criteria, including additional data requirements and 

modifications to reporting thresholds. 

6(a) Estimating Respondent Burden

 For the 2011 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 in the 

2010 principal reporting year. In future cycles, this reporting threshold will apply for 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, 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. Under the proposed amendments, Part III would be completed for all chemicals 

unless the chemical 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.” Each report is submitted for a unique 

chemical/site combination; that is, a site must complete a separate report for each applicable 

chemical, but Part I of Form U is completed only once per site. EPA anticipates that it will be 

completed when respondents register with CDX. To comply with the regulation, manufacturers 

(including importers) must complete the following activities in Table 2. Table 2 also provides a 

cross-walk of the related Information Collection that corresponds to each activity. 

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 manufactured (including 

imported) at a particular site, based on the 

chemical’s production volume and the applicability 

Compliance Determination 

Page 19 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

Page 20 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

of certain reporting exemptions. This involves 

determining whether the production volume of a 

chemical substance met or exceeded the 25,000 lb. 

threshold in the 2010 principal reporting year for the 

2011 submission period, and in any calendar year 

since the last principal reporting year in future 

reporting cycles. 

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 notarized; complete a 

Verification of Company Authorizing Official form, 

which is signed by an immediate supervisor or 

witnessing official; and mail both forms 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 chemicals 

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 RecordsPartial 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 RecordsFull 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 IUR respondents selected from the 

IUR 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 current proposal were derived as described in the Economic Analysis 

for the Proposed Inventory Update Reporting (IUR) Modifications Rule (EPA, 2010b). 

 

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. 
July 2010 

Page 21 of 49

 

 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

 

 Table 3 and Table 4 illustrate the burden for a typical respondent on a per-activity basis, 

including time required to complete each section of Form U. Because IUR reporting for all 

respondents occurs within a required timeframe, which EPA is proposing to change from once 

every five years to once every four years, the Agency expects only one collection to occur, in 

2001, during the three-year period covered by this ICR addendum. Therefore, burden hour 

estimates for 2011 (Table 3) are based on the first reporting cycle burdens in the Economic 

Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule (EPA, 2010b). 

Burden hour estimates for 2012 and 2013 (Table 4) are based on the future reporting cycle 

burdens as also described in the economic analysis (EPA, 2010b).4

 The section-by-section 

industry burden estimates for report preparation also include the burden of compliance 

determination and rule familiarization. EPA estimates the total industry burden for completing 

and submitting one partial report to be 57.36 hours, and the estimated burden for completing and 

submitting one full report, to be 140.38 hours in the first reporting cycle. Each site is expected to 

submit an average of 7.16 full reports and 0.15 partial reports. 

 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 IUR EA 

(EPA, 2010b). 

4

 EPA believes that the burden for future reporting cycles will be reduced because of efficiencies achieved through 

the establishment of compliance processes; as described in the IUR EA (EPA, 2010b). After a site’s first reporting 

cycle, the availability of data from previous reporting cycles and familiarity with reporting requirements will 

expedite the process for submitters who have previously submitted a Form U. 
July 2010 

Table 3: Total Industry Burden, by Activity, First Reporting Cycle 

Clerical Burden 

(hours) 

Technical Burden 

(hours) 

Ma

B

(h

Activity 

(a) (b) 

PREPARATION OF REPORT (Includes rule familiarization associated with each data element) Part I. Site Identification Information 

Certification 0.00 0.85 

Company Information (Parent Company Name, D&B Number, Mailing Address, Technical Contact, Technical Contact Mailing Address) 

0.00 0.04 

Plant Site Identification (Site Name, D&B Number, Mailing Address) 0.00 0.06 Total for Part I 0.00 0.95 

Part II. Manufacturing Information

Site-Limited, Activity, Production Volume (lb.) 0.00 2.28 Chemical Identification Upfront CBI Substantiation 0.00 1.45 Plant Site Upfront Substantiation 0.00 0.83 

Total Number of Workers 0.00 1.43 

Maximum Concentration, Physical Form, Percent Volume of Production 0.00 2.79 Production Volume for Each of the Years since Last Principal Reporting Year 0.00 4.10 Production Volume Used On-Site 0.00 0.20 Whether Imported Chemical is Physically at Reporting Site 0.00 0.11 Volume Exported 0.00 1.03 Whether a Chemical is to be Recycled, Remanufactured, Reprocessed, Reused, or Reworked 0.00 0.11 Total for Part II 0.00 14.34 

Part III. Processing and Use Information 

Upfront Substantiation for Processing and Use Information CBI Claims 0.00 0.43 

Industrial Processing and Use Exposure-Related Data 

Determination of Applicability 0.00 1.01 Industrial Function Category 0.00 4.67 Sector 0.00 0.94 

Page 22 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

Page 23 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

Clerical Burden 

(hours) 

Technical Burden 

(hours) 

Ma

B

(h

Activity 

(a) (b) 

Percent of Production Volume 0.00 10.00 Total Number of Processing and Use Sites 0.00 9.14 Total Number of Potentially Exposed Workers 0.00 15.43 

Consumer and Commercial Use Exposure-Related Data 

Determination of Applicability 0.00 0.94 Identification of Production Category/Use by Children 0.00 1.68 Percent of Production Volume 0.00 1.26 Maximum Concentration by Category 0.00 1.36 Number of Commercial Workers Reasonably Likely to be Exposed 0.00 15.43 

Total for Part III 0.00 62.26 

COMPLIANCE DETERMINATION 

Compliance Determination 0.00 2.50 

RULE FAMILIARIZATION 

Rule Familiarization 0.00 19.00 

CDX REGISTRATION ACTIVITIES 

CDX Registration 0.00 0.73 CDX Electronic Signature Agreement 0.00 1.00 

Total for CDX Registration Activities 0.00 1,73 

RECORDKEEPING 

Recordkeeping 0.75 1.50 

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

Rule Familiarization, Recordkeeping and CDX Registration Activities) 0.75 38.29 

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

Rule Familiarization, Recordkeeping and CDX Registration Activities) 0.75 100.55 

Note: Totals may not sum due to rounding.Source: Economic Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule (EPA, 2010b).
July 2010 

Table 4: Total Industry Burden, by Activity, Future Reporting Cycles 

Clerical Burden 

(hours) 

Technical Burden 

(hours) 

Ma

B

(h

Activity 

(a) (b) 

PREPARATION OF REPORT (Includes rule familiarization associated with each data element) Part I. Site Identification Information 

Certification 0.00 0.85 

Company Information (Parent Company Name,, D&B Number, Mailing Address, Technical Contact, Technical Contact Mailing Address) 

0.00 0.01 

Plant Site Identification (Site Name, D&B Number, Mailing Address) 0.00 0.01 Total for Part I 0.00 0.95 

Part II. Manufacturing Information

Site-Limited, Activity, Production Volume (lb.) 0.00 1.82 Chemical Identification Upfront CBI Substantiation 0.00 1.16 Plant Site Upfront Substantiation 0.00 0.66 

Total Number of Workers 0.00 1.14 

Maximum Concentration, Physical Form, Percent Volume of Production 0.00 2.23 Production Volume for Each of the Years since Last Principal Reporting Year 0.00 3.28 Production Volume Used On-Site 0.00 0.16 Whether Imported Chemical is Physically at Reporting Site 0.00 0.09 Volume Exported 0.00 0.82 Whether a Chemical is to be Recycled, Remanufactured, Reprocessed, Reused, or Reworked 0.00 0.09 Total for Part II 0.00 11.47 

Part III. Processing and Use Information 

Upfront Substantiation for Processing and Use Information CBI Claims 0.00 0.43 

Industrial Processing and Use Exposure-Related Data 

Determination of Applicability 0.00 0.81 Industrial Function Category 0.00 3.53 Sector 0.00 0.75 

Page 24 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

Page 25 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

Clerical Burden 

(hours) 

Technical Burden 

(hours) 

Ma

B

(h

Activity 

(a) (b) 

Percent of Production Volume 0.00 8.00 Total Number of Processing and Use Sites 0.00 7.31 Total Number of Potentially Exposed Workers 0.00 12.34 

Consumer and Commercial Use Exposure-Related Data 

Determination of Applicability 0.00 0.75 Identification of Production Category/Use by Children 0.00 0.67 Percent of Production Volume 0.00 1.01 Maximum Concentration by Category 0.00 1.09 Number of Commercial Workers Reasonably Likely to be Exposed 0.00 12.34 

Total for Part III 0.00 49.03 

COMPLIANCE DETERMINATION 

Compliance Determination 0.00 2.50 

RULE FAMILIARIZATION 

Rule Familiarization 0.00 2.00 

CDX REGISTRATION ACTIVITIES 

CDX Registration 0.00 0.73 CDX Electronic Signature Agreement 0.00 1.00 

Total for CDX Registration Activities 0.00 1.73 

RECORDKEEPING 

Recordkeeping 0.75 1.50 

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

Rule Familiarization, Recordkeeping and CDX Registration Activities) 0.75 18.34 

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

Rule Familiarization, Recordkeeping and CDX Registration Activities) 0.75 67.37 

Note: Totals may not sum due to rounding.Source: Economic Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule (EPA, 2010b).
July 2010 

Page 26 of 49

 

 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

6(b) Estimating 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 2008 (BLS, 2009). 

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 2008 dollars. Table 5 contains the loaded wage rates for the managerial, technical 

and clerical occupation categories. 

Table 5: Derivation of Loaded Wage Rates for the Private Manufacturing Sector in 2008$ 

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) 

Managerial $43.22 $19.46 48.37% 17% 1.62 $70.03 

Technical $35.29 $17.55 47.58% 17% 1.67 $58.84 

Clerical $17.22 $8.33 45.03% 17% 1.65 $28.48 1 Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006 – December 

2008, US Bureau of Labor Statistics, March 12, 2009 (BLS, 2009). 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 6 contains the cost per activity of completing Form U for one respondent in the 

first reporting cycle. Burden hours presented in Table 3 were multiplied by the corresponding 

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

partial report in the first reporting cycle is $3,538 and the cost for completing and submitting one 

full report is $8,655. More information on the derivation of these costs is found in the IUR EA 

(EPA, 2010b). 

Similarly, Table 7 contains the cost per activity of completing Form U for one respondent 

in future reporting cycles. 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 $1,636 and the cost for completing and 

submitting one full report is $5,684. More information on the derivation of these costs is found in 

the IUR EA (EPA, 2010b). 
July 2010 

Table 6: Total Industry Cost, by Activity, First Reporting Cycle 

Clerical Cost 

(2008$) 

Technical Cost 

(2008$) 

Ma

(

Activity 

(a) (b) 

PREPARATION OF REPORT (Includes rule familiarization associated with each data element) Part I. Site Identification Information 

Certification $0.00 $50.01 

Company Information (Parent Company Name, D&B Number, Mailing Address, Technical Contact, Technical Contact Mailing Address) 

$0.00 $2.35 

Plant Site Identification (Site Name, D&B Number, Mailing Address) $0.00 $3.53 Total for Part I $0.00 $55.90 

Part II. Manufacturing Information

Site-Limited, Activity, Production Volume (lbs) $0.00 $134.15 Chemical Identification Upfront CBI Substantiation $0.00 $85.32 Plant Site Upfront Substantiation $0.00 $48.84 Total Number of Workers $0.00 $84.14 Maximum Concentration, Physical Form, Percent Volume of Production $0.00 $164.16 Production Volume for Each of the Years since Last Principal Reporting Year $0.00 $241.48 Production Volume Used On-Site $0.00 $11.71 Whether Imported Chemical is Physically at Reporting Site $0.00 $6.71 Volume Exported $0.00 $60.37 Whether a Chemical is to be Recycled, Remanufactured, Reprocessed, Reused, or Reworked $0.00 $6.71 Total for Part II $0.00 $843.58 

Part III. Processing and Use Information 

Upfront Substantiation for Processing and Use Information CBI Claims $0.00 $25.12 

Industrial Processing and Use Exposure-Related Data 

Determination of Applicability $0.00 $59.27 Industrial Function Category $0.00 $274.49 Sector $0.00 $55.01 

Page 27 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

Page 28 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

Clerical Cost 

(2008$) 

Technical Cost 

(2008$) 

Ma

(

Activity 

(a) (b) 

Percent of Production Volume $0.00 $588.41 Total Number of Processing and Use Sites $0.00 $537.89 Total Number of Potentially Exposed Workers $0.00 $907.74 

Consumer and Commercial Use Exposure-Related Data 

Determination of Applicability $0.00 $55.01 Identification of Production Category/Use by Children $0.00 $98.73 Percent of Production Volume $0.00 $74.02 Maximum Concentration by Category $0.00 $80.02 Number of Commercial Workers Reasonably Likely to be Exposed $0.00 $907.74 

Total for Part III $0.00 $3,663.47 

COMPLIANCE DETERMINATION 

Compliance Determination $0.00 $147.10 

RULE FAMILIARIZATION 

Rule Familiarization $0.00 $1,117.95 

CDX REGISTRATION ACTIVITIES 

CDX Registration $0.00 $43.15 

CDX Electronic Signature Agreement $0.00 $58.84 

Total for CDX Registration Activities $0.00 $101.99 

RECORDKEEPING 

Recordkeeping $21.36 $88.26 

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

Rule Familiarization, Recordkeeping and CDX Registration Activities) $21.36 $2,354.77 

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

Rule Familiarization, Recordkeeping and CDX Registration Activities) $21.36 $6,018.24 

Note: Totals may not sum due to rounding.Source: Economic Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule (EPA, 2010b).
July 2010 

Table 7: Total Industry Cost, by Activity, Future Reporting Cycles 

Clerical Cost 

(2008$) 

Technical Cost 

(2008$) 

Ma

(

Activity 

(a) (b) 

PREPARATION OF REPORT (Includes rule familiarization associated with each data element) Part I. Site Identification Information 

Certification $0.00 $50.01 Company Information (Parent Company Name, D&B Number, Mailing Address, Technical Contact, Technical Contact Mailing Address) 

$0.00 $0.47 

Plant Site Identification (Site Name, D&B Number, Mailing Address) $0.00 $0.71 Total for Part I $0.00 $51.19 

Part II. Manufacturing Information

Site-Limited, Activity, Production Volume (lbs) $0.00 $107.32 Chemical Identification Upfront CBI Substantiation $0.00 $68.25 Plant Site Upfront Substantiation $0.00 $39.07 Total Number of Workers $0.00 $67.31 Maximum Concentration, Physical Form, Percent Volume of Production $0.00 $131.33 Production Volume for Each of the Years since Last Principal Reporting Year $0.00 $193.18 Production Volume Used On-Site $0.00 $9.37 Whether Imported Chemical is Physically at Reporting Site $0.00 $5.37 Volume Exported $0.00 $48.30 Whether a Chemical is to be Recycled, Remanufactured, Reprocessed, Reused, or Reworked $0.00 $5.37 Total for Part II $0.00 $674.87 

Part III. Processing and Use Information 

Upfront Substantiation for Processing and Use Information CBI Claims $0.00 $25.12 

Industrial Processing and Use Exposure-Related Data 

Determination of Applicability $0.00 $25.12 Industrial Function Category $0.00 $0.00 Sector $0.00 $47.41 

Page 29 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 
July 2010 

Page 30 of 49 Office of Pollution Prevention and Toxics 

 U.S. Environmental Protection Agency 

Clerical Cost 

(2008$) 

Technical Cost 

(2008$) 

Ma

(

Activity 

(a) (b) 

Percent of Production Volume $0.00 $207.82 Total Number of Processing and Use Sites $0.00 $44.01 Total Number of Potentially Exposed Workers $0.00 $470.73 

Consumer and Commercial Use Exposure-Related Data 

Determination of Applicability $0.00 $47.41 Identification of Production Category/Use by Children $0.00 $207.82 Percent of Production Volume $0.00 $44.01 Maximum Concentration by Category $0.00 $470.73 Number of Commercial Workers Reasonably Likely to be Exposed $0.00 $430.32 

Total for Part III $0.00 $2,884.62 

COMPLIANCE DETERMINATION 

Compliance Determination $0.00 $147.10 

RULE FAMILIARIZATION 

Rule Familiarization $0.00 $117.68 

CDX REGISTRATION ACTIVITIES 

CDX Registration $0.00 $43.15 CDX Electronic Signature Agreement $0.00 $58.84 

Total for CDX Registration Activities $0.00 $101.99 

RECORDKEEPING 

Recordkeeping $21.36 $88.26 

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

Rule Familiarization, Recordkeeping and CDX Registration Activities) $21.36 $1,079.09 

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

Rule Familiarization, Recordkeeping and CDX Registration Activities) $21.36 $3,963.71 

Note: Totals may not sum due to rounding.Source: Economic Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule (EPA, 2010b).
6(c) Estimating Agency Burden and Cost

EPA is responsible for the following activities associated with administering the IUR 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 IUR-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 0.181 FTEs are needed at the GS 12 level for 

quality control of data entry. Calculations of the Agency burden are presented in Economic 

Analysis for the Proposed Inventory Update Reporting (IUR) Modifications Rule (EPA, 2010b). 

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-PA-VA-WV 

locality pay area for 2008 (OPM, 2008). 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. 

Table 8 shows the loaded wage rates for Agency staff at the GS-12 Step 3, and GS-13 

Step 3 levels. 

Page 31 of 49 
Table 8: Derivation of Loaded Agency Wage Rates (2008$) 

Pay Grade Annual 

Salary 

Overhead and Fringe 

Benefits 

(% of wages) 

Overhead and Fringe 

Benefit Cost Total 

GS 12 Step 3 $77,416 58% $44,901 $122,317 

GS 13 Step 3 $88,493 58% $51,326 $139,819 

Source: The unloaded Federal salary for 2008 is from the Office of Personnel Management salary table 

for Washington-Baltimore-Northern Virginia (OPM, 2008). 

Table 9 contains the burden and cost per report for all EPA staff activities. 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 $139,819. 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 0.000054 FTE per report and the total cost per-report 

is approximately $0.81. The burden and cost of processing each data element in Form U are 

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

Modifications Rule (EPA, 2010b). 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, 2010b).

Table 9: EPA Staff Burden and Cost of Processing One Report 

Activity 

Agency Burden 

per Activity 

(FTE) 

Agency Burden 

per Activity 

(hours) 

Agency Cost 

per Activity 

(2008$) 

GS-12 Step 3 per-Report Burden 

Quality Control of Data for Part I 0.0000009 0.0019 $0.11 

Quality Control of Data for Part II 0.0000027 0.0056 $0.33 

Quality Control of Data for Part III 0.0000030 0.0063 $0.37 

Total GS-12 Burden, per report 0.0000066 0.0138 $0.81 

GS-13 Step 3 Fixed Cost Burden 

Systems development, and contract 

oversight and management 1 2,080 $139,819 

Total GS-13 Burden, per 

reporting cycle 1 2,080 $139,819 

 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, as presented in Table 10. 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. All fixed costs are taken from the last published ICR and were 

inflated from 2007 to 2008 dollars with an inflation factor calculated using the Employment Cost 

Index (ECI), seasonally adjusted, for white-collar occupations in private industry (BLS, 2009). 

Page 32 of 49 
EPA calculated the cost estimate per report for document receipt, tracking, and data 

entry, $0.63, by starting with the cost estimated in the 2007 ICR, and updating it to reflect the 

new data elements and the electronic submission requirement in the proposed amendments. The 

reduction in burden caused by the electronic submission requirement is based on a study 

conducted by EPA, “A Business Case Analysis of EPA’s Central Data Exchange” (EPA, 2007), 

of the costs and benefits of the electronic Central Data Exchange (CDX) system. The study 

estimates an 88.6 percent decrease in EPA processing burden as a result of using the CDX 

system. For more information, see the Economic Analysis for the Proposed Inventory Update 

Reporting (IUR) Modifications Rule (EPA, 2010b). 

Table 10: Cost of Contractor Activities

Activity Annual Cost 

(2007$) 

Inflation 

Factor 

Annual Cost 

(2008$) 

Variable Costs 

Document receipt, tracking, and data 

entry for Part I $0.78 n/a $0.09 

Document receipt, tracking, and data 

entry for Part II $1.92 n/a $0.25 

Document receipt, tracking, and data 

entry for Part III $2.45 n/a $0.29 

Total Cost of Document receipt, 

tracking, and data entry, per full 

report 

$5.14 n/a $0.63 

Fixed Costs 

Maintaining and Operating Back-Up 

Systems $56,711 1.04 $59,145 

Printing and Publishing Forms and 

Materials $5,298 1.04 $5,525 

Managing the TSCA Hotline $42,855 1.04 $44,694 

Total Fixed Cost $104,864 n/a $109,364 

 

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

 

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

rule, including the proposed amendments. The next IUR submission period will occur in 2011 

for chemicals manufactured (including imported) during the calendar year 2010. Even though 

reporting occurs only once per reporting cycle (once every five years for the 2011 cycle and, as 

proposed, once every four years in the future), 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 ICR addendum supporting statement is for the three-year period of 2011 through 2013; 

therefore, average annual figures for each of these three years are presented below. 

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 

Page 33 of 49 
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 2011 reporting cycle. In the 2011 reporting year, EPA expects a total of 4,085 sites to 

submit 29,253 full reports (98 percent of all reports) and 618 partial reports (two percent of all 

reports) for a total of 29,871 reports. In future reporting cycles, EPA expects 4,289 sites to 

submit 30,716 full reports and 649 partial reports for a total of 31,365 reports (98 percent and 

two percent of all reports, respectively). 

 

Total Industry Burden/Cost for First Reporting Cycle. EPA estimates the total 

industry burden for the first reporting cycle, including both current baseline burden and the 

burden resulting from the proposed amendments, to be 3.24 million hours. Given that this data 

collection is part of a five-year reporting cycle, EPA estimates the annual industry burden for 

2011 to be 647,016 hours. As presented in Table 11, EPA estimates the total cost to industry 

would be $199 million, or an annual cost of $39.7 million. 

Table 11: Estimated Respondent Burden and Cost Associated with the First Reporting Cycle (2011)

Activity 

Total 

Burden 

per 

Activity 

(hours) 

Total 

Number of 

Units 

Total 

Cost per 

Activity 

(2008$) 

Total 

Burden 

per 

Reporting 

Cycle 

(hours) 

Total Cost 

per 

Reporting 

Cycle 

(2008$)

Annual 

Burden 

(hours)

Annual 

Cost 

(hours) 

Compliance 

Determination 

(per Site) 

2.50 4,085 Sites $147.10 10,213 $600,896 2,043 $120,179 

Rule 

Familiarization 

(per Site) 

28.00 4,085 Sites $1,748.19 114,380 $7,141,370 22,876 $1,428,274 

CDX Registration 

Activities (per Site) 2.67 4,085 Sites $111.36 10,893 $454,905 2,179 $90,981 

Part I Preparation 

(per site) 2.00 4,085 Sites $129.43 8,170 $528,706 1,634 $105,741 

Partial Report 

Preparation 

(Part II, per Report) 

19.19 618 Partial 

Reports $1,183.56 11,861 $731,438 2,372 $146,288 

Full Report 

Preparation 

(Part II and Part 

III, 

 per Report) 

102.21 29,253 Full 

Reports $6,300.50 2,989,951 $184,308,643 597,990 $36,861,729 

Recordkeeping 

 (per Report) 3.00 29,871 

Reports $162.14 89,613 $4,843,211 17,923 $968,642 

Total Industry Burden and Cost for the First Reporting 

Cycle 3,235,080 $198,609,168 647,016 $39,721,834 

Page 34 of 49 
Total Industry Burden and Cost for Future Reporting Cycles. EPA estimates the total 

industry burden for future reporting cycles, including both current baseline burden and the 

burden resulting from the proposed amendments, to be 2.64 million hours. Given that this data 

collection will occur every four years, EPA estimates the annual industry burden for future years 

to be 659,742 hours. As presented in Table 12, EPA estimates the total cost to industry would be 

$162 million, or an annual cost of $40.5 million.

Table 12: Estimated Annual Respondent Burden and Cost Associated with Future Reporting 

Cycles

Activity 

Total 

Burden 

per 

Activity 

(hours) 

Total 

Number of 

Units 

Total 

Cost per 

Activity 

(2008$) 

Total 

Burden 

(hours) 

Total Cost 

per 

Reporting 

Cycle 

(2008$) 

Annual 

Burden 

(hours) 

Annual 

Cost 

(hours) 

Compliance 

Determination 

(per Site) 

2.50 4,289 Sites $147.10 10,723 $630,904 2,681 $157,726 

Rule Familiarization 

(per Site) 4.00 4,289 Sites $257.73 17,156 $1,105,419 4,289 $276,355 

CDX Registration 

Activities (per Site) 2.67 4,289 Sites $167.35 11,437 $717,751 2,859 $179,438 

Part I Preparation 

(per Site) 1.89 4,289 Sites $122.48 8,098 $525,309 2,024 $131,327 

Partial Report 

Preparation 

(Part II, per Report) 

15.35 649 Partial 

Reports $946.85 9,964 $614,503 2,491 $153,626 

Full Report 

Preparation 

(Part II and Part 

III, per Report) 

80.98 30,716 Full 

Reports $4,994.25 2,487,494 $153,403,359 621,873 $38,350,840 

Recordkeeping 

 (per Report) 3.00 31,365 

Reports $162.14 94,095 $5,085,444 23,524 $1,271,361 

Total Industry Burden and Cost for 

Future Reporting Cycles 2,638,966 $162,082,689 659,742 $40,520,672 

Page 35 of 49 
Annual Industry Burden and Cost for 2011 to 2013. As shown in Table 13, EPA 

calculated the estimated total annual respondent burden and cost associated with this ICR 

addendum by taking a weighted average of the first and future reporting cycles, to reflect that the 

period covered by this ICR, 2011 through 2013, spans two reporting cycles with different 

burdens and costs. The total annual burden associated with this ICR addendum is 655,500 hours. 

The total annual cost is $40.3 million. 

Table 13: Estimated Annual Average Burden and Cost Associated with this ICR Addendum 

2011 2012 2013 2011-2013 Average

Activity Annual 

Burden 

(hours)

Annual 

Cost 

(2008$)

Annual 

Burden

(hours)

Annual 

Cost 

(2008$)

Annual 

Burden

(hours)

Annual 

Cost 

(2008$)

Total 

Annual 

Burden

(hours)

Total 

Annual 

Cost 

(2008$)

Compliance 

Determination 

(per Site)

2,043 $120,179 2,681 $157,726 2,681 $157,726 2,468 $145,210

Rule 

Familiarization 

(per Site)

22,876 $1,428,274 4,289 $276,355 4,289 $276,355 10,485 $660,328

CDX 

Registration 

Activities 

(per Site)

2,179 $90,981 2,859 $179,438 2,859 $179,438 2,632 $149,952

Part I 

Preparation 

(per Site)

1,634 $105,741 2,024 $131,327 2,024 $131,327 1,894 $122,798

Partial Report 

Preparation 

(Part II, 

per Report)

2,372 $146,288 2,491 $153,626 2,491 $153,626 2,451 $151,180

Full Report 

Preparation 

(Part II and 

Part III, 

per Report)

597,990 $36,861,729 621,873 $38,350,840 621,873 $38,350,840 613,912 $37,854,469

Recordkeeping 

(per Report) 17,923 $968,642 23,524 $1,271,361 23,524 $1,271,361 21,657 $1,170,455

Total 655,500 $40,254,393

Page 36 of 49 
Average Burden and Cost per Site. As shown in Table 14, the Agency estimates the 

typical respondent burden for this information collection activity to be 792 hours in the first 

reporting cycle and 615 hours in future reporting cycles. Given that the 2011 (first) collection is 

based on a five-year reporting cycle, the average annual burden for the first reporting cycle 

would be 158 hours. Given that a collection would occur once every four years under the 

proposed rule, the average annual burden for future cycles would be 154 hours. These burden 

estimates assume each site will submit an average of 7.16 full reports and 0.15 partial reports in 

both the next, and future, reporting cycle. This is a decrease of 2.01 partial reports per site and an 

increase of 2.98 full reports per site compared to the average number of reports completed per 

site presented in the currently approved ICR (EPA ICR No. 1884.04) . 

Table 14: Average Burden per Site 

Burden Hours 

Activity Managerial Technical Clerical 

Total 

Hours 

per 

Activity 

Reports 

per 

Average 

Site 

Total 

Burden 

(hours 

per 

average 

site) 

Annual 

Burden 

(hours 

per 

average 

site) 

First Reporting Cycle 

Rule Familiarization. 

Compliance 

Determination, CDX 

Registration Activities 

and Part I Preparation 

(per Site) 

10.98 24.18 0.00 35.17 1.00 35.17 7.03 

Partial Report 

Preparation (Part II, 

 per Report) 

4.85 14.34 0.00 19.19 0.15 2.90 0.58 

Full Report Preparation 

(Part II and Part III, 

 per Report) 

25.61 76.60 0.00 102.21 7.16 732 146 

Recordkeeping 

 (per Report) 0.75 1.50 0.75 3.00 7.31 21.9 4.39 

Total Hours 792 158 

Future Reporting Cycles 

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) 

3.88 11.47 0.00 15.35 0.15 2.32 0.58 

Full Report Preparation 

(Part II and Part III, per 

Report) 

20.49 60.50 0.00 80.98 7.16 580 145 

Recordkeeping 

 (per Report) 0.75 1.50 0.75 3.00 7.31 21.9 5.48 

Total Hours 615 154 

Page 37 of 49 
Table 15 presents the average cost per site, by activity, for an IUR respondent. EPA 

estimates the average site will submit 7.16 full reports and 0.15 partial reports and incur a total 

cost of $48,678 during the first reporting cycle ($9,736 annually), and $37,790 during future 

reporting cycles ($9,448 annually) for Form U completion and submission. 

Table 15: Average Cost per Site 

Cost 

 (2008$) 

Activity 

Managerial Technical Clerical 

Total 

Cost 

per 

Activity 

Reports 

per 

 Average 

Site 

Total 

Cost 

(2008$ 

per 

average 

site) 

Annual 

Cost 

(2008$ 

per 

average 

site) 

First Reporting Cycle 

Rule Familiarization. 

Compliance 

Determination, CDX 

Registration Activities 

and Part I Preparation 

(per site) 

$769.13 $1,423 $0.00 $2,192.

06 1.00 $2,192 $438 

Partial Report 

Preparation (Part II, 

per Report) 

$339.98 $843.58 $0.00 $1,183.

56 0.15 $179 $35.82 

Full Report 

Preparation (Part II 

and Part III, per 

Report) 

$1,793.45 $4,507 $0.00 $6,300.

50 7.16 $45,122 $9,024 

Recordkeeping 

 (per Report) $52.52 $88.26 $21.36 $162.14 7.31 $1,186 $237 

Total Cost $48,678 $9,736 

Future Reporting Cycles 

Rule Familiarization. 

Compliance 

Determination, CDX 

Registration Activities 

and Part I Preparation 

(per site) 

$276.70 $417.96 $0.00 $694.66 $1.00 $695 $174 

Partial Report 

Preparation (Part II, 

per Report) 

$271.98 $674.87 $0.00 $946.85 $0.15 $143 $35.82 

Full Report 

Preparation (Part II 

and Part III, per 

Report) 

$1,434.76 $3,559.49 $0.00 $4,994.

25 $7.16 $35,767 $8,942 

Recordkeeping 

 (per Report) $52.52 $88.26 $21.36 $162.14 $7.31 $1,186 $296 

Total Cost $37,790 $9,448 

Page 38 of 49 
As shown in Table 16, EPA calculated the estimated burden and cost per site associated 

with this ICR addendum by taking a weighted average of the first and future reporting cycles to 

reflect that the period covered by this ICR addendum, 2011 through 2013, spans two reporting 

cycles with different burdens and costs. The average annual burden per site is 155 hours and the 

average annual cost per site is $9,544. 

Table 16: Estimated Annual Burden and Cost per Site Associated with this ICR Addendum 

2011 2012 2013 2011-2013 Average

Activity Annual 

Burden

(hours)

Annual 

Cost 

(2008$)

Annual 

Burden

(hours)

Annual 

Cost 

(2008$)

Annual 

Burden

(hours)

Annual 

Cost 

(2008$)

Annual 

Burden 

(hours)

Annual 

Cost 

(2008$)

Rule 

Familiarization. 

Compliance 

Determination, 

CDX 

Registration 

Activities and 

Part I 

Preparation 

(per site)

7.03 $438 2.76 $174 2.76 $174 4.19 $262

Partial Report 

Preparation 

(Part II, per 

Report)

0.58 $35.82 0.58 $36 0.58 $36 0.58 $36

Full Report 

Preparation 

(Part II and 

Part III, per 

Report)

146 $9,024 145 $8,942 145 $8,942 145 $8,969

Recordkeeping 

 (per Report) 4.39 $237 5.48 $296 5.48 $296 5.12 $277

Total 155 $9,544

Table 17 presents the burden hours, organized by information collection, for both the first 

and future reporting cycle, and weighted, annual averages for the ICR addendum period, for IUR 

respondents. 

Page 39 of 49 
Table 17: Information Collection Tally for First and Future Reporting Cycles 

Information Collection 

No. of 

Respondents 

No. of 

Responses / 

Respondent 

Responses 

Subtotal 

Burden 

Hours 

per 

Response 

Burden Hours 

Subtotal 

First Reporting Cycle 

Compliance Determination 4,085 1 4,085 2.50 10,213 

Rule Familiarization 4,085 1 4,085 28.00 114,380 

CDX Registration Activities 4,085 1 4,085 4.67 19,063 

− CDX Registration 4,085 1 4,085 0.92 3,745 

− ESA 4,085 1 4,085 1.75 7,149 

− Part I of Form U 4,085 1 4,085 2.00 8,170 

Prepare and Submit Report, and 

Maintain Records – Partial Report 4,085 0.15 618 22.19 13,718 

− Part II of Form U 4,085 0.15 618 19.19 11,863 

− Recordkeeping 4,085 0.15 618 3.00 1,854 

Prepare and Submit Report, and 

Maintain Records - Full Report 4,085 7.16 29,255 105.21 3,077,924 

− Part II and III of Form U 4,085 7.16 29,255 102.21 2,990,159 

− Recordkeeping 4,085 7.16 29,255 3.00 87,765 

Future Reporting Cycles 

Compliance Determination 4,289 1 4,289 2.50 10,723 

Rule Familiarization 4,289 1 4,289 4.00 17,156 

CDX Registration Activities 4,289 1 4,289 4.55 19,535 

− CDX Registration 4,289 1 4,289 0.92 3,932 

− ESA 4,289 1 4,289 1.75 7,506 

− Part I of Form U 4,289 1 4,289 1.89 8,098 

Prepare and Submit Report, and 

Maintain Records – Partial Report 4,289 0.15 649 18.35 11,911 

− Part II of Form U 4,289 0.15 649 15.35 9,964 

− Recordkeeping 4,289 0.15 649 3.00 1,947 

Prepare and Submit Report, and 

Maintain Records - Full Report 4,289 7.16 30,716 83.98 2,579,642 

− Part II and III of Form U 4,289 7.16 30,716 80.98 2,487,494 

− Recordkeeping 4,289 7.16 30,716 3.00 92,148 

Average for ICR Addendum Period

Compliance Determination 4,221 1 4,221 2.50 10,553

Rule Familiarization 4,221 1 4,221 12.00 49,564

CDX Registration Activities 4,221 1 4,221 4.59 19,378

Prepare and Submit Report, 

and Maintain Records – Partial 

Report 

4,221 0.15 639 19.63 12,513

 -- Part II of Form U 4,221 0.15 639 16.63 10,597

 -- Recordkeeping 4,221 0.15 639 3.00 1,916

Prepare and Submit Report, and 

Maintain Records - Full Report 4,221 7.16 30,229 91.05 2,745,736

 --Part II and III of Form U 4,221 7.16 30,229 88.06 2,655,049 

 --Recordkeeping 4,221 7.16 30,229 3.00 90,687 

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

Page 40 of 49 
Agency Tally 

Table 18 presents the Agency costs associated with the IUR rule for the first reporting 

cycle. 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 

total burden is 0.172 FTEs and the total cost is $37,396 in the first reporting cycle, 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 

$249,184. The total Agency burden is 1.181 FTEs. The estimated total cost incurred by the 

Agency for the first reporting cycle, $286,580, was calculated by summing the Agency staff and 

contractor activities. 

Table 18: Total Cost and Burden of Agency Activities (First Reporting Cycle) 

Activity Staff Form U 

Section 

Total 

Burden 

per 

Activity 

(FTE) 

Total 

Number of 

Units 

Total 

Cost per 

Activity 

(2008$) 

Total 

Burden 

(FTE) 

Total Cost 

(2008$) 

Variable Burdens and Costs

Part I N/A 4,085 Sites $0.09 N/A $360 

Part II N/A 29,871 Part 

IIs $0.25 N/A $7,550 

Document receipt, 

tracking, and data 

entry Contractor 

Part III N/A 29,253 Part 

IIIs $0.29 N/A $8,402 

Part I 0.0000009 4,085 Sites $0.11 0.004 $465 

Part II 0.0000027 29,871 Part 

IIs Quality Control of $0.32 0.080 $9.759 

Data 

EPA 

Employee 

(GS-12 

Step 3) Part III 0.0000030 29,253 Part 

IIIs $0.37 0.089 $10.860 

Total Variable Cost and Burden 0.172 $37,396 

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 $139,819 

Maintaining and 

Operating Back Up 

Systems 

Contractor N/A N/A N/A N/A N/A $59,145 

Printing and 

Publishing Forms 

and Materials 

Contractor N/A N/A N/A N/A N/A $5,525 

Managing the TSCA 

Hotline Contractor N/A N/A N/A N/A N/A $44,694 

Total Fixed Cost and Burden 1.000 $249,184 

Total Agency Cost and Burden 1.172 $286,580

Page 41 of 49 
6(e) Reasons for Change in Burden 

EPA estimates industry will incur an increase of 223,026 hours in annual burden 

compared to the estimate in the information collection request most recently approved by OMB 

(from 432,274 hours currently approved as reported in the currently approved ICR (EPA ICR 

No. 1884.04) (EPA, 2008a), to 655,500 hours as estimated in Section 6(d) above). This increase 

is due to both program changes and an adjustment in reporting requirement criteria. Several of 

the proposed IUR amendments change the number of partial and/or full reports EPA expects to 

be submitted, based on the specific chemicals the amendments affect. Details on the proposed 

amendments and the burden and cost impacts of each amendment when taken individually and 

considered together (i.e., one proposed amendment may change the impact of another), are 

described in the Economic Analysis for the Proposed Inventory Update Reporting (IUR) 

Modifications Rule (EPA, 2010b). 

6(f) Burden Statement 

 The annual public burden for this collection of information is estimated to average 155 

hours per respondent. According to the Paperwork Reduction Act, “burden” means the total time, 

effort, or financial resources expended by persons to generate, maintain, retain, or disclose or 

provide information to or for a Federal agency. For this collection it includes the time needed to 

determine whether a site is subject to the rule (Compliance Determination); review and 

understand instructions; prepare and submit reports (including searching data sources); complete 

and review the collection of information; transmit the information; and keep records. 

 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 burden, including the 

use of automated collection techniques, EPA has established a docket for this ICR addendum 

under Docket ID No. EPA-HQ-OPPT-2009-0187 which is available for public viewing at the 

Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC), EPA West, Room 

B102, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading 

Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. 

The telephone number for the Reading Room is (202) 566-1544 and the telephone number for 

the Pollution Prevention and Toxics Docket is (202) 566-0280. 

 An electronic version of this docket is available at http://www.regulations.gov/. Use the 

federal government wide electronic docket and comment system at www.regulations.gov to 

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

those documents in the docket that are available electronically. Once in the system, select 

Page 42 of 49 
“advance 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-2009-0187 and OMB control number 2070-

0162 in any correspondence. 

7. Sources 

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-HQOPPT-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. 

Page 43 of 49 
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, 2010a. 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) 

EPA, 2010b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy 

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

Modifications Rule. July 2010. 

OPM, 2008. Office of Personnel Management, Salary Table 2008-DCB, Washington Baltimore-Northern 

Virginia, DC-MD-PA-VA-WV. Accessed from http://www.opm.gov/oca/08tables/pdf/DCB.pdf.

Page 44 of 49 
Attachment A: 2011 IUR Form U

Attachment A - Page 1 of 4 
Attachment A - Page 1 of 4 
Attachment A - Page 2 of 4 
Attachment A - Page 3 of 4 
Attachment B - Page 4 of