EPA ICR No. 1139.11; OMB Control No. 2070-0033

ATTACHMENT 3

Economic Analysis Tables
Table A: Burden and Cost, per Activity 

Collection Activity

Per Activity Labor PerActivity 

Supply 

Costs 

(y)

Total perActivity Costs 

Type a Hours Rate Cost (x) (x+y)

CDX REGISTRATION

CDX Registration T 0.180 $72.22 $13.00 $0.00 $13.00 

CDX Electronic Signature T 0.350 $72.22 $25.28 $0.00 $25.28 

CDX Registration and eSignature Total 0.530 $144.44 $38.28 $0.00 $38.28 

TEST RULES AND TESTING AGREEMENT:

Interim Reports

Letter of Intent with Study Plans T 40 $72.22 $2,888.80 $0.00 $2,888.80 

Prepare Progress Report T 8 $72.22 $577.76 $0.00 $577.76 

Final Reports

Short-term Studies

Record and Prepare Test for 

Submission T 40 $72.22 $2,888.80 $0.00 $2,888.80 

Laboratory Review T 6 $72.22 $433.32 $0.00 $433.32 

Corporate Review M 6 $80.22 $481.32 $0.00 $481.32 

Recordkeeping C 0.5 $31.26 $15.63 $0.00 $15.63 

Short-term Studies' Final Reports Total 52.5 $3,819.07 $0.00 $3,819.07 

Long-term Studies

Record and Prepare Test for 

Submission T 80 $72.22 $5,777.60 $0.00 $5,777.60 

Corporate Review M 9 $80.22 $721.98 $0.00 $721.98 

Recordkeeping C 0.5 $31.26 $15.63 $0.00 $15.63 

Long-term Studies' Final Reports Total 89.5 $6,515.21 $0.00 $6,515.21 

Robust Summaries T 12 $72.22 $866.64 $0.00 $866.64 

VOLUNTARY SUBMISSIONS:b

Robust Summaries T 12 $72.22 $866.64 $0.00 $866.64 

Submission of Final Reports C 10 $31.26 $312.60 $8.41 $321.01 

Recordkeeping C 1 $31.26 $31.26 $0.00 $31.26 

EXEMPTION APPLICATIONS:

Prepare Exemption Applications T 2 $72.22 $144.44 0.00 $144.44 

Corporate Review M 6 $80.22 $481.32 0.00 $481.32 

Recordkeeping C 0.5 $31.26 $15.63 $0.00 $15.63 

Exemption Applications, Total 8.5 $641.39 $0.00 $641.39 

a Labor Type Codes are as follows: T = Technical; M = Managerial; C = Clerical
b Voluntary Submissions are the only type of TSCA Section 4 submission that not required to be submitted electronically. 

Paper and postage costs are estimated under "Per-Activity Supply Cost." These costs assumed that a voluntary submission 

contains: ten final reports averaging 35 pages, plus a cover letter and robust summary, totaling 362 pages. Paper costs at 

$.0092 per page total $3.30 (Staples 2015). Postage via 2 day FedEx Ground for the .4 lb package totals $8.41 (FedEx 2015). 

Unit supply costs for "Robust Summaries" and "Recordkeeping" were removed from voluntary submissions (compared to the 

estimates in the last IC period) because the costs are accounted for under "Submission of Final Reports."

Table B: Industry Wage Rates (Dec 2014)

Labor Category

Fringe 

Benefits 

($/hour)1

Fringes as 

% Wage

Overhead % 

Wage2

Fringe + Overhead 

Factor

Loaded 

Wages 

($/hour)

Wage 

($/hour)1

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

Managerial $47.90 $24.18 50% 17% 1.67 $80.22 

Technical $42.19 $22.86 54% 17% 1.71 $72.22 

Clerical $18.68 $9.40 50% 17% 1.67 $31.26 

Notes:

1

Source: Employer Costs for Employee Compensation Supplementary Tables: December 2006 – December 2014 (U.S. Bureau of Labor 

Statistics, 2015).

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

(Rice, 2002), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (US EPA, 2002).

Table C: Agency Wage Rate (Jan 2015)

Labor 

Category

Data Source for 

Wage 

Information

Wage 

($/hour)

Fringe 

Benefit

Fringes as 

% wage

Overhead 

as % wage

Fringe + 

Overhead 

Factor

Loaded 

Wage ($)

(a) (b) (c) = (b) / 

(a) (d) (e) = (c) + (d) + 1

(f) = (a) * 

(e)

EPA staff

Annual federal 

staff cost: OPM 

WashingtonBaltimoreNorthern 

Virginia, DCMD-PA-VA-WV 

area, GS-13 Step 

1 pay rates a

$43.52

Included 

in 60% 

overhead

N/A 60% b1.6 $69.63

a

Source: U.S. Office of Personnel Management. (2014). Salary Table 2014-DCB. Retrieved March 19, 2015 from Pay & Leave: 

Salaries & Wages: www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/14Tables/html/DCB_h.aspx.

bThe 60 percent fringes-and-overhead rate is from an EPA guide, Instructions for Preparing ICRs (US EPA, 2009).
Table D: Comparison of Burden: Previous ICR Versus Current e-Reporting, Per Activity

Previous ICR Post e-Reporting Rule

Collection Activity

Per Activity 

Labor

Per-Activity 

Supply Costs 

(y)

Per Activity 

Labor

Per-Activity 

Supply 

Type Costs (y)

a Hours Type a Hours

CDX REGISTRATION

CDX Registration N/A N/A N/A T 0.18 $0.00

CDX Electronic Signature N/A N/A N/A T 0.35 $0.00

CDX Registration and e-Signature Total 0.53 $0.00 

TEST RULES AND TESTING AGREEMENTS:

Interim Reports

Letter of Intent with Study Plans T 40 $21.91 T 40 $0.00

Prepare Progress Report T 8 $5.48 T 8 $0.00

Final Reports

Short-term Studies

Record and Prepare Test for Submission T 40 $0.00 T 40 $0.00

Laboratory Review T 6 $0.00 T 6 $0.00

Corporate Review M 6 $0.00 M 6 $0.00

Type and Print Results C 20 $0.00 N/A 0 $0.00

Recordkeeping C 1 $5.48 C 0.5 $0.00 

Short-term Studies Total 73 $5.48 52.5 $0.00

Long-term Studies

Record and Prepare Test for Submission T 80 $0.00 T 80 $0.00

Corporate Review M 9 $0.00 M 9 $0.00

Type and Print Results C 40 $0.00 N/A 0 $0.00

Recordkeeping C 1 $5.48 C 0.5 $0.00 

Long-term Studies Total 130 $5.48 89.5 $0.00 

Robust Summaries T 12 $0.00 T 12 $0.00

VOLUNTARY SUBMISSIONS:

Robust Summaries T 12 $0.00 T 12 $0.00

Submission of Final Reports C 10 $0.00 C 10 $8.41

Recordkeeping C 1 $5.48 C 1 $0.00 

EXEMPTION APPLICATIONS:

Prepare Exemption Applications T 2 0.00 T 2 0.00

Corporate Review M 6 0.00 M 6 0.00

Recordkeeping C 1 $5.48 C 0.5 $0.00 

Exemption Application Total 9 $5.48 8.5 $0.00 

a Labor Type Codes are as follows: T = Technical; M = Managerial; C = Clerical