Economic Analysis in Support of the TSCA Section 12(b) Information Collection Request 

Prepared by: 

Joseph M. Callahan 

Economic and Policy Analysis Branch 

Economics, Exposure, and Technology Division 

Office of Pollution Prevention and Toxics 

U.S. Environmental Protection Agency 

401 M Street, S.W. 

Washington, D.C. 20460 

October 30, 1998 
6. Estimating the Burden and Cost of the Collection 

 The Purpose of this analysis is to determine the incremental cost to industry and to the 

EPA, associated with export reports that would be submitted to the Agency under the TSCA 

section 12(b) reporting requirements. 

6 (a) Estimating the Respondent Burden 

 The burden to respondents of this information collection activity comprises the time 

required to perform the steps outlined in section 3 of this document. 

 Most companies comply by compiling a list of products exported by the company that are 

subject to section 12(b) reporting. Each outgoing order is checked to see if the chemical or 

product is on the list and, depending on the chemical, whether it is the first shipment to the 

importing country or the first shipment of the calendar year to that country. If so, a completed 

form letter is sent to EPA. In most cases the entire process is computerized. 

Compile List. Since this information collection activity has been in place for eighteen 

years, most respondents will have already developed a list of their products subject to section 

12(b) reporting. Respondents need only check for new regulations promulgated and any new 

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

of technical time (which may also include some proportion of legal time). This could vary 

depending on the number of products exported by the company and the number of their products 

subject to section 12(b). Based on past experience, approximately 350 companies report under 

section 12(b). Compiling the list for all respondents is estimated to take 350 hours (1 hour x 350 

firms). On average, about 100 of those companies are filing notices under TSCA Section 12(b) 

for the first time and thus could be incurring higher costs for this task. 

Write or Revise Letter. Companies that export chemicals subject to section 12(b) 

reporting must prepare an export notice to send to EPA. Time for initial preparation of the export 

notice probably varies depending on whether the company has prior experience with this 

program, but this step is estimated to take an average of one hour of technical time (which may 

also include some proportion of legal time) per year for each company subject to section 12(b) 

reporting. Many of the notifications received by EPA are for repeat submissions from a 

company. Most of the repeat submissions received by the Agency are computer generated form 

letters, and it is assumed that no additional time is required to prepare letters for repeat 

submissions. Thus we estimate a total of 350 hours (1 hour x 350 firms = 350 hours) per year in 

letter writing or revising. 

Checking Orders and Send Notices. The 350 companies that export chemicals subject to 

section 12(b) reporting must check outgoing shipments against the list of their products 

described above. Where the shipment is for a section 12(b) chemical and, depending on the 

chemical, if it is the first shipment to the importing country or the first shipment of the calendar 

year to that country, a form letter notifying EPA is printed out. This whole process is estimated 

to take on average one half hour of clerical time per notice. Based on past experience, 

approximately 11,000 notices will be sent. Total time will be 5,500 hours (11,000 notices x 1⁄2 
hour each). 

TABLE 1: ANNUAL AVERAGE BURDEN PER RESPONDENT FACILITY 

BURDEN HOURS 

ACTIVITY TECHNICAL CLERICAL TOTAL 

Compile list 1 - 1 

Write letter 1 - 1 

Check order and send 

notice 

- 16 16 

Total 2 16 18 

TABLE 2: ANNUAL AGGREGATE BURDEN 

BURDEN HOURS 

ACTIVITY TECHNICAL CLERICAL TOTAL 

Compile list 350 - 350 

Write letter 350 - 350 

Check order and send 

notice 

- 5,500 5,500 

Total 700 5,500 6,200 

Average burden hours 

per notice 

0.064 0.5 0.564 

 It is estimated that the annual number of notices to be submitted for 1999 to 2001 will be 

11,000. Estimating that the number of respondents will be 350 (a 75% increase over 1995), the 

average number of notices submitted per respondent will be 32. 

6(b) Estimating the Respondent Cost 

 The costs to respondents is based on the time needed to complete the tasks listed in 

section 3, the hourly cost of labor at appropriate levels (labor rates), the number of facilities 

affected, and the number of reports generated. There are also costs for mailing. There are no 
specific capital or overhead costs associated directly with this information collection activity. 

 Labor rates, including fringe costs, are $86.86 for management time, $64.30 for technical 

time, and $25.63 for clerical time, based on current labor market estimates produced in this 

office. 

 Companies will also incur a cost of $6.27 per export notice to send the letter to EPA via 

registered mail ($4.85 for registered mail, $1.10 for a return receipt, and 32¢ postage). Aggregate 

annual costs for mailing will be $68,970 ($6.27 x 11,000). 

TABLE 3: ANNUAL COST PER RESPONDENT FACILITY 

ANNUAL COST 

ACTIVITY TECHNICAL CLERICAL TOTAL 

Compile list $64.30 - $64.30 

Write letter $64.30 - $64.30 

Check order and send 

notice 

- $410.00 $410.00 

Mailing cost $275.88 

Total $128.60 $410.00 $814.48 

TABLE 4: ANNUAL AGGREGATE RESPONDENT COST 

ANNUAL COST 

ACTIVITY TECHNICAL 

$64.30/hr 

CLERICAL 

$25.63/hr 

TOTAL PRESENT 

VALUE* 

Compile list $22,500 - $22,500 $63,180 

Write letter $22,500 - $22,500 $63,180 

Check order and 

send notice 

- $143,500 $143,500 $402,950 

Mailing cost - - $68,970 $193,670 

Total $45,000 $143,500 $257,470 $722,980 

* Present value for 3 years at a 7% discount rate. 
6 (c) Federal Government Burden and Cost 

 Agency unit costs are based on past section 12(b) analyses, including the previous ICR, 

and on recent contacts with the Environmental Assistance Division (EAD) and with an EPA 

contractor’s office. EPA’s cost estimates are based on current experience with these activities. 

The Agency cost can be divided into three parts: receiving and processing incoming notices, 

preparing and mailing notifications to importing countries, and responding to requests for 

information and clarification from companies and importing countries. The allocation of burden 

hours and costs among these three parts is not exact, but the analysis below is reasonably 

accurate in terms of the overall burden estimate and the approximate allocation of that burden 

among these tasks. 

 In the first task, notices are received from firms that intend to export a product covered 

by this rule, the forms are checked for completeness, and the submissions are logged into a 

document control system. In 1997 EPA received and processed approximately 10,000 

submissions. Based on conversations with the workers responsible for this task, about ten 

submissions can be processed per hour. We project that an average of 11,000 submissions will be 

received per year over the period covered by this ICR, requiring approximately 1,100 hours of 

contractor support. This work is currently done by contractor staff with a fully-loaded cost to 

EPA of approximately $20.00 per hour and thus is projected to cost $22,000 per year over the 

period of this ICR. 

 In the second task, workers prepare letters of notification which are subsequently 

reviewed and sent out to importing countries. Not all notices submitted require that a notification 

be sent out. Based on conversations with EPA and contractor employees, this work varies 

considerably depending on the circumstances of any particular chemical, but averages 

approximately 35 minutes per notification. The previous ICR estimated 2,266 notifications to 

importing countries per year, but the recent experience has been approximately 1,700 per year. 

Assuming a 10% increase in these notifications, similar to the projected increase in submissions 

from companies, would project 1,870 notifications per year or a total of approximately 1090 

hours. This work is currently done by contractor staff with a fully-loaded cost to EPA of 

approximately $20.00 per hour and thus is projected to cost $21,800 per year over the period of 

this ICR. The cost of mailing a notifications can vary from $2.00 to $12.00, depending on 

whether it is sent to an embassy in the US or to an overseas destination, and depending on 

whether the notice is registered. Based on current experience, mailing cost is estimate to average 

approximately $4.50 per notification, for a projected annual cost of $8,415 

 The burden described above covers the routine tasks of handing both incoming notices 

and outgoing notifications. The totals above also include a certain amount of time spent 

responding to routine requests for information, since data is not available to separate this out 

from the other tasks. Based on conversations with EAD staff, the work of responding to nonroutine requests for information and clarification from industry and importing countries, 

assisting the contractor staff in handling non-routine issues, and handling other tasks associated 

with the section 12(b) program can be expected to require about 20% of the time of a GS-13 

EPA employee, or roughly 400 hours per year. Following the 1998 federal employee wage scale, 

and assuming an additional 60% to cover fringe benefits etc., that represents an annual cost of 
approximately $20,000. 

TABLE 5: ESTIMATED COSTS FOR THE FEDERAL GOVERNMENT 

ANNUAL COST PRESENT VALUE * 

Processing of notices from 

companies 

$22,000 $64,096 

Processing of notifications to 

importing countries 

$21,800 $63,513 

EPA staff time, responding to 

information requests, etc. 

$20,000 $58,269 

Mailing cost of notifications $8,415 $24,517 

Total $72,215 $210,396 

* Present value calculated for 3 years at a 3% discount rate. 

6 (d) Reasons for Change in Burden 

 This analysis shows about a 50% increase in the number of notices sent to EPA, a 75% 

increase in the number of firms sending notices, and about a 30% increase in labor wage rates in 

comparison to the estimates for the previous ICR. These factors in combination result in about a 

60% increase in projected burden hours and a 130% increase in burden cost to responding firms.