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**Interagency Review Draft – Do Not Cite, Quote, or Release During the Review** 

Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) i Economic and Policy Analysis Branch 

CONTRIBUTORS 

The EPA analyst responsible for this report was Joe Callahan. Analytical and draft preparation support 

was provided by Abt Associates Inc. under EPA Contract No. EP-W-08-010. 
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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) ii Economic and Policy Analysis Branch 

ABSTRACT 

This report estimates the costs of the U.S. Environmental Protection Agency (EPA)’s proposed 

Significant New Use Rule (SNUR) for the chemical alkanes, C12-13, chloro (C12-13 chloro alkanes, 

Chemical Abstracts Service Registry Number (CAS RN): 71011-12-6). C12-13 chloro alkanes, are short 

chained chlorinated paraffins (SCPPs); a SCCP is defined as any chlorinated paraffin with a carbon chain 

length between C10 and C13. 

The proposed SNUR applies to all manufacturing, import, and processing of C12-13 chloro alkanes for any 

use. EPA found no evidence of any manufacturing or importation into the United States of the chemical, 

and no data was reported in the 2006 Toxic Substances Control Act (TSCA) Inventory Update Reporting 

(IUR) database for C12-13 chloro alkanes (EPA 2006a).1

 Because the domestic manufacture, import and 

processing of C12-13 chloro alkanes has been discontinued, there is expected to be no economic impact 

from the proposed SNUR. 

The proposed SNUR would require persons to notify EPA at least 90 days before commencing the 

manufacture, import, or processing of C12-13 chloro alkanes for any significant new use as defined in the 

SNUR. A firm intending to engage in these activities would be required to submit a Significant New Use 

Notice (SNUN). EPA is proposing the SNUR because of concerns regarding the environmental fate and 

the exposure pathways that lead to C12-13 chloro alkanes presence in wildlife and humans. Because C12-13

chloro alkanes is not currently manufactured in or imported into the United States it is important that EPA 

is notified if a company chooses to produce, import, or process C12-13 chloro alkanes for any significant 

new use. The SNUN provides the Agency with an opportunity to evaluate the intended use and, if 

necessary, to prohibit or limit that activity before it occurs. 

To submit this SNUN, a firm incurs a modest submission cost of $8,112 and potentially other minor 

costs. However, since no firms have been identified which import, manufacture, or process C12-13 chloro 

alkanes for any significant new uses, it is highly unlikely that any firm will incur this cost. EPA does not 

require the development of test data for submission of a SNUN, although a firm may submit test data 

already in its possession or describe any other available data. Because EPA does not require the 

development of test data, EPA assumes that no firms will incur testing costs as a result of the proposed 

SNUR. 

In addition to the firms that make a SNUN submission, the proposed SNUR may also impact firms that do 

not make a submission. By avoiding a significant new use, a firm can avoid submission and testing costs 

but may incur other compliance costs. However, this may not be a concern given that the domestic 

manufacture, import and processing of C12-13 chloro alkanes for the uses subject to the SNUR have been 

phased out. 

Costs are estimated at the firm level and reflect the burden of a SNUR on the firms that would make a 

submission. 

 

1

 The IUR compiles production data from manufacturers and importers of certain chemical substances (including 

C12-13 chloro alkanes ) listed on the TSCA Chemical Substance Inventory. Sites are only required to submit IUR data 

if they manufacture or import more that 25,000 lbs of a chemical during the reporting year. The most recent year 

with data available was 2006. 
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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) iii Economic and Policy Analysis Branch 

TABLE OF CONTENTS

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

ABSTRACT .................................................................................................................................................. ii

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

1. INTRODUCTION ................................................................................................................................ 1

1.1 Background ................................................................................................................................. 1

Uses and Substitutes ................................................................................................................... 1

Health Effects ............................................................................................................................. 2

Environmental Exposure ............................................................................................................ 2

Current Manufacturing ............................................................................................................... 3

1.2 Statutory Authority ..................................................................................................................... 3

1.3 Summary of Methodology .......................................................................................................... 3

1.4 Organization of this Report ........................................................................................................ 3

2. INDUSTRY COMPLIANCE COSTS .................................................................................................. 4

2.1 Wage Rates ................................................................................................................................. 4

2.2 Unit Industry Compliance Costs ................................................................................................. 5

2.2.1 Rule Familiarization ...................................................................................................... 5

2.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup ................ 6

2.2.3 Form Completion and Submission Fee .......................................................................... 7

2.2.4 Recordkeeping ............................................................................................................... 8

2.2.5 Import Certification ....................................................................................................... 9

2.2.6 Export Notification ........................................................................................................ 9

2.3 Industry Costs of SNUR, by Option (per Submission) ............................................................. 11

2.4 Likelihood of a SNUN Submission .......................................................................................... 12

2.5 Potential for Subsequent Regulatory Action ............................................................................ 12

3. AGENCY COSTS ............................................................................................................................... 13

3.1 Labor Rates for EPA Staff ........................................................................................................ 13

3.2 SNUN Processing Costs ........................................................................................................... 14

3.3 Export Notification Cost ........................................................................................................... 17

4. BENEFITS .......................................................................................................................................... 18

5. ADDITIONAL ANALYSES .............................................................................................................. 19

5.1 Regulatory Flexibility Act ........................................................................................................ 19

5.2 Unfunded Mandates Reform Act .............................................................................................. 19

5.3 Paperwork Reduction Act ......................................................................................................... 19

5.4 National Technology Transfer and Advancement Act ............................................................. 19

5.5 Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations ............................................................................... 20

5.6 Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks ......................................................................................................................................... 20

5.7 Executive Order 13132: Federalism ......................................................................................... 20

5.8 Executive Order 13175: Consultation and Coordination with Indian Tribal Governments ..... 20

5.9 Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

 .................................................................................................................................................. 20

6. REFERENCES .................................................................................................................................... 21

A. INFLATORS AND WAGE RATES ..................................................................................................... 26
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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) iv Economic and Policy Analysis Branch 

LIST OF TABLES 

Table 1: Loaded Industry Wage Rates, December 2009 ............................................................................... 5

Table 2: Rule Familiarization Burden and Cost for SNUR Submitters ........................................................ 6

Table 3: CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup Burden and Cost for 

First-Time Submitters ................................................................................................................................... 7

Table 4: Industry Cost Estimate to Complete the SNUN Form .................................................................... 8

Table 5: Industry Cost Estimate to Complete and Submit the SNUN Form ................................................. 8

Table 6: Derivation of Total Mailing Cost for 12 Notices .......................................................................... 10

Table 7: TSCA 12(b) Export Notification Cost per Notification ................................................................ 11

Table 8: Compliance Options and Associated Costs Incurred by a Firm Due to the Proposed SNUR ...... 12

Table 9: Derivation of Loaded Agency Wage Rates .................................................................................. 14

Table 10: Derivation of Inflation Factors for Agency Extramural Costs .................................................... 15

Table 11: Agency Costs for SNUN and Other Submission Review and Processing .................................. 16

Table 12: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2009$) ........................... 17

Table 13 : Detail of Labor Categories Used in the Analysis ....................................................................... 26

Table 14: Derivation of Loaded Wage Rates .............................................................................................. 28

Table 15: Derivation of Inflation Factors ................................................................................................... 30
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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) 1 Economic and Policy Analysis Branch 

1. INTRODUCTION 

This report presents the U.S. Environmental Protection Agency (EPA), Office of Chemical Safety and 

Pollution Prevention’s (OCSSP’s) analysis of the potential costs incurred as a result of a proposed 

Significant New Use Rule (SNUR) the chemical alkanes, C12-13, chloro (C12-13 chloro alkanes, Chemical 

Abstracts Service Registry Number (CAS RN): 71011-12-6). C12-13 chloro alkanes is a short chained 

chlorinated paraffin (SCPP); a SCCP is defined as any chlorinated paraffin with a carbon chain length 

between C10 and C13. SNURs are proposed by EPA under the authority granted by Section 5(a)(2) of 

TSCA. The proposed SNUR would require persons to notify EPA at least 90 days before commencing the 

manufacture, import, or processing of C12-13 chloro alkanes. EPA promulgates a SNUR for a substance 

when potential uses could result in increased exposure to, or releases of, the substance which in turn, 

could present an unreasonable risk to health or the environment. 

1.1 Background 

As part of EPA’s efforts to enhance the existing chemicals program under TSCA, the Agency identified 

an initial list of widely recognized chemicals for the development of Action Plans based on one or more 

of the following factors: presence in humans; persistent, bioaccumulative, and toxic (PBT) characteristics: 

use in consumer products; and production volume. SCCPs were selected because they are 

bioaccumulative in wildlife and humans, are persistent and transported globally in the environment, 

and toxic to aquatic organisms at low concentrations. The Action Plan summarized all readily available 

use, exposure, and hazard information for SCCPs, considered which authorities provided under TSCA 

and other statutes could be used to address potential concerns; and described various courses of actions 

available to EPA to address the concerns (EPA 2009c). 

Uses and Substitutes 

The largest use of SCCPs in the United States is as a component of lubricants and coolants in metal 

cutting and metal forming operations. The second-largest use is as both a secondary plasticizer and a 

flame retardant in plastics, especially polyvinyl chloride (PVC). Other minor domestic SCCP uses are as a 

plasticizer and a flame-retardant additive to a variety of products including: rubber formulations, paints 

and other coatings, and adhesives and sealants (CPIA, 2009). For safety reasons, other countries (those in 

the European Union and Canada) have allowed SCCPs to be used as a flame retardant in underground 

mining conveyor belts (rubber formulations) and fire retardants in dam sealants (ECHA 2008a). 

Medium chained chlorinated paraffins (MCCP; C14-17 alkyl chain) are alternatives to SCCPs for many 

applications. Based on their physical-chemical properties, MCCPs are also expected to be persistent in the 

environment and several field surveys have shown they are present in sediments and biota, demonstrating 

their release to and persistence in the environment. Field-measured bioaccumulation factors (BAFs) that 

are greater than 5000 and biomagnification factors (BMF) greater than 1 indicate that MCCPs are 

bioaccumulative in biota and can biomagnify in food chains (UNEP, 2009). MCCPs have toxicity to 

sensitive aquatic organisms that is similar to SCCPs. Canada has concluded that MCCPs are “toxic” 

as defined by the Canadian Environmental Protection Act (CEPA) (Government of Canada 2008). 

The European Union’s 2005 Risk Assessment Report and 2007 draft update conclude that there is a 

need for limiting the risks posed by certain uses of MCCPs in the production of PVC and metal 

cutting (EC, 2005, 2007). 

Long-chained chlorinated paraffins (LCCP; generally C18 - 28) appear to have been used as 

alternatives to SCCPs in some of the more demanding metal working applications (HELCOM, 2002). 

LCCPs also appear to have potential as an alternative in leather, paints and coatings, sealants and 
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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) 2 Economic and Policy Analysis Branch 

rubber applications. LCCPs are expected to be persistent and bioaccumulative in the environment 

based on their physical-chemical properties and bioaccumulation modeling, respectively. Canada has 

concluded that LCCPs up to C20 are “toxic” as defined by CEPA (Government of Canada 2008). 

Canada has not made a determination of whether LCCPs greater that C20 are toxic. 

A number of other potential alternatives, e.g. nitroalkanes, alkyl phosphate and sulfonated fatty acid 

esters and vegetable oil based products, are available for specific applications. It is stated that these 

alternatives are considered less harmful than chlorinated paraffins (UNECE, 2006). These nonchlorinated paraffin alternatives are often more expensive and may require special handling. A UK 

estimated cost for completely converting SCCPs to non-SCCPs in metal working was predicted to be 

four million £ per year (IRTA, 2004). An analysis of costs conducted in California found that overall 

metal working processing costs were more expensive for the SCCP alternatives but including other 

associated costs (clean up and waste removal) made the non-SCCP alternatives competitive (IRTA, 

2004).

Health Effects 

Acute toxicity of SCCPs (C10-13) is very low (EC, 1999; UNEP, 2009). SCCPs may cause skin and eye 

irritation upon repeated application, but do not appear to induce skin sensitization (EC, 1999; UNEP, 

2009). There was no evidence of developmental effects in prenatal developmental toxicity studies in rats 

and rabbits (EC, 1999; UNEP, 2009). 

The liver, kidney and thyroid are major target organs in repeated-dose studies with rats and mice. When 

administered by gavage, chlorinated paraffins (C12, 60 percent chlorine) are carcinogenic in rats and mice 

of both sexes (NTP, 1986a; 2005). The underlying mechanisms for the carcinogenicity of SCCP in rats 

and mice are not clearly known. SCCPs were not mutagenic to bacteria with or without metabolic 

activation (NTP 1986a, b). There are some indications that the SCCP-induced kidney tumors in male rats 

are associated with alpha 2μ-globin accumulation in hyaline droplets, a mode of action unique to male 

rats and irrelevant to humans, but this could not be confirmed by immunocytochemical techniques. There 

are also data showing that the liver toxicity/carcinogenicity induced by SCCP is associated with 

peroxisome proliferation, whereas the thyroid effects are correlated to altered thyroid hormone 

homeostasis. A number of scientific working groups, including the International Agency for Research on 

Cancer (IARC), have concluded that liver tumors induced by peroxisome proliferators are not relevant to 

humans (IARC, 1990; Klaunig et al., 2003). Humans are expected to be much less sensitive to thyroid 

hormone perturbation than rats and mice. 

There is no experimental evidence using human data that demonstrates the carcinogenicity of SCCPs. In 

the 11th Report on Carcinogens, NCI lists chlorinated paraffins (C12, 60 percent chlorine) as reasonably 

anticipated to be human carcinogens based on sufficient evidence of carcinogenicity in experimental 

animals (NTP, 2005). They are classified by the IARC as Group 2B - possibly carcinogenic to humans 

based on sufficient evidence of carcinogenicity in experimental animals and mechanistic considerations 

(IARC, 1990). 

Health Canada and Environment Canada have characterized all chlorinated paraffins (SCCPs, MCCPs 

and LCCPs) as “toxic” under CEPA (Government of Canada 2008). 

Environmental Exposure 

SCCPs are highly toxic to aquatic invertebrates following acute (48-hr EC50 = 0.043 to 11 mg/L) and 

chronic (NOEC = 0.005 to 2 mg/L) exposures. In fish high toxicity is associated with chronic exposures, 

but not for acute exposures (96-hr LC50 = 300 to 10,000 mg/L and NOEC = 0.0096 to 0.05 mg/L). For 
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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) 3 Economic and Policy Analysis Branch 

aquatic plants, there is high toxicity associated with both acute and chronic exposures to SCCPs (96-hr 

EC50s range from 0.043 to 0.39 mg/L and NOEC ranges from 0.012 to 0.39 mg/L) (UNEP, 2009). 

Both Health Canada and Environment Canada have characterized all chlorinated paraffins (SCCPs, 

MCCPs and LCCPs) as “toxic” under CEPA (Government of Canada 2008). 

Current Manufacturing 

The current use of chlorinated paraffins (SCCP, MCCP, and LCCP) in the United States is on the order of 

150 million pounds per year. Production of short-chain and medium-chained chlorinated paraffins (C9 to 

C17) was 100 million pounds in 2007. A very small fraction of that number is attributable to import/export 

business. According to the Chlorinated Paraffins Industry Association, MCCPs represent the largest 

production and use of chlorinated paraffins in North America while SCCPs is only half that volume 

(CPIA, 2009). In the United States, Dover Chemical Corp. is the sole manufacturer of chlorinated 

paraffins and several companies import chlorinated paraffins according to 2006 IUR data (EPA, 2006). 

However, no 2006 IUR data has been reported for C12-13 chloro alkanes (CAS RN 71011-12-6) and EPA 

found no additional evidence of any importation or manufacturing of the chemical. It therefore appears, 

there is no current manufacture or importation of C12-13 chloro alkanes in the United States. 

1.2 Statutory Authority 

Section 5(a)(2) of TSCA (15 U.S.C. 2604(a)(2)) authorizes EPA to determine that a use of a chemical 

substance is a “significant new use.” EPA must make this determination by rule after considering all 

relevant factors, including those listed in TSCA section 5(a)(2). Once EPA determines that a use of a 

chemical substance is a significant new use, TSCA section 5(a)(1)(B) requires persons to submit a 

Significant New Use Notice (SNUN) to EPA at least 90 days before manufacturing, importing, or 

processing the chemical substance for that use (15 U.S.C. 2604(a)(1)(B)). 

The general SNUR provisions are found at 40 CFR Part 721, Subpart A. 

1.3 Summary of Methodology 

This analysis quantifies, to the extent possible, the costs to society of the proposed rule by identifying the 

costs to industry associated with performing the required reporting and recordkeeping, and the costs to 

EPA of administering the rule. Industry costs consist of rule familiarization; registration with the Central 

Data Exchange (CDX) electronic reporting tool; collection, compilation, and submission of required 

information for significant new uses of the subject chemicals; export notification; and recordkeeping. 

Agency costs include reviewing and processing the data received as a result of the rule. Data sources for 

this analysis include burden estimates derived from previous information collection requests and 

economic analyses for related rules, compensation data acquired from government publications, and 

supplementary market research. 

1.4 Organization of this Report 

The remainder of this report provides EPA’s economic analysis in support of the proposed rule. Chapter 

Error! Reference source not found. presents estimates of the costs incurred by manufacturers, 

importers, and/or processors under the SNUR options. Chapter 3 shows estimates of the government costs 

associated with the administration of the proposed rule. Chapter 4 discusses the benefits of the proposed 

rule. Chapter 5 presents an analysis of other impacts, as required by various statutes and executive orders. 

Note that all dollar amounts in this analysis are reported in fourth quarter 2009 dollars. 
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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) 4 Economic and Policy Analysis Branch 

2. INDUSTRY COMPLIANCE COSTS 

The proposed SNUR discussed in this report specifies that significant new uses of C12-13 chloro alkanes be 

reported under section 5(a)(2)(A) of TSCA. A significant new use is defined as the manufacturing, 

importation, and/or processing C12-13 chloro alkanes for any use. A firm intending to manufacture, import, 

and/or process C12-13chloro alkanes for any significant new use must submit a SNUN. Alternatively, a 

firm can decide not to manufacture, import, and/or process the chemical for a significant new use. The 

firm, therefore, has two options: 

• Option 1: Submit a SNUN. A SNUN indicates to EPA that the firm would like to manufacture, 

import, and/or process the chemical for a significant new use, which, in this case, means the 

manufacturing, importing, and/or processing of this chemical for any use. The firm must submit the 

SNUN to EPA at least 90 days before it plans to commence the manufacture, import, and/or 

processing of the substance; the SNUN provides EPA with the opportunity to evaluate the intended 

use and, if necessary, to prohibit or limit that activity before it occurs. If EPA allows the manufacture, 

import, or processing of C12-13 chloro alkanes for the intended use, then the costs associated with this 

option are the costs of submitting the SNUN (including a user fee) plus, if there is any export of these 

products, the export notification costs that result from TSCA Section 12(b) requirements that are 

automatically triggered for chemicals regulated under TSCA Section 5 (see Section 2.2.6 for details). 

Because the domestic manufacture, import and processing of C12-13 chloro alkanes for the uses subject 

to the SNUR have been phased out, EPA expects that no firms will choose this option. 

• Option 2: Decide not to manufacture, import, and/or process the chemical. The firm may decide 

simply not to proceed to manufacture, import, and/or process the chemical. While this option avoids 

the costs of submitting a SNUN, it entails the ‘hidden’ cost of the profit that will be foregone as a 

result of not engaging in the commercial activity originally planned. Similarly, if the firm would have 

used a given amount of C12-13 chloro alkanes in the production of another product, and must substitute 

to a more costly substance, it will incur those additional “hidden” costs of production. However, these 

hidden costs are expected to be minimal, if not zero, because C12-13 chloro alkanes is not currently 

manufactured in the United States. If the firm elects to produce C12-13 chloro alkanes for research and 

development (R&D) purposes only (an exemption for R&D purposes is provided in 40 CFR 

§721.47), it may have costs associated with R&D recordkeeping. 

Because the domestic manufacture, import and processing of C12-13 chloro alkanes for the uses subject to 

the SNUR have been phased out, EPA does not expect there to be compliance cost associated for either of 

the options. The remainder of this chapter estimates the quantified portion of costs associated with the 

proposed SNUR. Section 2.1 summarizes the wage rates used in this chapter. Section 2.2 provides the 

unit industry compliance costs, including the costs of rule familiarization, registration with the Central 

Data Exchange (CDX) electronic reporting tool, completing the SNUN form, submission fee, import 

certification, and export notification. Total costs under each option are presented in Section 2.3. 

2.1 Wage Rates 

The proposed rule involves activities that may require efforts by employees in three labor classifications: 

managerial, technical, and clerical. Costs for each activity are calculated by estimating the labor hours 

required in each labor category and multiplying those burdens by the wage rate for each labor category. 

This section presents the estimated wage rate in each labor category. 
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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) 5 Economic and Policy Analysis Branch 

Loaded wage rates for managerial, technical, and clerical personnel are derived by combining data on 

wages and fringe benefits with estimates of overhead rates, following the methodology described in 

“Wage Rates for Economic Analysis of the Toxics Release Inventory Program” (EPA 2002b). Wage data 

for each labor category in December 2009 are provided by the Employer Costs for Employee 

Compensation (ECEC) Supplemental Tables available on the BLS website (BLS 2010a). The loaded 

wage rate for managerial labor is $68.24; for technical labor, $59.49; and for clerical labor, $28.31. Table 

1 presents the basic data used to calculate the loaded wage rates for all three categories of labor. 

Table 1: Loaded Industry Wage Rates, December 2009 

Labor 

Category Data Sources 

Wage 

(2009$) 

Fringe 

Benefit 

(2009$) 

Fringes 

as % 

wage 

Overhead % 

wage2

Fringe + 

overhead 

factor 

Loaded 

Wages1 

(2009$) 

(a) (b) (c) 

=(b)/(a) 

(d) (e)=(c)+ 

(d)+1 

(f)=(a) x 

(e) 

Managerial 

BLS ECEC, Private 

Manufacturing industries, “Mgt, 

Business, and Financial”3 $42.36 $18.68 44.10% 17% 1.61 $68.24 

Professional/ 

Technical 

BLS ECEC, Private 

Manufacturing industries, 

“Professional and related“3 $35.96 $17.42 48.44% 17% 1.65 $59.49 

Clerical 

BLS ECEC, Private 

Manufacturing industries, 

“Office and Administrative 

Support” 3

$17.21 $8.17 47.47% 17% 1.64 $28.31 

1 Wage data are rounded to the closest pennies in this table. 2 An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory 

Program (EPA 2002b), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002a). 3

 Employer Costs for Employee Compensation Supplementary Tables: December 2009. US Bureau of Labor Statistics, March 10, 

201- (BLS 2010a).

2.2 Unit Industry Compliance Costs 

2.2.1 Rule Familiarization

The proposed rule requires submitters and their staff to become familiar with the SNUR and its various 

requirements. The per company burden associated with rule familiarization is approximately 0.55 hours 

of technical labor and 0.27 hours of managerial labor, as described in the Economic Analysis of the 

Premanufacture Notification Electronic Reporting Final Rule (EPA 2009a). As shown in Table 2 the total 

labor cost associated with rule familiarization by a first-time reporter is $50.92. 
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Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

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Table 2: Rule Familiarization Burden and Cost for SNUR Submitters

Reporting Activity 

Clerical Labor (at 

$28.31/hour) 

Technical Labor (at 

$59.49/hour) 

Managerial Labor 

(at $68.24/hour) 

Total Labor Cost 

Burden

(hours) 

Cost 

(2009$) 

Burden

(hours) 

Cost 

(2009$) 

Burden

(hours) 

Cost 

(2009$) 

Burden

(hours) 

Cost 

(2009$) 

Rule Familiarization 0.00 $0.00 0.55 $32.72 0.27 $18.20 0.82 $50.92 

Total 0.00 $0.00 0.55 $32.72 0.27 $18.20 0.82 $50.92 

Source: BLS 2010a (labor rates); EPA 2009a (burden hours) 

2.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup 

The proposed SNUR requires first-time submitters (that is, those companies who have not submitted 

information to EPA through CDX before) to register their company and key users with the CDX reporting 

tool, deliver a CDX electronic signature to EPA, and establish and use a Pay.gov E-payment account.2

These activities are only required of first-time submitters (companies already registered with CDX would 

not need to re-register for the purposes of complying with the proposed SNUR). The burdens associated 

with these activities were estimated in the Economic Analysis of the Premanufacture Notification 

Electronic Reporting Final Rule (EPA, 2009a) and are described in more detail below: 

• CDX registration: EPA estimates that companies will spend approximately 0.18 hours per employee 

to register with CDX, and that an average of four technical staff members and one manager will need 

to register for each company, totaling approximately 0.92 hours of burden per company. 

• CDX electronic signature: EPA estimates that companies will spend 0.25 hours preparing, 

submitting, and filing an electronic signature agreement (Authentication of Identity) form to EPA per 

employee. This burden will apply to four technical staff members and one manager per company, 

totaling to 1.25 hours of burden per company. In addition, EPA estimates that a manager will spend 

an additional 0.50 hours accessing, preparing, and submitting verification forms (Verification of 

Authorization) for all authorized submitters to EPA. The total burden incurred by companies 

submitting and then verifying electronic signature agreements is 1.75 hours. Note that this burden 

does not include any additional time required to contact EPA’s CDX help desk to notify of a change 

of submitter status, should one occur. 

Filing the electronic signature agreement requires an additional mailing cost of $2.30 per company 

(including five $0.44 stamps and five $0.02 business envelopes) (USPS 2010). 

• Payment via Pay.gov account: EPA estimates that one manager per company will spend 

approximately 0.13 hours setting up a Pay.gov ID account, logging into the system, finding the 

appropriate form, and filling it out. This burden does not include the time required to click ‘submit’ 

on the form and wait for payment processing. 

As shown in Table 3, the cost associated with CDX registration, CDX electronic signature, and Pay.gov 

account setup is $178.21, and this cost is only incurred by a first-time submitter. 

 

2 Although the proposed rule does not specifically require submitters to establish and use a Pay.gov account, the 

burden estimates in this analysis are conservative insofar as to include the use of Pay.gov as a required activity. 
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Table 3: CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup Burden 

and Cost for First-Time Submitters 

Reporting Activity 

Clerical Labor (at 

$28.31/hour) 

Technical Labor (at 

$59.49/hour) 

Managerial Labor 

(at $68.24/hour) Total Cost 

Burden

(hours) 

Cost 

(2009$)1

Burden

(hours) 

Cost 

(2009$)1

Burden

(hours) 

Cost 

(2009$)1

Burden

(hours) 

Cost 

(2009$)1

CDX Registration 0.00 $0.00 0.73 $43.63 0.18 $12.51 0.92 $56.13 

CDX Electronic 

Signature 0.00 $0.00 1.00 $59.49 0.75 $51.18 1.75 $110.67 

Mailing Cost $2.30 

E-Payment (Pay.gov 

ID) 0.00 $0.00 0.00 $0.00 0.13 $9.10 0.13 $9.10 

Total 0.00 $0.00 1.73 $103 1.07 $72.79 2.80 $178 

Notes: 

Costs may not equal labor wage rate times burden hours due to the rounded burden estimate presented in the table, 

unrounded estimates were used during the cost calculations. 

Source: BLS, 2010a (labor rates); EPA, 2009a (burden hours); USPS, 2010 (mailing cost) 

2.2.3 Form Completion and Submission Fee

Respondents are required to gather and submit information regarding the data elements identified in the 

applicable SNUN reporting form. The methodology and calculations used in this analysis assume that the 

employee responsible for collecting, filling out, and submitting the requested information has a 

reasonable level of familiarity with the company and knowledge of operations at the site. It is assumed 

that for most entities these tasks are similar to other employee duties that require familiarity with EPA, 

State, and other Federal agency requests for chemical information and do not require additional 

familiarization or training beyond the basic rule familiarization described above. In addition, this analysis 

focuses on the marginal costs of submitting information for the proposed rule and not the total costs for 

the company to comply with a range of other Federal and State environmental, health, and safety 

regulations or accounting requirements that rely on this type of information. 

Estimates of the costs of completing a Significant New Use Notice (SNUN) form are based on the costs 

of completing a Premanufacture Notification (PMN) submission, since the data requirements are the same 

and the same form is used for both. The PMN submission costs are based on EPA's 1994 Regulatory 

Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications and the 

updates to this estimate in 2009 (EPA 2009a). The original 1994 estimates relied on industry estimates of 

the effort needed to collect and compile all data required for a PMN submission, prepare the form, submit 

the form and data to EPA, and maintain a file of the submission (EPA 1994).3

 The 1994 estimates were 

based on a survey conducted by the Chemical Manufacturers Association, which became the American 

Chemistry Council. These burdens “include the time spent reading and becoming familiar with the form, 

gathering the required information and preparing the report, producing sanitized responses for items 

claimed as confidential business information, and maintaining a file of the submission” (EPA, 1994).4

The burden associated with SNUN submission and preparation has been adjusted to reflect burden 

reductions resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that requires the 

electronic submission of all TSCA section 5 notices. Electronic submission of SNUN forms is expected to 

remove all clerical burden associated with preparing a SNUN (EPA 2009a)5

. In addition, electronic 

 

3

 Table III-2 and pages III-11, -12, and -13. 

4

 p. III 11-13 

5

 The Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009a) 

estimates a 0.5 hour clerical burden and a 0.5 hour technical burden associated with recordkeeping in addition to the 
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submission is expected to generate an additional 0.18 hours of technical burden, for the completion of the 

User Fee Payment Identification Number and email address data elements on the electronic SNUN form. 

SNUN form completion and electronic submission is estimated to require 73.68 hours of technical labor 

and 18.00 hours of managerial labor. Table 4 combines the estimated reporting burden and loaded wage 

rates for all three labor categories to estimate the per-SNUN cost of form completion. The labor cost 

incurred by a SNUN submission for both large and small business submitters is $5,612. 

Table 4: Industry Cost Estimate to Complete the SNUN Form 

Reporting Activity 

Clerical Labor (at 

$28.31/hour) 

Technical Labor (at 

$59.49/hour) 

Managerial Labor 

(at $68.24/hour) Total Labor Cost 

Burden

(hours) 

Cost 

(2009$) 

Burden

(hours) 

Cost 

(2009$)1

Burden

(hours) 

Cost 

(2009$)1

Burden

(hours) 

Cost 

(2009$)1

Form Completion 0.00 $0.00 73.68 $4,414 18.00 $1,228 91.68 $5,612 

Notes: 

Costs may not equal labor wage rate times burden hours due to the rounded burden estimate presented in the table, 

unrounded estimates were used during the cost calculations. 

Source: 1 Loaded wages include fringe benefits and overhead. See Appendix A of this report for derivation. Wage rates presented in 

this table are rounded values; however, unrounded values are used to calculate total labor costs. For this reason, total labor 

costs may not equal the product of rounded values. 

2

 The estimate of no clerical burden is taken from the Economic Analysis of the Premanufacture Notice Electronic 

Reporting Final Rule (EPA, 2009a, page 7) 3 Technical and managerial labor burden is from the PMN Amendments RIA (EPA, 1994, Table III-2). An additional eleven 

minutes (0.18 hours) of technical burden is estimated to complete the User Fee Payment Identification Number and Email 

Address data elements on the Electronic SNUN form (EPA, 2009a page 15). 

In addition, each submitting large business must pay a $2,500 per-SNUN submission fee, and each 

submitting small business must pay a $100 per-SNUN submission fee. Table 5 adds the labor cost and 

submission fee to estimate the total cost of a SNUN submission. The total cost of a SNUN submission is 

$8,112 for large business submitters and $5,712 for small business submitters. 

Table 5: Industry Cost Estimate to Complete and Submit the SNUN Form

Reporting Population Labor Cost Submission Fee Total Cost 

(2009$) 

Large Business Submitters $5,612 $2,500 $8,112 

Small Business Submitters $5,612 $100 $5,712 

Source: EPA, 2009a. 

2.2.4 Recordkeeping 

Companies submitting a SNUN must keep records under 40 CFR §721.40. Some EPA reports have 

assumed that SNUN recordkeeping hours would be five percent of SNUN submission hours, or about five 

 

burden estimates from the 1994 RIA, which include the burden for recordkeeping (EPA, 1994, p. III-14). These 

burden estimates are based on the recordkeeping burden for polymer exemptions and not the recordkeeping burden 

associated with PMN submissions. Therefore, for this analysis we assume that any reduction in recordkeeping 

burden is captured in the reduction of the clerical burden, and we do not consider the one hour recordkeeping burden 

from the ePMN EA in order to avoid double counting. 
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to six hours.6 For this report, the SNUN recordkeeping hours were included in the SNUN submission 

hours (see Section 2.2.3) and the SNUN recordkeeping costs under 40 CFR §721.40 were not separately 

estimated.7 

2.2.5 Import Certification

In general, promulgation of a final SNUR triggers a TSCA Section 13 import certification requirement 

and the corresponding regulations at 19 CFR 12.118 to 12.127 and 19 CFR 127.28 for all imports of the 

relevant chemical substances. Thus, any U.S. manufacturer, importer, or processor receiving an imported 

shipment of chemicals subject to the proposed SNUR would have to certify that all chemical substances 

in the shipment either comply with all applicable rules and orders under TSCA or that all chemical 

substances in the shipment are not subject to TSCA.8

 The statement must be on or attached to a 

commercial invoice or entry document belonging to the imported shipment. 

In practice, import certification is fulfilled by checking a box on an invoice or entry document and 

generally imposes no additional burden or cost on the importer (EPA 2009b). Any potential burden 

associated with a submitter’s familiarization with this requirement is assumed to be included in the more 

general SNUR familiarization burden discussed above. 

2.2.6 Export Notification 

Under Section 12(b) of TSCA, exporters must notify EPA if they export or intend to export a chemical or 

an article subject to various TSCA sections (40 CFR §707.60 through 75). For TSCA 5(a)(2) (the section 

under which EPA promulgates significant new use rules) and certain other TSCA sections, this is a onetime notification requirement9 per destination country for each exporter of a chemical substance. After 

receiving a notification from a firm, EPA notifies the importing country and the United States State 

Department (40 CFR §707.70). To calculate the burden associated with making export notifications, EPA 

first estimated the average annual number of export notifications made by an exporter. EPA then derived 

the annual and per notification burden associated with preparing and submitting an export notification. 

 

6 For example, OPPT’s Information Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules 

for Existing Chemicals (Renewal), October 11, 2005, estimates SNUN recordkeeping costs at 5.67 hours (ICR 

118.08, page 10). 

7

 SNUN submission costs estimated in Section 2.2.3 of this report were based on PMN submission costs from a 

1994 report, Regulatory Impact Analysis of Amendments to Regulations for TSC Section 5 Premanufacture 

Notifications (EPA, 1994). Page III-14 of the 1994 report refers to “the normal records kept with a PMN submission 

which are included in the estimates for submission costs.” Page III-12 identifies “maintaining a file of the 

submission” as part of the labor hours for the PMN reporting form. These statements imply that the 95 to 114 total 

hours for a PMN submission (page III-10 of EPA 1994) included recordkeeping hours. 

8 The exact statements are as follows: For imports of chemical substances subject to TSCA, “I certify that all 

chemical substances in this shipment comply with all applicable rules or orders under TSCA and that I am not 

offering a chemical substance for entry in violation of TSCA or any applicable rule or order under TSCA.” For 

imports of chemical substances not subject to TSCA (e.g., pesticides), “I certify that all chemicals in this shipment 

are not subject to TSCA.” (40 CFR 707.20) 

9 On November 14, 2006, EPA revised the export notification requirement for chemicals subject to TSCA §5(a)(2), 

5(b), 5(e)(1) and 5(e)(2) from an annual to a one-time requirement per destination country for each exporter 

(November 14, 2006, 71 FR 66234). 
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Exporter Costs10

The 2009 TSCA Section 12(b) ICR estimated the annual export notification cost for an exporter under the 

one-time export notification requirement (EPA 2009b).11 These costs include the cost to the exporter of 

compiling a list of their products that are subject to TSCA Section 12(b) requirements, writing or revising 

an export notification letter to EPA, checking the outgoing shipments, and sending the notification letters 

with the associated shipping costs. 

The per-notification cost was calculated based on the assumption that the average exporter makes 12 

notifications per year.

12 Exporters making more notifications per year may benefit from economies of 

scale and have lower costs per notification; those making fewer notifications may have higher costs per 

notification. 

Estimated Submission (Mailing) Costs. Regulated companies will incur mailing costs for export 

notifications delivered to EPA. Notifications are assumed shipped via the U.S. Postal Service (USPS) as 

first-class registered mail with a return receipt (USPS 2010). The estimated per-shipment and annual 

mailing costs incurred by individual submitters are detailed in Table 6. 

Table 6: Derivation of Total Mailing Cost for 12 Notices

Dates that the rates were verified on United States Postal Service web site: April 2010 

Postal services costs

Registered mail, regular, with $0 declared value $10.60 

Return receipt, requested at time of mailing (receive by mail) $2.30 

Postage, regular First Class, up to 1 ounce $0.44

Cost per export notice – Subtotal $13.34 

Source: Mailing rates are from the US Postal Service web site as of April 2010 (http://www.usps.com/prices/). The mailing 

method comes from the Economic Analysis of the Proposed Change to TSCA Section 12(b) Export Notification 

Requirements, November 2005 (EPA, 2005), as clarified in a later SNUR economic analysis (EPA, 2007a, Table 8). 

Compile and Maintain the List of Products. Since TSCA §12(b) information collection activity has been 

in place for twenty years, most respondents will have already developed a list of their products subject to 

TSCA §12(b) export notification. Respondents need only check for new regulations promulgated and any 

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

technical time, which may also include some proportion of legal time (EPA 2009b). The total burden can 

vary from two hours per year up to two hours per month, depending on the number of products exported 

by the company and the number of their products subject to TSCA §12(b) (EPA 2009b). 

Write or Revise Export Notification. Companies that export chemicals subject to TSCA §12(b) reporting 

must prepare an export notification to send to EPA when export shipments are made. Time for initial 

preparation of the export notice may vary depending on whether the company has prior experience with 

this requirement. This step is estimated to take an average of one hour of technical time (which may also 

 

10 Most underlying data in this section come from the 2009 TSCA Section 12(b) ICR, ICR No.: 0795.13 

[Information Collection Request for] Notification of Chemical Exports - TSCA Section 12(b) Supporting Statement 

for Request for OMB Review under the Paperwork Reduction Act (EPA 2009b), with updating for inflation. 11 Page 11, Table 3 

12 EPA calculated the average number of export notifications per exporter in the 2009 TSCA Section 12(b) ICR 

(EPA 2009b) by dividing the estimated number of submitted notifications (3,500) by the estimated number of 

exporters (300). 
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include some proportion of legal time) per firm per year for 12 notifications per year, or 0.08 hours per 

notification (EPA 2009b). 

Check Orders and Send Notifications. Companies that export chemicals subject to TSCA §12(b) reporting 

must check outgoing shipments against the list of their products described above. A form letter notifying 

EPA and providing the required data must be printed and mailed within the required time period. This 

process is estimated to take an average one half hour of clerical time per export notification (EPA 2009b). 

The burdens and associated costs for each notification activity are provided in Table 7 below. 

Table 7: TSCA 12(b) Export Notification Cost per Notification 

Technical Clerical Total 

 $/Hr Hours 2009$3 $/Hr Hours 2009$3 Hours 2009$3

Compile list $59.49 0.78 $46.08 -- -- -- 0.78 $46.08 

Write letter $59.49 0.08 $4.96 -- -- -- 0.08 $4.96 

Check order and send 

notice -- -- -- $28.31 0.50 $14.17 0.50 $14.17 

Mailing cost1 -- -- -- - $13.34 

Total per notification 0.86 $51.04 0.50 $14.15 1.36 $78.54 

Notes: 

1

 Mailing costs reflect April 2010 USPS rates and can be found in Table 6.

2

Per notification costs are based on an average facility submitting 12 export notifications per year. 3

Costs may not equal labor wage rate times burden hours due to the rounded burden estimate presented in the table, unrounded 

estimates were used during the cost calculations. 

Source: ICR No.: 0795.13 [Information Collection Request for] Notification of Chemical Exports - TSCA Section 

12(b) Supporting Statement for Request for OMB Review under the Paperwork Reduction Act (EPA 2009b, p.10), 

and are updated to 2009 dollars. 

2.3 Industry Costs of SNUR, by Option (per Submission) 

The number of firms affected by not making submissions to EPA is not known; therefore, costs are not 

aggregated across the affected entities. Table 8 summarizes the costs to comply with the proposed rule, as 

described in more detail in section 2.2 above. 
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Table 8: Compliance Options and Associated Costs Incurred by a Firm Due to the Proposed SNUR

Option1 Costs Quantified Costs per Chemical (2008$)2

1. 

Electronic submission 

of a Significant New 

Use Notice (SNUN), 

indicating to EPA that 

the firm would like to 

manufacture, import, 

or process the 

chemical for a 

Significant New Use 

as defined in the 

SNUR. 

Costs of electronically submitting a 

SNUN, including rule 

familiarization, CDX registration 

(for companies that are first-time 

submitters), form completion, user 

fee, export notification cost (if 

relevant). Rarely, a firm may 

choose to conduct toxicity or fate 

testing to support the SNUN, but 

such testing is not required by law. 

$50.92 rule familiarization cost; $8,112 

submission cost (including SNUN 

recordkeeping and $2,500 fee). EPA usually 

receives well under ten SNUNs per year. Based 

on review of recent SNUNs, it appears that 

firms rarely conduct toxicity or fate testing to 

support a SNUN (such testing would be 

voluntary).3

 Export notifications costs are 

estimated at $78.56 per notification; total cost 

per company will vary. First time submitters 

would incur $178 for CDX registration and 

associated activities. 

2. 

Decide not to 

manufacture, import, 

or process the 

chemical for any nonexempt uses. 

Cost of the profit foregone as a 

result of not engaging in the 

commercial activity originally 

planned (opportunity costs). Other 

costs include rule familiarization, 

and export notification costs. 

Opportunity costs are not quantified. Other 

costs include rule familiarization ($50.92), and 

export notification costs ($78.56 per 

notification) would apply. 

Notes: 

1

 Firms may be subject to both options at once since submission of a SNUN results in profits foregone as a result of 

not manufacturing, importing, or processing the chemical. 

2 Quantified costs are attributable to the SNUR only if a firm would not otherwise follow the specified practices. 

Costs are detailed in Section 2.2. 

3 EPA does not require the development of test data for submission of a SNUN, although a firm may submit test data 

already in its possession and/or describe any other available data. Because EPA does not require the development of 

test data, EPA assumes that no firms will incur testing costs as a result of the proposed SNUR. 

2.4 Likelihood of a SNUN Submission 

Because the domestic manufacture, import and processing of C12-13 chloro alkanes for the uses subject to 

the SNUR have been phased out (see Section 1.1), very few, if any, entities are expected to submit a 

SNUN. 

2.5 Potential for Subsequent Regulatory Action 

EPA recognizes that if submission of a SNUN does result from the proposed SNUR, the Agency may 

take additional regulatory actions under TSCA. These additional regulatory actions might be necessary to 

further evaluate an intended new use and associated activities, or to prohibit or limit that activity before it 

occurs to prevent unreasonable risk of injury to human health or the environment. It is not known what 

specific subsequent regulatory actions, if any, the Agency may determine are necessary after reviewing a 

SNUN. Any such actions are highly dependent on the circumstances surrounding the individual SNUN 

(e.g., available information and scientific understanding of the chemical and its risks at the time the 

SNUN is being reviewed). 

Should EPA’s review of the SNUN result in further regulatory actions, the Agency will initiate and 

follow the appropriate procedures for taking those actions. Included in those procedures would be an 

assessment of the costs and benefits of those actions. 
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3. AGENCY COSTS 

As described in the following sections, EPA’s costs to review and process SNUN submissions are 

assumed to be the same as EPA costs to review PMNs. 

3.1 Labor Rates for EPA Staff 

Agency labor costs are calculated based on annual Federal salaries for the Washington-Baltimore area 

published by the Office of Personnel Management effective January 2009 (OPM 2009). EPA assumes 

that, on average, a federal GS-13, Step 5 full-time equivalent (FTE) will conduct its collection and 

administrative activities under the proposed rule.13 The average salary for a GS-13 Step 5 employee was 

$98,518 in 2009 without fringe benefits and overhead costs. In order to derive the fully loaded salary, 

EPA multiplied the annual salary by an assumed loading factor of 1.6 to reflect federal fringe benefits and 

overhead, which results in a fully loaded annual salary of $157,629 (see Table 9). Dividing the fully 

loaded annual salary by 2,080 hours (i.e., the number of hours in a work year) yields an hourly FTE 

compensation wage rate of $75.78. 

The Agency loading factor of 1.6 is from an EPA guide entitled Instructions for Preparing Information 

Collection Requests (ICRs) (EPA 1992).14 The 60 percent assumption was labeled “the benefits 

multiplication factor” in the EPA guide, but has been used in many EPA OPPT ICRs to reflect both fringe 

benefits and overhead for federal staff. For example, it was used in a document supporting EPA ICR No. 

1139.06 (EPA 2000), with the following explanation: 

The annual costs per FTE are derived by multiplying the annual pay rate by 1.6 (the benefits 

multiplication factor). The multiplication factor used is recommended in EPA’s Office of Policy, 

Planning, and Evaluation’s Instructions for Preparing Information Collection Requests (ICRs)

(June 1, 1992). An EPA internal phone call between Carol Rawie (OPPT/EETD/RIB) and Carl 

Koch (OPPE/RMD/IMB) on May 3, 1994, indicated that the 1.6 factor included not only benefits 

but also overhead. 

Fully loaded costs for Agency labor are shown in Table 9. 

 

13 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007) (EPA, 2007b), which covers PMN SNURs. Use of this 

grade level follows the approach introduced in EPA, 2007b. That report represented a change from an earlier PMN SNUR 

economic analysis (EPA, 2003), which used an average of GS-12 Step 1 and GS-12 Step 10 salaries. 14 page 30, footnote 9. 
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Table 9: Derivation of Loaded Agency Wage Rates 

Labor 

Category 

Data Source for Wage 

Information Date

Wage 

Fringe 

Benefit

Fringes as 

% wage 

Overhead 

as % wage

Fringe + 

overhead 

factor 

Loaded 

Wages 

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

EPA staff 

FTE 

Annual federal staff cost: 

OPM WashingtonBaltimore-Northern 

Virginia, DC-MD-PAVA-WV, area, GS-13 

Step 1 pay rates a 

Dec09 

$98,518 

(annual)

-- 

[Included 

in 60% 

overhead]

60% b

 1.60 

$157,629 

(annual) 

$47.36 

(hourly)

$75.78 

(hourly) 

Notes: a

 The Agency salary is the unloaded federal GS-13 Step 5 salary ($98,518 for 2009), from the OPM salary table for the 

Washington-Baltimore-Northern Virginia Locality Pay Area (OPM 2009). Hourly rates are based on annual salary divided by 

2,080 hours. 

b

 The 60% fringes-and-overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) 

(EPA 1992, page 30, footnote 9).

3.2 SNUN Processing Costs 

The list of review steps, estimates of extramural costs, and the percent of chemicals requiring a particular 

review step are derived from the costs for processing PMN submissions in a1994 EPA report entitled, 

Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture 

Notifications (EPA 1994).15 The Agency burden associated with processing a PMN has been adjusted to 

reflect burden reductions resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that 

requires the electronic submission of all TSCA section 5 notices. Electronic submission of SNUN forms 

is expected reduce Agency burden by 16.5 percent (EPA, 2009a).16

For each review step, the “EPA staff” cost is calculated by multiplying the number of FTEs (in the first 

column) by the fully loaded hourly salary. This shows EPA staff cost for chemicals requiring the selected 

review step. 

The Extramural Cost column shows costs for contractor support and other outside purchases for 

chemicals requiring the selected review step is inflated from 1993 prices using the Bureau of Labor 

Statistics (BLS) Employment Cost Index (ECI) data (BLS 2010b). The not seasonally adjusted ECI for 

total compensation of private industry professional and related workers (Series ID CIU2010000120000I) 

is used because it is the only series with continuous data since 1985, and that includes professional and 

technical labor, which perform the majority of Agency extramural activities. Table 10, below contains the 

derivation of inflation factors for Agency extramural costs. 

 

15 Table VII-1. 

16 p.28. 
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Table 10: Derivation of Inflation Factors for Agency Extramural Costs 

Item Inflation index source Starting 

year

Index for 

starting 

year 

(a) 

Index 

for 

2009 

(b) 

Inflation 

factor 

(b)/(a) 2

Agency Extramural costs 

White collar labor; 

equipment; supplies

BLS ECI, Total comp, Private 

industry, Professional and related, 

4th Q [BLS 2010d] 4

1993 67.0 111.4 1.663 

Source: 

Bureau of Labor Statistics. Employment Cost Index – Total Compensation: Professional and Related Private Industry, Not 

Seasonally Adjusted. (Series ID: CIU2010000120000I), extracted April 12, 2010 (BLS 2010b).

The Percent of Cases column in Table 11 is a weighting factor applied to reflect the fact that not all 

chemicals require each review step. For example, in the PMN process, all chemicals require 

Administrative Prescreening, but not all chemicals require the intensive scrutiny of “Standard Review.” 

The three types of submissions resulting from a SNUR may have weighting factors that differ from each 

other and from the weighting factors for PMNs. Changes in weighting factors could cause actual review 

costs to be higher or lower than calculated here. For example, some SNUNs require little review because 

they are determined to be “invalid” – i.e. not required in the first place. However, often a SNUN may take 

more Agency time than a typical PMN because of factors such as the need to retrieve old PMN records 

from archives, and the likelihood that more data requiring EPA review is submitted with a SNUN than 

would be submitted, on average, with a PMN. Resources were not available to update the review hours to 

reflect the current review process or to tailor the cost estimates to SNUNs. Therefore, for this analysis, the 

review steps and weighting factors are assumed to be the same as those derived in 1994 for PMNs. 

The Weighted Cost column is calculated by multiplying the un-weighted Costs (EPA staff cost plus 

extramural costs) by the percentage of cases requiring this review step. Weighted costs are then multiplied 

by the burden reduction of 16.5 percent to account for burden savings generated electronic submission. 

As shown in Table 11, this calculation yields total Agency costs of $4,934, per SNUN, for submission 

review and processing. 
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Table 11: Agency Costs for SNUN and Other Submission Review and Processing 

Review Steps 

EPA staff (FTE) Cost Extramural Cost 2 Unweighted 

Cost 

Pct. of 

Cases 

Weighted 

Cost3

ePM

Burd

Reduc

FTE 

fraction 

Cost per 

FTE 1

FTE Total 

($2009) 

1993 

dollars 

2009 

dollars 

(a) (b) (c)=(a)*(b) (d) (e) (f)=(c)+(e) (g) (h)=(f)*(g) (i

Pre-notice consultation 0.0024 $157,629 $378 $4.00 $6.65 $385 41% $158 0.1Administrative prescreen/ notice receipt/user fee 0.0024 $157,629 $378 $92.00 $152.97 $531 100% $531 0.1CRSS (Chemical Review and Search Strategy) 0.0025 $157,629 $394 $268.00 $445.60 $840 100% $840 0.1SAT (Structure Activity Team) 0.0006 $157,629 $94.58 $14.00 $23.28 $118 100% $118 0.1Engineering/Exposure 0.0015 $157,629 $236 $56.00 $93.11 $330 100% $330 0.1Exposure/Fate 0.0008 $157,629 $126 $0.00 $0.00 $126 100% $126 0.1Focus 0.0009 $157,629 $142 $23.00 $38.24 $180 100% $180 0.1Standard Review Functions 0.0219 $157,629 $3,452 $511.00 $849.63 $4,302 29% $1,247 0.1Division Directors Meeting 0.0129 $157,629 $2,033 $113.00 $187.88 $2,221 15% $333 0.1Order Development/Negotiation Review 

0.0171 $157,629 $2,695 $22.00 $36.58 $2,732 3% $81.96 0.1

Post Order Data Review 0.0886 $157,629 $13,966 $0.00 $0.00 $13,966 3% $419 0.1Order Modification 0.2167 $157,629 $34,158 $0.00 $0.00 $34,158 3% $1,025 0.1New Chemical SNUR Development 0.0277 $157,629 $4,366 $85.00 $141.33 $4,508 7% $316 0.1Notices of Commencement 0.0012 $157,629 $189 $40.00 $66.51 $256 31% $79 0.1FOIA (Freedom of Information Act) Requests 0.0333 $157,629 $5,249 $287.00 $477.19 $5,726 1% $57 0.1CBI (Confidential Business Information) Substantiation 0.0004 $157,629 $63.05 $3.00 $4.99 $68.04 100% $68.04 0.1TOTAL $5,909 0.16Notes: 1 GS-13 Step 5 salaries loaded with benefits and overhead. See Table 9 for derivation.

2 Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated from 1993 prices using the fa

3 Weighted costs were calculated using unrounded unit cost estimates, so results may differ from calculations using the rounded values shown in this table. 4 Electronic submission is expected to generate a cost savings of 16.5% to the Agency (EPA 2009b, p. 28).

Sources: FTEs per review step, 1993 extramural costs, and percents of cases are from EPA, 1994 Table VII-1, GS-13 salaries are from OPM 2009.
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) 17 Economic and Policy Analysis Branch 

3.3 Export Notification Cost 

The Agency burden and cost due to TSCA §12(b) export notification result from three tasks. In the first 

task, EPA receives export notifications from companies that intend to export one of the chemicals subject 

to TSCA §12(b) (EPA 2009b). In the second task, EPA staff prepares separate notification letters that are 

subsequently reviewed and delivered to importing countries, their embassies, or representatives, and to 

the importing country’s US embassies (EPA 2009b).17 The third task is comprised of EPA staff responses 

to public inquiries and other TSCA 12(b) activities. The work of responding to non-routine requests for 

information and clarification from industry and importing countries, and of handling other tasks 

associated with the TSCA §12(b) program, was estimated to require roughly 400 hours per year (EPA 

2009b). Since the current rulemaking covers only one chemical subject to TSCA 12(b) reporting for a 

minimal number of uses, a very small percent of such activity will be attributable to the current 

rulemaking. 

Because the domestic manufacture, import and processing of C12-13 chloro alkanes for the uses subject to 

the SNUR have been phased out, EPA does not expect to receive or send any export notifications. 

Nevertheless, should there be any notifications as a result of the current rulemaking, the costs to the 

Agency are presented per activity. The burden for the first two Agency activities is provided in Table 12 

below. To estimate the Agency cost, hourly burdens are multiplied by the loaded wage rate of a GS-13, 

Step 5 (see Table 9). 

Table 12: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2009$) 

Agency Activity 

Hours per 

Activity 

FTE per 

Activity1

Loaded Mailing 

Cost 

Total Agency Cost per 

Activity GS-13, Step 5 FTE 

Wage Rate 

(a) (b) = (a)/2,080 (c) (d) (e) = ((b)*(c))+(d) 

Process an incoming 

notification from an 

exporting company 

0.10 0.000048 $157,629 $0.00 $7.58 

Prepare and mail a 

notification to an 

importing country 

0.50 0.000240 $157,629 $13.34 $51.23 

Notes: 1

 The burden associated with an Agency activity is the burden for the Agency to process one incoming notification, 

or to prepare and mail an outgoing notification 

Source: Table 9 of this report derives Agency labor costs. Mailing costs are from Table 6 of this report. Other 

burdens are from EPA 2009b, updated for inflation.

 

17 See Table 6 for the cost of mailing one notification. 
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4. BENEFITS 

EPA requires additional information to fulfill its mandate under TSCA to fully assess the risks posed by 

the production, sale, and use of C12-13 chloro alkanes in the United States. A SNUN submission provides 

EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity 

before it occurs. This is especially important in this case, because C12-13 chloro alkanes, has been found to 

be harmful to wildlife, the environment, and human health, and there is no current US production or 

importation of the chemical. Therefore, the SNUN allows EPA to monitor any planned production or 

processing of the chemical and if the Agency chooses to continue to keep the chemical from being used in 

the United States. The proposed rule may also restrict future production, exposure, and release of the 

chemical, as a company may choose to manufacture or process an alterative that does not trigger a SNUR, 

as opposed to submitting a SNUN. 

Quantification of the benefits of the proposed rule would require more specific information about each 

user’s use patterns and preferences as well as the changes in these patterns and preferences that would 

result from the additional information made available under the proposed rule. These data are not readily 

available and collecting such data would be cost-prohibitive. 
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

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5. ADDITIONAL ANALYSES 

This section presents additional analysis of other potential impacts of this rulemaking, as required under 

various statutes and executive orders. 

5.1 Regulatory Flexibility Act 

The Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et. seq.), as amended by the Small Business 

Regulatory Enforcement Fairness Act, requires regulators to consider the impact of regulations on small 

entities, in particular small businesses. EPA’s experience to date is that, in response to the promulgation 

of SNURs covering over 1,000 chemicals, the Agency receives only a handful of notices per year. For 

example, the number of SNUNs was 4 in Federal fiscal year 2005, 8 in FY2006, 6 in FY2007, 8 in 

FY2008, and seven in FY2009.18 During this five-year period, three small entities submitted a SNUN, 

using the criteria for ‘small business’ was that the company checked the box on the PMN form, page 2, 

stating that it was a small business for the purpose of paying the $100 fee instead of the normal fee.19,20. 

5.2 Unfunded Mandates Reform Act 

Based on EPA's experience with proposing and finalizing SNURs, State, local, and Tribal governments 

have not been impacted by these rulemakings, and EPA does not have any reason to believe that any 

State, local, or Tribal government would be impacted by this rulemaking. 

5.3 Paperwork Reduction Act 

According to the Paperwork Reduction Act (PRA), 44 U.S.C. 3501 et seq., an Agency may not conduct or 

sponsor, and a person is not required to respond to a collection of information that requires OMB 

approval under the PRA, unless it has been approved by OMB and displays a currently valid OMB 

control number. The OMB control numbers for EPA's regulations in title 40 of the CFR, after appearing 

in the Federal Register, are listed in 40 CFR, part 9, and included on the related collection instrument, or 

form, if applicable. The information collection requirements related to this action have already been 

approved by OMB pursuant to the PRA under OMB control number 2070-0038 (EPA ICR No. 1188). 

This action does not impose any burden requiring additional OMB approval. If an entity were to submit a 

SNUN to the Agency, the annual burden is estimated to average 97 hours per response – 0.82 hours for 

rule familiarization (Section 2.2.1), 2.80 hours for CDX registration, CDX electronic signature, and 

pay.gov account setup (Section 2.2.2), 92.20 hours for form completion and submission 2.2.3), and 1.36 

hours for export notification (Section 2.2.4). 

 

5.4 National Technology Transfer and Advancement Act 

This action does not involve any technical standards; therefore, section 12(d) of the National Technology 

Transfer and Advancement Act of 1995 (NTTAA), Public Law 104–113, section 12(d) (15 U.S.C. 272 

note), does not apply to this action. 

 

18 February 5, 2009 email from Carol Rawie, EPA Office of Pollution Prevention and Toxics, to Tulika Narayan and 

Kimberly Wilson, Abt Associates. The counts include both “valid” and “invalid” SNUNs. SNUN numbering is 

according to Federal fiscal year, ending September 30. 

19 February 5, 2009 email from Carol Rawie, EPA Office of Pollution Prevention and Toxics to Tulika Narayan and 

Kimberly Wilson, Abt Associates. 

20 In order to submit SNUN as a “small business” a company needs to be classified as small using the TSCA based 

definition of annual revenue of less than $4,000,000 per year. This definition is not consistent with the definition of 

a small business using Small Business Administration (SBA) NAICs based definitions. 
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5.5 Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations 

This action does not involve special considerations of environmental justice-related issues as required by 

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and 

Low-Income Populations (59 FR 7629, February 16, 1994). 

5.6 Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks 

The proposed SNUR does not address environmental health or safety risks disproportionately affecting 

children. 

5.7 Executive Order 13132: Federalism 

The proposed SNUR is not expected to have a substantial direct effect on States, on the relationship 

between the national government and the States, or on the distribution of power and responsibilities 

among the various levels of government as specified in Executive Order 13132, entitled Federalism (64 

FR 43255, August 10, 1999). 

5.8 Executive Order 13175: Consultation and Coordination with Indian Tribal Governments 

This proposed SNUR would not have Tribal implications because it is not expected to have substantial 

direct effects on Indian Tribes. This proposed rule would not significantly or uniquely affect the 

communities of Indian Tribal governments, nor would it involve or impose any requirements that affect 

Indian Tribes. Accordingly, the requirements of Executive Order 13175, entitled Consultation and 

Coordination with Indian Tribal Governments (65 FR 67249, November 6, 2000), do not apply. 

5.9 Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use 

This proposed SNUR is not expected to affect energy supply, distribution, or use.
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

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6. REFERENCES 

15 U.S.C. 272, National Technology Transfer and Advancement Act of 1995 (NTTAA), Public Law 104–

113, Section 12(d). 

19 CFR 12, Customs Duties: Special Classes of Merchandise, Code of Federal Regulations, Part 12, Title 

19, August 1, 1983. 

40 CFR 707, Chemical Imports and Exports, Code of Federal Regulations, Part 707, Title 40, July 1, 

2003. 

40 CFR 720, Premanufacture Notification, Code of Federal Regulations, Part 720, Title 40, July 1, 2003. 

40 CFR 721, Significant New Use of Chemical Substances, Code of Federal Regulations, Part 721, Title 

40, July 1, 2003. 

59 FR 7629, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income 

Populations, Federal Register, Volume 59, February 16, 1994. 

59 FR 22951, Consultation and Coordination with Indian Tribal Governments, Federal Register, Volume 

59, November 6, 2000. 

62 FR 19885, Protection of Children from Environmental Health Risks and Safety Risks, Federal 

Register, Volume 62, April 23, 1997. 

64 FR 43255, Federalism, Federal Register, Volume 65, August 10, 1999. 

66 FR 28355, Actions Concerning Regulations that Significantly Affect Energy Supply, Distribution, or 

Use, Federal Register, Volume 66, May 22, 2001. 

71 FR 66234, Export Notification; Change to Reporting Requirements, Final Rule, Federal Register, 

Volume 71, November 14, 2006. Available in docket EPA-HQ-OPPT-2005-0058 at 

http://www.regulations.gov. 

BLS, 2006a. U.S. Bureau of Labor Statistics, Employer Costs for Employee Compensation: Changes to 

NAICS and SOC, Table 2. ECEC Occupational Comparability between SOC and OCS. 

Downloaded February 2006 from http://www.bls.gov/ncs/ect/sp/ecsm0003.htm.

BLS, 2006b. U.S. Bureau of Labor Statistics, Employment Cost Index News Release Text: Employment Cost 

Index, March 2006 (April 28, 2006), at http://www.bls.gov.

BLS, 2006c. U.S. Bureau of Labor Statistics. Change has Come to the ECI (June 14, 2006) at 

http://www.bls.gov/ncs/ect/sp/ecsm0001.htm 

BLS, 2010a. U.S. Bureau of Labor Statistics. Employer Costs for Employee Compensation Supplementary 

Tables December 2009. March 10, 2010. Available at: 

http://www.bls.gov/ncs/ect/sp/ecsuptc13.pdf. (Note: The BLS report title and content is updated 

periodically to include more recent data, on the same website.) 
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) 22 Economic and Policy Analysis Branch 

BLS, 2010b. U.S. Bureau of Labor Statistics. Employment Cost Index – Total Compensation: 

Professional and Related Private Industry, Not Seasonally Adjusted. (Series ID: 

CIU2010000120000I). Accessed April 12, 2010. 

Branch, 2006. Raphael E. Branch and Lowell Mason. U.S. Bureau of Labor Statistics, “Seasonal 

adjustment in the ECI and the conversion to NAICS and SOC.” Monthly Labor Review. Vol. 129, 

No. 4, April 2006. Available at www.bls.gov. 

CPIA. 2009. Chlorinated Paraffins Industry Association. Chlorinated Paraffins: A Status Report. 

Available at: http://www.regnet.com/cpia/status_report.html. Accessed April1, 2009. 

EC. 1999. European Commission. European Union Risk Assessment Report Alkanes, C10-13, chloro, CAS 

No. 85535-84-8. Volume 4. EUR 19010EN. Office for Official Publications of the European 

Communities: Luxembourg, 2008. 

EC. 2005. European Commission. Updated Risk Assessment of Alkanes, C14-17, chloro, (MCCP), Part I 

Environment, CAS No. 85535-85-9. Volume 58. EUR 21640 EN. Office for Official Publications 

of the European Communities: Luxembourg, 2005. 

EC. 2007. European Commission. European Union Risk Assessment Report Alkanes, C14-17, chloro, 

(Medium-Chain Chlorinated Paraffins), CAS No. 85535-85-9. Draft Environment Addendum of 

August 2007. R331_0807_env. Available at: http://ecb.jrc.ec.europa.eu/DOCUMENTS/ExistingChemicals/RISK_ASSESSMENT/ADDENDUM/mccp_add_331.pdf. Accessed December 22, 

2009. 

ECHA. 2008a. European Chemicals Agency. Data on Manufacture, Import, Export, Uses and Releases of 

Alkanes, C10-13, chloro, SCCPs as well as Information on Potential Alternatives to Its Use. 

Available at: 

http://echa.europa.eu/doc/consultations/recommendations/tech_reports/tech_rep_alkanes_chloro.

pdf. Accessed December 11, 2009. 

EPA, 1992. U.S. EPA, Office of Policy, Planning, and Evaluation. Instructions for Preparing Information 

Collection Requests (ICRs). Washington, DC, June 1, 1992. 

EPA, 1994. US EPA, Office of Toxic Substances, Regulatory Impacts Branch. Regulatory Impact 

Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications. 

Washington, DC: U.S. EPA/OPPT/EETD/RIB, September 9, 1994. (OTS/RIB later became 

OPPTS/EPAB.) 

EPA, 2000. U.S. EPA, Office of Pollution Prevention and Toxics, ICR No. 1139.06. [Information 

Collection Request for] TSCA Existing Chemical Test Rules, Consent Orders, Test Rule 

Exemptions, and Voluntary Test Data Submissions: Supporting Statement for Request for OMB 

Review under the Paperwork Reduction Act. Attachment 5, Wage Rates Estimation, August 29, 

2000. 

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

Revised Economic Analysis for the Amended Inventory Update Rule: Final Report. Washington, 

DC. August 2002. 
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) 23 Economic and Policy Analysis Branch 

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. 

Washington, DC, June 10, 2002. 

EPA, 2003. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. 

Economic Analysis of Expedited Significant New Use Rules for 65 Chemical Substances. 

Washington, DC, 2003. Available in docket EPA-HQ-OPPTS-2002-0078 at: 

http://www.regulations.gov.

EPA, 2005. Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Economic 

Analysis of the Proposed Change to TSCA Section 12(b) Export Notification Requirements, 

November 2005. Available in Federal Docket Management System as EPA-HQ-OPPT-2005-005 

8-0017 at: http://www.regulations.gov. 

EPA, 2006a. Inventory Update Reporting (IUR): Non-Confidential 2006 TSCA Inventory Update Rule 

(IUR) Records. Available at: http://cfpub.epa.gov/iursearch/index.cfm?s=chem. Accessed April 

9, 2009. 

EPA, 2007a. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis 

Branch. Economic Analysis of Expedited Significant New Use Rules for 38 Chemical 

Substances (EPA Docket OPPT-2006-0898), August 17, 2007. 

EPA, 2007b. U.S. EPA, Office of Pollution Prevention and Toxics, ICR No. 0574.14. [Information 

Collection Request for] Pre-Manufacture Review Reporting and Exemption Requirements for 

New Chemical Substances and Significant New Use Reporting Requirements for Chemical 

Substances: Supporting Statement for a Request for OMB Review under The Paperwork 

Reduction Act, December 6, 2007. 

EPA, 2009a. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis 

Branch. Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule. 

(EPA-HQ-OPPT-2008-0296). July 13, 2009. 

EPA, 2009b. U.S. EPA, Office of Pollution Prevention and Toxics. ICR No.: 0795.13 [Information 

Collection Request for] Notification of Chemical Exports - TSCA Section 12(b) Supporting 

Statement for Request for OMB Review under the Paperwork Reduction Act. Available at 

http://www.regulations.gov. Accessed March 6, 2009. 

EPA, 2009c. U.S. EPA, Office of Chemical Safety and Pollution Prevention. Short-Chained Chlorinated 

Paraffins (SCCPs) and Other Chlorinated Paraffins Action Plan. Available at: 

http://www.epa.gov/opptintr/existingchemicals/pubs/actionplans/sccps_ap_2009_1230_final.pdf

Government of Canada. 2008. Order Adding Toxic Substances to Schedule 1 to the Canadian 

Environmental Protection Act, 1999. Canada Gazette. September 20, 2008, 142 (38). 

HELCOM. 2002. Helsinki Commission. Baltic Marine Environment Protection Commission. Project 

Team for the Implementation of the HELCOM Objective with regard to Hazardous Substances 

7th Meeting. March 11-13, 2002. Final Report. 

IARC. 1990. International Agency for Research on Cancer. Monographs on the Evaluation of 

Carcinogenic Risks to Humans. Volume 48. Some Flame Retardants and Textile Chemicals,and 
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) 24 Economic and Policy Analysis Branch 

Exposures in the Textile Manufacturing Industry Summary of Data Reported and Evaluation. 

World Health Organization: Paris, France. 

Klaunig, J.E., Babich, M.A., Baetcke, K.P. Cook, J.C., Corton, J.C., David, R. M., DeLuca, J.G., Lai, 

D.Y., McKee, R. H., Peters, J.M., Roberts, R.A. and Fenner-Crisp, P.A. (2003). PPARα AgonistInduced Rodent Tumors: Modes of Action and Human Relevance. Crit. Rev. Toxicol. 33: 655-

780. 

NTP. 1986a. National Toxicology Program. Department of Health and Human Services. Toxicology and 

Carcinogenesis Studies of Chlorinated Paraffins(C12, 60% Chlorine) in F344/N Rats and B6C3F1

Mice. May 1986. Available at: http://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr308.pdf. Accessed 

December 11, 2009. 

NTP. 1986b. National Toxicology Program. Department of Health and Human Services. Toxicology and 

Carcinogenesis Studies of Chlorinated Paraffins(C23, 43% Chlorine) in F344/N Rats and B6C3F1

Mice. May 1986. Available at: http://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr305.pdf. Accessed 

December 11, 2009. 

NTP. 2005. National Toxicology Program. Department of Health and Human Services. Report on 

Carcinogens, Eleventh Edition; Substance Profiles: Chlorinated Paraffins (C12, 60% Chlorine) 

CAS No. 108171-26-2. 2005. Available at: 

http://ntp.niehs.nih.gov/ntp/roc/eleventh/profiles/s034chlo.pdf. Accessed Dec 11, 2009. 

OPM, 2009. Office of Personnel Management, Salary Table 2009-DCB, Washington-Baltimore/Northern 

Virginia, DC-MD-PA-VA-WV. Available at: http://www.opm.gov/oca/09tables/pdf/DCB.pdf. 

Rawie, Carol. 2009. EPA Office of Pollution Prevention and Toxics. Personal communication with Tulika 

Narayan and Kimberly Wilson of Abt Associates via e-mail. February 5, 2009. 

Sleemi, 2006. Fehimida Sleemi. U.S. Bureau of Labor Statistics, “Employment Cost Index Publication 

Plans”. Monthly Labor Review. Vol. 129, No. 4, April 2006. available at 

www.bls.gov/opub/mlr/2006/04/art2full.pdf 

UNECE. 2006. United Nations Economic Commission for Europe. Short Chain Chlorinated Paraffins 

Track B Review for the UNECE LRTAP Task Force on Persistent Organic Pollutants – Final 

Report. May 2006. 

UNEP. 2009. United Nations Environment Programme. Stockholm Convention on Persistent Organic 

Pollutants (POPs). Persistent Organic Pollutants Review Committee. Revised Draft Risk Profile: 

Short-Chained Chlorinated Paraffins. 9 July 2009. UNEP/POPS/POPRC.5/2. Available at: 

http://chm.pops.int/Convention/POPsReviewCommittee/hrPOPRCMeetings/POPRC5/POPRC5D

ocuments/tabid/592/language/en-US/Default.aspx. Accessed December 11, 2009. 

USPS, 2010. U.S. Postal Service Mailing and postage rates. Available at: http://www.usps.com/prices. 

Accessed August 16, 2010. 

Weinstein, 2004. Harriet G. Weinstein and Mark A. Loewenstein, U.S. Bureau of Labor Statistics. 

Comparing Current and Former Industry and Occupation ECEC Series. Originally posted August 

25, 2004 at http://www.bls.gov/opub/cwc/cm20040823ar01p1.htm 
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

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APPENDIX A 

INFLATORS AND WAGE RATES
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A. INFLATORS AND WAGE RATES 

This appendix describes the derivation of the fully loaded labor rates and inflation factors used in 

calculating costs of labor, materials, and other inputs. Costs for this report are for year-end 2008. 

A.1 Derivation of Loaded Wage Rates 

Unit labor costs are calculated by adding fringe benefits and overhead to the wage or salary to derive a 

fully loaded labor cost. The basic method is described in Wage Rates for Economic Analysis of the 

Toxics Release Inventory Program (EPA, 2002b). The resulting loaded labor rates are given in Table 14. 

Costs are calculated for several labor categories: Managerial, Professional/Technical, Clerical, and EPA 

staff. 

In March 2004, BLS began using the North American Industry Classification System (NAICS) codes 

instead of the Standard Industrial Classification (SIC) System, and the Standard Occupational 

Classification (SOC) system instead of the Occupational Classification System (OCS). Table 13 shows 

the crosswalk between old and new occupational titles. 

Table 13 : Detail of Labor Categories Used in the Analysis 

EPAB Reports Labor Category BLS Old Title (OCS) BLS New Title (SOC) 

Managerial Executive, administrative, and 

managerial 

Management, business, and 

financial 

Professional/Technical Professional specialty and technical Professional and related 

Clerical Administrative support, including 

clerical Office and administrative support 

Source: Employer Costs for Employee Compensation: Changes to NAICS and SOC, Table 2. ECEC Occupational 

Comparability between SOC and OCS (BLS, 2006a and Weinstein, 2004). 

A.1.1 Derivation of Labor Rates for Managerial, Professional/Technical, Clerical, and 

Production Labor 

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

from the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation (ECEC) data,21

for December, for manufacturing industries.22

The cost of fringe benefits such as paid leave and insurance, specific to each labor category, are taken 

from the same ECEC series. Fringe benefits as a percent of wages are calculated separately for each labor 

category. For example, for December 2009, the average wage rate for professional/technical23 labor was 

$35.96; the average fringe benefit was $17.42. Fringe benefits as a percent of wages were $17.42/$35.96, 

or approximately 48.4 percent. 

 

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

Substances: EPA Docket OPPT-2003-0063 (EPAB, 2007a). 22 Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006 – December 2008. 

(BLS, 2009a). This follows the approach introduced in EPAB, 2007a. Earlier PMN SNUR economic analyses, such as EPA, 

2003a, used ECEC data for “All Goods Producing” sectors (manufacturing, mining, and construction). However, the 

manufacturing sector data seem more relevant since the SNURs mainly affect the chemicals industry. 23 This follows terminology introduced in EPAB, 2007a. Earlier SNUR economic analyses used the term “technical” labor. Here 

the category is called “professional/technical” labor, to make clear how it relates to BLS categories. In 2004, BLS changed 

from the Occupational Classification System, OCS, to the Standard Occupational Classification system, SOC. In the process, 

the “Professional specialty and technical” category became the “Professional and related” category. However, the coverage of 

the old and new occupational groups is approximately the same. See the BLS article, Comparing Current and Former Industry 

and Occupation ECEC Series (Weinstein, 2004).
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An additional loading factor of 17 percent is applied to wages to account for overhead. This approach is 

used for consistency with Office of Pollution Prevention and Toxics economic analyses for two major 

rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b), 

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

This overhead loading factor is added to the benefits loading factor, and the total is then applied to the 

base wage to derive the fully loaded wage. For example, the December 2009 fully loaded wage for 

professional/technical labor is $35.96 × (1+0.4844 + 0.17) = $59.49.. 

Fully loaded costs for managerial, clerical, and production labor are calculated in a similar manner, as 

shown in Table 14. 

A.1.3 Derivation of Labor Rates for EPA Staff 

Agency labor costs are calculated based on annual Federal salaries for the Washington-Baltimore area 

published by the Office of Personnel Management effective January 2008 (OPM, 2008). The average 

salary for one FTE staff member is estimated as the salary for a GS-13 Step 5 employee.

24 

Multiplying the annual pay by an assumed loading factor of 1.6 to reflect Federal fringe benefits and 

overhead, the loaded annual salary of EPA staff was calculated to be $150,440. 

The Agency loading factor is from an EPA guide, Instructions for Preparing Information Collection 

Requests (ICRs) (EPA, 1992a, page 30, footnote 9). The 60 percent assumption was labeled “the benefits 

multiplication factor” in the EPA Guide, but has been used in many EPA Office of Pollution Prevention 

and Toxics ICRs to reflect both fringe benefits and overhead for Federal staff. For example, it was used in 

an August 2000 document supporting ICR No. 1139.06 (EPA, 2000), with the following explanation: 

“The annual costs per FTE are derived by multiplying the annual pay rate by 1.6 (the benefits 

multiplication factor). The multiplication factor used is recommended in EPA’s Office of Policy, 

Planning, and Evaluation’s Instructions for Preparing Information Collection Requests (ICRs)

(June 1, 1992). An EPA internal phone call between Carol Rawie (OPPT/EETD/RIB) and Carl 

Koch (OPPE/RMD/IMB) on May 3, 1994, indicated that the 1.6 factor included not only benefits 

but also overhead.” (ICR No.1139.06) 

 

24 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007), which covers PMN SNURs. Use of this grade level 

follows the approach introduced in EPAB, 2007a. That report represented a change from the earlier PMN SNUR economic 

analysis (EPA, 2003a), which used an average of GS-12 Step 1 and GS-12 Step 10 salaries.
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Po

(CAS RN): 71011-12-6) 28 Econom

Table 14: Derivation of Loaded Wage Rates 

EPAB Labor 

Category Data Sources Date Wage Fringe Benefit Fringes as % Wage Over- head % Wage2 Fringe + Overhead Factor 

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

Managerial 

BLS ECEC, Private Manufacturing 

industries, “Mgt, Business, and Financial”3

Dec-09 $42.36 $18.68 44.10% 17% 1.61 

Professional/ 

Technical 

BLS ECEC, Private Manufacturing 

industries, “Professional and related“3

Dec-09 $35.96 $17.42 48.44% 17% 1.65 

Clerical 

BLS ECEC, Private Manufacturing 

industries, “Office and Administrative Support” 3

Dec-09 $17.21 $8.17 47.47% 17% 1.64 

EPA staff 

FTE 

Annual Federal staff cost: OPM Washington-Baltimore-Northern Virginia, DC-MD-PA-VA-WV, area, GS-13 Step 5 pay rates, with 60% overhead. 3

Dec-09 $98,518(annual) -- 

[Included in 

60% 

overhead] 

60% 1.6 

Notes: 1Wage data are rounded to the closest penny in this table; however, in calculations using these numbers for this report, unrounded values were used. 2An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b), a

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

3 The salary is unloaded Federal GS-13 Step 5 salary for calendar 2009, from the Office of Personnel Management salary table for Washington-Baltimore-N

The 60% fringes-and-overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (EPA, 1992, page 30, footno
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) 29 Economic and Policy Analysis Branch 

A.2 Derivation of Inflation Factors 

Complete information on the derivation of the inflation factors used is given in Table 15. In 2006, the 

Bureau of Labor Statistics (BLS) made several changes to the Employment Cost Index. The changes are 

described on a BLS web page, “Change has come to the ECI,” (BLS, 2006c) and in several April 2006 

Monthly Labor Review articles posted on the BLS web site: “Changes affecting the Employment Cost 

Index: an overview” (Caroll 2006); “Employment Cost Index Publication Plans” (Sleemi, 2006); and 

“Seasonal adjustment in the ECI and the conversion to NAICS and SOC” (Branch, 2006). 

Under a mandate from OMB, BLS changed its classification of industries and occupations from the 

Standard Industrial Classification (SIC) and Occupational Classification System (OCS) to the North 

American Industry Classification System (NAICS) and Standard Occupational Classification (SOC) 

system. In 2006, BLS adjusted all ECI series to reflect this change. 

In addition to changing the industry and occupational classification systems, in 2006, BLS rebased the 

ECI from June 1989 = 100 to December 2005 = 100 for all current and historical non-seasonally adjusted 

series, including the NAICS and SIC based series. (Seasonally adjusted indices, including those in Table 

A-2 of this report, may not exactly equal 100 for December 2005 as a result of the seasonal adjustment. 

Seasonal adjustments are explained in Branch, 2006.) 

According to BLS, the official ECI for the years 1975-2005 is the SIC-OCS based series, and for 

subsequent years, the official ECI is the NAICS-SOC based series (Sleemi, 2006, p.8).25 

“Starting year” indices in Table 15 continue to be SIC-SOC based. Current year indices are NAICS-SOC 

based. We use indices from both the NAICS-SOC and the SIC-OCS based ECI series because neither 

series spans the entire period over which testing and other costs need to be inflated. 

 

25 BLS has been publishing the NIACS-SOC based ECI series since March 2001 and it became official in March 2006. The SICOCS based series and NAICS-SOC series have different series ID numbers, even when they describe essentially the same 

population. For example the series ID for seasonally adjusted total compensation for all private industry workers is 

ECS10002I for the SIC-OCS series and CIS2010000000000I for the NAICS-SOC series. 
Economic Analysis of SNUR for Alkanes, C12-13, chloro U.S. EPA Office of Pollution Prevention and Toxics 

(CAS RN): 71011-12-6) 30 Economic and Policy Analysis Branch 

Table 15: Derivation of Inflation Factors 

Item Inflation Index Source1 Starting

Year 

Index for 

Starting 

Year (a) 

Index for 

2008 

(b) 

Inflation 

Factor 

(b)/(a)2

Export notification 

BLS ECI, not SA, Total comp, 

Private industry, White Collar. 

ECS11102I, 4th Q [BLS, 2010b] 

1993 66.5 110.4 1.660 

Agency Extramural costs 

White collar labor; 

equipment; supplies

BLS ECI, not SA, Total comp, 

Private industry, White Collar. 

ECS11102I, 4th Q [BLS, 2010b]

1993 67.0 111.4 1.663 

Labels, placards etc. BLS CPI, inflation calculator, not 

SA. Annual [BLS, 2010c] 1997 160.5 214.537 1.337 

File cabinet 

 

Photocopies 

BLS CPI, inflation calculator, 

Annual [BLS,2010c] Record keeping materials 1988 118.3 214.537 1.813 

 

Key: BLS = Bureau of Labor Statistics. CPI = Consumer Price Index. ECI = Employment Cost Index. SA = Seasonally Adjusted. Total 

Comp = Total Compensation (wages/salaries and benefits). 4th Q = Fourth Quarter. “ECS10002I” etc. refer to BLS series Ids. 

Notes: 

1 In 2006, Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) series “were rebased to December 2005 = 100 from June 

1989 = 100.” The change is reflected in the indices in this table and explained on the BLS website, Employment Cost Index News 

Release Text: Employment Cost Index, March 2006 (BLS, 2006b). The Consumer Price Index (CPI) was not rebased. 

“Starting year” ECI indices are SIC-OCS based: Seasonally Adjusted (SA) ECS10002I for private industry All Workers, and not SA

ECU11122I for private industry Professional and Related Workers. 

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

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

2

 Inflation factors are rounded to three decimal places in this table, but calculations in this report use the unrounded values. BLS CPI 

values were published with one decimal place through 2006 and with three decimal places after that. 

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

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

4

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

OPPT-2009-0922 (EPA, 2010d) we began to use the not-seasonally adjusted CIU2010000120000I for private industry Professional, 

and Related workers, instead of SA CIS2010000W00000I for private industry white collar workers because BLS retired the “whitecollar” series.