Economic Analysis of the Final

Significant New Use Rule for 

Trichloroethylene (TCE)

(EPA DOCKET EPA-HQ-OPPT-2014-

0697; RIN 2070-AK05)

March 10, 2016

TCE SNUR_FINAL_EA_2016-03-10.docx

-- Does not contain TSCA CBI --

Prepared for:

Economic and Policy 

Analysis Branch

Chemistry, Economics, and 

Sustainable Strategies Division

Office of Pollution, Prevention, and Toxics

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue

Washington, DC 20460

This Page Intentionally Left Blank
▌pg. i

Table of Contents

1. Introduction ...................................................................................................................................1-1

1.1 Statutory Authority ...............................................................................................................1-1

1.2 Summary of Methodology ....................................................................................................1-1

1.3 Organization of this Report...................................................................................................1-1

2. Chemical Uses and Manufacturers..............................................................................................2-1

2.1 Significant New Uses under the Final SNUR.......................................................................2-1

2.2 Chemical Uses.......................................................................................................................2-2

2.2.1 Historical Uses........................................................................................................2-2

2.2.2 Ongoing Uses..........................................................................................................2-2

2.2.3 Consumer Product Information...............................................................................2-4

2.3 Potentially Affected Companies ...........................................................................................2-4

3. Industry Compliance Costs ..........................................................................................................3-1

3.1 Wage Rates ...........................................................................................................................3-2

3.2 Unit Industry Compliance Costs...........................................................................................3-3

3.2.1 Rule Familiarization................................................................................................3-3

3.2.2 CDX Registration, CDX Electronic Signature, and Pay.gov Account Setup .........3-3

3.2.3 Form Completion and Submission Fee ...................................................................3-4

3.2.4 Recordkeeping for Companies Choosing to Submit a SNUN ................................3-6

3.2.5 Recordkeeping for Companies that Do Not Submit a SNUN.................................3-6

3.2.6 Customer Notification.............................................................................................3-7

3.2.7 Import Certification.................................................................................................3-7

3.2.8 Export Notification..................................................................................................3-8

3.2.9 Estimated Number of Annual Export Notifications per Exporter...........................3-8

3.2.10 Exporter Costs.........................................................................................................3-9

3.3 Summary of per Submission Costs, by Option ...................................................................3-11

3.4 Likelihood of SNUN Submission .......................................................................................3-12

3.5 Potential for Subsequent Regulatory Actions.....................................................................3-12

4. Agency Costs..................................................................................................................................4-1

4.1 Labor Rates for EPA Staff ....................................................................................................4-1

4.2 SNUN Processing Costs........................................................................................................4-2

4.3 Export Notification Cost .......................................................................................................4-5

5. Benefits ...........................................................................................................................................5-1

6. Additional Analyses.......................................................................................................................6-1

6.1 Regulatory Flexibility Act ....................................................................................................6-1

6.2 Unfunded Mandates Reform Act (UMRA)...........................................................................6-1

6.3 Paperwork Reduction Act (PRA)..........................................................................................6-1

6.4 Executive Order 13132, Federalism......................................................................................6-2

6.5 Executive Order 12898, Environmental Justice....................................................................6-2

6.6 Executive Order 13045, Protection of Children....................................................................6-2

6.7 Executive Order 13175, Tribal Governments.......................................................................6-2

6.8 Executive Order 13211, Energy Supply, Distribution, or Use..............................................6-3

6.9 Executive Order 13563, Improving Regulation and Regulatory Review .............................6-3

7. References ......................................................................................................................................7-1
▌pg. ii

Appendix A – Inflators and Wage Rates

Appendix B – 2013 TRI Data for TCE
▌pg. iii

List of Tables

Table 2-1: 2012 CDR Consumer and Commercial Use Data for TCE.................................. 2-2

Table 2-2: 2012 CDR Industrial Use Data for TCE .............................................................. 2-3

Table 2-3: Site Level Production Volumes as Reported in the Non-Confidential 2012 CDR 

Database.............................................................................................................. 2-5

Table 3-1: Loaded Industry Wage Rates, December 2013.................................................... 3-2

Table 3-2: Rule Familiarization Burden and Cost for SNUR Submitters ............................. 3-3

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

and Cost for First-Time Submitters.................................................................... 3-4

Table 3-4: Industry Cost Estimate to Complete the SNUN Form ......................................... 3-6

Table 3-5: Industry Cost Estimate to Complete and Submit the SNUN Form...................... 3-6

Table 3-6: Annual Per-Chemical Costs of Recordkeeping Requirement for Companies that 

Choose not to Submit a SNUN........................................................................... 3-7

Table 3-7: Derivation of Total Mailing Cost for 13 Notices................................................. 3-9

Table 3-8: TSCA 12(b) Export Notification Cost per Notification ..................................... 3-11

Table 3-9: Compliance Options and Associated Costs Incurred by a Firm Due to the Final SNUR

.......................................................................................................................... 3-12

Table 4-1: Derivation of Loaded Agency Wage Rates, 2013................................................ 4-1

Table 4-2: Derivation of Inflation Factors for Agency Extramural Costs............................. 4-2

Table 4-3: Agency Costs for SNUN and Other Submission Review and Processing ........... 4-4

Table 4-4: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2013$) .... 4-5
▌pg. iv

Contributors

The EPA analyst responsible for this report was Lynne Blake-Hedges. Analytical and draft preparation 

support was provided by Abt Associates Inc. under EPA Contract No. EP-W-08-010.
▌pg. v

Executive Summary

Under section 5(a)(2) of the Toxic Substances Control Act (TSCA), the U.S. Environmental Protection 

Agency (EPA) is finalizing a significant new use rule (SNUR) at 40 CFR §721.10851 for 

trichloroethylene (TCE) (CAS 79-01-6) by designating manufacturing (including import) or processing of 

TCE for use in a consumer product, with an exception for use in cleaners and solvent degreasers, film 

cleaners, hoof polishes, lubricants, mirror edge sealants, and pepper spray. 

TCE is a volatile organic compound (VOC) that is classified as a human carcinogen (EPA, 2014a). It is a 

colorless liquid with a pleasant, sweet odor resembling that of chloroform (EPA, 2014a). EPA is 

concerned about the adverse effects of TCE and identified it for risk assessment under EPA's Existing 

Chemicals Management Program. EPA reviewed readily available information on TCE including uses, 

physical and chemical properties, fate, exposure potential, and associated hazards to humans and the 

environment. TCE was selected for risk assessment based on its potential hazard (e.g., human 

carcinogen), and its exposure profile and the risk assessment identified health risks to consumers using 

solvent degreasers and spray‐applied protective coating for arts and crafts (EPA, 2014a).

Persons subject to this SNUR will be required to notify EPA at least 90 days before commencing any 

significant new use. The required notifications are intended to provide EPA with the opportunity to 

evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs. A firm 

intending to engage in these activities will be required to submit a Significant New Use Notice (SNUN), 

incurring an estimated submission cost of approximately $8,900 for large businesses per chemical1

, and 

potentially other minor costs. The required notification will provide EPA with the opportunity to evaluate 

the intended use and, if necessary, to prevent or limit potentially adverse effects from chemical use before 

it occurs.

In addition to any firms that may make a SNUN submission, the SNUR may also affect 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. The firm may also incur “hidden” costs; for example, it could forego 

profitable opportunities to use the chemical in an application that will be a significant new use. 

Costs in this report are estimated at the firm level and reflect the burden of a SNUR on the firms that 

make a submission. The potential hidden costs to the firms that do not make a submission are not 

quantified. Neither the total number of firms that will submit a SNUN nor the number of firms not 

making a submission but that are otherwise affected, is known; therefore, costs are not aggregated across 

the affected entities. However, EPA only receives a small number of SNUNs per year.

 

1 For small businesses, the estimated cost is approximately $6,500 to complete and submit a SNUN. See section 

3.2.3 for details. 
▌pg. 1-1

1. Introduction

This report presents the estimated costs of the Significant New Use Rule (SNUR) for trichloroethylene 

(TCE) (CAS 79-01-6). Under section 5(a)(2) of the Toxic Substances Control Act (TSCA), EPA is 

finalizing a SNUR at 40 CFR § 721.10851 by designating as a significant new use, manufacturing 

(including import) or processing of TCE for any use in a consumer product, except for use in cleaners and 

solvent degreasers, film cleaners, hoof polishes, lubricants, mirror edge sealants, and pepper spray.

The final SNUR will require manufacturers (including importers) or processors of TCE to notify EPA at 

least 90 days prior to the occurrence of any significant new use. The required notifications will provide 

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

before it occurs.

1.1 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 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. 

1.2 Summary of Methodology

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

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

In addition to estimated costs, this report qualitatively discusses the benefits of the final rule based on the 

value of the information it will provide. 

1.3 Organization of this Report

The remainder of this report presents EPA’s economic analysis in support of the final rule. A description 

of TCE market information is provided in Chapter 2. Chapter 3 contains estimates of the industry costs to 

comply with the final rule, and Chapter 4 shows estimates of the government costs associated with the 

administration of the final rule. Chapter 5 addresses the benefits of the final rule. Several additional 

impact analyses are presented in Chapter 6, including: small entity impact analysis, as mandated by the 

Regulatory Flexibility Act (RFA); a burden hour analysis that responds to the requirements of the 
▌pg. 1-2

Paperwork Reduction Act (PRA); an analysis of unfunded mandates that pertains to the Unfunded 

Mandates Reform Act (UMRA); an analysis of environmental justice implications that addresses the 

requirements of Executive Order 12898; and an analysis of children’s health pertinent to Executive Order 

13045. 

Note that all dollar values in this analysis are reported in 2013 dollars.
▌pg. 2-1

2. Chemical Uses and Manufacturers

EPA is finalizing a SNUR that designates manufacturing and processing for any use of TCE in a 

consumer product, except for use in cleaners and solvent degreasers, film cleaners, hoof polishes, 

lubricants, mirror edge sealants, and pepper spray, as a significant new use. EPA defines consumer 

product as a chemical substance that is directly, or part of a mixture sold or made available to consumers 

for their use in or around a permanent or temporary household or residence, in or around a school, or in 

recreation (40 CFR 721.3)).

TCE is a volatile organic compound (VOC) that is classified as a human carcinogen (EPA, 2014a). It is a 

colorless liquid with a pleasant, sweet odor resembling that of chloroform. EPA is concerned about the 

adverse effects of TCE and identified it for a risk assessment under of EPA's Existing Chemicals 

Management Program. EPA reviewed readily available information on TCE including uses, physical and 

chemical properties, fate, exposure potential, and associated hazards to humans and the environment. 

TCE was selected for risk assessment based on concerns for its human health hazard (e.g., human 

carcinogen), and its exposure profile and the risk assessment identified health risks to consumers using 

solvent degreasers and spray‐applied protective coating for arts and crafts (EPA, 2014a).

However, the Agency believes that if a new consumer use is intended, it may present a risk that EPA 

should evaluate under TSCA before the manufacturing or processing for that use begins. This final SNUR 

will require persons that manufacture (including import) or process TCE for a significant new use, 

consistent with the requirements at 40 CFR 721.25, to notify EPA at least 90 days before commencing 

such manufacture or process of the chemical substance for a significant new use.

2.1 Significant New Uses under the Final SNUR 

According to TSCA Section 5(a)(2), the determination that a chemical use qualifies as a significant new 

use must consider all relevant factors, including:

• The projected volume of manufacturing, importation, and processing of the chemical substance;

• The extent to which a use changes the type or form of exposure of human beings or the environment 

to a chemical substance;

• The extent to which a use increases the magnitude and duration of exposure of human beings or the 

environment to a chemical substance; and

• The reasonably anticipated manner and methods of manufacturing, processing, distribution in 

commerce, and disposal of a chemical substance.

EPA is designating the significant new use as manufacturing and processing for any use of TCE in a 

consumer product except for use in cleaners and solvent degreasers, film cleaners, hoof polishes, 

lubricants, mirror edge sealants, and pepper spray.

A company will be expected to submit a SNUN for TCE for any consumer uses not explicitly exempted 

from the final SNUR prior to initiating a new use.
▌pg. 2-2

2.2 Chemical Uses 

2.2.1 Historical Uses

TCE has historically had a wide range of uses drawn from various markets, including intermediate 

chemicals (for refrigerant and polyvinyl chloride [PVC] manufacture), industrial and commercial 

solvents, pharmaceuticals, insecticides, fumigant, textiles (processing and flame retardants), adhesives, 

and paints (as diluent) (Ash and Ash, 2009). The chemical was first commercially used in the 1920s as a 

metal degreasing solvent and a processing solvent in food production (Doherty, 2000). Beginning in the 

1930s, TCE was also used dry-cleaning solvent but it never gained popularity as a primary solvent in drycleaning applications. However, it is still used as a pre-cleaning or spotting agent in dry-cleaning 

applications (State Coalition for Remediation of Drycleaners, 2009). The peak of TCE use in the United 

States was in the 1970 when it was the most popular vapor degreasing solvent in the United States. 

However, throughout the 1970s and 1980s the chemical became widely regulated by several Federal 

Agencies, including the FDA, EPA, and OSHA and its use declined (Doherty, 2000 ).

2.2.2 Ongoing Uses

As of 2011 the majority of U.S. consumption of TCE is attributable to two specific uses; 1) use as an 

intermediate in manufacturing the refrigerant HFC-134a, a major alternative to CFC-12 which was 

banned under the Montreal Protocol in 1996, (83.6 percent of production volume) and, 2) use as a metals 

degreasing solvent (14.7 percent of production volume). TCE is widely used as a solvent, because it 

works well on fats, grease, waxes, and a large variety of natural and synthetic substances (Doherty, 2000). 

Few solvents perform as well as TCE in cleaning and degreasing applications, in addition it is 

noncorrosive, nonflammable and easy to recycle (Doherty, 2000). The remaining 1.7 percent of 

production volume is attributed to other uses.2 Table 2-1 contains the consumer and commercial use data 

from the 2012 Chemical Data Reporting (CDR) database. 

Table 2-1: 2012 CDR Consumer and Commercial Use Data for TCE

Site Product

Category

Consumer or 

Commercial Use

Used in Children’s 

Productions

Percent of 

Production Volume 

in Use

The Dow Chemical 

Company - Freeport, 

2310 N Brasoport Blvd, 

Freeport, TX, 77541

Adhesives 

and 

Sealants

Both No 1

 

2 In order to identify current uses of TCE, EPA reviewed published literature including IHS’ Chemical Economics 

Handbook (formerly of SRI Consulting); National Institute of Health’s (NIH) Household Product Database;

EPA CPCat; the Consumer Product Information Database; the most recent data available from EPA’s Chemical 

Data Reporting program (CDR) and Toxic Release Inventory; general Google.com searches; Material Safety 

Data Sheets (MSDSs), Safety Data Sheets (SDSs) and other information from manufacturing company 

websites.
▌pg. 2-3

Site Product

Category

Consumer or 

Commercial Use

Used in Children’s 

Productions

Percent of 

Production Volume 

in Use

CBI* NKRA** NKRA NKRA 100

TRInternational Inc, 600 

Stewart Street Suite 1801, 

Seattle, WA, 98101

NKRA NKRA NKRA 100

* Confidential Business Information

** Reported as Not Known or Reasonably Ascertainable

Sources: EPA, 2014b. US Environmental Protection Agency. Office of Pollution Prevention and Toxics. Downloadable of 

the Non-Confidential Chemical Reporting Data (CDR) Database, July 2014

Table 2-2 contains a summary of industrial TCE uses from the 2012 Chemical Data Reporting (CDR) 

database. 

Table 2-2: 2012 CDR Industrial Use Data for TCE

Industrial Sector

(Based on NAICS) Industrial Function Type of Processing

Agriculture, Forestry, Fishing

and Hunting

Agricultural chemicals

(non‐pesticidal) Processing as a reactant

All Other Basic Organic Chemical 

Manufacturing

Intermediates Processing as a reactant

Solvents

(for cleaning or degreasing) Processing‐repackaging

NKRA* Processing‐repackaging

All Other Chemical Product and

Preparation Manufacturing

NKRA* Use‐non‐incorporative activities

Solvents

(which become part of product

formulation or mixture)

Processing‐incorporation into

formulation, mixture, or reaction 

product

Industrial Gas Manufacturing

Functional fluids

(closed systems) Processing as a reactant

Primary Metal Manufacturing

Solvents

(for cleaning or degreasing)

Processing‐incorporation into

formulation, mixture, or reaction 

product

Wholesale and Retail Trade

Solvents

(for cleaning or degreasing) Processing as a reactant

* Reported as Not Know or Reasonably Ascertainable

Sources: EPA, 2014b. US Environmental Protection Agency. Office of Pollution Prevention and Toxics. Downloadable of 

the Non-Confidential Chemical Reporting Data (CDR) Database, July 2014
▌pg. 2-4

2.2.3 Consumer Product Information

To identify consumer products available in the U.S. market, EPA examined its Chemical/Product 

Categorical Data (CPcat) database, the National Institutes of Health’s (NIH) Household Products 

Database, the Consumer Product Information Database, and conducted web searches for TCE-containing 

products including searches on online catalogs, and identified specific products that were thought to 

contain TCE. EPA also examined a list of products identified as containing TCE in a 2010 presentation to 

the Air and Waste Management Vapor Intrusion Conference (Dettenmaier and Gorder, 2010). EPA then

examined product MSDSs/SDSs and company websites to determine if products were still available and 

if they still contained TCE (e.g., some may have been reformulated). From this work, EPA concluded that 

ongoing uses of TCE in consumer products were cleaners and solvent degreasers, film cleaners, hoof 

polishes, lubricants, mirror edge sealants, and pepper spray.

A detailed example of the approach for identifying products from one of the databases follows. A search 

of NIH’s Household Products Database identified three companies manufacturing 12 consumer products 

containing TCE. However, upon further research of the products (e.g., searching company websites or 

MSDS/SDSs), EPA confirmed the presence of TCE in only six out of the 12 products listed in the 

database. These six products were degreaser and arts and crafts aerosol spray products that may be used 

by consumers at home. The remaining six products have either been discontinued or reformulated using 

other chemicals (DHHS, 2012 and EPA, 2014a).

2.3 Potentially Affected Companies

The final SNUR will require manufacturers, importers, and processors to notify EPA at least 90 days 

before commencing the manufacture, import, or processing TCE for any significant new use. The final

SNUR may also affect firms that currently do not manufacture, import, or process any of the chemicals, 

but who may be interested in manufacturing, importing, or processing these chemicals in the future. EPA 

has not identified any firm manufacturing, importing, or processing TCE for any of the new uses 

identified in the final rule.

However, certain firms manufacturing, importing, or processing TCE for uses not identified as new uses 

in the final rule may take actions based on the requirements of the rule such as rule familiarization and 

supplier notification. Based on Toxics Release Inventory (TRI) data a total of 203 sites had TCE releases 

to the environment in the year 2013; 26 sites used TCE as a formulation component, 26 sites used TCE in 

repackaging, 23 sites used TCE as a manufacturing aid, 3 sites used TCE as an article component, and 

101 sites used TCE for ancillary uses, such as degreasing. Appendix B contains a list of the most recent 

TRI data available for TCE in 2013. Some of these companies may take actions resulting from 

requirements in the final rule, however, it is not possible to estimate what actions they may undertake.

Seven companies publicly reported manufacturing or importing TCE at one site in the 2012 CDR 

database; Dow Chemical, Greenchem, PPG Industries Inc., Shin Etsu, Solvchem Inc., TRInternational, 

Inc., and Vinmar Overseas LTD (EPA, 2014b). Two other sites reported data, however their identities

were claimed as confidential business information (CBI) and are not in the public CDR database. Table 

2-3 contains site location and production data for TCE as reported in the public CDR database. Some of 

these companies may take actions resulting from requirements in the final rule (see Table 3-9 for more 

information), however, it is not possible to estimate what actions, if any, these firms may undertake.
▌pg. 2-5

Table 2-3: Site Level Production Volumes as Reported in the Non-Confidential 2012 CDR Database 

Company Site Manufactured

Volume

Imported

Volume

Past 

Production 

Volume 

(2010)

PPG INDUSTRIES 

INC

PPG INDUSTRIES INC., LAKE 

CHARLES PLANT, PO BOX 

1000, LAKE CHARLES, LA, 

70602

CBI 0 lbs/yr CBI

DOW CHEMICAL 

CO

The Dow Chemical Company -

Freeport, 2310 N Brasoport

Blvd, Freeport, TX, 77541

CBI 0 lbs/yr CBI

VINMAR 

OVERSEAS LTD

VINMAR INTERNATIONAL, 

LTD., 16800 IMPERIAL 

VALLEY DRIVE, HOUSTON, 

TX, 77060-3159

0 lb/yr 91,359 lb/yr 0 lb/yr

SOLVCHEM INC

SOLVENTS & CHEMICALS, 

4704 SHANK RD., 

PEARLAND, TX, 77581

109,116 lb/yr 0 lb/yr 35,963 lb/yr

TRINTERNATIONAL 

INC

TRInternational Inc, 600 Stewart 

Street Suite 1801, Seattle, WA, 

98101

0 lb/yr 209,780 lb/yr 219,590 lb/yr

GREENCHEM 

INDUSTRIES LLC

Greenchem Industries LLC, 222 

Clematis St. Suite 207, West 

Palm Beach, FL, 33401

0 lb/yr CBI CBI

SHIN ETSU

SHINTECH PLAQUEMINE 

PLANT, 26270 HIGHWAY 405, 

RIVER ROAD SOUTH, 

PLAQUEMINE, LA, 70764

140,810 lb/yr 0 lb/yr 33,863 lb/yr

CBI CBI CBI CBI CBI

CBI CBI CBI CBI CBI

* Confidential Business Information

Sources: EPA, 2014b. US Environmental Protection Agency. Office of Pollution Prevention and Toxics. Downloadable of 

the Non-Confidential Chemical Reporting Data (CDR) Database, July 2014

 
▌pg. 3-1

3. Industry Compliance Costs

The final SNUR discussed in this report specifies that any manufacture (including import) or processing 

of TCE for a designated significant new use will require reporting under section 5(a)(1)(A) of TSCA. 

Therefore, a firm intending to manufacture (including import) and/or process TCE for a significant new 

use must submit a SNUN. Alternatively, a firm can decide not to manufacture, import, and/or process the 

chemical in such a way that it is not considered a significant new use. The firm, therefore, has two 

options: 

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

and/or process TCE for a significant new use, which, in this case, means manufacturing (including 

import) or processing of TCE for any use in a consumer product, except for use in cleaners and 

solvent degreasers, film cleaners, hoof polishes, lubricants, mirror edge sealants, and pepper spray. A 

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 for a significant new use. 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, and/or processing of any of the chemical substances 

for a significant new 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 chemicals, 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 3.2.8 for details).

• Option 2: Comply with SNUR limits (not manufacture, import, and/or process for a significant new 

use of the chemical). A firm can avoid engaging in a Significant New Use and submitting a SNUN 

by not manufacturing, importing, and/or processing TCE in a manner such that will be considered a 

significant new use. That is, if the firm does not manufacture (including import) or process TCE for 

any use in a consumer product, except for use in cleaners and solvent degreasers, film cleaners, hoof 

polishes, lubricants, mirror edge sealants, and pepper spray, as a significant new user, then it will

meet all applicable SNUR requirements (except for potential notification costs (discussed in Section 

3.6)). While this option avoids the costs of submitting a SNUN, it may entail the “hidden” cost of the 

foregone profit as a result of not engaging in the commercial activity originally planned, and may 

involve substituting TCE for another, more costly substance. If the firm elects to produce the 

chemical 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. In addition, if 

the firm exports any TCE, it will incur the export notification costs. The firm may also pursue this 

option temporarily by complying with SNUR restrictions while also pursuing Option 1. Due to the 

uncertainty related to this option, and EPA’s expectation that affected entities will select Option 1, the 

costs of Option 2 are not fully quantified in this report.

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

Section 3.1 summarizes the wage rates used in this chapter. Section 3.2 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 3.3. 
▌pg. 3-2

3.1 Wage Rates

The final 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 burden hours by the wage rate for the 

corresponding labor category. This section presents the estimated wage rate in each labor category. 

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 for December 2013 are provided by the Employer Costs for Employee Compensation 

(ECEC) Supplemental Tables available on the BLS website (BLS, 2014b). The loaded wage rate is 

$77.77 for managerial labor; $67.59 for technical labor; and $30.36 for clerical labor. Table 3-1 presents 

the data used to calculate the loaded wage rates for the three labor categories. Appendix A: provides more 

information on the wage rates and inflation factors used in this analysis.

Table 3-1: Loaded Industry Wage Rates, December 2013

Labor 

Category Data Source Date

Wage Fringe 

Benefit

Fringe 

as % 

Wage

Overhead 

% 

Wage

Fringe +

Overhead

Loaded 

Wages1

(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

Dec 

'13

$46.21 $23.70 51.29% 17% 1.68 $77.77

Professional/

Technical

BLS ECEC, Private 

Manufacturing 

industries, 

“Professional and 

related“3

Dec 

'13 $39.70 $21.14 53.25% 17% 1.70 $67.59

Clerical

BLS ECEC, Private 

Manufacturing 

industries, “Office 

and Administrative 

Support”3

Dec 

'13 $18.05 $9.24 51.19% 17% 1.68 $30.36

Notes:

1 Wage rates are rounded to the closest pennies; however, unrounded values were used in calculations. 2 An overhead rate of 17 percent 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 2006-June 2014, US Bureau of Labor 

Statistics, September 10, 2014 (BLS, 2014b).
▌pg. 3-3

3.2 Unit Industry Compliance Costs

3.2.1 Rule Familiarization

The final rule will require manufacturers, processors, and importers of the chemicals subject to the final

rule to become familiar with the SNUR and its various requirements. Rule familiarization is estimated to 

require 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), which 

measures the costs of mandatory electronic reporting of SNUNs and other TSCA Section 5 notices. As 

shown in Table 3-2, the total labor cost associated with rule familiarization is estimated at $57.92.

Table 3-2: Rule Familiarization Burden and Cost for SNUR Submitters

Reporting 

Activity

Clerical Labor 

($30.36/hour)

Technical Labor 

($67.59/hour)

Managerial Labor 

($77.77/hour)

Total Labor Cost 

(2013$)

Burden Cost Burden Cost Burden Cost Burden Cost

Rule 

Familiarization 0.00 $0.00 0.55 $37.17 0.27 $20.74 0.82 $57.92

Note:

Costs may not equal labor wage rate multiplied by burden hours as shown, due to rounding. Unrounded values were used 

in calculations. 

Sources: Wage rates: Table 3-1; Burden estimates: EPA, 2009a.

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

The final SNUR will require submission of a SNUN for any firm that chooses to manufacture, import, 

and/or process a chemical for a significant new use. First-time submitters of any TSCA section 5 notice 

(including Premanufacture Notices (PMNs), SNUNs, Test Market Exemption (TME) applications, Low 

Volume Exemption (LVE) notices, Low Exposure/Low Release (LoREX) exemption notices, 

Biotechnology Notices for genetically modified microorganisms, Notices of Commencement of 

Manufacture or Import (NOCs), and support documents to Section 5 notices) are required 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.3 These activities are only required of first-time 

submitters of any Section 5 notice. These activities are estimated to require the following burden hours, 

based on the estimates presented in the Economic Analysis of the Premanufacture Notification Electronic 

Reporting Final Rule (EPA, 2009a):

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

 

3 Although the final rule does not 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.
▌pg. 3-4

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 a change of 

submitter status, should one occur. Filing the electronic signature agreement may be done either 

through mail or electronically. EPA believes the cost of electronic filing to be negligible, and the cost 

of a paper filing via the US Postal Service to be to be $2.62 per company (including five $0.46

stamps4 and five $0.06 business envelopes5

).

• 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 3-3, the cost associated with CDX registration, CDX electronic signature, and Pay.gov 

account setup is $203, and this cost is only incurred by a first-time submitter.

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

Cost for First-Time Submitters

Reporting Activity

Clerical Labor 

($30.36/hour)

Technical Labor 

($67.59/hour)

Managerial Labor 

($77.77/hour)

Total Labor Cost

(2013$)

Burden Cost Burden Cost Burden Cost Burden Cost

CDX Registration 0.00 $0.00 0.73 $49.56 0.18 $14.26 0.92 $64

CDX Electronic 

Signature 0.00 $0.00 1.00 $67.59 0.75 $58.33 1.75 $126 

Mailing Cost $2.77

E-Payment (Pay.gov ID) 0.00 $0.00 0.00 $0.00 0.13 $10.37 0.13 $10 

Total 0.00 $0.00 1.73 $117 1.07 $83 2.80 $203

Note:

Costs may not equal labor wage rate multiplied by burden hours as shown, due to rounding. Unrounded values were used in 

calculations. 

Sources: Wage rates: see Table 3-1; Burden estimates: EPA, 2009a.

3.2.3 Form Completion and Submission Fee

Respondents who choose to submit a SNUN 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 

 

4 Price for a stamp was taken from the Stamps.com website. (See Stamps.com, 2013)

5 Price for an envelope was determined based on the per unit price of a regular business envelope. See “Staples® 

#10, Self-Sealing Envelopes, 500/Box." Available at: http://www.staples.com/ (Accessed 10/1/2014).
▌pg. 3-5

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 final 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 SNUN form are based on the costs of completing a PMN submission, 

since the data requirements are the same and the same form is used for both. The PMN submission costs 

came from EPA's 1994 Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 

Premanufacture Notifications, which 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, Table III-2 and pages III-11, -12, and -13). 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. p. III 11-13). 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 and reduce the recordkeeping burden associated with preparing a 

SNUN (EPA, 2009a).6 In addition, electronic submission is expected to generate and 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 approximately 74 hours of 

technical labor and 18 hours of managerial labor (EPA, 2009a). Table 3-4 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 estimated to be approximately $6,400.

 

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

reported a 0.5 hour clerical and a 0.5 hour technical burden associated with recordkeeping in addition to the 

burden estimates from the 1994 RIA (EPA, 1994, p. III-14). These burden estimates (the 0.5 for clerical burden 

and 0.5 for technical burden) are based on the recordkeeping burden for polymer exceptions and not the 

recordkeeping burden associated with PMN submissions.

Therefore, for this analysis, the 0.5 hour for clerical labor and the 0.5 hour for technical labor were removed. It 

is important to note that for this analysis, clerical burden changes are not applicable because the entire clerical

burden is assumed to be eliminated under the electronic reporting requirements. In summary, we do not include 

the one hour recordkeeping burden (0.5 hour for clerical, 0.5 for technical) reported in the ePMN EA.
▌pg. 3-6

Table 3-4: Industry Cost Estimate to Complete the SNUN Form

Reporting 

Activity

Clerical Labor 

($30.36/hour)

Technical Labor 

($67.59/hour)

Managerial Labor 

($77.77/hour)

Total Labor 

Cost

(2013$)1

Burden Cost Burden Cost Burden Cost Burden Cost

Form 

Completion 0.00 $0.00 74.20 $5,015 18.00 $1,400 92.20 $6,400

Note:

1. Costs may not equal labor wage rate multiplied by burden hours as shown, due to rounding. 

2. Loaded wages include fringe benefits and overhead. See Table 3-1 of this report for derivation. Wage rates presented in this 

table are rounded; however, unrounded values were used in calculations. For this reason, total labor costs may not equal the 

product of rounded values.

3. The estimate of zero clerical burden is taken from the Economic Analysis of the Premanufacture Notice Electronic Reporting 

Final Rule (EPA, 2009a, page 7).

4. 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).

Sources: Burden estimated: EPA, 1994 and EPA, 2009a; Wage rates: see Table 3-1.

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 3-5 adds the labor cost and 

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

estimated to be approximately $8,900 for large business submitters and $6,500 for small business 

submitters.

Table 3-5: Industry Cost Estimate to Complete and Submit the SNUN Form

Reporting Population Labor Cost Submission Fee Total Cost

(2013$)

Large Business Submitters $6,400 $2,500 $8,900 

Small Business Submitters $6,400 $100 $6,500 

Source: Labor cost: see Table 3-4; Submission fees: EPA, 1994

3.2.4 Recordkeeping for Companies Choosing to Submit a SNUN

Companies submitting a SNUN must, under 40 CFR §721.40, keep records of the information contained 

in the SNUN. Some EPA reports have assumed that SNUN recordkeeping hours will be five percent of 

SNUN submission hours, or about five to six hours. For this report, the SNUN recordkeeping hours were 

included in the SNUN submission hours (see Section 3.2.3) and the SNUN recordkeeping costs under 40 

CFR §721.40 were not separately estimated.

3.2.5 Recordkeeping for Companies that Do Not Submit a SNUN

If a firm that manufactures, imports, or processes a substance subject to the final SNUR chooses not to 

submit a SNUN, EPA assumes they will keep records that document compliance with SNUR conditions 

for avoiding a Significant New Use. Such recordkeeping is estimated to involve copying and filing 

relevant records, including those related to category of use. Because records for SNUNs must be 

maintained for five years from the date of their creation (40 CFR 721.40), EPA also assumes these 
▌pg. 3-7

records would be maintained for a similar amount of time. For firms that choose to not submit a SNUN, 

costs for compliance with the recordkeeping requirements are estimated to be five percent of the reporting 

burden for reporting information for a specific section of the SNUN form and are performed by clerical 

staff (EPA, 2012b, page 14). EPA used the per-activity burden for reporting, human exposure, category of 

use and releases to the environment presented in the Information Collection Request (ICR) for TSCA 

Section 5(a)(2) Significant New Use Rules for Existing Chemicals (Renewal) (EPA, 2012b, page 12). Any 

clerical burden associated with these activities was removed to reflect the burden reduction associated 

with electronic submissions (EPA, 2009a). 

The recordkeeping burden for a company that does not submit a SNUN is estimated at 0.15 hours and 

$10.14 and is derived in Table 3-6.

Table 3-6: Annual Per-Chemical Costs of Recordkeeping Requirement for Companies that Choose 

not to Submit a SNUN

Reporting Activity

Per Activity 

Burden 

(Hours)

% of Reporting 

Burden 

Attributed to 

Recordkeeping

Total Labor Cost

(2013$)

Burden Cost

Category of Use1 3 5% 0.15 $10.14 

Notes: For the category of use reporting activity, the burden is associated with technical labor. See Table 3-1 for the technical 

wage rate.

Source: 1 US EPA, 2012b Office of Pollution Prevention and Toxics Information Collection Request (ICR) for TSCA Section 5(a)(2) 

Significant New Use Rules for Existing Chemicals (Renewal).

3.2.6 Customer Notification

Manufacturers, processors, and importers of chemicals subject to SNURs must notify recipients of such 

chemicals of the SNUR or verify that knowledge of the SNUR has been otherwise acquired by recipients, 

or that the recipients are unable to engage in significant new uses. Since it is not expected that all such 

entities will have complete knowledge of all uses of any products subject to a SNUR, and because filing a 

SNUN could require significantly more burden, it is assumed that manufacturers, processors, and 

importers will most often choose to notify their customers of SNUR regulatory activities. As this 

notification may be accomplished by simply annotating an SDS, EPA estimates the associated burden to 

be about one hour of a technical employee's time or $67.59 per manufacturer, processor, or importer per 

chemical. 

3.2.7 Import Certification

In general, persons importing chemical substances must certify that they are in compliance with 

applicable rules and orders under TSCA or not subject to TSCA in accordance with TSCA Section 13 
▌pg. 3-8

regulations at 19 CFR §12.118 to 12.127. 7 The statement must be on or attached to a commercial invoice 

or entry document belonging to the imported shipment.

Import certification is fulfilled by checking a box on an invoice or entry document and EPA assumes that 

it generally imposes no additional burden or cost on the importer. Any potential burden associated with 

submitter’s familiarization with this requirement is assumed to be included in the more general SNUR 

familiarization burden discussed above.

3.2.8 Export Notification

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

subject to various TSCA sections (see the TSCA Section 12(b) regulations at 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 one-time notification requirement8 per destination country for each 

exporter of a chemical substance. After receiving a notification from a firm, EPA notifies the importing 

country (40 CFR §707.70). To calculate the burden associated with making a single export notification, 

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. 

EPA estimated the average burden associated with making a single notification, but did not estimate 

either the total number of exporters of a SNUR chemical or the number of notifications per SNUR 

chemical. This is because the SNURs apply to a variety of different chemicals with a variety of unrelated 

uses, manufacturers, and processors, making it impractical within the resources available for this report to 

assess the potential number of exporters and importing countries per chemical. 

Most underlying data in this section come from the (2012 TSCA Section 12(b) ICR), ICR No.: 0795.14

OMB Control Number 2070-0030 [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, 2012c).

3.2.9 Estimated Number of Annual Export Notifications per Exporter

EPA’s 2012 TSCA Section 12(b) ICR estimated that the average exporter making notifications would

make 13 notifications per year.

9 This includes notifications resulting from SNURs and notifications 

 

7 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)

8 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).

9 EPA calculated the average number of export notifications per exporter in the 2012 TSCA Section 12(b) ICR

(EPA, 2012b) by dividing the estimated number of submitted notifications (3,090) by the estimated number of 

exporters (240).
▌pg. 3-9

resulting from other TSCA activities. Therefore, it is likely that an exporter will make less than 13

notifications per year as a result of this final SNUR. A notification is typically no more than one page per 

chemical/country combination, and one notification mailing often includes multiple chemicals and/or 

destination countries.10

The percent of notifications resulting from SNURs in general is unknown, and it is also unknown how 

many notifications may result from this rulemaking, as not all manufacturers may choose to export a 

chemical, or they may make several notifications for a single chemical. 

3.2.10 Exporter Costs

The 2012 TSCA Section 12(b) ICR (EPA, 2012c, page 11, Table 3), estimated the annual export 

notification cost for an exporter under the one-time export notification requirement. 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 average burden per firm. Exporters who make a 

larger number of notifications per year may benefit from economies of scale and have lower costs per 

notification; conversely firms making fewer notifications may have a higher cost 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 (U.S. PS) as 

first-class registered mail with a return receipt (Stamps.com, 2013). The estimated per-shipment and 

annual mailing costs incurred by individual submitters are detailed in Table 3-7.

Table 3-7: Derivation of Total Mailing Cost for 13 Notices

Postal Service Cost

Registered mail, regular, with $0 declared value $11.20

Return receipt, requested at time of mailing (receive by mail) $2.55

Postage, regular First Class, up to 1 ounce $0.46

Cost per export notice - Subtotal $14.21

× 13

Total Mailing Cost for 13 Notices $184.73

Source: Mailing rates are from the Stamps.com web site (http://www.stamps.com/whitepapers/2013-usps-postage-rateincrease-guide.pdf). The assumption on the mailing method is based on the Economic Analysis of the Proposed Change to 

TSCA Section 12(b) Export Notification Requirements, November 2005 (EPA, 2005a), as clarified in a later SNUR economic 

analysis (EPA, 2007c, Table 8). 

 

10 Based on review by an EPA economist of notifications received under TSCA Sections 4, 5 and 6 over 

approximately three weeks in early 2010.
▌pg. 3-10

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, 2012c). 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, 2012c).

The number of submitters per year who report under TSCA §12(b) has varied over time, rising from 

around 160 in 1991 to over 460 in 2000, and declining since. In the most recent TSCA §12(b) ICR, EPA 

estimated that there would be approximately 240 submitters per year in near-future years (EPA, 2012c). 

Of these 240 submitters, EPA estimated that 160 companies were near the lower burden estimate of two

hours per year, and 80 companies were near the upper estimate of 24 hours per year. Compiling the list 

for all respondents was therefore estimated to take 2,240 hours (2 hours x 160 firms plus 24 hours x 80

firms), or an average of about 9.3 hours of technical time per firm per year for 13 notifications per year 

(EPA, 2012c).

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 

include some proportion of legal time) per firm per year for 13 notifications per year (EPA, 2012c).

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 

or 6.5 hours for 13 notifications (EPA, 2012c).

Total Burden and Cost per Notification. The burdens and associated costs for each notification activity 

are provided in Table 3-8. EPA estimates that the burden associated with making one notification is 

approximately 1.3 hours and $83. 
▌pg. 3-11

Table 3-8: TSCA 12(b) Export Notification Cost per Notification

Notification Activity

Technical Labor Clerical Labor Total

Wage 

Rate 

($/hr)

Burden Cost

Wage 

Rate 

($/hr)

Burden Cost Burden Cost

Compile list $67.59 9.3 $629 -- -- -- 9.3 $629 

Write letter $67.59 1.0 $68 -- -- -- 1.0 $68 

Check order and send 

notice -- -- -- $30.36 6.5 $197 6.5 $197 

Mailing cost1 -- -- -- -- -- -- -- $185

Total per average 

facility2 -- 10.3 $696 -- 6.5 $197 16.8 $1,078 

Total per Notification -- 0.8 $53.55 -- 0.5 $15.18 1.3 $82.94

Notes:

Costs may not equal labor wage rate multiplied by burden hours as shown due to rounding. Unrounded values were used in 

calculations. 1 Mailing costs reflect 2013 U.S. PS rates and can be found in Table 3-7. 2 An average facility submitting notifications is assumed to submit 13 export notifications per year.

Source: Appendix A of this report derives technical and clerical hourly labor costs. Burden hour estimates are from ICR No.: 

0795.14 ICR for Notification of Chemical Exports - TSCA Section 12(b) Supporting Statement for Request for OMB Review 

under the Paperwork Reduction Act (EPA, 2012c, p.10). 

3.3 Summary of per Submission Costs, by Option

The number of firms affected that do not make submissions to EPA (see Option 2 in Table 3-9) is not 

known; therefore, costs are not aggregated across the affected entities. The following table summarizes 

the per-company per-chemical costs to comply with the final rule, as described in more detail in section 

3.2 above.
▌pg. 3-12

Table 3-9: Compliance Options and Associated Costs Incurred by a Firm Due to the Final SNUR

Option1 Costs Quantified Costs per Chemical (2013$)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 submitting a 

SNUN, including rule 

familiarization, CDX 

registration (for companies 

that are first-time 

submitters), form 

completion, user fee, export 

notification, and any test 

costs. 

$58 rule familiarization cost; $8,900 submission 

cost (including SNUN recordkeeping under 40 

CFR §721.40 and fee $2,500 for large 

businesses). EPA usually receives well under ten 

SNUNs per year3

. Import certification costs are

approximately $17 per transaction. Export 

notifications costs are estimated at $83 per 

notification; total cost per company will vary. 

First time submitters will incur $203 for CDX 

registration and associated activities. Companies 

manufacturing, importing, or processing a 

chemical currently used in commerce in the 

United States will incur a cost $68 for notifying 

consumers of SNUR regulatory activities. 

2.

Manufacture, import, or 

process in a way that 

avoids a Significant New 

Use.

Cost of the profit foregone 

as a result of not engaging 

in the commercial activity 

originally planned 

(opportunity costs), 

recordkeeping, and export 

notification costs. 

Opportunity costs are not quantified. Other costs 

include rule familiarization ($58), recordkeeping 

($10), import certification ($17 per transaction), 

export notification ($83 per notification), and 

customer notification ($68) may 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 will not otherwise follow the specified practices. Costs are 

detailed in Section 3.2. 3 See Section 3.4 for more details.

3.4 Likelihood of SNUN Submission

This analysis assumes that no entities are expected to submit a SNUN. EPA has, over the years, 

promulgated SNURs that cover a total of more than 1,000 chemicals. In response, the Agency receives 

only a handful of SNUNs per year. For example, the number of SNUNs received was six in Federal fiscal 

year (FY) 2007, eight in FY2008, seven in FY2009, two in FY2010, and ten in FY2011.

11 In addition, as 

discussed in Chapter 2, the no ongoing commercial uses of TCE are subject to this final rule, therefore 

this suggests that it is unlikely a firm will submit a SNUN.

3.5 Potential for Subsequent Regulatory Actions 

The Agency recognizes that if submission of a SNUN does result from a 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 

 

11 Values based on US EPA’s PMN Gold (V1.1) record keeping system as of September 1, 2011 (EPA, 2011a).
▌pg. 3-13

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 about the chemical and its risks at the time the 

SNUN is being reviewed). 

Should the Agency’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. 
▌pg. 4-1

4. 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. 

4.1 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 2013 (OPM, 2013). EPA assumes 

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

administrative activities under the final rule.12 The average salary for a GS-13 Step 5 employee was 

$100,904 in 2013 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 (EPA, 2009c), which results in a fully loaded annual salary of $161,446 (see Table 4-1). 

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

estimated hourly FTE wage rate of $77.62.

Fully loaded costs for Agency labor are shown in Table 4-1.

Table 4-1: Derivation of Loaded Agency Wage Rates, 2013

Labor 

Category Data Source 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 Washington-BaltimoreNorthern Virginia, DC-MDPA-VA-WV, area, GS-13 

Step 5 pay rates, with 60% 

overhead1

Jan 

2013

$100,904

(annual)

--

Included 

in 60% 

overhead

60%2 1.60

$161,446

(annual)

$48.51

(hourly)

$77.62

(hourly)

Notes:

1 The Agency salary is the unloaded federal GS-13 Step 5 salary ($100,904 for 2013), from the OPM salary table for the 

Washington-Baltimore-Northern Virginia Locality Pay Area (OPM, 2013). Hourly rates are based on annual salary divided by 

2,080 hours.

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

(EPA, 2009c).

 

12 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007) (EPA, 2007a), 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.
▌pg. 4-2

4.2 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 Table VII-1 of a 1994 EPA 

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

Notifications (EPA, 1994). 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 to reduce Agency burden by 16.5 percent (EPA, 2009b, p.28).

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, and is inflated from 1993 prices using the Bureau of Labor 

Statistics (BLS) Employment Cost Index (ECI) data (BLS, 2014c). The ECI for total compensation (not 

seasonally adjusted) 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 4-2 contains the 

derivation of inflation factors for Agency extramural costs.

Table 4-2: Derivation of Inflation Factors for Agency Extramural Costs

Item Inflation Index Source1 Starting 

year

Index 

for 

starting 

year

(a)

Index for 

December 

2013

(b)

Inflation 

factor 

(b)/(a) 2

Agency Extramural 

costs Professional 

and Related Private 

Industry

BLS ECI, Total comp, Private 

industry, Professional and 

related, 4th Q [BLS, 2014c]

3

1993 67.0 120.5 1.80

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.

2 Inflation factors are rounded; unrounded values were used in calculations. 3 Beginning with the report Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: EPA 

Docket OPPT-2009-0922 (EPA 2011b), 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 “white-collar” series.

Source: (BLS 2014c) Bureau of Labor Statistics. Employment Cost Index – Total Compensation: Professional and Related 

Private Industry, Not Seasonally Adjusted. (Series ID: CIU2010000120000I (B)), extracted October 2, 2014. 

http:/data.bls.gov/cgi-bin/srgate. (BLS 2014c).

The Percent of Cases column in Table 4-3 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 
▌pg. 4-3

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 are 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.

Values in 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. This calculation yields total Agency costs of approximately $5,100 per SNUN, for 

submission review and processing, as shown in Table 4-3.
Agency Costs ▌pg. 4-4

Table 4-3: Agency Costs for SNUN and Other Submission Review and Processing

Review Steps

EPA Staff (FTE) Cost Extramural Cost2

Unweighted 

Cost

% of 

Cases

Weighted 

Cost3

Burden 

Reduction4

Weighted 

Cost with 

Burden 

Reduction

FTE 

Fraction

Cost per 

FTE1

FTE Total 

(2013$) 1993$ 2013$

(a) (b) (c)=(a)*(b) (d) (e) (f)=(c)+(e) (g) (h)=(f)*(g) (i) (j)=(h)*(1-(i))

Pre-notice consultation 0.0024 $161,446 $387 $4.00 $7.19 $395 41% $162 0.165 $135

Administrative prescreen/ 

notice receipt/user fee 0.0024 $161,446 $387 $92.00 $165 $553 100% $553 0.165 $462

CRSS (Chemical Review and 

Search Strategy) 0.0025 $161,446 $404 $268 $482 $886 100% $886 0.165 $739

SAT (Structure Activity Team) 0.0006 $161,446 $96.87 $14.00 $25.18 $122 100% $122 0.165 $102

Engineering/Exposure 0.0015 $161,446 $242 $56.00 $101 $343 100% $343 0.165 $286

Exposure/Fate 0.0008 $161,446 $129 $0.00 $0.00 $129 100% $129 0.165 $108

Focus 0.0009 $161,446 $145 $23.00 $41.37 $187 100% $187 0.165 $156

Standard Review Functions 0.0219 $161,446 $3,536 $511 $919 $4,455 29% $1,292 0.165 $1,079

Division Directors Meeting 0.0129 $161,446 $2,083 $113 $203 $2,286 15% $343 0.165 $286

Order 

Development/Negotiation 

Review

0.0171 $161,446 $2,761 $22.00 $39.57 $2,800 3% $84.01 0.165 $70.15

Post Order Data Review 0.0886 $161,446 $14,304 $0.00 $0.00 $14,304 3% $429 0.165 $358

Order Modification 0.2167 $161,446 $34,985 $0.00 $0.00 $34,985 3% $1,050 0.165 $876

New Chemical SNUR 

Development 0.0277 $161,446 $4,472 $85.00 $153 $4,625 7% $324 0.165 $270

Notices of Commencement 0.0012 $161,446 $194 $40.00 $71.94 $266 31% $82.36 0.165 $68.77

FOIA (Freedom of Information 

Act) Requests 0.0333 $161,446 $5,376 $287.00 $516 $5,892 1% $58.92 0.165 $49.20

CBI (Confidential Business 

Information) Substantiation 0.0004 $161,446 $64.58 $3.00 $5.40 $69.97 100% $69.97 0.165 $58.43

TOTAL $6,100 $5,100

Notes:

1 GS-13 Step 5 salaries loaded with benefits and overhead. See Table 4-1 for derivation. 2 Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated from 1993 prices using Table 4-2. 3 Weighted costs were calculated using unrounded unit cost estimates. 

4 Electronic submission is expected to generate a cost savings of 16.5% to the Agency (EPA 2009a, p. 28).

Sources: FTEs per review step, 1993 extramural costs, and percent of cases are from EPA, 1994 Table VII-1; GS-13 salaries are from OPM, 2013.
▌pg. 4-5

4.3 Export Notification Cost

Under TSCA Section 12(b), exporters must notify EPA if they intend to export chemicals subject to 

SNURs, as described in Section 3.2.8. 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, 2012c). 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 U.S. embassies (EPA, 

2012c). (See Table 3-7 for the cost of mailing one notification). 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, 2012c). Since the current rulemaking covers only a very small percent of the chemicals subject to 

TSCA 12(b) reporting, a very small percent of such activity would be attributable to the current 

rulemaking. 

Because it is unknown how many, if any, notifications EPA will receive or send as a result of the current 

rulemaking, the costs to the Agency are presented per activity. The estimated burden for the first two 

Agency activities is provided in Table 4-4. To estimate the Agency cost, hourly burdens are multiplied by 

the loaded wage rate of a GS-13, Step 5, which is derived in Table 4-1. 

Table 4-4: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2013$)

Agency Activity

Hours per 

Activity

FTE per 

Activity1

Loaded Wages Mailing 

Cost

Total Agency

GS-13, Step 5 FTE Cost per Activity

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

((b)*(c))+(d)

Process an incoming 

notification from an 

exporting company

0.1 0.00005 $161,446 $0.00 $7.76 

Prepare and mail a 

notification to an 

importing country

0.5 0.00024 $161,446 $14.21 $53.02

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: Appendix A of this report derives Agency labor costs. Mailing costs are from Table 3-7 of this report. Other 

burden estimates are from ICR No.: 0795.14 [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 2012c), 

adjusted for inflation.
▌pg. 5-1

5. Benefits

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. It allows the Agency to take immediate action to mitigate an 

activity that the Agency deems harmful to the environment or human health. The final SNUR allows EPA 

to evaluate the use of, or exposure to these chemical and allow the Agency to take preventive action to 

limit or prohibit any Significant New Use. 

EPA is concerned about the adverse effects of TCE and identified it for a risk assessment as part of EPA's 

Existing Chemicals Management Program. TCE exposure has been associated with several types of 

cancer in humans including kidney, liver, and lymphatic system cancer (EPA, 2014a). Acute and chronic 

inhalation exposure can affect the liver, kidney, nervous system, immune system, and reproductive 

system and can cause developmental effects. (EPA, 2014a). EPA’s risk assessment identified cancer risk 

concerns and short‐term and long‐term non‐cancer risks for workers and occupational bystanders at small 

commercial degreasing facilities and dry-cleaning facilities that use TCE‐based spotting agents. EPA also 

identified short‐term non‐cancer risks for consumers and residential bystanders from the use of TCE‐

containing solvent degreasers and spray‐applied protective coatings. The main route of exposure for TCE 

is believed to be inhalation for the uses identified, but highly volatile compounds such, as TCE, may also 

be absorbed through the skin. However, based on the physical‐chemical properties of TCE and its 

exposure scenarios EPA believes that inhalation is the main exposure pathway (EPA, 2014a).

While the final SNUR would not address the risk to consumers from TCE exposure from cleaners and 

solvent degreasers, film cleaners, hoof polishes, lubricants, mirror edge sealants, and pepper spray, the 

Agency believes that if a new consumer use begins or resumes, it may present a risk to consumers and 

residential bystanders. The final SNUR allows EPA to evaluate the use of, or exposure to the chemical 

and allow the Agency to take preventive action to limit or prohibit any Significant New Use. EPA also 

expects that the final rule may restrict future uses or exposure to the chemical, as a company may choose 

to modify planned uses in such a way that does not trigger a SNUR, as opposed to submitting a SNUN.

Therefore, the final SNUR may limit future exposure to the chemical. 
▌pg. 6-1

6. Additional Analyses

6.1 Regulatory Flexibility Act 

Pursuant to section 605(b) of the Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et seq.), the Agency 

hereby certifies that promulgation of this SNUR would not have a significant adverse economic impact on 

a substantial number of small entities. The rationale supporting this conclusion is as follows. The 

requirement to submit a SNUN applies to any person (including small or large entities) who intends to 

engage in any activity described in the rule as a significant new use. Where a use is new, by definition no 

small or large entities presently engage in such activities. Although some small entities may decide to 

manufacture or process a substance for the new use after the SNUR is promulgated, EPA receives very 

few SNUNs, and few of those are submitted by small entities. In response to the promulgation of SNURs 

covering over 1,000 chemical substances, the Agency receives only a handful of SNUNs per year. For 

example, the number of SNUNs was four in Federal fiscal year 2005, eight in FY2006, six in FY2007, 

eight in FY2008, seven in FY2009, two in 2010, and ten in 2011 (EPA, 2012a), for an average of 6 per 

year from all SNURs. EPA has no reason to believe that this SNUR will alter the pattern of SNUN 

submissions that EPA has historically seen. In addition, the estimated reporting cost for submission of a 

SNUN is minimal regardless of the size of the firm, averaging about $8,900 including SNUN 

recordkeeping and reporting costs. The Agency currently offers some relief to certain small businesses 

with sales (including those of subsidiary/parent companies) of less than $40 million per year by reducing 

the SNUN submission fee from $2,500 to $100. This lower fee reduces the cost of submitting a SNUN to 

about $6,500 for smaller firms. During the six year period from 2005-2010, only three submitters selfidentified as small in their SNUN submission13 (EPA, 2012a). EPA believes the cost of submitting a 

SNUN is relatively small compared the cost of developing and marketing a chemical new to a firm and 

that the requirement to submit a SNUN generally does not have a significant economic impact. 

EPA believes that the potential economic impact of complying with a SNUR is not expected to be 

significant or adversely affect a substantial number of small entities.

6.2 Unfunded Mandates Reform Act (UMRA)

The final rule does not impose any enforceable duty, contain any unfunded mandate, or otherwise have 

any effect on small governments because none of the current producers of the subject chemicals are 

governments. Additionally, it is not expected that any governments would initiate production of these 

chemicals.

6.3 Paperwork Reduction Act (PRA)

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 

 

13 The three “small” submitters were identified by review of actual SNUN submissions from the years 2005-2010.
▌pg. 6-2

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

and 2070-0030 (EPA ICR No. 0795).

If an entity were to submit a SNUN to the Agency, the annual burden is estimated to average 98.2 hours 

per response: 0.82 hours for rule familiarization (Section 3.2.1), 2.80 hours for CDX registration, CDX 

electronic signature, and pay.gov account setup (Section 3.2.2), 92.2 hours for form completion, 

submission and recordkeeping under CFR §721.40 (Sections 3.2.3), 1 hour for consumer notifications 

(Section 3.2.6) and 1.36 hours for export notification (Section 3.2.8). The burdens for rule familiarization, 

CDX registration, CDX electronic signature, pay.gov account setup form completion, submission, and 

recordkeeping consumer notifications are approved under EPA ICR No. 1188 (OMB control number 

2070-0038). The burden for export notification is estimated to be 1.3 hours per notification. Burden for 

export notification is approved under EPA ICR No. 0795 (OMB control number 2070-0030). 

6.4 Executive Order 13132, Federalism

Executive Order 13132, entitled Federalism (64 FR 43255, August 10, 1999), requires EPA to develop an 

accountable process to ensure “meaningful and timely input by State and local officials in the 

development of regulatory policies that have federalism implications.” Policies that have federalism 

implications are defined in the Executive Order to include regulations that have “substantial direct effects 

on the 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” (64 FR 43255, August 10, 1999). 

The final rule establishes reporting and recordkeeping requirements that apply to manufacturers 

(including importers) and processors of certain chemicals. EPA has no information to indicate that any 

state or local government manufactures or processes the chemical substances covered by this action.

6.5 Executive Order 12898, Environmental Justice

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

Low Income Populations” (59 FR 7629, February 16, 1994), establishes federal executive policy on 

environmental justice. Its main provision directs federal agencies, to the greatest extent practicable and 

permitted by law, to make environmental justice part of their mission by identifying and addressing, as 

appropriate, disproportionately high and adverse human health or environmental effects of their programs, 

policies, and activities on minority populations and low-income populations in the United States.

The information collected under this final rule will assist EPA and others in determining the potential 

hazards and risks associated with various chemicals manufactured and used at high production volumes. 

Although not directly impacting environmental justice-related concerns, this information will enable the 

Agency to better protect human health and the environment, including in low-income and minority 

communities.

6.6 Executive Order 13045, Protection of Children

EPA interprets Executive Order 13045 (62 FR 19885, April 23, 1997), as applying only to those 

regulatory actions that concern environmental health or safety risks that EPA has reason to 

believe may disproportionately affect children, per the definition of “covered regulatory action” 

in section 2-202 of the Executive Order. This action is not subject to Executive Order 13045 
▌pg. 6-3

because it does not concern an environmental health risk or safety risk, nor is this action 

economically significant as the impact of this SNUR will be less than $100 million.

6.7 Executive Order 13175, Tribal Governments

Executive Order 13175 is Consultation and Coordination with Indian Tribal Governments (59 FR 22951, 

November 6, 2000). This rule does not have Tribal implications because EPA has no information to 

indicate that any tribal government manufactures or processes the chemical substances covered by this 

action.

6.8 Executive Order 13211, Energy Supply, Distribution, or Use

This rule is not subject to Executive Order 13211, entitled Actions Concerning Regulations That 

Significantly Affect Energy Supply, Distribution, or Use (66 FR 28355, May 22, 2001), because this 

action is not expected to affect energy supply, distribution, or use.

6.9 Executive Order 13563, Improving Regulation and Regulatory Review

Executive Order 13563, Improving Regulation and Regulatory Review (76 FR 3821, January 21, 2011), 

requires EPA to base regulations on the best available science, allow for public participation and the open 

exchange of ideas, promote predictability and reduce uncertainty , identify and use the best, most 

innovative, and least burdensome tools for achieving regulatory ends, consider both the costs and benefits 

qualitatively and quantitatively and ensure regulations are accessible, consistent, written in plain 

language, and easy to understand.

The final rule establishes reporting and recordkeeping requirements that apply to manufacturers 

(including importers) and processors of certain chemicals. Consistent with EO 13563, this document 

qualitatively and quantitatively describes both the costs and benefits of the final rule as well as the 

underlying data used in the analyses. EPA chose the best available data to analyze the costs and benefits 

described in this document and the best analytic approaches given the available data and other constraints.
▌pg. 7-1

7. References

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▌pg. 7-2

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▌pg. 7-3

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Virginia, DC-MD-PA-VA-WV. Accessed from http://www.opm.gov/policy-data-oversight/payleave/salaries-wages/2013/general-schedule/dcb.pdf

OIRA, 2011. U.S. Office of Information and Regulatory Affairs.. Historic Information Collection Data 

for the Information Collection Request (ICR) for the Importation of Chemicals Subject to the Toxic 

Substances Control Act (TSCA) OMB Control Number: 1515-0173 Accessed. June 2011.

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.

Stamps.com. 2013. “2013 USPS Postage Rate Increase Guide.” Available at 

http://www.stamps.com/whitepapers/2013-usps-postage-rate-increase-guide.pdf. Accessed December

2014.

State Coalition for Remediation of Drycleaners, 2009. Chemicals Used In Drycleaning Operations. 

Revised July 2009. Available at

http://www.drycleancoalition.org/chemicals/ChemicalsUsedInDrycleaningOperations.pdf

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.
▌pg. A-1

Appendix 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 presented in this report are in 2013 dollars.

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 A- 2. 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). The following 

table shows the crosswalk between old and new occupational titles. 

Table A- 1: Labor Category Crosswalk

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, and Clerical

Labor

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

Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation (ECEC) data,14 for 

December 2013, for manufacturing industries.15

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 

 

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

Substances: EPA Docket OPPT-2003-0063 (EPAB, 2007b). 

15 Employer Costs for Employee Compensation Supplementary Tables December 2006- June 2014. (BLS, 2014b). This follows 

the approach introduced in EPAB, 2007a. Earlier PMN SNUR economic analyses, such as EPA, 2003, 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.
▌pg. A-2

category. For example, for December 2013, the average wage rate for professional/technical16 labor was 

$39.70; the average fringe benefit was $21.14. Fringe benefits as a percent of wages were $21.14/$39.70, 

or approximately 53.25 percent.

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 2013 fully loaded wage for 

professional/technical labor is $39.70 × (1+0.5325 + 0.17) = $67.59.

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

A- 2.

A.1.2 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 2013 (OPM, 2013). The average 

salary for one FTE staff member is estimated as the salary for a GS-13 Step 5 employee.17

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 $161,446. 

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

Requests (ICRs) (EPA, 1992, 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, 2000a), 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)

 

16 This follows terminology introduced in EPAB, 2007b. 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).

17 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, 2003), which used an average of GS-12 Step 1 and GS-12 Step 10 salaries.
▌pg. A-3

Table A- 2: Derivation of Loaded Wage Rates

EPAB Labor 

Category Data Source Date Wage Fringe 

Benefit

Fringes as % 

Wage

Overhead 

% Wage2

Fringe + 

Overhead 

Factor

Loaded 

Wages1

(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

Dec-13 $46.21 $23.70 51.29% 17% 1.68 $77.77

Professional/

Technical

BLS ECEC, Private Manufacturing 

industries, “Professional and related“3 Dec-13 $39.70 $21.14 53.25% 17% 1.70 $67.59

Clerical

BLS ECEC, Private Manufacturing 

industries, “Office and Administrative 

Support”3

Dec-13 $18.05 $9.24 51.19% 17% 1.68 $30.36

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% 

overhead4

Jan-13 $48.51 -- [Included in 

60% overhead] 60% 1.60 $77.62

Notes:

1Wage data are rounded to the closest penny; however, unrounded values were used in calculations.

2An overhead rate of 17 percent 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). 3Employer Costs for Employee Compensation Supplementary Tables: December 2006-March 2014, U.S. Bureau of Labor Statistics, June 11, 2014 (BLS, 2014b). 4The Federal salary is the unloaded Federal GS-13 Step 5 salary ($100,904 divided by 2,080 hours to get the hourly wage rate in the table) for 2013, from the Office of 

Personnel Management salary table for Washington-Baltimore-Northern Virginia (OPM, 2013). The 60% fringes-and-overhead rate is from an EPA guide, Instructions for 

Preparing Information Collection Requests (ICRs) (EPA, 1992, page 30, footnote 9).
▌pg. A-4

A.2 Derivation of Inflation Factors

Detailed information on the derivation of the inflation factors used is presented in Table A- 3. 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- 3 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).18

“Starting year” indices in Table A- 3 continue to be SIC-OCS based. Current year indices are NAICSSOC 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. 

 

18 BLS has been publishing the NAICS-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. 
▌pg. A-5

Table A- 3: Derivation of Inflation Factors

Item Inflation Index Source1 Starting 

Year

Index for 

Starting Year 

(a)

Index for 

2013

(b)

Inflation 

Factor 

(b)/(a)2

Agency Extramural costs 

Professional and Related 

Private Industry

BLS ECI, Total comp, Private 

industry, Professional and 

related, 4th Q [BLS, 2014b] 3

1993 67 120.5 1.799

Labels, placards etc. BLS CPI, All urban 

consumers, not SA. 

CUUR0000SA0, Annual 

[BLS, 2014a]

1997 160.5 232.957 1.451

File cabinet

Photocopies BLS CPI, All urban 

consumers, not SA. 

CUUR0000SA0, Annual 

[BLS, 2014a]

1988 118.3 232.957 1.969

Record keeping materials

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. 

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. 

2Inflation factors are rounded; however, unrounded values were used in calculations.

3 Beginning with the report Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: EPA 

Docket OPPT-2009-0922 (EPA, 2011b) 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 “white-collar” series.
▌pg. B-1

Appendix B: 2013 TRI Data for TCE

Table B- 1: TRI Reporters for TCE in 2013

Facility Name Use

Total On Site 

Release 

(Pounds) 

Total Off Site 

Release 

(Pounds) 

DARAMIC LLC Manufacturing Aid 246,529 

ENTEK INTERNATIONAL LLC Manufacturing Aid 168,300 

US DOE WASTE ISOLATION PILOT 

PLANT Ancillary Use 108,711 

MICROPOROUS LLC 95,992 

PLYMOUTH TUBE CO Manufacturing Aid 71,794 

UTI HOLDINGS LLC DBA ACCELLENT Ancillary Use 69,195 98 

PPG INDUSTRIES INC BARBERTON 66,997 

SPIRIT AEROSYSTEMS INC

Ancillary Use; 

Formulation Component; 

Manufacturing Aid

 56,081 1,334 

ENERGIZER PERSONAL CARE Ancillary Use 48,800 

NATIONAL COPPER & SMELTING CO Ancillary Use 46,240 

AMETEK SPECIALTY METAL PRODUCTS 

DIV Ancillary Use 38,314 

CESSNA AIRCRAFT CO (PAWNEE 

FACILITY) Manufacturing Aid 33,000 

SUMMERILL TUBE CORP Manufacturing Aid 32,400 

GOODRICH PLATING OPS Ancillary Use 26,035 610 

FISCHER SPECIAL MANUFACTURING 

CO Ancillary Use 25,992 

SCHICK MANUFACTURING INC Ancillary Use; 

Manufacturing Aid 25,544 

SALEM TUBE INC Ancillary Use 24,677 

DRIL-QUIP INC Ancillary Use 24,144 

3P PROCESSING INC Manufacturing Aid 24,031 

GKN AEROSPACE NA INC Manufacturing Aid 22,000 

EAGLE US 2 LLC Ancillary Use 21,925 36 

DUTTON-LAINSON CO Ancillary Use 21,260 

GREATBATCH - GLOBE TOOL INC Ancillary Use 20,239 

ROMATIC MANUFACTURING CO INC Ancillary Use 19,864 268 

BELTSERVICE CORP Manufacturing Aid; 

Repackaging 19,506 

GLOBE ENGINEERING CO INC Ancillary Use 18,339 

PHIFER INC Ancillary Use 18,200 

BETTY MACHINE CO INC Ancillary Use 17,911 

LARSEN'S MANUFACTURING CO Ancillary Use 17,758 

WATER GREMLIN CO Ancillary Use 17,496 
▌pg. B-2

Facility Name Use

Total On Site 

Release 

(Pounds) 

Total Off Site 

Release 

(Pounds) 

MJ CELCO INC Manufacturing Aid 17,100 

HONEYWELL INTERNATIONAL INC 

AUTOMATION & CONTROL SOLUTIONS Ancillary Use 16,770 

API HEAT TRANSFER INC Manufacturing Aid 16,593 

DIAMOND CHROME PLATING INC Manufacturing Aid 16,562 

ADVANCED FORMING TECHNOLOGY Ancillary Use 16,292 

CHEMICAL WASTE MANAGEMENT OF 

THE NORTHWEST INC Ancillary Use 15,939 

VIKING DRILL & TOOL INC Ancillary Use 15,566 

THE BOEING CO Ancillary Use 15,000 

CHEM PROCESSING INC Ancillary Use 14,812 

ACCURATE FORMING LLC Ancillary Use 14,676 

DIXON BRASS Ancillary Use 14,260 

R E DARLING CO INC Ancillary Use 14,033 

GOODRICH CORP Ancillary Use 13,870 

FOUNTAIN PLATING CO INC Ancillary Use 13,420 266 

EXXONMOBIL REFINING & SUPPLY 

BATON ROUGE REFINERY Ancillary Use 13,190 

K & G MANUFACTURING CO Ancillary Use 12,382 

ROPER PUMP CO Ancillary Use 12,159 

NORDAM I&S DIV Manufacturing Aid 11,314 1,100 

MANUFACTURERS PLATING CO Ancillary Use 11,220 

ADVANCED HEAT TREAT CORP Manufacturing Aid 11,200 

OSRAM SYLVANIA INC Ancillary Use 11,080 671 

GASSER & SONS INC Ancillary Use 10,520 

ARLINGTON PLATING CO INC Ancillary Use 10,296 

HU-FRIEDY MFG CO LLC Ancillary Use 10,196 2,066 

ADVANCED HEAT TREAT CORP Manufacturing Aid 10,190 

ALLOYWELD INSPECTION CO Manufacturing Aid 10,088 

FENNER PRECISION Ancillary Use 9,264 

PROTECTIVE COATINGS INC Ancillary Use 8,944 

STEEL COATINGS INC Ancillary Use 8,820 

AGET MFG CO Ancillary Use 8,730 

FN MANUFACTURING LLC Ancillary Use 8,644 

MULLINS RUBBER PRODUCTS INC Ancillary Use 8,590 

NICO PRODUCTS INC Ancillary Use 8,518 

LYTRON INC Ancillary Use 8,334 

ANOPLATE CORP Ancillary Use 8,214 
▌pg. B-3

Facility Name Use

Total On Site 

Release 

(Pounds) 

Total Off Site 

Release 

(Pounds) 

ST REGIS MANUFACTURING LLC 

TRADING AS RS OWENS & CO Ancillary Use 8,000 

TWR SERVICE CORP Ancillary Use 7,840 

EYELET DESIGN INC Ancillary Use 7,572 1,060 

LAKE REGION MEDICAL Ancillary Use; 

Formulation Component 7,460 

EXXONMOBIL CHEMICAL BATON 

ROUGE CHEMICAL PLANT (PART) Ancillary Use 7,400 

WAUCONDA TOOL & ENGINEERING CO 

INC Ancillary Use 7,389 

LS STARRETT CO Ancillary Use 6,297 

ROCHESTER STEEL TREATING WORKS 

INC Ancillary Use 6,063 

HANDYTUBE CORP Ancillary Use 6,046 11 

TECH TUBE Ancillary Use; 

Formulation Component 5,940 

NATIONAL ELECTRICAL CARBON 

PRODUCTS DBA MORGAN ADV 

MATERIALS

 5,900 

HONEYWELL AEROSPACE -

MINNEAPOLIS Ancillary Use 5,611 

MUELLER COPPER TUBE PRODUCTS 

INC Ancillary Use 5,268 

MN TWIST DRILL AQUISITION LLC 4,958 

KASTALON INC Manufacturing Aid 3,960 

MARQUETTE TOOL & DIE CO Manufacturing Aid 3,960 

MCMILLAN ELECTRIC CO Manufacturing Aid 3,885 

US RINGBINDER Ancillary Use 2,645 

UTICA CUTLERY CO Ancillary Use 2,629 

DOW CHEMICAL CO FREEPORT 

FACILITY

Ancillary Use; 

Repackaging 2,416 

DYNEX/RIVETT INC Manufacturing Aid 1,997 

LORD CORP Formulation Component 1,995 

LIMCO-AIREPAIR INC Ancillary Use 1,716 

ENERGIZER BATTERY 

MANUFACTURING INC 1,535 

WHITAKER OIL CO Repackaging 1,486 

CRC INDUSTRIES INC Formulation Component; 

Repackaging 1,438 

ARKEMA INC 1,354 

TRAVIS PATTERN & FOUNDRY INC Manufacturing Aid 1,160 

QUESTVAPCO CORP Ancillary Use; 

Formulation Component 1,124 

AKEBONO - ELIZABETHTOWN PLANT Ancillary Use 1,000 
▌pg. B-4

Facility Name Use

Total On Site 

Release 

(Pounds) 

Total Off Site 

Release 

(Pounds) 

WESTLAKE VINYLS CO 880 

SHERWIN-WILLIAMS CO Formulation Component 844 40 

RR STREET & CO INC Repackaging 766 

FORMOSA PLASTICS CORP LOUISIANA Ancillary Use 712 

AMREP INC Formulation Component 669 

PLAZE INC Formulation Component 501 

LAFARGE MIDWEST INC (INCLD 

SYSTECH ENVIRONMENTAL) Repackaging 500 250 

KEYSTONE CEMENT CO Ancillary Use 500 

CHEMICAL SOLVENTS JENNINGS ROAD 

FACILITY

Formulation Component; 

Repackaging 500 

AERVOE INDUSTRIES INC Article Component 500 

CHEMICAL SOLVENTS INC--DENISON 

FACILITY

Ancillary Use; 

Repackaging 500 

FORMOSA PLASTICS CORP TEXAS Ancillary Use 440 

SLOCUM ADHESIVES CORP Formulation Component 408 

LPS LABORATORIES Formulation Component 372 

UNIVAR USA INC NORCROSS FACILI TY Repackaging 352 

UNITED LAUNCH ALLIANCE - DECATUR 

OPERATIONS Ancillary Use 287 

UNIVAR USA INC Repackaging 266 

CONTINENTAL CEMENT CO LLC Ancillary Use 255 

EMCO CHEMICAL DISTRIBUTORS INC Formulation Component; 

Repackaging 255 

PACKAGING SERVICES CO INC 

(PEARLAND FACILITY)

Formulation Component; 

Repackaging 255 

EMCO CHEMICAL DISTRIBUTORS INC Formulation Component; 

Repackaging 255 

PRECISION FORMING & STAMPING C O Ancillary Use 255 501 

IPS CORP Formulation Component 250 

COMMERCE INDUSTRIAL CHEMICALS 

INC Repackaging 250 

HALOCARBON PRODUCTS CORP 220 

HUBBARD-HALL INC Repackaging 217 

BUZZI UNICEM USA - GREENCASTLE 

PLANT

Ancillary 

UseRepackaging 189 

VEOLIA ES TECHNICAL SOLUTIONS 

LLC

Ancillary Use; 

Formulation Component; 

Repackaging

 188 336 

SOUTHWEST SHIPYARD LP Repackaging 180 

TREADS DIIRECT LLC DBA MIDWEST 

RUBBER Formulation Component 150 
▌pg. B-5

Facility Name Use

Total On Site 

Release 

(Pounds) 

Total Off Site 

Release 

(Pounds) 

3M COTTAGE GROVE CENTER Ancillary Use 146 

THE DOW CHEMICAL CO - LOUISIANA 

OPERATIONS Ancillary Use 135 

AXIALL LLC 129 3 

WRR ENVIRONMENTAL SERVICES CO 

INC Formulation Component 97 

OCCIDENTAL CHEMICAL CORP Ancillary Use 92 2 

EMERALD SERVICES INC 80 0.01 

ABC COMPOUNDING CO OF TEXAS INC Formulation Component 69 

INTERSTATE CHEMICAL CO INC Formulation Component; 

Repackaging 65 

OXY VINYLS LP DEER PARK-VCM 

PLANT Ancillary Use 63 0.03 

CLEAN HARBORS DEER PARK LLC Article Component 58 

ADCO INC Repackaging 52 

CLEAN HARBORS ENVIRONMENTAL 

SERVICES INC Ancillary Use 47 0.005 

CLEAN HARBORS ARAGONITE LLC Ancillary Use 47 101 

ROSS INCINERATION SERVICES INC Ancillary Use 42 39 

VEOLIA ES TECHNICAL SOLUTIONS 

LLC PORT ARTHUR FACILITY Ancillary Use 40 

SHINTECH PLAQUEMINE PLANT 33 

INTERSTATE CHEMICAL CO INC Formulation Component; 

Repackaging 29 

BARTON SOLVENTS INC DES MOINES Formulation Component; 

Repackaging 23 

SHAWMUT CORP 21 

DUPONT SABINE RIVER WORKS Ancillary Use 19 

HERITAGE THERMAL SERVICES Ancillary Use 17 10 

ASTRO CHEMICALS INC Repackaging 15 

GIANT CEMENT CO Ancillary Use 13 13 

GEORGIA GULF LAKE CHARLES LLC 12 

ENERGIZER BATTERY 

MANUFACTURING INC Ancillary Use 11 

SAFETY-KLEEN SYSTEMS INC Formulation Component; 

Repackaging 10 

SYSTECH ENVIRONMENTAL CORP Ancillary Use 10 

KAGA (USA) INC Ancillary Use 10 

AMERICAN JETWAY CORP Formulation Component 10 

MEXICHEM FLUOR INC 8 

BUZZI UNICEM USA - CAPE GIRARDEAU Ancillary Use 8 
▌pg. B-6

Facility Name Use

Total On Site 

Release 

(Pounds) 

Total Off Site 

Release 

(Pounds) 

EVOQUA WATER TECNOLOGIES 

DARLINGTON FACILITY Ancillary Use 8 38 

WESTLAKE VINYLS INC 5 

ESSROC CEMENT CORP Ancillary Use 5 

SHIELD PACKAGING CO INC Formulation Component 5 530 

CHEMTRON CORP Ancillary Use 4 4 

NORLITE LLC Ancillary Use 4 

OXY VINYLS LP LA PORTE VCM PLANT 3 0.01 

CLEAN HARBORS EL DORADO LLC Ancillary Use; 

Repackaging 2 

ASH GROVE CEMENT CO Ancillary Use 1 

ASH GROVE CEMENT CO Ancillary Use 1 

SOLVAY USA INC Ancillary Use 1 

SOLVAY USA INC Ancillary Use 0.4 

SUPERIOR FIBERGLASS & RESINS

SUPERIOR SOLVENTS & CHEMICALS

BRENNTAG GREAT LAKES LLC

BALMAR LLC

VEOLIA ES TECHNICAL SOLUTIONS 

LLC Ancillary Use 3 

QUAKER CITY CHEMICALS

SUPERIOR SOLVENTS & CHEMICALS

MON-ECO INDUSTRIES INC

31 INC

SUPERIOR OIL CO INC

THIRD COAST TERMINALS PEARLAND

RHO-CHEM LLC

FARLEY CO

COMCAST URETHANE

DELTA COS GROUP ST GABRIEL Repackaging

ROBERTS CAPITOL

BLENTECH CORP

AMC INTERNATIONAL

SUPERIOR SOLVENTS & CHEMICALS

PRIDE SOLVENT & CHEMICAL CO OF 

NY INC

MASTERS MACHINE CO Article Component; 

Manufacturing Aid

CENTRAL PLAINS CEMENT CO

BRENNTAG GREAT LAKES LLC
▌pg. B-7

Facility Name Use

Total On Site 

Release 

(Pounds) 

Total Off Site 

Release 

(Pounds) 

CHEMICAL & METAL INDUSTRIES INC

HILL MANUFACTURING CO INC

FOUR STAR CHEMICAL

BRENNTAG NORTHEAST INC

VANCE BROTHERS INC

CLEAN EARTH OF NORTH JERSEY INC Ancillary Use 10,971 

SPRAY PRODUCTS CORP

FBC CHEMICAL MEDINA

TEM-TEX SOLVENTS CORP

CHEMICAL DISTRIBUTORS INC

APOLLO TECHNOLOGIES

WEBB CHEMICAL SERVICE CORP

Sources: EPA, 2014c.