### Page 1 of 96 

## Supporting Statement for OMB Review under

the Paperwork Reduction Act

1. IDENTIFICATION OF THE INFORMATION COLLECTION

l(a) Title of the Information Collection

TITLE: ICR for Proposed Rule Implementing the Formaldehyde Emissions

Standards for Composite Wood Products Act [RIN 2070

- AJ92]

EPA ICR No.: 2446.01

OMB Control No.: 2070

- NEW

1(b) Short Characterization

The Formaldehyde Standards for Composite Wood Products Act, which establ ished Title

VI of the Toxic Substances Control Act (TSCA), set forth formaldehyde emission standards for

hardwood plywood, particleboard and medium

- density fiberboard and directs EPA to promulgate

implementing regulations by January 2013. TSCA Title VI al so directs EPA to promulgate

supplementary provisions to ensure compliance with the emissions standards, including testing

requirements, laminated product provisions, provisions for products made with no

- added

formaldehyde (NAF) resins or ultra

- low emittin g formaldehyde (ULEF) resins, product labeling

requirements, chain of custody provisions for product compliance documentation, recordkeeping,

product inventory sell

- through dates, a product stockpiling prohibition, and product certification

by an accredite d third party (third party certifier, or TPC). This ICR covers the recordkeeping

and reporting requirements for all aspects of the TSCA Title VI implementing regulations,

except those relating to accreditation bodies and third

- party certifiers that wish t o participate in

this third

- party certification program. A separate information collection request covers those

recordkeeping and reporting requirements.

Some examples of proposed reporting and third

- party reporting requirements covered by

this info rmation collection request include:

• Notifying EPA in the event of a failed quarterly test

• Reporting of the results of quality control tests to third

- party certifiers

• Notifying a third

- party certifier of a change in quality control manager

Examples of proposed recordkeeping requirements include:

• Records on quarterly test results and quality assurance test results

• Records of quality control manuals

• Records on quality control managers and employees and their qualifications

• Records on the disposition of non

- compliant lots

• Chain of custody recordkeeping requirements for importers, fabricators , and laminated

products producers

### Page 2 of 96 

## • Labeling requirements for manufacturers (including importers), fabricators, distributors,

and wholesalers

.

• Minimized requirements f or non

- importing distributors and retailers

The information collected under this ICR would be used by EPA’s Regional

Administrators, the Office of Enforcement and Compliance Assurance (OECA), and/or the

Office of Chemical Safety and Pollution Prevention (OCSPP), as appropriate. Some of the

informat ion would also be made available to the public via the internet. This would include the

names and address of companies that have products that qualified for reduced testing based on

the use of no

- added formaldehyde

- based resins. Downstream purchasers may use this

information in order to determine that the merchandise is compliant and to avoid purchasing

products that are not legally saleable in the United States. Confidential business information

(CBI) submitted to EPA will be maintained by the Agency pur suant to TSCA § 14 and 40 CFR

Part 2.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

The reporting and recordkeeping requirements of this ICR are implemented under the

authority of TSCA Title VI. TSCA Title VI directs E PA to promulgate regulations to ensure

compliance with the emissions standards, including provisions on testing requirements,

laminated products, products made with no

- added formaldehyde resins or ultra

- low emitting

formaldehyde resins, product labeling r equirements, chain of custody for product compliance

documentation, recordkeeping, product inventory sell

- through dates, a product stockpiling

prohibition, and product certification by a TPC. To meet its statutory obligations, EPA must

obtain sufficient i nformation to ensure compliance with the emissions standards; moreover, a

reasonable amount of reporting encourages regulated entities to fulfill their obligations under the

statute and regulations

.

2(b) Use of the Data

EPA would use the information coll ected to evaluate manufacturer and importer

compliance with the emissions standards. The information that is collected and required to be

reported to third

- party certifiers is necessary to ensure that producers of composite wood panels

maintain proper qua lity assurance and control measures. Third

- party certifiers require access to

this information so that they can certify that products are produce in accordance with TSCA Title

VI requirements. TSCA Title VI also directs EPA to include labeling provisions. The

information contained in the labels accompanying composite wood panels and finished goods

containing such panels will allow downstream purchasers of these products to determine whether

the merchandise is compliant; non

- compliant merchandise may not b e legally sold supplied or

offered for sale in the United States.

3. NON

- DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

### Page 3 of 96 

## 3(a) Non

- Duplication

TSCA Title VI assigns to the EPA Administrator the responsibility for promulgating

regulations that ensure compliance with the statutory emissions standards for formaldehyde from

composite wood products. The information collection requirements addressed in this ICR are not

duplicative of any other Federal requirement. There are no federa l regulations on formaldehyde

emissions from pressed wood products other than those of the Department of Housing and Urban

Development (HUD) that are applicable to particleboard and plywood used in manufactured

housing. In contrast with the HUD emissions s tandards which are only applicable to

particleboard and plywood used in manufactured housing, the emissions standards in TSCA Title

VI apply to hardwood plywood, medium

- density fiberboard, and particleboard sold, supplied,

offered for sale, or manufactured (defined by statute to include import) in the United States.

Because the proposed regulatory requirements are necessarily tailored to the unique

TSCA Title VI requirements, these records and reports are the sole source of information for

EPA to rely on to ensure compliance with the emissions standards.

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

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

should submit comments referencing Docket ID No. EPA

- HQ

- O PPT

- 2011

- 0380 to the address

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

rulemaking.

3(c) Consultations

On numerous occasions during the course of developing the proposed regulation, the

Agency has con sulted with the regulated community and the public. These consultations have

been held directly with industry officials and, on an ongoing basis, with owners and operators of

regulated facilities. EPA has also consulted with the California Air Resources B oard (CARB),

which operates a similar third

- party certification program for formaldehyde standards for

composite wood products that are sold, supplied or offered for sale in the State of California.

Since EPA began its regulatory investigation into form aldehyde emissions from pressed

wood products with an Advanced Notice of Proposed Rulemaking (ANPR) published in 2008,

EPA has met on numerous occasions with the composite wood panel and related industries.

These meetings have been in the form of presenta tions at trade shows and industry association

conferences, and meetings with the Composite Panel Association (CPA), the Hardwood Plywood

and Veneer Association (HPVA), the Kitchen Cabinet Manufacturing Association (KCMA), the

American Home Furnishings Alli ance (AHFA), the Business and Institutional Furniture

Manufacturer’s Association (BIFMA), and individual companies. EPA staff have, at the

invitation of potentially regulated manufacturers, conducted factory tours and site visits.

EPA convened a Small Business Advocacy Review Panel and hosted two panel outreach

meetings with small entity representatives (SER). Prior to each meeting, EPA distributed

### Page 4 of 96 

## outreach materials to the SERs, and after each meeting the SERs were asked to provide written

feedback on how EPA might reduce regulatory burden on small entities. The Panel received

written comments from the SERs in response to the discussions at the meetings and the outreach

materials. The Panel summarized written and oral comments from the SERs and develope d Panel

recommendations in its Panel Report. ( See Panel Report of the Small Business Advocacy Review

Panel on EPA’s Planned Proposed Rule Implementing the Formaldehyde Standards for

Composite Wood Products Act (TSCA Title VI), April 4, 2011).

EPA intends to carry out further consultations and outreach with potentially regulated

entities concurrent with the public comment period. These comments will be used to update the

Supporting Statement as needed.

3(d) Effects of Less Frequent Collection

EPA has judged that the reporting and recordkeeping requirements of the ICR are the

minimum amount necessary to fulfill its statutory mandate to promulgate regulations that ensure

compliance with the emissions standards. The reports and records in this ICR would allow EPA

carry out its statutorily

- delegated roles in program design, enforcement, and oversight . EPA

believes that less frequent reporting and failure to require notice of significant events could result

in uncertified and noncompliant products being distributed in commerce in violation of the

statute. For example, panel producers must provide their third

- party certifier with monthly

product data reports for each production facility, production line, and product type. These reports

will include production information and quality control test results, and will allow the third

- party

certifier to monitor quality control testing and ensure that production at the facility remains in

compliance with the statutory emission standards.

3(e) General Guid elines

In general, this information collection complies with the guidelines at 5 CFR

1320.5(d)(2). The exceptions to OMB’s Paperwork Reduction Act Guidelines, and the

explanation of why such characteristics are needed to fulfill the statutory requirement s, are

described below:

Record retention for 3 years is especially critical because these regulated products

(composite wood panels, component parts, and finished goods) may be in commerce for 3 years

or even longer. Composite wood products are regulated beginning with the manufacture

(including import) of panels through their incorporation into component parts and finished

goods, the distribution of those products, and the retail sale of those p roducts. This is a lengthy

process and the amount of time composite wood panels are held in inventory and the amount of

time before they are incorporated into a finished good are variable. This point was illustrated by

the fact that the State of Californ ia had to twice extend its “sell

- through date” when it enacted an

Airborne Toxic Control Measure (ATCM) establishing formaldehyde emissions standards for

composite wood products. The California Air Resources Board found that these extensions were

necessary because the recession increased the amount of time manufacturers needed to clear

preexisting inventory. ( See, e.g., Composite Wood Products Regulation Advisory: 11

- 01,

Extension of Sell

- Through Dates for: Distributors, Importers, Fabricators, and Retaile rs of

### Page 5 of 96 

## Finished Goods Containing Phase 1 Hardwood Plywood

- Veneer Core and Distributors of Phase

1 Particleboard and Medium Density Fiberboard Panels, available at

http://www.ar b.ca.gov/toxics/compwood/outreach/11_01_advisory.pdf ). It is essential that

proper chain

- of

- custody documentation be retained for this entire period of time so that both

EPA and interested downstream consumers can be assured that a finished good containing

regulated composite wood product was made from compliant composite wood panels.

A number of provisions require reporting only upon the occurrence of a specific event.

For example, a panel producer must notify its third

- party certifier immediately if it makes

production changes that are likely to have an impact on formaldehyde emissions from its

products. These reporting requirements are not triggered by the calendar ( i.e. , they are not

required quarterly or at more frequent intervals). Therefore, the Agency does not believe that

these provisions need special justification. Moreover, EPA believes that unless these

notifications are provided within the intervals prescribed in the proposed rule, a change in

circumstances could result in non

- compliant pro ducts being distributed in commerce. Not only is

this a violation of the statute, but it greatly increases the cost associated of segregating, treating

and retesting these products.

3(f) Confidentiality

Regulated entities may claim all or part of any in formation given to EPA as confidential

business information (CBI). EPA handles claims of confidentiality pursuant to established CBI

procedures, as found at Section 14 of TSCA, 40 CFR Part 2, and the Agency’s TSCA CBI

Manual. CBI is also protected under the Freedom of Information Act (5 USC Section 525).

Much of the information requested in the reporting requirements of these collections is not of a

confidential nature.

3(g) Sensitive Questions

EPA asks no questions of a sensitive nature.

4. THE RESP ONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/NAICS Codes

The primary respondents would be manufactures, distributors, importers, retailers of

regulated composite wood products and finished goods containing regulated composite wood

products.

The following NAICS codes may be affected:

• Hardwood Veneer and Plywood Manufacturing (NAICS code 321211);

• Reconstituted Wood Product Manufacturing (NAICS code 321219);

• All Other Miscellaneous Wood Product Manufacturing (NAICS code 321999);

• Furniture and Related Product Manufacturing (NAICS code 337);

• Miscellaneous Manufacturing (NAICS code 339);

### Page 6 of 96 

## • Merchant Wholesalers, Durable Goods (NAICS code 423);

• Merchant Wholesalers, Nondurable Goods (NAICS code 424); and

• Retail Trade (NAICS Sector 44 and 45).

4(b) I nformation Requested

(i) Data Items

The proposed recordkeeping requirements and reporting requirements include:

(A) Notifications/Reports . Respondents are required to submit information to EPA to

accomplish the following reporting tasks:

• Imports o f regulated composite wood products and finished goods containing regulated

composite wood products must be accompanied by a TSCA § 13 import certification.

• Panel producers who wish to qualify for reduced testing and third

- party certifier oversight

under the no

- added formaldehyde

- based resin provisions must apply to a third

- party

certifier and send a copy of the application to EPA.

• Third

- party certifiers mus t notify EPA and the panel producer of a failed quarterly test I

in writing within 24 hours.

(B) Third

- Party Notifications/Reports . Respondents are required to submit

information to entities other than EPA as follows:

• Composite wood product panel produ cers must apply for product certification from a

third

- party certifier. The application must include the panel producer’s name, address,

telephone number, and other contact information, including name and contact

information for the panel producer’s qualit y control manager, and an identification of the

specific products for which certification is requested, the chemical formulation of the

resins, including base resins, catalysts, and other additives used in panel production, and

testing results. A copy of t he panel producer’s quality control manual must also be

provided to the third

- party certifier with the application. Manuals must include

information on the organizational structure of the quality control department, a

description of the sampling procedure s and frequency of testing, a description of

procedures used to identify significant production changes, a description of the resin and

press time for each product type, and a description of recordkeeping procedures. Changes

in manuals must be submitted to and approved by an accredited third

- party certifier.

• Composite wood product panel producers must provide information on the qualifications

of their quality control manager and quality control employees to the third

- party certifier.

• Composite wood product panel producers must provide their third

- party certifier with a

monthly product data reports that include production information and quality control test

results for each production facility, pro duction line, and product type.

### Page 7 of 96 

## • Comp osite wood product panel producers must notify their third

- party certifiers if they

change quality control managers. This notification must occur within 10 days of the

change.

• Composite wood product panel producers wishing to take advantage of reduced t esting

and third

- party certification requirements for products made with no

- added formaldehyde

resins must apply to an accredited third

- party certifier. The application must include the

panel producer’s name and contact information as well as an identifica tion of the specific

product and the chemical formulation of the resins, including base resins, catalysts, and

other additives as used in manufacturing. Testing results must also be part of the

application. If the application is granted, every two years th ereafter, the panel producer

must have one test performed by an accredited third

- party certifier that demonstrates

continued compliance with the reduced formaldehyde emission standards for each

product type.

• Panels or bundles of regulated composite wood p roducts must be labeled with the

producer’s name (or number), lot or batch number, the number of the accredited third

party certifier, and markings indicating that the product complies with the TSCA Title VI

emission standards. Products that qualify for re duced testing and third

- party certification

requirements based on the use of ultra

- low formaldehyde or no

- added formaldehyde

resins must also be marked with indications that they were produced using ultra

- low

formaldehyde or no

- added formaldehyde resins. Boards that are shipped into the United

States for testing purposes must also be labeled as such.

• Fabricators of finished goods containing composite wood products are required to label

every finished good they produce, or every box containing finished g oods. The label

could be applied as a stamp, tag, sticker, or bar code and must include the fabricator’s

name, the date the finished good was produced and a marking to denote that the product

was made in compliance with TSCA Title VI.

(C) Records

. Respondents are required to maintain records as follows:

• Panel producers must maintain the following records for at least three years and make

them available upon request to EPA, their third

- party certifiers, and to purchasers of their

composite wood prod ucts:

o Records of all quarterly emission testing and all ongoing quality control testing

that identify the TPC conducting or overseeing the testing and the laboratory or

quality control facility actually performing the testing. These records must also

include th e date, the product type tested, the lot or batch number that the tested

material represents, the test method used, and the test results.

o Production records, including a description of the composite wood product(s), the

date of manufacture, lot or batch numbers, and tracking information allowing

each product to be traced to a specific lot number or batch produced.

o Records of changes in production, including changes of more than 10% in the

resin use percentage, changes in resin composition that result in a higher ratio of

### Page 8 of 96 

## formaldehyde to other resin components, and changes in the process, such as

changes in press time by more than 20 percent.

o Records demonstrating initial and continued eligibility for the reduced testing

provisions in 40 CFR § 770.17, if applicable.

o Purchaser information for each composite wood product, if applicable, including

the name, contact person, address, phone number, e

- mail address if available,

purchase order or invoice number, and amount purchased.

o Transporter information for each composite wood product, if applicable,

including name, contact person, address, phone number, e

- mail address if

available, and shipping invoice number.

o Information on the disposition of non

- complying lots, including product type and

amount of compo site wood products affected, lot or batch numbers, mitigation

measures used, results of retesting, and final disposition.

o Copies of labels used.

• Panel producers are required to maintain an up

- to

- date quality control manual on their

premises.

• Panel pr oducers are required to maintain the credentials of their quality control managers

and quality control employees for as long as employees are serving in a quality control

capacity.

• Producers of exempt laminated products are required to maintain records de monstrating

that they are using compliant platforms and NAF resins. These records would include

records of purchases of NAF resins and of compliant, certified platforms, or, if the resins

or platforms are made in

- house, records demonstrating that the plat forms have been

certified by an accredited TPC and records demonstrating the production of NAF resins.

• Importers, fabricators of finished goods that incorporate composite wood products,

laminated product producers whose products are exempt from the def inition of hardwood

plywood must maintain records identifying the panel producer, the date the composite

wood products were produced, the date the composite wood products were purchased

, and bills of lading or invoices that include a written affirmation fr om the supplier that the

composite wood products are compliant

.

• Non

- importing d istributors and retailers must retain invoices and bills of lading and

copies of labels used.

(ii) Respondent Activities

All respondents would need to read the rule and determine which provisions would be

applicable to their operations; plan and modify their procedures to come into compliance with

the rule; provide training to appropriate staff; process, compile, and review information for

accuracy and appropriateness; an d record, disclose, and/or report the required information.

5. THE INFORMATION COLLECTION

— AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION MANAGEMENT

### Page 9 of 96 

## 5(a) Agency Activities

EPA resources would be devoted to reviewing and analyzing import certifications,

auditing and inspecting facilities, producing audit and inspection reports, responding to public

inquiries, providing regulatory interpretations and developing rulemakings.

5(b) Collection Methodology and Management

At this time, the majority of the information requirements would not require the use of a

specific form or format, except that failed test results must be reported in writing. By a nd large

the reporting require ments of this rule are third

- party reporting requirements, in that panel

producers are required to submit information to TPCs. EPA wishes to give maximum latitude to

TPCs and panel producers as they choose how to most expediently structure their

communicat ions.

5(c) Small Entity Flexibility

Small businesses are not exempt from the requirements of TSCA Title VI. The

information collections would apply to all entities that manufacture (including import), sell,

supply, or offer for sale regulated composite w ood products in the United States regardless of

size. They would also apply to entities that manufacture regulated composite products, including

finished goods, for import into the U.S. and to third

- party certifiers that wish to participate in the

program. During the Small Business Advocacy Review Panel process, the Panel recommended

regulatory flexibility alternatives to alleviate burden on small business. EPA seeks to implement

those recommendations in its proposal. For example, EPA’s proposal would al low labeling by

bundle, as opposed to individual boards. EPA is also requiring quality control tests for

hardwood plywood based on production volume, allowing low volume producers to conduct

fewer tests.

5(d) Collection Schedule

Panel producers must p rovide their third

- party certifiers with monthly product data

reports. The rest of the reporting activities are triggered by specific events or on an as needed

basis rather than by specific dates.

6. ESTIMATING BURDEN AND COST OF THE COLLECTION

This se ction estimates the burden and associated costs for both the respondents and the

Agency associated with the recordkeeping and reporting requirements of the proposed TSCA

Title VI Implementation Rule. This supporting statement provides average annual burde n and

cost estimates for the next three years of the program. All costs are presented in year 2010

dollars.

This ICR presents the burden and associated costs for the activity types listed below.

Note that not all entities will incur burden or costs f rom these activities because they may already

### Page 10 of 96 

## be meeting the requirements under the CARB ATCM and/or their existing recordkeeping and

labeling systems may already be sufficient.

• Rule Familiarization: All respondents will need to read the rule in order to understand

the requirements;

• Testing and Certification: All composite panel producers will need to perform

formaldehyde emission testing on their composite wood products and attain certification

fro m an accredited third

- party certifier (TPC). These entities must undergo qualifying

tests at a TPC lab, obtain an on

- site audit from a TPC, implement quality control systems,

and train quality control employees in order to receive initial certification. Once

certified, a mill is required to conduct on

- going small scale quality control testing, submit

monthly reports to the certifying TPC, and receive quarterly on

- site audits and large

chamber testing to maintain its certified status. Mills that produce p roducts made with

ULEF or NAF resins that meet more stringent emissions limits may apply for exemptions

from some of the on

- going testing requirements;

• Recordkeeping : Firms that import, produce, or manufacture composite wood panels,

component parts, or finished goods are required to keep records showing the date of

purchase of the composite wood product, the supplier, and all precautions taken to ensure

that the product meets emissions standards. Wholesalers and retailers that do not import,

produce, or manufacture composite wood panels, component parts, or finished goods are

only required to maintain invoices and bills of lading; and

• Labeling: Panel producers, fabricators, and wholesalers that package or repackage

composite wood products or finished g oods containing composite wood products will

need to modify their labels to include their name, the date the finished good was

produced, and a statement of compliance.

Exhibit 6

- 1 summarizes the recordkeeping and reporting activities for respondents as a

result of the proposed rule:

### Page 11 of 96 Exhibit 6

- 1 : Summary of Recordkeeping and Reporting Acti vities, by Sector and Activity

Activity Composite Panel Producer 1

Fabricator Wholesaler

Retailer Standard ULEF NAF Imports No

Imports

1. Rule Familiarization 1

- time 1

- time 1

- time 1

- time

2. Certification Fee Annual

- - - -

3. Initial On

- site Audit 1

- time

- - - -

4. Develop Quality Control

Manual 1

- time

- - - -

5. Qualifying Test 1

- time

- - - -

6. Qualifying Test Shipment 1

- time

- - - -

7. Correlation Test 1

- time

- - - -

8. Recurring On

- site Audit 2 Quarterly Annual

- - -

9. Large Scale Testing Fee 3 Quarterly Annual

- - -

10. Large Scale Testing

Shipment 3 Quarterly Annual

- - -

11. On

- site Audit Travel 4 Annual

- - - -

12. Desk Audits 5 8 per year

- - - - -

13. Purchase of Small Chamber

Testing Unit 6 1

- time

- - - - -

14. Quality Control Testing 7 Up to Daily

- - - -

15. Lost Product 8 Up to Daily

- - - - 16. Initial Recordkeeping

- - - 1

- time

- - 17. Recurring Recordkeeping Annual Annual Annual

- - 18. Initial Labeling 1

- time 1

- time 1

- time

-

Notes:

1. This analysis assumes that panel producers with standard (Phase 2), ULEF, or NAF certifications under the CARB ATCM will reta in those

certifications under the TSCA Title VI rule, but that product lines being newly certified as a result of the TSCA Title VI rule will receive either

standard or NAF certifications. Furthermore, some TPCs may have more stringent requirements than the regulations require. For example,

HPVA requires mills to have on

- site audits and large chamber tests annually fo r NAF

- certified products, and quarterly for ULEF

- certified

products, which is more frequently than the CARB ATCM requires. This analysis therefore assumes that TPCs test and audit mills with NAF or

ULEF

- certified product lines more frequently than the CARB ATCM or the proposed TSCA Title VI rule require.

2. This analysis assumes that producers with new NAF certifications will incur the burden associated with one on

- site audit (in addition to the

initial audit) in the first year. The initial on

- site audit is assumed to be sufficient for producers with existing ULEF or NAF certifications. All

ULEF or NAF

- certified producers will have one on

- site audit annually thereafter.

3. Mills are assumed to p erform large scale testing quarterly unless all products are certified as NAF. It is assumed that mills with only NAF

certified products will perform large scale testing annually. In the first year, mills with added

- formaldehyde products will test those products

three times in addition to the qualifying testing, and mills with NAF products will test those once at the end of the qualify ing process.

4. It is assumed that travel is only necessary for the annual audits, as other intermediate audits can be p erformed by contracting inspectors closer

to the mill.

5. Desk audits for standard certification are assumed to occur monthly except in months with quarterly on

- site audits. The analysis assumes that

producers with new NAF certification will incur the bur den associated with two desk audits in the first year. ULEF or NAF

- certified producers

will not have any desk audits in subsequent years.

6. This analysis assumes that mills with standard certification or a new NAF certification will choose to set up and operate a small scale testing

facility on

- site; although, all particleboard and MDF mills with standard certification are assumed to already have a small scale testing facility on

site. Mills with an existing ULEF or NAF certification will already have b een exempted from quality control testing

. 7. Particleboard and MDF mills are required to test samples at least once per eight or twelve hour shift, but the frequency i s reduced to one test

per 48 hours if the plant or production line has shown consistent operations with low variability of test results. The testing frequency for

hardwood plywood producers depends on their production volume, ranging from as little as one test per hundred thousand square feet of

production to as much as four tests per week. This analysis makes the simplifying assumption that all panel producers with standard certification

will test once per day, which results in a conservative estimate of the burden and cost of quality control testing for hardwo od plywood producers.

8. Mills will need to forfeit a number of panels for initial and on

- going testing. Mills are expected to ship five 4’ x 8’ panels per product type for

qualifying testing. All producers of products with a standard certification are assumed to lose one panel per p roduct type each day for quality

control testing, which is a conservative estimate for hardwood plywood producers. In addition, mills are required to send on e panel per product

type to the TPC for large scale testing each quarter. However, product lines that are certified as NAF are exempt from routine quality control

testing after the three month qualifying period, and need only have large scale testing performed annually. Product lines th at are certified as

ULEF are exempt from routine quality control testing after the six month qualifying period, and are assumed to have large scale testing

performed quarterly.

### Page 12 of 96 

## Note that the TSCA Title VI rule requires importers of articles that are composite wood

products, or articles that contain composite wood pr oducts, to comply with the TSCA Section 13

import certification regulations for “Chemical Substances in Bulk and As Part of Mixtures and

Articles,” as found at 19 CFR 12.118 through 12.127. Thus, any U.S. importer of composite

wood products or articles th at contain composite wood products would have to certify that all

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

the articles in the shipment are not subject to TSCA. The statement must be on or attached to a

commercial invoice or entry document belonging to the imported shipment. In practice, import

certification is fulfilled by checking a box on an invoice or entry document. It is assumed that

this does not generally impose a significant additional bu rden or cost on the importer. Any

potential burden associated with a submitter’s familiarization with this requirement is assumed to

be included in the more general rule familiarization burden discussed below.

Ex hibit 6

- 2 

## summarizes the activities that have reporting and recordkeeping burden hours

(and thus labor costs) associated with them, and those that have non

- labor costs (such as

purchasing equ ipment, shipping composite wood samples for testing, TPC fees, etc.). Burden

hour estimates are discussed in section 6(a), while labor and non

- labor costs are discussed in

section 6(b). Exhibit 6

- 2 

## also summarizes the baseline calculations for this ICR analysis. Many

panel producers are already engaged in these activities because their products are certified under

the CARB ATCM. This analysis estimat es the burden and cost of the TSCA Title VI rule’s

requirements both with and without accounting for this baseline.

This analysis assumes that mills making product lines that have a standard certification 1



## or a ULEF or NAF certification under the CARB ATCM will not need to submit new data or

resubmit existing data to their existing TPC in order to receive the equivalent certification under

the TSCA Title VI regulations. Thus, this ICR does not include burdens and cost s for these

reporting and recordkeeping activities where it is assumed the activities were already performed

to comply with the CARB ATCM and will not need to be performed again. This is consistent

with the methodology used in the Economic Analysis for th e proposed rule.

However, this ICR does include the burdens and costs of required activities that will

continue to be performed under the TSCA Title VI rule, even if those activities would be

performed regardless of the TSCA rule (i.e., to comply with th e CARB ATCM). This is

different from the methodology in the Economic Analysis for the proposed rule, where the

baseline included activities performed to comply with the CARB ATCM. As a result, the

Economic Analysis excluded the costs of activities that w ould be performed even without the

TSCA rule.

1 The term standard certification is used here to describe a certification other than an ultra

- low

- emitting formaldehyde (ULEF) or

NAF certification.

### Page 13 of 96 Exhibit 6

- 2 : Summary of Recordkeeping and Reporting Activities, by Activity

Activity Labor

Costs

(see

Section

6(a)) Non

Labor

Costs

(see

Section

6(b)) Burden/Cost Included for

Incremental Estimate, by firm

type Burden/Cost Included for

Total Estimate, by firm

type

Baseline CARB

Compliant Not Baseline

CARB

Compliant Baseline

CARB

Compliant Not Baseline

CARB

Compliant

1. Rule Familiarization Yes Yes Yes Yes Yes

2. Certification Fee Yes Incremental Only Yes Yes Yes

3. Initial On

- site Audit Yes Yes Incremental Only Yes Yes Yes

4. Develop Quality Control

Manual Yes Yes Yes

5. Qualifying Test Yes Yes Yes

6. Qualifying Test Shipment Yes Yes Yes Yes

7. Correlation Test Yes Yes Yes Yes

8. Recurring On

- site Audit Yes Yes Incremental Only Yes Yes Yes

9. Large Scale Testing Fee Yes Incremental Only Yes Yes Yes

10. Large Scale Testing

Shipment Yes Yes Incremental Only Yes Yes Yes

11. On

- site Audit Travel Yes Incremental Only Yes Yes Yes

12. Desk Audits Yes Yes Incremental Only Yes Yes Yes

13. Purchase of Small Chamber

Testing Unit Yes Yes Yes

14. Quality Control Testing Yes Incremental Only Yes Yes Yes

15. Lost Product Yes Incremental Only Yes Yes Yes

16. Initial Recordkeeping Yes Yes Yes Yes

17. Recurring Recordkeeping Yes Yes Yes Yes

18. Initial Labeling Yes Yes Yes Yes Yes Yes

T his ICR uses two sets of baseline calculations because it calculates both the incremental and the total burden and cost of the

TSCA Title VI rule. The incremental burden and cost exclud es future activities that will be performed to comply with the CARB

ATCM in th e baseline. The total burden and cost includes future activities that will be performed to comply with the CARB

ATCM in the baseline. Neither includes activities that CARB compliant firms already performed in the past to meet the ATCM

requirements and th at are assumed not to be repeated in order to comply with the TSCA Title VI requirements.



## 6(a) Estimating Respondent Burden

(i) Number of Respondents

Since the rule applies to products imported into the U.S., the certification, testing,

recordkeeping, and reporting requirements also apply to entities outside the U.S. Therefore, this

analysis estimates both domestic and foreign entities. 2 

## The number of respondents is estimated

separately by sector (i.e., panel producers, fabricators, who lesalers, and retailers).

The number of domestic stock panel producers (41 stock hardwood plywood mills, 30

particleboard mills, and 22 MDF mills) is taken from EPA’s Economic Analysis for the

rulemaking, and is described in more detail there. The estim ate of foreign stock panel mills

exporting to the U.S. is based on the number of foreign mills on the CARB list of certified

mills. 3 

## To remain consistent with the Economic Analysis, which estimates that the share of

imports that is not CARB certified is l arger compared to the share of domestic production that is

2 EPA’s Economic Analysis for the rulemaking ( Economic Analysis of the Formaldehyde Standards for Composit e Wood

Products Act Implementing Regulations Proposed Rule ) does not estimate the number of foreign entities subject to the rule.

The number of domestic entities estimated here is the same as the number in the Economic Analysis.

3 California Air Resources Board 2011

.

### Page 14 of 96 

## not certified, the analysis assumes the number of foreign mills that are not currently certified

under the CARB ATCM but will seek certification under the Title VI rule as 20 percent of the

total n umber of foreign mills certified under the CARB ATCM.

The Economic Analysis for the rule estimated there are 7,486 to 13,875 domestic entities

making wood veneer laminated products. The high end estimate (13,875) is used here. Under the

rule, wood veneer laminated products are exempted from the definition of hardwood plywood if

they are made with compliant platforms and NAF resins. The Economic Analysis estimates that

most domestic laminators not already using NAF resins will switch to them so that their products

will be exempted from the definition of hardwood plywood. However, two percent of wood

veneer laminated product producers (278 entities) are assumed to continue to use added

formaldehyde resins and therefore will make products defined as h ardwood plywood. The

remaining wood veneer laminated product producers (13,597 entities) make products that will

not be defined as hardwood plywood, so these entities will be considered fabricators under the

rule. The process used to estimate the number of wood veneer laminated product producers is

described in greater detail in the Economic Analysis.

As described in the Economic Analysis for the rule, the number of domestic wholesale

and retail trade firms was estimated using employer and nonemployer data from the Census. 4



## These totals were adjusted to account for that fact that not all firms are expected to sell

composite wood products. For example, some retail stores in the Floor Covering Stores industry

(NAICS 442210) might only sell carpet and r ugs, and therefore would not be affected by the

proposed TSCA Title VI rule’s requirements. Data from the 2007 Economic Census’ Product

Lines Subject Series were used to estimate the percentage of wholesalers and retailers that sell

composite wood product s in affected industries. 5



## The numbers of foreign fabricators and wholesalers were estimated by 1) calculating the

ratio of the total customs value of imports for the affected fabricator NAICS to the total domestic

value of shipments for these NAICS and 2) applying it to the number of domestic firms in each

sector. In addition, the percentage of domestic wholesalers that import composite wood products

or articles that contain composite wood products was estimated as ratio of the customs value of

imports to the sum of the customs val ue of imports and the total domestic value of shipments.

Exhibit 6

- 3 

## presents the customs value of imports and the domestic value of shipments for the

affected industries.

4 The following NAICS are included for wholesalers: 423210, 423220, 423310, 423320, 423330, 423390, 423410, 423420,

423430, 423440, 423450, 423490, 423510, 423610, 423620, 423690, 423710, 423720, 423730, 423740, 423740, 423810,

423820, 423830, 423840, 423850, 423910, 423920, 423930, 423940, 423990, 424110, 424120, 424130, 424210, 424310,

424320, 424330, 424340, 424410, 424420, 424450, 424460, 424480, 424490, 424510, 424610, 424690, 424910, 424920,

424930, 424940, 424950, 424990.

The following NAICS are included for retailers: 441110, 441210, 441221, 441229, 441320, 442110, 442210, 442291, 442299,

443111, 443112, 443120, 443130, 444110, 444120, 444130, 444190, 444210, 444220, 445110, 445120, 445210, 445220,

44523 0, 445291, 445292, 445299, 445310, 446110, 446120, 446130, 446191, 446199, 447110, 447190, 448110, 448120,

448130, 448140, 448150, 448190, 448210, 448310, 448320, 451110, 451120, 451130, 451140, 451211, 451212, 451220,

452111, 452112, 452910, 452990, 45311 0, 453210, 453220, 453910, 453920, 453930, 453991, 453998, 454111, 454113,

454210, 454311, 454312, 454390.

5 U.S. Census Bureau 2010a

, 2011

.

### Page 15 of 96 Exhibit 6

- 3 : Customs Value of Imports and Domestic Value of Shipments, by NAICS (millions,

2010$)

NAICS Description Customs

Value of

Imports Domestic

Value of

Shipments Sum of

Imports and

Domestic

Shipme nts

321211 Hardwood veneer and plywood manufacturing $1,516 $3,327 $4,843

321219 Reconstituted wood product manufacturing $1,502 $6,721 $8,223

321911 Wood window and door manufacturing $491 $14,161 $14,653

321918 Other millwork (including flooring) $770 $7,483 $8,254

321991 Manufactured home (mobile home) manufacturing $2 $6,086 $6,089

321992 Prefabricated wood building manufacturing $50 $4,215 $4,265

321999 All other miscellaneous wood product manufacturing $1,927 $6,058 $7,984

336213 Motor home manufacturing $117 $5,779 $5,896

336214 Travel trailer and camper manufacturing $537 $10,641 $11,178

337110 Wood kitchen cabinet and countertop manufacturing $491 $18,658 $19,149

337121 Upholstered household furniture manufacturing $2,898 $11,269 $14,166

337122 Nonupholstered wood household furniture manufacturing

- - -

337124 Metal household furniture manufacturing $2,708 $2,393 $5,101

337127 Institutional furniture manufacturing $12,133 $5,799 $17,932

337129 Wood television, radio, and sewing machine cabinet manufacturing $4 $407 $411

337211 Wood office furniture manufacturing $697 $2,904 $3,601

337212 Custom architectural woodwork and millwork manufacturing

- - -

337214 Office furniture (except wood) manufacturing $410 $8,978 $9,388

337215 Showcase, partition, shelving, and locker manufacturing $4,283 $7,873 $12,156

339920 Sporting and athletic goods manufacturing $6,260 $12,510 $18,770

339932 Game, toy, and children's vehicle manufacturing $21,428 $2,712 $24,140

339950 Sign manufacturing $184 $13,003 $13,187

339992 Musical instrument manufacturing $1,190 $1,796 $2,986

Total $59,598 $152,772 $212,370

Ratio of Customs Value of Imports Domestic Shipments 39%

Ratio of Customs Value of Imports to Sum of Imports and Domestic Shipments 28%

Sources: U.S. Census Bureau 2010b

, U.S. International Trade Commission 2011



## As indicated in Exhibit 6

- 3 

## . imports are 39.0 percent of the U.S. value of shipments for

these goods. Therefore, as shown in Exhibit 6

- 4 , it is assumed that there are 39.0 percent as

many foreign fabricators that export products to the U.S. as there are domestic fabricators

(31,083 foreign fabricators compared to 79,701 domestic fabricators). Similarly, it is assum ed

that there are 39 percent as many foreign wholesalers that export composite wood products or

goods containing composite wood products to the U.S. as there are domestic wholesalers that are

subject to the rule (33,368 foreign wholesalers compared to 85,5 60 domestic wholesalers). The

analysis assumes that composite wood products and goods containing composite wood products

are generally exported to the United States by panel producers, fabricators, or wholesalers. Few

foreign retailers are assumed to exp ort composite wood products directly to the U.S., so the

analysis does not estimate that number.

The number of wholesalers that import composite wood products is assumed to be

proportional to the ratio of the value of imports of composite wood products to the sum of the

total import and domestic shipment values. As shown in Exhibit 6

- 3 imports represent 28

percent of the value of imports and domestic shipments. Thus, it is estimated that 28 percent of

wholesalers are importers of composite wood pr oducts. This results in an estimate that 23,957 of

the 85,560 domestic wholesalers import composite wood products. Since the number of

### Page 16 of 96 

## wholesalers that import products is estimated using the total customs value of imports (which

reflects imports by all s ectors), to the extent that some products are imported directly by retailers,

the number of such retailers (and their recordkeeping burden) would be reflected in the

wholesaler estimate. And to the extent that some fabricators import composite wood produc ts

directly, the estimated total recordkeeping burden may be overstated (since the recordkeeping

burden for fabricators is estimated separately).

Exhibit 6

- 4 : Summary of Respondents, by Sector and Geographic Location

Sector Domestic

Respondents Foreign

Respondents 1 Total

Respondents

Composite Panel Producers (Mills)

Stock Panel Mills

Stock Hardwood Plywood 41 538 579

Particleboard 30 209 239

MDF 22 274 296

Wood Veneer Laminated Product Producers

(Classified as making Hardwood Plywood) 2 277 108 385

Total Composite Panel Producers 370 1,129 1,499

Fabricators (Firms)

Wood Veneer Laminated Product Producers

(Classified as Fabricators) 13,598 5,303 18,901

Other Fabricators 66,103 25,780 91,883

Total Fabricators 79,701 31,083 110,784

Wholesalers (Firms)

Wholesalers that import 23,957

--- 23,957

Wholesalers that do not import 61,603

--- 61,603

Total Wholesalers 85,560 33,368 118,928

Retailers(Firms) 3 759,048 0 759,048

Total 924,679 65,580 990,259

Notes: 1. The numbers of foreign fabricators and wholesalers were estimated by 1) calculating the ratio of the total

customs value of imports for the affected fabricator NAICS to the total domestic value of shipments for these NAICS

(which is 39 percent) a nd 2) applying it to the number of domestic firms in each sector. The analysis assumes that

foreign retailers do not typically export composite wood products or goods containing composite wood products into the

United States. To remain consistent with th e Economic Analysis, which assumes that there is uncertified product being

imported into the U.S., the analysis assumes that the number of certified foreign mills is 20 percent of the total number of

certified mills.

2. These are laminators that are assumed to continue using added formaldehyde resins after the rule is implemented. It is

also assumed that all wood veneer laminated product producers are single

- establishment firms.

3. The analysis assumes that foreign retailers do not typically export c omposite wood products or goods containing

composite wood products into the United States.

Sources: California Air Resources Board 2011

, Composite Panel Association 2011

, U.S. Census Bureau

2009

, 2010a

, b

, c

, d

, e

, f

, g

, h

, 2011

, U.S. International Trade Commission 2011



## As indicated in Exhibit 6

- 4 , there are an estimated total of 990,259 domestic and foreign

respondents. Domestic respondents account for an estimated 93.4 percent of the total. Retailers

account for t he largest proportion of the total respondents (76.7 percent). Wholesalers,

fabricators, and composite panel producers account for approximately 12.0 percent, 11.2 percent,

and 0.2 percent of the total number of respondents, respectively.

(ii) Burden P er Respondent

This section describes the per

- activity recordkeeping and reporting burden for

respondents as a result of the proposed TSCA Title VI rule. Where s ome TPCs have more

stringent requirements than the proposed TSCA Title VI rule require s, the analysis is based on

### Page 17 of 96 

## the TPC requirements . For example, HPVA requires mills to have on

- site audits and large

chamber tests annually for NAF

- certified products, and quarterly for ULEF

- certified products,

which is more frequently than the CARB ATCM o r the proposed TSCA Title VI rule require.

T herefore t his analysis estimates the burden and cost estimates for mills based on the

requirements frequently imposed by TPCs, rather than the requirements in the CARB ATCM or

the proposed TSCA Title VI rule s

. Exhibit 6

- 5 summarizes the differences between how TPCs

are assumed to implement a standard certification and a certification with an NAF or ULEF

exemp tion.

Exhibit 6

- 5 : Testing and Certification Frequencies Assumed to be Implemented by TPCs

Category Standard NAF ULEF

Certification Fee Annual Annual (reduced fee after first

year) Annual (reduced fee after first

year)

Qualifying Testing One

- time One

- time One

- time

TPC Audit Quarterly Twice initially and annually

thereafter Twice initially and annually

thereafter

TPC Audit Travel First audit each year Annual Annual

Large Chamber TPC

Testing Quarterly Once initially and annually

thereafter Once initially and quarterly

thereafter

QC Testing On

- going First 3 months and exempt

thereafter First 6 months and exempt or

reduced thereafter

Desk Audit Monthly (excludes

audit months) First 2 months and exempt

thereafter First 4 months and exempt

thereafter



## Respondent activities are presented separately for each unique combination of (1)

responses per respondent and (2) per

- response burden that is accounted for in this analysis. For

example, while composite panel producers with a standard certification are required to have an

on

- site audit performed quarterly, those with ULEF or NAF certification receive two audits in

the first year and then are audited annually thereafter

. 6 

## As a result, even though these audits are

assumed to take the same amount of time for all producers (four managerial

- level hours), they

are presented as separate activities because they require a different number of annual responses,

depending on the certification type. The section begins with a descrip tion of activities that are

common to all respondents, and then separately discusses the activities by category of

respondents (composite panel producers, fabricators, wholesalers, and retailers).

This section also describes the process used to estimate the number of respondents in

each activity group. Note that the number of foreign respondents in each activity group is

estimated by 1) calculating the sector

- specific ratio of domestic respondents by certification type

to the total domestic respondents in that sector; 2) applying the ratio to the estimated number of

foreign respondents in the sector; and, 3) taking the sum of the rounded estimates across all

affected sectors. For example, this analysis assumes that 7 of the 41 domestic hardwood

plywood respondents (or 17

. 1 percent) are currently NAF certified under CARB and will

6 

### This is an example where the TPC requirements are more stringent than the regulatory requirements.

### Page 18 of 96 

## maintain NAF certification under the TSCA Title VI rule. As a result, it is assumed that 76

foreign hardwood plywood respondents ( 17.1 percent of the 448 foreign hardwood plywo od

mills with current CARB certification ) are currently NAF certified under CARB and will

maintain NAF certification under the TSCA Title VI rule

.

(A). All Respondents

The burden associated with rule familiarization is presented first because this activity is

common to all respondents. Composite panel producers are presented separately from the other

respondent types because they are subject to testing and certification requirements unique to their

sector. Since wood veneer laminated product produ cers will be defined as either hardwood

plywood manufacturers or fabricators under the proposed rule (depending on the resin they use),

they are discussed within the context of these respondent types.

Rule Familiarization (Activity #1)

All entities will need to familiarize themselves with the proposed regulation and either

ensure that their current systems are sufficient for the requirements or identify necessary

changes. The analysis assumes that all respondents will spend an average o f 4.0 managerial

labor hours on rule familiarization. This one

- time burden is incurred during the first year.

(B). Composite Panel Producers

In addition to rule familiarization, composite panel producers will also spend time on

testing and certificati on, recordkeeping, and labeling activities. This analysis assumes that mills

making product lines that are certified under the CARB ATCM will not need to submit new data

or resubmit existing data to their existing TPC in order to receive the equivalent ce rtification

under the TSCA Title VI regulations. Thus, this ICR does not include burdens and costs for

these reporting and recordkeeping activities where it is assumed the activities were already

performed to comply with the CARB ATCM and will not need to be performed again. This is

consistent with the methodology used in the Economic Analysis for the proposed rule. However,

this ICR does include the burdens and costs of required activities that will continue to be

performed under the TSCA Title VI rule, even if those activities would be performed regardless

of the TSCA rule (i.e., to comply with the CARB ATCM). This is different from the

methodology in the Economic Analysis for the proposed rule, where the baseline included

activities performed to compl y with the CARB ATCM. As a result, the Economic Analysis

excluded the costs of activities that would be performed even without the TSCA rule.

In addition, this analysis assumes that two percent of wood veneer laminated product

producers will continue to use added formaldehyde resins and thus be classified as hardwood

plywood producers. Since laminators are not certified under the CARB ATCM, these producers

will incur additional costs due to the TSCA Title VI rule.

TSCA Title VI requires panel produ cers to perform formaldehyde emission testing on

their composite wood products and obtain and maintain certification from an accredited TPC.

Panel producers must undergo qualifying tests at a TPC lab, obtain an on

- site audit from a TPC,

### Page 19 of 96 

## implement quality control systems, and train quality control employees in order to receive initial

certification. Once a TPC certifies a panel producer, that producer is required to conduct on

going small scale quality control testing, submit monthly reports to the TPC, an d receive

quarterly on

- site audits and large scale testing to maintain its certified status. Panel producers

that make products with ULEF or NAF resins and meet more stringent emissions limits may

apply for exemptions from some of the on

- going testing req uirements.

NAF certification can be achieved by performing three months of routine small scale

testing and one quarterly primary or secondary method test at the TPC. ULEF certification can

be achieved by performing six months of routine small scale test ing and one quarterly primary or

secondary method test at the TPC. Product lines approved for ULEF or NAF certification are

regulatorily exempt from routine small scale testing and quarterly primary or secondary method

TPC testing for two years, after whic h point the mill may reapply for a ULEF or NAF

certification by submitting the results of at least one primary or secondary method test

. H owever, because some TPC requirements are more stringent than the rule, this analysis

assumes that ULEF product line s will receive quarterly TPC testing, and that ULEF and NAF

certified mills will undertake a TPC audit annually. Where the frequency of testing is different

for composite panel producers with ULEF, NAF and standard certification, these groups are

presented separately.

Initial On

- site Audit (Activity #3)

Prior to certification, the TPC is expected to make at least one trip to the mill to inspect

the mill’s quality control systems and employees. During the initial visit, the TPC will assist the

mill in s etting up quality control systems, including the small scale testing facility, if applicable,

and methods for selecting samples. Audits typically do not take more than one day of travel and

visitation, though if the mill requires a substantial number of m odifications or is unprepared, the

duration of the visit may be longer. 7 

## This analysis assumes that a managerial

- level employee

will be present for eight hours during the initial on

- site audit of mills. It is assumed that the

initial quality control audit (see below) is sufficient for mills with existing CARB certifications.

Quality Control Systems Development (Activity #4)

Mills are required to implement quality control procedures to ensure that all certified

products consistently meet the applicable emissions standards. In addition, mills are required to

designate a quality control manager and quality control employees, if needed. The quality

control manager must have adequate training or experience to handle all quality control

procedures, including on

- site testing and shipping samples for TPC testing. All quality control

procedures and designated quality control personn el must be identified in a quality control

manual. Prior to the mill’s initial certification, the TPC will assist mills in developing and

documenting appropriate quality control procedures. In some cases, the mill’s resin supplier will

also help to train quality control employees and develop quality control procedures.

Based on conversations with CPA, HPVA, and composite wood manufacturers, it is

assumed that training, implementing quality control systems, and developing the quality control

7 Personal Communica tion with HPVA 2011

.

### Page 20 of 96 

## manual co uld take between one and five days to complete, depending on the mill’s existing

quality control systems. HPVA and CPA noted that smaller mills often do not have quality

control systems in place and that developing these systems can be a time

- consuming pr ocess.

This analysis assumes that a managerial

- level employee will spend forty hours training,

becoming familiarized with the testing and certification requirements, writing the quality control

manual, and setting up quality control systems and testing pr ocedures. It also assumes that mills

with existing certifications will have quality control systems in place and so will not need to

spend time on these activities.

Qualifying Test (Activities #5 and #6)

Composite panel producers are required to obta in five qualifying tests for each product

type (e.g., veneer core hardwood plywood) and production line for which certification is sought.

A TPC employee must select and mark the panels to be tested during the initial mill audit, with

at least one panel b eing selected for each test. After panel selection has occurred, the mill must

ship the marked panels to the TPC for large scale testing. 8 

## Results from the five large chamber

tests must not exceed the emission standards for each product type and producti on line. Mills are

expected to ship at least five 4’ x 8’ panels for each product type via a commercial shipping

carrier. Panels must be dead

- stacked (i.e., having no layers between panels), bundled air

- tight,

wrapped in polyethylene, and protected by co ver sheets. The analysis assumes that it will take a

managerial

- level employee half an hour to prepare the panels for shipping. Producers that are

already CARB compliant and are not expected to adopt a more stringent certification type thus

will not incu r this burden.

Quality Control Audits (Activities #8 and #11)

After certification has been granted, the TPC is obligated to perform an on

- site audit at

least once quarterly, unless the mill obtains ULEF or NAF certification. TPCs may also conduct

peri odic “desk audits,” which are quality control checks performed over the phone in which the

mill’s small scale testing procedures and data are reviewed. Desk audits are assumed to occur

monthly, except in months with quarterly on

- site audits. This analysi s assumes that a

managerial

- level employee will be present for four hours for every on

- site quality control audit,

and one hour for each desk audit.

This analysis assumes that producers with new NAF certifications will incur the burden

associated with o ne on

- site audit (in addition to the initial audit) and two desk audits in the first

year. The initial on

- site audit is assumed to be sufficient for producers with existing ULEF and

NAF certifications. All ULEF and NAF

- certified producers will have one o n

- site audit annually

thereafter.

Quality Control Testing (Activity #14)

Mills must also perform on

- going quality control testing on the applicable products.

8 Large scale testing can be performed using either the primary test method or an equivalent secondary test method; however,

this analysis assumes that all qualifying testing is performed using the primary test method. The primary method for

formaldehyde testing is the large chamber test, as defined by ASTM International Standard E1333.

### Page 21 of 96 

## Quality control testing is typically performed using a small chamber test (ASTM D6007) or

desi ccator test (ASTM D5582). These tests require smaller test samples and can be conducted at

the TPC facility or on

- site at a TPC

- approved lab at the composite wood mill. The TPC must

develop a statistical correlation between the large scale and small scal e test methods using a

minimum of five data pairs. It is assumed that mills will need to obtain all five data pairs during

qualifying testing, though it is possible that some mills may be able to use previous test results or

data obtained from the resin m anufacturer. Each large chamber test requires results from one

small chamber test or three desiccator tests to calculate the correlation. This analysis assumes

that the TPC will perform desiccator testing for half of the mills and small chamber testing f or

the other half during qualification when small scale testing is performed at the TPC. Thus, if the

TPC performs 5 large chamber tests, it would also perform either 15 desiccator tests or 5 small

chamber tests.

Mills have the option of constructing an on

- site lab and having it approved by a TPC, or

contracting a certified third

- party lab to perform small scale quality control testing. The decision

to perform on

- site testing is dependent on the relative costs of building and running an on

- site

lab, and the fees and shipping costs associated with hiring a third

- party lab. According to CPA

and HPVA, particleboard and MDF mills already have their own on

- site labs to test for

formaldehyde (because they have to test their products on a daily basis under the CARB ATCM),

while most smaller hardwood plywood mills pay their TPC to conduct their quality control

testing. (In part because hardwood plywood mills often use ULEF or NAF resins to qualify for

exemptions from some of the on

- going testing requirements un der the CARB ATCM.) However,

the CARB ATCM allows mills to ship panels from certified product lines before test results are

available. By contrast, the proposed TSCA VI rule requires mills to wait until test results

indicate that the emissions standards h ave been met before shipping a lot that has been tested. It

is uncertain how often mills currently ship product from a lot being tested before the test results

are available and therefore it is uncertain how mills will choose to comply with this requireme nt.

It may be the case that some mills normally maintain a level of inventory where they would

typically not ship any panels before test results have been determined for that lot, but other mills

may ship out panels on the same day they are produced. Thi s analysis assumes that all mills that

have not already done so will opt to set up and operate a quality control testing facility on

- site, in

order to minimize the time spent waiting for test results, and to maximize their flexibility to ship

out panels sh ortly after they have been produced. (Assuming that mills conduct on

- site testing

may overstate the costs of this requirement if some mills find it more cost effective to hold

products in inventory until test results have been determined by an outside lab .) Producers that

are already CARB compliant and are not expected to adopt a more stringent certification type

(e.g., NAF) will not need to perform correlation testing.

The frequency of small scale testing without ULEF or NAF certification depends on t he

product type and other factors. For hardwood plywood producers, the frequency of testing

depends upon the volume of hardwood plywood produced weekly at each plant. Plants

producing less than 100 thousand square feet (msf) per week are required to test once per 100

msf. Plants producing between 100 msf and 200 thousand square feet (msf) per week are

required to test once, plants producing between 200 msf and 400 msf per week are required to

test twice per week, and those producing greater than 400 msf per week are required to test four

times per week. Particleboard and MDF producers must test samples at least once per eight or

### Page 22 of 96 

## twelve hour shift, but this frequency may be reduced to one test per forty

- eight hours if the plant

or production line has show n consistent operations and low variability of test results. This

analysis makes the simplifying assumption that all producers will test each production line once

daily. This results in a conservative estimate of the burden and cost of quality control t esting for

hardwood plywood producers. It is assumed that the quality control manager will spend two

hours each day performing routine quality control testing.

As previously stated, composite panel producers need to perform 3 months of routine

small s cale testing to become NAF certified. As a result, it is assumed that new NAF producers

will perform 65 daily quality control tests (assuming that the plants are in operation 5 days per

week). It is assumed that producers with existing ULEF or NAF certif ications will not incur the

burden associated with initial quality control testing. ULEF and NAF certified producers will

not incur any additional burden associated with quality control testing in subsequent years. Note

that the numbers of quality control testing responses are presented at the product line level; as a

result, the per

- response burdens have been modified accordingly.

Recurring Recordkeeping (Activity #17)

Panel producers are assumed to incur an average labor burden of one hour of managerial

labor per week (equivalent to $3,710.72 per year) to maintain the following records for 3 years:

• Records of quarterly emission testing and quality control testing that identify the

accredited third

- party certifier conducting or overseeing the testing and the

laboratory or quality control facility actually performing the testing. These

records must also include the date, the product type tested, the lot or batch number

t hat the tested material represents, the test method used, and the test results;

• Production records, including a description of the composite wood product(s), the

date of manufacture, lot or batch numbers, the amount of resin use by volume and

weight, th e resin trade name, resin manufacturer and supplier contact information,

and tracking information allowing each product to be traced to a specific lot

number or batch produced;

• Records demonstrating initial and continued eligibility for the reduced testin g

provisions for products made with ultra

- low formaldehyde or no

- added

formaldehyde

- based resins, if applicable;

• Records of changes in production, including changes in resin use, resin

composition, and changes in the process, such as changes in press t ime;

• Purchaser information for each composite wood product, if applicable, including

the name, contact person, address, phone number, e

- mail address if available,

purchase order or invoice number, and amount purchased;

• Transporter information for each composite wood product, if applicable,

including name, contact person, address, phone number, e

- mail address if

available, and shipping invoice number;

• Information on the disposition of non

- complying lots, including product type and

amount of composite wood products affected, lot or batch numbers, mitigation

measures used, results of retesting, and final disposition;

• Copies of labels used;

### Page 23 of 96 

## • Panel producers are required to maintain an up

- to

- date quality control manual on

their premises; and

• Panel pro ducers are required to maintain the credentials of their quality control

managers and quality control employees for as long as employees are serving in a

quality control capacity.

Initial Labeling (Activity #18)

It is assumed that panel producers, for w hom product labeling is a customary business

practice, will incur the incremental costs of 6 hours of clerical labor for changing their labels

twice. They may need to change their labels once before the effective date of the rule (to

indicate that the pan els were produced before that date if they are to be sold after the rule goes

into effect) and again after their product lines are certified.

To remain consistent with the Economic Analysis, wood veneer laminated product

producers defined as hardwood p lywood producers are assumed to incur the same burden as the

fabricators who are assumed to incur more substantial initial labeling costs (an average of 100

hours of technical labor) (see below).

(C) Fabricators

While all fabricators will incur the burden associated with rule familiarization, only a

fraction will incur the additional burdens associated with recordkeeping and labeling. This is

because 1) many fabricators are already complying with similar requirements in the CARB

ATCM because the pro ducts they make are sold in California, and 2) many fabricators’ existing

recordkeeping and labeling systems are expected to be sufficient to meet the proposed rule’s

requirements without any significant modifications.

All fabricators are required to label their products with their name, the date the finished

good was produced, and a statement of compliance. Fabricators are also required to take

“reasonable precautions” to ensure that the composite wood products and fin ished goods they

acquire are in compliance with the applicable emission standards. This includes keeping records

showing the date of purchase, the supplier, as well as all precautions taken to ensure that the

product meets emissions standards. These reco rds must be kept for three years.

Baseline Compliance for Fabricators

The baseline level of compliance for most fabricators was determined based on

conversations with industry associations. 9 

## However, baseline compliance for some industries

was estimat ed simply as the number of establishments located in California divided by the total

number of U.S. establishments in each industry. Exhibit 6

- 6 prese nts the estimated baseline

CARB compliance levels for fabricator industries. The baseline CARB compliance category

represents the percent of fabricators estimated to be selling their products in California, and thus

using certified panels and complying wi th the recordkeeping requirements. Additional details

9 Conversations with industry represented informed assumptions for the following fabricator NAICS codes: 321211, 321219,

337110, 337129, 321911, 337121, 337122, 337127, 337211, 337214, 337215, 336213, and 336214.

### Page 24 of 96 

## are provided in the Economic Analysis for the rulemaking.

Exhibit 6

- 6 : Baseline CARB Compliance of Fabricator Industries

NAICS NAICS Definition Baseline CARB

Compliance a

321211 b Hardwood Veneer and Plywood Manufacturing 100%

321219 b Reconstituted Wood Product Manufacturing 100%

337110 b Wood Kitchen Cabinet and Countertop Manufacturing 50%

337129 b Wood Television, Radio, and Sewing Machine Cabinet Manufacturing 50%

321911 b Wood Window and Door Manufacturing 100%

337121 b Upholstered House Furniture Manufacturing 100%

337122 b Non

- upholstered Wood Household Furniture Manufacturing 100%

337124 b Metal Household Furniture Manufacturing 100%

337127 b Institutional Furniture Manufacturing 100%

337211 b Wood Office Furniture Manufacturing 100%

337214 b Office Furniture (except Wood) Manufacturing 100%

337215 b Showcase, Partition, Shelving, and Locker Manufacturing 100%

321918 c Other Millwork (including Flooring) 9.23%

337212 c Custom Architectural Woodwork and Millwork 9.83%

321999 c All Other Miscellaneous Wood Product Manufacturing 7.84%

336213 c Motor Home Manufacturing 100%

336214 c Travel Trailer and Camper 100%

321991 c Manufactured Home (Mobile Home) Manufacturing 10.90%

321992 c Prefabricated Building Manufacturing 5.92%

339950 c Sign Manufacturing 10.09%

Notes: a. Baseline CARB compliance represents the percent of fabricators estimated to be selling their products in California

, and thus using certified panels and complying with the recordkeeping requirements.

b. Assumptions based on conversations with industry associations.

c. Estimated as the percentage of establishments in CA.

Sources: U.S. Census Bureau 2009

, 2010i



## Fabricators incurring Recordkeeping and Labeling Costs

The proposed recordkeeping and labeling requirements under the TSCA Title VI rule are

similar to the requirements under the CARB ATCM. As a result, firms that manufacture or sell

composite wood products destined for California markets have experience implementing

recordkeeping and labeling requirements that are similar to the proposed TSCA Title VI rule. To

learn about the experiences of the firms who are complying with the CARB ATCM

requirements, two questionnaires (one for fabricators and one for wholesalers) were administered

to fewer than ten respondents per questionnaire. 10 

## These questionnaires aske d respondents for

descriptions of the changes they made and the costs they incurred to implement any changes.

This information is described in detail in the Economic Analysis, and is summarized below.

Nine fabricator firms were administered telephone qu estionnaires that asked about the

changes that were made and the costs that were incurred in order to achieve compliance with the

CARB recordkeeping and labeling requirements. Based on the questionnaire results, most

fabricators are not estimated to incur initial costs for recordkeeping, because their existing

recordkeeping systems are adequate and do not need to be modified to comply with the TSCA

10 Retailers are also subject to the chain of custody and recordkeeping requirements. The California Retailers Association

indicated that retailers’ customary business practices were gener ally sufficient to meet the chain of custody requirements in the

CARB ATCM ( Personal Communication with CRA 2011 ), so retailers were not administered a questionnaire.

### Page 25 of 96 

## Title VI requirements. It is estimated that 11 percent of the fabricators that are not currently

complying wi th the CARB ATCM because their products are not sold in California will incur

additional recurring recordkeeping costs.

The fabricator questionnaire respondent that reported incurring recurring recordkeeping

costs indicated that their recurring recordk eeping burden associated with the CARB ATCM was

about 10 hours per week (equivalent to 520 hours per year), which this analysis estimates to be

about $12,917 per year. However, the burden reported by this fabricator questionnaire

respondent seems unlikely to be representative for all the fabricator firms that incur a recurring

recordkeeping burden. This fabricator questionnaire respondent was a firm with employees, but

smaller firms, such as nonemployer firms, are likely to need much less time than 10 hou rs per

week (about a quarter of a 40 hour work week) to perform the necessary recordkeeping activities.

Since the recordkeeping requirements entail keeping track of composite wood materials

purchased and shipments that contain composite wood products, it is expected that the burden

associated with keeping records will typically increase with the volume of a fabricator’s sales.

Thus, to estimate the recurring recordkeeping burden for nonemployer fabricators, the analysis

assumes that there is a fixed

- cost component of the recurring recordkeeping costs associated with

two hours of labor and a variable cost component that is proportional to a firm’s revenue. It is

assumed that fabricators will use clerical staff to perform these activities.

For employer firms, the average recurring recordkeeping burden is estimated as 520

hours per year (based on 2 hours of fixed cost labor, with the remaining hours of variable cost

labor). For nonemployer firms, the variable cost component is calculated by subtracting t he two

hours of fixed cost labor (at a cost of $49.68) from the total reported cost ($12,917) and then

dividing by the estimated average revenue for affected employer fabricators ($4,241,245). The

resulting variable cost component (0.30338 percent of reve nue) is multiplied by average

nonemployer revenues ($42,690) and results in recurring recordkeeping costs of $179.19, or

approximately 7.21 labor hours per year.

Several of the respondents indicated that they already had labeling systems in place and

therefore they did not incur any significant costs associated with CARB’s labeling requirements.

However, this analysis assumes that these firms did in fact incur small costs associated with

making small changes to their labels. One of the firms that did report minor labeling costs

reported that it took “a few hours” to change over to using the new labels. The analysis assumes

that “a few hours” is 3 hours for the purpose of estimating costs. The analysis also assumes that

67 percent of firms that are n ot already complying with the CARB ATCM, and all firms that are

already complying with the CARB ATCM, incur the costs associated with 3 labor hours. 11 

## Two

other firms that responded to the questionnaire reported more substantial costs associated with

setti ng up their labeling systems and therefore, it is assumed that the remaining 33 percent of

firms that are not already complying with the CARB ATCM will incur the average burden

reported by these two firms (100 hours). 12 

## It is assumed that fabricators will use technical labor

to perform these activities. Since none of the fabricator respondents reported any recurring costs

for labeling, no recurring labeling costs are estimated.

11 67 percent is calculated as 4/6 since 4 of the 6 firms that reported l abeling their products are assumed to have these costs.

12 33 percent is calculated as 2/6 since 6 firms reported that they labeled their product.

### Page 26 of 96 

## (D). Wholesalers

While all wholesalers will incur the burden associated with rule familiarization, only a

fraction will incur incremental burdens associated with recordkeeping and labeling. As with

fabricators, this is because 1) many wholesalers are already complying with the CARB ATCM

because they handle products that are u ltimately sold in California, and 2) many wholesalers’

existing recordkeeping systems are expected to meet the proposed rule’s requirements without

any significant modifications. Like fabricators, wholesalers who import composite wood

products are require d to take “reasonable precautions” to ensure that the composite wood

products and finished goods they acquire are in compliance with the applicable emission

standards. These records must be kept for three years.

Wholesalers that are defined as manufactu rers under TSCA (because they import,

produce, or manufacture composite wood panels, component parts, or finished goods) must keep

records showing the date of purchase, the supplier, and all precautions taken to ensure that the

product meets the emissions standards. Wholesalers that are not defined as manufacturers under

TSCA (because they do not import such products) must keep invoices and bills of lading. Most

wholesalers are likely to keep invoices and bills of lading as part of their customary busines s

practices. 13 

## Therefore the requirement to keep invoices and bills of lading is not assumed to

impose any additional burden on wholesalers that do not import products. 14



## Baseline Compliance for Wholesalers

This analysis assumes that wholesale firms with establishments in California are

complying with the recordkeeping requirements of the CARB ATCM and therefore would not

incur the burden associated with some of the proposed rule’s requirements. Because data on the

number of firms with at least one e stablishment in California are not available, the following

steps must be taken to estimate baseline compliance for each affected industry: (1) use 2007

Economic Census data to identify the number of affected wholesale firms 15 

## (2) estimate the

number of sin gle

- unit firms in California; (3) estimate the number of multi

- unit firms with at

least one establishment in California; and (4) estimate baseline compliance as the percentage of

U.S. firms with at least one establishment in California. Note that this app roach may lead to an

understatement of the level of baseline compliance among wholesalers because they may sell

products in states where they do not have physical locations. In addition, two wholesale

industries

-- Furniture Merchant Wholesalers (423210) and Home Furnishing Merchant

Wholesalers (423220)

-- are assumed to be fully compliant with the CARB ATCM chain of

custody requirements in the baseline. 16 

## Exhibit 6

- 7 presents a summary of the baseline

compliance estimates for wholesale industries. The Economic Analysis for the rule provides a

detailed description of the baseline calculations.

13 For example, the Internal Revenue Service ( U.S. Internal Revenue Service 2007 ) recommends that firms keep invoices in

order to document their assets, expenses, gross receipts, and purchases.

14 While wholesalers that do not import composite wood products are assumed to meet the proposed rule’s recordkeeping

requirements with documents kept as part of their customary business practices, these firms do count toward the respondent

and response total s in Exhibit 6

- 9 through Exhibit 6

- 14

. 15 U.S. Census Bureau 2009

, 2010d

, j

. 16 Personal Communication with AHFA 2010

, Personal Communication with BIFMA 2010

.

### Page 27 of 96 Exhibit 6

- 7 : Baseline CARB Com pliance of Wholesale Industries

NAICS NAICS Description Baseline

CARB Compliance a

423210 b Furniture merchant wholesalers 100%

423220 b Home furnishing merchant wholesalers 100%

423310 Lumber, plywood, millwork, and wood panel merchant wholesalers 12.3%

423320 Brick, stone, and related construction material merchant wholesalers 14.9%

423330 Roofing, siding, and insulation material merchant wholesalers 13.7%

423390 Other construction material merchant wholesalers 14.6%

423410 Photographic equipment and supplies merchant wholesalers 24.8%

423420 Office equipment merchant wholesalers 18.1%

423430 Computer and software merchant wholesalers 23.9%

423440 Other commercial equipment merchant wholesalers 13.0%

423450 Medical equipment merchant wholesalers 15.9%

423490 Other professional equipment and supplies merchant wholesalers 14.8%

423510 Metal service centers and other metal merchant wholesalers 15.1%

423610 Elec. equip. and wiring merchant wholesalers 19.3%

423620 Electric appliance merchant wholesalers 25.2%

423690 Other electronic parts and equipment merchant wholesalers 26.1%

423710 Hardware merchant wholesalers 19.4%

423720 Plumbing equip. merchant wholesalers 18.8%

423730 HVAC equip. merchant wholesalers 14.5%

423740 Refrigeration equipment and supplies merchant wholesalers 22.2%

423810 Construction equipment merchant wholesalers 11.4%

423820 Farm and garden machinery and equipment merchant wholesalers 9.5%

423830 Industrial machinery and equipment merchant wholesalers 12.3%

423840 Industrial supplies merchant wholesalers 16.2%

423850 Service establishment equipment and supplies merchant wholesalers 9.9%

423910 Sporting and recreational goods and supplies merchant wholesalers 21.1%

423920 Toy and hobby goods and supplies merchant wholesalers 30.5%

423930 Recyclable material merchant wholesalers 13.3%

423940 Jewelry merchant wholesalers 19.6%

423990 Other miscellaneous durable goods merchant wholesalers 17.9%

424110 Printing and writing paper merchant wholesalers 17.8%

424120 Stationery and office supplies merchant wholesalers 15.1%

424130 Industrial and personal service paper merchant wholesalers 17.2%

424210 Drugs and druggists' sundries merchant wholesalers 21.7%

424310 Piece goods, notions, and other dry goods merchant wholesalers 29.6%

424320 Men's and boys' clothing and furnishings merchant wholesalers 24.6%

424330 Women's and children's clothing merchant wholesalers 32.0%

424340 Footwear merchant wholesalers 33.1%

424410 General line grocery merchant wholesalers 19.7%

424420 Packaged frozen food merchant wholesalers 19.6%

424450 Confectionery merchant wholesalers 15.1%

424460 Fish and seafood merchant wholesalers 12.3%

424480 Fresh fruit and vegetable merchant wholesalers 23.2%

424490 Other grocery and related products merchant wholesalers 18.8%

424510 Grain and field bean merchant wholesalers 5.2%

424610 Plastics materials and basic forms and shapes merchant wholesaler 18.1%

424690 Other chemical and allied products merchant wholesalers 13.6%

424910 Farm supplies merchant wholesalers 13.1%

424920 Book, periodical, and newspaper merchant wholesalers 16.4%

424930 Flower, nursery stock, & florists' supplies merchant wholesalers 17.9%

424940 Tobacco and tobacco product merchant wholesalers 8.1%

424950 Paint, varnish, and supplies merchant wholesalers 18.0%

424990 Other miscellaneous nondurable goods merchant wholesalers 24.4%

Notes: a. Baseline CARB compliance represents the percent of wholesalers estimated to be selling their products in California,

and thus complying with the recordkeeping requirements.

b. Two wholesale industries, Furniture Merchant Wholesalers (423210) and Home Furnishing Merchant Wholesalers

### Page 28 of 96 Exhibit 6

- 7 : Baseline CARB Com pliance of Wholesale Industries

NAICS NAICS Description Baseline

CARB Compliance a

(423220) are assumed to be fully compliant with the CARB ATCM chain of custody requirements in the baseline, based on

conversation with industry ( Personal Communication with AHFA 2010

, Personal Communication with BIFMA 2010 ).

Sources: U.S. Census Bureau 2010d

, j



## Wholesalers incurring Recordkeeping and Labeling Costs

Seven wholesale firms were administered telephone questionnaires that asked about the

changes that were made and the costs that were incurred in order to achieve compliance with the

CARB recordkeeping and labeling requirements. The questionnaire and the c alculation of

recordkeeping costs are described in detail in the Economic Analysis, and are summarized

below.

Based on the questionnaire responses, this analysis assumes that 57 percent of

wholesalers that import composite wood products and/or articles that contain composite wood

products will incur initial recordkeeping costs associated with 59.15 labor hours. 17 

## As indicated

above, this analysis estimates that 28 percent of domestic wholesalers import composite wood

products and/or articles tha t contain composite wood products. In addition, the analysis assumes

that one percent of wholesalers will repackage their products and so will incur the same burden

as the fabricators who are assumed to incur more substantial initial labeling costs (an av erage of

100 hours). However, the recurring recordkeeping burden reported by the wholesaler

questionnaire respondent (forty five minutes per day) seems unlikely to be representative for all

the wholesaler firms that incur this type of burden. This wholes aler questionnaire respondent

was a firm with employees, but smaller firms, such as nonemployer firms, are likely to need

much less time than 3.75 hours per week (nearly 10% of a 40 hour work week) to perform the

necessary recordkeeping activities. Since the recordkeeping requirements entail keeping track of

composite wood materials purchased and shipments that contain composite wood products, it is

expected that the burden associated with keeping records will typically increase with the volume

of a wholes aler’s sales. Thus, to estimate the recurring recordkeeping burden for nonemployer

wholesalers, the analysis assumes that there is a fixed

- cost component of the recurring

recordkeeping costs associated with two hours of labor and a variable cost component that is

proportional to a firm’s revenue. It is assumed that wholesalers will use clerical labor for

recordkeeping activities and technical labor for labeling.

For employer firms that import composite wood products, the recurring recordkeeping

cost is estimated as 195 hours per year (based on 2 hours of fixed cost labor, with the remaining

hours of variable cost labor). For nonemployer firms that import composite wood products, the

variable cost component is calculated by subtracting two hours of fixed labor cost (at a cost of

$51.08) from the total reported annual cost ($4,980) and then dividing by the estimated average

revenue for affected employer wholesalers ($8,308,417). The resulting variable cost component

(0.05933 percent of revenue) is multipl ied by average nonemployer revenues ($82,542) and

results in costs of $100.05, or 3.92 labor hours per year.

17 The average annual burden for wholesalers with initial recordkeeping costs was calculated as the average burden for the two

firms that quantified costs. One firm indicated that they spent $2,000 f or a “small amount of labor.” This was divided by the

clerical wage rate in the wholesale trade industry ($25.54) and equals approximately 78.3 hours. The other firm indicated th at

they spent 40 labor hours. As a result, the average firm incurred a labor burden of approximately 59.15 hours.

### Page 29 of 96 

## It is assumed that one percent of wholesalers incur labeling burden, either because they

are repackaging goods that were originally labeled on the packaging instead of on the individual

items, or because they are replacing an original label applied by the panel producer or fabricator

with a label listing a different company name. It is also assumed that these wholesalers incur the

same burden as the fabricators who are assumed to incur more substantial initial labeling burden

(an average of 100 hours).

(E). Retailers

It is assumed that retailers do not import composite wood products directly (without a

wholesaler), and thus are not subject to the rule’s chain of custody requirements for importers

. 18



## Retailers that do not import composite wood products must keep invoices and bills of lading.

Retailer’s customary business practices are assumed to be generally sufficient to meet the

proposed rul e’s recordkeeping requirements. 19 

## Therefore the recordkeeping requirements are not

assumed to impose any additional burden on retailers. 20



## Baseline Compliance for Retailers

Exhibit 6

- 8 presents a summary of the baseline compliance estimates for retail industries.

Baseline CARB compliance was calculated in the same manner as described the wholesale

section (i.e., by determining the number of f irms with at least one establishment in California).

Additional detail is provided in the Economic Analysis for the rulemaking.

18 Because all foreign products are assumed to be imported by wholesalers, the burden of the rule’s chain of custody

requirements for any retailers that do import products directly is accounted for under the wholesal er category.

19 Personal Communication with California Retailers Association 2011

. 20 While retailers are assumed to meet the proposed rule’s recordkeeping requirements with documents kept as part of their

customary business practices, these firms do count toward the respondent and response totals in Exhibit 6

- 9 through Exhibit 6

-

14

.

### Page 30 of 96 Exhibit 6

- 8 : Baseline CARB Compliance of Retail Industries

NAICS NAICS Description Baseline CARB

Compliance

441110 New car dealers 11.5%

441210 Recreational vehicle dealers 11.6%

441221 Motorcycle, ATV, and personal watercraft dealers 10.7%

441229 All other motor vehicle dealers 10.6%

441320 Tire dealers 14.7%

442110 Furniture stores 15.2%

442210 Floor covering stores 11.2%

442291 Window treatment stores 15.0%

442299 All other home furnishings stores 15.4%

443111 Household appliance stores 10.5%

443112 Radio, television, and other electronics stores 16.8%

443120 Computer and software stores 15.1%

443130 Camera and photographic supplies stores 17.8%

444110 Home centers 16.2%

444120 Paint and wallpaper stores 19.0%

444130 Hardware stores 9.7%

444190 Other building material dealers 12.3%

444210 Outdoor power equipment stores 5.7%

444220 Nursery, garden center, and farm supply stores 8.7%

445110 Supermarkets and other grocery (except convenience) stores 15.3%

445120 Convenience stores 11.2%

445210 Meat markets 10.9%

445220 Fish and seafood markets 10.3%

445230 Fruit and vegetable markets 10.4%

445291 Baked goods stores 12.4%

445292 Confectionery and nut stores 13.9%

445299 All other specialty food stores 12.2%

445310 Beer, wine, and liquor stores 11.3%

446110 Pharmacies and drug stores 15.5%

446120 Cosmetics, beauty supplies, and perfume stores 12.4%

446130 Optical goods stores 16.1%

446191 Food (health) supplement stores 13.1%

446199 All other health and personal care stores 13.3%

447110 Gasoline stations with convenience stores 15.0%

447190 Other gasoline stations 13.1%

448110 Men's clothing stores 18.0%

448120 Women's clothing stores 17.0%

448130 Children's and infants' clothing stores 15.6%

448140 Family clothing stores 19.6%

448150 Clothing accessories stores 15.3%

448190 Other clothing stores 15.2%

448210 Shoe stores 19.1%

448310 Jewelry stores 14.4%

448320 Luggage and leather goods stores 16.1%

451110 Sporting goods stores 13.5%

451120 Hobby, toy, and game stores 14.2%

451130 Sewing, needlework, and piece goods stores 13.2%

451140 Musical instrument and supplies stores 12.2%

451211 Book stores 15.6%

451212 News dealers and newsstands 11.5%

451220 Prerecorded tape, compact disc, and record stores 14.5%

452111 Department stores (except discount department stores) 70.8%

452112 Discount department stores 74.7%

452910 Warehouse clubs and supercenters 92.0%

452990 All other general merchandise stores 9.8%

453110 Florists 9.2%

### Page 31 of 96 Exhibit 6

- 8 : Baseline CARB Compliance of Retail Industries

NAICS NAICS Description Baseline CARB

Compliance

453210 Office supplies and stationery stores 17.6%

453220 Gift, novelty, and souvenir stores 12.8%

453910 Pet and pet supplies stores 12.9%

453920 Art dealers 13.7%

453930 Manufactured (mobile) home dealers 7.3%

453991 Tobacco stores 12.7%

453998 All other miscellaneous store retailers (except tobacco

stores) 11.5%

454111 Electronic shopping 10.3%

454113 Mail

- order houses 11.3%

454210 Vending machine operators 11.0%

454311 Heating oil dealers 11.7%

454312 Liquefied petroleum gas (bottled gas) dealers 20.4%

454390 Other direct selling establishments 11.1%

Total Retailers 13.2%

a. Baseline CARB compliance represents the percent of retailers estimated to be selling their

products in California, and therefore not expected to incur supplier notification costs.

Sources: U.S. Census Bureau 1997

, 2010g

, k

, l



## (F). Summary

Exhibit 6

- 9 and Exhibit 6

- 10 summarize the total number of respondents, total burden

per responden t and total burden for each response activity over the first year, and second and

third years of the ICR, respectively. Exhibit 6

- 11 presents the aver age total value for those

variables over the first three years of the rule (i.e., without accounting for the baseline

compliance with the CARB ATCM). Exhibit 6

- 12 through Exhibit 6

- 14 mirror the previous

three tables, except that they account for incremental burdens (excluding baseline burden and

cos t). Note that most respondents are incurring burdens for multiple activities listed in these

exhibits. As indicated, the average annual burden over the first three years of the rule is

estimated to be approximately 7.9 million hours, while the incrementa l burden over this time

period is estimated at 5.8 million hours. The domestic burden accounts for approximately 63.3

percent and 66. 9 percent of the totals, respectively

.

### Page 32 of 96 Exhibit 6

- 9 : Total (including baseline) First Year Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities

Per

Respondent Burden Per

Activity

(Hours) Total Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

1. Rule Familiarization

Producers 3 M 370 1,129 1,499 1 4.00 1,480 4,516 5,996

Fabricators 4 M 79,701 31,083 110,784 1 4.00 318,804 124,332 443,136

Wholesalers M 85,560 33,368 118,928 1 4.00 342,240 133,472 475,712

Retailers M 759,048

- 759,048 1 4.00 3,036,192

- 3,036,192

2. Certification Fee

- - - - - - - - -

3. Initial On

- site Audit

With Existing Certifications M 82 764 846 1 4.00 328 3,056 3,384

Without Existing Certifications 3,5 M 288 365 653 1 8.00 2,304 2,920 5,224

4. Develop Quality Control Manual 3 M 288 365 653 1 40.00 11,520 14,600 26,120

5. Qualifying Test

6. Qualifying Test Shipment 6

1 Product M 5 64 69 1 0.50 3 32 35

2 Products 3,5 M 288 365 653 2 0.25 144 183 327

7. Correlation Test

1 Product M 5 64 69 10 1.00 50 640 690

2 Products 3,5 M 288 365 653 20 1.00 5,760 7,300 13,060

8. Quarterly On

- site Audit 7

Standard 3,6 M 328 599 927 3 4.00 3,936 7,188 11,124

NAF (With New Certification) M 11 211 222 1 4.00 44 844 888

9. Large Scale Testing Fee

- - - - - - - - - 10. Large Scale Testing Shipment 7

Standard /ULEF Certification 3,5 M 345 778 1,123 3 0.50 518 1,167 1,685

NAF (With New Certification) M 11 211 222 1 0.50 6 106 112

NAF (With Existing Certification) M 14 140 154 1 0.50 7 70 77

11. On

- si te Audit Travel

- - - - - - - - -

12. Desk Audits 8

Standard Certification 3,5 M 328 599 927 8 1.00 2,624 4,792 7,416

NAF (With New Certification) M 11 211 222 2 1.00 22 422 444

13. Purchase of Small Chamber Testing

Unit 9 - - - - - - - - -

14. Qu ality Control Testing 10

Standard Certification 3,6 M 328 599 927 260 2.00 170,560 311,480 482,040

New NAF Certification M 11 211 222 65 2.00 1,430 27,430 28,860

15. Lost Product

- - - - - - - - -

16. Initi al Recordkeeping 11 C 8,576 11,945 20,521 1 59.15 507,270 706,547 1,213,817

17. Recurring Recordkeeping 12

Producers 3,5 M 370 1,129 1,499 1 52 19,240 58,708 77,948

### Page 33 of 96 Exhibit 6

- 9 : Total (including baseline) First Year Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities

Per

Respondent Burden Per

Activity

(Hours) Total Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

Fabricators with burden

- Employers 4 C 3,630 1,422 5,052 1 520.00 1,887,600 739,440 2,627,040

Fabricators with burden

- Nonemployers 4 C 5,137 1,997 7,134 1 7.21 37,038 14,398 51,436

Fabricators without burden C 70,934 27,664 98,598 1

- - - -

Wholesalers with burden

- Employers C 4,208 5,861 10,069 1 195.00 820,560 1,142,895 1,963,455

Wholesalers with burden

- Nonemployers C 6,094 8,487 14,581 1 3.92 23,888 33,269 57,158

Wholesalers without burden C 75,258 19,020 94,278 1

- - - -

Retailers C 759,048

- 759,048 1

- - - - 18. Initial Labeling 13

Minor Changes

- Producers 4,5 C 93 1,021 1,114 1 6.00 558 6,126 6,684

Minor Changes

- Fabricators 4 T 64,290 24,986 89,276 1 3.00 192,870 74,958 267,828

Major Changes

- Producers 3 C 277 108 385 1 100.00 27,700 10,800 38,500

Major Changes

- Fabricators and

Wholesalers 4 T 16,266 6,344 22,610 1 100.00 1,626,600 634,400 2,261,000

Total

- Year 1 9,041,296 4,066,091 13,107,388

Notes: 1. This column indicates the category of labor associated with the activity. "M", "T", and "C" stand for managerial, technical, and clerical labor, respectively.

2. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domestic value of

shipments for these NAICS (which is 39 percent) and 2) app lying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typically export composite wood

products or goods containing composite wood products into the United States. To remain consistent with the Economi c Analysis, which assumes that there is uncertified product being imported into the

U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.

3. This analysis assumes that two percent of wood v eneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined

as hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use added formaldehyde resins.

4. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formal dehyde resins.

5. Since CARB does not certify wood veneer laminated products, all produ cers of wood veneer laminated products defined as hardwood plywood will incur costs to have their products certified by a TPC

as a result of the TSCA Title VI rule.

6. Producers that are already CARB compliant are not assumed to need to perform correlation testing because it is assumed that their previous testing is sufficient.

7. On

- site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. This analysis assumes that producers with new NAF certifications will incur the burden

associated with one on

- site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the

initial on

- site audit in the first year . All producers with ULEF or NAF certification will have one on

- site audit annually thereafter.

8. Desk audits are assumed to occur monthly for standard certification s , except in months with a quarterly on

- site audit. Producers with new NAF certification s will incur the costs associated with two

desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with exist ing ULEF or NAF certification.

9. Although mills are likely to incur some labor burden while learning how to use the small chamber testing unit, it is not estimated in this analysis.

10. This analysis assumes that composite panel producers with a standard certification or a new NAF certification test each production line once daily. Produc ers with an existing ULEF or NAF

certification will already have been exempted from quality control testing

. 11. Recordkeeping costs are incurred by composite panel producers (including the estimated two percent of wood veneer lamina ted product producers defined as hardwood plywood producers),

fabricators, and wholesalers that import composite wood products or articles that contain composite wood products. However, composite panel producers and fabricators are not expected to need to make

any initial chan ges to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood prod ucts or articles that contain composite wood products. In

addition, it is assumed that 57 percent of wholesalers are not already c omplying with the CARB ATCM and will have initial burden to change their recordkeeping systems to comply with the TSCA Title

VI rule.

12. While recordkeeping is required for all respondents, not all entities will incur additional recordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existing

### Page 34 of 96 Exhibit 6

- 9 : Total (including baseline) First Year Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities

Per

Respondent Burden Per

Activity

(Hours) Total Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

recordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers will

have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import compos ite wood products or articles that contain composite wood products and

thus 43% of that 28% incur re curring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to be generally sufficient to meet the

proposed rule’s recordkeeping requirements. For fabricators and wholesalers wit h burden, the analysis assumes that there is a fixed

- cost component of the recurring recordkeeping costs associated with

two hours of labor and a variable cost component that is proportional to a firm’s revenue. The variable cost factor is estim ated by su btracting the fixed cost from the total reported cost and then dividing

by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the total report ed cost is $12,916.80, and the average revenue is $4,241,24 5. For wholesalers,

the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variab le cost factors are 0.30338 percent and 0.05933 percent of revenue. The

recurring recordkeeping burdens for e mployer fabricators and wholesalers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring re cordkeeping burden is estimated as the

sum of the burden associated with the fixed cost (2 hours) and the burden associated with th e respective variable costs, which are calculated as 0.30338 percent of average nonemployer fabricator

revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricat or and wholesaler nonemploye r recurring recordkeeping burdens are 7.21

and 3.92 hours per year, respectively.

13. Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modif y their labels to include

their name, the date the finished good was produced, and a statement of compliance. This analysis assumes that all producers , 67 percent of fabricators that are not already complying with the CARB

ATCM, and all fabricators that a re already complying with the CARB ATCM 33 percent of fabricators, and 1 percent of wholesalers will incur the cost associate d with 3 hours of labor for making small

changes to their labels. The remaining fabricators and one percent of wholesalers are ass umed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire

(see the Economic Analysis for more details).

### Page 35 of 96 Exhibit 6

- 10 : Total (including baseline) Second and Third Year Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Total Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

1. Rule Familiarization

Producers 3 M

- - - - - - - -

Fabricators 4 M

- - - - - - - -

Wholesalers M

- - - - - - - -

Retailers M

- - - - - - - -

2. Certification Fee

- - - - - - - - -

3. Initia l On

- site Audit

With Existing Certifications M

- - - - - - - - Without Existing Certifications 3,5 M

- - - - - - - - 4. Develop Quality Control Manual 3 M

- - - - - - - - 5. Qualifying Test

- - - - - - - - - 6. Qualif ying Test Shipment

1 Product M

- - - - - - - -

2 Products 3,5 M

- - - - - - - -

7. Correlation Test 6

1 Product M

- - - - - - - -

2 Products 3,5 M

- - - - - - - - 8. Quarterly On

- site Audit 7

Standard 3,6 M 328 599 927 4 4.00 5,248 9,584 14,832

NAF (Wi th New Certification) M 11 211 222 1 4.00 44 844 888

9. Large Scale Testing Fee

- - - - - - - - - 10. Large Scale Testing Shipment 7

Standard/ULEF Certification 3,5 M 345 778 1,123 4 0.50 690 1,556 2,246

NAF (Wi th New Certification) M 11 211 222 1 0.50 6 106 112

NAF (With Existing Certification) M 14 140 154 1 0.50 7 70 77

11. On

- sit e Audit Travel

- - - - - - - - -

12. Desk Audits 8

Standard Certification 3,5 M 328 599 927 8 1.00 2,624 4,792 7,416

NAF (Wi th New Certification) M

- - - - - - - -

13. Purchase of Small Chamber

Testing Unit 9 - - - - - - - - -

14. Qu ality Control Testing 10

Standard Certification 3,5 M 328 599 927 260 2.00 170,560 311,480 482,040

New NAF Ce rtification M

- - - - - - - -

15. Lost Product

16. Initial Recordkeeping 11 C

- - - - - - - - 17. Recurring Recordkeeping 12

Producers 3,5 

### M 370 1,129 1,499 1 52.00 19,240 58,708 77,948

### Page 36 of 96 Exhibit 6

- 10 : Total (including baseline) Second and Third Year Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Total Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

Fabricator s with burden

Employers 4 

### C 3,630 1,422 5,052 1 520.00 1,887,600 739,440 2,627,040

Fabricator s with burden

- Nonemployers 4 

### C 5,137 1,997 7,134 1 7.21 37,038 14,398 51,436

Fabricators without burden 

### C 70,934 27,664 98,598 1

-



## - - -

Wholesalers with burden

- Employers 

### C 4,208 5,861 10,069 1 195.00 820,560 1,142,895 1,963,455

Wholesalers with burden

- Nonemployers 

### C 6,094 8,487 14,581 1 3.92 23,888 33,269 57,158

Wholesalers without burden 

### C 75,258 19,020 94,278 1

-



## - - -

Retailers 

### C 759,048

- 759,048 1

-



## - - -

19. Initial Labeling 4,13

Minor Changes

- Producers 4,5 C

- - - - - - - - Minor Changes

- Fabricators 4 T

- - - - - - - - Major Changes

- Producers 3 C

- - - - - - - - Major Changes

- Fabricators and

Wholesalers 4 T

- - - - - - - -

Total

- Years 2 and 3 2,967,505 2,317,142 5,284,648

Notes: 1. This column indicates the category of labor associated with the activity. "M", "T", and "C" stand for managerial, technical, and clerical labor, respectively.

2. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affecte d fabricator NAICS to the total domestic value of

shipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typically export composite wood

products or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis , which assum es that there is uncertified product being imported into the

U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.

3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined

as hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use ad ded formaldehyde resins.

4. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formal dehyde resins.

5. Since CARB does not certify wood veneer laminated products, all producers of wood veneer lam inated products defined as hardwood plywood will incur costs to have their products certified by a

TPC as a result of the TSCA Title VI rule.

6. Producers that are already CARB compliant are not assumed to need to perform correlation testing because it is assumed that their previous testing is sufficient.

7. On

- site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. This analysis assumes that producers with new NAF certifications will incur the burden

associated with one on

- site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing ULEF or NAF certi fications under the CARB ATCM will only incur the

initial on

- site audit in the first year. All producers with ULEF or NAF certification will have one on

- site audit annually thereafter.

8. Desk audits are assumed to occur monthly for standard certification s , except in months with a quarterly on

- site audit. Producers with new NAF certifications will incur the costs associated with two

desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with exis ting ULEF or NAF certification.

9. Although mills are likely to incur some labor burden while learning how to use the small chamber testing unit, it is not e stimated in this analysis.

10. This analysis assumes that composite panel producers with s standard certification or a new NAF certification test each production line once daily. Producers with an existing ULEF or NAF

certification will already have been exempted from quality control testing

. 11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood p roducers), fabricators,

and wholesalers that import composite wood products or articles that contain composite wood products. Howe ver, composite panel producers and fabricators are not expected to need to make any initial

### Page 37 of 96 Exhibit 6

- 10 : Total (including baseline) Second and Third Year Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Total Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain compo site wood products. In addition, it

is assumed that 57 percent of wholesalers are not already complying with the CARB ATCM and will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule.

12. While recordkeeping i s required for all respondents, not all entities will incur additional recordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existing

recordkeeping systems that are sufficient to meet the rule's requirements. Ba sed on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers wil l

have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import compos ite wood products or articles that contain composite wood products and

thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wh olesalers, and all retailers are assumed to be generally suffici ent to meet

the proposed rule’s recordkeeping requirements. For fabricators and wholesalers with burden, the analysis assumes that there is a fixed

- cost component of the recurring recordkeeping costs associated

with two hours of labor and a variable cost component that is proportional to a firm’s revenue. The variable cost factor is estimated by subtracting the fixed cost from the total reported cost and then

dividing by the estimated average revenue for affected employer category. For fabricators, the f ixed cost is $49.68, the total reported cost is $12,916.80, and the average revenue is $4,241,245. For

wholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The resp ective variable cost factor s are 0.30338 percent and 0.05933 percent of revenue.

The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. F or nonemployers, the average recurring recordkeeping burden is estimated

as the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs, which are calculated as 0.30338 percent of average nonemployer fabricator

revenues ($42,690) and 0.05933 percent of average nonemp loyer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurring recordkeeping bur dens are 7.21

and 3.92 hours per year, respectively.

13. Panel producers, fabricators, and wholesalers that package or repackage c omposite wood products or finished goods containing composite wood products will need to modify their labels to include

their name, the date the finished good was produced, and a statement of compliance. This analysis assumes that all producers , 67 percen t of fabricators that are not already complying with the CARB

ATCM, and all fabricators that are already complying with the CARB ATCM 33 percent of fabricators, and 1 percent of wholesale rs will incur the cost associated with 3 hours of labor for making sm all

changes to their labels. The remaining fabricators and one percent of wholesalers are assumed to incur the average cost of t he two firms that reported initial labeling costs in the fabricator questionnaire

(see the Economic Analysis for more details).

### Page 38 of 96 Exhibit 6

- 11 : Three Year Average Burden Hours (including baseline), by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Total Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

1. Rule Familiarization

Producers 3 M 370 1,129 1,499 0.3333 4.0000 493 1,505 1,998

Fabricat ors 4 M 79,701 31,083 110,784 0.3333 4.0000 106,257 41,440 147,697

Wholesalers M 85,560 33,368 118,928 0.3333 4.0000 114,069 44,486 158,555

Retailer s M 759,048

- 759,048 0.3333 4.0000 1,011,963

- 1,011,963

2. Certification Fee

- - - - - - - - -

3. Init ial On

- site Audit

With Existing Certifications M 82 764 846 0.3333 4.0000 109 1,019 1,128

Without Existing Certifications 3,5 M 288 365 653 0.3333 8.0000 768 973 1,741

4. Develop Quality Control Manual 3 M 288 365 653 0.3333 40.0000 3,840 4,866 8,706

5. Quali fying Test

- - - - - - - - - 6. Qualifying Test Shipment

1 Product M 5 64 69 0.3333 0.5000 1 11 12

2 Products 3,5 M 288 365 653 0.6667 0.2500 48 61 109

7. Correlation Test 6

1 Product M 5 64 69 3.3333 1.0000 17 213 230

2 Pro ducts 3,5 M 288 365 653 6.6667 1.0000 1,920 2,433 4,353

8. Quart erly On

- site Audit 7

Standard 3,5 M 328 599 927 3.6667 4.0000 4,811 8,785 13,596

NAF ( With New Certification) M 11 211 222 1.0000 4.0000 44 844 888

9. Large Scale Testing Fee

- - - - - - - - -

10. Lar ge Scale Testing Shipment 7

Standard/ULEF Certification 3,5 M 345 778 1,123 3.6667 0.5000 633 1,426 2,059

NAF ( With New Certification) M 11 211 222 1.0000 0.5000 6 106 112

NAF (With Existing Certification) M 14 140 154 1.0000 0.5000 7 70 77

11. O n

- site Audit Travel

- - - - - - - - -

12. Des k Audits 8

Standard Certification 3,5 M 328 599 927 8.0000 1.0000 2,624 4,792 7,416

NAF ( With New Certification) M 11 211 222 0.6667 1.0000 7 141 148

13. Purchase of Small Chamber Testing Unit 9

- - - - - - - - - 14. Qua lity Control Testing 10

Standard Certification 3,5 M 328 599 927 260.0000 2.0000 170,560 311,480 482,040

New N AF Certification M 11 211 222 21.6667 2.0000 477 9,143 9,620

15. Lost Product

- - - - - - - - -

16. Ini tial Recordkeeping 11 C 8,576 11,945 20,521 0.3333 59.1500 169,073 235,492 404,565

17. Recurring Recordkeeping 12

Producers 3,5 M 370 1,129 1,499 1.0000 52.0000 19,240 58,708 77,948

### Page 39 of 96 Exhibit 6

- 11 : Three Year Average Burden Hours (including baseline), by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Total Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

Fabricators with burden

- Employers 4 C 3,630 1,422 5,052 1.0000 520.0000 1,887,600 739,440 2,627,040

Fabricators with burden

- Nonemployers 4 C 5,137 1,997 7,134 1.0000 7.2100 37,038 14,398 51,436

Fabricators without burden C 70,934 27,664 98,598 1.0000

- 

## - - -

Wholesalers with burden

- Employers C 4,208 5,861 10,069 1.0000 195.0000 820,560 1,142,895 1,963,455

Wholesalers with burden

- Nonemployers C 6,094 8,487 14,581 1.0000 3.9200 23,888 33,269 57,15 7

Wholesalers without burden C 75,258 19,020 94,278 1.0000

- 

## - - -

Retailers C 759,048

- 759,048 1.0000

- 

## - - -

18. Initial Labeling 4,13

Minor Changes

- Producers 4,5 C 93 1,021 1,114 0.3333 6.0000 186 2,042 2,228

Minor Ch anges

- Fabricators 4 T 64,290 24,986 89,276 0.3333 3.0000 64,284 24,984 89,26 8

Major Ch anges

- Producers 3 C 277 108 385 0.3333 100.0000 9,232 3,600 12,832

Major Changes

- Fabricators and Wholesalers 4 T 16,266 6,344 22,610 0.3333 100.0000 542,146 211,446 753,59 2

Total

- Three Year Average 4,991,901 2,900,068 7,891,969

Notes: 1. This column indicates the category of labor associated with the activity. "M", "T", and "C" stand for managerial, technical, and clerical labor, respectively.

2. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affecte d fabricator NAICS to the total domestic value of

shipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typically export composite wood

products or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis , which assum es that there is uncertified product being imported into the

U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.

3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined

as hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use ad ded formaldehyde resins.

4. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formal dehyde resins.

5. Since CARB does not certify wood veneer laminated products, all producers of wood veneer lam inated products defined as hardwood plywood will incur costs to have their products certified by a

TPC as a result of the TSCA Title VI rule.

6. Producers that are already CARB compliant are not assumed to need to perform correlation testing because it is assumed that their previous testing is sufficient.

7. On

- site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. This analysis assumes that producers with new NAF certifications will incur the burden

associ ated with one on

- site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the

initial on

- site audit in the first year. All producers with U LEF or NAF certification will have one on

- site audit annually thereafter.

8. Desk audits are assumed to occur monthly for standard certifications , except in months with a quarterly on

- site audit. Producers with new NAF certifications will incur the costs associated with two

desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with exist ing ULEF or NAF certification.

9. Although mills are likely to incur some labor burden while learning how to use the small chamber testing unit, it is not estimated in this analysis.

10. This analysis assumes that composite panel producers with a standard certification or a new NAF certification test each production line once daily. Producers with an existing UL EF or NAF

certification will already have been exempted from quality control testing

. 11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated pr oduct producers defined as hardwood plywood p roducers), fabricators,

and wholesalers that import composite wood products or articles that contain composite wood products. However, composite pan el producers and fabricators are not expected to need to make any initial

changes to their recordkeeping sy stems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it

is assumed that 57 percent of wholesalers are not already complying with the CARB ATCM a nd will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule.

12. While recordkeeping is required for all respondents, not all entities will incur additional recordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existing

recordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers wil l

### Page 40 of 96 Exhibit 6

- 11 : Three Year Average Burden Hours (including baseline), by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Total Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import compos ite wood products or articles that contain composite wood products and

thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wholesalers, and all retailers are assumed to be generally suf ficient to meet

the proposed rule’s recordkeeping requirements. For fabricators and wholesalers with burden, the analysis assume s that there is a fixed

- cost component of the recurring recordkeeping costs associated

with two hours of labor and a variable cost component that is proportional to a firm’s revenue. The variable cost factor is estimated by subtracting the fixed cost from the total reported cost and then

dividing by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the tot al reported cost is $12,916.80, and the average revenue is $4,241,245. For

wholesalers, the fixe d cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The respective variable cost factors are 0.30338 percent and 0.05933 percent of revenue.

The recurring recordkeeping burdens for employer fabricators and whole salers are 520 and 195 hours per year, respectively. For nonemployers, the average recurring recordkeeping burden is estimat ed

as the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable cost s, which are calculated as 0.30338 percent of average nonemployer fabricator

revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricat or and wholesaler nonemployer recurring recordkeeping bur dens are 7.21

and 3.92 hours per year, respectively.

13. Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify th eir labels to include

their name, the date the finished good was produced, and a statement of compliance. This analysis assumes that all producers, 67 p ercent of fabricators that are not already complying with the CARB

ATCM, and all fabricators that are already complying with the C ARB ATCM 33 percent of fabricators, and 1 percent of wholesalers will incur the cost associated with 3 hours of labor for mak ing small

changes to their labels. The remaining fabricators and one percent of wholesalers are assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire

(see the Economic Analysis for more details).

### Page 41 of 96 Exhibit 6

- 12 : Incremental First Year Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Incremental Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

1. Rule Familiarization

Producers 3 M 370 1,129 1,499 1 4.00 1,480 4,516 5,996

Fabricators 4 M 79,701 31,083 110,784 1 4.00 318,804 124,332 443,136

Wholesalers M 85,560 33,368 118,928 1 4.00 342,240 133,472 475,712

Retailers M 759,048

- 759,048 1 4.00 3,036,192

- 3,036,192

2. Certification Fee

- - - - - - - - -

3. Initial On

- site Audit

With Existing Certifications M 82 764 846 1 4.00 328 3,056 3,384

Without Ex isting Certifications 3,5 M 288 365 653 1 8.00 2,304 2,920 5,224

4. Develop Quality Control Manual 3 M 288 365 653 1 40.00 11,520 14,600 26,120

5. Qualify ing Test

- - - - - - - - - 6. Qualifying Test Shipment

1 Product M 5 64 69 1 0.50 3 32 35

2 Products 3,5 M 288 365 653 2 0.25 144 183 327

7. Correlation Test 6

1 Product M 5 64 69 10 1.00 50 640 690

2 Products 3,5 M 288 365 653 20 1.00 5,760 7,300 13,060

8. Quarterly On

- site Audit 7

Uncertified to Standard 3,5 M 277 154 431 3 4.00 3,324 1,848 5,172

NAF (With New Certification) M 11 211 222 1 4.00 44 844 888

9. Large Scale Testing Fee

- - - - - - - - - 10. Large Scale Testing Shipment 7

Uncertified to Standard 3,5 M 277 154 431 3 0.50 416 231 647

NAF (Wi th New Certification) M 11 211 222 1 0.50 6 106 112

11. On

- site Audit Travel

- - - - - - - - -

12. Desk Audits 8

Uncertified to Standard 3,5 M 277 154 431 8 1.00 2,216 1,232 3,448

NAF (Wi th New Certification) M 11 211 222 2 1.00 22 422 444

13. Purchase of Small Chamber Testing

Unit 9 - - - - - - - - -

14. Qu ality Control Testing 10

- - - - - - - - -

Standard Certification 3,5 M 277 154 431 260 2.00 144,040 80,080 224,120

New NAF Certification M 11 211 222 65 2.00 1,430 27,430 28,860

15. Lost Product

- - - - - - - - - 16. Initial Recordkeeping 11 C 8,576 11,945 20,521 1 59.15 507,270 706,547 1,213,817

17. Recurring Recordkeeping 12

Producers 3,5 M 370 1,129 1,499 1 52.00 19,240 58,708 77,948

Fabrica tors with burden

- Employers 4 C 2,176 848 3,024 1 520.00 1,131,520 440,960 1,572,480

### Page 42 of 96 Exhibit 6

- 12 : Incremental First Year Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Incremental Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

Fabricators with burden

- Nonemployers 4 C 3,054 1,191 4,245 1 7.21 22,019 8,587 30,606

Fabricator s without burden C 42,310 16,437 58,747 1

- 

## - - -

Wholesa lers with burden

- Employers C 2,642 3,680 6,322 1 195.00 515,190 717,600 1,232,790

Wholesa lers with burden

- Nonemployers C 3,826 5,331 9,157 1 3.92 14,998 20,898 35,895

Wholesalers without burden C 47,263 11,944 59,207 1



## - - - -

Retaile rs C 658,150

- 658,150 1



## - - - -

18. Ini tial Labeling 4,13

Minor Changes

- Producers 4,5 C 93 1,021 1,114 1 6.00 558 6,126 6,684

Minor Chan ges

- Fabricators 4 T 64,290 24,986 89,276 1 3.00 192,870 74,958 267,828

Major Chan ges

- Producers 3 C 277 108 385 1 100.00 27,700 10,800 38,500

Major Changes

- Fabricators and

Wholesalers 4 T 16,266 6,344 22,610 1 100.00 1,626,600 634,400 2,261,000

Total

- Year 1 7,928,288 3,082,828 11,011,115

Notes: 1. This column indicates the category of labor associated with the activity. "M", "T", and "C" stand for managerial, technical, and clerical labor, respectively.

2. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domestic value of

shipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analy sis assumes that foreign retailers do not typically export composite wood

products or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis , which assumes that there is uncertified product being imported into the

U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.

3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products wi ll be defined

as hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use ad ded formaldehyde resins.

4. Total excludes the estimated 2 percent of wood veneer laminated product producers expecte d to continue to use added formaldehyde resins.

5. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as har dwood plywood will incur costs to have their products certified by a

TPC as a resul t of the TSCA Title VI rule.

6. Producers that are already CARB compliant are not assumed to need to perform correlation testing because it is assumed tha t their previous testing is sufficient.

7. On

- site audits must be conducted at least once quarterly, u nless the mill obtains ULEF or NAF certification. This analysis assumes that producers with new NAF certifications will incur the burden

associated with one on

- site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the

initial on

- site audit in the first year. All producers with ULEF or NAF certification will have one on

- site audit annually thereafter.

8. Desk audits are assumed to occur mon thly for standard certifications , except in months with a quarterly on

- site audit. Producers with new NAF certifications will incur the costs associated with two

desk audits in the first year; none are required in subsequent years. No desk audits are req uired for respondents with existing ULEF or NAF certification.

9. Although mills are likely to incur some labor burden while learning how to use the small chamber testing unit, it is not e stimated in this analysis.

10. This analysis assumes that composit e panel producers with a standard certification or a new NAF certification test each production line once daily. Producers with an existing ULEF or NAF

certification will already have been exempted from quality control testing

. 11. Recordkeeping is requi red for composite panel producers (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fabricators,

and wholesalers that import composite wood products or articles that contain composite wo od products. However, composite panel producers and fabricators are not expected to need to make any initial

changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it

is assumed that 57 percent of wholesalers are not already complying with the CARB ATCM and will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule.

12. Whi le recordkeeping is required for all respondents, not all entities will incur additional recordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existing

### Page 43 of 96 Exhibit 6

- 12 : Incremental First Year Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Incremental Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

recordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent o f wholesalers will

have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood products and

thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wh olesalers, and all retailers are assumed to be generally sufficient to meet

the proposed rule’s recordkeeping requirements. For fabricators and wholesalers with burden, the analysis assumes that there is a fixed

- cost component of the recurring recordkeeping costs associated

with two hours of labor an d a variable cost component that is proportional to a firm’s revenue. The variable cost factor is estimated by subtracting t he fixed cost from the total reported cost and then

dividing by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the total reported cost is $12,916.80, and the average revenue is $4,241,245. For

wholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The resp ective va riable cost factors are 0.30338 percent and 0.05933 percent of revenue.

The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. F or nonemployers, the average recurring recordkeeping burde n is estimated

as the sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable cost s, which are calculated as 0.30338 percent of average nonemployer fabricator

revenues ($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurring recordkeeping burdens are 7.21

and 3.92 hours per year, respectively.

13. Panel producers, fabricators, and wholesalers that pac kage or repackage composite wood products or finished goods containing composite wood products will need to modify their labe ls to include

their name, the date the finished good was produced, and a statement of compliance. This analysis assumes that all p roducers, 67 percent of fabricators that are not already complying with the CARB

ATCM, and all fabricators that are already complying with the CARB ATCM will incur the cost associated with 3 hours of labor for making small changes to their labels. The rem aining fabricators and

one percent of wholesalers are assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).

### Page 44 of 96 Exhibit 6

- 13 : Incremental Second and Third Year Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Incremental Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

1. Rule Familiarization

Producers 3 M

- - - - - - - -

F abricators 4 M

- - - - - - - -

Wholesalers M

- - - - - - - -

R etailers M

- - - - - - - -

2. Certification Fee

- - - - - - - - -

3. Initi al On

- site Audit

With Existing Certifications M

- - - - - - - -

W ithout Existing Certifications 3,5 M

- - - - - - - - 4. Develop Quality Control Manual 3 M

- - - - - - - -

5 . Qualifying Test

- - - - - - - - - 6. Qualifying Test Shipment

1 Product M

- - - - - - - -

2 Products 3,5 M

- - - - - - - -

7 . Correlation Test 6

1 Product M

- - - - - - - -

2 Products 3,5 M

- - - - - - - - 8. Quarterly On

- site Audit 7

Uncertified to Standard 3,5 M 277 154 431 4 4.00 4,432 2,464 6,896

NAF (With New Certification) M 11 211 222 3 4.00 132 2,532 2,664

9. Large Scale Testing Fee

- - - - - - - - - 10. Larg e Scale Testing Shipment 7

Uncertified to Standard 3,5 M 277 154 431 4 0.50 554 308 862

NAF (With New Certification) M 11 211 222 1 0.50 6 106 11 2

11. On

- site Audit Travel

- - - - - - - - -

12. Desk Audits 8

Uncertified to Standard 3,5 M 277 154 431 8 1.00 2,216 1,232 3,448

NAF (With New Certification)

- - - - - - - - - 13. Purchase of Small Chamber Testing Unit 9

- - - - - - - - - 14. Qual ity Control Testing 10

Standard Certification 3,5 M 277 154 431 260 2.00 144,040 80,080 224,120

New NAF Certification M

- - - - - - - -

1 5. Lost Product

- - - - - - - - - 16. Initial Recordkeeping 11 C

- - - - - - - -

1 7. Recurring Recordkeeping 12

Producers 3,5 M 370 1,129 1,499 1 52.00 19,240 58,708 77,948

Fabricators with burden

- Employers 4 C 2,176 848 3,024 1 520.00 1,131,520 440,960 1,572,480

Fabricators with burden

- Nonemployers 4 C 3,054 1,191 4,245 1 7.21 22,019 8,587 30,606

### Page 45 of 96 Exhibit 6

- 13 : Incremental Second and Third Year Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Incremental Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

Fabricators without burden C 42,310 16,437 58,747 1

- 

## - - -

Wholesalers with burden

- Employers C 2,642 3,680 6,322 1 195.00 515,190 717,600 1,232,790

Wholesalers with burden

- Nonemployers C 3,826 5,331 9,157 1 3.92 14,998 20,898 35,895

Wholesalers without burden C 47,263 11,944 59,207 1



## - - - -

Retailers C 658,150

- 658,150 1



## - - - -

18. Initial Labeling 4,13

Minor Changes

- Producers 4,5 T

- - - - - - - -

M inor Changes

- Fabricators 4 T

- - - - - - - -

M ajor Changes

- Producers 3 T

- - - - - - - -

Major Changes

- Fabricators and Wholesalers 4 T

- - - - - - - -

T otal

- Years 2 and 3 1,854,347 1,333,475 3,187,821

Notes: 1. This column indicates the category of labor associated with the activity. "M", "T", and "C" stand for managerial, technical, and clerical labor, respectively.

2. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affecte d fabricator NAICS to the total domestic value of

shipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typically export composite wood

products or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis , which assum es that there is uncertified product being imported into the

U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.

3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined

as hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use ad ded formaldehyde resins.

4. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formal dehyde resins.

5. Since CARB does not certify wood veneer laminated products, all producers of wood veneer lam inated products defined as hardwood plywood will incur costs to have their products certified by a TPC

as a result of the TSCA Title VI rule.

6. Producers that are already CARB compliant are not assumed to need to perform correlation testing because it is assumed that their previous testing is sufficient.

7. On

- site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. This analysis assumes that producers with new NAF certifications will incur the burden

associ ated with one on

- site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the

initial on

- site audit in the first year. All producers with U LEF or NAF certification will have one on

- site audit annually thereafter.

8. Desk audits are assumed to occur monthly for standard certifications , except in months with a quarterly on

- site audit. Producers with new NAF certifications will incur the costs associated with two

desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with exist ing ULEF or NAF certification.

9. Although mills are likely to incur some labor burden while learning how to use the small chamber testing unit, it is not estimated in this analysis.

10. This analysis assumes that composite panel producers with a standard certification or a new NAF certification test each production line once daily. Producers with an existing ULEF or NAF

certification will already have been exempted from quality control testing

. 11. Recordkeeping is required for composite panel producers (including the estimated two percent of wood veneer laminated pr oduct producers defined as hardwood plywood producers), fabricators, and

wholesalers that import composite wood products. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis

assumes that 28 percent o f domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is a ssumed that 57 percent of wholesalers are not

already complying with the CARB ATCM and will have initial burden to change their rec ordkeeping systems to comply with the TSCA Title VI rule.

12. While recordkeeping is required for all respondents, not all entities will incur additional recordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have exi sting

recordkeeping systems that are sufficient to meet the rule's requirements. Based on responses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers will

have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import composite wood products or articles that contain com posite wood products and

thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remai ning fabricators, wholesalers, and all retailers are assumed to be generally sufficient to meet the

proposed rule’s recordkeeping requirements. For fabricators and wholesalers with burden, the analysis assumes that there is a fixed

- cost component of the r ecurring recordkeeping costs associated with

### Page 46 of 96 Exhibit 6

- 13 : Incremental Second and Third Year Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Incremental Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

two hours of labor and a variable cost component that is proportional to a firm’s revenue. The variable cost factor is estim ated by subtracting the fixed cost from the total reported cost and then dividing

by t he estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the total reported c ost is $12,916.80, and the average revenue is $4,241,245. For wholesalers,

the fixed cost is $51.08, the total reported cost is $4 ,890.30, and the average revenue is $8,308,417. The respective variable cost factors are 0.30338 percent and 0.05933 percent of revenue. The

recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respecti vely. For nonemployers, the average recurring recordkeeping burden is estimated as the

sum of the burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs, whic h are calculated as 0.30338 percent of aver age nonemployer fabricator revenues

($42,690) and 0.05933 percent of average nonemployer wholesaler revenues ($82,542). The resulting average fabricator and wh olesaler nonemployer recurring recordkeeping burdens are 7.21 and 3.92

hours per year, respecti vely.

13. Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify th eir labels to include

their name, the date the finished good was produced, and a statement of compliance. This analysis assumes that all producers, 67 percent of fabricators that are not already comp lying with the CARB

ATCM, and all fabricators that are already complying with the CARB ATCM will incur the cost associated with 3 hours of labor for making small changes to their labels. The remaining fabricators and

one percent of wholesalers are assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricator questionnaire (see the Economic Analysis for more details).

### Page 47 of 96 Exhibit 6

- 14 : Three Year Average Incremental Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Incremental Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

1. Rule Familiarization

Producers 3 M 370 1,129 1,499 0.3333 4.0000 493 1,505 1,998

Fabricators 4 M 79,701 31,083 110,784 0.3333 4.0000 106,257 41,440 147,697

Wholesalers M 85,560 33,368 118,928 0.3333 4.0000 114,069 44,486 158,555

Retailers M 759,048

- 759,048 0.3333 4.0000 1,011,963

- 1,011,963

2. Certification Fee



## - - - - - - - - -

3. Initia l On

- site Audit

With Existing Certifications M 82 764 846 0.3333 4.0000 109 1,019 1,128

Without Ex isting Certifications 3,5 M 288 365 653 0.3333 8.0000 768 973 1,741

4. Develop Quality Control Manual 3 M 288 365 653 0.3333 40.0000 3,840 4,866 8,706

5. Qualify ing Test



## - - - - - - - - -

6. Qualifying Test Shipment

1 Product M 5 64 69 0.3333 0.5000 1 11 12

2 Produ cts 3,5 M 288 365 653 0.6667 0.2500 48 61 109

7. Correlation Test 6

1 Product M 5 64 69 3.3333 1.0000 17 213 230

2 Products 3,5 M 288 365 653 6.6667 1.0000 1,920 2,433 4,353

8. Quarterly On

- site Audit 7

Uncertified to Standard 3,5 M 277 154 431 3.6667 4.0000 4,063 2,259 6,32 2

NAF (With New Certification) M 11 211 222 2. 3333 4.0000 103 1,969 2,072

9 . Large Scale Testing Fee



## - - - - - - - - -

10. Large Scale Testing Shipment 8

Uncertified to Standard 3,5 M 277 154 431 3.6667 0.5000 508 282 790

NAF (Wi th New Certification) M 11 211 222 1.0000 0.5000 6 106 112

11. On

- site Audit Travel



## - - - - - - - - -

12. Desk Audits 8

Uncertified to Standard 3,5 M 277 154 431 8.0000 1.0000 2,216 1,232 3,448

NAF (With New Certification) M 11 211 222 0.6667 1.0000 7 141 148

13. Purchase of Small Chamber

Testing Unit 9 

## - - - - - - - - -

14. Qu ality Control Testing 10

Standard Certification 3,5 M 277 154 431 260.0000 2.0000 144,040 80,080 224,120

New NAF Certification M 11 211 222 21.6667 2.0000 477 9,143 9,620

15. Lost Product



## - - - - - - - - -

16. Initi al Recordkeeping 11 C 8,576 11,945 20,521 0.3333 59.1500 169,073 235,492 404,565

17. Recurr ing Recordkeeping 12

Producers 3,5 M 370 1,129 1,499 1.0000 52.0000 19,240 58,708 77,948

### Page 48 of 96 Exhibit 6

- 14 : Three Year Average Incremental Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Incremental Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

Fabricator s with burden

Employers 4 C 2,176 848 3,024 1.0000 520.0000 1,131,520 440,960 1,572,480

Fabricators with burden

- Nonemployers 4 C 3,054 1,191 4,245 1.0000 7.2100 22,019 8,587 30,606

Fabricators without burden C 42,310 16,437 58,747 1.0000

- 

## - - -

Wholesalers with burden

- Employers C 2,642 3,680 6,322 1.0000 195.0000 515,190 717,600 1,232,790

Wholesalers with burden

- Nonemployers C 3,826 5,331 9,157 1.0000 3.9200 14,998 20,898 35,89 6

Wholesalers without burden C 47,263 11,944 59,207 1.0000

- 

## - - -

Retailers C 658,150

- 658,150 1.0000

- 

## - - -

18. Initial Labeling 4,13

Minor Changes

- Producers 4,5 C 93 1,021 1,114 0.3333 6.0000 186 2,042 2,228

Minor Changes

- Fabricators 4 T 64,290 24,986 89,276 0.3333 3.0000 64,284 24,984 89,26 8

Major Changes

- Producers 3 C 277 108 385 0.3333 100.0000 9,232 3,600 12,832

Major Chan ges

- Fabricators and

Wholesalers 4 T 16,266 6,344 22,610 0.3333 100.0000 542,146 211,446 753,59 2

Total

- Three Year Average 3,878,793 1,916,536 5,795,329

Notes: 1. This column indicates the category of labor associated with the activity. "M", "T", and "C" stand for managerial, technical, and clerical labor, respectively.

2. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total do mestic value of

shipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analy sis assumes that foreign retailers do not typically export composite wood

products or goods containing composite wo od products into the United States. To remain consistent with the Economic Analysis, which assumes that there is uncertified product being imported into the

U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total numb er of certified mills.

3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined

as hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use added formaldehyde resins.

4. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formal dehyde resins

. 5. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as har dwood plywood will incur costs to have their products certified by a

TPC as a result of the TSCA Title VI rule.

6. Producers that are already CARB compliant are not assumed to need to perform correlation testing because it is assumed that their previous t esting is sufficient.

7. On

- site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. This analysis assumes that producers with new NAF certifications will incur the burden

associated with one on

- site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing ULEF or NAF certi fications under the CARB ATCM will only incur the

initial on

- site audit in the first year. All producers with ULEF or NAF certification will have one on

- site audit annually thereafter.

8. Desk audits are assumed to occur monthly for standard certification s , except in months with a quarterly on

- site audit. Producers with new NAF certifications will incur the costs associated with two

desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with exis ting ULEF or NAF certification.

9. Although mills are likely to incur some labor burden while learning how to use the small chamber testing unit, it is not e stimated in this analysis.

10. This analysis assumes that composite panel producers with a standa rd certification or a new NAF certification test each production line once daily. Producers with an existing ULEF or NAF

certification will already have been exempted from quality control testing

. 11. Recordkeeping is required for composite panel produce rs (including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood producers), fa bricators,

and wholesalers that import composite wood products or articles that contain composite wood products. However, composit e panel producers and fabricators are not expected to need to make any initial

### Page 49 of 96 Exhibit 6

- 14 : Three Year Average Incremental Burden Hours, by Activity and Geographic Location

Activity Labor

Type 1 Number of Entities Number of

Activities Per

Respondent Burden Per

Activity

(Hours) Incremental Burden (Hours)

Domestic Foreign 2 Total Domestic Foreign Total

changes to their recordkeeping systems. This analysis assumes that 28 percent of domestic wholesalers import composite wood products or articles that contain composite wood pro ducts. In addition, it

is assumed that 57 percent of wholesalers are not already complying with the CARB ATCM and will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule.

12. While recordkeeping is required fo r all respondents, not all entities will incur additional recordkeeping burden and costs. This analysis assumes that some fabricators and wholesalers have existing

recordkeeping systems that are sufficient to meet the rule's requirements. Based on respon ses to EPA’s questionnaires, it is assumed that that 11 percent of fabricators and 43 percent of wholesalers will

have recurring recordkeeping costs. However, the analysis assumes that only 28 percent of domestic wholesalers import compos ite wood products or articles that contain composite wood products and

thus 43% of that 28% incur recurring recordkeeping burden. The customary business practices of the remaining fabricators, wh olesalers, and all retailers are assumed to be generally sufficient to meet

t he proposed rule’s recordkeeping requirements. For fabricators and wholesalers with burden, the analysis assumes that there is a fixed

- cost component of the recurring recordkeeping costs associated

with two hours of labor and a variable cost component tha t is proportional to a firm’s revenue. The variable cost factor is estimated by subtracting the fixed cost from the total re ported cost and then

dividing by the estimated average revenue for affected employer category. For fabricators, the fixed cost is $49.68, the total reported cost is $12,916.80, and the average revenue is $4,241,245. For

wholesalers, the fixed cost is $51.08, the total reported cost is $4,890.30, and the average revenue is $8,308,417. The resp ective variable cost factors are 0.30338 percent and 0.05933 percent of revenue.

The recurring recordkeeping burdens for employer fabricators and wholesalers are 520 and 195 hours per year, respectively. F or nonemployers, the average recurring recordkeeping burden is estimated

as the sum of th e burden associated with the fixed cost (2 hours) and the burden associated with the respective variable costs, which are cal culated as 0.30338 percent of average nonemployer fabricator

revenues ($42,690) and 0.05933 percent of average nonemployer wholesa ler revenues ($82,542). The resulting average fabricator and wholesaler nonemployer recurring recordkeeping burdens are 7.21

and 3.92 hours per year, respectively.

13. Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include

their name, the date the finished good was produced, and a statement of compliance. This analysis assumes that all producers , 67 percent of fabricat ors that are not already complying with the CARB

ATCM, and all fabricators that are already complying with the CARB ATCM will incur the cost associated with 3 hours of labor for making small changes to their labels. The remaining fabricators and

one perce nt of wholesalers are assumed to incur the average cost of the two firms that reported initial labeling costs in the fabricat or questionnaire (see the Economic Analysis for more details).

### Page 50 of 96 

## 1

6(b) Estimating Respondent Costs 2

3

Respondent costs are estimated by multiplying burden estimates from the previous 4

section with loaded wage rates, and adding in capital/startup costs and operating and 5

maintenance (O&M) costs. 6

7

(i) Wage Rates 8

9

The fully loaded unit labor cost for manager ial, technical, and clerical labor in the 10

regulated industry and for EPA staff is estimated by adding fringe benefits and overhead costs to 11

the hourly wage or annual salary for each category following the method described in Wage 12

Rates for Economic Analysi s of the Toxics Release Inventory Program . This section describes 13

the method employed to estimate the fully loaded unit labor costs for each labor category and 14

presents the results of the analysis. 15

16

Wage data used to calculate the labor costs are from th e May 2009 National Industry

17

Specific Occupational Employment and Wage Estimates estimated as part of the Bureau of 18

Labor Statistics’(BLS’) Occupational Employment Statistics Program (OES). 21 

## The values were 19

inflated to 2010 dollars using data from the BLS ’ Employer Costs for Employee Compensation 20

(ECEC) for all private industry for 2009 and 2010. 22 

## Thus, the analysis uses domestic wage rates 21

to estimate the costs for burden incurred by foreign firms. 22

23

The costs of fringe benefits (i.e., paid leave and ins urance) were estimated using the same 24

ECEC data for all private industry in 2010, resulting in a fringe benefit rate of 42 percent. An 25

additional loading factor of 17 percent is applied to wages to account for overhead. This 26

overhead loading factor is ad ded to the benefits loading factor, and the total (1.59) is then applied 27

to the base wage to derive the fully loaded wage. 28

29

The derivation of the fully loaded costs for managerial, technical, and clerical labor is 30

presented in Exhibit 6

- 15 . Note that two types of managerial labor costs are calculated

– one for 31

rule familiarization (a general managerial labor rate for wood pro duct manufacturing NAICS) 32

and one for testing and certification (a more specific managerial labor rate for composite panel 33

manufacturing NAICS). 34

35

21 U.S. Bureau of Labor Statistics (BLS) 2009

22 U.S. Bureau of Labor Statistics (BLS) 2011

### Page 51 of 96 Exhibit 6

- 15 : Derivation of Loaded Industry Wage Rates

Labor

Category Entity Type Burden Type Data Source for Wage Information Wage

($2010) Fringe and

Overhead Factor Loaded Wages

($2010)

(a) (b) (c) = (a)*(b)

Managerial Composite Panel Producers

Rule

Familiarization BLS OES , Managerial Occupations, NAICS

321000

- Wood Product Manufacturing $46.29

1.59 $73.60 Fabricators

Wholesalers BLS OES , Managerial Occupations, Sector 42

-

Wholesale Trade $58.67 $93.29

Retail ers BLS OES , Managerial Occupations, 321200

- Veneer, Plywood, and Engineered Wood Product

Manufacturing $44.47 $70.71

Composite Panel Producers Testing and

Certification,

Recordkeeping BLS OES , Managerial Occupations, 321200

- Veneer, Plywood, and Engineered Wood Product

Manufacturing $44.88 $71.36

Technical Fabricators / Wholesalers Labeling BLS OES , Computer and Mathematical Science

Occupations, 321200

- Veneer, Plywood, and

Engineered Wood Product Manufacturing $27.84 $44.27

Clerical Composite Panel Producers Recordkeeping

for Fabricators

and Wholesalers

/ Labeling for

Producers BLS OES , Office and Administrative Support

Occupations, NAICS 321000

- Wood Product

Manufacturing $15.62 $24.84 Fabricators

Wholesalers BLS OES , Office and Administrative Support

Occupations, Sector 42

- Wholesale Trade $16.06 $25.54

### Page 52 of 96 

## (ii) Costs Per Respondent

This section describes the recordkeeping and reporting costs for each respondent activity

as a result of the proposed TSCA Title VI Rule. The to tal cost is comprised of labor costs,

capital/start

- up costs, and operating and maintenance (O&M) costs. The latter two costs are

classified as non

- labor costs in this analysis. Labor costs are presented first since they are based

directly on the labor b urden and the loaded wage rates summarized above. Costs are broken out

such that each unique combination of (1) the number of responses per respondent and (2) per

response costs is classified as a separate activity.

Labor Costs

Exhibit 6

- 16 and Exhibit 6

- 17 summarize the tot al per

- activity recordkeeping and

reporting labor costs for all respondents over the first year, and second and third years of the

rule, respectively. Exhibit 6

- 18 presents the average labor costs over the first three years of the

rule, by activity. Exhibit 6

- 19 through Exhibit 6

- 21 present the same information as the previous

three tables, except for the incremental labor costs. These labor costs were estimated by

multiplying the labor burdens summarized in Exhibit 6

- 9 through Exhibit 6

- 14 by the loaded

wage rates presented in Exhibit 6

- 15 . As indicated, the estimated average annual total labor cost

over the first three years of the rule is approximately $ 307 million, while the incremental labor

costs are $ 242 million. The do mestic labor cost accounts for approximately 67 percent ($205

million) and 73 percent ($176 million) of these totals, respectively.

### Page 53 of 96 Exhibit 6

- 16 : Total (including baseline) First Year Labor Costs, by Activity and Geogra phic Location ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

1. Rule Familiarization

Producers 1

- - $108,928

- - $332,378

- - $441,306

Fabricators 1

- - $23,463,974

- - $9,150,835

- - $32,614,810

Wholesalers 2

- - $31,927,570

- - $12,451,603

- - $44,379,172

Retailers 3

- - $214,689,136

- - - - - $214,689,136

2. Certification Fee

- - - - - - - - -

3. Initia l On

- site Audit 4

With Existing Certifications

- - $23,406

- - $218,076

- - $241,482

Without Existing Certifications

- - $164,413

- - $208,371

- - $372,785

4. Develop Quality Control Manual 4

- - $822,067

- - $1,041,856

- - $1,863,923

5. Qualifying Test

- - - - - - - - - 6. Qualifying Test Shipment 4

1 Product

- - $214

- - $2,284

- - $2,498

2 Products

- - $10,276

- - $13,059

- - $23,335

7. Correlation Test 4

1 Product

- - $3,568

- - $45,670

- - $49,238

2 Products

- - $411,034

- - $520,928

- - $931,962

8. Quarterly On

- site Audit 4

Standard

- - $280,873

- - $512,936

- - $793,809

NAF (With New Certification)

- - $3,140

- - $60,228

- - $63,368

9. Large Scale Testing Fee

- - - - - - - - - 10. Large Scale Testing Shipment 4

Standard /ULEF Certification

- - $36,964

- - $83,277

- - $120,242

NAF (With New Certification)

- - $428

- - $7,564

- - $7,992

NAF (With Existing Certification)

- - $500 $4,995 $5,495

11. On

- site Audit Travel 4

- - - - - - - - -

12. Desk Audits 4

Standard Certification

- - $187,249

- - $341,957

- - $529,206

NAF (With New Certification)

- - $1,570

- - $30,114

- - $31,684

13. Purchase of Small Chamber Testi ng

Unit 

## - - - - - - - - -

14. Qu ality Control Testing 4

Standard Certification

- - $12,171,162



## - - $22,227,213



## - - $34,398,374

New NAF Certification

- - $102,045

- - $1,957,405

- - $2,059,450

15. Lost Product

- 

## - -

- - - - - -

16. Initi al Recordkeeping 5 $12,955,676



## - - $18,045,210



## - - $31,000,886

- - 17. Recurring Recordkeeping

Producers 4 $1,372,966



## - - $4,189,403



## - - $5,562,369



## - -

Fabricators with costs

- Employers 6 $46,887,984



## - - $18,367,690



## - - $65,255,674



## - -

### Page 54 of 96 Exhibit 6

- 16 : Total (including baseline) First Year Labor Costs, by Activity and Geogra phic Location ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

Fabricators with costs

- Nonemployers 6 $920,024



## - - $357,646



## - - $1,277,670



## - -

Fabricators without costs



## - - - - - - - - -

Wholesalers with costs

- Employers 5 $20,957,102



## - - $29,189,538



## - - $50,146,641



## - -

Wholesalers with costs

- Nonemployers 5 $610,100 

## - - $849,690 

## - - $1,459,815 

## - -

Wholesalers without costs



## - - - - - - - - -

Retailers



## - - - - - - - - -

18. Initial Labeling

Minor Changes

- Producers 6 $13,861



## - - $152,170



## - - $166,031



## - -

Minor Changes

– Fabricators 7

- $8,538,355



## -

- $3,318,391



## - - $11,856,746

-

Major Changes

– Producers 6 $688,068

- 

## - $268,272



## - - $956,340



## - -

Major Changes

- Fabricators and

Wholesalers 7 - $72,009,582



## - - $28,084,888



## - - $100,094,470

-

Total

- Year 1 $84,405,781 $80,547,937 $284,408,517 $71,419,619 $31,403,279 $49,210,749 $155,825,426 $111,951,216 $333,619,267

Notes: 1. The analysis uses a loaded wage rate of $73.60 for rule familiarization for composite panel producers and fabricato rs.

2. The analysis uses a loaded wage rate of $93.29 for rule familiarization for wholesalers.

3. The analysis uses a loaded wage rate of $70.71 for rule familiarization for retailers.

4. The analysis uses a loaded wage rate of $71.36 for testing and certification and recordkeeping for composite panel produce rs.

5. The analysis uses a l oaded wage rate of $25.54 for recordkeeping for wholesalers.

6. The analysis uses a loaded wage rate of $24.84 for recordkeeping for fabricators, and labeling for producers.

7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers.

### Page 55 of 96 Exhibit 6

- 17 : Total (including baseline) Second and Third Year Costs, by Activity and Geographic Location ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

1. Rule Familiarization

Producers 1



## - - - - - - - - -

Fa bricators 1



## - - - - - - - - -

Wholesalers 2



## - - - - - - - - -

Retailers 3



## - - - - - - - - -

2. Certification Fee



## - - - - - - - - -

3. Initial On

- site Audit 4

With Existing Certifications



## - - - - - - - - -

Without Existing Certifications



## - - - - - - - - -

4. Develop Quality Control Manual



## - - - - - - - - -

5. Qualifying Test



## - - - - - - - - -

6. Qualifying Test Shipment 7

1 Product



## - - - - - - - - -

2 Products



## - - - - - - - - -

7. Correlation Test 4

1 Product



## - - - - - - - - -

2 Products



## - - - - - - - - -

8. Quarterly On

- site Audit 4

Standard Certification



## - - $374,497



## - - $683,914



## - - $1,058,412

NAF (With New Certification)



## - - $3,140



## - - $60,228



## - - $63,368

9. Large Scale Testing F ee 

## - -

- 

## - -

- 

## - -

- 10. Large Scale Testing Shipment 4

Standard/ULEF Certification



## - - $49,238



## - - $111,036



## - - $160,275

NAF (With New Certification)



## - - $428



## - - $7,564



## - - $7,992

NAF (With Existing Certification)



## - - $500



## - - $4,995



## - - $5,495

11. On

- site Audit Travel



## - -

- 

## - -

- 

## - -

-

12. Desk Audits 4

Standard Certification



## - - $187,249

- - $341,957

- - $529,206

NAF (With New Certification)



## - - - - - - - - -

13. Purchase of Small Chamber

Testing Unit 

## - - - - - - - - -

14. Quality Control Testing 4

Standard Certification



## - - $12,171,162

- - $22,227,213

- - $34,398,374

### Page 56 of 96 Exhibit 6

- 17 : Total (including baseline) Second and Third Year Costs, by Activity and Geographic Location ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

New NAF Certification



## - - - - - - - - -

15. Lost Product



## - - - - - - - - -

16 . Initial Recordkeeping 5



## - - - - - - - - -

17. Recurring Recordkeeping

Producers 4 $1,372,966



## - - $4,189,403



## - - $5,562,369

Fabricators with costs

- Employers 6 $46,887,984



## - - $18,367,690



## - - $65,255,674



## - -

Fabricators with costs

Nonemployers 6 $920,024



## - - $357,646



## - - $1,277,670



## - -

Fabricators without costs



## - - - - - - - - -

Wholesalers with costs

- Employers 5 $20,957,102



## - - $29,189,538



## - - $50,146,641



## - -

Wholesalers with costs

- Nonemployers 5 $610,100



## - - $849,690



## - - $1,459,815



## - -

Wholesalers without costs



## - - - - - - - - -

Retailers



## - - - - - - - - -

18. Initial Labeling

Minor Changes

- Producers 6



## - - - - - - - - -

Mi nor Changes

– Fabricators 7



## - - - - - - - - -

Major Changes

– Producers 6



## - - - - - - - - -

Ma jor Changes

- Fabricators and

Wholesalers 7 

## - - - - - - - - -

Total

- Years 2 and 3 $70,748,176

- $12,786,214 $52,953,967



## - $23,436,907 $123,702,169



## - $36,223,122

Notes: 1. The analysis uses a loaded wage rate of $73.60 for rule familiarization for composite panel producers and fabricato rs.

2. The analysis uses a loaded wage rate of $93.29 for rule familiarization for wholesalers.

3. The analysis uses a loaded wage rate of $70.71 for rule familiarization for retailers.

4. The analysis uses a loaded wage rate of $71.36 for testing and certification and recordkeeping for composite pane l producers.

5. The analysis uses a loaded wage rate of $25.54 for recordkeeping for wholesalers.

6. The analysis uses a loaded wage rate of $24.84 for recordkeeping for fabricators, and labeling for producers.

7. The analysis uses a loaded wage rate of $4 4.27 for labeling for fabricators and wholesalers.

### Page 57 of 96 Exhibit 6

- 18 : Three Year Average Labor Costs (including baseline), by Activity and Geographic Location ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

1. Rule Familiarization

Producers 1



## - - $36,309

- - $110,793

- - $147,102

Fabricators 1



## - - $7,821,325

- - $3,050,278

- - $10,871,603

Wholesalers 2



## - - $10,642,523

- - $4,150,534

- - $14,793,057

Retailers 3



## - - $71,563,045

- - - - - $71,563,045

2. Certification Fee

- - - - - - - - -

3. Initial On

- site Audit 4

With Existing Certifications

- - $7,802

- - $72,692

- - $80,494

Without Existing

Certifications - - $54,804

- - $69,457

- - $124,262

4. Develop Quality Control

Manual 4 - - $274,022

- - $347,285

- - $621,308

5. Qualifying Test



## - - - - - - - - -

6. Qualifying Test Shipment 4

1 Product



## - - $71

- - $761

- - $833

2 Products



## - - $3,425

- - $4,353

- - $7,778

7. Correlation Test 4

1 Product



## - - $1,189

- - $15,223

- - $16,413

2 Products



## - - $137,011

- - $173,643

- - $310,654

8. Quarterly On

- site Audit 4

Standard Certification



## - - $343,289

- - $626,921

- - $970,211

NAF (With New

Certification) 

## - - $3,140

- - $60,228

- - $63,368

9. Large Scale Testing Fee



## - - - - - - - - -

10. Large Scale Testing Shipment 4

Standard/ULEF Certification



## - - $45,147

- - $101,783

- - $146,931

NAF (With New

Certification) 

## - - $428

- - $7,564

- - $7,992

NAF (With Existing

Certification) 

## - - $500

- - $4,995

- - $5,495

11. On

- site Audit Travel



## - - - - - - - - -

12. Desk Audits 4

Standard Certification



## - - $187,249

- - $341,957

- - $529,206

NAF (With New

Certification) 

## - - $523

- - $10,038

- - $10,561

13. Purchase of Small Chamber



## - - - - - - - - -

### Page 58 of 96 Exhibit 6

- 18 : Three Year Average Labor Costs (including baseline), by Activity and Geographic Location ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

Testing Unit

14. Quality Control Testing 4

Standard Certification



## - - $12,171,162

- - $22,227,213

- - $34,398,374

New NAF Certification



## - - $34,015

- - $652,468

- - $686,483

15. Lost Product



## - - - - - - - - -

16 . Initial Recordkeeping 5 $4,318,559



## - - $6,015,070



## - - $10,333,629



## - -

17. Recurring Recordkeeping

Producers 4 $1,372,966



## - - $4,189,403



## - - $5,562,369



## - -

Fabricators with costs

- Employers 6 $46,887,984



## - - $18,367,690



## - - $65,255,674



## - -

Fabricators with costs

- Nonemployers 6 $920,024



## - - $357,646



## - - $1,277,670



## - -

Fabricators without costs



## - - - - - - - - -

Wholesalers with costs

- Employers 5 $20,957,102



## - - $29,189,538



## - - $50,146,641



## - -

Wholesalers with costs

- Nonemployers 5 $610,100



## - - $849,690



## - - $1,459,815



## - -

Wholesalers without costs



## - - - - - - - - -

Retailers



## - - - - - - - - -

18. Initial Labeling

Minor Changes

– Producers 6 $4,620



## - - $50,723



## - - $55,344

- -

Minor Changes

–

Fabricators 7 - $2,846,118



## - - $1,106,130



## - - $3,952,249



## -

Major Change s

– Producers 6 $229,356



## - - $89,424



## - - $318,780

- -

Major Changes

- Fabricators

and Wholesalers 7 - $24,003,194



## - - $9,361,629



## - - $33,364,823



## -

Total

- Three Year Average $75,300,711 $26,849,312 $103,326,979 $59,109,184 $10,467,759 $32,028,186 $134,409,922 $37,317,072 $135,355,170

Notes: 1. The analysis uses a loaded wage rate of $73.60 for rule familiarization for composite panel producers and fabricators.

2. The analysis uses a loaded wage rate of $93.29 for rule familiarization for wholesalers.

3. The analysis uses a loaded wage rate of $70.71 for rule familiarization for retailers.

4. The analysis uses a loaded wage rate of $71.36 for te sting and certification and recordkeeping for composite panel producers.

5. The analysis uses a loaded wage rate of $25.54 for recordkeeping for wholesalers.

6. The analysis uses a loaded wage rate of $24.84 for recordkeeping for fabricators, and labeling for producers.

7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers.

### Page 59 of 96 Exhibit 6

- 19 : Incremental First Year Labor Costs, by Activity and Geographic Location ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

1. Rule Familiarization

Producers 1



## - - $108,928



## - - $332,378



## - - $441,306

Fabricators 1



## - - $23,463,974



## - - $9,150,835



## - - $32,614,810

Wholesalers 2



## - - $31,927,570



## - - $12,451,603



## - - $44,379,172

Retailers 3



## - - $214,689,136



## - - - - - $214,689,136

2. Certification Fee



## - - - - - - - - -

3. Initial On

- site Audit 4

With Existing Certifications



## - - $23,406



## - - $218,076



## - - $241,482

Without Existing

Certifications 

## - - $164,413



## - - $208,371



## - - $372,785

4. Develop Quality Cont rol

Manual 4 

## - - $822,067



## - - $1,041,856



## - - $1,863,923

5. Qualifying Test



## - - - - - -



## - - -

6. Qualifying Test Shipment 4

1 Product



## - - $214

- - $2,284

- - $2,498

2 Products



## - - $10,276



## - - $13,059



## - - $23,335

7. Correlation Test 4

1 Product



## - - $3,568

- - $45,670

- - $49,238

2 Products



## - - $411,034



## - - $520,928



## - - $931,962

8. Quarterly On

- site Audit 4

Uncertified to Standard



## - - $237,201



## - - $131,873



## - - $369,074

NAF (With New

Certification) 

## - - $3,140



## - - $60,228



## - - $63,368

9. Large Scale Testing Fee



## - - - - - - 

## - - -

10. Large Scale Testing Shipment 4

Uncertified to Standard



## - - $29,686

- - $16,484

- - $46,170

NAF (With New

Certification) 

## - - $428

- - $7,564

- - $7,992

11. On

- site Audit Travel



## - - - - - - - - -

12. Desk Audits 4

Uncertified to Standard



## - - $158,134



## - - $87,916



## - - $246,049

NAF (With New

Certification) 

## - - $1,570

- - $30,114

- - $31,684

13. Purchase of Small Chamber

Testing Unit 

## - - - - - - - - -

14. Quality Control Testing 4

### Page 60 of 96 Exhibit 6

- 19 : Incremental First Year Labor Costs, by Activity and Geographic Location ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

Standard Certification



## - - $10,278,694

- - $5,714,509

- - $15,993,203

New NAF Certification



## - - $102,045

- - $1,957,405

- - $2,059,450

15. Lost Product



## - - - - - - - - -

16. Initial Recordkeeping 5 $12,955,676



## - - $18,045,210



## - - $31,000,886



## - -

17. Recurring Recordkeeping

Producers 4 $1,372,966



## - - $4,189,403



## - - $5,562,369



## - -

Fabricators with costs

- Employers 6 $28,106,957



## - - $10,953,446



## - - $39,060,403



## - -

Fabricators with costs

- Nonemployers 6 $546,952



## - - $213,301



## - - $760,253



## - -

Fabricators without costs



## - - - - - - - - -

Wholesalers with costs

- Employers 5 $13,157,953



## - - $18,327,504



## - - $31,485,457



## - -

Wholesalers with co sts

- Nonemployers 5 $383,049



## - - $533,735



## - - $916,758



## - -

Wholesalers without costs



## - - - - - - - - -

Retailers



## - - - - - - - - -

18. Initial Labeling

Minor Changes

- Producers 6 $13,861



## - - $152,170



## - - $166,031

- 

## -

Minor Changes

–

Fabricators 7 - $8,538,355



## - - $3,318,391



## - - $11,856,746



## -

Major Changes

– Producers 6 $688,068

- 

## - $268,272



## - - $956,340

- 

## -

Major Changes

- Fabricators

and Wholesalers 7 - $72,009,582



## - - $28,084,888



## - - $100,094,470



## -

Total

- Year 1 $57,225,482 $80,547,937 $282,435,484 $52,683,041 $31,403,279 $31,991,153 $109,908,497 $111,951,216 $314,426,637

Notes: 1. The analysis uses a loaded wage rate of $73.60 for rule familiarization for composite panel producers and fabricators.

2. The analysis uses a loaded wage rate of $93.29 for rule familiarization for wholesalers.

3. The analysis uses a loaded wage rate of $70.71 for rule familiarization fo r retailers.

4. The analysis uses a loaded wage rate of $71.36 for testing and certification and recordkeeping for composite panel produce rs.

5. The analysis uses a loaded wage rate of $25.54 for recordkeeping for wholesalers.

6. The analysis uses a loaded wage rate of $24.84 for recordkeeping for fabricators and labeling for producers.

7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers.

### Page 61 of 96 Exhibit 6

- 20 : Incremental Second and Third Yea r Labor Costs, by Activity and Geographic Location ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

1. Rule Fa miliarization

Producers 1

- - - - - - - - -

Fabri cators 1

- - - - - - - - -

Wholesalers 2

- - - - - - - - -

Retailers 3

- - - - - - - - -

2. Ce rtification Fee

- - - - - - - - -

3. Initial On

- site Audit 4

With Existing Certifications

- - - - - - - - - Without Existing Certifications

- - - - - - - - - 4. Develop Quality Control Manual 4

- - - - - - - - - 5. Qualifying Test

- - - - - - - - - 6. Qu alifying Test Shipment 4

1 Product

- - - - - - - - -

2 Pro ducts

- - - - - - - - -

7. Correlation Test 4

1 Product

- - - - - - - - -

2 Pro ducts

- - - - - - - - - 8. Qu arterly On

- site Audit 4

Uncertified to Standard

- - $316,268

- - $175,831

- - $492,099

NAF (With New Certification)

- - $9,420

- - $180,684

- - $190,103

9. Large Scale Testing Fee

- - - - - - - - -

10. Large Scale Testing Shipment 4

Uncertified to Standard

- - $39,533

- - $21,979

- - $61,512

NAF (With New Certification)

- - $428

- - $7,564

- - $7,992

11. On

- site Audit Travel

- - - - - - - - -

12. D esk Audits 4

Uncertified to Standard

- - $158,134

- - $87,916

- - $246,049

NAF (With New Certification)

- - $6,280

- - $65,080

- - $71,360

13. P urchase of Small Chamber

Testing Unit

- - - - - - - - - 14. Quality Control Testing 4

Standard Certification

- - $10,278,694

- - $5,714,509

- - $15,993,203

New NAF Certification

- - - - - - - - -

15. L ost Product

- - - - - - - - - 16. Initial Recordkeeping 5

- - - - - - - - -

17. R ecurring Recordkeeping

Producers 4 $1,372,966

- - $4,189,403

- - $5,562,369

- -

Fabricators with costs

- Employers 6 $28,106,957

- - $10,953,446

- - $39,060,403

- -

Fabricators with cost s

- $546,952

- - $213,301

- - $760,253

- -

### Page 62 of 96 Exhibit 6

- 20 : Incremental Second and Third Yea r Labor Costs, by Activity and Geographic Location ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

Nonemployers 6

Fabricators without costs

- - - - - - - - -

Wholesalers with costs

- Employers 5 $13,157,953

- - $18,327,504

- - $31,485,457

- -

Wholesalers with costs

- Nonemployers 5 $383,049

- - $533,735

- - $916,758

- -

Wholesalers without costs

- - - - - - - - -

Retailers

- - - - - - - - - 18. Initial Labeling

Minor Changes

- Producers 6

- - - - - - - - -

Minor Changes

- Fabricators 7

- - - - - - - - - Major Changes

- Producers 6

- - - - - - - - - Major Changes

- Fabricators and

Wholesalers 7 - - - - - - - - -

To tal

- Years 2 and 3 $43,567,877

- $10,802,477 $34,217,389



## - $6,188,483 $77,785,240



## - $16,990,958

Notes: 1. The analysis uses a loaded wage rate of $73.60 for rule familiarization for composite panel producers and fabricators.

2. The analysis uses a loaded wage rate of $93.29 for rule familiarization for wholesalers.

3. The analysis uses a loaded wage rate of $70.71 for rule familiarization for retailers.

4. The analysis uses a loaded w age rate of $71.36 for testing and certification and recordkeeping for composite panel producers.

5. The analysis uses a loaded wage rate of $25.54 for recordkeeping for wholesalers.

6. The analysis uses a loaded wage rate of $24.84 for recordkeeping for f abricators and labeling for producers.

7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers.

### Page 63 of 96 Exhibit 6

- 21 : Three Year Average Incremental Labor Costs, by Activity and Geographic Loca tion ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

1. Rule Familiarization

Producers 1



## - - $36,309



## - - $110,793



## - - $147,102

Fabricators 1



## - - $7,821,325



## - - $3,050,278



## - - $10,871,603

Wholesalers 2



## - - $10,642,523



## - - $4,150,534



## - - $14,793,057

Retailers 3



## - - $71,563,045



## - - - - - $71,563,045

2. Certification Fee



## - - - - - - - - -

3. Initial On

- site Audit 4

With Existing Certifications



## - - $7,802

- - $72,692

- - $80,494

Without Existing

Certifications 

## - - $54,804

- - $69,457

- - $124,262

4. Develop Quality Control

Manual 4 

## - - $274,022

- - $347,285

- - $621,308

5. Qualifying Test



## - - - - - - - - -

6. Qualifying Test Shipment 4

1

- Product by TPC



## - - $71

- - $761

- - $833

2

- Product by TPC



## - - $3,425



## - - $4,353



## - - $7,778

7. Correlation Test 4

1

- Product by TPC



## - - $1,189

- - $15,223

- - $16,413

2

- Product by TPC



## - - $137,011

- - $173,643

- - $310,654

8. Quarterly On

- site Audit 4

Uncertified to Standard



## - - $289,912

- - $161,178

- - $451,091

NAF (With New

Certification) 

## - - $7,327

- - $140,532

- - $147,858

9. Large Scale Testing Fee



## - - - - - - - - -

10. Large Scale Testing Shipment 4

Uncertified to Standard



## - - $36,251

- - $20,147

- - $56,398

NAF (With New

Certification) 

## - - $428

- - $7,564

- - $7,992

11. On

- site Audit Travel



## - - - - - - - - -

12. Desk Audits 4

Uncertified to Standard



## - - $158,134

- - $87,916

- - $246,049

NAF (With New

Certification) 

## - - $523

- - $10,038

- - $10,561

13. Purchase of Small Chamber

Testing Unit 

## - - - - - - - - -

14. Qu ality Control Testing 4

### Page 64 of 96 Exhibit 6

- 21 : Three Year Average Incremental Labor Costs, by Activity and Geographic Loca tion ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

Standard Certification



## - - $10,278,694

- - $5,714,509

- - $15,993,203

New NAF Certification



## - - $34,015

- - $652,468

- - $686,483

15. Lost Product



## - - - - - - - - -

16. Initial Recordkeeping 5 $4,318,559

- - $6,015,070

- - $10,333,629

- - 17. Recurring Recordkeeping

Producers 4 $1,372,966



## - - $4,189,403



## - - $5,562,369



## - -

Fabricators with costs

- Employers 6 $28,106,957



## - - $10,953,446



## - - $39,060,403



## - -

Fabricators with costs

- Nonemployers 6 $546,952



## - - $213,301



## - - $760,253



## - -

Fabricators without costs



## - - - - - - - - -

Wholesalers with costs

- Employers 5 $13,157,953



## - - $18,327,504



## - - $31,485,457



## - -

Wholesalers with costs

- Nonemployers 5 $383,049



## - - $533,735



## - - $916,758



## - -

Wholesalers without costs



## - - - - - - - - -

Retailers



## - - - - - - - - -

18. Initial Labeling

Minor Changes

– Producers 6 $4,620



## - - $50,723



## - - $55,344



## -

Minor Changes

–

Fabricators 7 - $2,846,118

- - $1,106,130

- - $3,952,249

-

Major Changes

- Producers 6 $229,356

- - $89,424

- $318,780

- -

Major Changes

- Fabricators

and Wholesalers 7 - $24,003,194

- - $9,361,629

- - $33,364,823

-

Total

- Three Year Average $48,120,412 $26,849,312 $101,346,810 $40,372,606 $10,467,759 $14,789,371 $88,492,993 $37,31 7,072 $116,136,184

Notes: 1. The analysis uses a loaded wage rate of $73.60 for rule familiarization for composite panel producers and fabricato rs.

2. The analysis uses a loaded wage rate of $93.29 for rule familiarization for wholesalers.

3. The analysis uses a loaded wage rate of $70.71 for rule familiarization for retailers.

4. The analysis uses a loaded wage rate of $71.36 for testing and certification and recordkeeping for composite panel produce rs.

5. The analysis uses a loaded wage rate of $25.54 fo r recordkeeping for wholesalers.

6. The analysis uses a loaded wage rate of $24.84 for recordkeeping for fabricators and labeling for producers.

7. The analysis uses a loaded wage rate of $44.27 for labeling for fabricators and wholesalers.

### Page 65 of 96 

## Non

- Labor Costs

This subsection presents the non

- labor costs associated with the recordkeeping and

reporting requirements of the proposed TSCA Title VI rule. The different categories of

respondents (composite panel producers, fabricators, wholesalers, and retailers) are presented

separately because they engage indifferent activities. There are no activities that are common to

all respondents. Exhibit 6

- 23 through Exhibit 6

- 25 summarizes the number of respondents, per

respondent and total non

- labor costs for each response activity over the next three years. Exhibit

6

- 26 through Exhibit 6

- 28 present the corre sponding incremental costs.

(A). Composite Panel Producers

Composite panel producers will incur non

- labor costs from testing and certification

activities. As stated above, this analysis assumes that product lines that are certified under the

CARB ATCM w ill not have to submit new data or resubmit existing data to their TPC in order to

receive the equivalent certification under the TSCA Title VI regulations. In addition, this

analysis assumes that two percent of wood veneer laminated product producers wil l continue to

use added formaldehyde resins and thus be classified as hardwood plywood producers. These

entities are not certified by CARB and so will incur the burdens associated with first time

certification by a TPC.

Certification Fees (Activity #2)

CPA and HPVA charge administrative fees to mills for certifying their products. CPA

charges a quarterly fee of $1,500 regardless of NAF or ULEF status, which is equivalent to

$6,000 per year. HPVA charges an annual program fee of $4,500 to $5,500 (depe nding on

membership status) to mills that are not NAF or ULEF certified. Mills with ULEF or NAF

certifications are required to pay the standard annual program fee in the first year and an annual

fee of $2,700 to $3,700 in all subsequent years. This analy sis assumes that the annual

certification fee for mills with standard certification is $6,000, the fees for uncertified or

standard

- certified mills with new NAF certifications are $6,000 in the first year and $3,700 in all

subsequent years, and the annual certification fee for mills with a current NAF or ULEF

certification is $3,700. 23



### Exhibit 6

- 22 : Certification Fees

Cost Category Certification Type Fee

Initial Fee All $6,000

Annual Fee Standard $6,000

NAF/ULEF $3,700



## Qualifying Test (Activity #5)

Under TSCA Title VI, a composite panel producer is required to obtain five qualifying

tests for each product type (e.g., hardwood plywood

– veneer core) and production line from the

23 ULEF and N AF certifications apply to product lines, and not necessarily to the entire facility. Mills with multiple product

lines coul d have one or more lines certified as ULEF or NAF and other lines that are not. The ULEF and NAF testing costs do

not apply to any product lines that are not ULEF or NAF certified.

### Page 66 of 96 

## mill for which certification is sought. Th is ICR assumes that all qualifying testing is performed

using the primary test method, large chamber test, as defined by ASTM International Standard

E1333. This ICR assumes a cost of $480 per large scale test based on HPVA’s 2010 fee. 24 

## This

analysis assu mes that mills making product lines that have a standard certification or a NAF

certification under the CARB ATCM will not need to submit new data or resubmit existing data

to their existing TPC in order to receive the equivalent certification under the TS CA Title VI

regulations. Thus, producers that are already CARB compliant and are not expected to adopt a

more stringent certification type (e.g., NAF certification) will not incur this burden.

Qualifying Test Shipping (Activity #6)

Mills are expected t o ship at least five 4’ x 8’ panels for each product type via a

commercial shipping carrier. Panels must be dead

- stacked (i.e., having no layers between

panels), bundled air

- tight, wrapped in polyethylene, and protected by cover sheets. Based on

conversa tions with CPA and with CARB

- certified mills, the total shipping cost for the qualifying

tests is estimated to be approximately $200 per product line. This analysis assumes that mills

making product lines that are certified under the CARB ATCM will not ne ed to submit new data

or resubmit existing data to their existing TPC in order to receive the equivalent certification

under the TSCA Title VI regulations. Thus, producers that are already CARB compliant and are

not expected to adopt a more stringent cert ification type will not incur this burden.

Quarterly On

- site Audit (Activity #8)

The TPC is responsible for conducting on

- site visits to certified mills. Before the initial

certification, the TPC is expected to make at least one trip to the mill to inspect the mill’s quality

control systems and employees. During the initial visit, the TPC will assist the mill in setting up

quality control systems, including the small scale testing facility, if applicable, and methods for

selecting samples. After certification has been granted, the TPC is obligated to perform an on

site audit at least once quarterly, unless the mill obtains a ULEF or NAF certification. Audits

typically do not take more than one day of travel and visitation, though if the mill requires a

substantial number of modifications or is unprepared, the duration of the visit may be longer. 25



## The cost of the audit is borne by the composite panel producer and has two components:

audit fees and travel costs. Site audit fees can range from $300 to $450 for initial visits and from

$400 to $450 for quarterly visits, depending on the TPC. Based on these ranges, this analysis

assumes that will mills will pay a fee of $450 per visit.

As in the burden section, this analysis assumes that producers with new NAF

certifications will incur the costs associated with one on

- site audit (in add ition to the initial audit)

and two desk audits in the first year. The initial on

- site audit is assumed to be sufficient for

producers with existing ULEF or NAF certifications. All ULEF and NAF

- certified producers

will have one on

- site audit annually the reafter.

24 This is the rate charged by HPVA’s Reston Lab to non

- members for testin g panels. This lab charges non

- members $660 to

test doors, $840 to test finished engineered wood flooring, and $480 to test furniture and cabinets.

25 Personal Communication with HPVA 2011

### Page 67 of 96 

## Large Scale Testing Fees (Activity #9)

As described above, it is assumed that each large scale test costs $480. Mills are assumed

to perform large scale testing quarterly unless all products are certified as NAF. It is assumed

that mills with only NAF

- certified products will perform large scale testing annually. In the first

year, mills with added

- formaldehyde products will test those products three times in addition to

the qualifying testing, and mills with NAF products will test those once a t the end of the

qualifying process. Note that some respondents are assumed to have different certifications for

different product lines (i.e., combinations of standard , ULEF and NAF certifications )

.

Large Scale Testing Shipping (Activity #10)

Mills are expected to ship one 4’ x 8’ panel for each product type via a commercial

shipping carrier. Panels must be dead

- stacked (i.e., having no layers between panels), bundled

air

- tight, wrapped in polyethylene, and protected by cover sheets. Based on conversa tions with

CPA and with CARB

- certified mills, the total shipping cost for the quarterly tests is estimated to

be approximately $50 per product line. Note that some respondents are assumed to have different

certifications for different product lines (i.e., combinations of standard , ULEF and NAF

certifications )

.

On

- site Audit Travel (Activity #11)

Travel costs can vary depending on the relative location of the mill to the TPC; mills

within a close proximity may not incur any travel costs, whereas a mill across the country may

incur travel costs of up to $2,000 per visit. It is assumed that travel is only necessary for the

annual audits, as other intermediate audits can be performed by contracting inspectors closer to

the mill. Therefore, this analysis a ssumes that each annual audit costs $1,500 in travel costs. All

composite panel producers are assumed to incur this cost.

Desk Audits (Activity #12)

TPCs may conduct periodic “desk audits,” which are quality control checks performed

over the phone in wh ich the mill’s small scale testing procedures and data are reviewed. Desk

audits are assumed to occur monthly, except in months with quarterly on

- site audits. Based on

fees charged by CPA and HPVA, it is assumed that each desk audit costs $250.

As in th e burden section, this analysis assumes that producers with new NAF

certifications will incur the costs associated with two desk audits in the first year; none are

performed in subsequent years. No additional desk audits are assumed to be performed as a

r esult of this rule for respondents with existing NAF or ULEF certification.

Small Chamber Testing Unit (Activity #13)

This analysis assumes that all panel manufacturers that are required to perform routine

quality control testing will use their own small chamber testing unit rather than have the TPC

perform the testing. It is assumed that the unit costs $10,000 to purcha se.

### Page 68 of 96 

## Quality Control Testing (Activities #14)

To maintain certification, a mill must perform small scale quality control testing for each

certified product type and production line. Mills have the option of constructing an on

- site lab

and having it appr oved by a TPC, or contracting a certified third

- party lab to perform small scale

quality control testing. According to CPA and HPVA, particleboard and MDF mills already

have their own on

- site labs to test for formaldehyde (because they have to test their products on a

daily basis under the CARB ATCM), while most smaller hardwood plywood mills pay their TPC

to conduct their quality control testing. (In part because hardwood plywood mills often use

ULEF or NAF resins to qualify for exemptions from some of t he on

- going testing requirements

under the CARB ATCM.) However, the CARB ATCM allows mills to ship panels from

certified product lines before test results are available. By contrast, the proposed TSCA rule

requires mills to wait until test results indica te that the emissions standards have been met before

shipping a lot that has been tested. It is uncertain how often mills currently ship product from a

lot being tested before the test results are available and therefore it is uncertain how mills will

cho ose to comply with this requirement. It may be the case that some mills normally maintain a

level of inventory where they would typically not ship any panels before test results have been

determined for that lot, but other mills may ship out panels on the same day they are produced.

This analysis assumes that all mills that do not already do so will opt to set up and operate a

quality control testing facility on

- site, in order to minimize the time spent waiting for test results,

and to maximize their flex ibility to ship out panels shortly after they have been produced.

(Assuming that mills conduct on

- site testing may overstate the costs of this requirement if some

mills find it more cost effective to hold products in inventory until test results have been

determined by an outside lab. Producers that are already CARB compliant and are not expected

to adopt a more stringent certification type will not need to perform correlation testing.

HPVA typically uses a desiccator test for small scale testing, but s mall chamber tests may

also be performed. Each instance of desiccator testing requires three small samples to be cut

from a larger panel and tested. It is assumed that mills will incur fees of $70 per desiccator test

and $405 per small chamber test. The mean cost, weighted by the number of tests needed (three

for desiccator testing), is $154.

Lost Product (Activity #15)

Mills will need to forfeit a number of panels for initial and on

- going testing. Mills are

expected to ship five 4’ x 8’ panels per pr oduct type for qualifying testing. Producers will lose

one panel per product type for each day that quality control testing is performed . In addition to

routine small scale testing, standard certification and ULEF mills are assumed to send one panel

per product type to the TPC for large scale testing each quarter. However, product lines that are

certified as NAF are exempt from routine quality control testing after the three month qualifying

period, and need only have large scale testing performed annual ly. Note that the total

respondents with lost product costs presented in the exhibits below sum to more than the total

number of respondents because some respondents are assumed to have different certifications

for different product lines (i.e., combinat ions of standard , ULEF and NAF certifications )

.

### Page 69 of 96 

## This analysis estimated the cost of each panel using the average cost per square foot of

hardwood plywood, $0.49 and particleboard, $0.28 (RISI 2010). Assuming a panel size of 32 sq.

ft., each hardwood plyw ood panel will cost the mill $15.68, and each particleboard panel will

cost $8.96.

(B). Fabricators

Fabricators are subject to the proposed rule’s recordkeeping and labeling requirements.

However, not all fabricators incur the non

- labor costs associate d with proposed rule because 1)

they may already complying with the CARB ATCM ( Exhibit 6

- 6 ) or 2) their existing systems

are sufficient to meet the re quirements. As stated above, this analysis assumes that 98 percent of

wood veneer laminated product producers will likely switch to NAF resins and be classified as

fabricators. It is assumed that the entirety of this subset of fabricators will incur the non

- labor

costs associated with supplier notification.

As described in the Economic Analysis for the rulemaking, one respondent to the

fabricator questionnaire reported that that they would incur a one

- time cost of $250 for

purchasing new stamps for la beling. To remain consistent with the labor section, this cost was

averaged across the two firms that reported more significant costs. As a result, this analysis

assumes that the 33 percent of fabricators that are not CARB compliant in the baseline will incur

an initial non

- labor cost of approximately $125.00 ($250/2) associated with the labeling

requirements. There are not expected to be any non

- labor costs associated with recordkeeping

for fabricators.

(C). Wholesalers

Wholesalers are subject to th e proposed rule’s recordkeeping and labeling requirements.

This analysis assumes that 1 percent of wholesalers will repackage their products and so will

incur an initial non

- labor labeling cost. It is assumed that these wholesalers incur the same costs

a s the fabricators described above (an average of $125.00). In addition, not all wholesalers will

incur the non

- labor costs associated with recordkeeping because 1) they are already complying

with the CARB ATCM ( Exhibit 6

- 7 ), 2) their existing systems are sufficient to meet the

requirements, or 3) they do not import composite wood products or articles that contain

composite wood products and so are o nly required to keep ordinary business records.

As described in the Economic Analysis for the rulemaking, only one respondent to the

wholesaler questionnaire reported that they incurred non

- labor costs (a one

- time cost of $2,000

for programming changes). The average non

- labor cost is calculated for firms reporting

quantified costs. As a result, this analysis assumes that the 57 percent of wholesalers that import

composite wood products and/or articles that contain composite wood products will incur an

in itial non

- labor cost of approximately $1,000 ($2,000/2) associated with the recordkeeping

requirements (since one of two firms reporting costs reported a non

- labor cost of $2,000). As

indicated above, this analysis assumes that 28 percent of domestic whol esalers import composite

wood products and/or articles that contain composite wood products. There are not expected to

be any non

- labor costs associated with recurring recordkeeping costs.

### Page 70 of 96 

## (D). Retailers

As stated above, retailer’s customary business practices are assumed to be generally

sufficient to meet the proposed rule’s recordkeeping requirements. 26



## (E). Summary

Exhibit 6

- 23 and Exhibit 6

- 24 summarize the total (including baseline) per

- activity non

labor costs for all the respondents over the first year, and second and third years of the rule,

respectively. Exhibit 6

- 25 presents the average non

- labor costs over the first three years of the

rule, respectively. Exhibit 6

- 26 through Exhibit 6

- 28 mirror the previous three tables, except that

they account for incremental non

- labor costs (excluding baseline non

- labor costs) . Note that the

number of respondents cannot be summed across activities because many respondents are

incurring multiple burdens. As indicated, the average total annual non

- labor cost (including

baseline) over the first three years of the rule is estimated at approximately $ 35 million, while

the incremental non

- labor costs are $ 24 million. The domestic non

- labor costs account for

appro ximately 36 percent ($ 13 million) and 49 percent ($ 12 million) of these totals, respectively.

26 Personal Communication with C alifornia R etailers A ssociation 2011 ).

### Page 71 of 96 Exhibit 6

- 23 : Total (including baseline) First Year Non

- Labor Costs, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Response Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

1. Rule Familiarization

- 

## - - - - - - -

2. Certification Fee 2

Standard 3 328 599 927 1 6,000 $1,968,000 $3,594,000 $5,562,000

NAF (From Uncertified or Standard) 11 211 222 1 6,000 $66,000 $1,266,000 $1,332,000

NAF /ULEF (From NAF or ULEF) 31 319 350 1 3,700 $114,700 $1,180,300 $1,295,000

3. Initial On

- site Audit

With Existing Certifications 82 764 846 1 $450 $36,900 $343,800 $380,700

Without Existing Certifications 3,4 288 365 653 1 $450 $129,600 $164,250 $293,850

4. Develop Quality Control Manual

- 

## - - - - - - -

5. Qualifying Test 5

1 Product 5 64 69 5 480 $12,000 $153,600 $165,600

2 Products 3,4 288 365 653 10 $480 $1,382,400 $1,752,000 $3,134,400

6. Qualifying Test Shipping 5

1 Product 5 64 69 1 200 $1,000 $12,800 $13,800

2 Products 3,4 288 365 653 2 $200 $115,200 $146,000 $261,200

7. Correlation Test

- 

## - - - - - - -

8. Quarterly On

- site Audit 6

Standard 3,4 328 599 927 3 450 $442,800 $808,650 $1,251,450

NAF (With New Certification) 11 211 222 1 450 $4,950 $94,950 $99,900

9. Large Scale Testing Fee 7

1 Standard (Existing) 8 86 94 4 $480 $15,360 $165,120 $180,480

2 Standard (New) 3,4 277 154 431 6 $480 $797,760 $443,520 $1,241,280

2 Standard /ULEF (Existing) 54 473 527 8 $480 $207,360 $1,816,320 $2,023,680

1 NAF 3 22 25 1 $480 $1,440 $10,560 $12,000

2 NAF 25 351 376 2 480 $24,000 $336,960 $360,960

1 NAF and 1 ULEF 6 65 71 5 480 $14,400 $156,000 $170,400

10. Large Scale Testing Shipment 7

1 Standard (Existing) 8 86 94 4 $50 $1,600 $17,200 $18,800

2 Standard (New) 3,4 277 154 431 6 $50 $83,100 $46,200 $129,300

2 Standard (Existing) 54 473 527 8 $50 $21,600 $189,200 $210,800

1 NAF 3 22 25 1 $50 $150 $1,100 $1,250

2 NAF 25 351 376 2 $50 $2,500 $35,100 $37,600

1 NAF and 1 ULEF 6 65 71 5 $50 $1,500 $16,250 $17,750

11. On

- site Audit Travel 370 1,129 1,499 1 $1,500 $555,000 $1,693,500 $2,248,500

12. Desk Audits 8

Standard 3,4 328 599 927 8 $250 $656,000 $1,198,000 $1,854,000

NAF 11 211 222 2 $250 $5,500 $105,500 $111,000

### Page 72 of 96 Exhibit 6

- 23 : Total (including baseline) First Year Non

- Labor Costs, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Response Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

13. Purchase of Small Chamber Testing

Unit 3 282 208 490 1 $10,000 $2,820,000 $2,080,000 $4,900,000

14. Quality Control Testing

- 

## - - - - - - -

15. Lost Product 7

2 Standard (HWPW

- Existing) 3,4 10 109 119 528 $15.68 $82,790 $902,415 $985,206

1 NAF (HWPW

- New) 277 108 385 536 $15.68 $2,328,041 $907,684 $3,235,725

1 NAF (HWPW

- Existing) 8 87 95 8 $15.68 $1,004 $10,913 $11,917

2 NAF (HWPW

- New) 5 55 60 5 $15.68 $392 $4,312 $4,704

2 NAF (HWPW

- Existing) 11 211 222 142 $15.68 $24,492 $469,804 $494,296

1 Standard (PB/MDF

- Existing) 7 76 83 2 $15.68 $220 $2,383 $2,603

2 Standard (PB/MDF

- New) 3 22 25 265 $8.96 $7,123 $52,237 $59,360

2 Standard (PB/MDF

- Existing) 5 110 115 532 $8.96 $23,834 $524,339 $548,173

1 NAF (PB/MDF

- New) 33 250 283 528 $8.96 $156,119 $1,182,720 $1,338,839

1 NAF (PB/MDF

- Existing) 3 27 30 8 $8.96 $215 $1,935 $2,150

2 NAF (PB/MDF

- Existing) 7 64 71 2 $8.96 $125 $1,147 $1,272



### 1 NAF and 1 ULEF (PB/MDF

- Existing) 1 10 11 5 $8.96 $45 $448 $493

### Page 73 of 96 Exhibit 6

- 23 : Total (including baseline) First Year Non

- Labor Costs, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Response Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

16. Initial Recordkeeping 9 8,576 11,945 20,521 1 $1,000 $8,576,000 $11,945,000 $20,521,000

17. Recurring Recordkeeping

- 

## - - - - - - -

18. Initial Labeling 10

Minor Changes

- Producers

- 

## - - - - - - -

Minor Changes

- Fabricators

- 

## - - - - - - -

Major Changes

– Producers 3 277 108 385 1 $125 $34,625 $13,500 $48,125

Major Changes

- Fabricators and

Wholesalers 11 16,266 6,344 22,610 1 $125 $2,033,250 $793,000 $2,826,250

Total

- Year 1 $22,749,095 $34,638,718 $57,387,813

Notes: 1. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domestic value of

shipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analy sis assumes that there foreign retailers do not typically export composite wood

pro ducts or goods containing composite wood products into the United States. To remain consistent with the Economic Analysis, w hich assumes that there is uncertified product being imported into the U.S., the

analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.

2. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as har dwood plywood will incur costs to have their products certified by a TPC as a

result of the TSCA Title VI rule.

3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined as

hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use added formalde hyde resins.

4. This analysis assumes that mills will seek standard certification for uncertified product lines. The exceptions a re uncertified hardwood plywood producers, which are assumed to switch to NAF certification.

5. Producers that are already CARB compliant are assumed not to need to perform qualifying or correlation testing because it is assumed that their previous testing is sufficient.

6. On

- site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. This analysis assumes that producers with new NAF certifications will incur the burden associated

with one on

- site audit (in add ition to the initial audit) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the initial on

- site audit in

the first year. All producers with ULEF or NAF certification will have one on

- site audit annually thereafter.

7. The respondents sum to more than the total number of respondents because some respondents are assumed to have more than one certification type (i.e., standard , ULEF, and NAF )

. 8. Desk audits are assumed to occur mo nthly for standard certifications , except in months with a quarterly on

- site audit. Producers with new NAF certifications will incur the costs associated with two desk audits

in the first year; none are required in subsequent years. No desk audits are re quired for respondents with existing ULEF or NAF certification.

9. Firms that are manufacturers under TSCA (i.e., composite panel producers [ including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood produc ers ],

fabricators, and wholesalers that import composite wood products ) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meets the emissions standards.

However, composite panel producers a nd fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes th at 28 percent of domestic wholesalers import

composite wood products or articles that contain composite wood products. In addition , it is assumed that 57 percent of wholesalers that are not already complying with the CARB ATCM will have initial burden

to change their recordkeeping systems to comply with the TSCA Title VI rule.

10. Panel producers, fabricators, and wholesalers that p ackage or repackage composite wood products or finished goods containing composite wood products will need to modify their la bels to include their name,

the date the finished good was produced, and a statement of compliance. This analysis assumes that a ll 33 percent of fabricators that are not already complying with the CARB ATCM (because their products are

not sold in California) will incur a non

- labor cost of $125.00 for purchasing stamps for labeling. Producers and wholesalers are not expected to inc ur any non

- labor costs from initial labeling.

11. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added forma ldehyde resins.

### Page 74 of 96 Exhibit 6

- 24 : Total (including baselin e) Second and Third Year Non

- Labor Costs, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Response Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

1. Rule Familiarization

- - - - - - - -

2. Certification Fee 2

Standard 3 328 599 927 1 $6,000 $1,968,000 $3,594,000 $5,562,000

NAF (From Uncertified or Standard) 11 211 222 1 $3,700 $40,700 $780,700 $821,400

NAF/ULEF (From NAF or ULEF) 31 319 350 1 $3,700 $114,700 $1,180,300 $1,295,000

3. Initial On

- site Audit

With Existing Certifications

- - - - - - - - Without Existing Certifications 3,4

- - - - - - - - 4. Develop Quality Control Manual

- - - - - - - - 5. Qualifying Test 5

1 Product

- - - - - - - -

2 Products 3,4

- - - - - - - - 6. Qualifying Test Shipping 5

1 Product

- - - - - - - -

2 Products 3,4

- - - - - - - -

7. Correlation Test 5

- - - - - - - - 8. Quarterly On

- site Audit 6

Standard 3,4 328 599 927 4 $450 $590,400 $1,078,200 $1,668,600

NAF (With New Certification) 11 211 222 1 $450 $4,950 $94,950 $99,900

9. Large Scale Testing Fee 7

1 Standard (Existing) 8 86 94 4 $480 $15,360 $165,120 $180,480

2 Standard (New) 3,4 277 154 431 6 $480 $797,760 $443,520 $1,241,280

2 Standard/ULEF (Existing) 54 473 527 8 $480 $207,360 $1,816,320 $2,023,680

1 NAF 3 22 25 1 $480 $1,440 $10,560 $12,000

2 NAF 25 351 376 2 $480 $24,000 $336,960 $360,960

1 NAF and 1 ULEF 6 65 71 5 $480 $14,400 $156,000 $170,400

10. Large Scale Testing Shipment 7

1 Standard (Existing) 8 86 94 4 $50 $1,600 $17,200 $18,800

2 Standard (New) 3,4 277 154 431 6 $50 $83,100 $46,200 $129,300

2 Standard (Existing) 54 473 527 8 $50 $21,600 $189,200 $210,800

1 NAF 3 22 25 1 $50 $150 $1,100 $1,250

2 NAF 25 351 376 2 $50 $2,500 $35,100 $37,600

1 NAF and 1 ULEF 6 65 71 5 $50 $1,500 $16,250 $17,750

11. On

- site Audit Travel 370 1,129 1,499 1 $1,500 $555,000 $1,693,500 $2,248,500

12. Desk Audits 8

Standard 3,4 328 599 927 8 $250 $656,000 $1,198,000 $1,854,000

NAF

- - - - - - - - 13. Purchase of Small Chamber Testing Unit 3

- - - - - - - -

### Page 75 of 96 Exhibit 6

- 24 : Total (including baselin e) Second and Third Year Non

- Labor Costs, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Response Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

14. Quality Control Testing

- - - - - - - -

15. Lost Product 7

2 Standard (HWPW

- Existing) 3,4 10 109 119 528 $15.68 $82,790 $902,415 $985,206

1 NAF (HWPW

- New) 277 108 385 528 $15.68 $2,293,294 $894,136 $3,187,430

1 NAF (HWPW

- Existing) 8 87 95 8 $15.68 $1,004 $10,913 $11,917

2 NAF (HWPW

- New) 5 55 60 5 $15.68 $392 $4,312 $4,704

2 NAF (HWPW

- Existing) 11 211 222 2 $15.68 $345 $6,617 $6,962

1 Standard (PB/MDF

- Existing) 7 76 83 2 $15.68 $220 $2,383 $2,603

2 Standard (PB/MDF

- New) 3 22 25 265 $8.96 $7,123 $52,237 $59,360

2 Standard (PB/MDF

- Existing) 5 110 115 528 $8.96 $23,654 $520,397 $544,051

1 NAF (PB/MDF

- New) 33 250 283 528 $8.96 $156,119 $1,182,720 $1,338,839

1 NAF (PB/MDF

- Existing) 3 27 30 8 $8.96 $215 $1,935 $2,150

2 NAF (PB/MDF

- Existing) 7 64 71 2 $8.96 $125 $1,147 $1,272

1 NAF and 1 ULEF (PB/MDF

- Existing) 1 10 11 5 $8.96 $45 $448 $493

16. Initial Recordkeeping 9

- - - - - - - - 17. Recurring Recordkeeping

- - - - - - - - 18. Initial Labeling 10

Minor Changes

- Producers

- - - - - - - - Minor Changes

- Fabricators

- - - - - - - - Minor Changes

– Wholesalers 3

- - - - - - - - Major Changes

– Fabricators 11

- - - - - - - -

Total

- Years 2 and 3 $7,665,846 $16,432,841 $24,098,688

Notes: 1. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of impo rts for the affected fabricator NAICS to the total domestic

value of shipments for these NAICS (which is 39 percent) and 2) applyin g it to the number of domestic firms in each sector. The analysis assumes that there foreign retailers do not typically expo rt

composite wood products or goods containing composite wood products into the United States. To remain consistent with the Ec ono mic Analysis, which assumes that there is uncertified product being

imported into the U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of cer tified mills.

2. Since CARB does not certify wood veneer lamina ted products, all producers of wood veneer laminated products defined as hardwood plywood will incur costs to have their prod ucts certified by a

TPC as a result of the TSCA Title VI rule.

3. This analysis assumes that two percent of wood veneer laminated p roduct producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined

as hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use added formaldehyde resins.

4. This analysis assumes that mills will seek standard certification for uncertified product lines. The exceptions are unce rtified hardwood plywood producers, which are assumed to switch to NAF

certification.

5. Producers that are already CARB compliant are assumed not to need to perform qualifying or correlation testing because it is assumed that th eir previous testing is sufficient.

6. On

- site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. This analysis assumes that producers with new NAF certifications will incur the burden

associated with one on

- site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing ULEF or NAF cer ti fications under the CARB ATCM will only incur the

initial on

- site audit in the first year. All producers with ULEF or NAF certification will have one on

- site audit annually thereafter.

7. The respondents sum to more than the total number of respondents be cause some respondents are assumed to have more than one certification type (i.e., standard, ULEF, and NAF).

8. Desk audits for standard certifications are assumed to occur monthly, except in months with a quarterly on

- site audit. Producers with new NAF c ertifications will incur the costs associated with two

desk audits in the first year; none are required in subsequent years. No desk audits are required for respondents with exist ing ULEF or NAF certification.

9. Firms that are manufacturers under TSCA (i.e., composite panel producers [ including the estimated two percent of wood veneer laminated product producers defined as hardwood plywood

### Page 76 of 96 Exhibit 6

- 24 : Total (including baselin e) Second and Third Year Non

- Labor Costs, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Response Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

producers ], fabricators, and wholesalers that import composite wood products ) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meets

the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeepin g systems. This ana lysis assumes that 28 percent

of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying with

the CARB ATCM will have in itial burden to change their recordkeeping systems to comply with the TSCA Title VI rule.

10. Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods contai ning composite wood products will need to modify their labels to include

their name, the date the finished good was produced, and a statement of compliance. This analysis assumes that all 33 perc ent of fabricators that are not already complying with the CARB ATCM

(because their products are no t sold in California) will incur a non

- labor cost of $125.00 for purchasing stamps for labeling. Producers and wholesalers are not expected to incur any non

- labor costs

from initial labeling.

11. Total excludes the estimated 2 percent of wood veneer lamin ated product producers expected to continue to use added formaldehyde resins.

### Page 77 of 96 Exhibit 6

- 25 : Three Year Average Non

- Labor Costs (including baseline), by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Response Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

1. R ule Familiarization

- - - - - - - -

2. Certification Fee 2

Standard 3 328 599 927 1.0000 $6,000 $1,968,000 $3,594,000 $5,562,000

NAF (From Uncertified or Standard) 11 211 222 1.0000 $6,000 $49,133 $942,467 $991,600

NAF/ULEF (From NAF or ULEF) 31 319 350 1 .0000 $3,700 $114,700 $1,180,300 $1,295,000

3. Initial On

- site Audit

With Existing Certifications 82 764 846 0.3333 $450.00 $12,300 $114,600 $126,900

Without Existing Certifications 3,4 288 365 653 0.3333 $450.00 $43,200 $54,750 $97,950

4. Develop Quality Control Manual

- - - - - - - - 5. Qualifying Test 5

1 Product 5 64 69 1.6667 $480 $4,000 $51,200 $55,200

2 Products 3,4 288 365 653 3.3333 $480 $460,800 $584,000 $1,044,800

6. Qualifying Test Shipping 5

1 Product 5 64 69 0.3333 $200 $333 $4,267 $4,600

2 Products 3,4 288 365 653 0.6667 $200 $38,400 $48,667 $87,067

7. Correlation Test

- - - - - - - - 8. Quarterly On

- site Audit 6

Standard 3,4 328 599 927 3.6667 $450 $541,200 $988,350 $1,529,550

NAF (With New Certification) 11 211 222 1.0000 $450 $4,950 $94,950 $99,900

9. Large Scale Testing Fee 7

1 Standard (Existing) 8 86 94 4.0000 $480 $15,360 $165,120 $180,480

2 Standard (New) 3,4 277 154 431 6.0000 $480 $797,760 $443,520 $1,241,280

2 Standard /ULEF (Existing) 54 473 527 8.0000 $480 $207,360 $1,816,320 $2,023,680

1 NAF 3 22 25 1.0000 $480 $1,440 $10,560 $12,000

2 NAF 25 351 376 2.0000 $480 $24,000 $336,960 $360,960

1 NAF and 1 ULEF 6 65 71 5.0000 $480 $14,400 $156,000 $170,400

10. Large Scale Testing Shipment 7

1 Standard (Existing) 8 86 94 4.0000 $50 $1,600 $17,200 $18,800

2 Standard (New) 3,4 277 154 431 6.0000 $50 $83,100 $46,200 $129,300

2 Standard (Existing) 54 473 527 8.0000 $50 $21,600 $189,200 $210,800

1 NAF 3 22 25 1.0000 $50 $150 $1,100 $1,250

2 NAF 25 351 376 2.0000 $50 $2,500 $35,100 $37,600

1 NAF and 1 ULEF 6 65 71 5.0000 $50 $1,500 $16,250 $17,750

11. On

- site Audit Travel 370 1,129 1,499 1.0000 $1,500 $555,000 $1,693,500 $2,248,500

12. Desk Audits 8

Standard 3,4 328 599 927 8.0000 $250 $656,000 $1,198,000 $1,854,000

NAF 11 211 222 0.6667 $250 $1,833 $35,167 $37,000

13. Purchase of Small Chamber Testing Unit 3 282 208 490 0.3333 $10,000 $940,000 $693,333 $1,633,333

### Page 78 of 96 Exhibit 6

- 25 : Three Year Average Non

- Labor Costs (including baseline), by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Response Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

14. Quality Control Testing

- - - - - - - -

15. Lost Product 7

2 Standard (HWPW

- Existing) 3,4 10 109 119 528.0000 $15.68 $82,790 $902,415 $985,206

1 NAF (HWPW

- New) 277 108 385 530.6667 $15.68 $2,304,876 $898,652 $3,203,529

1 NAF (HWPW

- Existing) 8 87 95 8.0000 $15.68 $1,004 $10,913 $11,917

2 NAF (HWPW

- New) 5 55 60 5.0000 $15.68 $392 $4,312 $4,704

2 NAF (HWPW

- Existing) 11 211 222 48.6667 $15.68 $8,394 $161,013 $169,407

1 Standard (PB/MDF

- Existing) 7 76 83 2.0000 $15.68 $220 $2,383 $2,603

2 Standard (PB/MDF

- New) 3 22 25 265.0000 $8.96 $7,123 $52,237 $59,360

2 Standard (PB/MDF

- Existing) 5 110 115 529.3333 $8.96 $23,714 $521,711 $545,425

1 NAF (PB/MDF

- New) 33 250 283 528.0000 $8.96 $156,119 $1,182,720 $1,338,839

1 NAF (PB/MDF

- Existing) 3 27 30 8.0000 $8.96 $215 $1,935 $2,150

2 NAF (PB/MDF

- Existing) 7 64 71 2.0000 $8.96 $125 $1,147 $1,272

1 NAF and 1 ULEF (PB/MDF

- Existing) 1 10 11 5.0000 $8.96 $45 $448 $493

16. Initial Recordkeeping 9 8,576 11,945 20,521 0.3333 $1,000 $2,858,667 $3,981,667 $6,840,333

17. Recurring Recordkeeping

- - - - - - - - 18. Initial Labeling 10

Minor Changes

- Producers

- - - - - - - - Minor Changes

- Fabricators

- - - - - - - - Major Changes

– Producers 3 277 108 385 0.3333 $125.00 $11,542 $4,500 $16,042

Major Changes

- Fabricators and

Wholesalers 11 16,266 6,344 22,610 0.3333 $125.00 $677,750 $264,333 $942,083

Three

- Year Average Cost $12,693,595 $22,501,467 $35,195,063

### Page 79 of 96 Exhibit 6

- 25 : Three Year Average Non

- Labor Costs (including baseline), by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Response Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

Notes: 1. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domestic

value of shipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assumes that t here foreign retailers do not typically export

composite wood products or goods containing composite wood products into the United States. To remain consistent with the Ec onomic Analysis, which assumes that there is uncertified product being

imported into the U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mills.

2. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as har dwood plywood will incur costs to have their products certified by a

TPC as a result of the TSCA Title VI rule.

3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined

as hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use ad ded formaldehyde resins.

4. This analysis assumes that mills will seek standar d certification for uncertified product lines. The exceptions are uncertified hardwood plywood producers, which are assumed to switch to NAF

certification.

5. Producers that are already CARB compliant are assumed not to need to perform qualifying or corre lation testing because it is assumed that their previous testing is sufficient.

6. On

- site audits must be conducted at least once quarterly, unless the mill obtains ULEF or NAF certification. This analysis assum es that producers with new NAF certifications will incur the burden

associated with one on

- site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing ULEF or NAF cer tifications under the CARB ATCM will only incur the

initial on

- site audit in the firs t year. All producers with ULEF or NAF certification will have one on

- site audit annually thereafter.

7. The respondents sum to more than the total number of respondents because some respondents are assumed to have more than on e certification type (i.e., standard, ULEF, and NAF certifications).

8. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on

- site audit. Producers with new NAF certifications will incur the costs associated with two

desk audits i n the first year; none are required in subsequent years. No desk audits are required for respondents with existing ULEF or N AF certification.

9. Firms that are manufacturers under TSCA (i.e., composite panel producers [ including the estimated two percen t of wood veneer laminated product producers defined as hardwood plywood

producers ], fabricators, and wholesalers that import composite wood products ) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that th e product meets

the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeepin g systems. This analysis assumes that 28 percent

of domestic wholesalers import composi te wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying with

the CARB ATCM will have initial burden to change their recordkeeping systems to comply with th e TSCA Title VI rule.

10. Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods contai ning composite wood products will need to modify their labels to include

their name, the date the finished go od was produced, and a statement of compliance. This analysis assumes that all 33 percent of fabricators that are not alread y complying with the CARB ATCM

(because their products are not sold in California) will incur a non

- labor cost of $125.00 for purch asing stamps for labeling. Producers and wholesalers are not expected to incur any non

- labor costs

from initial labeling.

11. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added forma ldehyde resins.

### Page 80 of 96 Exhibit 6

- 26 : Incremental First Year Non

- Labor Costs, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Activity Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

1. Rule Familiarization

- - - - - - - -

2. Certification Fee 2

Uncertified to Standard 3,4 277 154 431 1 $6,000 $1,662,000 $924,000 $2,586,000

NAF (With New Certification) 11 211 222 1 $6,000 $66,000 $1,266,000 $1,332,000

3. Initial On

- site Audit

With Existing Certifications 82 764 846

- $450



## -

- - Without Existing Certifications 3,4 288 365 653 1 $450 $129,600 $164,250 $293,850

4. Develop Quality Control Manual

- - - - - - - - 5. Qualifying Test 5

1 Product 5 64 69 5 $480 $12,000 $153,600 $165,600

2 Products 3,4 288 365 653 10 $480 $1,382,400 $1,752,000 $3,134,400

6. Qualifying Test Shipping 5

1 Product 5 64 69 1 $200 $1,000 $12,800 $13,800

2 Products 3,4 288 365 653 2 $200 $115,200 $146,000 $261,200

7. Correlation Test 5

- - - - - - - - 8. Quarterly On

- site Audit 6

Uncertified to Standard 3,4 277 154 431 3 $450 $373,950 $207,900 $581,850

NAF (With New Certification) 11 211 222 1 $450 $4,950 $94,950 $99,900

9. Large Scale Testing Fee

1 New Standard 5 64 69 3 $480 $7,200 $92,160 $99,360

2 New Standard 3,4 277 154 431 6 $480 $797,760 $443,520 $1,241,280

2 ULEF to 2 Standard 11 114 125 6 $480 $31,680 $328,320 $360,000

1 New NAF 6 65 71 1 $480 $2,880 $31,200 $34,080

2 New NAF 5 146 151 2 $480 $4,800 $140,160 $144,960

1 NAF and 1 ULEF 6 65 71 5 $480 $14,400 $156,000 $170,400

10. Large Scale Testing Shipment

1 New Standard 5 64 69 3 $50 $750 $9,600 $10,350

2 New Standard 3,4 277 154 431 6 $50 $83,100 $46,200 $129,300

2 ULEF to 2 Standard 11 114 125 6 $50 $3,300 $34,200 $37,500

1 New NAF 6 65 71 1 $50 $300 $3,250 $3,550

2 New NAF 5 146 151 2 $50 $500 $14,600 $15,100

1 NAF and 1 ULEF 6 65 71 5 $50 $1,500 $16,250 $17,750

11. On

- site Audit Travel 288 365 653 1 $1,500 $432,000 $547,500 $979,500

12. Desk Audits 7

Uncertified to Standard 3,4 277 154 431 8 $250 $554,000 $308,000 $862,000

NAF (With New Certification) 11 211 222 2 $250 $5,500 $105,500 $111,000

13. Purchase of Small Chamber Testing Unit 2 282 208 490 1 $10,000 $2,820,000 $2,080,000 $4,900,000

### Page 81 of 96 Exhibit 6

- 26 : Incremental First Year Non

- Labor Costs, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Activity Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

14. Quality Control Testing

- - - - - - - -

15. Lost Product

2 Standard (HWPW

– Existing) 3,4 10 109 119 416 $15.68 $65,229 $710,994 $776,223

2 Standard (HWPW

- New) 3,4 277 108 385 536 $15.68 $2,328,041 $907,684 $3,235,725

2 NAF (HWPW

- New) 11 211 222 142 $15.68 $24,492 $469,804 $494,296

2 Standard (PB/MDF

- New) 5 110 115 268 $8.96 $12,006 $264,141 $276,147

16. Initial Recordkeeping 8 8,576 11,945 20,521 1 $1,000 $8,576,000 $11,945,000 $20,521,000

17. Recurring Recordkeeping

- - - - - - - - 18. Initial Labeling 9

Minor Changes

- Producers

- - - - - - - - Minor Changes

- Fabricators

- - - - - - - - Major Changes

– Producers 3 277 108 385 1 $125 $34,625 $13,500 $48,125

Major Changes

- Fabricators and Wholesalers 10 16,266 6,344 22,610 1 $125 $2,033,250 $793,000 $2,826,250

Total

- Year 1 $21,580,413 $24,182,083 $45,762,496

Notes: 1. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domestic

value of shipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typica lly export composite

wood products or goods containing composite wood products into the United States. To remain consistent with t he Economic Analysis, which assumes that there is uncertified product being imported

into the U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mi lls.

2. This analysis assumes that mills wil l seek standard certification for uncertified product lines. The exceptions are uncertified hardwood plywood producers, whic h are assumed to switch to NAF

certification.

3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined

as hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use ad ded formaldehyd e resins.

4. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as har dwood plywood will incur costs to have their products certified by a

TPC as a result of the TSCA Title VI rule.

5. Producers that are already CARB compliant are not assumed to need to perform qualifying or correlation testing because it is assumed that their previous testing is sufficient.

6. On

- site audits must be conducted at least once quarterly, unless the mill obt ains ULEF or NAF certification. This analysis assumes that producers with new NAF certifications will incur the burden

associated with one on

- site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the

initial on

- site audit in the first year. All producers with ULEF or NAF certification will have one on

- site audit annually thereafter.

7. Desk audits are assumed to occur monthly for standard certifications, except in months with a quarterly on

- site audit. Producers with new NAF certifications will incur the costs associated with two

desk audits in the first year; none are required in subsequent years. No desk audits are required for responde nts with existing ULEF or NAF certification.

8. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneer lamina ted product producers defined as hardwood plywood

producers], fabricators, and wholesalers that import composite wood products ) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meets

the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent

of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed tha t 57 percent of wholesalers that are not already complying with

the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule.

9. Panel producers, fabricators, and wholesalers that package or repackage c omposite wood products or finished goods containing composite wood products will need to modify their labels to include

their name, the date the finished good was produced, and a statement of compliance. This analysis assumes that all 33 percen t of fabric ators that are not already complying with the CARB ATCM

(because their products are not sold in California) will incur a non

- labor cost of $125.00 for purchasing stamps for labeling. Producers and wholesalers are not expected to incur any non

- labor costs

from initial labeling.

### Page 82 of 96 Exhibit 6

- 26 : Incremental First Year Non

- Labor Costs, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Activity Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

10. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added forma ldehyde resins.

### Page 83 of 96 Exhibit 6

- 27 : Incremental Second and Third Year Non

- Labor Cos ts, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Activity Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

1 . Rule Familiarization

- - - - - - - -

3. Certification Fee 2

Uncertified to Standard 3,4 277 154 431 1 $6,000 $1,662,000 $924,000 $2,586,000

NAF (With New Certification) 11 211 222 1 $3,700 $40,700 $780,700 $821,400

4. Initial On

- site Audit

With Existing Certifications

- - - - - - - - Without Existing Certifications 3,4

- - - - - - - - 5. Develop Quality Control Manual

- - - - - - - - 6. Qualifying Test 5

1 Product

- - - - - - - -

2 Products 3,4

- - - - - - - - 7. Qualifying Test Shipping 5

1 Product

- - - - - - - -

2 Products 3,4

- - - - - - - -

8. Correlation Test 5

- - - - - - - - 9. Quarterly On

- site Audit 6

Uncertified to Standard 3,4 277 154 431 4 $450 $498,600 $277,200 $775,800

NAF (With New Certification) 11 211 222 3 $450 $14,850 $284,850 $299,700

10. Large Scale Testing Fee

1 New Standard 5 64 69 4 $480 $9,600 $122,880 $132,480

2 New Standard 3,4 277 154 431 8 $480 $1,063,680 $591,360 $1,655,040

2 ULEF to 2 Standard 11 114 125 6 $480 $31,680 $328,320 $360,000

1 New NAF 6 65 71 1 $480 $2,880 $31,200 $34,080

2 New NAF 5 146 151 2 $480 $4,800 $140,160 $144,960

1 NAF and 1 ULEF 6 65 71 5 $480 $14,400 $156,000 $170,400

11. Large Scale Testing Shipment

1 New Standard 5 64 69 4 $50 $1,000 $12,800 $13,800

2 New Standard 3,4 277 154 431 8 $50 $110,800 $61,600 $172,400

2 ULEF to 2 Standard 11 114 125 6 $50 $3,300 $34,200 $37,500

1 New NAF 6 65 71 1 $50 $300 $3,250 $3,550

2 New NAF 5 146 151 2 $50 $500 $14,600 $15,100

1 NAF and 1 ULEF 6 65 71 5 $50 $1,500 $16,250 $17,750

12. On

- site Audit Travel 288 365 653 1 $1,500 $432,000 $547,500 $979,500

13. Desk Audits 7

Uncertified to Standard 3,4 277 154 431 8 $250 $554,000 $308,000 $862,000

NAF (With New Certification)

- - - - - - - -

14. Purchase of Small Chamber Testing Unit

- - - - - - - - 15. Quality Control Testing

- - - - - - - -

### Page 84 of 96 Exhibit 6

- 27 : Incremental Second and Third Year Non

- Labor Cos ts, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities Per

Respondent Cost Per

Activity Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

16. Lost Product

2 Standard (HWPW

– Existing) 3,4 10 109 119 416 $16 $65,229 $710,994 $776,223

2 Standard (HWPW

- New) 3,4 277 108 385 528 $16 $2,293,294 $894,136 $3,187,430

2 NAF (HWPW

- New) 11 211 222 2 $16 $345 $6,617 $6,962

2 Standard (PB/MDF

- New) 5 110 115 264 $9 $11,827 $260,198 $272,026

17. Initial Recordkeeping 8

- - - - - - - - 18. Recurring Recordkeeping

- - - - - - - - 19. Initial Labeling 9

Minor Changes

- Producers

- - - - - - - - Minor Changes

- Fabricators

- - - - - - - - Major Changes

– Producers 3

- - - - - - - - Major Changes

- Fabricators and Wholesalers 10

- - - - - - - -

Total

- Years 2 and 3 $6,817,285 $6,506,816 $13,324,101

Notes: 1. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domestic

value of shipments for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assumes that foreign retailers do not typica lly export composite

wood products or goods containing composite wood products into the United States. To remain consistent with t he Economic Analysis, which assumes that there is uncertified product being imported

into the U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mi lls.

2. This analysis assumes that mills wil l seek standard certification for uncertified product lines. The exceptions are uncertified hardwood plywood producers, whic h are assumed to switch to NAF

certification.

3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined

as hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assumed to continue to use ad ded formaldehyd e resins.

4. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as har dwood plywood will incur costs to have their products certified by a

TPC as a result of the TSCA Title VI rule.

5. Producers that are already CARB compliant are not assumed to need to perform qualifying or correlation testing because it is assumed that their previous testing is sufficient.

6. On

- site audits must be conducted at least once quarterly, unless the mill obt ains ULEF or NAF certification. This analysis assumes that producers with new NAF certifications will incur the burden

associated with one on

- site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing ULEF or NAF certifications under the CARB ATCM will only incur the

initial on

- site audit in the first year. All producers with ULEF or NAF certification will have one on

- site audit annually thereafter.

7. Desk audits are assumed to occur monthly for standard certifications , except in months with a quarterly on

- site audit. Producers with new NAF certifications will incur the costs associated with two

desk audits in the first year; none are required in subsequent years. No desk audits are required for responde nts with existing ULEF or NAF certification.

8. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneer lamina ted product producers defined as hardwood plywood

producers], fabricators, and wholesalers that import composite wood products ) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meets

the emissions standards. However, composite panel producers and fabricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent

of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed tha t 57 percent of wholesalers that are not already complying with

the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule.

9. Panel producers, fabricators, and wholesalers that package or repackage c omposite wood products or finished goods containing composite wood products will need to modify their labels to include

their name, the date the finished good was produced, and a statement of compliance. This analysis assumes that all 33 percen t of fabric ators that are not already complying with the CARB ATCM

(because their products are not sold in California) will incur a non

- labor cost of $125.00 for purchasing stamps for labeling. Producers and wholesalers are not expected to incur any non

- labor costs

from initial labeling.

10. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added forma ldehyde resins.

### Page 85 of 96 Exhibit 6

- 28 : Three Year Average Incremental Non

- Labor Costs, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities

Per

Respondent Cost Per

Activity Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

1. Rule Fam iliarization

- - - - - - - -

2. Certification Fee 2

Uncertified to Standard 3,4 277 154 431 1.0000 $6,000.00 $1,662,000 $924,000 $2,586,000

NAF (With New Certification) 11 211 222 1.0000 $4,466.67 $49,133 $942,467 $991,60

3. Initial On

- site Audit

With Existing Certifications 82 764 846

- $450.00

- - - Without Existing Certifications 3,4 288 365 653 0.3333 $450.00 $43,200 $54,750 $97,950

4. Develop Quality Control Manual

- - - - - - - - 5. Qualifying Test 5

1 Product 5 64 69 1.6667 $480 $4,000 $51,200 $55,200

2 Products 3,4 288 365 653 3.3333 $480 $460,800 $584,000 $1,044,800

6. Qualifying Test Shipping 5

1 Product 5 64 69 0.3333 $200 $333 $4,267 $4,600

2 Products 3,4 288 365 653 0.6667 $200 $38,400 $48,667 $87,067

7. Correlation Test

- - - - - - - - 8. Quarterly On

- site Audit 5

Uncertified to Standard 3,4 277 154 431 3.6667 $450 $457,050 $254,100 $711,150

NAF (With New Certification) 11 211 222 2.3333 $450 $11,550 $221,550 $233,100

9. Large Scale Testing Fee

1 New Standard 5 64 69 3.6667 $480 $8,800 $112,640 $121,440

2 New Standard 3,4 277 154 431 7.3333 $480 $975,040 $542,080 $1,517,120

2 ULEF to 2 Standard 11 114 125 6.0000 $480 $31,680 $328,320 $360,000

1 New NAF 6 65 71 1.0000 $480 $2,880 $31,200 $34,080

2 New NAF 5 146 151 2.0000 $480 $4,800 $140,160 $144,960

1 NAF and 1 ULEF 6 65 71 5.0000 $480 $14,400 $156,000 $170,400

10. Large Scale Testing Shipment

1 New Standard 5 64 69 3.6667 $50 $917 $11,733 $12,650

2 New Standard 3,4 277 154 431 7.3333 $50 $101,567 $56,467 $158,033

2 ULEF to 2 Standard 11 114 125 6.0000 $50 $3,300 $34,200 $37,500

1 New NAF 6 65 71 1.0000 $50 $300 $3,250 $3,550

2 New NAF 5 146 151 2.0000 $50 $500 $14,600 $15,100

1 NAF and 1 ULEF 6 65 71 5.0000 $50 $1,500 $16,250 $17,750

11. On

- site Audit Travel 288 365 653 1.0000 $1,500 $432,000 $547,500 $979,500

12. Desk Audits 7

Uncertified to Standard 3,4 277 154 431 8.0000 $250.00 $554,000 $308,000 $862,000

NAF (With New Certification) 11 211 222 0.6667 $250 $1,833 $35,167 $37,000

13. Purchase of Small Chamber Testing Unit 282 208 490 0.3333 $10,000 $940,000 $693,333 $1,633,333

### Page 86 of 96 Exhibit 6

- 28 : Three Year Average Incremental Non

- Labor Costs, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities

Per

Respondent Cost Per

Activity Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

14. Quality Control Testing

- - - - - - - -

15. Lost Product

2 Standard (HWPW

– Existing) 3,4 10 109 119 416.0000 $16 $65,229 $710,994 $776,223

2 Standard (HWPW

- New) 3,4 277 108 385 530.6667 $16 $2,304,876 $898,652 $3,203,529

2 NAF (HWPW

- New) 11 211 222 48.6667 $16 $8,394 $161,013 $169,407

2 Standard (PB/MDF

- New) 5 110 115 265.3333 $9 $11,887 $261,513 $273,399

16. Initial Recordkeeping 8 8,576 11,945 20,521 0.3333 $1,000 $2,858,667 $3,981,667 $6,840,333

17. Recurring Recordkeeping

- - - - - - - -

18. Initial Labeling 9

Minor Changes

- Producers

- - - - - - - - Minor Changes

- Fabricators

- - - - - - - - Major Changes

– Producers 3 277 108 385 0.3333 $125.00 $11,542 $4,500 $16,042

Major Changes

- Fabricators and

Wholesalers 10 16,266 6,344 22,610 0.3333 $125.00 $677,750 $264,333 $942,083

Three

- Year Average Cost $11,738,328 $12,398,573 $24,136,899

Notes: 1. The numbers of foreign fabricators, and wholesalers were estimated by 1) calculating the ratio of the total customs value of imports for the affected fabricator NAICS to the total domestic

value of shipment s for these NAICS (which is 39 percent) and 2) applying it to the number of domestic firms in each sector. The analysis assu mes that foreign retailers do not typically export composite

wood products or goods containing composite wood products into the Uni ted States. To remain consistent with the Economic Analysis, which assumes that there is uncertified product being imported

into the U.S., the analysis estimates the number of certified foreign mills as 20 percent of the total number of certified mi lls.

2. This analysis assumes that mills will seek standard certification for uncertified product lines. The exceptions are unce rtified hardwood plywood producers, which are assumed to switch to NAF

certification.

3. This analysis assumes that two percent of wood veneer laminated product producers (277 domestic entities) will continue to use added formaldehyde resins and therefore their products will be defined

as hardwood plywood. A similar proportion of foreign laminators exporting to the U.S. are also assu med to continue to use added formaldehyde resins.

4. Since CARB does not certify wood veneer laminated products, all producers of wood veneer laminated products defined as har dwood plywood will incur costs to have their products certified by a

TPC as a res ult of the TSCA Title VI rule.

5. Producers that are already CARB compliant are not assumed to need to perform qualifying or correlation testing because it is assumed that their previous testing is sufficient.

6. On

- site audits must be conducted at least o nce quarterly, unless the mill obtains ULEF or NAF certification. This analysis assumes that producers with new NAF certifications will incur the burden

associated with one on

- site audit (in addition to the initial audit) and two desk audits in the first year. Producers with existing ULEF or NAF certi fications under the CARB ATCM will only incur the

initial on

- site audit in the first year. All producers with ULEF or NAF certification will have one on

- site audit annually thereafter.

7. Desk audits are assumed to occur monthly for standard certifications , except in months with a quarterly on

- site audit. Producers with new NAF certifications will incur the costs associated with two

desk audits in the first year; none are required in subsequent years. No desk audits are require d for respondents with existing ULEF or NAF certification.

8. Firms that are manufacturers under TSCA (i.e., composite panel producers [including the estimated two percent of wood veneer lamina ted product producers defined as hardwood plywood

producers], fabricators, and wholesalers that import composite wood products ) must keep records showing the date of purchase, the supplier, and all precautions taken to ensure that the product meets

the emissions standards. However, composite panel producers and fa bricators are not expected to need to make any initial changes to their recordkeeping systems. This analysis assumes that 28 percent

of domestic wholesalers import composite wood products or articles that contain composite wood products. In addition, it is assumed that 57 percent of wholesalers that are not already complying with

the CARB ATCM will have initial burden to change their recordkeeping systems to comply with the TSCA Title VI rule.

9. Panel producers, fabricators, and wholesalers that package or repackage composite wood products or finished goods containing composite wood products will need to modify their labels to include

their name, the date the finished good was produced, and a statement of compliance. This analysis assumes that all 33 per cent of fabricators that are not already complying with the CARB ATCM

(because their products are not sold in California) will incur a non

- labor cost of $125.00 for purchasing stamps for labeling. Producers and wholesalers are not expected to incur any no n

- labor costs

### Page 87 of 96 Exhibit 6

- 28 : Three Year Average Incremental Non

- Labor Costs, by Activity and Geographic Location ($2010)

Activity Number of Respondents Number of

Activities

Per

Respondent Cost Per

Activity Total Cost

Domestic Foreign 1 Total Domestic Foreign Total

from initial labeling.

10. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added forma ldehyde resins.

### Page 88 of 96 

## (iii) Total Burden and Costs

Exhibit 6

- 29 presents a summary of the total non

- incremental burden and costs for this

information collection request over the first three years of the rule, by geographic location.

Exhibit 6

- 30 presents a summary of the total incremental burden and costs for this information

collection request over the first three years of the ru le, by geographic location. As indicated, the

total average domestic incremental cost over the first three years of the rule is approximately 86

percent of the total domestic cost of the rule. Note that the incremental costs for domestic

respondents pres ented in Exhibit 6

- 30 differ from the values in the Economic Analysis. This is

due to two factors: 1) the Economic Analysis includes the costs of chan ges to raw materials for

composite panel producers, while the ICR does not (because it is not a reporting or

recordkeeping cost); and 2) the burden in the ICR is calculated at the activity level and rounded

to nearest tenth of a percentage, while the costs in the Economic Analysis are calculated at the

establishment level.

Exhibit 6

- 29 : Total (including baseline) Burden and Costs ($2010)

Geographic Location of

Respondents Labor Non

- Labor Cost Total Cost Hours Cost

Year 1

Domestic Respondents 9,041,296 $449,362,235 $22,749,095 $472,111,329

Foreign Respondents 4,066,091 $152,033,647 $34,638,718 $186,672,365

Total Respondents 13,107,388 $601,395,909 $57,387,813 $658,783,722

Years 2 and 3

Domestic Respondents 2,967,505 $83,534,390 $7,665,846 $91,200,236

Foreign Respondents 2,317,142 $76,390,874 $16,432,841 $92,823,715

Total Respondents 5,284,648 $159,925,291 $24,098,688 $184,023,979

Three Year Average

Domestic Respondents 4,991,901 $205,477,002 $12,693,595 $218,170,598

Foreign Respondents 2,900,068 $101,605,129 $22,501,467 $124,106,597

Total Respondents 7,891,969 $307,082,164 $35,195,063 $342,277,228

Notes: Values may not sum to totals due to rounding



### Exhibit 6

- 30 : Total Incremental Burden and Costs, by Geographic Location ($2010)

Geographic Location of

Respondents Labor Non

- Labor

Cost Total Incremental

Cost Hours Cost

Year 1

Domestic Respondents 7,928,288 $420,208,903 $21,580,413 $441,789,316

Foreign Respondents 3,082,828 $116,077,473 $24,182,083 $140,259,556

Total Respondents 11,011,115 $536,286,350 $45,762,496 $582,048,846

Years 2 and 3

Domestic Respondents 1,854,347 $54,370,354 $6,817,285 $61,187,639

Foreign Respondents 1,333,475 $40,405,872 $6,506,816 $46,912,688

Total Respondents 3,187,821 $94,776,198 $13,324,101 $108,100,299

Three Year Average

Domestic Respondents 3,878,793 $176,316,534 $11,738,328 $188,054,863

Foreign Respondents 1,916,536 $65,629,736 $12,398,573 $78,028,310

Total Respondents 5,795,329 $241,946,249 $24,136,899 $266,083,149

Notes: Values may not sum to totals due to rounding

### Page 89 of 96 

## 6(c) Estimating Agency Burden and Cost

EPA resources would be devoted to reviewing and analyzing data submissions, compiling

and recording data, maintaining hard

- copy files of submitted data, auditing and inspecting

facilities, producing audit and inspection reports, responding to public inquiries, and providing

regulatory interpretations. EPA anticipates that these activities will require the equi valent of one

full

- time employee (FTE) at Headquarters. Using the 2010 Washington/Baltimore area annual

salary rate for a GS

- 13, Step 5 employee ($100,904), and multiplying by a loading factor of 1.6

to reflect overhead and fringe benefits results in an e stimated EPA cost of $161,446 per year.

6(d) Bottom Line Burden Hours and Costs/Master Table

Exhibit 6

- 31 presents the frequency for each of the respondent activities assumed in the

bottom line burden hour and cost tables. Exhibit 6

- 32 and Exhibit 6

- 33 present the respective

total and incremental bottom line burden and costs, by activity frequency and respondent type.

In Exhibit 6

- 32 , all activities of a given frequency that a single respondent performs are

accounted for as a single response for that time period. For example, if a respondent performs

two different quarte rly activities per quarter this is accounted for as a single response per quarter

or four responses per year (e.g., paying the large scale testing fee and paying shipment costs for

large scale testing is counted as a single response not two separate respon ses).

### Page 90 of 96 Exhibit 6

- 31 : Frequency of Activities

Activity Assumed Activity Frequency 1

1. Rule Familiarization

Producers One

- Time

Fabricators One

- Time

Wholesalers One

- Time

Retailers One

- Time

2. Certification Fee

Standard Annual

New NAF Annual

Existing NAF/ULEF Annual

3. Initial On

- site Audit

With Existing Certifications One

- Time

Without Existing Certifications One

- Time

4. Develop Quality Control Manual One

- Time

5. Qualifying Test

1 Product One

- Time

2 Products One

- Time

6. Qualifying Test Shipping

1 Product One

- Time

2 Products One

- Time

7. Correlation Test

1 Product One

- Time

2 Products One

- Time

8. Quarterly On

- site Audit

Standard Quarterly

NAF (With New Certification) Annual

NAF (Existing Certifications Only) Annual

9. Large Scale Testing Fee

1 Product with Standard Certification (Existing) Quarterly

2 Products with Standard Certification (New) Quarterly

2 Products with Standard Certification (Existing) Quarterly

1 Product with NAF Certification Annual

2 Product with NAF Certification Annual

10. Quarterly On

- site Audit Shipment

Standard Certification Quarterly

NAF (With New Certification) Annual

NAF (With Existing Certification) Annual

10a. Large Scale Testing Shipment

1 Product with Standard Certification (Existing) Quarterly

2 Products with Standard Certification (New) Quarterly

2 Products with Standard Certification (Existing) Quarterly

1 Product with NAF Certification Annual

2 Product with NAF Certification Annual

1 ULEF and 1 NAF Certification Annual

11. On

- site Audit Travel Annual

12. Desk Audits

Standard Annual

NAF (With New Certification) Annual

13. Purchase of Small Chamber Testing Unit One

- Time

14. Quality Control Testing

- HWPW

Standard Certification Daily

New NAF Certification One

- Time

15. Lost Product

2 Products with Standard Certification (HWPW

- Existing) Daily

2 Products with Standard Certification (HWPW

- New) Daily

2 Products with ULEF Certification (HWPW

- New) Annual

1 ULEF and 1 NAF Certification (HWPW

- Existing)

### Page 91 of 96 Exhibit 6

- 31 : Frequency of Activities

Activity Assumed Activity Frequency 1

1 Product with NAF Certification (HWPW

- New) Annual

1 Product with NAF Certification (HWPW

- Existing) Annual

2 Products with NAF Certification (HWPW

- New) Annual

2 Products with NAF Certification (HWPW

- Existing) Annual

1 Standard and 1 NAF Certification (PB/MDF

- Existing) Daily

2 Products with Standard Certification (PB/MDF

- New) Daily

2 Products with Standard Certification (PB/MDF

- Existing) Daily

1 Product with NAF Certification (PB/MDF

- New) Annual

1 ULEF and 1 NAF Certification (PB/MDF

- Existing) Annual

1 Product with NAF Certification (PB/MDF

- Existing) Annual

2 Products with NAF Certification (PB/MDF

- Existing) Annual

16. Initial Recordkeeping One

- Time

17. Recurring Recordkeeping

Producers Annual

Fabricators Annual

Wholesalers Annual

Retailers Annual

18. Initial Labeling

Minor Changes

- Producers One

- Time

Minor Changes

- Fabricators One

- Time

Major Changes

- Producers One

- Time

Major Changes

- Fabricators and Wholesalers One

- Time

1 This represents the activity frequency assumed for the purpose of the calculations in Exhibit 6

- 33 (which

classifies activities as one

- time, annual, quarterly, or daily), not the frequency required by the rule. For example,

the ru le requires panel producers to be certified by a TPC every two years. Exhibit 6

- 33 assumes that

certification occurs annually but halves the average burden per response, so that the total burden is unchanged.

### Page 92 of 96 Exhibit 6

- 32 : Summary of Three Year Average Total (including baseline) Burden and Costs, by

Geographic Location ($2010)

Response and

Respondent Type Number of

Respondents Average Responses

per Respondent Average Burden per

Response (hours) Total Burden Total Cost

Domestic

Producers

One

- Time 370 0.3333 138.5895 17,091 $2,293,200

Annual 370 1.0000 59.2649 21,928 $4,975,931

Quarterly 370 4.0000 3.6784 5,444 $2,056,416

Daily 370 260.0000 1.7730 170,560 $14,738,661

Fabricators

One

- Time 79,701 0.3333 26.8287 712,687 $35,348,387

Daily 79,701 1.0000 24.1482 1,924,638 $47,808,008

Wholesalers

One

- Time 85,560 0.3333 9.9288 283,142 $17,819,748

Annual 85,560 1.0000 9.8697 844,448 $21,567,202

Retailers

One

- Time 759,048 0.3333 4.0000 1,011,963 $71,563,045

Annual 1 759,048 1.0000

- - -

Total 924,679 4,991,901 $218,170,598

Foreign

Producers

One

- Time 1,129 0.3333 68.7385 25,866 $3,142,139

Annual 1,129 1.0000 57.2728 64,661 $14,142,927

Quarterly 1,129 4.0000 2.2611 10,211 $4,394,614

Daily 1,129 260.0000 1.0611 311,480 $25,732,711

Fabricators

One

- Time 31,083 0.3333 26.8215 277,870 $13,782,371

Daily 31,083 1.0000 24.2524 753,838 $18,725,336

Wholesalers

One

- Time 33,368 0.3333 25.1744 279,978 $14,147,271

Annual 33,368 1.0000 1,176,164 $30,039,228

Retailers

One

- Time

- 0.3333

- - -

Total 65,580 2,900,068 124,106,597

Total

Producers

One

- Time 1,499 0.3333 85.9799 42,957 $5,435,343

Annual 1,499 1.0000 57.7645 86,589 $19,118,857

Quarterly 1,499 4.0000 2.6109 15,655 $6,451,032

Daily 1,499 260.0000 1.2368 482,040 $40,471,373

Fabricators

One

- Time 110,784 0.3333 26.8267 990,557 $49,130,759

Daily 110,784 1.0000 24.1775 2,678,476 $66,533,344

Wholesalers

One

- Time 118,928 0.3333 14.2063 563,120 $31,967,019

Annual 118,928 1.0000 16.9902 2,020,612 $51,606,456

Retailers

One

- Time 759,048 0.3333 4.0000 1,011,963 $71,563,045

Annual 1 759,048 1.0000

- - -

Total 990,259 7,891,969 $342,277,228

1. Retailers are assumed not to import products directly, in which case they are only required to keep invoices and bills of lading.

These records are typically kept as a customary business practice, so no annual burden is attributed to retailers.

### Page 93 of 96 Exhibit 6

- 33 : Summary of Three Year Average Total Incremental Burden and Costs, by Geographic

Location ($2010)

Response and

Respondent

Type Number of

Respondents Average Activities

per Respondent Average

Burden per

Response

(h ours) Total

Burden Total Cost

Domestic

Producers

One

- Time 370 0.3333 138.5895 17,091 $2,280,900

Annual 370 1.0000 58.3027 21,572 $4,282,669

Quarterly 370 4.0000 3.0 885 4,571 $1,904,517

Daily 370 260.0000 1.4973 144,040 $12,660,686

Fabricators

One

- Time 79,701 0.3333 26.8287 712,687 $35,348,387

Annual 47,540 1.0000 24.2646 1,153,539 $28,653,909

Wholesalers

One

- Time 85,560 0.3333 9.9288 283,142 $17,819,748

Annual 85,560 1.0000 0.0002 530,188 $13,541,002

Retailers

One

- Time 759,048 0.3333 4.0000 1,011,963 $71,563,045

Annual 1 658,150 1.0000

- - -

Total 924,679 3,878,793 $188,054,863

Foreign

Producers

One

- Time 1,129 0.3333 68.7385 25,866 $3,027,539

Annual 1,129 1.0000 55.0540 62,156 $7,936,610

Quarterly 1,129 4.0000 0.5 627 2,541 $1,520,865

Daily 1,129 260.0000 0.2728 80,080 $7,585,668

Fabricators

One

- Time 31,083 0.3333 26.8215 277,870 $13,782,371

Annual 18,476 1.0000 24.3314 449,547 $11,166,747

Wholesalers

One

- Time 33,368 0.3333 25.1744 279,978 $14,147,271

Annual 20,955 1.0000 35.2421 738,498 $18,861,239

Retailers

One

- Time

- 0.3333

- - -

Total 65,580 1,916,536 78,028,310

Total

Producers

One

- Time 1,499 0.3333 85.9799 42,957 $5,308,443

Annual 1,499 1.0000 55.8559 83,728 $12,219,276

Quarterly 1,499 4.0000 1. 1861 7,112 $3,425,382

Daily 1,499 260.0000 0.5751 224,120 $20,246,354

Fabricators

One

- Time 110,784 0.3333 26.8267 990,557 $49,130,759

Annual 66,016 1.0000 24.2833 1,603,086 $39,820,656

Wholesalers

One

- Time 118,928 0.3333 14.2063 563,120 $31,967,019

Annual 74,686 1.0000 16.9869 1,268,686 $32,402,215

Retailers

One

- Time 759,048 0.3333 4.0000 1,011,963 $71,563,045

Annual 1 658,150 1.0000

- - -

Total 990,259 5,795,329 $266,083,149

1. Retailers are assumed not to import products directly, in which case they are only required to keep invoices and bills of lading.

These records are typically kept as a customary business practice, so no annual burden is attributed to retailers.

### Page 94 of 96 

## 6(e) Reasons for Changes in Burden

Not applicable. These are new requirements so there was no previous ICR.

6(f) Burden Statement

The annual public burden for this collection of information, which is approved under

OMB Control No. xxxx

- xxxx, is estimated to be 4.6 0 hours per response (i.e., 7, 891

, 969 burden

hours for an estimated 1

, 716

, 048 responses). 27 

## According to the Paperwork Reduction Act,

“burden” means the total time, effort, or financial resources expended by persons to generate,

maint ain, retain, or disclose or provide information to or for a Federal agency. For this

collection it includes such activities as annual familiarization with requirements, recordkeeping,

notification, and reporting requirements. An agency may not conduct or sponsor, and a person is

not required to respond to, a collection of information unless it displays a currently valid OMB

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

appearing in the Federal Register, are l isted in 40 CFR part 9 and included on the related

collection instrument or form, if applicable.

To comment on the Agency’s need for this information, the accuracy of the provided

burden estimates, and any suggested methods for minimizing respondent burde n, including the

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

Docket ID No. EPA

- HQ

- OPPT

- 2012

- 0018. The docket is available for public viewing at the

Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). The EPA/DC

Public Reading Room is located in the EPA West Building, Room 3334, 1301 Constitution Ave.,

NW., Washington, DC. The EPA/DC Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,

Monday through Friday, excluding legal holid ays. The telephone number for the EPA/DC

Public Reading Room is (202) 566

- 1744, and the telephone number for the Pollution Prevention

and Toxics Docket is (202) 566

- 0280. An electronic version of the public docket is available

through the Federal Docket Management System (FDMS) at www.regulations.gov. Use FDMS

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

and to access those documents in the public docket that are available electronically. Once in the

system, select “search,” then key in the docket ID number identified above. Also, you can send

comments to the Office of Information and Regulatory Affairs, Office of Management and

Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please

include the EPA Docket ID No. EPA

- HQ

- OPPT

- 2012

- 0018 and OMB control number xxxx

xxxx in any correspondence.

27 The total number of responses is calculated by taking the sum of the products of the number of respondents and the number of

responses presented in Exhibit 6

- 32

.

### Page 95 of 96 

## References

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.

Composite Panel Association. 2011. 2011 Surface & Panel Buyers Guide

.

Personal Communication with AHFA. 2010. Conversation between Bill Perdue (American Home

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Personal Communication with BIFMA. 2010. Brad Miller's (BIFMA) Written Responses to Questions

about FSCWPA Impacts on Members . November 23, 2011.

Personal Communication with CRA. 2011. Conversation between Pamela Williams (California Retailers

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