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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 established 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 also 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 emitting 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 accredited 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 to 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 information 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
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• Labeling requirements for manufacturers (including importers), fabricators, distributors, 

and wholesalers.

• Minimized requirements for 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 

information 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 pursuant 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 EPA 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 requirements, 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 information 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 collected 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 quality 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 be legally sold supplied or 

offered for sale in the United States. 

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
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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 federal 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 standards 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-OPPT-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 consulted 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 Board (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 formaldehyde 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 presentations 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 Alliance (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 
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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 developed 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 Guidelines

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 requirements, 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 products. 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 California 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 Retailers of 
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Finished Goods Containing Phase 1 Hardwood Plywood- Veneer Core and Distributors of Phase 

1 Particleboard and Medium Density Fiberboard Panels, available at 

http://www.arb.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 products 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 information 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 RESPONDENTS 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);
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• Merchant Wholesalers, Durable Goods (NAICS code 423);

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

• Retail Trade (NAICS Sector 44 and 45).

4(b) Information 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 of 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 must 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 producers 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 quality 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 the 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 procedures 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, production line, and product type. 
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• Composite 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 testing 

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 identification 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 thereafter, 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 products must be labeled with the 

producer’s name (or number), lot or batch number, the number of the accredited thirdparty certifier, and markings indicating that the product complies with the TSCA Title VI 

emission standards. Products that qualify for reduced 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 goods. 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 products:

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 the 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 
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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 composite 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 producers 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 demonstrating 

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 platforms 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 definition 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 from the supplier that the 

composite wood products are compliant. 

• Non-importing distributors 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; and record, disclose, and/or report the required information. 

5. THE INFORMATION COLLECTION — AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT
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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 and large 

the reporting requirements 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 

communications.

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 wood 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 allow 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 provide 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 section 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 burden 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 from these activities because they may already 
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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 

from 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 products 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 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. 

Exhibit 6-1 summarizes the recordkeeping and reporting activities for respondents as a 

result of the proposed rule:
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Exhibit 6-1: Summary of Recordkeeping and Reporting Activities, 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 Audit2 Quarterly Annual - - -

9. Large Scale Testing Fee3 Quarterly Annual - - -

10. Large Scale Testing 

Shipment3 Quarterly Annual - - -

11. On-site Audit Travel4 Annual - - - -

12. Desk Audits5 8 per year - - - - -

13. Purchase of Small Chamber 

Testing Unit6 1-time - - - - -

14. Quality Control Testing7 Up to Daily - - - -

15. Lost Product8 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 retain 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 for 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 perform large scale testing quarterly unless all products are certified as NAF. It is assumed that mills with only NAFcertified 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 qualifying process. 

4. 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. 

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 burden 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 onsite. Mills with an existing ULEF or NAF certification will already have been 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 is 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 hardwood 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 product type each day for quality 

control testing, which is a conservative estimate for hardwood plywood producers. In addition, mills are required 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 annually. Product lines that 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.
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Note that the TSCA Title VI rule requires importers of articles that are composite wood 

products, or articles that contain composite wood products, 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 that 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 burden 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.

Exhibit 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 equipment, 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 estimates 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 certification1

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 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 comply with the CARB ATCM. As a result, the 

Economic Analysis excluded the costs of activities that would 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))

NonLabor 

Costs

(see 

Section 

6(b))

Burden/Cost Included for 

Incremental Estimate, by firm 

type

Burden/Cost Included for 

Total Estimate, by firm 

type

Baseline CARBCompliant

Not Baseline 

CARBCompliant

Baseline 

CARBCompliant

Not Baseline 

CARBCompliant 

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

This 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 excludes future activities that will be performed to comply with the CARB 

ATCM in the 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 that 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, wholesalers, 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 estimate 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 larger compared to the share of domestic production that is 

 2 EPA’s Economic Analysis for the rulemaking (Economic Analysis of the Formaldehyde Standards for Composite 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 number 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 hardwood 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 rugs, 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 products 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 value 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, 

445230, 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, 453110, 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 

Shipments

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 assumed 

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 85,560 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 export 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 products. 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 sectors), 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 products 

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 

Respondents1

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) 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 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 composite 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 the 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 Per Respondent

This section describes the per-activity recordkeeping and reporting burden for 

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

stringent requirements than the proposed TSCA Title VI rule requires, 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 or the proposed TSCA Title VI rule require. 

Therefore this 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 rules. Exhibit 6-5 summarizes the differences between how TPCs 

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

exemption.

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 description 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 plywood 

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 producers 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 of 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 certification, 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 certification 

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 comply 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 producers 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 ongoing small scale quality control testing, submit monthly reports to the TPC, and 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 requirements. 

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 testing 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 which point the mill may reapply for a ULEF or NAF 

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

However, because some TPC requirements are more stringent than the rule, this analysis 

assumes that ULEF product lines will receive quarterly TPC testing, and that ULEF and NAFcertified 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 setting 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 modifications 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 personnel 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 Communication with HPVA 2011.
Page 20 of 96

manual could 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 process. 

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 procedures. 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 obtain 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 being 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 production 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 cover 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 incur 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 

periodic “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 analysis 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 one 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 on-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 

desiccator 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 scale 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 manufacturer. 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 for 

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 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 VI rule requires mills to wait until test results 

indicate 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 choose 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 

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 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 

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

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

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 shown 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 testing 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 scale 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 certifications 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 

that 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, the 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 testing 

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 time; 

• 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 producers 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 whom 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 panels 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 plywood 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 products 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 finished 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 records 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 estimated simply as the number of establishments located in California divided by the total 

number of U.S. establishments in each industry. Exhibit 6-6 presents 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 with 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 

Compliancea

321211b 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%

321918c Other Millwork (including Flooring) 9.23%

337212c Custom Architectural Woodwork and Millwork 9.83%

321999c All Other Miscellaneous Wood Product Manufacturing 7.84%

336213c Motor Home Manufacturing 100%

336214c Travel Trailer and Camper 100%

321991c Manufactured Home (Mobile Home) Manufacturing 10.90%

321992c Prefabricated Building Manufacturing 5.92%

339950c 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 asked 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 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. 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 generally 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 with 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 recordkeeping 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 hours 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 the 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 revenue) 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 not 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 

setting 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 labeling 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 ultimately 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 required 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 manufacturers 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 business 

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 establishment 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 firms15 (2) estimate the 

number of single-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 approach 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 totals 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 Compliance of Wholesale Industries

NAICS NAICS Description Baseline 

CARB Compliancea

423210b Furniture merchant wholesalers 100%

423220b 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 Compliance of Wholesale Industries

NAICS NAICS Description Baseline 

CARB Compliancea

(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 calculation 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 that 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 average 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 wholesaler 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 wholesaler’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 multiplied 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 for 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 that 

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 rule’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 firms 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 wholesaler 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 respondent 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 average 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 

cost). 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 incremental 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 

Type1

Number of Entities Number of 

Activities 

Per 

Respondent

Burden Per 

Activity 

(Hours)

Total Burden (Hours)

Domestic Foreign2 Total Domestic Foreign Total

1. Rule Familiarization

Producers3 M 370 1,129 1,499 1 4.00 1,480 4,516 5,996

Fabricators4 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 Certifications3,5 M 288 365 653 1 8.00 2,304 2,920 5,224

4. Develop Quality Control Manual3 M 288 365 653 1 40.00 11,520 14,600 26,120

5. Qualifying Test

6. Qualifying Test Shipment6

1 Product M 5 64 69 1 0.50 3 32 35

2 Products3,5 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 Products3,5 M 288 365 653 20 1.00 5,760 7,300 13,060

8. Quarterly On-site Audit7

Standard3,6 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 Shipment7

Standard/ULEF Certification3,5 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-site Audit Travel - - - - - - - - -

12. Desk Audits8

Standard Certification3,5 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 

Unit9 - - - - - - - - -

14. Quality Control Testing10

Standard Certification3,6 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. Initial Recordkeeping11 C 8,576 11,945 20,521 1 59.15 507,270 706,547 1,213,817

17. Recurring Recordkeeping12

Producers3,5 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 

Type1

Number of Entities Number of 

Activities 

Per 

Respondent

Burden Per 

Activity 

(Hours)

Total Burden (Hours)

Domestic Foreign2 Total Domestic Foreign Total

Fabricators with burden- Employers4 C 3,630 1,422 5,052 1 520.00 1,887,600 739,440 2,627,040

Fabricators with burden - Nonemployers4 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 Labeling13

Minor Changes - Producers4,5 C 93 1,021 1,114 1 6.00 558 6,126 6,684

Minor Changes - Fabricators4 T 64,290 24,986 89,276 1 3.00 192,870 74,958 267,828

Major Changes - Producers3 C 277 108 385 1 100.00 27,700 10,800 38,500

Major Changes - Fabricators and 

Wholesalers4 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) 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 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 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 formaldehyde resins.

5. Since CARB does not certify wood veneer laminated products, all producers 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 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 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 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 costs are incurred by 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 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 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. 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 

Type1

Number of Entities Number of 

Activities 

Per 

Respondent

Burden Per 

Activity 

(Hours)

Total Burden (Hours)

Domestic Foreign2 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 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, 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 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 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 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, respectively. 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, 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 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 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 wholesalers 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 35 of 96

Exhibit 6-10: Total (including baseline) Second and Third Year Burden Hours, by Activity and Geographic Location

Activity

Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Total Burden (Hours)

Domestic Foreign2 Total Domestic Foreign Total

1. Rule Familiarization

Producers3 M - - - - - - - -

Fabricators4 M - - - - - - - -

Wholesalers M - - - - - - - -

Retailers M - - - - - - - -

2. Certification Fee - - - - - - - - -

3. Initial On-site Audit

With Existing Certifications M - - - - - - - -

Without Existing Certifications3,5 M - - - - - - - -

4. Develop Quality Control Manual3 M - - - - - - - -

5. Qualifying Test - - - - - - - - -

6. Qualifying Test Shipment

1 Product M - - - - - - - -

2 Products3,5 M - - - - - - - -

7. Correlation Test6

1 Product M - - - - - - - -

2 Products3,5 M - - - - - - - -

8. Quarterly On-site Audit7

Standard3,6 M 328 599 927 4 4.00 5,248 9,584 14,832

NAF (With New Certification) M 11 211 222 1 4.00 44 844 888

9. Large Scale Testing Fee - - - - - - - - -

10. Large Scale Testing Shipment7

Standard/ULEF Certification3,5 M 345 778 1,123 4 0.50 690 1,556 2,246

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-site Audit Travel - - - - - - - - -

12. Desk Audits8

Standard Certification3,5 M 328 599 927 8 1.00 2,624 4,792 7,416

NAF (With New Certification) M - - - - - - - -

13. Purchase of Small Chamber 

Testing Unit9 - - - - - - - - -

14. Quality Control Testing10

Standard Certification3,5 M 328 599 927 260 2.00 170,560 311,480 482,040

New NAF Certification M - - - - - - - -

15. Lost Product

16. Initial Recordkeeping11 C - - - - - - - -

17. Recurring Recordkeeping12

Producers3,5 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 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Total Burden (Hours)

Domestic Foreign2 Total Domestic Foreign Total

Fabricators with burdenEmployers4 C 3,630 1,422 5,052 1 520.00 1,887,600 739,440 2,627,040

Fabricators with burden -

Nonemployers4 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 Labeling4,13

Minor Changes - Producers4,5 C - - - - - - - -

Minor Changes - Fabricators4 T - - - - - - - -

Major Changes - Producers3 C - - - - - - - -

Major Changes - Fabricators and 

Wholesalers4 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 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 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 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 formaldehyde resins.

5. Since CARB does not certify wood veneer laminated products, all producers 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 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 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 estimated 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 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 
Page 37 of 96

Exhibit 6-10: Total (including baseline) Second and Third Year Burden Hours, by Activity and Geographic Location

Activity

Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Total Burden (Hours)

Domestic Foreign2 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 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 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 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, 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 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 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 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, respectively. 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, 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 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 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 wholesalers 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 38 of 96

Exhibit 6-11: Three Year Average Burden Hours (including baseline), by Activity and Geographic Location

Activity

Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Total Burden (Hours)

Domestic Foreign2 Total Domestic Foreign Total

1. Rule Familiarization

Producers3 M 370 1,129 1,499 0.3333 4.0000 493 1,505 1,998

Fabricators4 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. Initial On-site Audit 

With Existing Certifications M 82 764 846 0.3333 4.0000 109 1,019 1,128

Without Existing Certifications3,5 M 288 365 653 0.3333 8.0000 768 973 1,741

4. Develop Quality Control Manual3 M 288 365 653 0.3333 40.0000 3,840 4,866 8,706

5. Qualifying Test - - - - - - - - -

6. Qualifying Test Shipment

1 Product M 5 64 69 0.3333 0.5000 1 11 12

2 Products3,5 M 288 365 653 0.6667 0.2500 48 61 109

7. Correlation Test6

1 Product M 5 64 69 3.3333 1.0000 17 213 230

2 Products3,5 M 288 365 653 6.6667 1.0000 1,920 2,433 4,353

8. Quarterly On-site Audit7

Standard3,5 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. Large Scale Testing Shipment7

Standard/ULEF Certification3,5 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. On-site Audit Travel - - - - - - - - -

12. Desk Audits8

Standard Certification3,5 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 Unit9 - - - - - - - - -

14. Quality Control Testing10

Standard Certification3,5 M 328 599 927 260.0000 2.0000 170,560 311,480 482,040

New NAF Certification M 11 211 222 21.6667 2.0000 477 9,143 9,620

15. Lost Product - - - - - - - - -

16. Initial Recordkeeping11 C 8,576 11,945 20,521 0.3333 59.1500 169,073 235,492 404,565

17. Recurring Recordkeeping12

Producers3,5 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 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Total Burden (Hours)

Domestic Foreign2 Total Domestic Foreign Total

Fabricators with burden- Employers4 C 3,630 1,422 5,052 1.0000 520.0000 1,887,600 739,440 2,627,040

Fabricators with burden - Nonemployers4 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 57,157

Wholesalers without burden C 75,258 19,020 94,278 1.0000 - - - -

Retailers C 759,048 - 759,048 1.0000 - - - -

18. Initial Labeling4,13

Minor Changes - Producers4,5 C 93 1,021 1,114 0.3333 6.0000 186 2,042 2,228

Minor Changes - Fabricators4 T 64,290 24,986 89,276 0.3333 3.0000 64,284 24,984 89,268

Major Changes - Producers3 C 277 108 385 0.3333 100.0000 9,232 3,600 12,832

Major Changes - Fabricators and Wholesalers4 T 16,266 6,344 22,610 0.3333 100.0000 542,146 211,446 753,592

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 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 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 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 formaldehyde resins.

5. Since CARB does not certify wood veneer laminated products, all producers 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 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 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 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 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 

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. 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 will 
Page 40 of 96

Exhibit 6-11: Three Year Average Burden Hours (including baseline), by Activity and Geographic Location

Activity

Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Total Burden (Hours)

Domestic Foreign2 Total Domestic Foreign Total

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, 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 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 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 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, respectively. 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, 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 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 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 wholesalers 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 41 of 96

Exhibit 6-12: Incremental First Year Burden Hours, by Activity and Geographic Location

Activity Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Incremental Burden (Hours)

Domestic Foreign2 Total Domestic Foreign Total

1. Rule Familiarization

Producers3 M 370 1,129 1,499 1 4.00 1,480 4,516 5,996

Fabricators4 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 Certifications3,5 M 288 365 653 1 8.00 2,304 2,920 5,224

4. Develop Quality Control Manual3 M 288 365 653 1 40.00 11,520 14,600 26,120

5. Qualifying Test - - - - - - - - -

6. Qualifying Test Shipment

1 Product M 5 64 69 1 0.50 3 32 35

2 Products3,5 M 288 365 653 2 0.25 144 183 327

7. Correlation Test6

1 Product M 5 64 69 10 1.00 50 640 690

2 Products3,5 M 288 365 653 20 1.00 5,760 7,300 13,060

8. Quarterly On-site Audit7

Uncertified to Standard3,5 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 Shipment7

Uncertified to Standard3,5 M 277 154 431 3 0.50 416 231 647

NAF (With New Certification) M 11 211 222 1 0.50 6 106 112

11. On-site Audit Travel - - - - - - - - -

12. Desk Audits8

Uncertified to Standard3,5 M 277 154 431 8 1.00 2,216 1,232 3,448

NAF (With New Certification) M 11 211 222 2 1.00 22 422 444

13. Purchase of Small Chamber Testing 

Unit9 - - - - - - - - -

14. Quality Control Testing10 - - - - - - - - -

Standard Certification3,5 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 Recordkeeping11 C 8,576 11,945 20,521 1 59.15 507,270 706,547 1,213,817

17. Recurring Recordkeeping12

Producers3,5 M 370 1,129 1,499 1 52.00 19,240 58,708 77,948

Fabricators with burden- Employers4 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 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Incremental Burden (Hours)

Domestic Foreign2 Total Domestic Foreign Total

Fabricators with burden -

Nonemployers4 C 3,054 1,191 4,245 1 7.21 22,019 8,587 30,606

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 Labeling4,13

Minor Changes - Producers4,5 C 93 1,021 1,114 1 6.00 558 6,126 6,684

Minor Changes - Fabricators4 T 64,290 24,986 89,276 1 3.00 192,870 74,958 267,828

Major Changes - Producers3 C 277 108 385 1 100.00 27,700 10,800 38,500

Major Changes - Fabricators and 

Wholesalers4 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 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 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 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 formaldehyde resins.

5. Since CARB does not certify wood veneer laminated products, all producers 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 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 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 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 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 

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. 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 43 of 96

Exhibit 6-12: Incremental First Year Burden Hours, by Activity and Geographic Location

Activity Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Incremental Burden (Hours)

Domestic Foreign2 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 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, 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 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 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 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, respectively. 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, 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 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 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 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 44 of 96

Exhibit 6-13: Incremental Second and Third Year Burden Hours, by Activity and Geographic Location

Activity Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Incremental Burden (Hours)

Domestic Foreign2 Total Domestic Foreign Total

1. Rule Familiarization

Producers3 M - - - - - - - -

Fabricators4 M - - - - - - - -

Wholesalers M - - - - - - - -

Retailers M - - - - - - - -

2. Certification Fee - - - - - - - - -

3. Initial On-site Audit

With Existing Certifications M - - - - - - - -

Without Existing Certifications3,5 M - - - - - - - -

4. Develop Quality Control Manual3 M - - - - - - - -

5. Qualifying Test - - - - - - - - -

6. Qualifying Test Shipment

1 Product M - - - - - - - -

2 Products3,5 M - - - - - - - -

7. Correlation Test6

1 Product M - - - - - - - -

2 Products3,5 M - - - - - - - -

8. Quarterly On-site Audit7

Uncertified to Standard3,5 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. Large Scale Testing Shipment7

Uncertified to Standard3,5 M 277 154 431 4 0.50 554 308 862

NAF (With New Certification) M 11 211 222 1 0.50 6 106 112

11. On-site Audit Travel - - - - - - - - -

12. Desk Audits8

Uncertified to Standard3,5 M 277 154 431 8 1.00 2,216 1,232 3,448

NAF (With New Certification) - - - - - - - - -

13. Purchase of Small Chamber Testing Unit9 - - - - - - - - -

14. Quality Control Testing10

Standard Certification3,5 M 277 154 431 260 2.00 144,040 80,080 224,120

New NAF Certification M - - - - - - - -

15. Lost Product - - - - - - - - -

16. Initial Recordkeeping11 C - - - - - - - -

17. Recurring Recordkeeping12

Producers3,5 M 370 1,129 1,499 1 52.00 19,240 58,708 77,948

Fabricators with burden- Employers4 C 2,176 848 3,024 1 520.00 1,131,520 440,960 1,572,480

Fabricators with burden - Nonemployers4 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 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Incremental Burden (Hours)

Domestic Foreign2 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 Labeling4,13

Minor Changes - Producers4,5 T - - - - - - - -

Minor Changes - Fabricators4 T - - - - - - - -

Major Changes - Producers3 T - - - - - - - -

Major Changes - Fabricators and Wholesalers4 T - - - - - - - -

Total - 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 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 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 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 formaldehyde resins.

5. Since CARB does not certify wood veneer laminated products, all producers 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 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 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 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 product 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 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. 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 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, 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 recurring 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 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Incremental Burden (Hours)

Domestic Foreign2 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 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 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 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, respectively. 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, 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 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 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 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 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Incremental Burden (Hours)

Domestic Foreign2 Total Domestic Foreign Total

1. Rule Familiarization

Producers3 M 370 1,129 1,499 0.3333 4.0000 493 1,505 1,998

Fabricators4 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. Initial On-site Audit

With Existing Certifications M 82 764 846 0.3333 4.0000 109 1,019 1,128

Without Existing Certifications3,5 M 288 365 653 0.3333 8.0000 768 973 1,741

4. Develop Quality Control Manual3 M 288 365 653 0.3333 40.0000 3,840 4,866 8,706

5. Qualifying Test - - - - - - - - - 6. Qualifying Test Shipment

1 Product M 5 64 69 0.3333 0.5000 1 11 12

2 Products3,5 M 288 365 653 0.6667 0.2500 48 61 109

7. Correlation Test6

1 Product M 5 64 69 3.3333 1.0000 17 213 230

2 Products3,5 M 288 365 653 6.6667 1.0000 1,920 2,433 4,353

8. Quarterly On-site Audit7

Uncertified to Standard3,5 M 277 154 431 3.6667 4.0000 4,063 2,259 6,322

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 Shipment8

Uncertified to Standard3,5 M 277 154 431 3.6667 0.5000 508 282 790

NAF (With New Certification) M 11 211 222 1.0000 0.5000 6 106 112

11. On-site Audit Travel - - - - - - - - - 12. Desk Audits8

Uncertified to Standard3,5 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 Unit9 - - - - - - - - -

14. Quality Control Testing10

Standard Certification3,5 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. Initial Recordkeeping11 C 8,576 11,945 20,521 0.3333 59.1500 169,073 235,492 404,565

17. Recurring Recordkeeping12

Producers3,5 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 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Incremental Burden (Hours)

Domestic Foreign2 Total Domestic Foreign Total

Fabricators with burdenEmployers4 C 2,176 848 3,024 1.0000 520.0000 1,131,520 440,960 1,572,480

Fabricators with burden -

Nonemployers4 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 35,896

Wholesalers without burden C 47,263 11,944 59,207 1.0000 - - - -

Retailers C 658,150 - 658,150 1.0000 - - - - 18. Initial Labeling4,13

Minor Changes - Producers4,5 C 93 1,021 1,114 0.3333 6.0000 186 2,042 2,228

Minor Changes - Fabricators4 T 64,290 24,986 89,276 0.3333 3.0000 64,284 24,984 89,268

Major Changes - Producers3 C 277 108 385 0.3333 100.0000 9,232 3,600 12,832

Major Changes - Fabricators and 

Wholesalers4 T 16,266 6,344 22,610 0.3333 100.0000 542,146 211,446 753,592

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 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 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 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 formaldehyde resins.

5. Since CARB does not certify wood veneer laminated products, all producers 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 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 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 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 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 
Page 49 of 96

Exhibit 6-14: Three Year Average Incremental Burden Hours, by Activity and Geographic Location

Activity Labor 

Type1

Number of Entities Number of 

Activities Per 

Respondent

Burden Per 

Activity 

(Hours)

Incremental Burden (Hours)

Domestic Foreign2 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 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 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 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, 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 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 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 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, respectively. 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, 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 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 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 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 50 of 96

1

2 6(b) Estimating Respondent Costs

3

4 Respondent costs are estimated by multiplying burden estimates from the previous 

5 section with loaded wage rates, and adding in capital/startup costs and operating and 

6 maintenance (O&M) costs. 

7

8 (i) Wage Rates

9

10 The fully loaded unit labor cost for managerial, technical, and clerical labor in the 

11 regulated industry and for EPA staff is estimated by adding fringe benefits and overhead costs to 

12 the hourly wage or annual salary for each category following the method described in Wage 

13 Rates for Economic Analysis of the Toxics Release Inventory Program. This section describes 

14 the method employed to estimate the fully loaded unit labor costs for each labor category and 

15 presents the results of the analysis.

16

17 Wage data used to calculate the labor costs are from the May 2009 National Industry18 Specific Occupational Employment and Wage Estimates estimated as part of the Bureau of 

Labor Statistics’(BLS’) Occupational Employment Statistics Program (OES).21 19 The values were 

20 inflated to 2010 dollars using data from the BLS’ Employer Costs for Employee Compensation 

(ECEC) for all private industry for 2009 and 2010.22 21 Thus, the analysis uses domestic wage rates 

22 to estimate the costs for burden incurred by foreign firms.

23

24 The costs of fringe benefits (i.e., paid leave and insurance) were estimated using the same 

25 ECEC data for all private industry in 2010, resulting in a fringe benefit rate of 42 percent. An 

26 additional loading factor of 17 percent is applied to wages to account for overhead. This 

27 overhead loading factor is added to the benefits loading factor, and the total (1.59) is then applied 

28 to the base wage to derive the fully loaded wage. 

29

30 The derivation of the fully loaded costs for managerial, technical, and clerical labor is 

31 presented in Exhibit 6-15. Note that two types of managerial labor costs are calculated – one for 

32 rule familiarization (a general managerial labor rate for wood product manufacturing NAICS) 

33 and one for testing and certification (a more specific managerial labor rate for composite panel 

34 manufacturing NAICS).

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

Retailers

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 total 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 burden 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) perresponse costs is classified as a separate activity. 

Labor Costs

Exhibit 6-16 and Exhibit 6-17 summarize the total 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 domestic 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 Geographic Location ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

1. Rule Familiarization

Producers1 - - $108,928 - - $332,378 - - $441,306

Fabricators1 - - $23,463,974 - - $9,150,835 - - $32,614,810

Wholesalers2 - - $31,927,570 - - $12,451,603 - - $44,379,172

Retailers3 - - $214,689,136 - - - - - $214,689,136

2. Certification Fee - - - - - - - - -

3. Initial On-site Audit4

With Existing Certifications - - $23,406 - - $218,076 - - $241,482

Without Existing Certifications - - $164,413 - - $208,371 - - $372,785

4. Develop Quality Control Manual4 - - $822,067 - - $1,041,856 - - $1,863,923

5. Qualifying Test - - - - - - - - -

6. Qualifying Test Shipment4

1 Product - - $214 - - $2,284 - - $2,498 

2 Products - - $10,276 - - $13,059 - - $23,335 

7. Correlation Test4

1 Product - - $3,568 - - $45,670 - - $49,238 

2 Products - - $411,034 - - $520,928 - - $931,962 

8. Quarterly On-site Audit4

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 Shipment4

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 Travel4 - - - - - - - - -

12. Desk Audits4

Standard Certification - - $187,249 - - $341,957 - - $529,206 

NAF (With New Certification) - - $1,570 - - $30,114 - - $31,684 

13. Purchase of Small Chamber Testing 

Unit - - - - - - - - -

14. Quality Control Testing4

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. Initial Recordkeeping5 $12,955,676 - - $18,045,210 - - $31,000,886 - -

17. Recurring Recordkeeping

Producers4 $1,372,966 - - $4,189,403 - - $5,562,369 - -

Fabricators with costs - Employers6 $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 Geographic Location ($2010)

Activity Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

Fabricators with costs -

Nonemployers6 $920,024 - - $357,646 - - $1,277,670 - -

Fabricators without costs - - - - - - - - -

Wholesalers with costs - Employers5 $20,957,102 - - $29,189,538 - - $50,146,641 - - Wholesalers with costs -

Nonemployers5 $610,100 - - $849,690 - - $1,459,815 - -

Wholesalers without costs - - - - - - - - -

Retailers - - - - - - - - - 18. Initial Labeling

Minor Changes - Producers6 $13,861 - - $152,170 - - $166,031 - -

Minor Changes – Fabricators7 - $8,538,355 - - $3,318,391 - - $11,856,746 -

Major Changes – Producers6 $688,068 - - $268,272 - - $956,340 - - Major Changes - Fabricators and 

Wholesalers7 - $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 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 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 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

Producers1 - - - - - - - - -

Fabricators1 - - - - - - - - -

Wholesalers2 - - - - - - - - -

Retailers3 - - - - - - - - -

2. Certification Fee - - - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - - - - - - - -

Without Existing Certifications - - - - - - - - -

4. Develop Quality Control Manual - - - - - - - - -

5. Qualifying Test - - - - - - - - - 6. Qualifying Test Shipment7

1 Product - - - - - - - - -

2 Products - - - - - - - - - 7. Correlation Test4

1 Product - - - - - - - - -

2 Products - - - - - - - - - 8. Quarterly On-site Audit4

Standard Certification - - $374,497 - - $683,914 - - $1,058,412

NAF (With New Certification) - - $3,140 - - $60,228 - - $63,368

9. Large Scale Testing Fee - - - - - - - - -

10. Large Scale Testing Shipment4

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 Audits4

Standard Certification - - $187,249 - - $341,957 - - $529,206

NAF (With New Certification) - - - - - - - - - 13. Purchase of Small Chamber 

Testing Unit - - - - - - - - -

14. Quality Control Testing4

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 Recordkeeping5 - - - - - - - - - 17. Recurring Recordkeeping

Producers4 $1,372,966 - - $4,189,403 - - $5,562,369

Fabricators with costs -

Employers6 $46,887,984 - - $18,367,690 - - $65,255,674 - -

Fabricators with costsNonemployers6 $920,024 - - $357,646 - - $1,277,670 - -

Fabricators without costs - - - - - - - - - Wholesalers with costs -

Employers5 $20,957,102 - - $29,189,538 - - $50,146,641 - -

Wholesalers with costs -

Nonemployers5 $610,100 - - $849,690 - - $1,459,815 - -

Wholesalers without costs - - - - - - - - -

Retailers - - - - - - - - - 18. Initial Labeling

Minor Changes - Producers6 - - - - - - - - -

Minor Changes – Fabricators7 - - - - - - - - -

Major Changes – Producers6 - - - - - - - - - Major Changes - Fabricators and 

Wholesalers7 - - - - - - - - -

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 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 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 fabricators, and labeling for producers.

7. The analysis uses a loaded wage rate of $44.27 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

Producers1 - - $36,309 - - $110,793 - - $147,102

Fabricators1 - - $7,821,325 - - $3,050,278 - - $10,871,603

Wholesalers2 - - $10,642,523 - - $4,150,534 - - $14,793,057

Retailers3 - - $71,563,045 - - - - - $71,563,045

2. Certification Fee - - - - - - - - -

3. Initial On-site Audit4

With Existing Certifications - - $7,802 - - $72,692 - - $80,494

Without Existing 

Certifications - - $54,804 - - $69,457 - - $124,262

4. Develop Quality Control 

Manual4 - - $274,022 - - $347,285 - - $621,308

5. Qualifying Test - - - - - - - - - 6. Qualifying Test Shipment4

1 Product - - $71 - - $761 - - $833

2 Products - - $3,425 - - $4,353 - - $7,778

7. Correlation Test4

1 Product - - $1,189 - - $15,223 - - $16,413

2 Products - - $137,011 - - $173,643 - - $310,654

8. Quarterly On-site Audit4

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 Shipment4

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 Audits4

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 Testing4

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 Recordkeeping5 $4,318,559 - - $6,015,070 - - $10,333,629 - - 17. Recurring Recordkeeping

Producers4 $1,372,966 - - $4,189,403 - - $5,562,369 - - Fabricators with costs -

Employers6 $46,887,984 - - $18,367,690 - - $65,255,674 - -

Fabricators with costs -

Nonemployers6 $920,024 - - $357,646 - - $1,277,670 - -

Fabricators without costs - - - - - - - - - Wholesalers with costs -

Employers5 $20,957,102 - - $29,189,538 - - $50,146,641 - -

Wholesalers with costs -

Nonemployers5 $610,100 - - $849,690 - - $1,459,815 - -

Wholesalers without costs - - - - - - - - -

Retailers - - - - - - - - - 18. Initial Labeling

Minor Changes – Producers6 $4,620 - - $50,723 - - $55,344 - -

Minor Changes –

Fabricators7 - $2,846,118 - - $1,106,130 - - $3,952,249 -

Major Changes – Producers6 $229,356 - - $89,424 - - $318,780 - -

Major Changes - Fabricators 

and Wholesalers7 - $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 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 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

Producers1 - - $108,928 - - $332,378 - - $441,306

Fabricators1 - - $23,463,974 - - $9,150,835 - - $32,614,810

Wholesalers2 - - $31,927,570 - - $12,451,603 - - $44,379,172

Retailers3 - - $214,689,136 - - - - - $214,689,136

2. Certification Fee - - - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - $23,406 - - $218,076 - - $241,482

Without Existing 

Certifications - - $164,413 - - $208,371 - - $372,785

4. Develop Quality Control 

Manual4 - - $822,067 - - $1,041,856 - - $1,863,923

5. Qualifying Test - - - - - - - - -

6. Qualifying Test Shipment4

1 Product - - $214 - - $2,284 - - $2,498

2 Products - - $10,276 - - $13,059 - - $23,335

7. Correlation Test4

1 Product - - $3,568 - - $45,670 - - $49,238

2 Products - - $411,034 - - $520,928 - - $931,962

8. Quarterly On-site Audit4

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 Shipment4

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 Audits4

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 Testing4
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 Recordkeeping5 $12,955,676 - - $18,045,210 - - $31,000,886 - - 17. Recurring Recordkeeping

Producers4 $1,372,966 - - $4,189,403 - - $5,562,369 - - Fabricators with costs -

Employers6 $28,106,957 - - $10,953,446 - - $39,060,403 - -

Fabricators with costs -

Nonemployers6 $546,952 - - $213,301 - - $760,253 - -

Fabricators without costs - - - - - - - - - Wholesalers with costs -

Employers5 $13,157,953 - - $18,327,504 - - $31,485,457 - -

Wholesalers with costs -

Nonemployers5 $383,049 - - $533,735 - - $916,758 - -

Wholesalers without costs - - - - - - - - -

Retailers - - - - - - - - - 18. Initial Labeling

Minor Changes - Producers6 $13,861 - - $152,170 - - $166,031 - - Minor Changes –

Fabricators7 - $8,538,355 - - $3,318,391 - - $11,856,746 -

Major Changes – Producers6 $688,068 - - $268,272 - - $956,340 - - Major Changes - Fabricators 

and Wholesalers7 - $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 for retailers.

4. The analysis uses a loaded wage 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 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 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

Producers1 - - - - - - - - -

Fabricators1 - - - - - - - - -

Wholesalers2 - - - - - - - - -

Retailers3 - - - - - - - - -

2. Certification Fee - - - - - - - - -

3. Initial On-site Audit4

With Existing Certifications - - - - - - - - -

Without Existing Certifications - - - - - - - - -

4. Develop Quality Control Manual4 - - - - - - - - -

5. Qualifying Test - - - - - - - - -

6. Qualifying Test Shipment4

1 Product - - - - - - - - -

2 Products - - - - - - - - -

7. Correlation Test4

1 Product - - - - - - - - -

2 Products - - - - - - - - -

8. Quarterly On-site Audit4

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 Shipment4

Uncertified to Standard - - $39,533 - - $21,979 - - $61,512

NAF (With New Certification) - - $428 - - $7,564 - - $7,992

11. On-site Audit Travel - - - - - - - - -

12. Desk Audits4

Uncertified to Standard - - $158,134 - - $87,916 - - $246,049

NAF (With New Certification) - - $6,280 - - $65,080 - - $71,360

13. Purchase of Small Chamber 

Testing Unit - - - - - - - - -

14. Quality Control Testing4

Standard Certification - - $10,278,694 - - $5,714,509 - - $15,993,203

New NAF Certification - - - - - - - - -

15. Lost Product - - - - - - - - -

16. Initial Recordkeeping5 - - - - - - - - -

17. Recurring Recordkeeping

Producers4 $1,372,966 - - $4,189,403 - - $5,562,369 - -

Fabricators with costs -

Employers6 $28,106,957 - - $10,953,446 - - $39,060,403 - -

Fabricators with costs - $546,952 - - $213,301 - - $760,253 - -
Page 62 of 96

Exhibit 6-20: Incremental Second and Third Year Labor Costs, by Activity and Geographic Location ($2010)

Activity

Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

Nonemployers6

Fabricators without costs - - - - - - - - -

Wholesalers with costs -

Employers5 $13,157,953 - - $18,327,504 - - $31,485,457 - -

Wholesalers with costs -

Nonemployers5 $383,049 - - $533,735 - - $916,758 - -

Wholesalers without costs - - - - - - - - -

Retailers - - - - - - - - -

18. Initial Labeling

Minor Changes - Producers6 - - - - - - - - -

Minor Changes - Fabricators7 - - - - - - - - -

Major Changes - Producers6 - - - - - - - - -

Major Changes - Fabricators and 

Wholesalers7 - - - - - - - - -

Total - 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 wage 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 fabricators 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 Location ($2010)

Activity

Domestic Foreign Total

Clerical Technical Managerial Clerical Technical Managerial Clerical Technical Managerial

1. Rule Familiarization

Producers1 - - $36,309 - - $110,793 - - $147,102

Fabricators1 - - $7,821,325 - - $3,050,278 - - $10,871,603

Wholesalers2 - - $10,642,523 - - $4,150,534 - - $14,793,057

Retailers3 - - $71,563,045 - - - - - $71,563,045

2. Certification Fee - - - - - - - - - 3. Initial On-site Audit4

With Existing Certifications - - $7,802 - - $72,692 - - $80,494

Without Existing 

Certifications - - $54,804 - - $69,457 - - $124,262

4. Develop Quality Control 

Manual4 - - $274,022 - - $347,285 - - $621,308

5. Qualifying Test - - - - - - - - - 6. Qualifying Test Shipment4

1-Product by TPC - - $71 - - $761 - - $833

2-Product by TPC - - $3,425 - - $4,353 - - $7,778

7. Correlation Test4

1-Product by TPC - - $1,189 - - $15,223 - - $16,413

2-Product by TPC - - $137,011 - - $173,643 - - $310,654

8. Quarterly On-site Audit4

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 Shipment4

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 Audits4

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. Quality Control Testing4
Page 64 of 96

Exhibit 6-21: Three Year Average Incremental 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 - - $34,015 - - $652,468 - - $686,483

15. Lost Product - - - - - - - - -

16. Initial Recordkeeping5 $4,318,559 - - $6,015,070 - - $10,333,629 - -

17. Recurring Recordkeeping

Producers4 $1,372,966 - - $4,189,403 - - $5,562,369 - - Fabricators with costs -

Employers6 $28,106,957 - - $10,953,446 - - $39,060,403 - -

Fabricators with costs -

Nonemployers6 $546,952 - - $213,301 - - $760,253 - -

Fabricators without costs - - - - - - - - - Wholesalers with costs -

Employers5 $13,157,953 - - $18,327,504 - - $31,485,457 - -

Wholesalers with costs -

Nonemployers5 $383,049 - - $533,735 - - $916,758 - -

Wholesalers without costs - - - - - - - - -

Retailers - - - - - - - - - 18. Initial Labeling

Minor Changes – Producers6 $4,620 - - $50,723 - - $55,344 - Minor Changes –

Fabricators7 - $2,846,118 - - $1,106,130 - - $3,952,249 -

Major Changes - Producers6 $229,356 - - $89,424 - $318,780 - -

Major Changes - Fabricators 

and Wholesalers7 - $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 $37,317,072 $116,136,184

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 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 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, perrespondent and total non-labor costs for each response activity over the next three years. Exhibit 

6-26 through Exhibit 6-28 present the corresponding 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 will 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 will 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 (depending 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 analysis 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 NAF certifications apply to product lines, and not necessarily to the entire facility. Mills with multiple product 

lines could 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. This 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 assumes 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 TSCA 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 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 cover sheets. Based on 

conversations 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 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, producers that are already CARB compliant and are 

not expected to adopt a more stringent certification 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 onsite 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 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 or NAF certifications. All ULEF and NAF-certified producers 

will have one on-site audit annually thereafter.

 24 This is the rate charged by HPVA’s Reston Lab to non-members for testing 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 at 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 conversations 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 assumes 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 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. Based on 

fees charged by CPA and HPVA, it is assumed that each desk audit costs $250.

As in the 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 

result 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 purchase. 
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 approved 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 the 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 indicate 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 

choose 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 flexibility 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 small 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 product 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 annually. 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., combinations 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 plywood 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 associated 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 requirements. 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 labeling. 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 the 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 

as 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 only 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 

initial 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 wholesalers 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 nonlabor 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 

approximately 36 percent ($13 million) and 49 percent ($12 million) of these totals, respectively.

 26 Personal Communication with California Retailers Association 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 Foreign1 Total Domestic Foreign Total

1. Rule Familiarization - - - - - - - - 2. Certification Fee2

Standard3 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 Certifications3,4 288 365 653 1 $450 $129,600 $164,250 $293,850

4. Develop Quality Control Manual - - - - - - - - 5. Qualifying Test5

1 Product 5 64 69 5 480 $12,000 $153,600 $165,600 

2 Products3,4 288 365 653 10 $480 $1,382,400 $1,752,000 $3,134,400

6. Qualifying Test Shipping5

1 Product 5 64 69 1 200 $1,000 $12,800 $13,800 

2 Products3,4 288 365 653 2 $200 $115,200 $146,000 $261,200

7. Correlation Test - - - - - - - - 8. Quarterly On-site Audit6

Standard3,4 328 599 927 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 Fee7

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 Shipment7

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 Audits8

Standard3,4 328 599 927 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 Foreign1 Total Domestic Foreign Total

13. Purchase of Small Chamber Testing 

Unit3 282 208 490 1 $10,000 $2,820,000 $2,080,000 $4,900,000 

14. Quality Control Testing - - - - - - - - 15. Lost Product7

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 Foreign1 Total Domestic Foreign Total

16. Initial Recordkeeping9 8,576 11,945 20,521 1 $1,000 $8,576,000 $11,945,000 $20,521,000

17. Recurring Recordkeeping - - - - - - - - 18. Initial Labeling10

Minor Changes - Producers - - - - - - - -

Minor Changes - Fabricators - - - - - - - - Major Changes – Producers3 277 108 385 1 $125 $34,625 $13,500 $48,125 

Major Changes - Fabricators and 

Wholesalers11 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 analysis assumes that there 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.

2. Since CARB does not certify wood veneer laminated products, all producers 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.

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. This analysis assumes that mills will seek standard 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 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 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. 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 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 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 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 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 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 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 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 formaldehyde resins.
Page 74 of 96

Exhibit 6-24: Total (including baseline) 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 Foreign1 Total Domestic Foreign Total

1. Rule Familiarization - - - - - - - -

2. Certification Fee2

Standard3 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 Certifications3,4 - - - - - - - -

4. Develop Quality Control Manual - - - - - - - -

5. Qualifying Test5

1 Product - - - - - - - -

2 Products3,4 - - - - - - - -

6. Qualifying Test Shipping5

1 Product - - - - - - - -

2 Products3,4 - - - - - - - -

7. Correlation Test5 - - - - - - - -

8. Quarterly On-site Audit6

Standard3,4 328 599 927 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 Fee7

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 Shipment7

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 Audits8

Standard3,4 328 599 927 8 $250 $656,000 $1,198,000 $1,854,000 

NAF - - - - - - - -

13. Purchase of Small Chamber Testing Unit3 - - - - - - - -
Page 75 of 96

Exhibit 6-24: Total (including baseline) 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 Foreign1 Total Domestic Foreign Total

14. Quality Control Testing - - - - - - - -

15. Lost Product7

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 Recordkeeping9 - - - - - - - -

17. Recurring Recordkeeping - - - - - - - -

18. Initial Labeling10

Minor Changes - Producers - - - - - - - -

Minor Changes - Fabricators - - - - - - - -

Minor Changes – Wholesalers3 - - - - - - - -

Major Changes – Fabricators11 - - - - - - - -

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 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 there 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.

2. Since CARB does not certify wood veneer laminated products, all producers 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.

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. This analysis assumes that mills will seek standard 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 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 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. 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 for standard certifications are assumed to occur monthly, 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 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 
Page 76 of 96

Exhibit 6-24: Total (including baseline) 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 Foreign1 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 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.

10. 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 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 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 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 Foreign1 Total Domestic Foreign Total

1. Rule Familiarization - - - - - - - -

2. Certification Fee2

Standard3 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 Certifications3,4 288 365 653 0.3333 $450.00 $43,200 $54,750 $97,950 

4. Develop Quality Control Manual - - - - - - - -

5. Qualifying Test5

1 Product 5 64 69 1.6667 $480 $4,000 $51,200 $55,200 

2 Products3,4 288 365 653 3.3333 $480 $460,800 $584,000 $1,044,800 

6. Qualifying Test Shipping5

1 Product 5 64 69 0.3333 $200 $333 $4,267 $4,600 

2 Products3,4 288 365 653 0.6667 $200 $38,400 $48,667 $87,067 

7. Correlation Test - - - - - - - -

8. Quarterly On-site Audit6

Standard3,4 328 599 927 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 Fee7

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 Shipment7

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 Audits8

Standard3,4 328 599 927 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 Unit3 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 Foreign1 Total Domestic Foreign Total

14. Quality Control Testing - - - - - - - -

15. Lost Product7

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 Recordkeeping9 8,576 11,945 20,521 0.3333 $1,000 $2,858,667 $3,981,667 $6,840,333 

17. Recurring Recordkeeping - - - - - - - -

18. Initial Labeling10

Minor Changes - Producers - - - - - - - -

Minor Changes - Fabricators - - - - - - - -

Major Changes – Producers3 277 108 385 0.3333 $125.00 $11,542 $4,500 $16,042 

Major Changes - Fabricators and 

Wholesalers11 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 Foreign1 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 there 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.

2. Since CARB does not certify wood veneer laminated products, all producers 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.

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. This analysis assumes that mills will seek standard 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 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 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. 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 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 in the first year; none are required in subsequent years. No desk audits are required 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 

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 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 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 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 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 formaldehyde 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 Foreign1 Total Domestic Foreign Total

1. Rule Familiarization - - - - - - - -

2. Certification Fee2

Uncertified to Standard3,4 277 154 431 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 Certifications3,4 288 365 653 1 $450 $129,600 $164,250 $293,850

4. Develop Quality Control Manual - - - - - - - -

5. Qualifying Test5

1 Product 5 64 69 5 $480 $12,000 $153,600 $165,600 

2 Products3,4 288 365 653 10 $480 $1,382,400 $1,752,000 $3,134,400

6. Qualifying Test Shipping5

1 Product 5 64 69 1 $200 $1,000 $12,800 $13,800 

2 Products3,4 288 365 653 2 $200 $115,200 $146,000 $261,200

7. Correlation Test5 - - - - - - - -

8. Quarterly On-site Audit6

Uncertified to Standard3,4 277 154 431 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 Standard3,4 277 154 431 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 Standard3,4 277 154 431 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 Audits7

Uncertified to Standard3,4 277 154 431 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 Unit2 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 Foreign1 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 Recordkeeping8 8,576 11,945 20,521 1 $1,000 $8,576,000 $11,945,000 $20,521,000

17. Recurring Recordkeeping - - - - - - - -

18. Initial Labeling9

Minor Changes - Producers - - - - - - - -

Minor Changes - Fabricators - - - - - - - -

Major Changes – Producers3 277 108 385 1 $125 $34,625 $13,500 $48,125

Major Changes - Fabricators and Wholesalers10 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 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. 

2. This analysis assumes that mills will seek standard certification for uncertified product lines. The exceptions are uncertified 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 assumed 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 hardwood 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 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.

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 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 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 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 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 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 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 Foreign1 Total Domestic Foreign Total

10. Total excludes the estimated 2 percent of wood veneer laminated product producers expected to continue to use added formaldehyde resins.
Page 83 of 96

Exhibit 6-27: Incremental Second and Third 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 Foreign1 Total Domestic Foreign Total

1. Rule Familiarization - - - - - - - -

3. Certification Fee2

Uncertified to Standard3,4 277 154 431 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 Certifications3,4 - - - - - - - -

5. Develop Quality Control Manual - - - - - - - -

6. Qualifying Test5

1 Product - - - - - - - -

2 Products3,4 - - - - - - - -

7. Qualifying Test Shipping5

1 Product - - - - - - - -

2 Products3,4 - - - - - - - -

8. Correlation Test5 - - - - - - - -

9. Quarterly On-site Audit6

Uncertified to Standard3,4 277 154 431 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 Standard3,4 277 154 431 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 Standard3,4 277 154 431 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 Audits7

Uncertified to Standard3,4 277 154 431 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 Costs, by Activity and Geographic Location ($2010)

Activity

Number of Respondents Number of 

Activities Per 

Respondent

Cost Per 

Activity

Total Cost

Domestic Foreign1 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 Recordkeeping8 - - - - - - - -

18. Recurring Recordkeeping - - - - - - - -

19. Initial Labeling9

Minor Changes - Producers - - - - - - - -

Minor Changes - Fabricators - - - - - - - -

Major Changes – Producers3 - - - - - - - -

Major Changes - Fabricators and Wholesalers10 - - - - - - - -

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 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. 

2. This analysis assumes that mills will seek standard certification for uncertified product lines. The exceptions are uncertified 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 assumed 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 hardwood 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 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.

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 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 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 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 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 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 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 formaldehyde 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 Foreign1 Total Domestic Foreign Total

1. Rule Familiarization - - - - - - - -

2. Certification Fee2

Uncertified to Standard3,4 277 154 431 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 Certifications3,4 288 365 653 0.3333 $450.00 $43,200 $54,750 $97,950 

4. Develop Quality Control Manual - - - - - - - -

5. Qualifying Test5

1 Product 5 64 69 1.6667 $480 $4,000 $51,200 $55,200 

2 Products3,4 288 365 653 3.3333 $480 $460,800 $584,000 $1,044,800 

6. Qualifying Test Shipping5

1 Product 5 64 69 0.3333 $200 $333 $4,267 $4,600 

2 Products3,4 288 365 653 0.6667 $200 $38,400 $48,667 $87,067 

7. Correlation Test - - - - - - - -

8. Quarterly On-site Audit5

Uncertified to Standard3,4 277 154 431 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 Standard3,4 277 154 431 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 Standard3,4 277 154 431 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 Audits7

Uncertified to Standard3,4 277 154 431 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 Foreign1 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 Recordkeeping8 8,576 11,945 20,521 0.3333 $1,000 $2,858,667 $3,981,667 $6,840,333 

17. Recurring Recordkeeping - - - - - - - -

18. Initial Labeling9

Minor Changes - Producers - - - - - - - -

Minor Changes - Fabricators - - - - - - - -

Major Changes – Producers3 277 108 385 0.3333 $125.00 $11,542 $4,500 $16,042 

Major Changes - Fabricators and 

Wholesalers10 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 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 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. This analysis assumes that mills will seek standard certification for uncertified product lines. The exceptions are uncertified 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 assumed 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 hardwood 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 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.

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 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 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 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 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 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 incur any non-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 Foreign1 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 formaldehyde 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 rule, 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 presented 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 changes 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 

Hours Cost 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 equivalent 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 estimated 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 quarterly 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 responses).
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 rule 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

Annual1 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 

(hours)

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 3.0885 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

 Annual1 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 0.5627 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

 Annual1 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 4.60 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, 

maintain, 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 listed 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 burden, 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 holidays. 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 xxxxxxxx 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

California Air Resources Board. 2011. CARB List of Certified Mills.

Composite Panel Association. 2011. 2011 Surface & Panel Buyers Guide.

Personal Communication with AHFA. 2010. Conversation between Bill Perdue (American Home 

Furnishings Alliance) and Abt Associates Inc. November 3, 2010.

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 

Association) and Abt Associates Inc. January 20, 2011.

Personal Communication with HPVA. 2011. Conversation between Kip Howlett (HPVA) and Abt 

Associates Inc. January 4, 2011.

U.S. Bureau of Labor Statistics (BLS). 2009. Occupational Employment Statistics 2009 Mean Hourly 

Wages.

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