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OMB Control Number 2070-0173; EPA ICR Number 2327.02

ICR ATTACHMENT 11

Derivation of Industry Wage Rates 

and Agency Costs

1. DERIVATION OF INDUSTRY WAGE RATES

This attachment provides a brief discussion of the methods that were used to derive the 

final “fully loaded” wages used in the calculation of quantified costs. Base hourly wages for 

relevant labor categories were loaded with factors for benefits and overhead to derive a loaded 

hourly rate. The derivation of fully loaded wages in year 2007 dollars, for each of the labor 

categories used in this ICR, is discussed in Section 1 and is summarized in Table 4-1. 

The basic method used to derive loaded wage rates for technical, managerial, and clerical 

personnel is described more fully in Wage Rates for Economic Analysis of the Toxics Release 

Inventory Program (EPA, 2002). 

December 2007 average wages for technical, managerial, and clerical labor were taken 

from the Employer Costs for Employee Compensation (ECEC) report from the Bureau of Labor 

Statistics for all goods-producing, private industries, white collar occupations (BLS, 2007).

The additional cost of benefits, such as paid leave and insurance (“fringe benefits”), 

specific to each labor category, is also taken from the same BLS series. Fringe benefit as a 

percentage of wage is then calculated separately for each labor category. For example, the average 

wage rate in December 2007 for technical labor was $32.52, and the average fringe benefit was 

40.9 percent of the wage, or $13.30. An additional loading factor of 17 percent is applied to wages 

for overhead. This overhead loading factor is added to the benefits loading factor, and the total is 

then applied to the base wage to derive the fully loaded wage. The fully loaded wage for technical 

labor, for example, is $33.25 x (1+0.409 + 0.17) = $33.25 x (1.611) = $51.35. Fully loaded costs 

for managerial and clerical labor were calculated in a similar manner.
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Table 4-1. Derivation of Loaded Wage Rates

Labor 

Category Data Sources

Uninflated wages and fringes / 

hour Fringe 

benefits 

as % of 

wage

Overhead as 

% of 

wage1

Fringe + 

Overhead 

factor

Loaded Wage 

Rate

(2007$) Date Wages 

($)

Fringe 

benefits

($)

Managerial BLS Employer Costs for Employee 

Compensation. Private industry, 

goods-producing industries, white 

collar occupations. Management, 

business and financial [BLS, 2007]

Dec.

2007 $36.44 $16.07 44.1% 17% 1.579 $58.71

Technical BLS Employer Costs for Employee 

Compensation. Private industry, 

goods-producing industries, white 

collar occupations. Professional and 

related. [BLS, 2007]

Dec 

2007 $32.52 $13.30 40.9% 17% 1.611 $51.35

Clerical BLS Employer Costs for Employee 

Compensation. Private industry, 

goods-producing industries, white 

collar occupations. Office and 

administrative support.[BLS, 2007]

Dec

2007 $15.78 $8.28 44.9% 17% 1.619 $25.54

1An overhead rate of 17 percent applied to wages is used for consistency with recent EPAB economic analyses for two major rulemakings: Wage Rates for Economic 

Analyses of the Toxics Release Inventory Program, June 10, 2002, and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report, August 

2002. 

Note: Calculations are based on unrounded values, so the total may not equal the product of the rounded factors.
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2. AGENCY COSTS

EPA’s costs to review and process industry submissions (SNUNs, requests to modify

SNUR, and requests for equivalency determination) are assumed to be the same as EPA costs to 

review PMNs. The previous ICR calculated an average of the annual salaries for GS-12 Steps 1 

and 10 for Washington, DC. However, to be consistent with the New Chemicals ICR and the 

Economic Analysis for the proposed e-PMN rule, Agency wage rate data used to calculate labor 

costs were gathered from the U.S. Office of Personnel Management Salary Table 2007-DCB, for 

a GS-13, step 5 employee in the Washington, D.C. (OPM, 2008). A loading factor of 1.6 was 

applied to the base salary of $89,985 to arrive at the 2007 loaded salary of $143,976. The final 

loaded hourly wage of $69.22 was calculated by dividing the loaded salary by the 2,080 hours 

associated with a full-time employee to arrive at the 2007 loaded wage rate of $143,976. This 

loaded hourly wage was used in calculations of Agency cost.

Examples of the activities EPA undertakes in reviewing and processing SNUNs include 

prenotice consultation; conducting an administrative prescreen, and processing the notice and 

user fee; conducting engineering/exposure and exposure/fate reviews; holding internal decisionmaking meetings; developing, negotiating, and then reviewing data submitted from a consent 

order; and reviewing Notices of Commencement. 

EPA uses extramural contractor labor to assist in some of the SNUN-related activities. 

The cost of extramural labor in this process is estimated to be $814 for SNUNs submitted via 

CDX, and $975 for non-CDX submissions. The non-CDX extramural cost is from the 

Premanufacture Review Reporting and Exemption Requirements for New Chemical Substances 

and Significant New Use Reporting Requirements for Chemical Substances, EPA ICR No: 

0574.12, OMB Control No.: 2070-0012. It was updated to 2007$ using the Bureau of Labor 

Statistics Producer Price Index data for the chemical manufacturing industry (BLS series 325).