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ECONOMIC ANALYSIS OF THE PROPOSED SIGNIFICANT NEW USE RULE FOR 14 GLYMES 

(EPA DOCKET EPA-HQ-OPPT-2009-0767)

April 8, 2010 

—Does not contain TSCA CBI—

Prepared by: 

Economic and Policy Analysis Branch 

Economics, Exposure and Technology Division 

Office of Pollution Prevention and Toxics 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 
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Economic Analysis of SNUR U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

 

i

CONTRIBUTORS 

The EPA analyst responsible for this report was Nishkam Agarwal. Analytical and draft 

preparation support was provided by Abt Associates Inc. under EPA Contract No. EP-W-08-010. 
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Economic Analysis of SNUR U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

 

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ABSTRACT 

This report estimates the costs of the proposed Significant New Use Rule (SNUR) that 

applies to 14 chemicals, collectively known as “glymes” ([poly]ethylene glycol diethers). The 

specific glymes subject to the proposed SNUR are monoglyme, diglyme, ethylglyme, 

ethyldiglyme, triglyme, butyldiglyme, tetraethylene glycol dibutyl ether, tetraglyme, 

pentaethylene glycol diethyl ether, polyglyme, tetraethylene glycol diethyl ether, polyethylene 

glycol dibutyl ether, pentaethylene glycol dibutyl ether, and butyltriglyme. 

The proposed SNUR applies to all proposed significant new uses of 14 glymes that are 

defined as use in a consumer product of 12 glymes (monoglyme, diglyme, triglyme, tetraglyme, 

polyglyme, ethylglyme, ethyldiglyme, butyldiglyme, tetraethylene glycol dibutyl ether, 

pentaethylene glycol diethyl ether, tetraethylene glycol diethyl ether, polyethylene glycol dibutyl 

ether) with the exception of excluded ongoing consumer uses for five glymes (monoglyme, 

diglyme, triglyme, tetraglyme, and polyglyme), and any uses (consumer or non-consumer) of 

two glymes (pentaethylene glycol dibutyl ether and butyltriglyme). 

All consumer uses that are exempted from the proposed SNUR are confirmed ongoing 

uses of these chemicals in consumer products. A "consumer product" is defined as: “a chemical 

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

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

recreation.” To identify the confirmed ongoing consumer uses, as well as potential industrial 

uses, EPA relied on the TSCA Inventory Update Reporting (IUR) information combined with 

direct communications with manufacturers. EPA has distinguished confirmed uses from 

unconfirmed or reported uses, where the latter are uses identified only in chemical dictionaries 

and other comparable reference materials. 

Of the 14 glymes, five have confirmed consumer uses that are excluded from the proposed 

SNUR. These excluded uses are: 

• Monoglyme in electrolyte solutions for sealed lithium batteries 

• Diglyme as a solvent in printing inks for consumer products 

• Triglyme as a solvent in consumer adhesives, as a component of consumer brake fluids, 

as a component of consumer paint/graffiti removers, and in consumer paints 

• Tetraglyme as a hydrofluorocarbon/chlorofluorocarbon (HFC/CFC) lubricant, as a 

solubilizing agent for consumer printing inks, and as a coalescing agent in consumer 

paints 

• Polyglyme in consumer paint strippers 

Glymes are used mostly as industrial solvents, reaction solvents, or processing aids, but they 

have been used in some consumer products. The U.S. Environmental Protection Agency (EPA) 

is proposing the SNUR because it is concerned about the reproductive and/or developmental 

toxicity of monoglyme, diglyme, and ethylglyme and believes that individuals could suffer 

adverse effects from their use. In addition, due to the absence of use, exposure, and toxicity data 

to suggest otherwise, EPA remains concerned about the other 11 glymes. A firm intending to 

manufacture, import, and/or process any of these 14 glymes for any significant new use 
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Economic Analysis of SNUR U.S. EPA Office of Pollution Prevention and Toxics 

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(described in Section 1.2) would be required to submit a Significant New Use Notice (SNUN), 

incurring an estimated submission cost of $8,455 per chemical. 

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

commencing the manufacture, import, or processing of glymes for any significant new use as 

described in the SNUR. 

To submit this SNUN, a firm incurs a modest submission cost. EPA does not require the 

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

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

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

proposed SNUR. 

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

firms that do not make a submission. By avoiding a significant new use, a firm can avoid 

submission and testing costs but may incur other compliance costs. The firm may also incur 

“hidden” costs; for example, it could forego profitable opportunities to use the chemical in an 

application that would be a significant new use or limit production volume to avoid a significant 

new use. 

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

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

EPA receives only a handful of SNUNs per year due to SNURs. However, the number of firms 

affected by not making submissions to EPA is not known; therefore, costs are not aggregated 

across the affected entities. 
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TABLE OF CONTENTS

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

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

LIST OF TABLES.......................................................................................................................... v 

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

1.1 Uses of 14 Glymes ......................................................................................................... 2

1.2 Consumer Uses Excluded by the proposed SNUR ........................................................ 4 

1.3 Potentially Affected Industries....................................................................................... 6 

1.4 Impact of a SNUR.......................................................................................................... 7

2. COSTS OF A SNUR, BY OPTION........................................................................................ 8 

2.1 Submit a SNUN (Option 1)............................................................................................ 8 

2.2 Decide Not to Produce Chemical (Option 2) ................................................................. 9 

2.3 Likelihood of a SNUN Submission ............................................................................... 9 

2.4 Potential for Subsequent Regulatory Actions .............................................................. 10 

2.5 Agency Costs ............................................................................................................... 11 

3. EXPORT NOTIFICATION COSTS ..................................................................................... 11 

3.1 Estimated Number of Exporters and Export Notifications .......................................... 11 

3.2 Exporter Costs.............................................................................................................. 12 

3.3 Agency Costs ............................................................................................................... 15 

4. ADDITIONAL ANALYSES................................................................................................. 19 

4.1 Regulatory Flexibility Act ........................................................................................... 19 

4.2 Unfunded Mandates Reform Act ................................................................................. 20 

4.3 Paperwork Reduction Act ............................................................................................ 20 

4.4 National Technology Transfer and Advancement Act................................................. 20 

4.5 Executive Order 12866: Regulatory Planning and Review ......................................... 20 

4.6 Executive Order 12898: Environmental Justice........................................................... 20 

4.7 Executive Order 13045: Protection of Children........................................................... 20 

4.8 Executive Order 13132: Federalism ............................................................................ 21 

4.9 Executive Order 13175: Tribal Governments.............................................................. 21 

4.10 Executive Order 13211: Energy Supply, Distribution, or Use .................................... 21 

A. INFLATORS AND WAGE RATES................................................................................... A-1 

B. COSTS FOR SNUN ............................................................................................................ B-1 

C. AGENCY COSTS ............................................................................................................... C-1 

D. REFERENCES .................................................................................................................... D-1 
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Economic Analysis of SNUR U.S. EPA Office of Pollution Prevention and Toxics 

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LIST OF TABLES 

Table 1: CAS Number and Common Name for Glymes Covered by the Proposed SNUR ........... 2 

Table 2: Proposed Excluded Consumer Uses by Chemical............................................................ 5 

Table 3: Industries Potentially affected by the proposed SNUR, by NAICS Code........................ 7 

Table 4: Costs of Requirement to Submit a SNUN (2008$) .......................................................... 9 

Table 5: Compliance Options and Associated Costs Incurred by a Firm Due to the proposed 

SNUR............................................................................................................................................ 10 

Table 6: Estimated Number of Exporters and Export Notifications Submitted to EPA as a Result 

of the Proposed SNUR.................................................................................................................. 12 

Table 7: TSCA 12(b) Export Notification Cost: Annual Burden per Respondent Facility (2008$)

....................................................................................................................................................... 13 

Table 8: Derivation of Total Mailing Cost for 12 Notices............................................................ 14 

Table 9: Industry Total Cost Estimate per Year (2008$).............................................................. 14 

Table 10: Three Year Industry Costs (2008$) .............................................................................. 15 

Table 11: Estimated Number of Export Notifications Submitted to EPA and Notifications sent to 

Importing Countries...................................................................................................................... 16 

Table 12: TSCA 12(b) Export Notification Cost: Annual Agency Burden (2008$) .................... 17 

Table 13: Derivation of Agency Mailing Cost for 35 Notices...................................................... 18 

Table 14: Agency Total Cost Estimate per Year (2008$)............................................................. 18 

Table 15: Three Year Agency Costs (2008$) ............................................................................... 19 

Table A-1: Derivation of Loaded Wage Rates ........................................................................... A-3 

Table A-2: Derivation of Inflation Factors ................................................................................. A-5 

Table B-1: Industry Costs for SNUN.......................................................................................... B-1

Table C-1: Agency Costs for SNUN and Other Submission Review and Processing................ C-2 
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Economic Analysis of SNUR 1 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

1. INTRODUCTION 

Glymes ([poly]ethylene glycol diethers) are clear, colorless, liquid ethers that are primarily 

used as solvents or processing aids in a wide variety of industrial applications. Glymes are polar 

aprotic in nature, miscible in water, and hydrocarbon type solvents (Cheremisinoff, 2003). 

These properties make them excellent solvents for organic and inorganic compounds and 

polymers (Clariant, 2008). In addition, they are chemically stable in a wide pH range and may 

be used in several high-temperature applications (Clariant, 2008). 

This report estimates the costs of the proposed Significant New Use Rule (SNUR) that 

applies to 14 glymes. These glymes are either ethylene glycol dialkyl ethers or dialkyl ethers of 

repeating units of oxyethylene (such as dialkyl ethers of diethylene glycol or triethylene glycol, 

etc.) where both alkyl groups are the same as shown in the following structure: R-(OCH2CH2)nOR, where n=(i) a discrete value of 1,2,3,4, or 5 or (ii) a range of values (as in polyethylene 

glycol) with both R’s = CH3, C2H5, or C4H9. 

 The specific glymes subject to the proposed SNUR are: monoglyme, diglyme, ethylglyme, 

ethyldiglyme, triglyme, butyldiglyme, tetraethylene glycol dibutyl ether, tetraglyme, 

pentaethylene glycol diethyl ether, polyglyme, tetraethylene glycol diethyl ether, polyethylene 

glycol dibutyl ether, pentaethylene glycol dibutyl ether, and butyltriglyme. For the purposes of 

this SNUR, a significant new use is defined as use in a consumer product of 12 glymes 

(monoglyme, diglyme, triglyme, tetraglyme, polyglyme, ethylglyme, ethyldiglyme, 

butyldiglyme, tetraethylene glycol dibutyl ether, pentaethylene glycol diethyl ether, tetraethylene 

glycol diethyl ether, polyethylene glycol dibutyl ether, pentaethylene glycol dibutyl ether, and 

butyltriglyme) with the exception of the excluded ongoing consumer uses for five of the glymes 

(monoglyme, diglyme, triglyme, tetraglyme, and polyglyme). For the remaining two glymes 

(pentaethylene glycol dibutyl ether and butyltriglyme), a significant new use is defined as any 

use (consumer or non-consumer) of these glymes. 

To identify the ongoing uses in consumer uses of these glymes, as well as potential industrial 

products of these glymes, EPA used information reported under the 2006 Inventory Update 

Reporting (IUR) rule, contacted manufacturers, searched business periodicals, and searched 

other available sources. All uses exempted from the proposed SNUR are confirmed ongoing 

uses of these chemicals in consumer products. A "consumer product" is defined as: “a chemical 

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

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

recreation.” To identify these confirmed uses, EPA relied on the IUR information combined 

with direct communications with manufacturers. EPA has distinguished confirmed uses from 

unconfirmed (reported) uses, where the latter are uses identified only in chemical dictionaries 

and other comparable reference materials. EPA is not proposing exclusions to the proposed 

significant new uses based only on the existence of a use being reported. 

Table 1 lists the CAS number, synonym, and Chemical Abstract Index name for the 14 

glymes subject to the proposed SNUR.
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Economic Analysis of SNUR 2 U.S. EPA Office of Pollution Prevention and Toxics 

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Table 1: CAS Number and Common Name for Glymes Covered by the Proposed SNUR 

CAS RN Common Name Chemical Abstract Index Name 

Chemicals with Consumer Use as the Significant New Use 

110-71-4 Monoglyme or Monoethylene glycol dimethyl ether Ethane, 1,2-dimethoxy111-96-6 Diglyme or Diethylene glycol dimethyl ether Ethane, 1,l'-oxybis[2-methoxy629-14-1 Ethylene glycol diethyl ether Ethane, 1,2-diethoxy112-36-7 Ethyldiglyme or Diethylene glycol diethyl ether Ethane, 1,l'-oxybis[2-ethoxy112-49-2 Triglyme or Triethylene glycol dimethyl ether 2, 5, 8, 11-Tetraoxadodecane 

112-73-2 Butyldiglyme or Diethylene glycol dibutyl ether Butane, 1,1'-(oxybis(2,1-ethanediyloxy)]bis112-98-1 Tetraethylene glycol dibutyl ether 5, 8, 11, 14, 17-Pentaoxaheneicosane 

143-24-8 Tetraglyme or Tetraethylene glycol dimethyl ether 2, 5, 8, 11, 14-Pentaoxapentadecane 

23601-39-0 Pentaethylene glycol diethyl ether 3, 6, 9, 12, 15, 18-Hexaoxaeicosane 

24991-55-7 Polyglyme or Polyethylene glycol dimethyl ether Poly(oxy-l,2-ethanediyl), .alpha,-methyl 

.omega.-methoxy4353-28-0 Tetraethylene glycol diethyl ether 3, 6, 9, 12, 15-Pentaoxaheptadecane 

31885-97-9 Tetraethylene glycol diethyl ether Poly(oxy-1,2-ethanediyl), alpha.-butyl-

.omega.-butoxyChemicals with Any Use as the Significant New Use 

51105-00-1 Pentaethylene glycol dibutyl ether 5, 8, 11, 14, 17, 20-Hexaoxatetracosane 

63512-36-7 Butyltriglyme or Triethylene glycol dibutyl ether 5, 8, 11, 14-Tetraoxaoctadecane 

Source: Chemical Abstract Service (CAS) 

1.1 Uses of 14 Glymes 

Monoglyme (CASRN 110-71-4) has one confirmed use in a consumer product, as an 

electrolyte solvent (1-5 percent) in sealed lithium ion batteries (ERG, 2009a). The chemical is 

also reported to be included in a process to treat aluminum surfaces to ensure surfaces are less 

reactive (Clariant, 2008). Monoglyme is also reportedly used in the inner and outer layer etching 

of printed circuit board manufacturing (Scorecard, 2005); in reactions with strong bases (Ferro, 

2009); in mixtures where solvent separation and recovery is necessary; as an inert special solvent 

for certain organo metallic reactions (Clariant, 2008); and as a solvent for oligo- and 

polysaccharides; and in sugar and carbohydrate chemistry (Clariant, 2008). The confirmed nonconsumer use of monoglyme is its use as a solvent in pharmaceutical production (ERG, 2009a). 

Diglyme (CASRN 111-96-6) has only one confirmed use in a consumer product, as a solvent 

in printing inks for consumer products (ERG, 2009a). Reported uses for diglyme under the 

commercial/consumer category of the 2006 IUR include use in automotive care products as a 

component of brake fluid, paints and coatings, and adhesives and sealants (EPA, 2006b). One 

confirmed non-consumer use for diglyme is as a solvent in the production of pharmaceutical 

products (ERG, 2009a). The reported non-consumer uses of diglyme include its use as a solvent 

for lithium aluminum hydride and sodium borohydride reductions and in the production of 

pharmaceutical products (Clariant, 2008). 

While EPA has been unable to confirm through the 2006 IUR and company contact that there 

are any uses of ethylglyme (CASRN 629-14-1) in a consumer product, there has been reported 

use of ethylglyme as a solvent in consumer paint production (Ash, 2009), as well as use as an 
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Economic Analysis of SNUR 3 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

adhesive solvent and polycarbonate swelling agent (Ferro, 2009). Another potential use in a 

consumer product is in the preparation of “other” polishes and related products (Score Card, 

2005). Other reported uses of ethylglyme include use as a solvent for ester gum, shellac and 

some resins and oils, use as a reaction medium for organic synthesis, use as a solvent and diluent 

for detergent and dye solvents in non-grain-raising stains (HSDB, 2009a). 

Triglyme (CASRN 112-49-2) has several confirmed uses in consumer products, including in 

consumer brake fluids, as a solvent in consumer adhesives, as a component of consumer paint 

and graffiti removers and in consumer paints (ERG, 2009b and ERG, 2009a). Confirmed nonconsumer uses include generation of chemicals, use as a selective solvent for methylation 

reactions, use as a binding agent in porcelain powders and as a reaction solvent for the 

manufacture of sodium cyanide (ERG, 2009a). 

Tetraglyme (CASRN 143-24-8) has several confirmed uses in consumer products as a 

solubilizing agent for consumer printing inks, as a coalescing agent in consumer paints, and as an 

HFC/CFC lubricant which may be used in consumer air conditioners (ERG, 2009b and ERG, 

2009a). Confirmed non-consumer uses include use as a solubilizing agent in textiles and 

plastics, as a dye fixation additive for cotton textiles, and as a fungicide process solvent (ERG, 

2009a). Tetraglyme has a reported use in fabrics, textiles and apparel (EPA, 2006b) and as a gas 

scrubbing agent and has been shown to effectively remove CO, CO2, H2S, and other sour-gas 

components from natural, synthetic, or ammonia gas streams (Ferro, 2009). 

Polyglyme (CASRN 24991-55-7) has a confirmed use in consumer paint strippers (ERG, 

2009a). Reported consumer uses include use in adhesive removers, fragrance production, antifog compounds, brake fluid (Ferro, 2009), automotive care products and paper products (EPA, 

2006a). Polyglyme is often used as special, high boiling solvents for several chemical reactions 

including depolymerization and hydrogenation. Confirmed non-consumer uses for polyglyme 

include use as a solubilizing agent for plastic, textile, and paper processes (ERG, 2009a). A 

reported non-consumer use is in removing sour gas compounds from gas streams, absorbing 

hydrogenated liquids, and scrubbing gas stacks (Ferro, 2009). Other reported non-consumer uses 

include use in paper products and automotive care products (EPA, 2006b). 

Ethyldiglyme (CASRN 112-36-7) has several reported consumer uses in paint and paint 

varnishes, in coatings (Score Card, 2005) and adhesives manufacturing and as a solvent in 

printing ink production (Ash, 1996). Reported non-consumer uses include use as a high-boiling 

solvent for nitrocellulose, resins, and lacquers; as a solubilizer in organic synthesis (Ash, 2009); 

in manufacturing processes as a solvent in the production of plastic resins, compounds, and 

rubber chemicals (HSDB, 2009b). 

Butyldiglyme (CASRN 112-73-2) has no confirmed or reported consumer uses. Confirmed 

non-consumer uses include use as a solvent for conductive printing ink and in the production of 

printed circuit etchants (ERG, 2009a). Reported non-consumer uses include use in the 

preparation of and reaction with Grignard reagents, and use in metal extractions (Clariant, 2008). 

Polyethylene glycol dibutyl ether (CASRN 31885-97-9) has only one reported consumer use, 

in the production of gel laundry detergents (Unilever, 2007). The chemical has several reported 
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Economic Analysis of SNUR 4 U.S. EPA Office of Pollution Prevention and Toxics 

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non-consumer uses, including use as a solvent in several pharmaceutical syntheses including 

antiviral and blood pressure medication (Clariant, 2008), use as a gas scrubbing liquid (Clariant, 

2008), use in the production of various coatings and in the soldering of electronic components 

(Multicore Solders Limited, 1990). 

Tetraethylene glycol diethyl ether (CASRN 4353-28-0) has no confirmed consumer uses. 

There has been a reported consumer use as an ingredient in brake fluid and may contain between 

10 and 50 percent of the chemical (Wagner, 1998). There are no confirmed non-consumer uses 

for this chemical. It has a reportedly non-consumer use in the production of a heat resistant 

resin, which in turn is used in the production of electronic circuit boards and semiconductor 

devices (Hitachi Chemical Company, 1992 and 2006). 

 

Tetraethylene glycol dibutyl ether (CASRN 112-98-1) has no confirmed consumer uses but 

there is a reported consumer use as a brake fluid ingredient and may comprise between 10 and 50 

percent of the product (Wagner, 1998). The chemical does not have any confirmed nonconsumer uses but it has a reported non-consumer use in the production of heat resistant resin 

pastes. These pastes are used to produce electronic circuit boards and semiconductor devices 

(Hitachi Chemical Company, 1992 and Hitachi Chemical Company, 2006). 

 

Pentaethylene glycol diethyl ether (CASRN 23601-39-0) has no confirmed consumer uses 

but has a reported consumer use as an ingredient in brake fluid (Cross Packaging, 2008) and use 

in the soldering of electronic circuit boards (US Patent 4871109). There are no confirmed nonconsumer uses. 

Pentaethylene glycol dibutyl ether (CASRN 51105-00-1) has no confirmed or reported 

consumer uses, nor any confirmed non-consumer uses. A 1967 reference suggests that this 

glyme was reportedly used in the production of methacrylic acid, but it is unknown if the 

chemical is still used for that purpose (LONZA AG, 1967). Methacrylic acid was used in the 

production of polymers, resins, and adhesives. 

Butyltriglyme (CASRN 63512-36-7) has no confirmed or reported consumer uses. There 

were no confirmed non-consumer uses but there was a 1992 reference that the chemical was 

reportedly used as a scrubbing liquid in the removal or recycling of various components of gas 

streams (Schiller and Gmehling, 1992), and there is a 1967 reference to use in the production of 

methacrylic acid. It is unknown if butyltriglyme is still used in these applications (LONZA AG, 

1967). 

1.2 Consumer Uses Excluded by the proposed SNUR 

As mentioned above, the proposed SNUR applies to all uses (both consumer and nonconsumer uses) of two glymes and all consumer uses of 12 glymes with the exception of the 

specific excluded consumer uses listed in Table 2. It is important to note that each proposed 

excluded consumer use is only for a specific glyme. For example, the proposed excluded use as 

an electrolyte solution in sealed lithium batteries is only an excluded consumer use for 

monoglyme. It is a proposed significant new use for all other glymes; therefore, the use of any 

other glyme as an electrolyte solution in sealed lithium batteries would be subject to the 

proposed SNUR. 
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Economic Analysis of SNUR 5 U.S. EPA Office of Pollution Prevention and Toxics 

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Of the 14 glymes, nine have no proposed excluded consumer uses: ethylglyme, ethyldiglyme, 

butyldiglyme, tetraethylene glycol dibutyl ether, pentaethylene glycol diethyl ether, tetraethylene 

glycol diethyl ether, polyethylene glycol dibutyl ether, pentaethylene glycol dibutyl ether, and 

butyltriglyme. Five glymes have proposed excluded consumer uses: monoglyme, diglyme, 

triglyme, tetraglyme, and polyglyme (Table 2). 

Table 2: Proposed Excluded Consumer Uses by Chemical 

Glyme CAS RN Proposed Excluded Consumer Uses 

Monoglyme 110-71-4 In electrolyte solutions for sealed lithium 

batteries 

Diglyme 111-96-6 As a solvent in printing inks for consumer 

products 

Triglyme 112-49-2 

As a solvent in consumer adhesives; 

As a component of consumer brake fluids; 

As a component of consumer paint/graffiti 

removers; 

In consumer paints 

Tetraglyme 143-24-8 

As an hydrofluorocarbon/chlorofluorocarbon 

(HFC/CFC) lubricant; 

As a solubilizing agent for consumer printing 

inks; 

As a coalescing agent in consumer paint 

Polyglyme 24991-55-7 Use in consumer paint strippers 

Sources: Novolyte Technologies, 2008a-d; personal communication between Eastern Research Group and Joe 

Valcho (Novolyte Technologies), June 2009; personal communication between Eastern Research Group and Terry 

Wells (Clariant Corporation), June 2009.

• Proposed Excluded Consumer Uses for Monoglyme: Monoglyme is used as an electrolyte in 

sealed lithium batteries (Blomgren and Hunter, 2000) or as a solvent for electrolytes of 

sealed lithium batteries (ERG, 2009a, 2009b). Batteries may contain between one and five 

percent monoglyme and may be sold directly to consumers through battery distributors or as 

components of products containing these batteries (ERG, 2009a). 

• Proposed Excluded Consumer Uses for Diglyme: Diglyme is currently used as a solvent in 

printing inks for consumer products (PNEAC, 1996). Printing inks containing between one 

and five percent diglyme may be sold directly to consumers through distributors (ERG, 

2009a). 

• Proposed Excluded Consumer Uses for Triglyme: Triglyme is currently used as a solvent in 

consumer adhesives. In addition, Triglyme has confirmed uses as a solvent in consumer 

paints (Yamaguchi et al., 1999). Consumers may be able to purchase paint and adhesives 

solvents, each containing between one and five percent triglyme, through distributors (ERG, 

2009a). In addition, triglyme is used as a component of consumer brake fluids and consumer 

paint and graffiti removers (ERG, 2009b). 

• Proposed Excluded Consumer Uses for Tetraglyme: Tetraglyme is used as an HFC/CFC 

lubricant and may be present as a CFC lubricant in consumer air conditioners, in a 

concentration between one and two percent (ERG, 2009a). In addition, the glyme is used as 

a solubilizing agent for printing inks, which may contain one to five percent tetraglyme and 
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be sold to consumers through distributors (ERG, 2009a). Tetraglyme is also used as a 

coalescing agent in paint formulations (Clariant, 2008). Coalescing agents serve to separate 

the sticky molecules of resin while the product is being stored and applied, and the final paint 

product may be used by consumers (ERG, 2009b).

• Proposed Excluded Consumer Uses for Polyglyme: Polyglyme is used to formulate paint 

strippers, adhesive removers, and delacquer formulations and may be present in paint 

strippers accessible by consumers (ERG, 2009b).

1.3 Potentially Affected Industries 

EPA may promulgate a SNUR for a substance when potential use could result in significant 

changes in human exposure or environmental release levels and/or that concern exists about the 

substance’s health or environmental effects (40 CFR §721.170). In contrast to Premanufacture 

Notification (PMN) requirements, which apply mainly to manufacturers and importers (40 CFR 

§720.22), the SNUR can also apply to processors as well as to manufacturers and importers (40 

CFR §721.5). 

This proposed SNUR would require manufacturers, importers, and processors to notify EPA 

at least 90 days before commencing the manufacture, import, or processing of any of the 14 

glymes for any uses not excluded in the proposed SNUR (see Section 1.2). 

Table 3 provides summary information on the industries potentially affected by this proposed 

SNUR. Note that the table is not intended to be entirely comprehensive; rather it provides a 

sample of the potentially affected industries for illustration purposes. 
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Economic Analysis of SNUR 7 U.S. EPA Office of Pollution Prevention and Toxics 

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Table 3: Industries Potentially affected by the proposed SNUR, by NAICS Code 

NAICS Name Description 

Primary Manufacturers of the Glymes

325199 All Other Basic Organic 

Chemical Manufacturing 

This U.S. industry comprises establishments primarily engaged in 

manufacturing basic organic chemical products (except aromatic 

petrochemicals, industrial gases, synthetic organic dyes and 

pigments, gum and wood chemicals, cyclic crudes and intermediates, 

and ethyl alcohol). 

Industries Using the Glymes

335912 Primary Battery 

Manufacturing 

This U.S. industry comprises establishments primarily engaged in 

manufacturing wet or dry primary batteries. 

325910 Printing Ink 

Manufacturing 

This industry comprises establishments primarily engaged in 

manufacturing printing and inkjet inks and inkjet cartridges. 

325510 Paint and Coating 

Manufacturing 

This industry comprises establishments primarily engaged in (1) 

mixing pigments, solvents, and binders into paints and other 

coatings, such as stains, varnishes, lacquers, enamels, shellacs, and 

water repellent coatings for concrete and masonry, and/or (2) 

manufacturing allied paint products, such as putties, paint and 

varnish removers, paint brush cleaners, and frit. 

325520 Adhesive Manufacturing This industry comprises establishments primarily engaged in 

manufacturing adhesives, glues, and caulking compounds. 

336340 Motor Vehicle Brake 

System Manufacturing 

This industry comprises establishments primarily engaged in 

manufacturing and/or rebuilding motor vehicle brake systems and 

related components. 

Source: DOC, 2003, U.S. Department of Commerce, Census Bureau, “2002 NAICS Definitions.” 

1.4 Impact of a SNUR 

The proposed SNUR discussed in this report specifies that any manufacture, import, or 

processing of two glymes for any use, and 12 glymes for consumer uses other than excluded 

consumer uses would be considered a significant new use and require reporting under section 

5(a)(1)(A) of TSCA. Therefore, a firm intending to manufacture, import, and/or process this 

chemical for these applications must submit a SNUN. Alternatively, a firm can decide not to 

manufacture, import, and/or process this chemical. The firm, therefore, has two options: 

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

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

case, means any manufacture, importing, and/or processing of this chemical for purposes that 

are not excluded (see Table 2 for a list of exclusions by chemical). The firm must submit the 

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

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

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

allows the manufacture, import, and/or processing of any of the 14 glymes for a significant 

new use, then the costs associated with this option are the costs of submitting the SNUN 

(including a user fee) plus, if there is any export of these chemicals, the export notification 

costs that result from TSCA Section 12 (b) requirements that are automatically triggered for 

chemicals regulated under TSCA Section 5 (see Section 3 for details). 
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Economic Analysis of SNUR 8 U.S. EPA Office of Pollution Prevention and Toxics 

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

simply decide to not manufacture, import, and/or process any one of the 14 listed glymes for 

a significant new use. While this option avoids the costs of submitting a SNUN, it entails the 

“hidden” cost of the foregone profit as a result of not engaging in the commercial activity 

originally planned. Similarly, if the firm would have used a given amount of one of the 

glymes in the production of another product and must substitute that glyme with a more 

costly substance, it will incur those additional “hidden” costs of production. If the firm elects 

to produce the glyme for research and development (R&D) purposes only (an exemption for 

R&D purposes is provided in 40 CFR §721.47), it may have costs associated with R&D 

recordkeeping. In addition, if the firm exports any existing stockpiles of the chemicals, it 

will incur the export notification costs (see Section 3 for details). 

The remainder of this report estimates the quantified portion of costs associated with the 

proposed SNUR for these uses of glymes. Section 2 presents estimates of the costs incurred by 

manufacturers, importers, and/or processors under the SNUR options. Section 3 addresses onetime export notification costs. Section 1 addresses costs to EPA of administering the SNUR, 

while Section 4 presents an analysis of other impacts, as required by various statutes and 

executive orders. The appendices provide cost estimation details. 

2. COSTS OF A SNUR, BY OPTION 

To meet the requirements of the proposed SNUR, a firm may choose to follow only one of 

the options previously described: submit a SNUN or decide not to manufacture, import, and/or 

process the chemical. The costs of these options are described below. Appendix A provides the 

wage rates and inflators used in this analysis. 

2.1 Submit a SNUN (Option 1) 

Under 40 CFR §721.5, manufacturers, importers, and/or processors that would like to 

undertake a significant new use of a substance listed in a SNUR are required to submit a SNUN 

at least 90 days before the firm plans to commence the manufacture, import, and/or processing of 

the substance. Because the proposed SNUR discussed in this report specifies that any

manufacture, importation, and/or processing of glymes for any uses other than the excluded uses 

constitutes a significant new use, a firm wishing to manufacture, import, and/or process any 

volume of glymes for any significant new use would have to submit a SNUN. The notice form 

used to submit a SNUN is the same as that for a PMN, so the costs of submitting a SNUN are 

estimated based on the costs estimated for submitting a PMN (EPA, 1994). 

This option could have the following costs: 

• Costs of preparing the SNUN and the $2,500 user fee. 

• Costs of avoiding production while the SNUN is being processed; costs of recordkeeping 

and complying with any restrictions resulting from the SNUN review. 

• Costs for the development of test data. EPA does not require the development of test 

data for submission of a SNUN, although a firm may submit test data already in its 

possession and/or describe any other available data. Because EPA does not require the 

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

the proposed SNUR. 
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Economic Analysis of SNUR 9 U.S. EPA Office of Pollution Prevention and Toxics 

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• Costs for export notification, if the chemical is exported (see Section 3 for details) 

Table 4 shows the costs of preparing a SNUN; details are presented in Appendix B. 

Table 4: Costs of Requirement to Submit a SNUN (2008$) 

Cost Element Cost 

(2008$)1

Costs of preparing submission (110 labor hours) $5,955 

User fees $2,5002

TOTAL $8,455 

Notes:

1

Figures are rounded to whole dollars (see Appendix B for derivation). 

2

Small businesses with annual sales of less than $40 million when combined with those of the parent company (if 

any) are subject to a reduced user fee of $100. 

In addition, as was mentioned above, there could be testing costs, delay costs, or other costs not 

included here. Another option available to firms before the SNUR is promulgated is to seek an 

advance compliance exemption under 40 CFR §721.45(h). The submission cost for this option is 

the same as that for a SNUN, but by negotiating an advance compliance agreement with EPA, a 

firm can diminish the loss of profits due to delay. This option is not available after the SNUR is 

promulgated. 

2.2 Decide Not to Produce Chemical (Option 2) 

Some firms may find that the costs of preparing a SNUN are financially unattractive. In this 

case, the firm could choose not to manufacture, import, and/or process the glyme for any 

significant new consumer uses. While this option avoids the costs of meeting the specifications 

in the SNUR or submitting a request for some alternative, it entails the “hidden” cost of the 

foregone profit as a result of not engaging in the commercial activity originally planned. For 

example, if the firm does not produce the substance, then it will forego the profit it would have 

achieved by producing it. That foregone profit is a potential hidden cost of Option 2. Similarly, 

if the firm would have used the substance in the production of another product and must 

substitute a more costly substance, it will incur those additional costs of production. If the firm 

elects to produce the glyme for R&D purposes only, it may have costs associated with R&D 

recordkeeping attributable to the SNUR. These costs were not quantified because of lack of 

information on the number of firms that exercise this option and the lack of data to estimate their 

foregone profits. Firms that exercise option 2 may still incur export notification costs, if they 

export any existing stockpiles of the product. This cost is quantified in Section 3 below. 

2.3 Likelihood of a SNUN Submission 

Given that all current consumer uses of the 14 glymes are excluded from the proposed 

SNURs applicability, the likelihood that manufacturing companies will submit SNUNs is 

expected to be low and limited to consumer uses that are discovered in the future. In addition to 

manufacturers, other companies, such as processors may also submit SNUNs, depending on how 

they use these glymes. 
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2.4 Potential for Subsequent Regulatory Actions 

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

Agency may take additional regulatory actions under TSCA. These additional regulatory actions 

might be necessary to further evaluate an intended new use and associated activities, or to 

prohibit or limit that activity before it occurs to prevent unreasonable risk of injury to human 

health or the environment. It is not known what specific subsequent regulatory actions, if any, 

the Agency may determine are necessary after reviewing a SNUN. Any such actions are highly 

dependent on the circumstances surrounding the individual SNUN (e.g., available information 

and scientific understanding of the chemical and its risks at the time the SNUN is being 

reviewed). 

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

initiate and follow the appropriate procedures for taking those actions. Included in those 

procedures would be an assessment of the costs and benefits of those actions. 

Table 5 summarizes the costs associated with each option, other than the export notification costs 

that are discussed separately in Section 3. 

Table 5: Compliance Options and Associated Costs Incurred by a Firm Due to the 

proposed SNUR 

Option1 Costs Quantified Costs per Chemical 

(2008$)2

1. Submit a SNUN. 

Costs of submitting a SNUN, 

including testing costs, associated 

recordkeeping, and user fee. 

$8,455 submission cost (including 

SNUN recordkeeping and $2,500 fee) 

plus ongoing recordkeeping costs of 

under $1,133. EPA usually receives 

well under ten SNUNs per year. Based 

on review of recent SNUNs, it appears 

that firms rarely conduct toxicity or fate 

testing to support a SNUN (such testing 

would be voluntary).3

2. 

Decide not to manufacture, 

import, or process the 

chemical. 

Cost of the profit foregone as a 

result of not engaging in the 

commercial activity originally 

planned, and recordkeeping costs 

only if manufacturing for research 

and development. 

Costs not quantified. 

1

 Firms may be subject to both options at once since submission of a SNUN results in profits foregone as a result of not 

manufacturing, importing, or processing the chemical. 

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

are detailed in Table A-1 and Appendix A. 

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

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

test data, EPA assumes that no firms will incur testing costs as a result of the proposed SNUR. 
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Economic Analysis of SNUR 11 U.S. EPA Office of Pollution Prevention and Toxics 

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2.5 Agency Costs 

EPA’s costs to review and process SNUNs are assumed to be the same as EPA costs to 

review PMNs. These costs are estimated at $5,693 per case. The required Agency steps, fulltime equivalent (FTE) staff needs, and extramural costs such as for contractor support are 

derived in Appendix C from EPA’s analysis of Agency costs of processing PMN submissions 

(EPA, 1994), with adjustments to reflect inflation and changes in Agency staff levels. The 

original EPA analysis used a range of salaries, but this analysis uses one typical salary. 

The PMN costs reflect estimates developed in 1994, in Regulatory Impact Analysis of 

Amendments to Regulations for TSCA Section 5 Premanufacture Notifications (EPA, 1994). The 

average costs to review a SNUN may be different from those estimated for PMNs, both because 

of differences between PMNs and SNUNs, and because the hours required to review a PMN may 

have changed since 1994. Resources were not available to re-estimate costs for SNUNs. See 

Appendix C for details. 

3. EXPORT NOTIFICATION COSTS 

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

a chemical subject to various TSCA sections (40 CFR §707.60 through 75). For TSCA 5(a)(2) 

(the section under which EPA promulgates significant new use rules) and certain other TSCA 

sections, this is a one-time notification requirement1

 per destination country for each exporter of 

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

country and the United States State Department (40 CFR §707.70). 

3.1 Estimated Number of Exporters and Export Notifications 

To identify the number of potential exporters of glymes in the United States, EPA relied on 

the TSCA Inventory Update Reporting (IUR) information combined with chemical buyers’ 

guides, chemical producer databases, and other comparable reference materials. Because a 

single export notification can include multiple chemicals, an entity was only counted once, even 

if it exports multiple glymes. At total of 30 different companies were identified as possible 

glymes exporters.2 

To estimate the number of export locations, the EPA consulted the U.S. International Trade 

Commission (ITC) Harmonized Tariff System (HTS). The ITC tracks U.S. imports and exports 

of chemicals and other goods under distinct Harmonized Tariff System codes. EPA determined 

that glymes fit under the HTS subheading 2909.19.6000 [Chapter 29: Article IV: Ethers, etheralcohols, ether-phenols, ether-alcoholphenols, alcohol peroxides, ether peroxides, ketone 

peroxides (whether or not chemically defined), and their halogenated, sulfonated, nitrated or 

nitrosated derivatives: Acyclic ethers and their halogenated, sulfonated, nitrated or nitrosated 

derivatives: Ethers of polyhydric alcohols: Other], because glymes are diethers of [poly]ethylene 

 

1

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

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

(November 14, 2006, 71 FR 66234). 

2 It should be noted that while the Ferro Corporation is listed as a producer of glymes in the 2006 IUR data it is not 

included in the count of 30 possible exporters. Ferro has transferred its glymes production to Novolyte 

Technologies Inc since the last IUR reporting cycle (ERG, 2009). 
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Economic Analysis of SNUR 12 U.S. EPA Office of Pollution Prevention and Toxics 

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glycol and are therefore acyclic. Because ITC does not measure imports and exports of glymes 

within a distinct HTS code (examples of other chemicals in this group include triethyl 

orthoformate (CAS No. 122-51-0), and 2-methoxyethoxymethyl chloride (CAS No. 3970-21-6) 

or other chemicals with more than two ether moieties, ether moieties with non-identical alkyl 

groups, or halogenated, sulfonated, nitrated or nitrosated derivatives of any of these ethers), EPA 

was unable to determine the exact number of export locations. Therefore, for the purposes of 

this analysis, EPA assumes that glymes are exported to 12 destinations, reflecting the average 

number of yearly export notifications estimated for the 2009 TSCA §12(b) ICR (EPA, 2009).3 

This analysis assumes that each of the 30 potential exporters submits on average 12 

notifications per year. This may be an overestimate, as not all 30 of the potential exporters may 

choose to export a glyme. In addition, the estimate may be upwardly biased, because a single 

export notification can include multiple chemicals and/or destination countries. Combining the 

estimated number of regulated exporters under the proposed rule and their projected annual 

number of submissions yields an estimate of 360 export notifications submitted to EPA per year, 

shown in Table 6. 

Table 6: Estimated Number of Exporters and Export Notifications Submitted to EPA as a 

Result of the Proposed SNUR 

Number of 

Submitters 

Export Notifications per 

Submitter 

Total Export Notifications 

sent to EPA 

(a) (b) (c) = (a)*(b) 

30 12 360 

3.2 Exporter Costs 

The 2009 TSCA Section 12(b) ICR, ICR No.: 0795.13 [Information Collection Request for] 

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

OMB Review under the Paperwork Reduction Act (EPA, 2009, page 11, Table 3), estimated the 

annual export notification cost for an exporter under the one-time export notification 

requirement. These costs include the cost to the exporter of compiling a list of their products that 

are subject to TSCA Section 12(b) requirements, writing or revising an export notification letter 

to EPA, checking the outgoing shipments, and sending the notification letters with the associated 

shipping costs 

3.2.1 Compile and Maintain the List of Products 

Since TSCA §12(b) information collection activity has been in place for twenty years, most 

respondents will have already developed a list of their products subject to TSCA §12(b) export 

notification. Respondents need only check for new regulations promulgated and any new 

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

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

burden can vary from two hours per year up to two hours per month, depending on the number of 

 

3 EPA calculated the average number of export notifications per exporter in ICR No.: 0795.13 [Information 

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

for OMB Review under the Paperwork Reduction Act by dividing the estimated number of submitted notifications 

(3,500) by the estimated number of exporters (300). 
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Economic Analysis of SNUR 13 U.S. EPA Office of Pollution Prevention and Toxics 

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

(EPA, 2009a). 

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

rising from around 160 in 1991 to over 460 in 2000, and declining since. In the most recent 

TSCA §12(b) ICR, EPA estimated there would be approximately 300 submitters per year in 

near-future years (EPA, 2009a). Of these 300 submitters, EPA estimated that 200 companies 

were near the lower burden estimate of 2 hours per year, and 100 companies were near the upper 

estimate of 24 hours per year. Compiling the list for all respondents was therefore estimated to 

take 2,800 hours (2 hours x 200 firms plus 24 hours x 100 firms), or an average of about 9.3 

hours of technical time per firm per year (EPA, 2009). 

3.2.2 Write or Revise Export Notification 

Companies that export chemicals subject to TSCA §12(b) reporting must prepare an export 

notification to send to EPA when export shipments are made. Time for initial preparation of the 

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

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

also include some proportion of legal time) per firm per year (EPA, 2009). 

3.2.3 Check Orders and Send Notifications 

Companies that export chemicals subject to TSCA §12(b) reporting must check outgoing 

shipments against the list of their products described above. A form letter notifying EPA and 

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

process is estimated to take an average one half hour of clerical time per export notification, or 6 

hours of clerical time per firm per year (assuming exporters submit approximately 12 

notifications per year) (EPA, 2009). The burdens and associated costs for each notification 

activity are provided in Table 7 below: 

Table 7: TSCA 12(b) Export Notification Cost: Annual Burden per Respondent Facility 

(2008$) 

 Technical Clerical Total 

 $/Hr Hours 2008$ $/Hr Hours 2008$ 2008$ Hours 

Compile list $58.84 9.3 $547 -- -- -- $547 9.3 

Write letter $58.84 1 $59 -- -- -- $59 1 

Check order and send 

notice 

-- -- -- $28.48 6 $171 $171 6 

Total per facility` 10.3 $606 6 $171 $776 16.3 

Notes: 

1

An average facility is assumed to submit 12 export notifications per year. 

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

0795.13 [Information Collection Request for] Notification of Chemical Exports - TSCA Section 12(b) Supporting 

Statement for Request for OMB Review under the Paperwork Reduction Act (EPA, 2009, p.10), and are updated to 

2008 dollars. 
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Economic Analysis of SNUR 14 U.S. EPA Office of Pollution Prevention and Toxics 

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3.2.4 Estimated Submission (Mailing) Costs 

Regulated companies will also incur mailing costs for export notifications delivered to EPA. 

Notifications are assumed shipped via the U.S. Postal Service (USPS) as first-class registered 

mail with a return receipt. Each shipment is estimated to cost $13.34: $10.60 for registered mail, 

$2.20 for a return receipt, and $0.44 for first-class postage (USPS, 2009). The estimated pershipment and annual mailing costs incurred by individual submitters are detailed in Table 8 

Table 8: Derivation of Total Mailing Cost for 12 Notices 

Dates that the rates were verified on United States Postal Service web 

site: 

May 2008 December 2009 

Postal services costs 

Registered mail, regular, with $0 declared value $10.00 $10.60 

Return receipt, requested at time of mailing (receive by mail) $2.20 $2.30 

Postage, regular First Class, up to 1 ounce $0.42 $0.44

Cost per export notice - Subtotal $12.62 $13.34 

×12 × 12

Total Mailing Cost for 12 Notices $151.44 $160.08 

Notes: 

Information in italics shows the exact postal services for which the costs were estimated in [Information Collection 

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

Review under the Paperwork Reduction Act. ICR No.: 0795.13 (EPA, 2009). These costs are included for 

comparison with the costs in this report. Costs for the 2009 report were verified in May of 2008, as show in the 

Economic Analysis of Expedited Significant New Use Rules for 56 Chemical Substances (EPA, 2008). 

Source: Mailing rates are from the US Postal Service web site as of May 2008 and December 2009 

(http://www.usps.com/prices/). 

3.2.5 Estimated Annual Industry Compliance Cost 

The aggregate, annual industry compliance cost of the TSCA §12(b) export notification 

requirement, is the sum of the annual compliance cost across all potentially regulated entities. 

Assuming a population of 30 submitters, a per-submitter labor cost of $776.91, and a persubmitter mailing cost of $160.08 the annual industry cost will be $936.99. This estimate likely 

overstates the cost to industry of the proposed rule, as it assumes that exporters will not combine 

multiple destination countries into a single export notification, and it further assumes that 

exporters will submit 12 notifications each year, following the methodology outlined in the 2009 

TSCA Section 12(b) ICR (EPA, 2009), implying growth in exported chemicals and/or export 

destinations. The export notification cost per notice is estimated to be $78 ($936.99/12). 

However, it is expected that the cost per notice may be decreasing in the total number of notices 

so that the cost per notification may be higher for an exporter that has only one notification. 

Table 9: Industry Total Cost Estimate per Year (2008$) 

Labor Cost Mailing Cost Total Cost 

Number of 

Submitters Per 

Submitter 

Total 

Industry 

Cost 

Per 

Submitter 

Total 

Industry 

Cost 

Per 

Submitter 

Total 

Industry 

Cost 
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Economic Analysis of SNUR 15 U.S. EPA Office of Pollution Prevention and Toxics 

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30 $776.91 $23,307 $160.08 $4,802 $936.99 $28,110 

Source: 

Table 7 of this report derives industry labor costs and Table 8 derives industry mailing costs

3.2.6 Estimated Three-Year Industry Compliance Cost 

Assuming constant annual industry compliance cost and a seven percent discount rate, the 

proposed SNUR imposes a total three-year industry cost of $78,932. 

Table 10: Three Year Industry Costs (2008$) 

Year Industry Cost Present Value 

Year 1 $28,110 $28,110 

Year 2 $28,110 $26,271 

Year 3 $28,110 $24,552 

Total $84,329 $78,932 

3.3 Agency Costs 

3.3.1 Methodology for Agency Burden and Cost Analysis 

The agency burden and cost incurred as a result of the TSCA §12(b) export notification 

requirement are calculated using estimates of agency wage rates; the EPA staff time required to 

process incoming export notifications from industry and outgoing notifications to importing 

countries; and the EPA staff time required to handle requests for information and clarification 

from industry, importing countries, and the general public. These estimates are derived below 

and the annualized costs to EPA over three years are then calculated. 

3.3.2 Estimated Number of Notifications Submitted to EPA and Sent to Importing 

Countries 

As previously described there are a total of 30 possible exporters of glymes, each of which is 

expected to submit 12 export notifications to EPA approximately each year, for a total estimated 

360 additional export notifications submitted to EPA per year. In the 2009 TSCA §12(b) ICR, 

EPA further estimated it will deliver a total of 54 notification letters to importing countries per 

year (EPA, 2009). The marginal effect of the proposed rule on EPA notification of importing 

countries is thus based on an estimate of the number of countries receiving U.S. exports of 

chemicals under the HTS subheading that contains glymes. According to ITC, an average of 35 

countries received U.S exports of chemicals under HTS subheading that contains glymes (HTS 

2909.19.6000 [Chapter 29: Article IV: Ethers, ether-alcohols, ether-phenols, etheralcoholphenols, alcohol peroxides, ether peroxides, ketone peroxides (whether or not chemically 

defined), and their halogenated, sulfonated, nitrated or nitrosated derivatives: Acyclic ethers and 

their halogenated, sulfonated, nitrated or nitrosated derivatives: Ethers of polyhydric alcohols: 

Other]) per year from 2007 to 2008. Because this category includes other chemicals besides 

glymes some of the countries on the ITC list may not import glymes but rather import other 

chemicals under HTS subheading 2909.19.6000. Therefore it is likely that the estimate of 35 

glyme importing countries is an over estimate, and all costs in this section are overstated as a 

result. 
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Economic Analysis of SNUR 16 U.S. EPA Office of Pollution Prevention and Toxics 

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Table 11: Estimated Number of Export Notifications Submitted to EPA and 

Notifications sent to Importing Countries 

Additional EPA Incoming Notifications 

(from Exporting Companies)

Additional EPA Outgoing Notifications 

(to Importing Countries)

360 35 

3.3.3 Estimates of Labor Hours (Burden) and Cost 

The Agency burden and cost associated with TSCA §12(b) export notification can be 

divided into three parts; 1) receiving and processing incoming notifications from exporters, 2) 

preparing and mailing notifications to importing countries, and 3) responding to requests for 

information and clarification from companies and importing countries. The allocation of burden 

hours and costs among these three parts is not exact, but the analysis below is expected to be 

reasonably accurate in terms of the overall burden estimate and the approximate allocation of 

that burden among these tasks. 

In the first task, EPA receives export notifications from companies that intend to export one 

of the chemicals subject to TSCA §12(b). These forms are checked for completeness and the 

submissions are logged into a document control system. Based on conversations with workers 

responsible for this task, about ten notifications can be processed per hour, or one notification 

every 0.1 hours (EPA, 2009). As a result, Agency staff are estimated to spend a total of 36 hours 

per year for 360 incoming notifications resulting from the proposed rule. This estimate includes 

a certain amount of time spent responding to routine requests for information. 

In the second task, EPA staff prepares separate notification letters that are subsequently 

reviewed and delivered to importing countries, their embassies, or representatives. This activity 

is estimated to take 0.5 hours per outgoing notification for a total of 17.5 hours per year for 35 

outgoing notifications. 

The third task comprises EPA staff response to public inquiries. The work of responding to 

non-routine requests for information and clarification from industry and importing countries and 

handling other tasks associated with the TSCA §12(b) program was estimated to require about 

20% of the time of a GS-13, Step 5 FTE employee, or roughly 400 hours per year, in the 2009 

TSCA §12(b) ICR. The ICR derived this estimate under the assumption of 300 submitters and 

54 notified countries per year, for a total of 354 potentially inquiring entities per year (EPA, 

2009, pages 12-13). Assuming the same ratio of staff time per inquiring entity (400/354), the 

additional 30 exporters and 35 importing countries estimated to be affected by the proposed rule 

may require approximately 73 hours of staff time per year. The burdens and for each Agency 

activity are provided in Table 12 below. To estimate the Agency cost, hourly burdens are 

multiplied by the loaded wage rate of a GS-13, Step 5 (150,440), which is derived in Appendix A 
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Economic Analysis of SNUR 17 U.S. EPA Office of Pollution Prevention and Toxics 

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Table 12: TSCA 12(b) Export Notification Cost: Annual Agency Burden (2008$) 

Hours per 

Notification

Number of 

Notifications 

Hours per 

Year FTE per Year 

Loaded 

GS-13, Step 5 FTE 

Wage Rate

Total Agency 

Costs Agency 

Activity 

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

Process 

notices from 

companies 

0.10 360 36.00 0.017 $150,440 $2,604 

Process 

notices to 

importing 

countries 

0.50 35 17.50 0.008 $150,440 $1,266 

EPA staff 

responding to 

information 

requests, etc. 

(400/354) 65 73.24 0.035 $150,440 $5,297 

Total - - 126.74 0.061 -- $9,167 

Source: Appendix A of this report derives Agency labor costs. Other burdens are from ICR No.: 0795.13 [Information Collection 

Request for] Notification of Chemical Exports - TSCA Section 12(b) Supporting Statement for Request for OMB Review under the 

Paperwork Reduction Act

3.3.4 Estimates of Submission (Mailing) Costs 

EPA will incur mailing costs to deliver notifications to importing countries. Notifications are 

assumed shipped to the importing countries’ embassies, rather than a foreign address, as the 

lowest-cost shipping option. Notifications are further assumed mailed with the U.S. Postal 

Service (USPS) as first-class registered mail with a return receipt. Each shipment is estimated to 

cost $13.34: $10.60 for registered mail, $2.20 for a return receipt, and $0.44 for first-class 

postage (USPS, 2009). EPA estimates that the Agency will send notices to 35 countries. The 

estimated per-shipment and annual mailing costs incurred by the Agency are detailed in Table 

13. 
*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review *** 

 

Economic Analysis of SNUR 18 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

Table 13: Derivation of Agency Mailing Cost for 35 Notices 

Dates that the rates were verified on United States Postal Service web 

site: 

May 2008 December 2009 

Postal services costs 

Registered mail, regular, with $0 declared value $10.00 $10.60 

Return receipt, requested at time of mailing (receive by mail) $2.20 $2.30 

Postage, regular First Class, up to 1 ounce $0.42 $0.44

Cost per export notice - Subtotal $12.62 $13.34 

×35 × 35

Total Mailing Cost for 12 Notices $441.7 $466.90 

Notes: 

Information in italics shows the exact postal services for which the costs were estimated in [Information Collection 

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

Review under the Paperwork Reduction Act. ICR No.: 0795.13 (EPA, 2009). These costs are included for 

comparison with the costs in this report. Costs for the 2009 report were verified in May of 2008, as show in the 

Economic Analysis of Expedited Significant New Use Rules for 56 Chemical Substances (EPA, 2008). 

Source: Mailing rates are from the US Postal Service web site as of May 2008 and December 2009 

(http://www.usps.com/prices/). 

3.3.5 Estimates of Annual Agency Cost 

The annual agency cost of the TSCA §12(b) export notification requirement triggered by the 

proposed SNUR is $9,634, the sum of agency labor and mailing costs. This estimate likely 

overstates the cost to EPA of the proposed rule, as it assumes that 35 countries will receive U.S. 

exports of the glymes. 

Table 14: Agency Total Cost Estimate per Year (2008$) 

Number of Incoming 

Notifications 

Number of 

Outgoing 

Notifications 

Labor 

Cost 

Mailing 

Cost Total Cost 

360 35 $9,167 $467 $9,634

Source: 

Table 12 of this report derives Agency labor costs and Table 13derives Agency mailing 

costs

3.3.6 Estimates of Three-Year Agency Cost 

Assuming constant annual agency cost and a seven percent discount rate, the proposed 

SNUR imposes a total three-year agency cost of $27,051. 
*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review *** 

 

Economic Analysis of SNUR 19 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

Table 15: Three Year Agency Costs (2008$) 

Year Industry Cost Present Value 

Year 1 $9,634 $9,634 

Year 2 $9,634 $9,003 

Year 3 $9,634 $8,414 

Total $28,901 $27,051 

4. ADDITIONAL ANALYSES 

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

required under various statutes and executive orders. 

4.1 Regulatory Flexibility Act 

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

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

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

the promulgation of SNURs covering more than 1,000 chemicals, the Agency receives only a 

handful of notices per year. For example, the number of SNUNs was four in Federal fiscal year 

2005, eight in FY2006, six in FY2007, and eight in FY2008.4 During this four-year period, one 

SNUN was submitted by a small entity.5 The criterion for “small business” was that the 

company checked the box on page 2 of the PMN form, stating that it was a small business for the 

purpose of paying the $100 fee instead of the normal fee. 

This leaves open the question of how many small businesses are affected but do not submit 

SNUNs. For example, businesses may change their behavior in order to use a chemical in a 

manner that avoids triggering significant new use notification requirements and make no 

submission to EPA. Data and resources were not available to estimate the number of small 

businesses affected by the current rule. 

Small businesses may be affected by SNURs without EPA being aware; for example, if the 

firms have made no submissions or comments to EPA. However, even if a small business were 

interested in supplying a SNUR chemical, the SNUR’s impact on profits is generally expected to 

be minor. For example, the firm may have a small expense of keeping records and/or of 

changing workplace practices to comply with any new restrictions. If modifying production 

practices would be overly costly, or if the firm wishes to engage in a significant new use but 

believes that expensive testing is needed to support a submission to EPA, it may instead forego 

production, thus sacrificing profits. The amounts of lost profits, if any, were not quantified for 

this report, but are expected to be low because the proposed SNUR does not apply to nonconsumer uses for 12 out of the 14 glymes, and all confirmed consumer uses of the glymes are 

also exempt. Any remaining consumer uses are expected to be new so that they unlikely to be 

central to a firm’s business. Based on these considerations and on the limited data available, 

 

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

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

numbering is according to Federal fiscal year, ending September 30. 5

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

Kimberly Wilson, Abt Associates. 
*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review *** 

 

Economic Analysis of SNUR 20 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

EPA expects that any compliance with a SNUR will not have a significant economic impact on a 

substantial number of small entities. 

4.2 Unfunded Mandates Reform Act 

EPA has determined that this regulatory action does not impose any enforceable duty, 

contain any unfunded mandate, or otherwise have any effect on small governments subject to the 

requirements of sections 202, 203, 204, or 205 of the Unfunded Mandates Reform Act of 1995 

(Public Law 104-4). 

4.3 Paperwork Reduction Act 

According to the Paperwork Reduction Act (PRA), 44 USC 3501 et seq., an agency may not 

conduct or sponsor, and a person is not required to respond to, a collection of information that 

requires Office of Management and Budget (OMB) approval under the PRA, unless it has been 

approved by OMB and displays a currently valid OMB control number. The information 

collection requirements related to this action have already been approved by OMB pursuant to 

the PRA under OMB control number 2070-0038 (EPA ICR No. 1188). This action does not 

impose any additional burden requiring OMB approval. 

4.4 National Technology Transfer and Advancement Act 

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

Technology Transfer and Advancement Act of 1995 (NTTAA), Public Law 104–113, section 

12(d) (15 U.S.C. 272 note), does not apply to this action. 

4.5 Executive Order 12866: Regulatory Planning and Review 

 Under Executive Order 12866, entitled Regulatory Planning and Review (58 FR 51735, 

October 4, 1993), the Office of Management and Budget (OMB) has determined that this 

proposed SNUR is a ‘‘significant regulatory action,’’ because it meets the criteria in section 3(f) 

of the Executive Order. Accordingly, this action was submitted to the OMB for review under 

Executive Order 12866 and any changes made based on OMB recommendations have been 

documented in the public docket for this rulemaking as required by section 6(a)(3)(E) of the 

Executive Order. 

4.6 Executive Order 12898: Environmental Justice 

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

required by Executive Order 12898, Federal Actions to Address Environmental Justice in 

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

4.7 Executive Order 13045: Protection of Children 

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

Risks (62 FR 19885, April 23, 1997), requires EPA to identify and assess environmental health 

and safety risks that may disproportionately affect children. This type of analysis is required for 

rules that will have an impact of $100 million or more only. The impact of the proposed SNUR 

will be less than $100 million, and therefore no analysis of such impacts on children is required. 
*** EO 12866 Review DRAFT – Do Not Cite, Quote or Release During the Review *** 

 

Economic Analysis of SNUR 21 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

4.8 Executive Order 13132: Federalism 

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

develop an accountable process to ensure “meaningful and timely input by State and local 

officials in the development of regulatory policies that have federalism implications.” This 

action will not have a substantial direct effect on States, on the relationship between the national 

government and the States, or on the distribution of power and responsibilities among the various 

levels of government, as specified in Executive Order 13132, entitled Federalism (64 FR 43255, 

August 10, 1999). 

4.9 Executive Order 13175: Tribal Governments 

Executive Order 13175 is Consultation and Coordination with Indian Tribal Governments 

(59 FR 22951, November 6, 2000). This rule does not have Tribal implications because it is not 

expected to have substantial direct effects on Indian Tribes. 

4.10 Executive Order 13211: Energy Supply, Distribution, or Use 

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

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

because this action is not expected to affect energy supply, distribution, or use. 
APPENDIX A 

INFLATORS AND WAGE RATES
Economic Analysis of SNUR A-1 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

A. INFLATORS AND WAGE RATES 

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

used in calculating costs of labor, materials, and other inputs. Costs for this report are for yearend 2008. 

A.1 Derivation of Loaded Wage Rates 

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

to derive a fully loaded labor cost. The basic method is described in Wage Rates for Economic 

Analysis of the Toxics Release Inventory Program (EPA, 2002b). The resulting loaded labor 

rates are given in Table A-1. Costs are calculated for several labor categories: Managerial, 

Professional/Technical, Clerical, and EPA staff. 

In March 2004, BLS began using the North American Industry Classification System 

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

Occupational Classification (SOC) system instead of the Occupational Classification System 

(OCS). The following table shows the crosswalk between old and new occupational titles. 

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

Managerial Executive, administrative, and 

managerial 

Management, business, and 

financial 

Professional/Technical Professional specialty and technical Professional and related 

Clerical Administrative support, including 

clerical Office and administrative support 

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

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

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

Production Labor 

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

labor were taken from the Bureau of Labor Statistics (BLS) Employer Costs for Employee 

Compensation (ECEC) data,6

 for December, for manufacturing industries.7

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

are taken from the same ECEC series. Fringe benefits as a percent of wages are calculated 

separately for each labor category. For example, for December 2008, the average wage rate for 

 

6

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

Substances: EPA Docket OPPT-2003-0063 (EPAB, 2007a). 7

 Employer Costs for Employee Compensation Supplementary Tables: Historical Data December 2006 – December 2008. 

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

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

manufacturing sector data seem more relevant since the SNURs mainly affect the chemicals industry. 
Economic Analysis of SNUR A-2 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

professional/technical8 labor was $35.29; the average fringe benefit was $17.55. Fringe benefits 

as a percent of wages were $17.55/$35.29, or approximately 49.7 percent. 

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

approach is used for consistency with Office of Pollution Prevention and Toxics economic 

analyses for two major rulemakings: Wage Rates for Economic Analyses of the Toxics Release 

Inventory Program (EPA, 2002b), and the Revised Economic Analysis for the Amended 

Inventory Update Rule: Final Report (EPA, 2002a). This overhead loading factor is added to the 

benefits loading factor, and the total is then applied to the base wage to derive the fully loaded 

wage. For example, the December 2008 fully loaded wage for professional/technical labor is 

$35.29 × (1+0.4973+0.17) = $58.84. 

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

manner, as shown in Table A-1. 

A.1.3 Derivation of Labor Rates for EPA Staff 

Agency labor costs are calculated based on annual Federal salaries for the WashingtonBaltimore area published by the Office of Personnel Management effective January 2008 (OPM, 

2008). The average salary for one FTE staff member is estimated as the salary for a GS-13 

Step 5 employee.

9

 

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

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

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

Collection Requests (ICRs) (EPA, 1992a, page 30, footnote 9). The 60 percent assumption was 

labeled “the benefits multiplication factor” in the EPA Guide, but has been used in many EPA 

Office of Pollution Prevention and Toxics ICRs to reflect both fringe benefits and overhead for 

Federal staff. For example, it was used in an August 2000 document supporting ICR No. 

1139.06 (EPA, 2000), with the following explanation: 

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

benefits multiplication factor). The multiplication factor used is recommended in EPA’s 

Office of Policy, Planning, and Evaluation’s Instructions for Preparing Information 

Collection Requests (ICRs) (June 1, 1992). An EPA internal phone call between Carol 

Rawie (OPPT/EETD/RIB) and Carl Koch (OPPE/RMD/IMB) on May 3, 1994, indicated 

that the 1.6 factor included not only benefits but also overhead.” (ICR No.1139.06) 

 

8 This follows terminology introduced in EPAB, 2007a. Earlier SNUR economic analyses used the term “technical” labor. Here 

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

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

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

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

and Occupation ECEC Series (Weinstein, 2004). 9

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

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

analysis (EPA, 2003a), which used an average of GS-12 Step 1 and GS-12 Step 10 salaries.
Economic Analysis of SNUR A-3 U.S. EPA Office of 

For Non-Exempt Use of 14 Glymes Econo

Table A-1: Derivation of Loaded Wage Rates 

Wage Fringe Benefit Fringes as % Wage Over- head % Wage2 Fringe + Overhead Factor 

EPAB Labor Category Data Sources Date 

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

Managerial 

BLS ECEC, Private Manufacturing 

industries, “Mgt, Business, and Financial”3

Dec-08 $43.22 $19.46 45.03% 17% 1.62 

Professional/ 

Technical 

BLS ECEC, Private Manufacturing 

industries, “Professional and related“3

Dec-08 $35.29 $17.55 49.73% 17% 1.67 

Clerical 

BLS ECEC, Private Manufacturing 

industries, “Office and Administrative Support” 3

Dec-08 $17.22 $8.33 48.37% 17% 1.65 

EPA staff 

FTE 

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

Dec-08 $94,025(annual) -- 

[Included in 

60% 

overhead] 

60% 1.6 

Notes: 1Wage data are rounded to the closest penny in this table; however, in calculations using these numbers for this report, unrounded values were used. 2An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b), a

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

3The salary is unloaded Federal GS-13 Step 5 salary for calendar 2008, from the Office of Personnel Management salary table for Washington-Baltimore-N

The 60% fringes-and-overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (EPA, 1992a, page 30, footn
Economic Analysis of SNUR A-4 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

A.2 Derivation of Inflation Factors 

Complete information on the derivation of the inflation factors used is given in Table A-2. In 

2006, the Bureau of Labor Statistics (BLS) made several changes to the Employment Cost Index. 

The changes are described on a BLS web page, “Change has come to the ECI,” (BLS, 2006c) 

and in several April 2006 Monthly Labor Review articles posted on the BLS web site: “Changes 

affecting the Employment Cost Index: an overview” (Caroll 2006); “Employment Cost Index 

Publication Plans” (Sleemi, 2006); and “Seasonal adjustment in the ECI and the conversion to 

NAICS and SOC” (Branch, 2006). 

Under a mandate from OMB, BLS changed its classification of industries and occupations 

from the Standard Industrial Classification (SIC) and Occupational Classification System (OCS) 

to the North American Industry Classification System (NAICS) and Standard Occupational 

Classification (SOC) system. In 2006, BLS adjusted all ECI series to reflect this change. 

In addition to changing the industry and occupational classification systems, in 2006, BLS 

rebased the ECI from June 1989 = 100 to December 2005 = 100 for all current and historical 

non-seasonally adjusted series, including the NAICS and SIC based series. (Seasonally adjusted 

indices, including those in Table A-2 of this report, may not exactly equal 100 for December 

2005 as a result of the seasonal adjustment. Seasonal adjustments are explained in Branch, 

2006.) 

According to BLS, the official ECI for the years 1975-2005 is the SIC-OCS based series, 

and for subsequent years, the official ECI is the NAICS-SOC based series (Sleemi, 2006, p.8).10 

“Starting year” indices in Table A-2 continue to be SIC-SOC based. Current year indices 

are NAICS-SOC based. We use indices from both the NAICS-SOC and the SIC-OCS based ECI 

series because neither series spans the entire period over which testing and other costs need to be 

inflated. 

 

10 BLS has been publishing the NIACS-SOC based ECI series since March 2001 and it became official in March 2006. The 

SIC-OCS based series and NAICS-SOC series have different series ID numbers, even when they describe essentially the same 

population. For example the series ID for seasonally adjusted total compensation for all private industry workers is 

ECS10002I for the SIC-OCS series and CIS2010000000000I for the NAICS-SOC series. 
Economic Analysis of SNUR A-5 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

Table A-2: Derivation of Inflation Factors 

Item Inflation Index Source1 Starting 

Year 

Index for 

Starting Year 

(a) 

Index for 

2008 

(b) 

Inflation 

Factor 

(b)/(a)2

Export notification 

BLS ECI, not SA, Total comp, 

Private industry, White Collar. 

ECS11102I, 4th Q [BLS, 2008a] 

1992 63.2 109.4 1.731 

Agency Extramural costs 

White collar labor; 

equipment; supplies

BLS ECI, not SA, Total comp, 

Private industry, White Collar. 

ECS11102I, 4th Q [BLS, 2008a]

1993 65.5 109.4 1.670 

Labels, placards etc. 

File cabinet 

 

BLS CPI, inflation calculator, not 

SA. Annual [BLS, 2008b] 1997 160.5 215.303 1.341 

Photocopies 

Record keeping materials 

 

BLS CPI, inflation calculator, 

Annual [BLS, 2008b] 1988 118.3 215.303 1.820 

Key: BLS = Bureau of Labor Statistics. CPI = Consumer Price Index. ECI = Employment Cost Index. SA = Seasonally Adjusted. Total 

Comp = Total Compensation (wages/salaries and benefits). 4th Q = Fourth Quarter. “ECS10002I” etc. refer to BLS series Ids. 

Notes: 

1 In 2006, Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) series “were rebased to December 2005 = 100 from June 

1989 = 100.” The change is reflected in the indices in this table and explained on the BLS website, Employment Cost Index News 

Release Text: Employment Cost Index, March 2006 (BLS, 2006b). The Consumer Price Index (CPI) was not rebased. 

“Starting year” ECI indices are SIC-OCS based: ECS10002I for private industry All Workers, and ECS11102I for private industry 

White Collar Workers. The indices are Seasonally Adjusted (SA). 

After 2006, ECI indices are NAICS-SOC based: CIS2010000000000I for private industry All Workers, and CIS2010000W00000I for 

private industry White Collar Workers. The indices are Seasonally Adjusted. 

2 Inflation factors are rounded to three decimal places in this table, but calculations in this report use the unrounded values. BLS CPI 

values were published with one decimal place through 2006 and with three decimal places after that. 
APPENDIX B 

COSTS FOR SNUN 
Economic Analysis of SNUR B-1 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

B. COSTS FOR SNUN 

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

on the costs of completing a PMN submission, since the data requirements are the same and the 

same form is used for both. EPA’s 1994 Regulatory Impact Analysis (RIA) for amendments to 

the PMN regulations relied on industry estimates of the effort needed to collect and compile all 

data required for a PMN submission, prepare the form, and submit the form and data to EPA 

(EPA, 1994). These estimates were based on a survey conducted by the Chemical Manufacturers 

Association (CMA, 1991), which became the American Chemistry Council. 

In the 1994 EPA report, the average effort required to prepare and submit a PMN was 95 to 

114 hours. This included recordkeeping for the submission, but the recordkeeping cost was not 

broken out. For this analysis, the costs of a preparing a SNUN were derived using the averages 

of the hours for each type of labor from the 1994 report. The method of calculating hourly 

loaded labor costs is described in Appendix A. In addition to preparing and submitting a SNUN, 

manufacturers must maintain records on the submission for five years. Thus, this analysis 

includes a recordkeeping burden assumed to be five percent of the preparation and submission 

burden (5.3 hours); this is assumed to be performed with clerical labor. Thus, the total time 

burden for SNUN preparation, submission, and recordkeeping is estimated to be between 100 

and 119 hours.

Table B-1 details the cost of submitting a SNUN, including the $2,500 EPA notification user 

fee. 

Table B-1: Industry Costs for SNUN 

Labor Category Hours Range1 Average Hours Loaded Wage Rate2

(2008$) SNUN (Option 1) 

Clerical 12 - 14 13 $28.48 $370 

Technical 67 - 80 73.5 $58.84 $4,325 

Managerial 16 - 20 18 $70.03 $1,260 

Subtotal 100.3 – 119.3 109.8 $5,955 

User fee (SNUN only) $2,500 

TOTAL $8,455 

Notes: 

1 Hours range for each labor category are from the PMN Amendments RIA (EPA, 1994). 2

 Loaded wages include fringe benefits and overhead. See Appendix A for derivation. Wage rates presented in this 

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

labor costs may not equal the product of rounded values. 
APPENDIX C 

AGENCY COSTS 
Economic Analysis of SNUR C-1 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

C. AGENCY COSTS 

EPA submission review costs are presented in Table C-1. Costs to review and process 

industry submissions – SNUNs, requests to modify a SNUR, and requests for equivalency 

determination – are assumed to be similar to EPA costs to review PMNs.11 

The list of review steps, estimates of staff-year full-time equivalents (FTEs), estimates of 

extramural costs, and the percent of chemicals requiring a particular review step are derived from 

the costs for processing PMN submissions in Table VII-1 of a 1994 EPA report, Regulatory 

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

(EPA, 1994). 

The GS levels used for Agency staff reflect the judgment of Agency staff familiar with the 

PMN/SNUN review process. The salary of a Full Time Equivalent EPA staff was calculated 

using GS-13 Step 5 salary data (OPM, 2008). The original PMN cost estimates were for GS-12 

and were presented as low and high estimates, based on the most junior (Step 1) and the most 

senior (Step 10) GS-12 pay rates, respectively. However, this analysis uses the higher GS-13 

staff level and, for simplicity, a single intermediate pay rate (Step 5) within that GS level. A 

loading factor of 1.6 was applied to the salary to reflect fringe benefits and overhead (EPA, 

1992a). The loaded salary calculations are described in Appendix A. 

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

(in the first column) by the fully loaded average salary. This shows EPA staff cost for chemicals 

requiring the selected review step. 

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

for chemicals requiring the selected review step, inflated from 1993 prices, as explained in 

Appendix A. 

The “percent of cases” is a weighting factor applied to reflect the fact that not all chemicals 

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

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

Review.” The three types of submissions resulting from a SNUR may have weighting factors 

that differ from each other and from the weighting factors for PMNs. Changes in weighting 

factors could cause actual review costs to be higher or lower than calculated here. For example, 

some SNUNs require little review because they are determined to be “invalid” -- i.e., not 

required in the first place. However, often a SNUN may take more Agency time than a typical 

PMN because of factors such as the need to retrieve old PMN records from archives, and the 

likelihood that more data requiring EPA review is submitted with a SNUN than would be 

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

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

analysis, the review steps and weighting factors are assumed to be the same as those derived in 

1994 for PMNs. 

 

11 For an overview of the PMN review process, see the Chemistry Assistance Manual for Premanufacture Notification 

Submitters, EPA, 1997. 
Economic Analysis of SNUR C-2 U.S. EPA Office of Pollution Prevention and Toxics 

For Non-Exempt Use of 14 Glymes Economic and Policy Analysis Branch 

The “Weighted Cost” column is calculated by multiplying the unweighted costs (EPA staff 

cost plus extramural costs) by the percentage of cases requiring this review step. This 

calculation yields total Agency costs for submission review and processing shown in Table C-1. 

Table C-1: Agency Costs for SNUN and Other Submission Review and Processing 

EPA staff (FTE) Cost Extramural 

Cost2

FTE

fraction 

Cost per 

FTE 1

FTE Total 

(2008$) 

1993 

dollars 

2008 

dollars 

Unweighted 

Cost 

Pct. of 

Cases 

Weighted 

Review Steps Cost 

(1) (2) (3)=(1)*(2) (4) (5) (6)=(3)+(5) (7) (8)=(6)*(7) 

Prenotice Consultation 0.0024 $150,440 $361 $4 $7 $368 41% $151 

Administrative Prescreen/ 

Notice Receipt/User Fee 0.0024 $150,440 $361 $92 $154 $515 100% $515 

CRSS (Chemical Review 

and Search Strategy) 0.0025 $150,440 $376 $268 $448 $824 100% $824 

SAT (Structure Activity 

Team) 0.0006 $150,440 $90 $14 $23 $114 100% $114 

Engineering/Exposure 0.0015 $150,440 $226 $56 $94 $319 100% $319 

Exposure/Fate 0.0008 $150,440 $120 $0 $0 $120 100% $120 

Focus 0.0009 $150,440 $135 $23 $38 $174 100% $174 

Standard Review Functions 0.0219 $150,440 $3,295 $511 $853 $4,148 29% $1,203 

Division Directors Meeting 0.0129 $150,440 $1,941 $113 $189 $2,129 15% $319 

Order Development/ 

Negotiation Review 0.0171 $150,440 $2,573 $22 $37 $2,609 3% $78 

Post Order Data Review 0.0886 $150,440 $13,329 $0 $0 $13,329 3% $400 

Order Modification 0.2167 $150,440 $32,600 $0 $0 $32,600 3% $978 

New Chemical SNUR 

Development 0.0277 $150,440 $4,167 $85 $142 $4,309 7% $302 

Notices of Commencement 0.0012 $150,440 $181 $40 $67 $247 31% $77 

FOIA (Freedom of 

Information Act) Requests 0.0004 $150,440 $60 $3 $5 $65 100% $65 

CBI (Confidential Business 

Information) Substantiation 0.0004 $150,440 $60 $3 $5 $65 100% $65 

TOTAL $5,693 

Notes:

1

 GS-13 Step 5 salaries loaded with benefits and overhead. See Appendix B derivation.

2

 Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated from 

1993 prices as described in Appendix A. 

3

Weighted costs were calculated using unrounded unit cost estimates, so results may differ from calculations using the rounded values 

shown in this table.

Sources: FTEs per review step and 1993 extramural costs are from EPA, 1994. Percents of cases are from EPA, 1994. GS-13 

salaries are from OPM, 2008. 
APPENDIX D 

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