Economic Analysis of the 

Significant New Use Rule for 

Perfluoroalkyl Sulfonates and 

Long-Chain Perfluoroalkyl 

Carboxylate Chemical 

Substances

(EPA DOCKET EPA-HQ-OPPT2012-0268)

Contract # EP-W-08-010

August 6, 2012

-- Does not contain TSCA CBI --

Prepared for:

Economic and Policy Analysis Branch

Economics, Exposure and Technology Division

Office of Pollution, Prevention, and Toxics

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue

Washington, DC 20460
This Page Intentionally Left Blank
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Front Matter ▌pg. i

Economic Analysis of the Significant New Use Rule for Perfluoroalkyl 

Sulfonates and Long-Chain Perfluoroalkyl Carboxylate Chemical Substances

(EPA DOCKET EPA-HQ-OPPT-2012-0268)

Table of Contents

List of Exhibits.....................................................................................................................................iii

Contributors.........................................................................................................................................iv

Executive Summary .............................................................................................................................v

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

1.1 Statutory Authority.........................................................................................................1-2

1.2 Summary of Methodology..............................................................................................1-2

1.3 Organization of this Report ............................................................................................1-2

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

2.1 Chemicals Subject to the Proposed Rule........................................................................2-1

2.1.1 PFAS Chemical Substances..............................................................................2-1

2.1.2 LCPFAC Chemical Substances........................................................................2-1

2.2 Significant New Uses under the Proposed SNUR..........................................................2-2

2.3 Chemical Uses................................................................................................................2-3

2.3.1 PFAS Chemical Substances..............................................................................2-3

2.3.2 LCPFAC Chemical Substances........................................................................2-6

2.4 Potentially Affected Companies.....................................................................................2-6

2.4.1 PFAS Chemical Substances..............................................................................2-6

2.4.2 LCPFAC Chemical Substances........................................................................2-6

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

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

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

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

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

3.2.3 Form Completion and Submission Fee.............................................................3-5
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Front Matter ▌pg. ii

3.2.4 Recordkeeping for Companies Choosing to Submit a SNUN..........................3-7

Recordkeeping for Companies that Do Not Submit a SNUN ........................................3-7

3.2.5 Customer Notification ......................................................................................3-8

3.2.6 Import Certification ..........................................................................................3-8

3.2.7 Export Notification...........................................................................................3-8

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

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

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

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

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

4.2 SNUN Processing Costs.................................................................................................4-1

4.3 Export Notification Cost.................................................................................................4-6

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

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

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

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

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

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

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

6.6 Executive Order 13045, Protection of Children .............................................................6-3

6.7 Executive Order 13175, Tribal Governments.................................................................6-3

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

7. References................................................................................................................................7-1

Appendix A – Wage Rate Calculations
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Front Matter ▌pg. iii

List of Exhibits

Exhibit 2-1: PFAS Chemicals Added to the SNUR............................................................................2-1

Exhibit 2-2: Articles Containing PFAS Chemical Substances............................................................2-5

Exhibit 3-1: Loaded Industry Wage Rates, December 2011 ..............................................................3-2

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

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

Cost for First-Time Submitters.......................................................................................3-5

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

Exhibit 3-5: Industry Cost Estimate to Complete and Submit the SNUN Form ................................3-7

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

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

Exhibit 3-7: Derivation of Total Mailing Cost for 12 Notices..........................................................3-10

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

Exhibit 3-9: Compliance Options and Associated Costs Incurred by a Firm Due to the Proposed 

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

Exhibit 4-1: Derivation of Loaded Agency Wage Rates, 2011 ..........................................................4-1

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

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

Exhibit 4-4: TSCA 12(b) Export Notification Cost: Agency Burden per Activity (2011$)...............4-6

Exhibit 7-1: Derivation of Loaded Wage Rates.................................................................................A-3

Exhibit 7-2: Derivation of Inflation Factors......................................................................................A-5
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Front Matter ▌pg. iv

Contributors

The EPA analyst responsible for this report was Timothy Lehman. Analytical and draft preparation 

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

Executive Summary

U.S. Environmental Protection Agency (EPA) is proposing to amend a significant new use rule 

(SNUR) for perfluoroalkyl sulfonate (PFAS) chemical substances1to add PFAS chemical substances 

that have completed the TSCA new chemical review process but have not yet commenced production 

or import, and to designate processing as a “significant new use.” EPA is also proposing to add a 

SNUR for long-chain perfluoroalkyl carboxylate (LCPFAC) chemical substances that would 

designate manufacturing, importing, or processing for use as part of carpets or for treating carpet as a 

significant new use. For this SNUR, EPA is also proposing to make the article exemption 

inapplicable to the import of LCPFAC chemical substances as part of carpets. This report estimates 

the costs of the Significant New Use Rule (SNUR) being proposed by the EPA.

Since the manufacture, import, and processing of PFAS and LCPFAC chemical substances for the 

proposed uses have been discontinued, EPA expects their presence in humans and the environment to 

decline over time as has been observed in the past when production and use of other persistent 

chemicals has ceased.

Persons subject to these SNURs would be required to notify EPA at least 90 days before commencing 

any significant new use. The required notifications would provide EPA with the opportunity to 

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

significant new use is defined as: 1) the manufacture, import, processing of any of the PFAS chemical 

substances subject to this proposed rule, for any use except ongoing uses specified in the 2007 PFAS 

Chemical Substances SNUR at § 721.9582(a)(3) through (a)(5) and 2) the manufacture, import, 

processing, or import as part of carpet, of any of the LCPFAC chemical substances subject to this 

proposed rule for use as part of carpet or to treat carpets. A firm intending to engage in these activities 

would be required to submit a Significant New Use Notice (SNUN), incurring an estimated 

submission cost of $8,571 for large businesses per chemical2, and potentially other minor costs. The 

required notification would provide EPA with the opportunity to evaluate the intended use and, if 

necessary, to prevent or limit potentially adverse effects from chemical use before it occurs.

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

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

and testing costs but may incur other compliance costs. The firm may also incur “hidden” costs; for 

example, it could forego profitable opportunities to use the chemical in an application that would be a 

significant new use, or limit production volume to avoid a significant new use.

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

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

quantified. EPA receives only a handful of SNUNs per year. The number of firms affected by not 

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

entities.

 

1 On March 10, 2006 (71 FR 12311) (FRL-7740-6), EPA proposed to add 183 PFAS chemical substances to the 

SNUR at 40 CFR 721.9582, and published a final rule for these 183 PFAS chemical substances on October 

9, 2007 (71 FR 12311) (FRL-8150-4) (EPA, 2007d).

2

For small businesses, the estimated cost is $6,171 to complete and submit a SNUN. See section 3.2.3 for 

details. 
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Agency Costs ▌pg. 1-1

1. Introduction

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

specific perfluoroalkyl sulfonates chemicals (PFAS) and for long-chain perfluoroalkyl carboxylate

chemicals (LCPFACs) used in carpet treatments. EPA is proposing to amend a SNUR at § 721.9582 

for PFAS chemical substances to add PFAS chemical substances that have completed the TSCA new 

chemical review process but have not yet commenced production or import, and to designate (for all 

listed PFAS chemical substances) processing as a “significant new use.” EPA is also proposing to add 

a SNUR for LCPFAC chemical substances that would designate manufacturing, importing, or 

processing for use as part of carpets or for treating carpet (e.g., for use in the carpet aftercare market) 

as a “significant new use.” 

For this SNUR, EPA is also proposing to make the article exemption at § 721.45(f) inapplicable to 

persons who import LCPFAC chemical substances as part of carpets. The article exemption at § 

721.45(f) remains in effect for persons who import LCPFAC chemical substances as part of other 

sorts of articles. The article exemption at § 721.45(f) relating to persons who process chemical 

substances as part of an article would also remain in effect, for both the PFAS SNUR and the 

LCPFAC SNUR. Persons subject to these SNURs would be required to notify EPA at least 90 days 

before commencing any significant new use. The required notifications would provide EPA with the 

opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it 

occurs. 

PFAS Chemical Substances

In this proposed SNUR, the term PFAS refers to a general category of perfluorinated sulfonate 

chemical substances of any chain length. The PFAS chemical substances for which EPA is proposing 

to modify an existing SNUR are currently listed in the 2007 SNUR at § 721.9582. The PFAS 

chemical substances that EPA is proposing to add to the existing SNUR would be added to this list. 

See 2.1.1 for the list of additional chemicals. All of these chemical substances are referred 

collectively in this proposed rule as perfluoroalkyl sulfonates, or PFAS chemical substances.

The proposed SNUR requires manufacturers, importers, or processors of PFAS chemical substances

to notify EPA at least 90 days prior to the occurrence of any significant new use. A significant new

use is defined as: the manufacture, import, processing of any of the PFAS chemical substances 

subject to this proposed rule, for any use except ongoing uses specified in the 2007 PFAS Chemical 

Substances SNUR at § 721.9582(a)(3) through (a)(5).

LCPFAC Chemical Substances

The term LCPFAC refers to the long-chain category of perfluorinated carboxylate chemical 

substances with perfluorinated carbon chain lengths equal to or greater than seven carbons. The 

category of LCPFAC chemical substances also includes the salts and precursors of these 

perfluorinated carboxylates (See section 2.1.2 for further details).

The proposed SNUR requires manufacturers, importers, or processors of LCPFACs for use in carpet 

treatments to notify EPA at least 90 days prior to the occurrence of any significant new use. A 

significant new use is defined as; the manufacture, import, processing, or import as part of carpet, of 
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Agency Costs ▌pg. 1-2

any of the LCPFAC chemical substances subject to this proposed rule for use as part of carpet or to 

treat carpets. 

1.1 Statutory Authority 

Section 5(a)(2) of TSCA (15 U.S.C. 2604(a)(2)) authorizes EPA to determine that a use of a chemical 

substance is a “significant new use.” EPA must make this determination by rule after considering all 

relevant factors, including those listed in TSCA section 5(a)(2). Once EPA determines that a use of a 

chemical substance is a significant new use, TSCA section 5(a)(1)(B) requires persons to submit a 

SNUN to EPA at least 90 days before manufacturing, importing, or processing the chemical 

substance for that use (15 U.S.C. 2604(a)(1)(B)).

The general SNUR provisions are found at 40 CFR Part 721, Subpart A.

1.2 Summary of Methodology

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

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

and the costs to EPA of administering the rule. Industry costs consist of rule familiarization; 

registration with the Central Data Exchange (CDX) electronic reporting tool; collection, compilation, 

and submission of required information for significant new uses of the subject chemicals; export 

notification; and recordkeeping. Agency costs include reviewing and processing the data received as a 

result of the rule. Data sources for this analysis include burden estimates derived from previous 

information collection requests and economic analyses for related rules, compensation data acquired 

from government publications, and supplementary market research.

In addition to estimated costs, this report qualitatively discusses the benefits of the proposed rule 

based on the value of the information it would provide. 

1.3 Organization of this Report

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

description of the PFAS chemicals affected by this SNUR as well as the LCPFACs and their use in 

carpet treatments is provided in Chapter 2. Chapter 3 contains estimates of the industry costs to 

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

with the administration of the proposed rule. Chapter 5 addresses the benefits of the proposed rule. 

Several additional impact analyses are presented in Chapter 6, including: small entity impact analysis, 

as mandated by the Regulatory Flexibility Act (RFA); a burden hour analysis that responds to the 

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

to the Unfunded Mandates Reform Act (UMRA); an analysis of environmental justice implications 

that addresses the requirements of Executive Order 12898; and an analysis of children’s health 

pertinent to Executive Order 13045. 

Note that all dollar values in this analysis are reported in 2011 dollars, except for the U.S. Postal 

service mailing rates, which were acquired in January 2012.
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Agency Costs ▌pg. 2-1

2. Chemical Uses and Manufacturers

2.1 Chemicals Subject to the Proposed Rule 

2.1.1 PFAS Chemical Substances

EPA is proposing to amend a SNUR at § 721.9582 for PFAS chemical substances to add PFAS 

chemical substances that have completed the TSCA new chemical review process but have not yet 

commenced production or import, and to designate (for all listed PFAS chemical substances) 

processing as a significant new use. Exhibit 2-1 presents seven PMN case numbers and the generic 

chemical names of the PFAS chemical substances being added to the list of 183 PFAS chemicals

(listed in the SNUR at § 721.9582).

Exhibit 2-1: PFAS Chemicals Added to the SNUR

PMN Case Numbers Generic Chemical Name

P-83-0126 N/A

P-90-0110 N/A

P-94-1508 Fluorinated polysiloxane

P-94-1509B Fluorinated polysiloxane

P-98-0809 N/A

P-99-0296 Fluoroalkyl derivative

P-01-0035 Perfluorooctane sulfonate

EPA believes that the commencement of manufacturing, import, or processing of these chemicals 

would significantly increase the magnitude and duration of exposure to humans and the environment. 

Given the structural similarity of these chemicals to the PFAS chemicals covered under 40 CFR 

721.9582, EPA believes that action on these PFAS chemicals is warranted.

2.1.2 LCPFAC Chemical Substances

This SNUR applies to LCPFACs used to treat carpets. PFACs are substances with special properties 

that have a variety of industrial applications. PFACs are used widely in the textile industry because of 

their thermo-stability, ability to adapt to a variety of surface characteristics, high chemical stability, 

and other characteristics.

3

Specifically, LCPFAC chemical substances are synthetic chemicals that do 

not occur naturally in the environment. The LCPFAC chemical substances are identified as follows, 

> 5 or m > 6: 

i. CF3(CF2)n-COO-M where M = H+ or any other group where a formal dissociation can be 

made; 

ii. CF3(CF2)n-CH=CH2; 

iii. CF3(CF2)n-C(=O)-X where X is any chemical moiety; 

iv. CF3(CF2)m-CH2-X where X is any chemical moiety; 

v. CF3(CF2)m-Y-X where Y = non-S, non-N hetero atom and where X is any chemical 

moiety; and 

 

3 Armeduri, Bruno; Bouterin, Bernard. Well-Architectured Floropolymers: Synthesis, Properties, and 

Applications. “Applications of Flourinated Telomers,” (p. 71).
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Agency Costs ▌pg. 2-2

vi. structurally similar degradation products of any of the compounds in ii. through v. above.

This category definition of LCPFAC, based on the chemical structures above, refers to a large group 

of chemical substances containing perfluorooctanoic acid (PFOA) and its higher homologues. The 

category also includes the salts and precursors of these chemical substances. The precursors may be 

simple derivatives of PFOA and higher homologues or polymers that contain or may degrade to 

PFOA or higher homologues. PFACs are used in carpets to impart stain, soil, and grease repellant 

properties. During the manufacturing process, PFACs are utilized in the impregnation of carpets or as 

a chemical finish which endows fabrics with those characteristics. 

Long-chain perfluorinated chemicals (LCPFCs) are found world-wide in the environment, wildlife, 

and humans. They are bioaccumulative in wildlife and humans, and are persistent in the environment

(Danish Ministry of the Environment, 2008). To date, significant adverse effects have not been found 

in the general human population4; however, LCPFCs have been linked to a number of health effects, 

including thyroid disease and reproductive function (Knox, et al., 2011; Melzer, et al., 2010).

Because of their bioaccumulative and persistent properties, EPA is proposing a SNUR for all 

LCPFACs used in carpet treatments and carpet treatment products. The Agency believes that the 

LCPFAC chemical substances included in this proposal are no longer being manufactured, processed, 

or imported for use as part of carpet or for treating carpet (e.g., for use in the carpet aftercare market)

in the United States. The Agency also believes that LCPFAC chemical substances are not being 

imported as part of carpet. EPA is proposing a SNUR for any commercial uses of these chemicals, so

that the Agency may be informed of any intended use of these chemicals in commerce. 

2.2 Significant New Uses under the Proposed SNUR 

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). According to TSCA Section 5(a)(2), the 

determination that a chemical use qualifies as a significant new use must consider all relevant factors, 

including:

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

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

environment to a chemical substance;

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

the environment to a chemical substance; and

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

commerce, and disposal of a chemical substance.

EPA is proposing to define the significant new use as: 1) the manufacture, import, processing of any of 

the PFAS chemical substances subject to this proposed rule, for any use except ongoing uses 

specified in the 2007 PFAS Chemical Substances SNUR at § 721.9582(a)(3) through (a)(5); and 2) 

the manufacture, import, processing, or import as part of carpet, of any of the LCPFAC chemical 

 

4 Based on review of a number of studies examining health effects of LCPFCs.
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Agency Costs ▌pg. 2-3

substances subject to this proposed rule for use as part of carpet or to treat carpets, is a significant 

new use.

A company would be expected to submit a SNUN for any PFAS chemical substances or for any 

LCPFAC substances used in carpet treatment products included in the proposed SNUR prior to 

initiating a new use.

2.3 Chemical Uses 

2.3.1 PFAS Chemical Substances

In the past, PFAS chemical substances were used in a variety of products, which can be divided into 

three main use categories: surface treatments, paper protection, and performance chemicals.
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Agency Costs ▌pg. 2-4

Exhibit 2-2 presents a list of the applications PFAS Chemical Substances and their end products. 
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Agency Costs ▌pg. 2-5

Exhibit 2-2: Articles Containing PFAS Chemical Substances

Category Application(s) End Product(s)

Surface 

Treatments

Treatment of fabrics Automotive interiors

Carpet protector Carpets

Fabric/ Upholstery protector Fabrics, furniture

Apparel and leather protector Apparel, leather

Protective products for after 

markets and consumer 

applications

Other products

Mist suppressant corrosion 

inhibitors

Acid mist suppressants for metal plating and electronic 

etching baths

Treatment of metal and glass Surface of metals (mostly chromium), glass

Paper Protection Water/ Oil/ Grease/ Solvent 

repellent

Masking papers

Folding cartons

Plates and food containers

Bags and wraps

Food packaging

Carbonless forms (an alternative to carbon paper that 

makes copies of documents without electronics)

Paper products, paperboard

Performance 

Chemicals

Surfactants

Fire-fighting foams

Alkaline cleaners (help remove oil and grease off 

metals)

Mining and oil well surfactants

Cleaning agents

Denture cleaners

Carpet spot cleaners

Mold release agents

Glass cleaning waxes; floor polishes

Shampoos

Inks Printing inks

Chemical synthesis Chemical intermediates

Pesticides/ Insecticides Pesticides active ingredient; Insecticide in bait stations 

for ants

Photography

Antistatic agents; 

Surfactants for paper, films,

photographic plates

Photolithography Coatings for semiconductors (anti-reflective coatings)

Paints and vanishes Floor paints

Medical applications Waterproofing casts; Wound dressings

Waxes and polishes Emulsifier in wax and floor polishes

Coatings Coating additives

Aviation - hydraulic fluids Hydraulic fluid agents

Sources: EPA, 2005c; 3M Company, 1999; Carolini, 2009; OSPAR, 2006.
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Agency Costs ▌pg. 2-6

2.3.2 LCPFAC Chemical Substances

LCPFAC chemical substances were used in carpets to impart stain, soil, and grease repellant 

properties (Kissa, 2001). There are four typical scenarios for chemical application that could lead to 

the presence of these chemical substances in carpet products. First, these chemical substances could 

be applied to carpet at a carpet and rug mill during the manufacturing process. Secondly, these 

chemical substances could be applied to carpet after the manufacturing process at a separate finishing 

facility. Thirdly, treatment products containing these chemical substances could be applied to carpets 

by final consumers in the post manufacturing stage. In the described scenarios, LCPFAC chemical 

substances could be domestically produced or imported. In addition, domestically produced carpets 

could be made using imported fabrics that had been treated with PFAS or LCPFAC chemical 

substances. Finally, carpet containing these chemical substances could be imported into the United 

States as a final product. 

The Agency believes that the LCPFAC chemical substances included in this proposal are no longer 

being manufactured, processed, or imported for use as part of carpet or for treating carpet (e.g., for 

use in the carpet aftercare market) in the United States. The Agency also believes that LCPFAC 

chemical substances are not being imported as part of carpet.

2.4 Potentially Affected Companies 

The proposed SNUR applies to processors as well as to manufacturers and importers (40 CFR 

§721.5). It would require manufacturers, importers, and processors to notify EPA at least 90 days 

before commencing the manufacture, import, or processing of any of the subject chemicals for any 

significant new use. The proposed SNUR may also affect firms that currently do not manufacture, 

import, or process any of the chemicals, but who may be interested in manufacturing, importing, or 

processing these chemicals in the future. 

2.4.1 PFAS Chemical Substances

The PFAS chemical substances that EPA is proposing to add to the existing PFAS SNUR are 

chemical substances that have completed the TSCA new chemical review process but have not yet 

commenced production or import. Any person who commences the manufacture or import of a new 

chemical substance for which that person previously submitted a section 5(a) notice must submit a 

notice of commencement of manufacture or import (40 CFR 720.102). EPA has not received any 

notices of commencements for these chemical substances, and there is currently no production or 

import of these chemical substances. If commenced, these chemical substances could be used for the 

PFAS uses described above, significantly increasing the magnitude and duration of exposure to 

humans and the environment. 

2.4.2 LCPFAC Chemical Substances

The Agency believes that the LCPFAC chemical substances included in this proposal are no longer 

being manufactured, processed, or imported for use as part of carpet or for treating carpet (e.g., for 

use in the carpet aftercare market) in the United States. The Agency also believes that LCPFAC 

chemical substances are not being imported as part of carpet. 

Potentially affected entities would include chemical manufacturers as primary producers of LCPFCs 

and carpet manufacturers as secondary manufacturers that purchase LCPFCs from domestic or 
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Agency Costs ▌pg. 2-7

foreign chemical manufacturers for use in carpets. This SNUR might also affect entities that are 

involved in importing of LCPFAC chemical substances.

Although industry phase-out of LCPFCs in carpet treatment products was voluntary, EPA’s recent 

focus on the chemicals leads the Agency to believe that LCPFCs used in carpets subject to this SNUR 

are no longer manufactured in or imported into the United States. Therefore, there are likely to be no 

entities affected by this proposed SNUR. 
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Agency Costs ▌pg. 3-1

3. Industry Compliance Costs

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

PFAS chemical substances and LCPFCs as part of carpet or to treat carpets for a designated 

significant new use would require reporting under section 5(a)(1)(A) of TSCA. Therefore, a firm 

intending to manufacture, import, and/or process any of these chemicals for these applications must 

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

chemicals or to manufacture, import, and/or process these chemicals in such a way that it is not 

considered a significant new use. The firm, therefore, has two options: 

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

import, and/or process the chemical for a significant new use, which, in this case, means (1): the 

manufacture, import, processing of any of the PFAS chemical substances subject to this proposed 

rule, for any use except ongoing uses specified in the 2007 PFAS Chemical Substances SNUR at 

§ 721.9582(a)(3) through (a)(5); and (2) the manufacture, import, processing, or import as part of 

carpet, of any of the LCPFAC chemical substances subject to this proposed rule for use as part of 

carpet or to treat carpets. 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 new use 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 LCPFACs for use as part of carpet or to treat carpets for a significant new use, 

then the costs associated with this option are the costs of submitting the SNUN (including a user 

fee) plus, if there is any export of these chemicals, the export notification costs that result from 

TSCA Section 12 (b) requirements that are automatically triggered for chemicals regulated under 

TSCA Section 5 (see Section 3.2.7 for details).

 Option 2: Comply with SNUR limits (not manufacture, import, and/or process a new use of the 

chemical). A firm can avoid engaging in a Significant New Use and submitting a SNUN by not 

manufacturing, importing, and/or processing any of the chemical substances in a manner such 

that they would be considered new uses. That is, if the firm does not use (1): the manufacture, 

import, processing of any of the PFAS chemical substances subject to this proposed rule, for any 

use except ongoing uses specified in the 2007 PFAS Chemical Substances SNUR at § 

721.9582(a)(3) through (a)(5); and (2) does not use the manufacture, import, processing, or 

import as part of carpet, of any of the LCPFAC chemical substances subject to this proposed rule 

for use as part of carpet or to treat carpets, then it would meet all applicable SNUR requirements. 

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

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

involve substituting one of the subject chemicals for another, more costly substance. If the firm 

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

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

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

incur the export notification costs. The firm may also pursue this option temporarily by 

complying with SNUR restrictions while also pursuing Option 1. Due to the uncertainty related to 

this option, and EPA’s expectation that affected entities would select Option 1, the costs of 

Option 2 are not fully quantified in this report.
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 3-2

The remainder of this chapter estimates the quantified portion of costs associated with the proposed 

SNUR. Section 3.1 summarizes the wage rates used in this chapter. Section 3.2 provides the unit 

industry compliance costs, including the costs of rule familiarization, registration with the Central 

Data Exchange (CDX) electronic reporting tool, completing the SNUN form, submission fee, import 

certification, and export notification. Total costs under each option are presented in Section 3.3. 

3.1 Wage Rates

The proposed rule involves activities that may require efforts by employees in three labor 

classifications: managerial, technical, and clerical. Costs for each activity are calculated by estimating 

the labor hours required in each labor category and multiplying those burden hours by the wage rate 

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

category.

Loaded wage rates for managerial, technical, and clerical personnel are derived by combining data on 

wages and fringe benefits with estimates of overhead rates, following the methodology described in 

Wage Rates for Economic Analysis of the Toxics Release Inventory Program (EPA, 2002b). Wage 

data for each labor category for December 2011 are provided by the Employer Costs for Employee 

Compensation (ECEC) Supplemental Tables available on the BLS website (BLS, 2012a). The loaded 

wage rate is $70.72 for managerial labor; $64.66 for technical labor; and $29.63 for clerical labor. 

Exhibit 3-1 presents the data used to calculate the loaded wage rates for the three labor categories. 

Appendix A provides more information on the wage rates and inflation factors used in this analysis.

Exhibit 3-1: Loaded Industry Wage Rates, December 2011

Labor 

Category Data Source Date

Wage Fringe 

Benefit

Fringe 

as %

Wage

Overhead 

% 

Wage

Fringe +

Overhead

Loaded 

Wages1

(a) (b) (c) 

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

(d)+1

(f)=(a) 

x (e)

Managerial

BLS ECEC, Private 

Manufacturing 

industries, “Mgt, 

Business, and 

Financial”3

12/11 $43.01 $20.40 47.43% 17% 1.64 $70.72

Professional/

Technical

BLS ECEC, Private 

Manufacturing 

industries, 

“Professional and 

related“3

12/11 $38.48 $19.64 51.04% 17% 1.68 $64.66

Clerical

BLS ECEC, Private 

Manufacturing 

industries, “Office and 

Administrative 

Support”3

12/11 $17.69 $8.93 50.48% 17% 1.67 $29.63
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 3-3

Notes:

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

2 An overhead rate of 17 percent was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release 

Inventory Program (EPA, 2002b), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report 

(EPA, 2002a).

3 Employer Costs for Employee Compensation Supplementary Tables December 2011, U.S. Bureau of Labor Statistics, March 

14, 2012 (BLS, 2012a).

3.2 Unit Industry Compliance Costs

3.2.1 Rule Familiarization

The proposed rule requires submitters and their staff to become familiar with the SNUR and its 

various requirements. Rule familiarization is estimated to require 0.55 hours of technical labor and 

0.27 hours of managerial labor, as described in the Economic Analysis of the Premanufacture 

Notification Electronic Reporting Final Rule (EPA, 2009a), which measures the costs of mandatory 

electronic reporting of SNUNs and other TSCA Section 5 notices. As shown in Exhibit 3-2, the total 

labor cost associated with rule familiarization is estimated at $54.43.

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

Reporting 

Activity

Clerical Labor 

($29.63/hour)

Technical Labor 

($64.66/hour)

Managerial Labor 

($70.72/hour)

Total Labor Cost 

(2011$)

Burden Cost Burden Cost Burden Cost Burden Cost

Rule 

Familiarization 0.00 $0.00 0.55 $35.56 0.27 $18.86 0.82 $54.43

Note:

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

calculations. 

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

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

The proposed SNUR requires submission of a SNUN for any firm that chooses to manufacture, 

import, and/or process a chemical for a significant new use. First-time submitters of any TSCA 

section 5 notice (including Premanufacture Notices (PMNs), SNUNs, Test Market Exemption (TME) 

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

exemption notices, Biotechnology Notices for genetically modified microorganisms, Notices of 

Commencement of Manufacture or Import (NOCs), and support documents to Section 5 notices) are 

required to register their company and key users with the CDX reporting tool, deliver a CDX 

electronic signature to EPA, and establish and use a Pay.gov E-payment account.5These activities are 

only required of first-time submitters of any Section 5 notice. These activities are estimated to require 

the following burden hours, based on the estimates presented in the Economic Analysis of the 

Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009a):

 

5 Although the proposed rule does not require submitters to establish and use a Pay.gov account, the burden 

estimates in this analysis are conservative insofar as to include the use of Pay.gov as a required activity.
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 3-4

 CDX registration. EPA estimates that companies would spend approximately 0.18 hours per 

employee to register with CDX, and that an average of four technical staff members and one 

manager would need to register for each company, totaling approximately 0.92 hours of burden 

per company.

 CDX electronic signature. EPA estimates that companies would spend 0.25 hours preparing, 

submitting, and filing an electronic signature agreement (Authentication of Identity) form to EPA 

per employee. This burden would apply to four technical staff members and one manager per 

company, totaling 1.25 hours of burden per company. In addition, EPA estimates that a manager 

would spend an additional 0.50 hours accessing, preparing, and submitting verification forms 

(Verification of Authorization) for all authorized submitters to EPA. The total burden incurred by 

companies submitting and then verifying electronic signature agreements is 1.75 hours. Note that 

this burden does not include any additional time required to contact EPA’s CDX help desk to 

notify a change of submitter status, should one occur. Filing the electronic signature agreement 

requires an additional mailing cost of $2.55 per company (including five $0.45 stamps6and five 

$0.06 business envelopes7).

 Payment via Pay.gov account. EPA estimates that one manager per company would spend 

approximately 0.13 hours setting up a Pay.gov ID account, logging into the system, finding the 

appropriate form, and filling it out. This burden does not include the time required to click 

‘submit’ on the form and wait for payment processing.

As shown in Exhibit 3-3, the labor cost consists of CDX registration, CDX electronic signature, and 

Pay.gov account setup by a first-time submitter. As noted above, an additional $2.55 in mailing cost 

per company is attributable to these activities, for a total cost of approximately $190 per company.

 

6

Price for a stamp was taken from the U.S. Postal Service website on January 24, 2012. (See U.S. PS, 

2012)

7

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

“Staples® #10, Self-Sealing Envelopes, 500/Box." Available at: http://www.staples.com/ (Accessed 

1/25/2012).
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 3-5

Exhibit 3-3: CDX Registration, CDX Electronic Signature, and Pay.gov Account 

Setup Burden and Cost for First-Time Submitters

Reporting Activity

Clerical Labor 

($29.63/hour)

Technical Labor 

($64.66/hour)

Managerial Labor 

($70.72/hour)

Total Labor Cost

(2011$)

Burden Cost Burden Cost Burden Cost Burden Cost

CDX Registration 0.00 $0.00 0.73 $47.42 0.18 $12.96 0.92 $60.38 

CDX Electronic 

Signature 0.00 $0.00 1 $64.66 0.75 $53.04 1.75 $118

Mailing Cost $2.55

E-Payment (Pay.gov ID) 0.00 $0.00 0.00 $0.00 0.13 $9.43 0.13 $9.43 

Total 0.00 $0.00 1.73 $112 1.07 $75.43 2.80 $190

Note:

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

calculations. 

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

3.2.3 Form Completion and Submission Fee

Respondents who choose to submit a SNUN are required to gather and submit information regarding 

the data elements identified in the applicable SNUN reporting form. The methodology and 

calculations used in this analysis assume that the employee responsible for collecting, filling out, and 

submitting the requested information has a reasonable level of familiarity with the company and 

knowledge of operations at the site. It is assumed that for most entities these tasks are similar to other 

employee duties that require familiarity with EPA, State, and other Federal agency requests for 

chemical information and do not require additional familiarization or training beyond the basic rule 

familiarization described above. In addition, this analysis focuses on the marginal costs of submitting 

information for the proposed rule and not the total costs for the company to comply with a range of 

other Federal and State environmental, health, and safety regulations or accounting requirements that 

rely on this type of information.

Estimates of the costs of completing a 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. The PMN submission costs came from EPA's 1994 Regulatory Impact Analysis of 

Amendments to Regulations for TSCA Section 5 Premanufacture Notifications, which relied on 

industry estimates of the effort needed to collect and compile all data required for a PMN submission, 

prepare the form, submit the form and data to EPA, and maintain a file of the submission (EPA, 1994, 

Table III-2 and pages III-11, -12, and -13). The 1994 estimates were based on a survey conducted by 

the Chemical Manufacturers Association, which became the American Chemistry Council. These 

burdens include “the time spent reading and becoming familiar with the form, gathering the required 

information and preparing the report, producing sanitized responses for items claimed as confidential 

business information, and maintaining a file of the submission” (EPA, 1994. p. III 11-13). The burden 

associated with SNUN submission and preparation has been adjusted to reflect burden reductions 

resulting from the 2009 final PMN Electronic Reporting (ePMN) Rule that requires the electronic 

submission of all TSCA section 5 notices. Electronic submission of SNUN forms is expected to 
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 3-6

remove all clerical burden and reduce the recordkeeping burden associated with preparing a SNUN 

(EPA, 2009a).8In addition, electronic submission is expected to generate and an additional 0.18 hours 

of technical burden, for the completion of the User Fee Payment Identification Number and email 

address data elements on the electronic SNUN form.

SNUN form completion and electronic submission is estimated to require approximately 74 hours of 

technical labor and 18 hours of managerial labor (EPA, 2009a). Exhibit 3-4 combines the estimated 

reporting burden and loaded wage rates for all three labor categories to estimate the per-SNUN cost 

of form completion. The labor cost incurred by a SNUN submission for both large and small business 

submitters is estimated at $6,071.

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

Reporting 

Activity

Clerical Labor 

($29.63/hour)

Technical Labor 

($64.66/hour)

Managerial Labor 

($70.72/hour)

Total Labor 

Cost

(2011$)

Burden Cost Burden1 Cost Burden Cost Burden Cost

Form 

Completion 0.00 $0.00 74.2 $4,798 18 $1,273 92.2 $6,071 

Note:

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

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

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

the product of rounded values.

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

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

4. Technical and managerial labor burden is from the PMN Amendments RIA (EPA, 1994, Table III-2). An additional eleven 

minutes (0.18 hours) of technical burden is estimated to complete the User Fee Payment Identification Number and Email 

Address data elements on the Electronic SNUN form (EPA, 2009a, page 15).

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

In addition, each submitting large business must pay a $2,500 per-SNUN submission fee, and each 

submitting small business must pay a $100 per-SNUN submission fee. Exhibit 3-5 adds the labor cost 

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

submission is $8,571 for large business submitters and $6,171 for small business submitters.

 

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

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

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

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

the recordkeeping burden associated with PMN submissions.

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

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

entire clerical burden is assumed to be eliminated under the electronic reporting requirements. In summary, 

we do not include the one hour recordkeeping burden (0.5 hour for clerical, 0.5 for technical) reported in 

the ePMN EA.
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 3-7

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

Reporting Population Labor Cost Submission Fee Total Cost

(2011$)

Large Business Submitters $6,071 $2,500 $8,571 

Small Business Submitters $6,071 $100 $6,171 

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

3.2.4 Recordkeeping for Companies Choosing to Submit a SNUN

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

contained in the SNUN. Some EPA reports have assumed that SNUN recordkeeping hours would be 

five percent of SNUN submission hours, or about five to six hours. For this report, the SNUN 

recordkeeping hours were included in the SNUN submission hours (see Section 3.2.3) and the SNUN 

recordkeeping costs under 40 CFR §721.40 were not separately estimated.

Recordkeeping for Companies that Do Not Submit a SNUN

If a firm that manufactures, imports, or processes a substance subject to the proposed SNUR chooses 

not to submit a SNUN, they must keep records that document compliance with SNUR conditions for 

avoiding a Significant New Use. Such recordkeeping requirements essentially involve copying and 

filing relevant records, including those related to category of use. Records must be maintained for five 

years from the date of their creation (40 CFR 721.40). For firms that choose to not submit a SNUN, 

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

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

by clerical staff (EPA, 2005b, pages 10 and 14). EPA used the per-activity burden for reporting, 

human exposure, category of use and releases to the environment presented in the Information 

Collection Request (ICR) for TSCA Section 5(a)(2) Significant New Use Rules for Existing Chemicals 

(Renewal) (EPA, 2005b, page 12). Any clerical burden associated with these activities was removed 

to reflect the burden reduction associated with electronic submissions (EPA, 2009a). 

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

$9.70 and is derived in Exhibit 3-6. 

Exhibit 3-6: Annual Per-Chemical Costs of Recordkeeping Requirement for 

Companies that Choose not to Submit a SNUN

Reporting Activity

Per Activity 

Burden 

(Hours)

% of Reporting 

Burden 

Attributed to 

Recordkeeping

Total Labor Cost

(2011$)

Burden Cost

Category of Use13 5% 0.15 $9.70

Notes: For the category of use reporting activity, the burden is associated with technical labor. See Exhibit 

3-1 for the technical wage rate.

Source:

1 US EPA, 2005b Office of Pollution Prevention and Toxics Information Collection Request (ICR) for TSCA 

Section 5(a)(2) Significant New Use Rules for Existing Chemicals (Renewal),page 13.
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 3-8

3.2.5 Customer Notification

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

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

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

that all such entities would have complete knowledge of all uses of any products subject to a SNUR, 

and because filing a SNUN could require significantly more burden, it is assumed that manufacturers, 

processors, and importers would most often choose to notify their customers of SNUR regulatory 

activities. As this notification may be accomplished by simply annotating an MSDS, EPA estimates 

the associated burden to be about one hour of a technical employee's time or $64.66 per manufacturer, 

processor, or importer per chemical. The proposed SNUR would cover PFAS Chemical Substances 

and LCPFACs for use as part of carpet or to treat carpets; however EPA believes these chemicals are 

not used in the U.S. and therefore no manufacturers, processors, or importers would be affected. 

Therefore, customer notifications would not be necessary. 

3.2.6 Import Certification

In general, promulgation of a SNUR triggers a TSCA Section 13 import certification requirement and 

the corresponding regulations at 19 CFR §12.118 to 12.127 and 19 CFR §127.28 for all imports of the 

relevant chemical substances. Thus, any U.S. manufacturer, importer, or processor receiving an 

imported shipment of chemicals subject to the proposed SNUR would have to certify that all chemical 

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

chemical substances in the shipment are not subject to TSCA.9 The statement must be on or attached 

to a commercial invoice or entry document belonging to the imported shipment.

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

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

associated with submitter’s familiarization with this requirement is assumed to be included in the 

more general SNUR familiarization burden discussed above.

3.2.7 Export Notification

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

chemical subject to various TSCA sections (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 requirement10 per destination country for each exporter of a chemical 

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

 

9 The exact statements are as follows: For imports of chemical substances subject to TSCA, “I certify that all 

chemical substances in this shipment comply with all applicable rules or orders under TSCA and that I am 

not offering a chemical substance for entry in violation of TSCA or any applicable rule or order under 

TSCA.” For imports of chemical substances not subject to TSCA (e.g., pesticides), “I certify that all 

chemicals in this shipment are not subject to TSCA.” (40 CFR 707.20)

10 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).
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 3-9

United States State Department (40 CFR §707.70). To calculate the burden associated with making a 

single export notification, EPA first estimated the average annual number of export notifications 

made by an exporter. EPA then derived the annual and per notification burden associated with 

preparing and submitting an export notification. 

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

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

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

unrelated uses, manufacturers, and processors, making it impractical within the resources available 

for this report to assess the potential number of exporters and importing countries per chemical. 

Most underlying data in this section come from the (2009 TSCA Section 12(b) ICR), ICR No.: 

0795.13 OMB Control Number 2070-0030 [Information Collection Request for] Notification of 

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

the Paperwork Reduction Act (EPA, 2009b).

Estimated Number of Annual Export Notifications per Exporter

EPA’s 2009 TSCA Section 12(b) ICR estimated that the average exporter making notifications would

make 12 notifications per year.

11 This includes notifications resulting from SNURs and notifications 

resulting from other TSCA activities. Therefore, it is likely that an exporter would make less than 12 

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

page per chemical/country combination, and one notification mailing often includes multiple 

chemicals and/or destination countries.12

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

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

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

Exporter Costs

The 2009 TSCA Section 12(b) ICR (EPA, 2009b, page 11, Table 3), estimated the annual export 

notification cost for an exporter under the one-time export notification requirement. These costs 

include the cost to the exporter of compiling a list of their products that are subject to TSCA Section 

12(b) requirements, writing or revising an export notification letter to EPA, checking the outgoing 

shipments, and sending the notification letters with the associated shipping costs.

The per-notification cost was calculated based on the average burden per firm. Exporters who make a 

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

notification; conversely firms making fewer notifications may have a higher cost per notification.

 

11 EPA calculated the average number of export notifications per exporter in the 2009 TSCA Section 12(b)

ICR (EPA, 2009b) by dividing the estimated number of submitted notifications (3,500) by the estimated 

number of exporters (300).

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

approximately three weeks in early 2010.
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 3-10

Estimated Submission (Mailing) Costs. Regulated companies would incur mailing costs for export 

notifications delivered to EPA. Notifications are assumed shipped via the U.S. Postal Service (U.S. 

PS) as first-class registered mail with a return receipt (U.S. PS, 2012). The estimated per-shipment 

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

Exhibit 3-7: Derivation of Total Mailing Cost for 12 Notices

Postal Service Cost

Registered mail, regular, with $0 declared value $10.95 

Return receipt, requested at time of mailing (receive by mail) $2.35 

Postage, regular First Class, up to 1 ounce $0.45 

Cost per export notice - Subtotal $13.75 

× 12

Total Mailing Cost for 12 Notices $165 

Source: Mailing rates are from the U.S. Postal Service web site as of January 2012 (http://www.usps.com/prices/). The 

assumption on the mailing method is based on the Economic Analysis of the Proposed Change to TSCA Section 12(b) Export 

Notification Requirements, November 2005 (EPA, 2005a), as clarified in a later SNUR economic analysis (EPA, 2007c, Table 

8).

Compile and Maintain the List of Products. Since TSCA §12(b) information collection activity has 

been in place for twenty years, most respondents would 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, 2009b). The total burden can vary from two hours per year up to two hours per 

month, depending on the number of products exported by the company and the number of their 

products subject to TSCA §12(b) (EPA, 2009b).

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

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

EPA estimated that there would be approximately 300 submitters per year in near-future years (EPA, 

2009b). Of these 300 submitters, EPA estimated that 200 companies were near the lower burden 

estimate of two 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 

for 12 notifications per year (EPA, 2009b).

Write or Revise Export Notification. Companies that export chemicals subject to TSCA §12(b) 

reporting must prepare an export notification to send to EPA when export shipments are made. Time 

for initial preparation of the export notice may vary depending on whether the company has prior 

experience with this requirement. This step is estimated to take an average of one hour of technical 

time (which may also include some proportion of legal time) per firm per year for 12 notifications per 

year (EPA, 2009b).

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 
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 3-11

time period. This process is estimated to take an average one half hour of clerical time per export 

notification or six hours for 12 notifications (EPA, 2009b).

The burdens and associated costs for each notification activity are provided in Exhibit 3-8. EPA 

estimates that the burden associated with making one notification is approximately 1.4 hours and $84. 

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

Notification Activity Technical Labor Clerical Labor Total

Wage 

Rate 

($/hr)

Burden Cost

Wage 

Rate 

($/hr)

Burden Cost Burden Cost

Compile list $64.66 9.3 $601 -- -- -- 9.3 $601 

Write letter $64.66 1 $65 -- -- -- 1 $65 

Check order and send 

notice -- -- -- $29.63 6 $178 6 $178 

Mailing cost1-- -- -- -- -- -- -- $165 

Total per average facility2` 10.30 $666 6.00 $178 16.30 $1,008 

Total per Notification $0.86 $55.50 0.50 $14.81 1.36 $84.06 

Notes:

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

calculations. 

1 Mailing costs reflect January 2012 USPS rates and can be found in Exhibit 3-7.

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

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

0795.13 ICR for Notification of Chemical Exports - TSCA Section 12(b) Supporting Statement for Request for OMB Review under 

the Paperwork Reduction Act (EPA, 2009b, p.10). 

3.3 Summary of per Submission Costs, by Option

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

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

summarizes the per-company per-chemical costs to comply with the proposed rule amendment, as 

described in more detail in section 3.2 above.
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Agency Costs ▌pg. 3-12

Exhibit 3-9: Compliance Options and Associated Costs Incurred by a Firm Due to 

the Proposed SNUR

Option1 Costs Quantified Costs per Chemical (2011$)2

1.

Electronic submission of 

a Significant New Use 

Notice (SNUN), 

indicating to EPA that the 

firm would like to 

manufacture, import, or 

process the chemical for 

a Significant New Use as 

defined in the SNUR.

Costs of submitting a SNUN, 

including rule familiarization, 

CDX registration (for 

companies that are first-time 

submitters), form 

completion,user fee, export 

notification, and any test 

costs.

$54.43 rule familiarization cost; $8,571 submission cost 

(including SNUN recordkeeping under 40 CFR §721.40 

and fee $2,500 for large businesses). EPA usually 

receives well under ten SNUNs per year. Export 

notifications costs are estimated at $84.06 per 

notification; total cost per company would vary. First time 

submitters would incur $190 for CDX registration and 

associated activities. Companies manufacturing,

importing, or processing a chemical currently used in 

commerce in the United States would incur a cost $64.66

for notifying consumers of SNUR regulatory activities. 

2.

Manufacture, import, or 

process in a way that 

avoids a Significant New 

Use.

Cost of the profit foregone as 

a result of not engaging in the 

commercial activity originally 

planned (opportunity costs), 

recordkeeping, and export 

notification costs.

Opportunity costs are not quantified. Other costs include 

rule familiarization ($54.43), recordkeeping ($9.70), 

export notification costs ($84.06 per notification), and

customer notification ($64.66) may apply.

Notes:

1

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

importing, or processing the chemical.

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

3.2.

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 would incur testing costs as a result of the proposed SNUR.

3.4 Likelihood of SNUN Submission

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

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

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

Federal fiscal year (FY) 2007, eight in FY2008, seven in FY2009, two in FY2010, and ten in 

FY2011.

13 In addition, as discussed in sections 2.3, all of the chemicals subject to this proposed rule 

are currently not being manufactured, imported or processed. It is important to note that LCPFCs

have recently been a focus of EPA activities aimed to reduce these chemicals, which resulted in a 

drive by industry to stop using LCPFACs as part of carpet or to treat carpets. Therefore, it is unlikely 

that manufacturers would resume use of LCPFACs in carpets or carpet treatments. This suggests that 

it is unlikely a firm would submit a SNUN.

3.5 Potential for Subsequent Regulatory Actions 

The Agency recognizes that if submission of a SNUN does result from a SNUR, the Agency may take 

additional regulatory actions under TSCA. These additional regulatory actions might be necessary to 

further evaluate an intended new use and associated activities, or to prohibit or limit that activity 

 

13 Values based on US EPA’s PMN Gold (V1.1) record keeping system as of September 1, 2011 (EPA, 

2011a).
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 3-13

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 about the chemical and 

its risks at the time the SNUN is being reviewed). 

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

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. 
SNUR EA for PFAS and Long Chain PFAC in Carpets

Agency Costs ▌pg. 4-1

4. Agency Costs

As described in the following sections, EPA’s costs to review and process SNUN submissions are 

assumed to be the same as EPA costs to review PMNs. 

4.1 Labor Rates for EPA Staff 

Agency labor costs are calculated based on annual Federal salaries for the Washington-Baltimore area 

published by the Office of Personnel Management effective January 2011 (OPM, 2011). EPA 

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

collection and administrative activities under the proposed rule.14 The average salary for a GS-13 Step 

5 employee was $100,904 in 2011 without fringe benefits and overhead costs. In order to derive the 

fully loaded salary, EPA multiplied the annual salary by an assumed loading factor of 1.6 to reflect 

federal fringe benefits and overhead (EPA, 2009c), which results in a fully loaded annual salary of 

$161,446 (see Exhibit 4-1). Dividing the fully loaded annual salary by 2,080 hours (i.e., the number 

of hours in a work year) yields an estimated hourly FTE wage rate of $77.62.

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

Exhibit 4-1: Derivation of Loaded Agency Wage Rates, 2011

Labor 

Category Data Source Date Wage Fringe 

Benefit

Fringes 

as %

wage

Overhead 

as %

wage

Fringe + 

overhead 

factor

Loaded 

Wages

(a) (b) (c)=(b)/(a) (d) (e)=(c)+(d)+1 (f)=(a)*(e)

EPA staff 

FTE

Annual Federal staff cost: 

OPM Washington-BaltimoreNorthern Virginia, DC-MDPA-VA-WV, area, GS-13 

Step 5 pay rates, with 60% 

overhead1

Jan 

2011

$100,904 

(annual)

--

Included 

in 60% 

overhead

60%21.60

$161,446

(annual)

$48.51

(hourly)

$77.62

(hourly)

Notes:

1

The Agency salary is the unloaded federal GS-13 Step 5 salary ($100,904 for 2011), from the OPM salary table for the 

Washington-Baltimore-Northern Virginia Locality Pay Area (OPM, 2011). Hourly rates are based on annual salary divided by 

2,080 hours.

2

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

(EPA, 2009c).

4.2 SNUN Processing Costs 

The list of review steps, estimates of extramural costs, and the percent of chemicals requiring a 

particular review step are derived from the costs for processing PMN submissions in Table VII-1 of a 

 

14 The GS-13 Step 5 is consistent with ICR No. 0574.14 (12/18/2007) (EPA, 2007a), which covers PMN 

SNURs. Use of this grade level follows the approach introduced in EPA, 2007b. That report represented a 

change from an earlier PMN SNUR economic analysis (EPA, 2003), which used an average of GS-12 Step 

1 and GS-12 Step 10 salaries.
SNUR EA for PFAS and Long Chain PFAC in Carpets

Agency Costs ▌pg. 4-2

1994 EPA report, Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 

Premanufacture Notifications (EPA, 1994). The Agency burden associated with processing a PMN 

has been adjusted to reflect burden reductions resulting from the 2009 final PMN Electronic 

Reporting (ePMN) Rule that requires the electronic submission of all TSCA section 5 notices. 

Electronic submission of SNUN forms is expected to reduce Agency burden by 16.5 percent (EPA, 

2009b, p.28).

For each review step, the “EPA staff” cost is calculated by multiplying the number of FTEs (in the 

first column) by the fully loaded hourly salary. This shows EPA staff cost for chemicals requiring the 

selected review step. 

The Extramural Cost column shows costs for contractor support and other outside purchases for 

chemicals requiring the selected review step, and is inflated from 1993 prices using the Bureau of 

Labor Statistics (BLS) Employment Cost Index (ECI) data (BLS, 2012b). The ECI for total 

compensation (not seasonally adjusted) of private industry professional and related workers (Series 

ID CIU2010000120000I) is used because it is the only series with continuous data since 1985, and 

that includes professional and technical labor, which perform the majority of Agency extramural 

activities. Exhibit 4-2 contains the derivation of inflation factors for Agency extramural costs.

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

Item Inflation Index Source1 Starting 

year

Index 

for 

starting 

year

(a)

Index for 2011

(b)

Inflation 

factor 

(b)/(a) 2

Agency Extramural 

costs Professional 

and Related Private 

Industry

BLS ECI, Total comp, Private 

industry, Professional and 

related, 4th Q [BLS, 2012b]

3

1993 67.00 115.7 1.73

Notes:

1

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

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

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

rebased.

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

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

Docket OPPT-2009-0922 (EPA 2011b), we began to use the not-seasonally adjusted CIU2010000120000I for private industry 

Professional, and Related workers, instead of SA CIS2010000W00000I for private industry white collar workers because BLS 

retired the “white-collar” series.

Source: (BLS 2012b) Bureau of Labor Statistics. Employment Cost Index – Total Compensation: Professional and Related 

Private Industry, Not Seasonally Adjusted. (Series ID: CIU2010000120000I (B)), extracted March 22, 2012. 

http:/data.bls.gov/cgi-bin/srgate. (BLS 2012b).

The Percent of Cases column in Exhibit 4-3 is a weighting factor applied to reflect the fact that not all 

chemicals require each review step. For example, in the PMN process, all chemicals require 

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 
SNUR EA for PFAS and Long Chain PFAC in Carpets

Agency Costs ▌pg. 4-3

require little review because they are determined to be “invalid” – i.e. not required in the first place. 

However, often a SNUN may take more Agency time than a typical PMN because of factors such as 

the need to retrieve old PMN records from archives, and the likelihood that more data requiring EPA 

review are submitted with a SNUN than would be submitted on average with a PMN. Resources were 

not available to update the review hours to reflect the current review process or to tailor the cost 

estimates to SNUNs. Therefore, for this analysis, the review steps and weighting factors are assumed 

to be the same as those derived in 1994 for PMNs.

Values in the Weighted Cost column is calculated by multiplying the un-weighted costs (EPA staff 

cost plus extramural costs) by the percentage of cases requiring this review step. Weighted costs are 

then multiplied by the burden reduction of 16.5 percent to account for burden savings generated 

electronic submission. This calculation yields total Agency costs of $5,066 per SNUN, for submission 

review and processing, as shown in Exhibit 4-3.
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 4-4

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

Review Steps

EPA Staff (FTE) Cost Extramural Cost2

Unweighted 

Cost

% of 

Cases

Weighte

d Cost3

Burden 

Reductio

n

4

Weighted 

Cost with 

Burden 

Reduction

FTE 

Fraction

Cost per 

FTE1

FTE Total 

(2011$)

1993$ 2011$

(a) (b) (c)=(a)*(b) (d) (e) (f)=(c)+(e) (g) (h)=(f)*(

g) (i) (j)=(h)*(1-(i))

Pre-notice consultation 0.0024 $161,446 $387.47 $4.00 $6.91 $394 41% $161.70 0.165 $135 

Administrative 

prescreen/ notice 

receipt/user fee

0.0024 $161,446 $387.47 $92.00 $158.87 $546 100% $546.34 0.165 $456 

CRSS (Chemical 

Review and Search 

Strategy)

0.0025 $161,446 $403.62 $268.00 $462.80 $866 100% $866.42 0.165 $723 

SAT (Structure Activity 

Team) 0.0006 $161,446 $96.87 $14.00 $24.18 $121 100% $121.04 0.165 $101 

Engineering/Exposure 0.0015 $161,446 $242.17 $56.00 $96.70 $339 100% $338.87 0.165 $283 

Exposure/Fate 0.0008 $161,446 $129.16 $0.00 $0.00 $129 100% $129.16 0.165 $108 

Focus 0.0009 $161,446 $145.30 $23.00 $39.72 $185 100% $185.02 0.165 $154 

Standard Review 

Functions 0.0219 $161,446 $3,535.68 $511.00 $882.43 $4,418 29% $1,281.25 0.165 $1,070 

Division Directors 

Meeting 0.0129 $161,446 $2,082.66 $113.00 $195.14 $2,278 15% $341.67 0.165 $285 

Order 

Development/Negotiatio

n Review

0.0171 $161,446 $2,760.73 $22.00 $37.99 $2,799 3% $83.96 0.165 $70 

Post Order Data Review 0.0886 $161,446 $14,304.15 $0.00 $0.00 $14,304 3% $429.12 0.165 $358 

Order Modification 0.2167 $161,446 $34,985.43 $0.00 $0.00 $34,985 3% $1,049.5

6 0.165 $876 

New Chemical SNUR 

Development 0.0277 $161,446 $4,472.07 $85.00 $146.78 $4,619 7% $323.32 0.165 $270 

Notices of 

Commencement 0.0012 $161,446 $193.74 $40.00 $69.07 $263 31% $81.47 0.165 $68 

FOIA (Freedom of 

Information Act) 0.0333 $161,446 $5,376.17 $287.00 $495.61 $5,872 1% $58.72 0.165 $49 
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 4-5

Review Steps

EPA Staff (FTE) Cost Extramural Cost2

Unweighted 

Cost

% of 

Cases

Weighte

d Cost3

Burden 

Reductio

n

4

Weighted 

Cost with 

Burden 

Reduction

FTE 

Fraction

Cost per 

FTE1

FTE Total 

(2011$)

1993$ 2011$

(a) (b) (c)=(a)*(b) (d) (e) (f)=(c)+(e) (g) (h)=(f)*(

g) (i) (j)=(h)*(1-(i))

Requests

CBI (Confidential 

Business Information) 

Substantiation

0.0004 $161,446 $64.58 $3.00 $5.18 $70 100% $69.76 0.165 $58 

TOTAL $6,067 0.165 $5,066

Notes:

1 GS-13 Step 5 salaries loaded with benefits and overhead. See Exhibit 4-1 for derivation.

2 Extramural costs consist of contracting support and other purchases directly attributable to the PMN review process inflated from 1993 prices using Exhibit 4-2. 

3 Weighted costs were calculated using unrounded unit cost estimates. 

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

Sources: FTEs per review step, 1993 extramural costs, and percent of cases are from EPA, 1994 Table VII-1; GS-13 salaries are from OPM, 2011.
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 4-6

4.3 Export Notification Cost

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

SNURs, as described in Section 3.2.7. The Agency burden and cost due to TSCA §12(b) export 

notification result from three tasks. In the first task, EPA receives export notifications from 

companies that intend to export one of the chemicals subject to TSCA §12(b) (EPA, 2009b). In the 

second task, EPA staff prepares separate notification letters that are subsequently reviewed and 

delivered to importing countries, their embassies, or representatives, and to the importing country’s 

U.S. embassies (EPA, 2009b). (See Exhibit 3-7 for the cost of mailing one notification). The third 

task is comprised of EPA staff responses to public inquiries and other TSCA 12(b) activities. The 

work of responding to non-routine requests for information and clarification from industry and 

importing countries, and of handling other tasks associated with the TSCA §12(b) program, was 

estimated to require roughly 400 hours per year (EPA, 2009b). Since the current rulemaking covers 

only a very small percent of the chemicals subject to TSCA 12(b) reporting, a very small percent of 

such activity would be attributable to the current rulemaking. 

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

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

first two Agency activities is provided in Exhibit 4-4. To estimate the Agency cost, hourly burdens 

are multiplied by the loaded wage rate of a GS-13, Step 5, which is derived in Exhibit 4-1. 

Exhibit 4-4: TSCA 12(b) Export Notification Cost: Agency Burden per Activity

(2011$)

Agency Activity

Hours per 

Activity

FTE per Activity

1

Loaded Wages Mailing 

Cost

Total Agency

GS-13, Step 5 FTE Cost per Activity

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

Process an incoming 

notification from an 

exporting company

0.1 0.00005 $161,446 $0.00 $7.76 

Prepare and mail a 

notification to an 

importing country

0.5 0.00024 $161,446 $13.75 $52.56 

Notes:

1

The burden associated with an Agency activity is the burden for the Agency to process one incoming notification, or to 

prepare and mail an outgoing notification.

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

estimates 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 2009b), adjusted for 

inflation.
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 5-1

5. Benefits

A SNUN submission provides EPA with the opportunity to evaluate the intended use and, if 

necessary, to prohibit or limit that activity before it occurs. It allows the Agency to take immediate 

action to mitigate an activity that the Agency deems harmful to the environment or human health. The 

proposed SNUR allows EPA to evaluate the use of, or exposure to these chemicals and allow the 

Agency to take preventive action to limit or prohibit any Significant New Use. EPA also expects that 

the proposed rule may restrict future uses or exposure to the chemicals, as a company may choose to 

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

Therefore, the proposed SNUR may limit future exposure to the chemicals. 
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 6-1

6. Additional Analyses

6.1 Regulatory Flexibility Act 

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

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

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

follows. The requirement to submit a SNUN applies to any person (including small or large entities) 

who intends to engage in any activity described in the rule as a significant new use. Where a use is 

new, by definition no small or large entities presently engage in such activities. Although some small 

entities may decide to manufacture or process a substance for the new use after the SNUR is 

promulgated, EPA receives very few SNUNs, and few of those are submitted by small entities. In 

response to the promulgation of SNURs covering over 1,000 chemical substances, the Agency 

receives only a handful of SNUNs per year. For example, the number of SNUNs was four in Federal 

fiscal year 2005, eight in FY2006, six in FY2007, eight in FY2008, seven in FY2009, two in 2010, 

and ten in 2011 (EPA, 2012), for an average of 6 per year from all SNURs. EPA has no reason to 

believe that this SNUR would alter the pattern of SNUN submissions that EPA has historically seen. 

In addition, the estimated reporting cost for submission of a SNUN is minimal regardless of the size 

of the firm, averaging about $8,600 including SNUN recordkeeping and reporting costs. The Agency 

currently offers some relief to certain small businesses with sales (including those of 

subsidiary/parent companies) of less than $40 million per year by reducing the SNUN submission fee 

from $2,500 to $100. This lower fee reduces the cost of submitting a SNUN to about $6,200 for 

smaller firms. During the six year period from 2005-2010, only three submitters self-identified as 

small in their SNUN submission15 (EPA, 2012). EPA believes the cost of submitting a SNUN is

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

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

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

significant or adversely affect a substantial number of small entities.

6.2 Unfunded Mandates Reform Act (UMRA)

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

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

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

these chemicals.

6.3 Paperwork Reduction Act (PRA)

According to the Paperwork Reduction Act (PRA), 44 U.S.C. 3501 et seq., an Agency may not 

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

OMB approval under the PRA, unless it has been approved by OMB and displays a currently valid 

OMB Control number. The OMB control numbers for EPA's regulations in title 40 of the CFR, after 

 

15 The three “small” submitters were identified by review of actual SNUN submissions from the years 2005-

2010.
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 6-2

appearing in the Federal Register, are listed in 40 CFR, part 9, and included on the related collection 

instrument, or form, if applicable. The information collection requirements related to this action have 

already been approved by OMB pursuant to the PRA under OMB control numbers 2070-0038 (EPA 

ICR No. 1188) and 2070-0030 (EPA ICR No. 0795).

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

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

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

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

notifications (Section 3.2.5) and 1.36 hours for export notification (Section 3.2.7). The burdens for 

rule familiarization, CDX registration, CDX electronic signature, pay.gov account setup form 

completion, submission, and recordkeeping consumer notifications are approved under EPA ICR No. 

1188 (OMB control number 2070-0038). The burden for export notification is approved under EPA 

ICR No. 0795 (OMB control number 2070-0030). 

6.4 Executive Order 13132, Federalism

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

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

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

federalism implications are defined in the Executive Order to include regulations that have 

“substantial direct effects on the States, on the relationship between the national government and the 

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

(64 FR 43255, August 10, 1999). 

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

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

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

action.

6.5 Executive Order 12898, Environmental Justice

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

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

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

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

addressing, as appropriate, disproportionately high and adverse human health or environmental 

effects of their programs, policies, and activities on minority populations and low-income populations 

in the United States.

The information collected under this proposed rule, if finalized, would assist EPA and others in 

determining the potential hazards and risks associated with various chemicals manufactured and used 

at high production volumes. Although not directly impacting environmental justice-related concerns, 

this information would enable the Agency to better protect human health and the environment, 

including in low-income and minority communities.
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 6-3

6.6 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 would have 

an impact of $100 million or more only. The impact of this SNUR would be less than $100 million 

and therefore no analysis of such impacts on children is required.

6.7 Executive Order 13175, Tribal Governments

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

22951, November 6, 2000). This rule does not have Tribal implications because EPA has no 

information to indicate that any tribal government manufactures or processes the chemical substances 

covered by this action.

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

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

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

action is not expected to affect energy supply, distribution, or use.
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 7-1

7. References

3M Company. 1999. Fluorochemical Use, Distribution, and Release Overview. St. Paul, Minnesota. 

May 6, 1999. (AR226-0550).

40 CFR 721 Toxic Substances Control Act, Significant New Uses for Chemical Substances Code of 

Federal Regulations. Part 721 Title 40, July 27, 1988, as amended, June 23, 1993

Armeduri, Bruno; Bouterin, Bernard. Well-Architectured Floropolymers: Synthesis, Properties, and 

Applications. “Applications of Flourinated Telomers,” (p. 71).

BLS, 2006a. U.S. Bureau of Labor Statistics, Employer Costs for Employee Compensation: Changes 

to NAICS and SOC, Table 2. ECEC Occupational Comparability between SOC and OCS. 

Downloaded February 2006 from http://www.bls.gov/ncs/ect/sp/ecsm0003.htm.

BLS, 2006b. U.S. Bureau of Labor Statistics, Employment Cost Index News Release Text: 

Employment Cost Index, March 2006 (April 28, 2006), at http://www.bls.gov.

BLS, 2006c. U.S. Bureau of Labor Statistics. Change has Come to the ECI (June 14, 2006) at 

http://www.bls.gov/ncs/ect/sp/ecsm0001.htm

BLS, 2012a. U.S. Bureau of Labor Statistics. “Employer Costs for Employee Compensation 

Supplementary Tables December 2011.” (Accessed on March 14, 2012.) Available at: 

http://www.bls.gov/ncs/ect/sp/ecsuptc21.pdf. (Note: The BLS report title and content is updated 

periodically to include more recent data, on the same website.) 

BLS, 2012b. Bureau of Labor Statistics. Employment Cost Index – Total Compensation: Professional 

and Related Private Industry, Not Seasonally Adjusted. (Series ID: CIU2010000120000I (B)), 

extracted March 22, 2012. Available at: http:/data.bls.gov/cgi-bin/srgate.

BLS, 2012c. U.S. Bureau of Labor Statistics. Consumer Price Index- All Urban Consumers, U.S. City 

Average (Series ID: CUUR0000SA0), extracted March 22, 2012. Available at; 

http:/data.bls.gov/cgi-bin/srgate.

Branch, 2006. Raphael E. Branch and Lowell Mason. U.S. Bureau of Labor Statistics, “Seasonal 

adjustment in the ECI and the conversion to NAICS and SOC.” Monthly Labor Review. Vol. 

129, No. 4, April 2006. Available at www.bls.gov. 

Carolini, Dorian. 2009. Perfluorooctane Sulfonate (PFOS) Production and Use: Past and Current 

Evidence. Prepared for UNIDO. December 2009.

Caroll, 2006. Richard E. Caroll. U.S. Bureau of Labor Statistics, “Changes affecting the Employment 

Cost Index: an overview.” Monthly Labor Review. Vol. 129, No. 4, April 2006. Available at 

www.bls.gov 

Danish Ministry of the Environment. 2008. Survey and Environmental/Health Assessment of 

Fluorinated Substances in Impregnated Consumer Products and Impregnating Agents: Survey of 

Chemical Substances in Consumer Products, No. 99.

EPA, 1992. U.S. EPA, Office of Policy, Planning, and Evaluation. Instructions for Preparing 

Information Collection Requests (ICRs). Washington, DC, June 1, 1992.

EPA, 1994. U. S. EPA, Office of Toxic Substances, Regulatory Impacts Branch. Regulatory Impact 

Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications. 

Washington, DC, September 9, 1994. (OTS/RIB later became OPPT/EPAB.)

EPA, 2000. U.S. EPA, Office of Pollution Prevention and Toxics, ICR No. 1139.06. OMB Control No.: 

2070-0033 [Information Collection Request for] TSCA Existing Chemical Test Rules, Consent 
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 7-2

Orders, Test Rule Exemptions, and Voluntary Test Data Submissions: Supporting Statement for 

Request for OMB Review under the Paperwork Reduction Act. Attachment 5, Wage Rates 

Estimation, August 29, 2000.

EPA, 2002a. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis

Branch. Revised Economic Analysis for the Amended Inventory Update Rule: Final Report. 

Washington, DC. August 2002.

EPA, 2002b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis 

Branch, Wage Rates for Economic Analysis of the Toxics Release Inventory Program. Washington, 

DC: June 10, 2002.

EPA, 2003. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis 

Branch. Economic Analysis of Expedited Significant New Use Rules for 65 Chemical Substances. 

Washington, DC, 2003. Available from the Federal Docket Management System as EPA-HQOPPTS-2002-0078 at http://www.regulations.gov.

EPA, 2005a. Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. 

Economic Analysis of the Proposed Change to TSCA Section 12(b) Export Notification 

Requirements, November 2005, available from the Federal Docket Management System as EPAHQ-OPPT-2005-005 8-0017 at http://www.regulations.gov.

EPA, 2005b. U.S. EPA, Office of Pollution Prevention and Toxics ICR No. 118.08. OMB Control No.: 

2070-0038 [Information Collection Request for] TSCA Section 5(a)(2) Significant New Use Rules 

for Existing Chemicals (Renewal). Supporting Statement for a Request for OMB Review under the 

Paperwork Reduction Act, October 11, 2005.

EPA, 2005c. Economic Analysis of the Proposed Significant New Use Rule for 183 Perfluoroalkyl 

Sulfonates. November 3, 2005.

EPA, 2007a. U.S. EPA, Office of Pollution Prevention and Toxics, EPA ICR No. 0574.14. OMB 

Control No.: 2070-0014 [Information Collection Request for] Pre-Manufacture Review 

Reporting and Exemption Requirements for New Chemical Substances and Significant New Use 

Reporting Requirements for Chemical Substances: Supporting Statement for a Request for OMB 

Review under the Paperwork Reduction Act, December 6, 2007.

EPA, 2007b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis

Branch. Economic Analysis of Expedited Significant New Use Rules for 65 Chemical Substances 

(EPA Docket OPPT-2003-0063), December 4, 2006 (Revised March 12, 2007).

EPA, 2007c. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis

Branch. Economic Analysis of Expedited Significant New Use Rules for 38 Chemical Substances 

(EPA Docket OPPT-2006-0898), August 17, 2007

EPA, 2007d. ``Perfluoroalkyl Sulfonates; Proposed Significant New Use Rule, Final Rule.'' 72 FR 

57222. October 9, 2007.

EPA, 2009a. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis 

Branch. Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule. 

(EPA-HQ-OPPT-2008-0296). July 13, 2009

EPA, 2009b. U.S. EPA, Office of Pollution Prevention and Toxics. EPA ICR No.: 0795.13 OMB 

Control Number 2070-0030 [Information Collection Request for] Notification of Chemical 

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

Paperwork Reduction Act. March 6, 2009 at http://www.regulations.gov.
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Agency Costs ▌pg. 7-3

EPA, 2009c. U.S. EPA, Office of Environmental Information, Collection Strategies Division, ICR 

Handbook EPA’s Guide to Writing Information Collection Requests under the Paperwork 

Reduction Act of 199. Revised 10/2009. 

EPA, 2011a. U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics. 

PMN Gold Database (Confidential Business Information) accessed September 1, 2011.

EPA, 2011b. U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics. 

Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances, (EPA 

Docket OPPT-2009-0922) August 2011.

EPA, 2012. Count of SNUN Submissions as tracked in EPA’s Confidential Business Information 

Tracking System (CBITS). February, 2012.

Kissa, David. Fluorinated Surfactants and Repellents. Surfactant Science Series. Marcel 

Dekker, Inc.: New York. 2001.

Knox, S. S., T. Jackson, B. Javins, Stephanie J. Frisbee, A. Shankar and A. M. Ducatman. 2011. 

Implications of Early Menopause in Women Exposed to Perfluorocarbons. J Clin Endocrinol 

Metab 96(6): 1-7.

Melzer, D., N. Rice, M. H. Depledge, W. E. Henley and T. S. Galloway. 2010. Association between 

Serum Perfluorooctanoic Acid (PFOA) and Thyroid Disease in the U.S. National Health and 

Nutrition Examination Survey. Environmental Health Perspectives. 118(5): 686-692.

OPM, 2011. Office of Personnel Management, Salary Table 2011-DCB, Washington-BaltimoreNorthern-Virginia, DC-MD-VA-WV-PA. Accessed from 

http://www.opm.gov/oca/11tables/pdf/DCB.pdf. 

OSPAR. 2006. Hazardous Substance Series: Perfluorooctane Sulphonate (PFOS). OSPAR 

Commission 2005 (2006 Update).Sleemi, 2006. Fehimida Sleemi. U.S. Bureau of Labor 

Statistics, “Employment Cost Index Publication Plans”. Monthly Labor Review. Vol. 129, No. 4, 

April 2006. available at www.bls.gov/opub/mlr/2006/04/art2full.pdf

Sleemi, 2006. Fehimida Sleemi. U.S. Bureau of Labor Statistics, “Employment Cost Index 

Publication Plans”. Monthly Labor Review. Vol. 129, No. 4, April 2006. available at 

www.bls.gov/opub/mlr/2006/04/art2full.pdf

U.S. Postal Service (U.S. PS). 2012. “Prices” <http://www.usps.com/prices/>. Accessed January 

2012

Weinstein, 2004. Harriet G. Weinstein and Mark A. Loewenstein, U.S. Bureau of Labor Statistics. 

Comparing Current and Former Industry and Occupation ECEC Series. Originally posted August 

25, 2004 at http://www.bls.gov/opub/cwc/cm20040823ar01p1.htm
SNUR EA for PFAS and Long Chain PFAC in Carpets Contract # EP-W-08-010

Appendix A ▌pg. A-1

Appendix A – Inflators and Wage Rates

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

calculating costs of labor, materials, and other inputs. Costs presented in this report are in 2011

dollars.

A.1 Derivation of Loaded Wage Rates 

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

a fully loaded labor cost. The basic method is described in Wage Rates for Economic Analysis of the 

Toxics Release Inventory Program (EPA, 2002b). The resulting loaded labor rates are given in 

Exhibit 7-1. 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, and Clerical Labor

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

the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation (ECEC) data,16 for 

December 2011, for manufacturing industries.17

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 

 

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

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

17 Employer Costs for Employee Compensation Supplementary Tables December 2011. (BLS, 2012a). This follows the 

approach introduced in EPAB, 2007a. Earlier PMN SNUR economic analyses, such as EPA, 2003, used ECEC data for 

“All Goods Producing” sectors (manufacturing, mining, and construction). However, the manufacturing sector data seem 

more relevant since the SNURs mainly affect the chemicals industry.
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Appendix A ▌pg. A-2

labor category. For example, for December 2011, the average wage rate for professional/technical18

labor was $38.48; the average fringe benefit was $19.64. Fringe benefits as a percent of wages were 

$19.64/$38.48, or approximately 51.0 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 

2011 fully loaded wage for professional/technical labor is $38.48 × (1+0.5104 + 0.17) = $64.66.

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

Exhibit 7-1.

A.1.2 Derivation of Labor Rates for EPA Staff

Agency labor costs are calculated based on annual Federal salaries for the Washington-Baltimore area 

published by the Office of Personnel Management effective January 2011 (OPM, 2011). The average 

salary for one FTE staff member is estimated as the salary for a GS-13 Step 5 employee.19

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

overhead, the loaded annual salary of EPA staff was calculated to be $161,446. 

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

Requests (ICRs) (EPA, 1992, page 30, footnote 9). The 60 percent assumption was labeled “the 

benefits multiplication factor” in the EPA Guide, but has been used in many EPA Office of Pollution 

Prevention and Toxics ICRs to reflect both fringe benefits and overhead for Federal staff. For 

example, it was used in an August 2000 document supporting ICR No. 1139.06 (EPA, 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)

 

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

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

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

In the process, the “Professional specialty and technical” category became the “Professional and related” category. 

However, the coverage of the old and new occupational groups is approximately the same. See the BLS article, Comparing 

Current and Former Industry and Occupation ECEC Series (Weinstein, 2004).

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

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

economic analysis (EPA, 2003), which used an average of GS-12 Step 1 and GS-12 Step 10 salaries.
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Agency Costs ▌pg. A-3

Exhibit 7-1: Derivation of Loaded Wage Rates

EPAB Labor 

Category Data Source Date Wage Fringe 

Benefit

Fringes as %

Wage

Overhead 

% Wage2

Fringe + 

Overhead 

Factor

Loaded 

Wages1

(a) (b) (c) =(b)/(a) (d) (e)=(c)+(d)+1 (f)=(a) x (e)

Managerial

BLS ECEC, Private Manufacturing 

industries, “Mgt, Business, and 

Financial”3

Dec-11 $43.01 $20.40 47.43% 17% 1.64 $70.72

Professional/

Technical

BLS ECEC, Private Manufacturing 

industries, “Professional and related“3 Dec-11 $38.48 $19.64 51.04% 17% 1.68 $64.66

Clerical BLS ECEC, Private Manufacturing 

industries, “Office and Administrative 

Support”3

Dec-11 $17.69 $8.93 50.48% 17% 1.67 $29.63

EPA staff 

FTE

Annual Federal staff cost: OPM 

Washington-Baltimore-Northern 

Virginia, DC-MD-PA-VA-WV, area, GS13 Step 5 pay rates, with 60% 

overhead4

Jan-11 $48.51 --

[Included in 

60% overhead] 60% 1.6 $77.62

Notes:

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

2An overhead rate of 17 percent was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory Program (EPA, 2002b), and the Revised 

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

3Employer Costs for Employee Compensation Supplementary Tables December 2011, U.S. Bureau of Labor Statistics, March 14, 2012 (BLS, 2012a).

4

The Federal salary is the unloaded Federal GS-13 Step 5 salary ($100,904 divided by 2080 hours to get the hourly wage rate in the table) for 2011, from the Office of Personnel 

Management salary table for Washington-Baltimore-Northern Virginia (OPM, 2011). The 60% fringes-and-overhead rate is from an EPA guide, Instructions for Preparing Information 

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

A.2 Derivation of Inflation Factors

Detailed information on the derivation of the inflation factors used is presented in Exhibit 7-2. 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 Exhibit 7-2 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).20

“Starting year” indices in Exhibit 7-2 continue to be SIC-OCS 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. 

 

20 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. 
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Agency Costs ▌pg. A-5

Exhibit 7-2: Derivation of Inflation Factors

Item Inflation Index Source1 Starting 

Year

Index for 

Starting Year 

(a)

Index for 

2011

(b)

Inflation 

Factor 

(b)/(a)2

Agency Extramural costs 

Professional and Related 

Private Industry

BLS ECI, Total comp, Private 

industry, Professional and 

related, 4

th Q [BLS, 2012b]3

1993 67 115.7 1.727

Labels, placards etc. BLS CPI, All urban consumers, not 

SA. CUUR0000SA0, Annual [BLS, 

2012c]

1997 160.5 224.939 1.401

File cabinet

Photocopies BLS CPI, All urban consumers, not 

SA. CUUR0000SA0, Annual 

[BLS, 2012c]

Record keeping materials 1988 118.3 224.939 1.901

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). 4

th Q = Fourth Quarter. 

Notes:

1 In 2006, Bureau of Labor Statistics (BLS) Employment Cost Index (ECI) series “were rebased to December 2005 = 100 from June 1989 

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

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

“Starting year” ECI indices are SIC-OCS based: Seasonally Adjusted (SA) ECS10002I for private industry All Workers, and not SA 

ECU11122I for private industry Professional and Related Workers. 

After 2006, ECI indices are NAICS-SOC based: Seasonally Adjusted (SA) CIS2010000000000I for private industry All Workers, and not 

SA CIU2010000120000I (B) for private industry Professional, and Related workers. 

2

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

3 Beginning with the report Economic Analysis of Expedited Significant New Use Rules for 25 Chemical Substances: EPA Docket OPPT2009-0922 (EPA, 2011b) we began to use the not-seasonally adjusted CIU2010000120000I for private industry Professional, and Related 

workers, instead of SA CIS2010000W00000I for private industry white collar workers because BLS retired the “white-collar” series.