SUPPORTING STATEMENT FOR 

EPA INFORMATION COLLECTION REQUEST NUMBER 2455.01

“REVISION TO THE EXPORT PROVISIONS OF THE CATHODE 

RAY TUBE (CRT) RULE - PROPOSED RULE”

FEBRUARY 2012
TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION........................................4

1(a) Title and Number of the Information Collection .....................................................4

1(b) Short Characterization .............................................................................................4

2. NEED FOR AND USE OF THE COLLECTION...............................................................5

2(a) Need and Authority for the Collection.....................................................................5

2(b) Practical Utility and Users of the Data ....................................................................5

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA ...........................................................................................................................6

3(a) Nonduplication.........................................................................................................6

3(b) Public Notice............................................................................................................6

3(c) Consultations............................................................................................................6

3(d) Effects of Less Frequent Collection.........................................................................6

3(e) General Guidelines...................................................................................................7

3(f) Confidentiality .........................................................................................................7

3(g) Sensitive Questions..................................................................................................7

4. THE RESPONDENTS AND THE INFORMATION REQUESTED.................................7

4(a) Respondents and SIC/NAICS Codes.......................................................................7

4(b) Information Requested...........................................................................................10

5. THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT.......................................12

5(a) Agency Activities...................................................................................................12

5(b) Collection Methodology and Management............................................................13

5(c) Small Entity Flexibility..........................................................................................13

5(d) Collection Schedule ...............................................................................................13

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION...............14

6(a) Estimating Respondent Burden Hours...................................................................14

6(b) Estimating Respondent Costs ................................................................................14

6(c) Estimating Agency Burden and Costs ...................................................................15

6(d) Estimating the Respondent Universe and Total Burden and Costs .......................16

6(e) Bottom Line Burden Hours and Costs...................................................................18

6(f) Reasons for Change In Burden ..............................................................................18

6(g) Burden Statement...................................................................................................18
3

EXHIBITS

Estimated Respondent Burden and Cost for Reading the Rule.........................................20

Costs for New Annual Reporting by Exporters of CRTs for Recycling...............................21

Costs for Meeting Proposed Reuse & Recycling Notification Changes..............................22

(Asking for minor additional information)
4

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

This Information Collection Request (ICR) is entitled “Revision to the Export Provisions 

of the Cathode Ray Tube (CRT) Rule – Proposed Rule,” EPA ICR Number 2455.01. 

1(b) Short Characterization

The U.S. Environmental Protection Agency (EPA) promulgated the CRT rule on July 28, 

2006 (71 FR 42928). In that rule, EPA amended its regulations under the Resource Conservation 

and Recovery Act (RCRA) to streamline the management requirements for used CRTs in an effort 

to encourage recycling and reuse of these materials rather than landfilling or possible incineration. 

The CRT rule also contained requirements for used CRTs exported for reuse or recycling. 

Exporters of used CRTs for recycling must notify EPA of an intended shipment before the 

shipment occurs. Notifications may cover exports extending over a 12-month or shorter period. 

The notification must include several items of information. When EPA receives this information, 

it notifies the receiving country. When the receiving country consents in writing to receive the 

CRTs, EPA forwards an Acknowledgement of Consent (AOC) to the exporter. The exporter may

not ship the CRTs until he receives the AOC. With respect to CRTs that are exported for reuse, 

the CRT rule requires exporters to submit a one-time notification to EPA with contact information 

and a statement that they are exporting the CRTs for reuse. They must keep copies of normal 

business records demonstrating that each shipment will be reused. (See 40 CFR 261.39 and 

261.41 for existing notification and recordkeeping requirements about used CRTs exported for 

reuse or recycling. The burden associated with these requirements is approved under EPA ICR 

Number 1189.24, and the OMB control number for this ICR is 2050-0053.)

EPA is proposing to revise the export provisions of the CRT rule. The purpose of these 

proposed revisions is to address certain implementation concerns with the current export 

provisions of the CRT rule. EPA is proposing a definition of “CRT exporter” that includes any

intermediaries arranging for the export. Because CRTs are sometimes exported to more than one 

recycler in the receiving country, EPA is also proposing to require that the exporter state the name 

and address of the recycler or recyclers and the estimated quantity of CRTs to be sent to each 

facility, as well as the names of any alternate recyclers.

In addition, EPA is proposing to expand the current reuse notice and model the notice on 

that required for CRTs exported for recycling. Instead of a one-time notice, EPA is proposing to 

require that reuse notices be submitted to cover a twelve month or shorter period. EPA is also 

proposing to add additional items of information to the notice, including contact information about 

the exporter and the destination facility, the frequency or rate at which the CRTs would be 

exported, the quantity of CRTs, transport information, and a description of the manner in which 

the CRTs will be reused in the receiving country. Furthermore, EPA is proposing to require that 

the exporter sign a certification that the CRTs are fully functioning or capable of being functional 

after refurbishment. EPA believes that the proposed expanded notice will help the Agency
5

determine whether the exported CRTs have been handled as products that are actually reused in the 

receiving country.

Finally, EPA is proposing to add a requirement that exporters of CRTs for recycling 

submit an annual report documenting the actual numbers of CRTs exported during the previous 

calendar year. This number may differ from the estimate submitted in the original notice. This 

information will help ensure that the shipments occurred under the terms approved by the 

receiving country, and would enable EPA to provide receiving countries with information that 

may help them to determine the quantity of CRTs that were received in a particular country for 

recycling. 

In Sections 1 through 5 of this ICR, EPA presents a comprehensive description of the new 

information collection requirements in the proposed rule to revise the export provisions of the 

CRT rule. In Section 6, EPA estimates the total annual hour and cost burden to respondents and 

the Agency associated with these new information collection requirements. 

In the following paragraphs, EPA briefly describes the new information collection 

requirements covered in this ICR.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection

EPA is proposing the information collection under the authority of Sections 2002(a), 3001, 

3002, 3004, and 3006 of RCRA, as amended. The proposed rule revises the notification that must 

be submitted to EPA when CRTs are exported for reuse or recycling and adds a requirement that 

exporters of CRTs for recycling submit an annual report documenting the actual numbers of CRTs 

exported during the previous calendar year. EPA believes the information collection 

requirements covered in this ICR are needed to ensure that CRTs exported for reuse or recycling 

are managed in compliance with the regulations. 

2(b) Practical Utility and Users of the Data

Since promulgation of the CRT rule in 2006, it has become apparent that some CRTs 

ostensibly exported for reuse are actually disassembled and recycled when they reach the receiving 

country, sometimes under unsafe conditions. EPA will use the collected information to ensure 

exported CRTs have been handled as products that are actually reused in the receiving country. 

In addition, the collected information would enable EPA to provide receiving countries with 

information that may help them to determine the quantity of CRTs that were received in a 

particular country for recycling.
6

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Nonduplication

None of the information required by the proposed rule would duplicate information 

required by existing RCRA regulations. 

3(b) Public Notice

In compliance with the Paperwork Reduction Act of 1995, EPA has issued a public notice 

in the Federal Register. The public comment period for this ICR is combined with the proposed 

rule, and it will run for 60 days. To assist the public in commenting on the proposal, EPA raised a 

few issues in the preamble to the proposed rule and asked for the public to comment on them. At 

the end of the comment period, EPA will review public comments received in response to the 

notice and will address comments received, as appropriate.

3(c) Consultations

The proposed revisions to the export provisions of the CRT rule were recommended by the 

Interagency Task Force on Electronics Stewardship (the “Task Force”) in its report titled National 

Strategy for Electronics Stewardship (July 20, 2011). Several federal agencies participated in 

drafting the recommendations of the National Strategy for Electronics Stewardship, including the

General Services Administration, Office of the US Trade Representative, and the Departments of 

Commerce, Defense, and Energy. On behalf of the Task Force, EPA solicited public comment 

from stakeholders through a Federal Register notice. Also on behalf of the Task Force, the 

Council on Environmental Quality held three stakeholder listening sessions in March 2011 with 

state and local government agencies, non-governmental organizations, and industry, respectively. 

Comments provided through both of these methods were evaluated by the Task Force and 

considered in developing the National Strategy on Electronics Stewardship. 

3(d) Effects of Less Frequent Collection

EPA has carefully considered the information collection burden imposed upon the 

regulated community by the proposed rule. EPA is confident that those activities required of 

respondents are necessary, and to the extent possible, the Agency has attempted to minimize the 

burden imposed. EPA believes strongly that, if the minimum information collection 

requirements of the proposed rule are not met, neither the respondents (e.g., exporters) nor EPA 

can ensure that CRTs exported for reuse or recycling are managed in compliance with the 

regulations. In addition, EPA would be unable to provide receiving countries the information that 

they would need to help ensure that CRTs are properly managed.
7

3(e) General Guidelines

This ICR adheres to the guidelines stated in the Paperwork Reduction Act of 1995, OMB’s 

implementing regulations, EPA’s ICR Handbook, and other applicable OMB guidance.

3(f) Confidentiality

Section 3007(b) of RCRA; 40 CFR part 2, subpart B; and 40 CFR 260.2 contain provisions 

for confidentiality. If a business asserts a claim of confidentiality covering any of the information 

collection requirements covered in this ICR, EPA must and will treat the information in 

accordance with the regulations cited above. EPA also will assure that this information collection 

complies with the Privacy Act of 1974 and OMB Circular 108.

3(g) Sensitive Questions

No questions of a sensitive nature are included in any of the information collection 

requirements.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and SIC/NAICS Codes

The following is a list of Standard Industrial Classification (SIC) codes and corresponding 

North American Industry Classification System (NAICS) codes associated with industries most 

likely affected by the information collection requirements included in the existing CRT rule. The 

respondents for the proposed information collection requirements covered in this ICR are 

exporters of CRTs from these industries. The Agency estimates that a total of approximately 12 

entities exported CRTs for recycling during 2011 (i.e., per EPA data on the number of approved 

exporters and the number of export notices that were submitted during 2011). However, far more 

entities are on record as being exporters of CRTs for purposes of reuse. Based on the number of 

CRT Reuse Notifications submitted during 2011, there exists approximately 126 such entities in 

the U.S. (i.e., according to data from Sept. 14th, 2011 published on EPA’s CRT informational 

website at [ http://www.epa.gov/epawaste/hazard/international/crts/recycling.htm ]).

 Industry SIC Code NAICS Code

AGRICULTURE

Agricultural crop production 01 111

Agricultural livestock production 02 112

Agricultural services 07 115, 311, 541, 561, 812

Forestry 08 111, 113, 115

Fishing, hunting, trapping 09 111, 112, 114
8

 Industry SIC Code NAICS Code

MINING

Metal mining 10 212, 213

Coal mining 12 212, 213

Oil & gas extraction 13 211, 213

Non-metallic minerals, except fuels 14 212, 213

CONSTRUCTION

General contractors 15 233-235

Heavy construction 16 233-235

Special trade contractors 17 233-235

MANUFACTURING 

Food & kindred products 20 111, 311, 312

Tobacco products 21 312

Textile mill products 22 313-315

Apparel & other textile products 23 313-315, 336, 339

Lumber & wood products 24 113, 321, 333

Furniture & fixtures 25 336, 337, 339

Paper & allied products 26 322, 326

Printing & publishing 27 323, 511, 512

Chemicals & allied products 28 211, 311, 325, 331

Petroleum and coal products 29 324

Rubber & miscellaneous plastics products 30 316, 325, 326, 337, 339

Leather & leather products 31 315, 316, 321

Stone, clay, and glass products 32 212, 327

Primary metal industries 33 331

Fabricated metal products 34 332, 337, 339

Industrial machinery & equipment 35 331-335, 339

Electronic & other electronic equipment 36 332-336, 512

Transportation equipment 37 332, 333, 336, 488, 541, 811

Instrument & related products 38 322, 325, 333, 334, 339

Miscellaneous manufacturing 39 325, 336, 339, 488

TRANSPORTATION

Local & inter-urban passenger transit 41 485, 487

Trucking & warehousing 42 493, 484, 488, 492, 531

U.S. postal service 43 491

Water transportation 44 483, 487, 488, 532
9

 Industry SIC Code NAICS Code

Transportation by air 45 481, 488, 492, 561, 621

Pipelines, except natural gases 46 486

Transportation services 47 488, 532, 561, 722

Communication 48 513

Electronic, gas, & sanitary services 49 221, 488, 562

WHOLESALE TRADE

Wholesale trade-durable goods 50 421, 441-444, 446, 453

Wholesale trade-nondurable goods 51 312, 313, 422, 444, 451, 454

Bldg. materials & garden supplies 52 444, 453

RETAIL TRADE

General merchandise store 53 452

Food stores 54 311, 445, 447, 722

Auto dealers & service station 55 441, 447, 452

Apparel & accessory stores 56 315, 448

Furniture & home furnishing stores 57 337, 442, 451

Eating & drinking places 58 722

Miscellaneous retail 59 339, 443, 445, 446, 448, 451, 453, 454, 522, 722

FINANCE, INSURANCE, AND REAL ESTATE

Depository institution 60 521, 522

Nondepository institution 61 522, 523

Security & commodity brokers 62 523, 525, 533, 551, 813

Insurance carriers 63 523-525

Insurance agents, brokers, & services 64 523-525

Real estate 65 233, 531, 711, 812

Holding & other investment offices 67 523, 525, 533, 551, 813

SERVICES

Hotels & other lodging places 70 721

Personal services 72 512, 532, 561, 611, 811, 812

Business services 73 234, 313, 314, 323, 325, 334, 421, 443, 491, 511, 512, 

514, 522, 532, 541, 561, 562, 711, 811, 812

Auto repair, services, & parking 75 326, 488, 532, 811, 812

Misc. repair services 76 115, 235, 335, 442, 443, 451, 488, 561, 562, 711, 811

Motion picture 78 334, 421, 512, 514, 532, 541, 561, 711

Amusement & recreation services 79 487, 532, 561, 611, 711, 712, 713

Health services 80 339, 541, 621

Legal services 81 541
10

 Industry SIC Code NAICS Code

Educational services 82 514, 611

Social services 83 623, 624, 813, 922

Museums, botanical, zoological gardens 84 712

Membership organization 86 561, 813, 912

Engineering & management service 87 233, 234, 541, 561, 611

Private household services 88 81

Services 89 512, 541, 711

4(b) Information Requested

(1) Revised Export Notification for Used CRTs Destined for Recycling

Under existing 40 CFR 261.39(a)(5), exporters of used, broken CRTs must provide written 

notification to EPA of an intended export before the CRTs are scheduled to leave the U.S. The 

existing notice (40 CFR 261.39(a)(5)(F)) requires the exporter to state the name and address of the 

recycler and any alternate recycler. Because CRTs are sometimes exported to more than one 

recycler in the receiving country, EPA is proposing to replace this language with a requirement 

that the exporter state the name and address of the recycler or recyclers and the estimated quantity 

of CRTs to be sent to each facility, as well as the names of any alternate recyclers. 

(2) Annual Report for CRTs Exported for Recycling 

Under new 40 CFR 261.39(a)(5)(x), exporters must file with EPA no later than March 1 of 

each year, a report summarizing the quantities (in kilograms), frequency of shipment, and ultimate 

destination(s) of all CRTs exported during the previous calendar year. Such reports must also 

include the following:

 The name, EPA ID number (if applicable), and mailing and site address of the exporter;

 The calendar year covered by the report;

 A certification signed by the exporter which states:

“I certify under penalty of law that I have personally examined and am familiar with the 

information submitted in this and all attached documents, and that based on my inquiry of those 

individuals immediately responsible for obtaining the information, I believe that the submitted 

information is true, accurate, and complete. I am aware that there are significant penalties for 

submitting false information including the possibility of fine and imprisonment.”
11

(3) Revised Export Notification for Used CRTs Destined for Reuse

Under existing 40 CFR 261.41, exporters of used, intact CRTs for reuse must submit a 

one-time notification with minimal information to EPA. To require exporters to submit more 

complete information about the purported reuse of the exported CRTs over a specific period of 

time, EPA is proposing to add items to the reuse notification that are modeled on those required in 

the notification for CRTs exported for recycling. This notification may cover export activities 

extending over a twelve (12) month or lesser period. The notification must be in writing, signed 

by the exporter, and include the following information:

 Name, mailing address, telephone number and EPA ID number (if applicable) of the 

exporter of the CRTs.

 The estimated frequency or rate at which the CRTs are to be exported and the period of 

time over which they are to be exported.

 The estimated total quantity of CRTs specified in kilograms. 

 All points of entry to and departure from each transit country through which the CRTs will 

pass, a description of the approximate length of time the CRTs will remain in such country

and the nature of their handling while there. 

 A description of the means by which each shipment of the CRTs will be transported (e.g., 

mode of transportation vehicle (air, highway, rail, water, etc.), type(s) of container 

(drums, boxes, tanks, etc.)).

 The name and address of the ultimate destination facility or facilities and the estimated 

quantity of CRTs to be sent to each facility, as well as the name of any alternate 

destination facility or facilities.

 A description of the manner in which the CRTs will be reused (including reuse after 

refurbishment) in the foreign country that will be receiving the CRTs.

 A certification signed by the exporter which states: 

“I certify under penalty of law that the CRTs described in this notice are fully functioning or 

capable of being functional after refurbishment. I am aware that there are significant penalties 

for submitting false information including the possibility of fine and imprisonment.

I certify under penalty of law that I have personally examined and am familiar with the 

information submitted in this and all attached documents, and that based on my inquiry of 

those individuals immediately responsible for obtaining the information, I believe that the 

submitted information is true, accurate, and complete. I am aware that there are significant 

penalties for submitting false information including the possibility of fine and imprisonment.”
12

5. THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

The following section discusses how EPA or the implementing agency will collect and 

manage the information received from respondents. This section also includes a discussion of 

how EPA has taken steps to ensure that the information collections are not overly burdensome on 

small entities.

5(a) Agency Activities

(1) Export Notification for Used CRTs Destined for Recycling

 

Per the existing CRT rule, Agency activities associated with the conditional exclusion for 

used CRTs exported for recycling will continue as described below. There will be only minor 

additional information received under the proposed revised export notification for the Agency to 

review and process.

· Receive and review notification submitted by an exporter of used CRTs to 

determine whether or not the notification is complete. A notification is complete 

when EPA determines that it satisfies the requirements of 40 CFR 261.39(a)(5)(i).

· Solicit, from exporter, additional information requested by the receiving country.

· Provide, in conjunction with the Department of State, the complete notification to 

the receiving country.

· Forward the receiving/transit country’s written consent to the receipt of the used 

CRTs to the exporter.

· Prepare and send written notification to the exporter if the receiving/transit country 

objects to the receipt of the used CRTs or withdraws a prior consent. 

· Keep copies of notifications, consents, and other related documents.

(2) Annual Report for CRTs Exported for Recycling

Agency activities associated with the new requirement for submission of an annual report 

for exporters of CRTs sent for recycling include the following:

· Receive and record the report.
13

(3) Export Notification for Used CRTs Destined for Reuse

Per the existing CRT rule, Agency activities associated with the conditional exclusion for 

used CRTs exported for reuse will continue as described below. There will be additional 

information received under the proposed revised export notification, similar to the information 

contained in the notice for CRTs exported for recycling, for the Agency to review and process (see 

Exhibit 3).

· Receive and process notification submitted by exporter of used CRTs.

· Keep copy of notification.

5(b) Collection Methodology and Management

In collecting and analyzing the information submitted under 40 CFR 261.39(a)(5) and 

261.41, EPA will use equipment such as personal computers and applicable database software, 

where appropriate. EPA will ensure the accuracy and completeness of the collected information 

by reviewing each submittal.

5(c) Small Entity Flexibility

In establishing the existing conditional exclusion for used CRTs, EPA considered the 

reporting and recordkeeping burden for small businesses. The conditional exclusion was a 

regulatory relief initiative that reduced hour and cost burden for generators and subsequent 

handlers of excluded CRTs, particularly small entities. These reductions in hour and cost burden 

under the existing exclusion will not be significantly impacted as result of the newly proposed 

information requirements.

5(d) Collection Schedule

(1) Export Notification for Used CRTs Destined for Recycling

Exporters of used CRTs destined for recycling must provide written notification to EPA of 

an intended export before the CRTs are scheduled to leave the U.S. A complete notification must 

be submitted 60 days before the initial shipment is intended to be shipped off site. This 

notification may cover export activities extending over a 12-month or lesser period. In addition, 

upon request by EPA, exporters must furnish to EPA any additional information that a receiving 

country requests in order to respond to a notification.

(2) Annual Report for CRTs Exported for Recycling

Exporters must file with EPA no later than March 1 of each year, a report summarizing the 

quantities (in kilograms), frequency of shipment, and ultimate destination(s) of all CRTs exported 

during the previous calendar year.
14

(3) Export Notification for Used CRTs Destined for Reuse

Exporters of used CRTs destined for reuse must send a notification to EPA. This 

notification may cover export activities extending over a 12-month or lesser period. In addition, 

they must keep, at the facility, copies of normal business records (e.g., contracts) demonstrating 

that each shipment of exported CRTs will be reused. 

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

6(a) Estimating Respondent Burden Hours

In Exhibits 1, 2 and 3, EPA estimates the respondent burden hours associated with the new 

information collection requirements in the proposed rule. Exhibit 1 includes estimates of burden 

hours (total and by labor type) per entity (exporter or respondent) for reading the rule. EPA 

estimates 3.5 hours per respondent for reading the rule and a universe of 138 respondents. This 

would result in a total of 483 hours for all of the respondents reading the rule. For a one-time 

activity like reading the rule, EPA annualizes the burden hours over a three year effective life of 

the ICR. This is done by dividing the number of respondents by three (138/3 = 46) and then 

calculating the total hours (46 x 3.5 = 161 hours). Exhibit 2 includes estimates of burden hours 

(total and by labor type) per respondent for the new annual reporting by exporters of CRTs for 

recycling. EPA estimates 3.4 hours per large exporter and 2.1 hours per small exporter. EPA 

also estimates 12 exporters of CRTs for recycling, and assumes that one-half (6) of the exporters 

are large exporters and one-half (6) are small exporters. This would result in a total of 33 hours 

for the new annual reporting by all 12 exporters. Exhibit 3 includes estimates of burden hours 

(total and by labor type) per notice prepared and submitted by a respondent under the modified 

reuse and recycling notification requirements. EPA estimates 0.15 hour per modified notice and a

total of 233 to 435 reuse and recycling notices submitted by respondents each year. This would 

result in a total of 35 hours to 65 hours for preparation and submission of the modified reuse and 

recycling notices by respondents. Therefore, based on the above burden hour calculations, EPA 

estimates that the total annual respondent burden for the new information collection requirements 

in the proposed rule ranges from 229 to 259 hours.

6(b) Estimating Respondent Costs

EPA estimates that the total annual respondent cost for the new information collection

requirements in the proposed rule to be $17,591 to $19,714. The total annual cost includes the 

cost for reading the rule, cost for new annual reporting by exporters of CRTs for recycling, and the 

cost for preparation and submission of the revised reuse and recycling notices by respondents. 

EPA’s estimates for costs to be incurred by respondents for the new information collection 

requirements in the proposed rule are included in Exhibits 1, 2 and 3.

Labor Costs 

For purposes of this analysis, EPA estimates an average hourly respondent labor cost of 
15

$107.06 for managerial staff, $70.08 for technical staff, and $36.60 for clerical staff. These labor 

rates were originally obtained by relying on prior EPA Cost Assessments and then updated to 2011 

using Employment Cost Indices developed by the U.S. Bureau of Labor Statistics. (See 

“Economic Impacts Assessment for Proposed Revisions to the Export Provisions of the Cathode 

Ray Tube (CRT) Rule,” which is available in the public docket identified under Section 6(g)).

Annual Capital and Operation & Maintenance Costs

Capital costs usually include any produced physical good needed to provide the needed 

information, such as machinery, computers, and other equipment. EPA does not anticipate that 

respondents will incur capital costs in carrying out the information collection requirements in the 

proposed rule.

O&M costs are those costs associated with paperwork requirements incurred continually

over the life of the ICR. They are defined by the EPA as “the recurring dollar amount of costs 

associated with O&M or purchasing services.” Minimal O&M costs were assumed to be 

associated with the preparation and submission of new Annual Reports and Notification 

requirements in the proposed rule. These costs are for mailing, copying, faxing, and for making 

telephone calls.

6(c) Estimating Agency Burden and Costs

In Exhibits 2 and 3, EPA provides estimates of the Agency hour and cost burden 

associated with the new information collection requirements covered in this ICR. EPA estimates 

an average hourly labor cost of $74.67 for managerial staff (GS-14, Step 1), $63.20 for technical 

staff (GS-13, Step 1), and $36.64 for clerical staff (GS-9, Step 1). To derive these hourly 

estimates, EPA referred to the General Schedule (GS) Salary Table 2011. This publication 

summarizes the unloaded (base) hourly rate for various labor categories in the Federal 

Government. EPA then applied the standard government overhead factor of 1.6 to the unloaded 

rate to derive these loaded hourly rates. (See “Economic Impacts Assessment for Proposed 

Revisions to the Export Provisions of the Cathode Ray Tube (CRT) Rule,” which is available in 

the public docket identified under Section 6(g)).

Receive and Record Annual Reports Submitted by Exporters of CRTs for Recycling

EPA estimates that it will receive 12 annual reports per year. EPA estimates that it will incur 

$24.64 to receive and record each annual report (see Exhibit 2). Thus, EPA estimates that the 

Agency will experience an annual cost of $295.68 (i.e., 12 annual reports/year x $24.64/report) to 

meet this requirement of the proposed rule. 

Receive and Process Revised Reuse and Recycling Notifications 

EPA estimates that it will incur an additional cost of $10.51 per notice to receive and process these 

notices (see Exhibit 3). Thus, EPA estimates that the Agency will experience a total incremental
16

annual cost in the range of $2,449 to $4,572 (i.e., 233 to 435 notices per year x $10.51 per notice) 

under the proposed rule. 

6(d) Estimating the Respondent Universe and Total Burden and Costs

The Agency estimates that a total of approximately 12 entities exported CRTs for recycling during 

2011 (i.e., per EPA data on the number of approved exporters and the number of export notices 

that were submitted during 2011). However, far more entities are on record as being exporters of 

CRTs for purposes of reuse. Based on the number of CRT Reuse Notifications submitted during 

2011, there exists approximately 126 such entities in the U.S. (i.e., according to data from Sept. 

14th, 2011 published on EPA’s CRT informational website at 

[ http://www.epa.gov/epawaste/hazard/international/crts/recycling.htm ]). Therefore, as shown 

below in Table 1, EPA estimates that 138 entities will be subject to the new information collection 

requirements covered in this ICR.

TABLE 1

NUMBER OF EXPORTER ENTITIES (RESPONDENTS)

POTENTIALLY AFFECTED BY THE PROPOSED RULE

Type of Entity Number of Entities

Exporter of CRTs for Recycling 12

Exporter of CRTs for Reuse 126

Total 138

Respondent Burden and Cost

In the following paragraphs, EPA discusses the assumptions used in developing the 

respondent burden estimates associated with the new information collection requirements covered 

in Exhibits 1, 2, and 3 of this ICR. 

Reading the Regulations

EPA estimates that 138 U.S. exporters will need to read the rule in order to understand and comply 

with the new requirements. For purposes of this analysis, we assumed that the hours required for 

reading/reviewing this new rule would be similar to the hours used in EPA’s assessment of the 

impacts associated with reading/reviewing the 2009 Final Rule governing the Exporting of Spent 

Lead-Acid Batteries (SLAB). In Exhibit 1, EPA estimates 3.5 hours per respondent for reading 
17

the rule for the 138 respondents. This would result in a total of 483 hours for all of the 

respondents reading the rule. As noted in Section 6(a), for a one-time activity like reading the 

rule, EPA annualizes the burden hours over a three year effective life of the ICR. This is done by 

dividing the number of respondents by three (138/3 = 46) and then calculating the total hours (46 x 

3.5 = 161 hours).

New Annual Reporting by Exporters of CRTs for Recycling

As noted above in Section 6(d), EPA estimated that approximately 12 U.S. exporters of CRTs sent 

for recycling will be required to prepare and submit an annual report in accordance with this 

provision of the proposed rule. Furthermore, this new annual report for these exporters has been 

fashioned after other existing annual reporting requirements recently codified in the 2009 Final 

Rule governing the Exporting of Spent Lead-Acid Batteries (SLAB) from the U.S. Therefore, 

EPA used the cost estimates for annual reporting already available in the May 2009 Cost 

Assessment prepared for the “SLAB Rule”, as the best and most recent relevant reference (see 

Footnote 1 in “Economic Impacts Assessment for Proposed Revisions to the Export Provisions of 

the Cathode Ray Tube (CRT) Rule,” which is available in the public docket identified under 

Section 6(g)). Based on these figures, EPA estimates that the cost for a CRT exporter to prepare 

and submit an annual report ranges from $156.07 to $203.36, depending upon whether the size of 

the exporter is large vs. small. For purposes of analysis, EPA assumed a 50/50 distribution of 

these exporters (e.g. with half considered large and half considered small). Thus, EPA estimated 

that the total cost of the annual reporting requirement for exporting CRTs for recycling is 

$2,158.32 (i.e., $203.36/annual report x 6 Large Recycling Exporters, plus $156.07/annual report 

x 6 Small Recycling Exporters). (See Exhibit 2). 

Revisions to Reuse and Recycling Notifications (Asking for additional Information)

Under the current CRT Rule, exporters already must submit notifications to EPA indicating their 

intent to export CRTs. The proposed CRT Rule revisions call for very minor additional reporting 

elements to the current CRT rule requirements. To calculate the notification-related cost impacts, 

EPA started by relying on the original burden hour estimates associated with the current 

notification requirements. EPA then adjusted these burden hour estimates to reflect our best 

estimate of the potential burden associated with the proposed changes in the notification 

requirements. Our best estimate is that these burden estimates would not exceed 10% of the 

burden attributable to the current notification requirements. Then EPA utilized the adjusted 

burden estimates and labor rates in combination with the projected quantity of CRT Notices to 

derive costs associated with the relevant proposed changes to the CRT notification process. 

Based on the calculations above, EPA estimated that CRT exporters will submit between 233 and 

435 notices each year. We estimated that each notice will cost an additional $10.26 (see Exhibit 

3). In total, EPA estimates that the additional costs to exporters will be in the range of $2,386 to 

$4,453 (i.e., 233 to 435 notices per year x $10.26 per notice) under the proposed rule. 
18

Total Respondent Burden and Cost

In Exhibits 1, 2, and 3, EPA presents a summary of the total annual respondent burden and 

costs associated with the new information collection requirements in the proposed rule. The 

specific information collection activities of the new paperwork requirements are described 

throughout this ICR.

6(e) Bottom Line Burden Hours and Costs

Respondent Tally

In Exhibits 1, 2 and 3, EPA presents the total annual respondent burdens and costs

associated with the new information collection requirements in the proposed rule. As described 

specifically in Section 6(d) above, there are 138 respondents (12 U.S. exporters of CRTs sent for 

recycling and 126 U.S. exporters of CRTs sent for reuse) that will be subject to the new 

information collection requirements covered in this ICR. Based on the information in Exhibits 1,

2, and 3, the total annual respondent burden for the new paperwork requirements will range from 

229 to 259 hours, and the total annual respondent cost for the new paperwork requirements will be

approximately $17,600 to $19,700

6(f) Reasons for Change in Burden 

EPA is proposing to revise certain export provisions of the CRT final rule published on 

July 28, 2006 (71 FR 42928) to ensure that CRTs are managed in compliance with the regulations.

These revisions will require exporters of CRTs to provide some additional information to EPA

(see Section 6(d)).

6(g) Burden Statement

The estimated annual burden for this collection of information ranges from 0.15 to 3.5 

hours per response for the 138 respondents. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information to 

or for a Federal agency. This includes the time needed to review instructions; develop, acquire, 

install, and utilize technology and systems for the purposes of collecting, validating, and verifying 

information, processing and maintaining information, and disclosing and providing information; 

adjust the existing ways to comply with any previously applicable instructions and requirements; 

train personnel to be able to respond to a collection of information; search data sources; complete 

and review the collection of information; and transmit or otherwise disclose the information. An 

agency may not conduct or sponsor, and a person is not required to respond to, a collection of 

information unless it displays a currently valid OMB control number. The OMB control numbers 

for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the use 

of automated collection techniques, EPA has established a public docket for this ICR under Docket 
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ID Number EPA-HQ-RCRA-2011-1014, which is available for online viewing at 

www.regulations.gov, or in person viewing at the RCRA Docket in the EPA Docket Center 

(EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The 

EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through 

Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 

566-1744, and the telephone number for the RCRA Docket is (202) 566-0270. An electronic 

version of the public docket is available at www.regulations.gov. This site can be used to submit 

or view public comments, access the index listing of the contents of the public docket, and to 

access those documents in the public docket that are available electronically. When in the 

system, select “search,” then key in the Docket ID Number identified above. Also, you can send 

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 

include the EPA Docket ID Number EPA-HQ-RCRA-2011-1014 and OMB Control Number 

2050-NEW in any correspondence.
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Exhibit 1

Estimated Respondent Burden and Cost for Reading the Rule

Cost per Entity Cost of All Entities

Activity Managerial 

Staff Hours a

Technical Staff 

Hours a

Clerical Staff 

Hours a

Hours Labor 

Cost b

Materials 

Cost c

Total Cost 

per Entity

Number of 

Entities d

Total Cost 

Reading the Regulations 

U.S. Exporters 1.00 2.50 0.00 3.50 $282.26 $0.00 $282.26 138 $38,952

NOTES:

a

 Based on hourly burden estimates discussed in Section 3.3 of EIA (*). 

b

 Based on hourly labor rates discussed in Section 3.2 of EIA.

c

 Based on materials costs discussed in Section 3.4 of EIA.

d

 Based on universe assumptions discussed in Section 3.1 of EIA.

(*) “Economic Impacts Assessment for Proposed Revisions to the Export Provisions of the 

Cathode Ray Tube (CRT) Rule.”
21

Exhibit 2

Costs for New Annual Reporting by Exporters of CRTs for Recycling

Cost per Entity Cost for all Entities

Activity Managerial 

Staff Hours a

Technical Staff 

Hours a

Clerical Staff 

Hours a

Total 

Hours 

Total Labor 

Cost b

Material 

Cost c

Total 

Cost

Number of 

Entities d

Total Cost 

Annual Report

Large U.S. Exporters

Research specific export 

information

0.00 1.00 1.00 2.00 $106.68 $0.00 $106.68 6 $640.08

Prepare and submit report 0.10 1.00 0.30 1.40 $91.77 $5.20 $96.97 6 $581.82

Subtotal: $198.45 $5.20 $203.65 6 $1,221.90

Small U.S. Exporters

Research specific export 

information

0.00 0.50 0.50 1.00 $70.08 $0.00 $70.08 6 $420.48

Prepare and submit report 0.10 0.50 0.50 1.10 $80.79 $5.20 $85.99 6 $515.94

Subtotal: $150.87 $5.20 $156.07 6 $936.42

Total for Exporters: $2,158.32

EPA

Receive and record report 0.00 0.10 0.50 0.60 $24.64 $0.00 $24.64 12 $295.68

Total for EPA: 0.00 0.10 0.50 0.60 $24.64 $0.00 $24.64 12 $295.68

TOTAL:

(for both Exporters & 

EPA)

$2,454

NOTES:

a

 Based on hourly burden estimates discussed in Section 3.3 of EIA (*). 

b

 Based on hourly labor rates discussed in Section 3.2 of EIA.

c

 Based on material costs discussed in Section 3.4 of EIA.

d

 Based on universe assumptions discussed in Section 3.1 of EIA, which reveal a total of approximately 12 CRT Recycling Exporters in the U.S. And, we 

assume there is a 50/50 Percent Ratio regarding the total number of Large vs. Small U.S. CRT Exporters, such that there are 6 of each type in the above calculations.

(*) See Exhibit 1.
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Exhibit 3

Costs for Meeting Proposed Reuse & Recycling Notification Changes

(Asking for minor additional information)

Cost per Notice Cost of All Notices

Activity Manager 

Staff 

Hours a

Technical 

Staff 

Hours a

Clerical 

Staff 

Hours a

Total Hours b

(10% of Orig. 

Hours)

Total 

Labor 

Cost c

Total 

Material 

Costs d

Total 

Cost per 

Notice

Number 

of 

Entities e

Estimated 

Number of 

Notices f

Total Cost 

U.S. Exporters

Prepare& submit notification Subtotal for Exporters: 0.00 1.50 0.00 0.15 $10.51 $0.00 $10.51 138 233 to 

435

$2,449 to $4,572

EPA

Receive and process notification 0.00 1.00 0.00 0.10 $6.32 $0.00 $6.32 138 233 to 

435

$1,473 to $2,749

Prepare and transmit confirmation of receipt to U.S. 

exporter

0.00 0.00 0.25 0.025 $0.92 $0.00 $0.92 138 233 to 

435

$213 to $398

Forward notification to the competent authorities of the 

countries of import and transit 

0.00 0.00 0.16 0.016 $0.59 $0.00 $0.59 138 233 to 

435

$137 to $255

Receive and process Acknowledgement of Receipt 

from the competent authority of the country of import

0.00 0.00 0.25 0.025 $0.92 $0.00 $0.92 138 233 to 

435

$213 to $398

Receive and process consent/objection from the 

competent authorities of the countries of import and 

transit 

0.00 0.00 0.16 0.016 $0.59 $0.00 $0.59 138 233 to 

435

$137 to $255

Forward written Acknowledgement of Consent or 

objection to U.S. exporter 

0.00 0.00 0.25 0.025 $0.92 $0.00 $0.92 138 233 to 

435

$213 to $398

Subtotal for EPA: 0.00 1.00 1.07 0.207 $10.26 $0.00 $10.26 138 233 to 

435

$2,386 to $4,453

Total for both Exporters & EPA 0.00 2.50 1.07 0.357 $20.77 $0.00 $20.77 138 233 to 

435

$4,835 to $9,025

Notes:

a

 Staff level hourly burden estimates are discussed in Section 3.3 of EIA (*).

b

 Total final hourly burden estimates are conservatively assumed to only involve an additional burden equal to 10% of the overall burden from 

the notification requirements under the current CRT Rule. 

c

 Based on hourly labor rates discussed in Section 3.2 of EIA.

d Since entities are already required to submit Recycling and Reuse Notices, the effected entities face no additional costs associated with mailings, 

copies, facsimiles, etc. due to the newly proposed modifications to the existing notices.

e

 The projections for the total number of entities potentially impacted by the rule are discussed in Section 3.1 of EIA.

f

 The projections for the total number of notifications that may be submitted annually is discussed in Section 3.5 of EIA.

(*) See Exhibit 1.
23