Type of Entity

No. of 

Establishments 

(FRIA) % SBA Small

 Fish Primary Processors 18 78%

 Fish Secondary Processors 10 100%

 Fish Producers/hatcheries 624 100%

 Fish Feed Mills 14 86%

 Fish Live Loaders, Haulers, Wholesalers 11 100%

 Fish Importers, Brokers 165 100%

Total 842

Sources: 2003 NASS, USDC, FDA, DNB, Census of Agriculture, Economic Census, DHS/CBP

FSIS updated Table 3 of the Appendix A - Executive Order 12866 -

Preliminary Regulatory Impact Analysis (February 24, 2011).

Available here:

http://www.fsis.usda.gov/wps/wcm/connect/1ff464d1-ae27-4d78-831db21ccce26ec5/Catfish_Impact_Analysis.pdf?MOD=AJPERES 

The table is replicated as Table 5 in the Regulatory Flexibility Act 

Assessment of the Final Regulatory Impact Analysis (FRIA)
7% 3%

0.94 0.97

0.87 0.94

0.82 0.92

0.76 0.89

0.71 0.86

0.67 0.84

0.62 0.81

0.58 0.79

0.54 0.77

0.51 0.74

OMB mid-year discount factor
Wage/Hour Data used in FRIA

Category Wage/Hour Benefits Total OCC

Hours per 

Year

Annual 

Salary

QC Manager $ 25.87 0.33 $ 34.41 11-3051 2,087 71,813.67

Supervisors/QC Tech $ 19.01 0.33 $ 25.28 51-1011 - -

Production Workers $ 13.54 0.33 $ 18.00 51-9000 - -
Additional Costs Associated with the Development of a Sanitation SOP

Step One - Sanitation SOPs - Plan Development

No. of Processes

No. of 

Establishments Time (Hours) /1 One Time Cost

1 - Typical 4 8 $1,101

2 - Complex 10 8 $2,753

2 - Not Complex 9 4 $1,239

Place 5 - -

Total 28 $5,093

Step Two - Sanitation SOPs recordkeeping and record storage

Recordkeeping

No. of 

Establishments

Record-keeping 

Time 

(Hours/Day) /1

Review Time 

(Hours/Day) /2

Recurring 

Cost /3

One Shift 8 0.25 0.17 $18,299

Two Shifts 4 0.5 0.34 $18,299

Not Affected 16 - - -

$36,598

Record storage

No. of 

Establishments 

Affected

Additional 

Storage Space 

(square feet)

Annual 

Additional 

Storage Cost /4

Recurring 

Costs 

One Shift 8 6 $58 $462

Two Shifts 4 7 $67 $270

Not Affected 16 - - -

$732

$37,330

Step Three - Sanitation SOPs training

Personnel No. of Establishments No. of Shifts Time (Hours)

Recurring Cost 

per Training 

/1 QC Manager Wage Rate

/1 Production Worker Wage Rate

/2 QC Tech Wage Rate

/3 Operating Days Per Year - 260

/4 Recordkeeping storage costs were based on a national survey of storage costs showing an average annual cost of 

$8.40 per square foot in 1994, which was updated to $9.63 per square foot. 

Verification:

Total 

Total 

Total Recordkeeping and Record Storage Recurring Costs

For further discussion see Table 6 of the Appendix A -

Executive Order 12866 - Preliminary Regulatory 

Impact Analysis (February 24, 2011).

For further discussion see Table 7 of the Appendix A -

Executive Order 12866 - Preliminary Regulatory Impact 

Analysis (February 24, 2011).

For further discussion see Table 8 of the Appendix A -
17 1 2 $860

6 2 2 $607

 Sub-Total 23 $1,466

17 1 2 $612

6 2 2 $432

 Sub-Total 23 $1,044

$2,510

One Time Recurring

Additional Sanitation 3 0.17 $796 $2,387

Additional Water 3 - $160 $480

Additional Cleaning 

Equipment 23 - $130 $2,990

$2,990 $2,867

One-time Recurring

Plan 

Development, 

Validation and 

Reassessment $5,093

Recordkeeping 

and Record 

Storage $37,330

Training 

(years 1, 4, 7 & 

10) $2,510

Additional 

Ongoing 

Implementation $2,990 $2,867

Total $8,083 $42,707

7 Percent 3 Percent

1 $5,093 $37,330 $2,510 $5,857 $50,790 $47,467 $49,310 0.935 0.971

2 - $37,330 $2,867 $40,197 $35,109 $37,889 0.873 0.943

3 - $37,330 $2,867 $40,197 $32,812 $36,786 0.816 0.915

4 - $37,330 $2,510 $2,867 $42,707 $32,581 $37,945 0.763 0.888

5 - $37,330 $2,867 $40,197 $28,660 $34,674 0.713 0.863

6 - $37,330 $2,867 $40,197 $26,785 $33,664 0.666 0.837

7 - $37,330 $2,510 $2,867 $42,707 $26,596 $34,725 0.623 0.813

8 - $37,330 $2,867 $40,197 $23,395 $31,732 0.582 0.789

Costs

Measure

Step Five - Total Costs for Sanitation SOPs 

Total

/1 Training Period occurs every 4 years

Cost Per Cost 

Type No. of Establishments Time (Hours) Establishment

O d

year 

discount 

O d yea 

discount 

factor 7%

Total

Recordkeeping:

Step Four - Sanitation SOPs ongoing additional domestic 

QC Tech

Production Worker

Annualization Table 

Costs

Net PV of Cost

Year

Plan 

Development

Recordkeeping 

and Storage Training

Additional 

Ongoing Total Direct 

For further discussion see Table 8 of the Appendix A 

Executive Order 12866 - Preliminary Regulatory Impact 

For further discussion see Sanitation SOPs 

Ongoing Additional Implementation Costs 

section of the Appendix A - Executive Order 
9

- $37,330 $2,867 $40,197 $21,864 $30,807 0.544 0.766

10- $37,330 $2,510 $2,867 $42,707 $21,710 $31,778 0.508 0.744

$296,979 $359,310

$42,283 $42,122

10-year Present Value

Annualized Total 
Recordkeeping

No. of 

Establishments 

Affected

Record-keeping 

Time 

(Hours/Day) /1

Review Time 

(Hours/Day) /2 Recurring Cost /3

One Shift 8 0.25 0.17 $18,299

Two Shifts 4 0.5 0.34 $18,299

Not Affected 16 - - -

$36,598

Record storage

No. of 

Establishments 

Affected

Additional 

Storage Space 

(square feet)

Annual Additional 

Storage Cost /4 Recurring Costs 

One Shift 8 6 $58 $462

Two Shifts 4 7 $67 $270

Not Affected 16 - - -

$732

$37,330

/3 Operating Days Per Year - 260

/4 Recordkeeping storage costs were based on a national survey of storage costs showing an average annual cost of $8.40 per 

square foot in 1994, which was updated to $9.63 per square foot. Annual storage costs for sanitation SOP records were assumed to 

be $60 per establishment. 

Step Two - Sanitation SOPs recordkeeping and record storage

Total Recordkeeping and Record Storage Recurring Costs

Total 

Total 

/1 Production Worker Wage Rate

/2 QC Tech Wage Rate
Additional costs associated with the development of a HACCP Plan

Step One - Development of a HACCP Plan

Firms

No. of 

Establishment

s Per Process

Reassessment 

per process One Time Recurring 

One Process 4 $8,000 $70 $32,000 $280

Two Process 11 $6,000 $70 $132,000 $1,540

$164,000 $1,820

Step Two - Projected additional domestic cost of HACCP training

 Establishment/ Type of E

No. of 

Establishment

s 

No. of 

Additional 

Employees per 

establishment

No. of 

Additional 

Employees

Recurring Cost 

per training 

period /1

One shift:

 QC Manager 2 8 16 $ 22,022.40

 QC Technician 3 5.3 16 $ 16,179.20

Two shifts:

 QC Manager 3 5.3 4 $ 5,505.60

 QC Technician 3 5.3 4 $ 4,044.80

Total 11 $ 47,752.00

/1 Total Training Hours = 40

Step Three - HACCP additional personnel additional domestic cost

Shift / Process

No. of 

Establishment

s HACCP Employees 

Percent of 

time

Recurring Cost 

per 

Establishment 

/1

One shift:

One Process 2 2 5%

$7,181

Two Processes 3 12 10%

$21,544

Two shifts:

One process 3 6 5%

$10,772

Two processes 3 6 10%

$21,544

$61,042

/1 QC Manager wage rate used.

Step Four - HACCP additional domestic costs for recordkeeping and monitoring (certification)

Shift / Task /Process

No. of 

Establishment

s

HACCP 

Processes in 

Plans CCPs per Plan

Time Per 

CCP 

(Minutes) Recurring Cost 

One Shift:

Recordkeeping /1:

 1 process 4 1 5 3 $4,680

 2 processes 11 2 5 3 $25,740

Monitoring /2:

 1 process 4 1 5 1 $2,191

 2 processes 11 2 5 1 $12,050

Two shifts:

Recordkeeping:

 1 process 1 1 5 3 $1,170

 2 processes 2 2 5 3 $4,680

Monitoring:

 1 process 1 1 5 1 $548

 2 processes 2 2 5 1 $2,191

$53,250

/1 Production Worker Wage Rate

/2 QC Tech Wage Rate

Step Five - Additional Storage Costs

Type

No. of 

Establishment

s 

Additional 

square feet per 

establishment

Additional 

Annual Cost 

per 

establishment

Recurring Total 

Record Storage 

Costs /1

Additional Record 

Storage 18 6.23 $60 $1,080

/1 Recordkeeping storage costs were based on a national survey of storage costs showing an average annual cost of $8.40 per square foot in 1994, which was updated to $9.63 per square foot. Annual storage costs for sanitation SOP records were assumed to be $60 per establishment. 

Step Six. HACCP additional domestic costs for Other - Process Control Laboratory Testing

Type

No. of 

Establishment

s One Time Cost 

Recurring Cost 

/1

Primary establishments 7 $ 7,350.00 $ 6,125.00 

Secondary 

Establishments 5 $ 5,250.00 $ 4,375.00 

Total 12 $ 12,600.00 $ 10,500.00 

Number of Samples in Baseline - 30

Testing Cost Per Sample - $35

Additional Ongoing Samples - 25

Step Seven - Total Costs for HACCP

Measure

First year / 

One-time Cost Recurring Cost 

Plan development, valid $ 164,000.00 $ 1,820.00

Training (years 1 & 6) $ 47,752.00

Cost

Total

For further discussion see HACCP Plan Development, Validation, and 

Reassessment Additional Costs section and Table 10 of the Appendix A -

For further discussion see HACCP Training Additional Costs section and Table 

11 of the Appendix A - Executive Order 12866 - Preliminary Regulatory 

Impact Analysis (February 24, 2011).

For further discussion see HACCP Personnel Additional Costs section and Table 12 of the 

Appendix A - Executive Order 12866 - Preliminary Regulatory Impact Analysis (February

24, 2011).

For further discussion see HACCP Recordkeeping and Record Storage Additional 

Costs section and Table 13 of the Appendix A - Executive Order 12866 -

Preliminary Regulatory Impact Analysis (February 24, 2011).

For further discussion see HACCP Recordkeeping and Record Storage Additional 

Costs section of the Appendix A - Executive Order 12866 - Preliminary 

Regulatory Impact Analysis (February 24, 2011).
Additional Personnel – H $ 61,041.62 $ 61,041.62

Recordkeeping and certi $ 53,249.73 $ 53,249.73

Record Storage $ 1,079.91 $ 1,079.91

Other Costs $ 12,600.00 $ 10,500.00

$ 339,723.26 $ 127,691.26

Year

Plan 

Development, 

Validation, 

Reassessment Training Personnel

 Recordkeeping 

and 

Certification

Record 

Storage Other Ongoing

Total 

Direct 7 percent 3 percent

OMB 

midyear 

discou

nt 

factor 

7%

OMB 

midyear 

discou

nt 

factor 

3%

1 $164,000 $47,752 $61,042 $53,250 $1,080 $12,600 $339,723 $317,498 $329,828 0.935 0.971

2 $1,820 $0 $61,042 $53,250 $1,080 $10,500 $127,691 $111,530 $120,361 0.873 0.943

3 $1,820 $0 $61,042 $53,250 $1,080 $10,500 $127,691 $104,234 $116,856 0.816 0.915

4 $1,820 $0 $61,042 $53,250 $1,080 $10,500 $127,691 $97,415 $113,452 0.763 0.888

5 $1,820 $0 $61,042 $53,250 $1,080 $10,500 $127,691 $91,042 $110,148 0.713 0.863

6 $1,820 $47,752 $61,042 $53,250 $1,080 $10,500 $175,443 $116,905 $146,931 0.666 0.837

7 $1,820 $0 $61,042 $53,250 $1,080 $10,500 $127,691 $79,520 $103,825 0.623 0.813

8 $1,820 $0 $61,042 $53,250 $1,080 $10,500 $127,691 $74,317 $100,801 0.582 0.789

9 $1,820 $0 $61,042 $53,250 $1,080 $10,500 $127,691 $69,456 $97,865 0.544 0.766

10 $1,820 $0 $61,042 $53,250 $1,080 $10,500 $127,691 $64,912 $95,014 0.508 0.744

$1,126,830 #########

Annualized Total $160,435 $156,512

10-year Present Value

Additional Cost Net PV of Cost

Annualization Table of additional costs associated with the development of a HACCP plan
Additional costs associated with the New Labels

Type of Product

Type of label Pre-printed Sticker Pre-printed Sticker

No. of Establishments 33 33 33 33

Average No. of 

Additional Labels per 

Establishment 3 3 4 4

Average No. of 

Additional Labels 

Setups/ Plates 99 99 132 132

One-Time Average Cost 

per Label Setup $310 $260 $310 $260

Average No. of Additional 

Recurring Labels per 

Establishment 7,000 4,600 7,000 4,600

Average No. of Additional 

Recurring Labels 231,000 151,800 231,000 151,800

Recurring Average Costs 

per Label $0.03 $0.03 $0.005 $0.005

$131,670

$13,398

$30,918

Annualized Total Costs (3 percent over 10 years) $28,384.16

Fresh Frozen

Total One-Time Average Costs for Label Setup 

Total Additional Recuring Costs

Annualized Total Costs (7 percent over 10 years)

For further discussion see New Labels: Additional Domestic Costs 

section and Table 15 of the Appendix A - Executive Order 12866 -

Preliminary Regulatory Impact Analysis (February 24, 2011).
One Time Costs

Per 

Establishment Total

Additional Space2 $900 $13,500

Furnishing $200 $3,000

Reaccuring Costs

Annual Heating and Cooling $480 $7,200

$16,500

$7,200

$9,396

$9,078

Additional domestic cost of new government office space1 

Annualized total Costs (7 percent over 10 years)

Annualized total Costs (3 percent over 10 years)

1- From the PRIA: The proposal requires provision of Government office space 

and some equipment in each of the approximately 23 catfish and catfish 

products processing establishments, and in each of the approximetly 10 catfish 

and catfish products furhter processing establishments. FSIS assumes that it 

would occupy the existing 18 NMFS offices of the 23 establishments, leaving 15 

plants that will incure additional costs.

2- From the PRIA: FSIS assuems that it would need a 150 square feet of securable 

office and projects that this space would costs $6 per square foot. 

Total One-Time Average Costs 

Total Additional Recuring Costs 
Additional Annual Costs Per Establishment No. of Establishments Total

Recordkeeping 

(2 hours x $34.41 per hour) $69 624 $42,944

Additional Storage Space 

(3 square feet X $9.63 per square foot) $29 624 $18,027

$60,971

$60,971

$60,971

Table A-15B. Additional domestic cost of pre-harvest actions

Total Recurring Costs

Annualized total Costs (7 percent over 10 years)

Annualized total Costs (3 percent over 10 years)
Additional Annual 

Costs

Per 

Establishment Total

Recordkeeping2 $69 $757

Additional Storage 

Space3 $29 $318

$1,075

Old Trucks4 $10,800 $54,000

New New5 $5,400 $32,400

Total Additional 

Equipment Costs $86,400

Old Trucks4 $2,160 $10,800

New Trucks5 $1,080 $6,480

$17,280

$86,400

$18,355

$29,851.46

$28,188.51

 

harvest actions - for live-fish 

loaders/haulers/wholesalers1

Records

Fleet

Total One-Time Costs

Total Additional Recuring Costs

2- 2 hours x $34.41 per hour

3- 3 square feet X $9.63 per square foot

4- 5 establishments will upgrade 6 old trucks each at 

a cost of $1,800 per truck and with $360 in opperating 

costs.

5- 6 establishments will upgrade 6 trucks each at a 

cost of $900 per truck and with $180 in opperating 

costs.

Total Recordkeeping Costs

Total Opperating Costs

Annualized Total Costs (3 percent over 

1- From the PRIA - FSIS assumes 11 firms that conduct 

pre-harvest actions would incure additional costs.

Annualized Total Costs (7 percent over 
Additional Annual Costs

No.of 

Establishments

Cost Per 

Establishment Cost

Re-inspection Recordkeeping1 165 $138 $22,711

Additional Storage Space2 165 $29 $4,767

$27,477

Additional Storage Space3 165 $54 $8,910

$8,910

$28,663

$28,492

Table A-15D. Importers re-inspection costs

Records

Sub-Total Recurring Records Costs

2- 3 square feet X $ 9.63 per square foot

3- 9 square feet X $6.00 per square foot

Re-inspection Space

Sub-Total One Time Re-inspection Costs

Annualized Total Costs (7 percent over 10 years)

Annualized Total Costs (3 percent over 10 years)

1- 4 hours x $34.41 per hour
Per Establishment Total

Pounds of Product Currently Subject to USDC 

inspection (pound per establishment) 218,000 3,270,000

Cost Per Pound for FDA USDC Inspection $0.01 $35,970

$35,970

$35,970

$35,970

Annualized Total Costs (7 percent over 10 years)

Annualized Total Costs (3 percent over 10 years)

1- FSIS assumes 15 plants are currently inspected by FDA USDC

Table A-15E. Reduced payment fees for inspection and certifications - Additional reduced 

domestic costa for domestic industry1

Annual Cost Savings From Reduced Fees
7 percent 3 percent year year 

1 $1,494,990 $125,100 $1,800 $11,232 $3,600 $36,000 $1,258,300 $65,000 $2,996,023 $2,800,021 $2,908,760 0.935 0.971

2 $1,816,929 $277,605 $2,100 $14,904 $4,200 $10,000 $558,000 $65,000 $2,748,740 $2,400,856 $2,590,951 0.873 0.943

3 $1,816,929 $232,500 $2,100 $14,904 $4,200 $0 $640,500 $65,000 $2,776,136 $2,266,154 $2,540,558 0.816 0.915

4 $1,816,929 $382,500 $2,100 $14,904 $4,200 $36,000 $156,600 $65,000 $2,478,237 $1,890,635 $2,201,882 0.763 0.888

5 $1,816,929 $382,500 $2,100 $14,904 $4,200 $10,000 $156,600 $65,000 $2,452,238 $1,748,412 $2,115,322 0.713 0.863

6 $1,816,929 $382,500 $2,100 $14,904 $4,200 $0 $156,600 $65,000 $2,442,239 $1,627,367 $2,045,337 0.666 0.837

7 $1,816,929 $382,500 $2,100 $14,904 $4,200 $36,000 $156,600 $65,000 $2,478,240 $1,543,323 $2,015,036 0.623 0.813

8 $1,816,929 $382,500 $2,100 $14,904 $4,200 $10,000 $156,600 $65,000 $2,452,241 $1,427,227 $1,935,822 0.582 0.789

9 $1,816,929 $382,500 $2,100 $14,904 $4,200 $0 $156,600 $65,000 $2,442,242 $1,328,418 $1,871,775 0.544 0.766

10 $1,816,929 $382,500 $2,100 $14,904 $4,200 $36,000 $156,600 $65,000 $2,478,243 $1,259,813 $1,844,046 0.508 0.744

$25,744,580

$18,292,227

$22,069,488

$2,604,402

$2,587,217

Average annual costs $2,574,458

Net PV

Year S&B Travel

Costs

Transport Comms Supplies Equipment Training Testing Annual Total

Annualized Total 3 Percent

Annualized Total 7 Percent

10-year Present Value 3 percent

Table A-16 and A-17 - Exhibit A-A. Summary Table of FSIS and other Agencies Schedule of Costs

Total Annual Costs

10-year Present Value 7 percent
Entity

Cost Savings 

(Annual) 

Annualized Cost 

Savings (.07) 

Annualized Cost 

Savings (.03) 

FDA $150,000 $150,000 $150,000

USDC $1,340,000 $1,340,000 $1,340,000

Total $1,490,000 $1,490,000 $1,490,000

Reduced Costs to Government (FDA and USDC)
7 percent 3 percent

Sanitation SOPs $8,083 $42,707 $42,283 $42,122

HACCP Plans - Validation $339,723 $127,691 $160,435 $156,512

Pre-Harvest Actions - for Producers $0 $60,971 $60,971 $60,971

Pre-Harvest Actions - for Haulers $86,400 $18,355 $29,851 $28,189

Labels $131,670 $13,398 $30,918 $28,384

Government Office Space and Equipment $16,500 $7,200 $9,396 $9,078

Re-inspection at Import Establishments $8,910 $27,477 $28,663 $28,492

Other - Reduced Payments $0 ($35,970) ($35,970) ($35,970)

Sub-Total Industries Costs $591,286 $261,829 $326,548 $317,777

Additional Costs to FSIS Inspection $2,574,458 $2,604,402 $2,587,217

Reduced Costs to FDA $150,000 ($150,000) ($150,000)

Reduced Costs to Commerce Dept NOAA NMFS ($1,340,000) ($1,340,000) ($1,340,000)

Sub-Total Agency Additional Costs $0 $1,384,458 $1,114,402 $1,097,217

$1,440,949 $1,414,995

Agency Costs:

Total Net Costs

Annualized Total Costs 

(Savings)

Costs Summary

Industry Costs

One-Time

Recurring 

New Measure (Savings)
7 percent 3 percent

Siluriformes Fish Industry $ 326.55 $ 317.78 

Federal Government Agencies $ 1,114.40 $ 1,097.22

Total $ 1,440.95 $ 1,414.99

Pounds Produced 388000000 388000000

Pounds Produced (thousands) 388000 388000

cost/pound (Industry) $ 0.0008 $ 0.0008

Breakeven Analysis

Salmonella COI $ 2,423.00 $ 2,423.00

Salmonella COI (thousands) $ 2.42 $ 2.42

Illnesses Avereted 595 584

7 percent 3 percent 7 percent 3 percent

Siluriformes Fish Industry $ 326.55 $ 317.78 135 131

Federal Government Agencies $ 1,114.40 $ 1,097.22 460 453

Total $ 1,440.95 $ 1,414.99 595 584

Table 1. Projected Summary Additional Annualized Average Net Direct Costs (Domestic) of the Final Rule 

Table 4. Projected Summary Additional Annualized Average Net Direct Costs and Break-Even Assessment

Affected Sectors of the domestic 

economy

Additional annualized cost, over 10 years, 

Affected Sectors of the domestic 

economy

Additional annualized cost, over 10 years, 

discounted $thousands

 Assessment of Salmonellosis Illnesses Reduced 

Needed to Break Even on Annualized Costs,