0091 SS UDOC Amendment

SUPPORTING STATEMENT
U.S. DEPARTMENT OF COMMERCE
BUREAU OF INDUSTRY & SECURITY
AMENDMENT TO:
CHEMICAL WEAPONS CONVENTION (CWC) REGULATIONS AND
HANDBOOK AND FORMS
OMB NUMBER 0694-0091

On July 12, 2006, the Office of Management and Budget (OMB) approved the renewal of the
information collection package for implementing the Chemical Weapons Convention (CWC)
program. The CWC paperwork package supports collection of information required under the
CWC Regulations (CWCR) (15 CFR 710-722) and the CWC Handbook and Forms for Schedule
1, 2 and 3 chemicals and unscheduled discrete organic chemicals (UDOCs).
This revision to the existing collection involves two changes: 1) the addition of a new
declaration requirement and associated form that will have minimal impact on the scope of the
collection for certain inspectable UDOC plant sites; and 2) clarification of records review
requirements for inspections and recordkeeping requirements of the CWCR. The background
and impact of each of these issues is discussed below.
The total annual impact on burden hours to implement both changes is estimated to be an
increase of 31 hours.

Detailed Explanation of Changes:

A.

SECTION 715 .1(d) - ROUTINE INSPECTIONS OF DECLARED UDOC PLANT
SITES AND NEW UDOC ACHANGE IN INSPECTION STATUS@ FORM .

The CWC information collection package is being revised to add a new declaration
requirement to the CWCR ('715.1(d)(2)) and a new form, entitled AChange In Inspection
Status Form,@ to the CWC Handbook and Forms for declared UDOC plant sites (see
Attachment 1 for form). The UDOC AChange In Inspection Status Form@ should be
submitted by a plant site that is currently declared 1 and inspectable 2 based upon its
1

A plant site is subject to declaration if: 1) it produced by synthesis during the previous
calendar year more than 200 metric tons aggregate of UDOCs; or 2) comprises one or more
plants which produced by synthesis during the previous calendar year more than 30 metric tons
of a UDOC containing the elements phosphorus, sulfur or fluorine (PSF plants and PSFchemical).

production activities that occurred in the previous calendar year, but which anticipates its
activities in the current calendar year will not exceed the inspection threshold and,
therefore, will not be subject to on-site verification by international inspectors of the
Organization for the Prohibition of Chemical Weapons (OPCW) in the next calendar year.
Background:
Treaty requirements: Paragraph 3 of Part IX of the Verification Annex (VA) of the CWC
establishes an initial declaration requirement for UDOC plant sites that meet certain
production threshold requirements. A State Party will submit to the Technical Secretariat
of the OPCW an initial declaration for each UDOC plant site that meets these declaration
requirements within 30 days of the Convention entering into force for a State Party.
Paragraph 3 of Part IX of the VA further requires each State Party to submit to the
Technical Secretariat an Aannual update@ to the information submitted in its initial
declaration in order to accurately reflect the current status (declared, declared/inspectable)
of UDOC plant sites within the State Party. The UDOC annual update declaration should
include: 1) information on changes to a declared plant site=s activities; 2) declarations for
new declared and declared/inspectable plant sites; and 3) identification of plant sites that
are no longer declared as part of the State Party=s UDOC declaration. The annual update
declaration is due to the Technical Secretariat within 90 days after the beginning of each
calendar year.
The Technical Secretariat views a State Party=s initial declaration and any annual updates
thereto as an accurate representation of declared and declared/inspectable plant sites until
it is otherwise advised of any changes, regardless of when the annual update declaration is
submitted.
Current CWCR and Form Requirements: Section 715.1(b)(1) and (2) of the CWCR
require UDOC plant sites to submit an Annual Declaration on Past Activities 3 or a ANo
Changes@ Certification Form 4 to the Department of Commerce no later than February 28th
of the year that follows the calendar year in which the UDOC activities took place. The
2

A plant sites is subject to inspection if it produced by synthesis during the previous
calendar year more than 200 metric tons aggregate of UDOCs (including any amount of a PSFchemical).
3

Annual Declaration on Past Activities for UDOCs provides information on production
quantities and activities of declared UDOC plant sites that occurred during the previous year.
4

No Changes Authorization Form for UDOCs may be submitted by a declared UDOC
plant site if there are no updates or changes to any information (expect the certifying official and
dates signed and submitted) in the plant site=s previously submitted annual declaration on past
activities.
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U.S. Government then forwards an annual update declaration to the OPCW within 90 days
(generally March 31st) after the beginning of the calendar year in which the declarations
were submitted to BIS.
Section 716.1(b)(4) of the CWCR state that a UDOC plant site is subject to inspection only
if it produced in excess of 200 metric tons aggregate of UDOCs during the previous
calendar year.
Since U.S. declarations are not due to BIS until February 28 of the year that follows the calendar
year in which the UDOC activities took place, there is no mechanism in the CWCR for
determining which UDOC plant sites are subject to inspection and notifying the OPCW prior to
submission of the U.S. annual update declaration to the OPCW. In other words, a plant site
cannot be subject to inspection for the previous calendar year if a declaration has not yet
been submitted to the OPCW B thereby establishing a A90Bday gap@ in which U.S. UDOC
plant sites are not subject to inspection by the OPCW.
Since U.S. declarations are not due to BIS until February 28 of the year that follows the calendar
year in which the UDOC activities took place, there is no mechanism in the CWCR for
determining which UDOC plant sites are subject to inspection and notifying the OPCW prior to
the conclusion of the 90-day period for submission of the U.S. annual update declaration to the
OPCW. Universal application of this approach would interfere with the OPCW=s conduct
of UDOC inspections in States Parties for the first 90 days of each year, thereby
undermining the verification regime of the CWC.
The revision to the CWCR and addition of the AChange In Inspection Status@ Form
described below will allow the U.S. Government to fully implement the verification
provisions of Part XI of the Verification Annex of the CWC.
Revised CWCR and Form Requirements: To rectify the A90-day gap@ in which UDOC
plant sites may be excluded from inspection by the OPCW, BIS proposes to establish
'715.1(d)(2) of the CWCR that would require declared and inspectable plant sites that
anticipate to not produce more than 200 metric tons aggregate of UDOCs (including any
amount of PSF-chemicals) during the current calendar year to submit a AChange In
Inspection Status Form@ no later than December 15th of each year. The U.S. Government
will then inform the OPCW [within 15 calendar days (generally no later than December
30)] that such plant sites are not subject to inspection during the next calendar year.
The AChange In Inspection Status Form@ requires UDOC plant sites to submit minimal
information to notify the Department of Commerce that their inspection status will change
in the next calendar year, including: company and plant site name, U.S. code number
(plant site code), name and title of the certifying official, date signed and submitted, and
the reporting year to which the change in inspection status applies.
A plant site that submitted a AChange In Inspection Status Form@ must still submit an
Annual Declaration on Past Activities by February 28th of the next calendar year unless its
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activities did not exceed the declaration thresholds established by '715.1(a)(1) of the
CWCR. However such plant sites may choose to submit their Annual Declaration on Past
Activities in lieu of the AChange In Inspection Status Form@ by December 15, which will serve as
notification of change in inspection status during the first 90 days of the next calendar year as
well as meet its obligation to submit an Annual Declaration on Past Activities.
If a plant site anticipates that it will not produce by synthesis more than 200 metric tons
aggregate of UDOCs (including any amount of PSF-chemicals) and it does not submit a
AChange In Inspection Status Form,@ it remains subject to the declaration requirements of
'715.1 of the CWCR and will be subject to inspection by the OPCW until at least the U.S.
Government submits its annual update declaration to the OPCW 90 days after the
beginning of the calendar year.

B.

SECTIONS 716 AND 721 - INSPECTION RECORDS REVIEW AND
RECORDKEEPING REQUIREMENTS

The CWCR information collection package is being revised to clarify that the facility must
provide access to OPCW Inspection Teams for all records used to prepare declarations, and
otherwise comply with the CWCR, up through the date of the inspection, even when an
inspection takes place during the first 90 days of a calendar year prior to submission of the U.S.
annual declaration on past activities to the OPCW. It clarifies that records include all materials
and documentation associated with the movement into, around, and from the facility of declared
chemicals and their feedstock or any product chemicals formed from such chemicals and
feedstock. Such records are necessary during an inspection to demonstrate to the OPCW
Inspection Team that the inspection aims have been verified. Finally, this revision will clarify
the scope of associated recordkeeping requirements for verifying the non-diversion of Schedule
1 and Schedule 2 chemicals.
These revisions will have minimal impact because industry already uses such records to prepare
declarations and has provided such records to the OPCW Inspection Team during previous
inspections conducted under the CWCR.
Background:
Treaty requirements: Parts VI-IX of the Verification Annex of the Convention establish the
aims for inspections. For Schedule 1, 2, 3 and UDOC inspections, the inspection aims are to
verify the consistency of activities contained in declarations and to verify the absence of the
production of Schedule 1 chemicals, except in accordance with Part VI of the Annex. For
Schedule 1 and 2 inspections, there is an additional aim to verify the non-diversion of Schedule 1
and Schedule 2 chemicals, respectively. The Annexes do not address the specific types of
records necessary to achieve these inspection aims.
Current Sections 716.4(e)and 721.2(a): The inspection provisions under Section 716.4(e) of
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the CWCR state that a facility must provide the Inspection Team with access to all supporting
materials and documentation used to prepare the declaration. Similarly, the recordkeeping
provisions of '721.2 require the facility to retain supporting materials and documentation used to
prepare the declaration.
These provisions do not specify the types/scope of records that should be used by the facility to
prepare a declaration, and retained in support of such declaration. Moreover, these provision do
not clearly indicate that facilities are required to make available to the Inspection Team, and to
retain, all supporting materials and documentation associated with the movement into, around,
and from the facility of declared chemicals and their feedstock or any product chemicals formed
from such chemicals and feedstock during the current and previous calendar years, as applicable.
Revised Section 716.4(e) and Section 721.2(a): Revised '716.4(e) would clearly indicate that
the facility must make available for inspection all supporting materials and documentation used
to prepare declarations, and otherwise comply with the CWCR up through the date of inspection,
available to OPCW inspection team, even when an inspection takes place prior to the facility=s
submission of its Annual Declaration on Past Activities to BIS or the submission of the U.S.
annual declaration on past activities to the OPCW. This section will indicate that such records
shall include all materials and documentation associated with the movement into, around, and
from the facility of declared chemicals and their feedstock or any product chemicals formed from
such chemicals and feedstock. This change is intended to ensure that inspections achieve the
verification objectives described in the CWCR, including verification that a facility=s activities
are consistent with the information contained in its declarations and non-diversion of Schedule 1
and Schedule 2 chemicals. .
Consistent with the above revisions to '716.4(e) noted above, Section 721.2(a) will also clarify
that recordkeeping requirements include all supporting materials and documentation associated
with the movement into, around, and from the facility of declared chemicals and their feedstock
or any product chemicals formed from such chemicals and feedstock. This clarification is being
made to ensure that the CWCR records review and recordkeeping requirements fully conform
with the inspection aims described in the inspection provisions of the CWCR, which include
verifying the non-diversion of Schedule 1 and Schedule 2 chemicals.
C.

TOTAL ESTIMATED INCREASE IN BURDEN HOURS (PER ANNUM).

The above-described revisions to the CWCR are expected to increase the annual burden hours
related to declarations, reports, amendments, notifications and compliance requests under this
collection from 4,471 to 4,502. As a result, the total annual burden hours for this collection will
increase from 10,811 to 10,842 hours; i.e., 4,502 (for declarations, reports, amendments and
compliance requests) + 6,340 (for inspections) = 10,842 total burden hours (see Attachment 3 for
Burden Hour Chart for Declarations, Reports, Amendments, Notifications and Compliance
Reviews).

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Section 715.1(d) - Routine inspections of declared UDOC plant sites and new AChange In
Inspection Status@ Form. In support of determining the estimated burden on UDOC plant sites
for submitting a AChange In Inspection Status Form,@ Attachment 2 lists the number of declared
and inspectable plant sites for reporting years 1999 through 2005. Attachment 3 identifies the
number of UDOC plant sites that would have been to eligible to submit theAChange In
Inspection Status Form@ because their inspection status changed from declared/inspectable in the
previous calendar year to only declared for the next calendar year.
The total estimated annual burden hours for UDOC plant sites to submit a AChange In Inspection
Status Form@ is 31 hours. However, as noted above, this burden could be mitigated if the plant
site is eligible for and chooses to submit early its Annual Declaration on Past Activities.
Sections 716 and 721 - Inspection Records Review and Recordkeeping Requirements. To
assess the additional burden hours and associated costs for the records to verify non-diversion of
Schedule 1 and Schedule 2 records, BIS conducted a voluntary survey of nine Schedule 2
facilities, of which five facilities responded (see Attachment 5 for format of survey).
Specifically, BIS requested these facilities to estimate the time to prepare and maintain records
used to determine non-diversion of Schedule 1 and 2 chemicals, including for example, records
on production, processing and consumption, transfer, inventory, or otherwise disposed. All five
facilities indicated that they are already use and maintain such records in order to prepare their
declarations or for other internal procedures. Therefore, BIS has determined that there is no
additional burden or cost on industry to use and maintain records for verification of nondiversion of Schedule 1 and 2 chemicals.
This proposed rule amends Section 716.4(e) of the CWCR to clarify that a facility undergoing
inspection must provide the Inspection Team with access to all supporting materials and
documentation used by the facility to prepare declarations and to otherwise comply with the
CWCR, including records related to activities that have taken place at the facility since the
beginning of the previous calendar year (i.e., up to and including the date of the inspection),
regardless of whether or not the facility has submitted its Annual Declaration on Past Activities
to BIS at the time of the inspection.
Regarding the requirement for facilities to provide the Inspection Team with access to all
supporting materials and documentation used by the facility to prepare declarations, including
records related to activities that have taken place at the facility since the beginning of the
beginning of the calendar year, but for which a Annual Declaration on Past Activities has not
been submitted at the time of the inspection, BIS has determined that there is no additional
burden or cost on industry as facilities have been providing access to such records for all
inspections that have occurred since implementation of inspection verification regime in
April 2000.

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LIST OF ATTACHMENTS FOR THE
REVISION TO INFORMATION COLLECTION
OMB Form Number 0694-00910694-0091
Attachment
Number

Attachment Name

1

AChange In Inspection Status@ Form and Instructions

2

Number of Declared and Inspectable UDOC Plant Sites
for CYs 1997-2005

3

4
5

Estimated number of UDOC facilities that would have
been eligible to submit the AChange In Inspection
Status@ Form for CYs 1997-2005
Burden Hour Chart for Declarations, Reports,
Notifications and Compliance Reviews
Survey Format for Collection of Information from
Industry to Determine Estimated Burden Hours and Cost
for Maintaining Records and Information for NonDiversion of Schedule 2 Chemicals

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Page Numbers
8-9
10
11

12 - 14
15-16

ATTACHMENT 1
FORM APPROVED: OMB NO. 0694-0091

U.S.
DEPARTMENT OF
COMMERCE
Bureau of Industry
and Security

DATE RECEIVED
(Leave Blank)

ACHANGE IN INSPECTION STATUS@
This AChange in Inspection Status@ Form may only be used
by an Unscheduled Discrete Organic Chemical (UDOC)
plant site if:
the plant site is Adeclared@ and subject to inspection based on
production by synthesis in excess of 200 metric tons
aggregate of UDOCs (including any amount of PSFchemicals) during the previous calendar year; and

the plant site does not anticipate producing by
synthesis in excess of 200 metric tons aggregate of
UDOCs during the remainder o fthe current calendar
year.
NOTE: This AChange in Inspection Status Form@ must be
submitted no later than December 15th of the current
calendar year. The purpose of this form is to ensure your
plant site will not be selected for inspection during the first
90 days of the next calendar year if your current calendar
year activities are not anticipated to exceed the CWC
Regulations= inspection threshold ('715.1(d)).
B.1

Company Name:

B.2

Plant Site Name:

B.3

Plant Site USC Code:

B.4

Date Submitted (YYYY-MM-DD):

B.5

CERTIFICATION

I hereby certify that the inspection status for the declared
plant site is below the inspection threshold (i.e., less than 200
metric tons aggregate of UDOCs) for the current year and is
Name and title of responsible official (type or print):

Signatu
re:

Date
Signed
(YYYY
REPORTING YEAR:
B.6
Change in Inspection Status for the Current
Calendar Year (YYYY):

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B.7

General Optional Comment:

Declaration requirements for Unscheduled
Discrete Organic Chemicals (UDOCs) are set
You may submit this form to ensure that your
plant site will not be selected for inspection by
the Organization for the Prohibition of
Chemical Weapons (OPCW) during the first 90
days of the next calendar year if:

forth in Part 715 of the CWC Regulations (15
CFR 715).

3) your plant site is currently subject to
inspection by the OPCW as outlined
under Section 715.1(d) of the CWC
Regulations because it produced by
synthesis in excess of 200 metric tons
aggregate of UDOCs during the
previous year; and

Note 2: Upon receipt of the AChange In
Inspection Status@ Form or ADPA, the
Department of Commerce will inform the
OPCW that your plant site is not
inspectable during the next calendar year,
if appropriate.

Activities (ADPA) by December 15 if you
are certain the aggregate production
threshold for the plant site will not change
before the end of the current calendar
year.

Your signature on the AChange in Inspection
Status@ Form authorizes the Department of
Commerce to inform the OPCW that your
plant site will not be subject to inspection
during the next calendar year thereby
eliminating the possibility that an inspection
may occur during the first 90 days of the next
calendar year.

4) your plant site is not anticipating to
exceed the 200 metric ton aggregate
production threshold during the
current calendar year.
The AChange in Inspection Status Form@ must
be submitted no later than December 15th of
the current calendar year. This form may
only be used to certify that the inspection
status of the plant site will change based on
current year activities. If you do not submit a
AChange in Inspection Status@ Form, your
plant site will continue to be subject to
inspection (during the first 90 days of the next
calendar year) until: (1) a new Annual
Declaration on Past Activities (ADPA) has
been submitted that declares the production
range for the plant site as below the inspection
threshold and thereby changes the inspection
status; or (2) your plant site is not required to
submit an ADPA (Note: The OPCW will be
informed that your plant site is no longer
subject to declaration B see Question B.7).

If after submitting a AChange in Inspection
Status@ Form, you determine that the
production for the plant site actually exceeded
200 metric tons aggregate threshold, you must
submit by February 28 an ADPA (i.e.,
Certification Form, UDOC Form - Parts A
and B, and Form B) and indicate on Form B
the reason the plant site exceeded the
inspection threshold after submission of the
AChange in Inspection Status@ Form.
Question B.1 through B.3 Company Name
and Plant Site name and USC Code: Provide
the name of the company, plant site and the
plant site USC code.

NOTE 1: In lieu of submitting a AChange
in Inspection Status@ Form, you may
submit an Annual Declaration on Past

Questions B.4 and B.5 Date Submitted and
Certification: The Certification must be
signed and dated by the owner, operator, or
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senior management official who certifies the
accuracy and completeness of the information
submitted. The certification signature block
must contain an original signature. The date
submitted block should indicate the date the
certification is submitted.

Question B.6 Reporting Year: Provide the
current year for which the information
applies.
Question B.7: General Optional Comment:
Provide any voluntary comments regarding
your plant site (e.g., no longer subject to
declaration).

ATTACHMENT 2
NUMBER OF DECLARED AND INSPECTABLE UDOC PLANT SITES

Reporting 5
Year

Number of Declared
UDOC Plant Sites

CY 1999

650

650

CY 2000

632

620

CY 2001

626

612

CY 2002

592

581

CY 2003

579

568

CY 2004

566

557

CY 2005

554

546

5

Number of Inspectable
UDOC Plant Sites

The Annual Declaration on Past Activities for a reporting year is due to the Department
of Commerce (postmarked) by February 28th of the year that follows the calendar year in which
the UDOC activities took place.

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ATTACHMENT 3
ESTIMATED NUMBER OF UDOC FACILITIES
THAT WOULD HAVE BEEN ELIGIBLE TO
SUBMIT THE ACHANGE IN INSPECTION STATUS@ FORM

CY 1999
CY 2000

4 of 622

CY 2000
CY 2001

6 of 620

CY 2001
CY 2002

7 of 612

CY 2002
CY 2003

3 of 581

CY 2003
CY 2004

3 of 568

CY 2004
CY 2005

2 of 557

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ATTACHMENT 4
BURDEN HOUR CHART FOR DECLARATIONS, REPORTS, AMENDMENTS,
NOTIFICATIONS AND COMPLIANCE REVIEWS
The information in this chart is based upon actual declarations, reports, amendments,
notifications and records submitted by U.S. chemical facilities and trading companies for
Reporting Year (RY) 2005 activities, as required by the Chemical Weapons Convention
Regulations (CWCR) (15 CFR Parts 710-722). Certain facilities may have submitted
multiple declarations or reports under different chemical regimes. This data includes RY
2005 Declarations on Annual Anticipated Activities, Annual Declaration on Past Activities
(ADPA), Annual Reports on Exports and Imports and any amendments thereto (excluding
cases returned without action), which were received by the Department of Commerce=s
Bureau of Industry and Security (BIS) during Calendar Years (CYs) 2005 and 2006.
For the UDOC AChange In Inspection Status@ Form, the data field accounts for the
estimated number of facilities that would have been eligible to submit the new form in order
to be excluded from possible inspection during the first 90 days of the next calendar year (see
Attachment 3). The number of declarations was derived by first identifying the number of
declared and inspectable facilities in CYs 1999 through 2005 (see Attachment 2), and then
identifying the number of facilities that would have been eligible to submit the UDOC
AChange In Inspection Status@ Form, because they were declared and inspectable in the
previous calendar year but were only declarable for the applicable reporting year (i.e., not
subject to inspection) (see Attachment 3). The burden hours for completing this form is
estimated to be the same as for the UDOC ANo Changes@ Certification Form because the
amount of time to collect information and prepare the form is the same (5.1 burden hours x 6
UDOC plant sites eligible to submit a AChange In Inspection Status@ Form = 31 hour
increase in burden hours).

CHEMICAL
REGIME

BURDEN
HOURS

ACTUAL NUMBER OF
DECLARATIONS, REPORTS, &
AMENDMENTS RECEIVED*
& ESTIMATED NUMBER OF
REQUESTS FOR COMPLIANCE
INFORMATION

TOTAL
BURDEN
HOURS

SCHEDULE 1

10.6 **

3

32

SCHEDULE 2

11.9 **

47

559

SCHEDULE 3

2.5 ***

127

318

UDOC'S

5.3 ***

495

2624

5.1 ****

55

281

UDOC ANo Changes@

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UDOC AChange in
Inspection Status@

5.1*****

6

31

SCHEDULE 1
EXPORT/IMPORT
ADVANCE
NOTIFICATIONS

0.17 x 3 = 0.51
******

1

1

Compliance Review
Requests

1.7 *******

50 (estimate)

85

867

4502

TOTAL

* These numbers include all annual declarations on anticipated and past activities and annual
reports on exports and import for RY 2005. All amendments received (e.g., amendment
submitted based on an inspection finding) are also included in these numbers.
** These estimates are based on the average time required to complete each page of the
UDOC forms in our field test times the total number of pages in the Schedule 1 and 2
declarations. For example, for Schedule 1, this would be as follows:
(5.3 hours/4 UDOC pages) x 8 Schedule 1 pages = 10.6 hours.
*** These estimates were derived from our field test. The sample size for Schedule 3 was
two respondents. The sample size for UDOCs was four respondents.
**** This estimate was obtained by comparing the difference in the amount of time to Atype@
a ANo Changes@ Certification Form (one page) versus a complete ADPA (three pages). A
proficient typist took 0.1 hours to type a ANo Changes@Certification Form and 0.3 hours to
type an ADPA (0.3 - 0.1 = 0.2 hour). The amount of time to collect the support
documentation to prepare a UDOC declaration remains unchanged. Accordingly, only 0.2
hours (typing time) was subtracted from the amount of time to collect the information and
prepare the complete ADPA (5.3 - 0.2 = 5.1). The final CWC Regulations, including
authorization for the new UDOC ANo Changes@ Certification Form, was published in the
Federal Register on April 27, 2006. Therefore, facilities were not authorized to submit this
reporting form for the CY 2005 declaration on past activities. The estimate number of 55
was determined based on the number of facilities that would have been eligible to submit the
UDOC ANo Changes@ Certification Form. Accordingly actual UDOCs submitted was 550 of
which 55 were eligible for, and are reported under, the UDOC ANo Changes@ Certification
Form (550 - 55 = 495).
***** The burden hours for completing the AChange In Inspection Status@ Form are
estimated to be the same as the UDOC ANo Changes@ Certification Form because the

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amount of time to collect information and prepare would be the same (see item ****
above).
****** This estimate is based on the estimated time required to complete the notification, on
company letterhead, per respondent (10 minutes) times the estimated number of responses
per respondent (3) times the actual number of plant sites or trading companies (1).
******* This estimate is based upon an estimated 50 requests to industry for typical
compliance related information during a calendar year (50 x 1.7 = 85 hours). The final CWC
Regulations, including authorization for BIS to conduct compliance reviews, was published
in the Federal Register on April 27, 2006. Therefore, BIS does not have actual statistics for
this collection and is reporting the original estimated number.

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ATTACHMENT 5
SURVEY FORMAT USED FOR COLLECTION OF INFORMATION FROM
INDUSTRY TO DETERMINE ESTIMATED BURDEN HOURS AND COST FOR
MAINTAINING RECORDS AND INFORMATION FOR NON-DIVERSION OF
SCHEDULE 2 CHEMICALS
++++++++++++
BURDEN HOUR CHART
Estimate of Hours
Required to Prepare and Maintain Records
to Demonstrate Non-Diversion of Schedule 2 Chemicals

Company Name: _________________________________________
Point-of-Contact: _________________________________________
USC Code: ______________________________________________
Plant Site Name: _________________________________________
Please estimate the number of minutes/hours required to prepare and maintain the below listed
records on an annual basis for Schedule 2 activities (i.e., production, processing and consumption) that
you declared in your CY 2005 Annual Declaration on Past Activities or Combined Declaration.
Note: Certain activities or record types may not be applicable to your facility, in which case, please
leave the item blank.

Schedule 2
Activity

Production

Record

Number of Minutes/Hours
Annually
Preparation Maintenance

Quantities of reactant(s) used to produce Schedule 2
chemical
Analysis of the Schedule 2 chemical produced in the final
product and in waste stream(s), if applicable and if
available
Quantities of the Schedule 2 chemical produced if the
concentration is above 30% and of other chemicals
produced as by-products to the Schedule 2 chemical
Batch records of Schedule 2 chemical production
Quantities of the Schedule 2 chemical sold, transferred
off-site or otherwise disposed of, by transaction

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Record
Already Used
to Prepare
Declarations?
(Yes / No)

Processing

Inventory of the Schedule 2 chemical and any
adjustments to inventory
Quantities of Schedule 2 chemical purchased or
transferred on-site, by transaction
Batch records of the Schedule 2 chemical processed
Quantities of the final product resulting from processing
of the Schedule 2 chemical if the concentration is above
30%
Quantities of other chemicals with which the Schedule 2
chemical is processed
Analysis of the Schedule 2 chemical in the product and
in waste stream(s), if applicable and if available
Quantities sold, transferred off-site, or otherwise
disposed of, of the processed product containing
Schedule 2 chemical
Inventory of the Schedule 2 chemical and any
adjustments to inventory

Consumption

Inventory of the processed product containing Schedule
2 chemical and any adjustments to inventory
Quantities of Schedule 2 chemical purchased or
transferred on-site, by transaction
Schedule 2 chemical inventory and any adjustments to
inventory
Analysis of the Schedule 2 chemical and of Schedule 2
chemical in waste stream(s), if applicable and if available
Quantities of other reactants to the Schedule 2 chemical
Quantities of chemicals produced from the Schedule 2
chemical
Analysis of chemicals produced from the Schedule 2
chemical, if applicable and if available

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