Attachment J: Worksheet to Calculate Labor Costs

Renewal ICR: Section 3

June 4, 2015

ICR ATTACHMENT J: EPA ICR Number 0277.17
Labor Wage Formulas

For this ICR, the Agency revised the estimated wages, benefits, and overhead for all
labor categories for affected industry and EPA employees based on the most recent publicly
available data from the US Bureau of Labor Statistics. The methodology for calculating the
wage rates is the same for both the emergency exemption and SLN collections, and are based on
2014 wage data. The calculation of the wage rates uses base wage data for each sector and labor
type for an Unloaded wage rate (hourly wage rate) and calculates the Loaded wage rate
(unloaded wage rate + benefits) and the Fully loaded wage rate (loaded wage rate + overhead)
based on that data. Fully loaded wage rates are used to calculate respondent costs.
Unloaded Wage Rate: Wages are estimated for labor types (management, technical, and
clerical) within applicable sectors. The Agency uses average wage data for the relevant sectors
available in the National Industry-Specific Occupational Employment and Wage Estimates from
the Bureau of Labor Statistics (BLS) (see http://www.bls.gov/oes/current/oes_nat.htm).
Sectors: The specific North American Industry Classification System (NAICS) code and
website for each sector is included in that sector’s wage rate table. Within each sector, the wage
data are provided by Standard Occupational Classification (SOC). The SOC system is used by
Federal statistical agencies to classify workers into occupational categories for the purpose of
collecting, calculating, or disseminating data (see http://www.bls.gov/oes/current/oes_stru.htm).
Loaded Wage Rate: Unless stated otherwise, all benefits represent 44% of unloaded wage
rates, based on average rate of benefits for all civilian non-farm workers (see
http://www.bls.gov/news.release/ecec.t01.htm). If any sectors are listed for which 44% is not
applicable; the applicable percentage will be stated.
Fully Loaded Wage Rate: The loaded wage rate is multiplied by 50% (EPA guidelines
suggest 20-70%) to get overhead costs.

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Renewal ICR: Section 3

June 4, 2015

Registrant Labor Costs
Labor Category:

Formula

Managerial

Technical

Clerical

Unloaded Hourly Rate 1

=W

$56.61

$33.43

$19.00

Benefits Percentage 2

Lb = B/W

Benefits per hour

B = W*Lb

44%
$24.64

44%
$14.58

44%
$8.28

Loaded Hourly Rate

Wb = W+B = W(1+Lb)

$81.15

$48.01

$27.28

Overhead Percentage 3

Lo = OH/Wb

Overhead per hour

OH = Wb*Lo

50%
$40.57

50%
$24.00

50%
$13.64

Fully Loaded Wage Rate

Wf = Wb + OH
= W + B + OH

$121.72

$72.01

$40.93

1. Data Source: http://www.bls.gov/oes/current/naics4_325300.htm
Management: 11-0000, Management Occupations
Technical: 19-0000, Life Physical, and Social Science Occupations
Clerical: 43-0000, Office and Administrative Support Occupations
2. Fringe benefits ÷ wage per hour
3. U.S. Environmental Protection Agency, EPA Air Pollution Control Cost Manual, Sixth Edition,
EPA-452-02-001, January 2002, pg. 2-34. The loading for indirect costs is within the range of
20-70% of the loaded labor rate (wage + benefits) suggested in EPA guidance.
Source: US Department of Labor, Bureau of Labor Statistics, May 2014

EPA (Agency) Labor Costs
Labor Category
Unloaded Hourly Rate 1
Benefits Percentage 2
Benefits per hour
Loaded Hourly Rate
Overhead Percentage 3
Overhead per hour
Fully Loaded Wage Rate

Formula
=W
Lb = B/W
B = W*Lb
Wb = W+B = W(1+Lb)
Lo = OH/Wb
OH = Wb*Lo
Wf = Wb + OH
= W + B + OH

Managerial
$56.54
44%
$24.65
$81.19
50%
$40.60

Technical
$37.15
44%
$16.20
$53.35
50%
$26.67

Clerical
$21.15
44%
$9.22
$30.37
50%
$15.19

$121.79

$80.02

$45.56

1. Data Source: http://www.bls.gov/oes/current/naics4_999100.htm
Management: 11-0000, Management Occupations
Technical: 19-0000, Life Physical, and Social Science Occupations
Clerical: 43-0000, Office and Administrative Support Occupations
2. Fringe benefits ÷ wage per hour
3. U.S. Environmental Protection Agency, EPA Air Pollution Control Cost Manual, Sixth Edition,
EPA-452-02-001, January 2002, pg. 2-34. The loading for indirect costs is within the range of
20-70% of the loaded labor rate (wage + benefits) suggested in EPA guidance.
Source: US Department of Labor, Bureau of Labor Statistics, May 2014

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