0152-12 Attachment G

ATTACHMENT G

Work Sheets used to Calculate Respondent & Agency Labor Costs

This attachment is available as part of the electronic docket EPA-HQ-OPP-2016-0122 and is part of the ICR’s Supporting Statement.

Respondent Labor Costs

Pesticide Registrants1 (NAICS: 325300)
Item	Formula	Labor Category2
		Managerial	Technical	Clerical
Unloaded Hourly Rate1	= W	$56.51	$33.43	$19.00
Benefits Percentage3	Lb = B/W	46%	46%	46%
Benefits per hour	B = W*Lb	26.17	15.48	8.80
Loaded Hourly Rate	Wb = W + B = W(1+Lb)	82.68	48.91	27.80
Overhead Percentage4	Lo = OH/Wb	50%	50%	50%
Overhead per hour	OH = Wb*Lo	41.34	24.46	13.90
Fully Loaded Hourly Rate	Wf = Wb + OH = W + B + OH	124.02	73.37	41.70

1. Source: Bureau of Labor Statistics, NAICS 325300 - Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing, 2014 data, Accessed March 2016, http://www.bls.gov/oes/current/naics4_325300.htm

2. Standard Occupational Codes:

Management: 11-0000, Management Occupations

Technical: 19-0000, Life Physical, and Social Science Occupations

Clerical: 43-0000, Office and Administrative Support Occupations

3. Total benefits/wages based on June 2014 Employer costs for employee compensation, All Civilian nonfarm workers, http://www.bls.gov/news.release/ecec.t02.htm

4. U.S. Environmental Protection Agency, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA-452-02-001, January 2002, pp. 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.

Agency Labor Costs

EPA or Federal Government1 (NAICS: 999100)
Item	Formula	Labor Category2
		Managerial	Technical5	Clerical
Unloaded Hourly Rate1	= W	$56.54	$37.15	$21.15
Unloaded Yearly Wage Rate ($/year)	= W * 2080 (52wks * 40hrs)	n/a	$77,272	n/a
Benefits Percentage3	Lb = B/W		46%
Benefits per hour	B = W*Lb		$35,787
Loaded Hourly Rate	Wb = W + B = W(1+Lb)		$113,059
Overhead Percentage4	Lo = OH/Wb		50%
Overhead per hour	OH = Wb*Lo		$56,530
Fully Loaded Hourly Rate	Wf = Wb + OH = W + B + OH		$169,589

1. Source: Bureau of Labor Statistics, NAICS 999100 - Federal Executive Branch, 2014 data, Accessed March 2016, http://www.bls.gov/oes/current/naics4_999100.htm

2. Standard Occupational Codes:

Management: 11-0000, Management Occupations

Technical: 19-0000, Life Physical, and Social Science Occupations

Clerical: 43-0000, Office and Administrative Support Occupations

3. Total benefits/wages based on June 2014 Employer costs for employee compensation, All Civilian nonfarm workers, http://www.bls.gov/news.release/ecec.t02.htm

4. U.S. Environmental Protection Agency, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA-452-02-001, January 2002, pp. 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.

5. Only technical is used because the other labor types are not very involved in the reviewing of NOA submissions. The Fully Loaded Hourly Rate will be multiplied by the number of FTEs (full time equivalents) to get the labor cost component of the annual Agency burden.