Attachment 3:
Documentation of Labor Burden and Cost Assumptions and Estimates for the Information Collection Request for the Formaldehyde Standards for Composite Wood Products Act (EPA ICR #2446.03; OMB Control No.: 2070-0185)
This attachment presents documentation of the assumptions and calculations used to estimate the burden and costs for this Information Collection Request supporting statement. EPA’s TSCA Title VI rule (which implements the amendments made to TSCA by the Formaldehyde Standards for Composite Wood Products Act) regulates panel producers, fabricators and laminators, distributors, importers, and retailers of composite wood products, as well as accrediting bodies and third-party certifiers. Panel producers manufacture regulated composite wood products – hardwood plywood (HWPW), medium density fiberboard (MDF) and particleboard. Fabricators and laminators incorporate composite wood products into component parts or into finished goods. Distributors and importers supply composite wood products, component parts, or finished goods to other firms. Retailers sell composite wood products or finished goods directly to consumers. Third-party certifiers are responsible for auditing panel producers, conducting and verifying formaldehyde emissions tests, and ensuring producers’ quality assurance and testing procedures comply with the applicable requirements. Accreditation bodies verify the competency of third-party certifiers.
The burden and cost estimates for producers, fabricators and laminators, distributors and importers, retailers, accrediting bodies, and third party certifiers are presented in sections 3.1 through 3.6. Not all firms subject to the TSCA Title VI rule will incur additional burden or costs for compliance. Many of the provisions in this rule are identical to those in the 2008 Airborne Toxics Control Measure (ATCM) to reduce formaldehyde emissions from composite wood products promulgated by the California Air Resources Board (CARB). Because of the similarities between the CARB ATCM and the TSCA Title VI rule, firms that were already complying with the CARB ATCM incur little to no additional burden or costs to comply with EPA’s rule. In other cases, the ordinary business practices at firms subject to the TSCA Title VI rule are sufficient to comply with the rule’s requirements without additional burden or costs.
Panel producers make hardwood plywood (HWPW), medium-density fiberboard (MDF) or particleboard panels that are classified as composite wood products under TSCA Title VI. Based on data from the TSCA Title VI program there are currently 1,204 panel producers in the program. There are 757 HWPW producers, 293 MDF producers, and 196 particleboard producers.1
EPA’s Economic Analysis for the 2016 TSCA Title VI rule estimated that most U.S. panel producers were already compliant with the CARB ATCM. 2 Specifically, all MDF product lines were estimated to be certified; all particleboard producers had at least one product line certified, although a few producers did not have all their product lines certified; and some hardwood plywood producers did not have any of their product lines certified. Because the TSCA Title VI rule’s requirements are so similar to provisions in the CARB ATCM, many of the information collection requirements in the TSCA rule create incremental burdens and costs for only the panel producers that had products that were not certified under the CARB ATCM.
There are separate burden and cost estimates for HWPW and particleboard producers because the latter do not incur additional costs for certain third party certification activities with fixed costs. (Particleboard producers were already incurring those costs because they had at least one product certified in the baseline.) Furthermore, the frequency of quality control testing differs for HWPW and particleboard producers under the TSCA Title VI rule. Note that MDF producers are not estimated to incur incremental burdens or costs to comply with the TSCA Title VI rule because all their product lines were certified under the CARB ATCM in the baseline.
This analysis uses the mean wage rate ($52.15/hour) in the U.S. Bureau of Labor Statistics’ Occupational Employment Statistics data series for the “Wood Products Manufacturing” (NAICS 321) industry sector and the “Management Occupations” (OCC-CODE 11-000). The wage is loaded to reflect benefits using U.S. Bureau of Labor Statistics’ Employer Costs for Employee Compensation (ECEC) data series from June 2019. In the manufacturing data series, employer costs for total benefits are 52.8% of wages. This analysis also adds a 17% loading factor to account for the employer’s overhead. Thus, the loaded wage rate is $52.15*(1+.528+.17) = $89/hour after rounding to the nearest dollar.
The TSCA Title VI rule requires producers to have their composite wood products certified by a TPC. A TPC charges a producer it certifies an annual administrative fee for this service. The economic analysis (EA) for the 2016 final TSCA Title VI rule estimated that the only U.S. firms that would incur incremental TPC fees were HWPW panel producers. 3 The 2016 EA estimated that 11 of 41 domestic HWPW mills would incur incremental TPC certification costs. The other 30 domestic HWPW mills (as well as all the domestic MDF and particleboard mills) were already incurring TPC fees due to the CARB ATCM.
Based on data from the TSCA Title VI program there are currently 48 domestic and 709 foreign HWPW panel producers. Maintaining the same assumption about the percentage of HWPW panel producers that would incur incremental TPC certification costs (26.8%), this analysis estimates that there are 13 domestic and 191 foreign mills that incur incremental costs for TPC fees due to the TSCA Title VI rule.4
The TPC fee was previously estimated to be $6,000 in 2011$ for HWPW manufacturers based on estimates from the Hardwood Plywood and Veneer Association (HPVA).5 This analysis uses the U.S. Bureau of Labor Statistics’ Consumer Price Index (CPI) to inflate the estimate of the fee to $6,698 in 2018$.
Thus, the total incremental TPC fee costs estimated are $87,074 for domestic mills and $1,279,318 for foreign mills, totaling $1,366,392 per year for all HWPW mills combined.
The TSCA Title VI rule requires TPCs to conduct quarterly on-site audits of certified panel producers. The cost of the audit is borne by the composite panel producer. The initial recurring on-site audit fee was previously estimated to be $450 per audit in 2011$ based on estimates from HPVA. This analysis uses the U.S. Bureau of Labor Statistics’ CPI to inflate the fee to $502 in 2018$. Each mill with incremental costs is assumed to have quarterly on-site audits. Mills are also assumed to incur a labor burden of 4 hours for each audit since a mill employee will be present during the audit. Thus, total annual costs per mill for recurring onsite audits are estimated to be 4*($502+$89/hr*4 hours) = $3,432.
The only firms estimated to incur incremental recurring onsite audit costs in the economic analysis for the 2016 TSCA Title VI rule were HWPW panel producers. As described above in the TPC fee cost description, this analysis estimates that 13 domestic and 191 foreign mills incur incremental TPC certification costs. Thus, the total incremental on-site audit costs estimated are $44,616 for domestic mills and $655,512 for foreign mills, totaling $700,128 per year for all mills combined.
The TSCA Title VI rule requires panel producers to have the emissions from each production line tested on a quarterly basis. Quarterly testing must be supervised by a TPC and performed by a TPC laboratory. Quarterly testing must be performed using a large chamber test (ASTM E1333) or, with a showing of equivalence, a small chamber test (ASTM D6007). The fee for quarterly testing was previously estimated to be $480 per product line in 2011$ based on estimates from HPVA. This analysis uses the U.S. Bureau of Labor Statistics’ CPI to inflate the fee to $536 in 2018$. Each mill with incremental costs is assumed to incur a labor burden of 1 hour each quarter associated with this testing, which is an annual labor burden of 4 hours. Based on current TSCA Title VI certification data, HWPW stock panel producers certify an average of 2.6 product lines per mill. Thus, total annual costs per mill for quarterly testing are estimated to be 4*(2.6*$536+($89/hr*1 hour)) = $5,930.
As described above in the TPC fee cost description, this analysis estimates that 13 domestic and 191 foreign mills incur incremental TPC certification costs. Thus, the total incremental quarterly testing costs estimated are $77,095 for domestic mills and $1,132,706 for foreign mills, totaling $1,209,802 per year for all mills combined.
The TSCA Title VI rule requires panel producers to have a third party test the emissions from each production line on a quarterly basis. The 2016 Economic Analysis estimated that 5 of 30 domestic particleboard mills would incur incremental TPC fees for quarterly testing. Based on current data from EPA’s TSCA Title VI program, this analysis estimates that there are now 22 domestic and 174 foreign particleboard panel producers in total and this analysis estimates that 16.7% of both foreign and domestic mills incur incremental costs (4 domestic and 29 foreign).6
The quarterly testing fee was previously estimated to be $480 per product line in 2011$ based on estimates from HPVA. This analysis uses the U.S. Bureau of Labor Statistics’ CPI to inflate the fee to $536 in 2018$. EPA’s 2016 Economic Analysis assumed that the particleboard producers incurring these costs had two product lines (one of which was certified in the CARB ATCM program in the baseline and one of which was not), so that the mills incurred incremental testing costs for half of their product lines. This analysis similarly assumes that particleboard mills incur incremental testing costs for the additional product lines but not incremental labor costs for selecting and preparing panels for shipping associated with the additional testing. Based on current TSCA Title VI certification data, particleboard stock panel producers certify an average of 4.3 product lines per mill, and so this analysis assumes that they incur incremental costs due to quarterly testing fees for an average of 2.2 product lines per mill. Thus, total annual costs per mill for quarterly testing are estimated to be 4*(2.2*$536) = $4,717.
Thus, the total incremental large scale testing costs are estimated to be $18,867 for domestic mills and $136,787 for foreign mills, totaling $155,654 per year for all mills combined.
Mills incur a cost to ship panels to their TPC’s laboratory for quarterly testing. This analysis estimates that the shipping costs are $50 in 2011$.7 This analysis uses the U.S. Bureau of Labor Statistics’ CPI to inflate the cost to $56 in 2018$. Based on current data from the TSCA Title VI program, HWPW stock panel producers certify an average of 2.6 product lines per mill, and therefore the annual costs per mill are $582.4.
As described above, there are 13 domestic and 191 foreign HWPW mills that incur quarterly testing costs. Thus, the total incremental shipping costs for quarterly testing are estimated at $7,571 for domestic mills and $111,238 for foreign mills, totaling $118,810 per year for all HWPW mills combined.
This analysis assumes that particleboard mills incur the same costs to ship panels for quarterly testing as HWPW mills, $56 in 2018$. Based on current TSCA Title VI certification data, particleboard stock panel producers certify an average of 4.3 product lines per mill. Since half of these product lines are assumed to incur incremental certification costs due to the TSCA Title VI rule (based on the 2016 assumption that they incurred these costs for 1 of their 2 product lines), this analysis assumes that they incur these incremental costs for an average of 2.2 product lines per mill. Therefore the annual incremental costs per mill are $492.80.
As described above, there are 4 domestic and 29 foreign particleboard mills that incur incremental quarterly testing costs. Thus, the total incremental shipping costs for quarterly testing are estimated at $1,971 for domestic mills and $14,291 for foreign mills, totaling $16,262 per year for all particleboard mills combined.
In addition to the TPC fee for on-site audits described in Section 1.1.3, panel producers also pay for the cost of TPC staff to travel to the mill for an annual on-site audit. (For the other three quarterly audits, TPCs are assumed to hire contract inspectors closer to the mill that do not incur significant travel expenses.) Based on information from HPVA, EPA previously estimated these travel costs to be $1,500 in 2011$; this analysis uses the U.S. Bureau of Labor Statistics’ CPI to inflate the cost to $1,675 in 2018$.
As described above, there are 13 domestic and 191 foreign HWPW mills that incur incremental costs associated with product certification. Thus, the total incremental costs for TPC travel for on-site audits are estimated at $21,775 for domestic mills and $319,925 for foreign mills, totaling $341,700 per year for all HWPW mills combined.
TPCs may conduct periodic “desk audits” which are quality control checks performed over the phone in which the mill’s quality control testing procedures and data are reviewed. As with the quarterly audits, the mills incur costs for both the TPC’s fee and the labor of the mill staff involved in the audit. Based on information from HPVA, EPA previously estimated the cost of desk audits to be $250 per audit in 2011$. This analysis uses the U.S. Bureau of Labor Statistics’ CPI to inflate the cost to $279 per audit in 2018$, or $1,116 annually. Desk audits are assumed to occur in months where there is no quarterly audit and require a mill labor burden of 1 hour per audit. With 8 audits per year, and a wage rate of $89, the annual labor burden is $712. The annual cost per mill is therefore $2,944.
As described above, there are 13 domestic and 191 foreign HWPW mills that incur incremental costs associated with product certification. Thus, the total incremental desk audit costs are estimated at $38,272 for domestic mills and $562,304 for foreign mills, totaling $600,576 per year for all HWPW mills combined.
The TSCA Title VI rule requires mills to perform routine quality control testing for each certified product line. For HWPW mills the frequency of QC testing depends on the production volume, ranging from once per hundred thousand square feet of production to four times a week. This analysis makes the simplifying assumption that HWPW mills will test each product line once per week. Mills have the option of constructing an on-site laboratory for QC testing and having it approved by a TPC, or contracting with a certified third-party lab to perform their QC testing. This analysis assumes that HWPW mills that incur incremental costs will pay their TPC to perform QC testing.
QC testing must be performed using one of several allowable test methods. The 2016 EA assumed that half of the HWPW mills with incremental costs use desiccator tests (ASTM D5582), incurring a fee of $73 per test (2013$); and that the other half use small chamber tests (ASTM D6007), incurring a fee of $420 per test. Thus the average cost of QC testing by a TPC lab was estimated at $246 (2013$) per test. This analysis uses the U.S. Bureau of Labor Statistics’ CPI to inflate the cost to $265 in 2018$. With an average cost of $265 per product line each week, and an average of 2.6 product lines per mill, the total annual cost is $35,828. Quality control testing for HWPW mills is assumed to occur weekly and require a mill labor burden of 1.5 hours per week. With a wage rate of $89, the annual labor cost is $6,942. The annual cost per mill is therefore $42,770.
As described above, there are 13 domestic and 191 foreign HWPW mills that incur incremental costs associated with product certification. Thus, the total incremental costs for quality control testing by HWPW mills is estimated at $556,010 for domestic mills and $8,169,070 for foreign mills, totaling $8,725,080 per year for all HWPW mills combined.
HWPW mills that have their TPC’s lab conduct their QC testing incur a cost to ship samples to the lab. The 2016 EA assumed that mills would incur shipping costs of $8 (2013$) per product line to ship samples for quality control testing. This analysis uses the U.S. Bureau of Labor Statistics’ CPI to inflate the cost to $9 in 2018$. With an average cost of $9 per product line each week, and an average of 2.6 product lines per mill, the total annual cost per HWPW mill is $1,216.80.
As described above, there are 13 domestic and 191 foreign HWPW mills that incur incremental costs associated with product certification. Thus, the total incremental costs for shipping samples for quality control testing are estimated at $15,818 for domestic mills and $232,409 for foreign mills, totaling $248,227 per year for all HWPW mills combined.
The composite wood product samples that are tested for emissions are not sold, so mills lose the revenue that could have been generated from the sale of these panels. EPA’s 2016 Economic Analysis estimated these costs to be $17 per panel in 2013$; this analysis uses the U.S. Bureau of Labor Statistics’ CPI to inflate the cost to $18 in 2018$. Producers will lose one panel per product type for each day that quality control testing is performed. Since quality control testing is assumed to occur weekly, there is additional product lost during the 4 quarterly audits, and HWPW producers have 2.6 product lines on average, annual costs are estimated to be $2,620.80 per mill.
As described above, there are 13 domestic and 191 foreign HWPW mills that incur incremental costs associated with product certification. Thus, the total incremental costs for lost product by HWPW mills are estimated at $34,070 for domestic mills and $500,573 for foreign mills, totaling $534,643 per year for all HWPW mills combined.
The composite wood product samples that are tested for emissions are not sold, so mills lose the revenue that could have been generated from the sale of these panels. EPA’s 2016 Economic Analysis estimated these costs to be $13 in 2013$; this analysis uses the U.S. Bureau of Labor Statistics’ CPI to inflate the cost to $14 in 2018$. Since this testing occurs quarterly and particleboard producers have 2.16 product lines on average with incremental costs, annual costs are estimated to be $120.96 per mill.
As described above, there are 4 domestic and 29 foreign particleboard mills that incur incremental costs associated with product certification. Thus, the total incremental costs for lost product due to testing are estimated at $484 for domestic mills and $3,508 for foreign mills, totaling $3,992 per year for all particleboard mills combined.
Panel producers must maintain various records including emissions testing results, product and production records, and representative copies of labels used. Based on recent TSCA Title VI and CARB ATCM data, this analysis estimates there are a total of 1,204 HWPW, MDF, and particleboard producers affected by this information collection requirement. Each producer is assumed to incur a recordkeeping burden of 1 hour per week. Thus the total annual labor burden is 62,608 hours (=1,204*52) per year and the total cost of the burden is $5,572,112 (=62,608*$89) per year.
Fabricators and laminators incorporate composite wood products into component parts or into finished goods. The previously approved ICR (EPA ICR #2446.02) estimated that there were 79,978 domestic and 31,183 foreign fabricators and laminators subject to the TSCA Title VI rule, for a total of 111,161 firms. This analysis retains those estimates.
Under the TSCA Title VI rule, all fabricators and laminators are required to label their products with their name, the date the finished good was produced, and a statement of compliance. The previously approved ICR (EPA ICR #2446.02) concluded that many fabricators and laminators would not incur an incremental cost to comply with the TSCA labeling requirements because the firms were already complying with similar requirements in the CARB ATCM or because their existing labeling systems were sufficient to meet the TSCA rule’s requirements without any significant modification. While some firms were estimated to incur a one-time burden to change their labels to comply with the TSCA rule’s requirements, such firms have now incurred those burdens and do not incur additional burden for this activity in the period covered by this ICR. Therefore, no incremental labeling costs are estimated in this ICR for fabricators and laminators.
Fabricators and laminators that do not import composite wood panels or component parts are only required to maintain invoices, bills of lading, or other similar documents from their suppliers that include a statement that the composite wood products or component parts are TSCA Title VI compliant or were produced before a date one year after the publication of the final rule. Such documents are assumed to be kept as ordinary business records and therefore no recordkeeping burden is estimated.
Firms that import composite wood panels or component parts must be able to provide EPA with additional records identifying the panel producer, supplier, date of manufacture, and date of purchase within 30 days of request. These documents are assumed to be kept as ordinary business records and therefore no recordkeeping burden is estimated.
Laminated product producers whose products are exempt from the definition of hardwood plywood will have to keep records demonstrating eligibility for the exemption once that requirement takes effect seven years after the promulgation of the final rule. Since that occurs in the next ICR cycle, there is no burden for this activity during the time period covered by this ICR.
Distributors and importers supply composite wood products, component parts, or finished goods to other firms. The previously approved ICR (EPA ICR #2446.02) estimated that there were 85,559 domestic distributors and importers and 33,249 foreign distributors subject to the TSCA Title VI rule, for a total of 118,808 firms. This analysis retains those estimates.
Distributors that do not import composite wood panels, component parts, or finished goods are only required to maintain invoices, bills of lading, or other similar documents from their suppliers that include a statement that the composite wood products, component parts, or finished goods are TSCA Title VI compliant or were produced before a date one year after the publication of the final rule. These documents are assumed to be kept as ordinary business records and therefore no recordkeeping burden is estimated.
Firms that import composite wood panels, component parts, or finished goods must be able to provide EPA with additional records identifying the panel producer, supplier, date of manufacture, and date of purchase within 30 days of request. These documents are assumed to be kept as ordinary business records and therefore no recordkeeping burden is estimated.
If a finished good (including component parts sold separately) is not individually labeled, the importer or distributor must retain a copy of the label, be able to identify the products associated with that label and make the label information available to potential customers upon request. Following the assumptions in the final rule’s economic analysis, this analysis assumes that compliance is achieved through implementing a labeling system with initial, but no recurring incremental costs.
Note that the TSCA Title VI rule requires importers of articles that are composite wood products, or articles that contain composite wood products, to comply with the TSCA Section 13 import certification regulations for “Chemical Substances in Bulk and As Part of Mixtures and Articles,” as found at 19 CFR 12.118 through 12.127. Thus, any U.S. importer of composite wood products or articles that contain composite wood products must certify that all articles in the shipment either comply with all applicable rules and orders under TSCA or that all the articles in the shipment are not subject to TSCA. The statement must be on or attached to a commercial invoice or entry document belonging to the imported shipment. In practice, import certification is fulfilled by certifying electronically as a matter of course during the standard U.S. Customs and Border Protection’s (CBP) Automated Commercial Environment system. Importers have the option to certify that the shipment complies with TSCA (as applicable) or use a disclaim code to signal to the U.S. CBP and EPA that the TSCA Title VI regulation does not apply to those products. EPA considers these to be certifications, and not an “information” collection within the meaning of the Paperwork Reduction Act.
Retailers sell composite wood products or finished goods directly to consumers. The previously approved ICR (EPA ICR #2446.02) estimated that there were 759,046 domestic and no foreign retailers subject to the TSCA Title VI rule, for a total of 759,046 firms. This analysis retains those estimates.
Retailers that do not import composite wood panels, component parts, or finished goods are only required to maintain invoices, bills of lading, or other similar documents from their suppliers that include a statement that the composite wood products, component parts, or finished goods are TSCA Title VI compliant or were produced before a date one year after the publication of the final rule. These documents are assumed to be kept as ordinary business records and therefore no recordkeeping burden is estimated.
If a finished good (including component parts sold separately) is not individually labeled, the retailer must retain a copy of the label, be able to identify the products associated with that label and make the label information available to potential customers upon request. Following the assumptions in the final rule’s economic analysis, this analysis assumes that compliance is achieved through implementing a labeling system with initial, but no recurring incremental costs.
Accreditation bodies (ABs) verify the competency of third-party certifiers. This analysis maintains the assumptions about ABs from the previous ICR supporting statement (EPA ICR #2446.02), but the start-up and initial burdens and costs from that ICR are excluded since these one-time costs have already been incurred. In addition, this analysis uses the annual average number of activities for activities that do not occur every year. For example, since AB applications to participate in the TSCA Title VI program must be submitted once every three years, this analysis assumes an average of 0.33 application submissions per AB annually.
In the sections below, the burden and cost estimate assumptions and calculations are described for each burden element.
According to current EPA records, there are 4 domestic ABs and 10 foreign ABs participating in the TSCA Title VI program.
Wages are estimated using the U.S. Bureau of Labor Statistics’ Employer Costs for Employee Compensation data for private industry workers. The total compensation for “management, business, and financial” are used for manager labor; total compensation for “professional and related” are used for the technical labor; and total compensation for “office and administrative support” is used for clerical labor. Adding a 17% overhead loading to the respective total compensation values of $66.78, $56.55, $27.02 per hour, results in loaded wages of: $78.13, $66.16, and $31.61 per hour for managerial, technical, and clerical labor, respectively.
Respondents must submit their applications, notifications and reports to EPA using the Central Data Exchange (CDX). When ABs first began participating in the TSCA Title VI program they all incurred one-time burdens to register with CDX and complete a subscriber agreement. During the time period covered by this ICR, some respondents may incur additional burdens to revise their CDX registrations due to employee turnover or compromised electronic signatures. Ten percent of CDX users are assumed to be replaced each year by new employees, who will have to comply with the subscriber agreement and/or CDX registration requirements. It is also assumed that each year one percent of respondents will report a compromised or surrendered electronic signature, which requires the submittal of a new subscriber agreement.
Table 1 shows the labor burden assumptions and calculations for domestic and foreign ABs. The shaded rows are the labor burdens as presented in the previously approved ICR supporting statement (EPA ICR #2446.02). The consolidated domestic and foreign labor burdens in the bottom two rows are calculated by combining the burden hours per activity and the number of annual activities, and summing across the relevant activities. For example, the 0.053 hours of managerial labor burden for domestic ABs is calculated as (0.17*0.1)+(0.25*0.1)+(0.07*0.1)+(0.4*0.01). Note the bottom line burden are converted to be in terms of 1 activity per respondent per year, which is necessary to consolidate the multiple activities previously listed under the CDX Electronic Reporting heading. The bottom line burdens are presented in the IC tables in the main body of this ICR supporting statement.
The total annual labor burden for the respondents is:
0.6 hours for the 4 domestic ABs (=4*0.147); and
1.6 hours for the 10 foreign ABs (=10*0.155).
Applying the wages described above to the labor burdens in Table 1:
Total costs for the 4 domestic ABs combined are $41.44 (=4*(0.094*$66.16 + 0.053*$78.13)); and
Total costs for the 10 foreign ABs combined are $109.85 (=10*(0.094*$66.16 + 0.061*$78.13)).
Table 1: CDX Electronic Recurring Reporting by ABs |
|||||
Activity
|
Per Activity Burden Hours |
|
|
||
Clerical
$78.13/hr |
Technical
$66.16/hr |
Managerial
$31.61/hr |
Number of Annual Activities per Respondent |
Total Burden Hours per Respondent |
|
(a) |
(b) |
(c) |
(d) |
(e) = (d)*[(a)+(b)+(c)] |
|
|
0 |
0.67 |
0.17 |
0.1 |
0.084 |
|
0 |
0 |
0.25 |
0.1 |
0.025 |
|
0 |
0 |
0.33 |
0.1 |
0.033 |
|
0 |
0.27 |
0.07 |
0.1 |
0.034 |
|
0 |
0 |
0.4 |
0.01 |
0.004 |
Domestic Consolidated Burden (Sum of 1, 2, 4, 5) |
0 |
0.094 |
0.053 |
1 |
0.147 |
Foreign Consolidated Burden (Sum of 1, 2, 3, 5) |
0 |
0.094 |
0.061 |
1 |
0.155 |
ABs are required to renew their recognition agreements with EPA every three years. Table 2 shows the labor burden assumptions and calculations for application submission by domestic and foreign ABs. The shaded rows are the labor burdens as presented in the previously approved ICR supporting statement (EPA ICR #2446.02). The consolidated domestic and foreign labor burdens in the bottom row are presented in the IC table in the main body of this ICR supporting statement.
The total average annual burden per respondent is 0.4818 hours, so with 14 ABs, the total labor burden is 6.7 hours (=14*0.4818).
Applying the wages described above to the labor burdens in Table 2, total annual costs for the 14 ABs combined are $476.68 (=14*0.33*(0.91*$66.16 + 0.55*$78.13)).
Table 2: Application Submission for ABs |
|||||
Activity
|
Per Activity Burden Hours |
|
|
||
Clerical
$78.13/hr |
Technical
$66.16/hr |
Managerial
$31.61/hr |
Number of Annual Activities per Respondent |
Total Burden Hours per Respondent |
|
(a) |
(b) |
(c) |
(d) |
(e) = (d)*[(a)+(b)+(c)] |
|
|
0 |
0.04 |
0.02 |
0.33 |
0.02 |
|
0 |
0.04 |
0.02 |
0.33 |
0.02 |
|
0 |
0.83 |
0.51 |
0.33 |
0.442 |
Consolidated Burden |
0 |
0.91 |
0.55 |
0.33 |
0.4818 |
Accreditation bodies are required to notify EPA if they lose signatory status; if they suspend, reduce or withdraw a TPC’s accreditation; or if a TPC fails to comply with its requirements. Table 3 shows the labor burden assumptions and calculations for domestic and foreign ABs. The shaded rows are the labor burdens as presented in the previously approved ICR supporting statement (EPA ICR #2446.02). The consolidated domestic and the foreign burdens presented in the bottom two rows are presented in the IC table in the main body of this ICR supporting statement. Since each sub-activity has the same labor burden, 0.08 technical labor hours and 0.04 managerial labor hours, these sub-activities are consolidated into a single activity by using a labor burden of 0.08 technical labor hours and 0.04 managerial labor hours and summing the numbers of activities (e.g., the 7.41 activities for foreign ABs is the sum of the number of activities listed for sub-activities 1-7 in Table 3).
The total annual labor burden for the respondents is:
3.3 hours for the 4 domestic ABs (=4*0.8292); and
8.9 hours for the 10 foreign ABs (=10*0.8892).
Applying the wages described above to the labor burdens in Table 3:
Total annual costs for the 4 domestic ABs combined are $232.67 (=4*6.91*(0.08*$66.16 + 0.04*$78.13); and
Total annual costs for the 10 foreign ABs combined are $623.77 (=10*7.41*(0.08*$66.16 + 0.04*$78.13).
Table 3: AB Notifications to EPA |
|||||
Activity
|
Per Activity Burden Hours |
|
|
||
Clerical
$78.13/hr |
Technical
$66.16/hr |
Managerial
$31.61/hr |
Number of Annual Activities per Respondent |
Total Burden Hours per Respondent |
|
(a) |
(b) |
(c) |
(d) |
(e) = (d)*[(a)+(b)+(c)] |
|
|
0 |
0.08 |
0.04 |
0.05 |
0.006 |
|
0 |
0.08 |
0.04 |
3 |
0.36 |
|
0 |
0.08 |
0.04 |
3 |
0.36 |
|
0 |
0.08 |
0.04 |
0.33 |
0.0396 |
|
0 |
0.08 |
0.04 |
0.33 |
0.0396 |
|
0 |
0.08 |
0.04 |
0.2 |
0.024 |
|
0 |
0.08 |
0.04 |
0.5 |
0.06 |
Domestic Consolidated Burden (Sum of 1-6) |
0 |
0.08 |
0.04 |
6.91 |
0.8292 |
Foreign Consolidated Burden (Σ 1-7) |
0 |
0.08 |
0.04 |
7.41 |
0.8892 |
Accreditation bodies are required to notify TPCs if the AB withdraws or is removed from the TSCA Title VI program. Table 4 shows the labor burden assumptions and calculations for domestic and foreign ABs. The shaded rows are the labor burdens as presented in the previously approved ICR supporting statement (EPA ICR #2446.02). The consolidated labor burdens in the bottom row are presented in the IC table in the main body of this ICR supporting statement.
The total average annual burden per respondent is 0.015 hours, so with 14 ABs, the total annual labor burden is 0.2 hours (=14*0.015).
Applying the wages described above to the labor burdens in Table 4, total annual costs for the 14 ABs combined are $14.73 (=14*0.25*(0.04*$66.16 + 0.02*$78.13)).
Table 4: AB Notification to Third Party Certifiers |
|||||
Activity
|
Per Activity Burden Hours |
|
|
||
Clerical
$78.13/hr |
Technical
$66.16/hr |
Managerial
$31.61/hr |
Number of Annual Activities per Respondent |
Total Burden Hours per Respondent |
|
(a) |
(b) |
(c) |
(d) |
(e) = (d)*[(a)+(b)+(c)] |
|
Withdraw from or be Removed from Program |
0 |
0.04 |
0.02 |
0.25 |
0.015 |
Accreditation bodies are required to maintain records documenting compliance with on-site assessments, reassessments, and/or surveillance on-site assessments of third-party certifiers. Table 5 shows the labor burden assumptions and calculations for domestic and foreign ABs. The shaded rows are the labor burdens as presented in the previously approved ICR supporting statement (EPA ICR #2446.02). The consolidated labor burdens in the bottom row are presented in the IC table in the main body of this ICR supporting statement.
The total average annual burden per respondent is 3 hours, so with 14 ABs, the total labor burden is 42 hours (=14*3).
Applying the wages described above to the labor burdens in Table 5, total annual costs for the 14 ABs combined are $2,946.30 (=14*2*(1*$66.16 + 0.5*$78.13)).
Table 5: AB Recordkeeping |
|||||
Activity
|
Per Activity Burden Hours |
|
|
||
Clerical
$78.13/hr |
Technical
$66.16/hr |
Managerial
$31.61/hr |
Number of Annual Activities per Respondent |
Total Burden Hours per Respondent |
|
(a) |
(b) |
(c) |
(d) |
(e) = (d)*[(a)+(b)+(c)] |
|
|
0 |
1 |
0.5 |
1 |
1.5 |
|
0 |
1 |
0.5 |
1 |
1.5 |
Consolidated Burden |
0 |
1 |
0.5 |
2 |
3.0 |
EPA-recognized product ABs are required to submit an annual report to EPA including the number and locations of assessment, reassessment, and surveillance on-site assessments performed for each EPA-recognized TPC during the previous calendar year. Table 6 shows the labor burden assumptions and calculations for domestic and foreign ABs. The shaded rows are the labor burdens as presented in the previously approved ICR supporting statement (EPA ICR #2446.02). The consolidated labor burdens in the bottom row are presented in the IC table in the main body of this ICR supporting statement.
The total average annual burden per respondent is 3.75 hours, so with 14 ABs, the total labor burden is 52.2 hours (=14*3.75).
Applying the wages described above to the labor burdens in Table 6, total annual costs for the 14 ABs combined are $3,682.88 (=14*5*(0.5*$66.16 + 0.25*$78.13)).
Table 6: AB Annual Report to EPA |
|||||
Activity
|
Per Activity Burden Hours |
|
|
||
Clerical
$78.13/hr |
Technical
$66.16/hr |
Managerial
$31.61/hr |
Number of Annual Activities per Respondent |
Total Burden Hours per Respondent |
|
(a) |
(b) |
(c) |
(d) |
(e) = (d)*[(a)+(b)+(c)] |
|
|
0 |
0.5 |
0.25 |
1 |
0.75 |
|
0 |
0.5 |
0.25 |
1 |
0.75 |
|
0 |
0.5 |
0.25 |
1 |
0.75 |
|
0 |
0.5 |
0.25 |
1 |
0.75 |
|
0 |
0.5 |
0.25 |
1 |
0.75 |
Consolidated Burden |
0 |
2.5 |
1.25 |
1 |
3.75 |
Foreign ABs are required to designate an agent for service in the United States capable of accepting service of notices and processes made in administrative and judicial proceedings. Since foreign ABs are assumed to already have identified and retained a registered agent, their only costs are assumed to be the annual fee. Fees vary depending on the registered agent, and this analysis assumes an annual cost of $150, which is closer to the higher end of registered agent fees.9
Third-party certifiers (TPCs) are responsible for auditing panel producers, conducting and verifying formaldehyde emissions tests, and ensuring producer’s quality assurance and testing procedures comply with the applicable requirements. For TPCs, this ICR supporting statement analysis maintains the assumptions from the previous ICR supporting statement (EPA ICR #2446.02), but the start-up and initial burdens and costs in that ICR are excluded since those one-time costs have already been incurred. In addition, this analysis uses the annual average number of activities for activities that do not occur every year.
In the sections below, the burden and cost estimate assumptions and calculations are described for each burden element.
According to current EPA records, there are 11 domestic TPCs and 25 foreign TPCs participating in the TSCA Title VI program.
The wage rates for TPC employees are the same as the wage rates for AB employees described above. Wages are estimated using the U.S. Bureau of Labor Statistics’ Employer Costs for Employee Compensation data for private industry workers. The total compensation for “management, business, and financial” are used for manager labor; total compensation for “professional and related” are used for the technical labor; and total compensation for “office and administrative support” is used for clerical labor. Adding a 17% overhead loading to the respective total compensation values of $66.78, $56.55, $27.02 per hour results in loaded wages of: $78.13, $66.16, and $31.61 per hour for managerial, technical, and clerical labor, respectively.
All TPCs spent time in the first year of the TSCA Title VI program completing a subscriber agreement and registering with CDX. Some TPCs will also spend time on CDX registration in subsequent years due to employee turnover or compromised electronic signatures. Table 8 shows the labor burden assumptions and calculations for domestic and foreign TPCs. The shaded rows are the labor burdens presented in the previously approved ICR supporting statement (EPA ICR #2446.02). The consolidated domestic and foreign labor burdens in the bottom rows are presented in the IC table in the main body of this ICR supporting statement.
The total annual labor burden for the respondents is:
1.6 hours for the 11 domestic TPCs (=11*0.147); and
3.9 hours for the 25 foreign TPCs (=25*0.155).
Applying the wages described above to the labor burdens in Table 8:
Total annual costs for the 11 domestic TPCs combined are $113.96 (=11* (0.094*$66.16 + 0.053*$78.13); and
Total annual costs for the 25 foreign TPCs combined are $274.62 (=25* (0.094*$66.16 + 0.061*$78.13)).
Table 8: CDX Electronic Recurring Reporting by TPCs |
|||||
Activity
|
Per Activity Burden Hours |
|
|
||
Clerical
$78.13/hr |
Technical
$66.16/hr |
Managerial
$31.61/hr |
Number of Annual Activities per Respondent |
Total Burden Hours per Respondent |
|
(a) |
(b) |
(c) |
(d) |
(e) = (d)*[(a)+(b)+(c)] |
|
|
0 |
0.67 |
0.17 |
0.1 |
0.084 |
|
0 |
0 |
0.25 |
0.1 |
0.025 |
|
0 |
0 |
0.33 |
0.1 |
0.033 |
|
0 |
0.27 |
0.07 |
0.1 |
0.034 |
|
0 |
0 |
0.4 |
0.01 |
0.004 |
Domestic Consolidated Burden (1, 2, 4, 5) |
0 |
0.094 |
0.053 |
1 |
0.147 |
Foreign Consolidated Burden (1, 2, 3, 5) |
0 |
0.094 |
0.061 |
1 |
0.155 |
TPCs must provide their TPC number to panel producers they certify, and notify the panel producer if they fail a quarterly test or if the TPC withdraws from the TSCA Title VI program or loses its accreditation. Table 9 shows the labor burden assumptions and calculations for domestic and foreign TPCs. The shaded rows are the labor burdens presented in the previously approved ICR supporting statement (EPA ICR #2446.02). The consolidated labor burdens in the bottom row are presented in the IC table in the main body of this ICR supporting statement.
The total average annual burden per respondent is 0.075 hours, so with 36 TPCs, the total annual labor burden is 2.7 hours (=36*0.075).
Applying the wages described above to the labor burdens in Table 9, total annual costs for the 36 TPCs combined are $189.41 (=36*1.25*(0.04*$66.16 + 0.02*$78.13)).
Table 9: TPC Notifications to Manufacturers |
|||||
Activity
|
Per Activity Burden Hours |
|
|
||
Clerical
$78.13/hr |
Technical
$66.16/hr |
Managerial
$31.61/hr |
Number of Annual Activities per Respondent |
Total Burden Hours per Respondent |
|
(a) |
(b) |
(c) |
(d) |
(e) = (d)*[(a)+(b)+(c)] |
|
|
0 |
0.04 |
0.02 |
1 |
0.06 |
|
0 |
0.04 |
0.02 |
0.25 |
0.015 |
Consolidated Burden |
0 |
0.04 |
0.02 |
1.25 |
0.075 |
Third-party certifiers are required to retain records on the results of inspections and audits, and emission tests conducted for each panel producer, a list of panel producers that it has certified and their respective product types, a list of laboratories that it uses, test methods, and test results, methods and results for establishing test method correlations, and a copy of the most recent assessment report conducted by its EPA-recognized accreditation body. Table 10 shows the labor burden assumptions and calculations for domestic and foreign TPCs. The shaded rows are the labor burdens presented in the previously approved ICR supporting statement (EPA ICR #2446.02). The consolidated labor burdens in the bottom row are presented in the IC table in the main body of this ICR supporting statement.
The total average annual burden per respondent is 9 hours, so with 36 TPCs, the total annual labor burden is 324 hours (=36*9).
Applying the wages described above to the labor burdens in Table 10, total annual costs for the 36 TPCs combined are $22,728.60 (=36*(6*$66.16 + 3*$78.13)).
Table 10: TPC Recordkeeping |
|||||
Activity
|
Per Activity Burden Hours |
|
|
||
Clerical
$78.13/hr |
Technical
$66.16/hr |
Managerial
$31.61/hr |
Number of Annual Activities per Respondent |
Total Burden Hours per Respondent |
|
(a) |
(b) |
(c) |
(d) |
(e) = (d)*[(a)+(b)+(c)] |
|
|
0 |
1 |
0.5 |
1 |
1.5 |
|
0 |
1 |
0.5 |
1 |
1.5 |
|
0 |
1 |
0.5 |
1 |
1.5 |
|
0 |
1 |
0.5 |
1 |
1.5 |
|
0 |
1 |
0.5 |
1 |
1.5 |
|
0 |
1 |
0.5 |
1 |
1.5 |
Consolidated Burden |
0 |
6 |
3 |
1 |
9 |
TPCs are required to submit an annual report to EPA that includes: 1) A list of panel producers that the certifier has certified during the previous year and their products, including resins used and the average and range of formaldehyde emissions by panel producer, resin, and product type; 2) A list of any noncomplying products or events by a panel producer; 3) A list of laboratories and test methods used by the certifier; and 4) the results of inter-laboratory comparison or proficiency testing for the laboratories used by the certifier. Table 11 shows the labor burden assumptions and calculations for domestic and foreign TPCs. The shaded rows are the labor burdens presented in the previously approved ICR supporting statement (EPA ICR #2446.02). The consolidated labor burdens in the bottom row are presented in the IC table in the main body of this ICR supporting statement.
The total average annual burden per respondent is 3 hours, so with 36 TPCs, the total annual labor burden is 108 hours (=36*3).
Applying the wages described above to the labor burdens in Table 11, total annual costs for the 36 TPCs combined are $7,576.20 (=36*(2*$66.16 + 1*$78.13)).
Table 11: TPC Annual Reports to EPA |
|||||
Activity
|
Per Activity Burden Hours |
|
|
||
Clerical
$78.13/hr |
Technical
$66.16/hr |
Managerial
$31.61/hr |
Number of Annual Activities per Respondent |
Total Burden Hours per Respondent |
|
(a) |
(b) |
(c) |
(d) |
(e) = (d)*[(a)+(b)+(c)] |
|
|
0 |
0.5 |
0.25 |
1 |
0.75 |
|
0 |
0.5 |
0.25 |
1 |
0.75 |
|
0 |
0.5 |
0.25 |
1 |
0.75 |
|
0 |
0.5 |
0.25 |
1 |
0.75 |
Consolidated Burden |
0 |
2 |
1 |
1 |
3 |
TPCs must notify their AB of any changes in personnel qualifications, procedures, or laboratories used. Table 12 shows the labor burden assumptions and calculations for domestic and foreign TPCs. The shaded rows are the labor burdens presented in the previously approved ICR supporting statement (EPA ICR #2446.02). The consolidated labor burdens in the bottom row are presented in the IC table in the main body of this ICR supporting statement.
The total average annual burden per respondent is 0.09 hours, so with 36 TPCs, the total annual labor burden is 3.2 hours (=36*0.09).
Applying the wages described above to the labor burdens in Table 12, total annual costs for the 36 TPCs combined are $227.29 (=36*1.5*(0.04*$66.16 + 0.02*$78.13)).
Table 12: TPC Notifications to ABs |
|||||
Activity
|
Per Activity Burden Hours |
|
|
||
Clerical
$78.13/hr |
Technical
$66.16/hr |
Managerial
$31.61/hr |
Number of Annual Activities per Respondent |
Total Burden Hours per Respondent |
|
(a) |
(b) |
(c) |
(d) |
(e) = (d)*[(a)+(b)+(c)] |
|
|
0 |
0.04 |
0.02 |
0.5 |
0.03 |
|
0 |
0.04 |
0.02 |
0.5 |
0.03 |
|
0 |
0.04 |
0.02 |
0.5 |
0.03 |
Consolidated Burden |
0 |
0.04 |
0.02 |
1.5 |
0.09 |
If a TPC approves an application for reduced testing, it must forward copies of the application to EPA. If requested, TPCs must provide EPA with checklists and other records documenting compliance with the requirements for systems audits and on-site assessments of third-party certifiers. Table 13 shows the labor burden assumptions and calculations for domestic and foreign TPCs. The shaded rows are the labor burdens presented in the previously approved ICR supporting statement (EPA ICR #2446.02). The consolidated labor burdens in the bottom row are presented in the IC table in the main body of this ICR supporting statement.
The total average annual burden per respondent is 0.06 hours, so with 36 TPCs, the total annual labor burden is 2.2 hours (=36*0.06).
Applying the wages described above to the labor burdens in Table 13, total annual costs for the 36 TPCs combined are $151.52 (=36* (0.04*$66.16 + 0.02*$78.13)).
Table 13: TPC Notifications to EPA |
|||||
Activity
|
Per Activity Burden Hours |
|
|
||
Clerical
$78.13/hr |
Technical
$66.16/hr |
Managerial
$31.61/hr |
Number of Annual Activities per Respondent |
Total Burden Hours per Respondent |
|
(a) |
(b) |
(c) |
(d) |
(e) = (d)*[(a)+(b)+(c)] |
|
|
0 |
0.04 |
0.02 |
0.5 |
0.03 |
|
0 |
0.04 |
0.02 |
0.5 |
0.03 |
Consolidated Burden |
0 |
0.04 |
0.02 |
1 |
0.06 |
Foreign TPCs are required to designate an agent for service in the United States capable of accepting service of notices and processes made in administrative and judicial proceedings. Since foreign ABs are assumed to already have identified and retained a registered agent, their only costs are assumed to be the annual fee. Fees vary depending on the registered agent, and this analysis assumes an annual cost of $150, which is closer to the higher end of registered agent fees.10
1 The number of producers of each product type (757, 293 and 196) sums to more than the total number of producers (1,204) because some produce more than one product type (e.g., both MDF and particleboard).
2 See Economic Analysis of the Formaldehyde Standards for Composite Wood Products Act Final Rule. U.S. Environmental Protection Agency, July 2016.
3 All U.S. MDF and particleboard producers already had a TPC prior to the TSCA Title VI rule, although some particleboard producers did not have all their products certified. See Economic Analysis of the Formaldehyde Standards for Composite Wood Products Act Final Rule. U.S. Environmental Protection Agency, July 2016.
4This analysis multiplies 48 and 709 by 26.8% and rounds up to the nearest whole number. Note that the previous ICR (EPA ICR #2446.02) estimated that the number of baseline uncertified mills is 20% of the baseline certified mills and also assumed that 26.8% of the remaining 80% also incurred these costs. Since it does not seem sensible to assume that foreign mills have a higher rate of baseline compliance, this analysis assumes that foreign mills have the same rate of baseline compliance as domestic mills.
5 HPVA subsequently changed its name to the Decorative Hardwoods Association
6 This analysis multiplies 11 and 164 by 16.7% and rounds up to the nearest whole number to get 4 and 29 domestic and foreign mills, respectively.
7 Note that the 2016 economic analysis used a shipping cost of $8 (in 2013$) , which was the same cost estimated to ship samples for quality control testing. Since shipping 4’ by 8’ panels is expected to be more expensive than shipping the much smaller samples used for quality control testing, this analysis instead uses a $50 cost for shipping full panels for quarterly testing).
8 This element was labeled “CDX Electronic Reporting (Subsequent Years)” in the previously approved ICR supporting statement (EPA ICR #2446.02).
9 The web site for one registered agent firm lists charges of $120 for the first year and $169 for subsequent years; the web site for another registered agent firm lists charges of $89 for 1 year and $60/year for 5 years.
10 The web site for one registered agent firm lists charges of $120 for the first year and $169 for subsequent years; the web site for another registered agent firm lists charges of $89 for 1 year and $60/year for 5 years.
Page
3-
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Coleman, Todd |
| File Modified | 0000-00-00 |
| File Created | 2021-01-14 |