Burden Calculation Tables

ATTACHMENT C
Work Sheets used to Calculate Respondent & Agency Labor Costs
This attachment is available as part of the electronic docket EPA-HQ-OPP-2024-0139 and is part of the
ICR’s Supporting Statement.

Respondent Labor Costs
Pesticide Registrants1 (NAICS: 3250A1)

Labor Category2
Item
Unloaded Hourly Rate

Formula

Managerial

Technical

Clerical

=W

$76.32

$41.48

$28.16

Lb = B/W

45.2%

45.2%

45.2%

$34.46

$18.73

$12.72

$110.78

$60.21

$40.88

1

Benefits Percentage3
Benefits per hour

B = W*Lb

Loaded Hourly Rate

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

Overhead Percentage4

Lo = OH/Wb

50%

50%

50%

Overhead per hour

OH = Wb*Lo

$55.39

$30.11

$20.44

Wf = Wb + OH = W + B + OH

$166.18

$90.32

$61.31

Fully Loaded Hourly Rate

1. Source: Bureau of Labor Statistics, NAICS 3250A1 - Pesticide, Fertilizer, and Other Agricultural Chemical
Manufacturing, 2023 data, Accessed April 2024, https://www.bls.gov/oes/home.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. Fringe benefits/wage per hour. The average for non-farm, non-federal civilian workers.
https://www.bls.gov/oes/home.htm
4. U.S. Environmental Protection Agency, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA-45202-001, 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)

Labor Category2
Item
Unloaded Hourly Rate1
Unloaded Yearly Wage
($/year)
Benefits Percentage3
Benefits per year
Loaded Yearly Wage
($/year)
Overhead Percentage4
Overhead per Wage
($/year)
Fully Loaded Yearly
Wage ($/year)

Formula

=W
= W * 2080 (52wks * 40hrs)

Managerial

Technical5

Clerical

$69.38

$46.73

$25.27

n/a

$97,198

n/a

Lb = B/W

45.2%

B = W*Lb

$43,893.05

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

$141,091.45

Lo = OH/Wb

50%

OH = Wb*Lo

$70,545.72

Wf = Wb + OH = W + B + OH

$211,637.17

1. Source: Bureau of Labor Statistics, NAICS 999100 - Federal Executive Branch, 2023 data, Accessed April
2024, https://www.bls.gov/oes/home.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. Fringe benefits/wage per hour. The average for non-farm, non-federal civilian workers.
https://www.bls.gov/oes/home.htm
4. U.S. Environmental Protection Agency, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA-45202-001, 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 Yearly Wage will be multiplied by the number of FTEs (full time
equivalents) to get the labor cost component of the annual Agency burden.