Base Wages[a]
Fringe Benefitsa + Overhead Factor[b]
Loaded Wages
Attorney
                                    $58.28
                                      1.6
                                    $93.25
Professional/Technical
                                    $49.32
                                      1.6
                                    $78.91
Notes:
[a] Wage rates and fringe benefits are calculated using the January 2015 estimates from OPM (2015)
[b] The 60% fringe-and-overhead rate is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (EPA, 1992, page 30, footnote 9)

Unit Agency Costs
EPA will incur costs in administering the rule. The rule requires EPA to provide industry and public assistance (e.g., provide guidance and facilitate compliance), process submitted reports, and maintain the information technology systems that support these activities. Based on previous estimates of Agency time used in economic analyses of Preliminary Assessment Information Reporting (PAIR) rules, which require Agency activity similar to that required under the rule, it is estimated to take 1.5 labor hours per report to provide industry and public assistance and 3.75 labor hours per report to provide data processing and systems support for a total of 5.25 labor hours per report (EPA, 2003a) when the reporting is accomplished through non-electronic reporting. However, the electronic reporting required by the rule is expected to result in cost savings to EPA. This analysis used the same methodology as that in the Economic Analysis of the Premanufacture Notification Electronic Reporting Final Rule (EPA, 2009a) to calculate EPA burden savings from electronic reporting. Potential Agency burden savings associated with the electronic reporting of the respective TSCA reports were characterized based on information in the CDX Business Case Analysis regarding the estimated monetary benefit from using CDX. Of the six Program Data Flows studied in the CDX Business Case Analysis, monetary benefits from using CDX as compared to a paper submission baseline were quantified for two flows: TRI (Toxic Release Inventory) and e-NOI (electronic Notice of Intent under the National Pollution Discharge Elimination System). Benefits ranged from eleven percent savings (e-NOI) to 22 percent savings (TRI) compared to the cost of the baseline process. For this analysis, EPA assumed an average annual savings of 16.5 percent. Applying the 16.5 percent annual savings to burden estimates described above results in an estimated 1.25 per report for providing industry and public assistance and 3.13 per report for data processing and systems support.
Under the Frank R. Lautenberg Chemical Safety for the 21[st] Century Act, EPA must review a number of the CBI claims received, including some associated with submissions under this rule, within 90 days after receipt. EPA estimates that it will take 8 hours (6 attorney hours and 2 technical staff hours) to review each CBI claim substantiation submission and make a confidentiality determination. This is based on the estimate for reviewing CBI substantiation letters and making final confidentiality determinations under 4 CFR part 2, as described in EPA ICR No. 1665.12 (OMB Control No 2020-0003) (EPA, 2013). Under the Act, EPA must review 100 percent of claims related to chemical identity, and at least 25 percent (a representative sample) of all other claims where substantiation is required. EPA assumes that there will be no claims for chemical identity, as the materials subject to this rule are existing chemicals and would already either have a non-CBI identity or would have an established generic identity. EPA assumes that each report claims CBI, therefore EPA must review 25 percent of reports. Therefore, per report received, the EPA labor is 2 hours (6 x 0.25 = 1.5 attorney hours and 2 x 0.25 = 0.5 technical staff hours).
As shown in Table 4-2, EPA estimated a total cost of approximately $525 to administer and process a chemical report.
Table 4-2: Agency Cost Estimate to Administer the Rule (per report)
                                 EPA Activity
                       Technical Labor
(at $78.91/hour)
                       Attorney Labor
(at $93.25/ hour)
                               Total Labor Cost

                                    Burden
                                     Cost
                                    Burden
                                     Cost
                                    Burden
                                     Cost
Industry/Public Assistance
                                     1.25
                                      $99
                                       0
                                      $0
                                     1.25
                                      $99
Data Processing and Systems Support
                                     3.13
                                     $247
                                       0
                                      $0
                                     3.13
                                     $247
Review of CBI claim substantiations
                                      0.5
                                      $39
                                      1.5
                                     $140
                                       2
                                     $179
Total
                                     4.88
                                     $385
                                      1.5
                                     $140
                                     6.38
                                     $525
Source: EPA, 2003a; EPA, 2013; OPM, 2015.

As explained in Chapter 3, approximately 2,559 chemical reports will be filed in the first year of the rule and 285 reports in subsequent years. As shown in Table 4-3, the total Agency hours and costs for the rule are estimated to total 16,326 hours and $1.34 million in the first year of the rule before decreasing to 1,818 hours and $0.15 million in subsequent years. The annualized costs of the rule over the 10-year analysis period are $0.26 million with a three percent discount rate and $0.29 million with a seven percent discount rate.
Table 4-3: Agency Cost and Burden Hour Estimate for the Final Rule
                                     Year
                               Hours per Report
                            Agency Cost per Report
                                    (2015$)
                            Total Number of Reports
                                     Total
                       Discounted Cost
(Millions 2015$)

                                     Hours
                             Cost (Millions 2015$)
                               3% Discount Rate
                               7% Discount Rate
                                       1
                                     6.38
                                     $525
                                     2,559
                                    16,326
                                    $1.34
                                    $1.34
                                    $1.34
                                       2
                                     6.38
                                     $525
                                      285
                                     1,818
                                    $0.15
                                    $0.15
                                    $0.14
                                       3
                                     6.38
                                     $525
                                      285
                                     1,818
                                    $0.15
                                    $0.14
                                    $0.13
                                       4
                                     6.38
                                     $525
                                      285
                                     1,818
                                    $0.15
                                    $0.14
                                    $0.12
                                       5
                                     6.38
                                     $525
                                      285
                                     1,818
                                    $0.15
                                    $0.13
                                    $0.11
                                       6
                                     6.38
                                     $525
                                      285
                                     1,818
                                    $0.15
                                    $0.13
                                    $0.11
                                       7
                                     6.38
                                     $525
                                      285
                                     1,818
                                    $0.15
                                    $0.13
                                    $0.10
                                       8
                                     6.38
                                     $525
                                      285
                                     1,818
                                    $0.15
                                    $0.12
                                    $0.09
                                       9
                                     6.38
                                     $525
                                      285
                                     1,818
                                    $0.15
                                    $0.12
                                    $0.09
                                      10
                                     6.38
                                     $525
                                      285
                                     1,818
                                    $0.15
                                    $0.11
                                    $0.08
                                     Total
                                     63.80

                                     5,124
                                    32,688
                                     $2.69
                                       -
                                       -
                                                                Annualized Cost
                                    $0.26
                                    $0.29
Source: EPA, 2003a; EPA, 2013; OPM, 2013

  -  Total Social Costs and Sensitivity Analyses
Table 5-1 presents the total social burden and costs of the rule in the first and subsequent years, and the annualized costs discounted over the 10-year period using three and seven percent discount rates. As indicated, the total burden of the rule is expected to be approximately 754,081 hours over the 10-year analysis period, while the annualized costs are expected to be from approximately $5.71 million with a three percent discount rate and approximately $6.26 million with a seven percent discount rate.
Table 5-1: Total Social Burden and Cost of the Rule
                                     Year
                                Burden (Hours)
                           Discounted Costs (2015$)

                               3 % Discount Rate
                               7 % Discount Rate

                                   Industry
                                    Agency
                                     Total
                                   Industry
                                    Agency
                                     Total
                                   Industry
                                    Agency
                                     Total
                                       1
                                    360,331
                                    16,326
                                    376,657
                                    $27.79
                                    $1.34
                                    $29.13
                                    $27.79
                                    $1.34
                                    $29.13
                                       2
                                    40,118
                                     1,818
                                    41,936
                                    $3.00
                                    $0.15
                                    $3.15
                                    $2.89
                                    $0.14
                                    $3.03
                                       3
                                    40,118
                                     1,818
                                    41,936
                                    $2.92
                                    $0.14
                                    $3.06
                                    $2.70
                                    $0.13
                                    $2.83
                                       4
                                    40,118
                                     1,818
                                    41,936
                                    $2.83
                                    $0.14
                                    $2.97
                                    $2.53
                                    $0.12
                                    $2.65
                                       5
                                    40,118
                                     1,818
                                    41,936
                                    $2.75
                                    $0.13
                                    $2.88
                                    $2.36
                                    $0.11
                                    $2.47
                                       6
                                    40,118
                                     1,818
                                    41,936
                                    $2.67
                                    $0.13
                                    $2.80
                                    $2.21
                                    $0.11
                                    $2.32
                                       7
                                    40,118
                                     1,818
                                    41,936
                                    $2.59
                                    $0.13
                                    $2.72
                                    $2.06
                                    $0.10
                                    $2.16
                                       8
                                    40,118
                                     1,818
                                    41,936
                                    $2.52
                                    $0.12
                                    $2.64
                                    $1.93
                                    $0.09
                                    $2.02
                                       9
                                    40,118
                                     1,818
                                    41,936
                                    $2.44
                                    $0.12
                                    $2.56
                                    $1.80
                                    $0.09
                                    $1.89
                                      10
                                    40,118
                                     1,818
                                    41,936
                                    $2.37
                                    $0.11
                                    $2.48
                                    $1.68
                                    $0.08
                                    $1.76
                                     Total
                                    721,393
                                    32,688
                                    754,081
                                       -
                                                               Annualized Costs
                                    $5.44
                                    $0.26
                                    $5.71
                                    $5.98
                                    $0.29
                                    $6.26
Source: EPA, 2003a; OPM, 2015

 - Sensitivity Analyses
To show the possible range of costs and burden associated with the rule, EPA conducted several alternative analyses that estimate how sensitive the cost and burden estimates presented in Chapter 3 and Chapter 4 are to changes in the estimated number of nanoscale materials and firms subject to the rule. EPA conducted four sensitivity analyses, estimating: (1) a low and high cost based on a range of number of firms subject to the rule; (2) costs based on a potential growth in the number of firms subject to the rule over the 10 year period; (3) a low and high cost based on the range of number of reports submitted by a manufacturer in year one; and (4) a low and high cost based the growth rate of the number of nanomaterials over the ten year period
Number of Firms
Low and High-end Estimates for the Number of Firms Subject to the Rule
As described in Section 2.4, this economic analysis estimates there to be 165 manufacturers and 1,788 processors subject to the rule in the first year, for a total of 1,953 firms. In the second year, the number of processors drops to 199, for a total of 364 firms. As an alternative analysis, EPA examined costs associated with the rule for a wider range of number of affected firms.
Manufacturers. The number of manufacturers was based on BCC Research (2008)'s estimate of companies worldwide with "nanotechnology activities", and a percentage of their sampled companies that were determined to be specifically involved in the manufacturing business (75.76 percent). For the sensitivity analysis, EPA estimated costs associated with the rule assuming a 100 percent (high-end) rate and a 50 percent (low-end) rate for companies that are specifically involved in nanomaterials manufacturing.
Therefore, multiplying the estimated total number of nanotechnology companies worldwide (1,600) by the percent of the sample that are based in the U.S. (67.88 percent), by the percent that have greater than $11 million in sales (21 percent) and by the percent of the sample that are nanomaterials manufacturers (100 or 50 percent) suggests an estimated range of 114 to 228 U.S. nanoscale manufacturers for this sensitivity analysis.
Processors. .For the main analysis, EPA estimated the number of processors per nanomaterial at 2.32. For this sensitivity analysis, we assume a low-end estimate of one processor per nanomaterial. For the high-end estimate, we assume more than double our main analysis estimate, at five processors per nanomaterial. By calculating the number of regulated processors as described in Section 2.3 (Table 2-4), this results in a low-end estimate of 771 for the first year and 86 for subsequent years, and a high-end estimate of 3,853 for the first year and 429 for subsequent years.
Total. The total number of firms under the low- and high-end estimates are summarized in Table 6-1.

Table 6-1: Low- and High-end Estimates of Number of Firms
                              Population Category
                               Low-end Estimate
                               High-end Estimate

                                  First year
                               Subsequent years
                                  First year
                               Subsequent years
Manufacturers
                                      114
                                      114
                                      228
                                      228
Processors
                                      771
                                      86
                                     3,853
                                      429
Total
                                      885
                                      200
                                     4,081
                                      657

Industry, Agency, and Total Costs
Low-end estimates. Based on the low-end estimate of firms, the number of reports estimated in Chapter 2, and burden estimates derived in Section 3.2, the total industry burden is 183,166 hours in the first year and 20,354 hours in future years, with an annualized cost of $2.75 million with a 3 percent discount rate ($3.02 with a 7 percent discount rate). Table 6-2 and Table 6-3 present these industry cost and burden estimates.
Table 6-4 shows the Agency burden low-end estimate of 8,313 hours in the first year and 926 hours each subsequent year, and the annualized cost of estimates of $0.13 million with a 3 percent discount rate ($0.15 million with a 7 percent discount rate).
Table 6-5 presents the total low-end social costs of $2.88 million with a 3 percent discount rate and $3.17 million with a 7 percent discount rate.
High-end estimates. Using the high end estimate of firms, the industry burden is 693,200 hours in the first year and 77,227 hours in each subsequent year, with an annualized cost of $10.39 million with a 3 percent discount rate ($11.40 with a 7 percent discount rate). The industry burden and cost estimates are presented in Table 6-2 and Table 6-3 respectively.
Table 6-4 presents the total Agency high-end burden estimate of 31,374 hours in the first year and 3,493 hours in each subsequent year, and the annualized Agency cost estimate of $0.51 million with a 3 percent discount rate ($0.55 with a 7 percent discount rate).
Table 6-5 contains the total social costs and burden of using the high end-estimate. The total social burden is 1.5 million hours over the ten year period, and the annualized cost is $10.89 million with a 3 percent discount rate and $11.96 with a 7 percent discount rate.

Table 6-2: Total Annual Industry Burden Hours (Number of Firms Sensitivity Analysis)
                                     Year
                                Number of Firms
                               Reports per Firm
                    Rule Familiarization Burden
(per Firm)
  Form Completion, CBI Substantiation, and Recordkeeping Burden (per Report)
                     Electronic Reporting Costs (per Firm)
                             Total Burden Per Firm
                       Total Industry Number of Reports
                             Total Industry Burden

                                      Low
                                     High

                                      Low
                                     High
                                      Low
                                     High
Manufacturers
                                       1
                                      114
                                      228
                                     4.67
                                     0.82
                                      139
                                     1.42
                                      652
                                      532
                                     1,065
                                    74,257
                                    148,652
                                       2
                                      114
                                      228
                                     0.52
                                     0.00
                                      139
                                     0.17
                                      73
                                      59
                                      119
                                     8,227
                                    16,593
                                       3
                                      114
                                      228
                                     0.52
                                     0.00
                                      139
                                     0.17
                                      73
                                      59
                                      119
                                     8,227
                                    16,593
                                       4
                                      114
                                      228
                                     0.52
                                     0.00
                                      139
                                     0.17
                                      73
                                      59
                                      119
                                     8,227
                                    16,593
                                       5
                                      114
                                      228
                                     0.52
                                     0.00
                                      139
                                     0.17
                                      73
                                      59
                                      119
                                     8,227
                                    16,593
                                       6
                                      114
                                      228
                                     0.52
                                     0.00
                                      139
                                     0.17
                                      73
                                      59
                                      119
                                     8,227
                                    16,593
                                       7
                                      114
                                      228
                                     0.52
                                     0.00
                                      139
                                     0.17
                                      73
                                      59
                                      119
                                     8,227
                                    16,593
                                       8
                                      114
                                      228
                                     0.52
                                     0.00
                                      139
                                     0.17
                                      73
                                      59
                                      119
                                     8,227
                                    16,593
                                       9
                                      114
                                      228
                                     0.52
                                     0.00
                                      139
                                     0.17
                                      73
                                      59
                                      119
                                     8,227
                                    16,593
                                      10
                                      114
                                      228
                                     0.52
                                     0.00
                                      139
                                     0.17
                                      73
                                      59
                                      119
                                     8,227
                                    16,593
Processors
                                       1
                                      771
                                     3,853
                                       1
                                     0.82
                                      139
                                     1.42
                                      141
                                      771
                                     3,853
                                    108,910
                                    544,548
                                       2
                                      86
                                      429
                                       1
                                     0.82
                                      139
                                     1.42
                                      141
                                      86
                                      429
                                    12,127
                                    60,635
                                       3
                                      86
                                      429
                                       1
                                     0.82
                                      139
                                     1.42
                                      141
                                      86
                                      429
                                    12,127
                                    60,635
                                       4
                                      86
                                      429
                                       1
                                     0.82
                                      139
                                     1.42
                                      141
                                      86
                                      429
                                    12,127
                                    60,635
                                       5
                                      86
                                      429
                                       1
                                     0.82
                                      139
                                     1.42
                                      141
                                      86
                                      429
                                    12,127
                                    60,635
                                       6
                                      86
                                      429
                                       1
                                     0.82
                                      139
                                     1.42
                                      141
                                      86
                                      429
                                    12,127
                                    60,635
                                       7
                                      86
                                      429
                                       1
                                     0.82
                                      139
                                     1.42
                                      141
                                      86
                                      429
                                    12,127
                                    60,635
                                       8
                                      86
                                      429
                                       1
                                     0.82
                                      139
                                     1.42
                                      141
                                      86
                                      429
                                    12,127
                                    60,635
                                       9
                                      86
                                      429
                                       1
                                     0.82
                                      139
                                     1.42
                                      141
                                      86
                                      429
                                    12,127
                                    60,635
                                      10
                                      86
                                      429
                                       1
                                     0.82
                                      139
                                     1.42
                                      141
                                      86
                                      429
                                    12,127
                                    60,635

Table 6-3: Total Annual Industry Cost (Number of Firms Sensitivity Analysis)
                                     Year
                               Number of Firmsa
                               Reports per Firm
                     Rule Familiar-ization Cost (per Firm)
        Form Compltn, CBI Subst, and Record-keeping Cost (per Report)d
                     Electronic Reporting Cost (per Firm)e
                             Total Cost (per Firm)
                          Discounted Cost (Per Firm)
                       Total Industry Number of Reportsb
                     Total Industry Cost (Millions 2015$)
                           Industry Discounted Cost

                               (Millions 2015$)

                               3 % Discount Rate
                               7 % Discount Rate

                               3 % Discount Rate
                               7 % Discount Rate

                                      Low
                                     High

                                      Low
                                      High
                                      Low
                                      High
                                      Low
                                     High
                                      Low
                                      High
Manufacturers
                                       1
                                      114
                                      228
                                     4.67
                                    $63.66
                                   $10,730
                                   $110.31
                                   $50,285
                                   $50,285
                                   $50,285
                                      532
                                     1,065
                                    $5.73
                                    $11.46
                                    $5.72
                                    $11.44
                                    $5.72
                                                                          $11.4
                                       2
                                      114
                                      228
                                     0.52
                                    $0.00
                                   $10,730
                                    $13.41
                                    $5,593
                                    $5,430
                                    $5,227
                                      59
                                      119
                                    $0.64
                                    $1.28
                                    $0.62
                                    $1.24
                                    $0.59
                                                                          $1.19
                                       3
                                      114
                                      228
                                     0.52
                                    $0.00
                                   $10,730
                                    $13.41
                                    $5,593
                                    $5,272
                                    $4,885
                                      59
                                      119
                                    $0.64
                                    $1.28
                                    $0.60
                                    $1.20
                                    $0.56
                                                                          $1.11
                                       4
                                      114
                                      228
                                     0.52
                                    $0.00
                                   $10,730
                                    $13.41
                                    $5,593
                                    $5,119
                                    $4,566
                                      59
                                      119
                                    $0.64
                                    $1.28
                                    $0.58
                                    $1.16
                                    $0.52
                                                                          $1.04
                                       5
                                      114
                                      228
                                     0.52
                                    $0.00
                                   $10,730
                                    $13.41
                                    $5,593
                                    $4,970
                                    $4,267
                                      59
                                      119
                                    $0.64
                                    $1.28
                                    $0.57
                                    $1.13
                                    $0.49
                                                                          $0.97
                                       6
                                      114
                                      228
                                     0.52
                                    $0.00
                                   $10,730
                                    $13.41
                                    $5,593
                                    $4,825
                                    $3,988
                                      59
                                      119
                                    $0.64
                                    $1.28
                                    $0.55
                                    $1.10
                                    $0.45
                                                                          $0.91
                                       7
                                      114
                                      228
                                     0.52
                                    $0.00
                                   $10,730
                                    $13.41
                                    $5,593
                                    $4,684
                                    $3,727
                                      59
                                      119
                                    $0.64
                                    $1.28
                                    $0.53
                                    $1.07
                                    $0.42
                                                                          $0.85
                                       8
                                      114
                                      228
                                     0.52
                                    $0.00
                                   $10,730
                                    $13.41
                                    $5,593
                                    $4,548
                                    $3,483
                                      59
                                      119
                                    $0.64
                                    $1.28
                                    $0.52
                                    $1.03
                                    $0.40
                                                                          $0.79
                                       9
                                      114
                                      228
                                     0.52
                                    $0.00
                                   $10,730
                                    $13.41
                                    $5,593
                                    $4,415
                                    $3,255
                                      59
                                      119
                                    $0.64
                                    $1.28
                                    $0.50
                                    $1.00
                                    $0.37
                                                                          $0.74
                                      10
                                      114
                                      228
                                     0.52
                                    $0.00
                                   $10,730
                                    $13.41
                                    $5,593
                                    $4,287
                                    $3,042
                                      59
                                      119
                                    $0.64
                                    $1.28
                                    $0.49
                                    $0.98
                                    $0.35
                                                                          $0.69
Processors
                                       1
                                      771
                                     3,853
                                       1
                                    $63.66
                                    $10,730
                                    $110.31
                                   $10,904
                                   $10,904
                                   $10,904
                                      771
                                     3,853
                                    $8.40
                                    $42.01
                                    $8.32
                                    $41.59
                                    $8.32
                                                                         $41.59
                                       2
                                      86
                                      429
                                       1
                                    $63.66
                                    $10,730
                                    $110.31
                                   $10,904
                                   $10,587
                                   $10,191
                                      86
                                      429
                                    $0.94
                                    $4.68
                                    $0.90
                                    $4.50
                                    $0.87
                                                                          $4.33
                                       3
                                      86
                                      429
                                       1
                                    $63.66
                                    $10,730
                                    $110.31
                                   $10,904
                                   $10,278
                                    $9,524
                                      86
                                      429
                                    $0.94
                                    $4.68
                                    $0.87
                                    $4.36
                                    $0.81
                                                                          $4.04
                                       4
                                      86
                                      429
                                       1
                                    $63.66
                                    $10,730
                                    $110.31
                                   $10,904
                                    $9,979
                                    $8,901
                                      86
                                      429
                                    $0.94
                                    $4.68
                                    $0.85
                                    $4.24
                                    $0.76
                                                                          $3.78
                                       5
                                      86
                                      429
                                       1
                                    $63.66
                                    $10,730
                                    $110.31
                                   $10,904
                                    $9,688
                                    $8,319
                                      86
                                      429
                                    $0.94
                                    $4.68
                                    $0.82
                                    $4.11
                                    $0.71
                                                                          $3.53
                                       6
                                      86
                                      429
                                       1
                                    $63.66
                                    $10,730
                                    $110.31
                                   $10,904
                                    $9,406
                                    $7,775
                                      86
                                      429
                                    $0.94
                                    $4.68
                                    $0.80
                                    $3.99
                                    $0.66
                                                                          $3.30
                                       7
                                      86
                                      429
                                       1
                                    $63.66
                                    $10,730
                                    $110.31
                                   $10,904
                                    $9,132
                                    $7,266
                                      86
                                      429
                                    $0.94
                                    $4.68
                                    $0.78
                                    $3.88
                                    $0.62
                                                                          $3.09
                                       8
                                      86
                                      429
                                       1
                                    $63.66
                                    $10,730
                                    $110.31
                                   $10,904
                                    $8,866
                                    $6,791
                                      86
                                      429
                                    $0.94
                                    $4.68
                                    $0.75
                                    $3.77
                                    $0.58
                                                                          $2.88
                                       9
                                      86
                                      429
                                       1
                                    $63.66
                                    $10,730
                                    $110.31
                                   $10,904
                                    $8,608
                                    $6,346
                                      86
                                      429
                                    $0.94
                                    $4.68
                                    $0.73
                                    $3.66
                                    $0.54
                                                                          $2.70
                                      10
                                      86
                                      429
                                       1
                                    $63.66
                                    $10,730
                                    $8,686
                                   $10,904
                                    $8,357
                                    $5,931
                                      86
                                      429
                                    $0.94
                                    $4.68
                                    $0.71
                                    $3.55
                                    $0.50
                                                                          $2.52

Table 6-4: Total Annual Agency Burden and Cost (Number of Firms Sensitivity Analysis)
                                     Year
                               Hours per Report
                        Agency Cost per Report (2015$)
                           Total Number of Reportsa
                                     Total
                       Discounted Cost (Millions 2015$)

                                     Hours
                             Cost (Millions 2015$)
                               3% Discount Rate
                               7% Discount Rate

                                      Low
                                     High
                                      Low
                                     High
                                      Low
                                     High
                                      Low
                                     High
                                      Low
                                     High
                                       1
                                     6.38
                                     $525
                                     1,303
                                     4,918
                                     8,313
                                    31,374
                                    $0.68
                                    $2.58
                                    $0.68
                                    $2.58
                                    $0.68
                                     $2.58
                                       2
                                     6.38
                                     $525
                                      145
                                      548
                                      926
                                     3,493
                                    $0.08
                                    $0.29
                                    $0.07
                                    $0.28
                                    $0.07
                                     $0.27
                                       3
                                     6.38
                                     $525
                                      145
                                      548
                                      926
                                     3,493
                                    $0.08
                                    $0.29
                                    $0.07
                                    $0.27
                                    $0.07
                                     $0.25
                                       4
                                     6.38
                                     $525
                                      145
                                      548
                                      926
                                     3,493
                                    $0.08
                                    $0.29
                                    $0.07
                                    $0.26
                                    $0.06
                                     $0.23
                                       5
                                     6.38
                                     $525
                                      145
                                      548
                                      926
                                     3,493
                                    $0.08
                                    $0.29
                                    $0.07
                                    $0.26
                                    $0.06
                                     $0.22
                                       6
                                     6.38
                                     $525
                                      145
                                      548
                                      926
                                     3,493
                                    $0.08
                                    $0.29
                                    $0.07
                                    $0.25
                                    $0.05
                                     $0.20
                                       7
                                     6.38
                                     $525
                                      145
                                      548
                                      926
                                     3,493
                                    $0.08
                                    $0.29
                                    $0.06
                                    $0.24
                                    $0.05
                                     $0.19
                                       8
                                     6.38
                                     $525
                                      145
                                      548
                                      926
                                     3,493
                                    $0.08
                                    $0.29
                                    $0.06
                                    $0.23
                                    $0.05
                                     $0.18
                                       9
                                     6.38
                                     $525
                                      145
                                      548
                                      926
                                     3,493
                                    $0.08
                                    $0.29
                                    $0.06
                                    $0.23
                                    $0.04
                                     $0.17
                                      10
                                     6.38
                                     $525
                                      145
                                      548
                                      926
                                     3,493
                                    $0.08
                                    $0.29
                                    $0.06
                                    $0.22
                                    $0.04
                                     $0.16
                                     Total
                                     63.80

                                     2,609
                                     9,846
                                    16,647
                                    62,815

                                                                Annualized Cost
                                    $0.13
                                    $0.51
                                    $0.15
                                    $0.55

Table 6-5: Total Social Costs (Number of Firms Sensitivity Analysis)
                                     Year
                                Burden (Hours)
                       Discounted Costs (millions 2015$)

                               3% Discount Rate
                               7% Discount Rate

                                   Industry
                                    Agency
                                    Total
                                   Industry
                                    Agency
                                    Total
                                   Industry
                                    Agency
                                    Total

                                     Low
                                     High
                                     Low
                                     High
                                     Low
                                     High
                                     Low
                                     High
                                     Low
                                     High
                                     Low
                                     High
                                     Low
                                     High
                                     Low
                                     High
                                     Low
                                     High
                                       1
                                    183,166
                                    693,200
                                     8,313
                                    31,374
                                    191,479
                                    724,574
                                     $14.0
                                    $53.03
                                    $0.68
                                    $2.58
                                     $14.7
                                     $55.6
                                     $14.0
                                    $53.0
                                    $0.68
                                    $2.58
                                    $14.72
                                     $55.6
                                       2
                                    20,354
                                    77,227
                                      926
                                     3,493
                                    21,280
                                    80,721
                                    $1.52
                                    $5.74
                                    $0.07
                                    $0.28
                                     $1.59
                                     $6.02
                                    $1.46
                                    $5.52
                                    $0.07
                                    $0.27
                                     $1.53
                                     $5.79
                                       3
                                    20,354
                                    77,227
                                      926
                                     3,493
                                    21,280
                                    80,721
                                    $1.47
                                    $5.56
                                    $0.07
                                    $0.27
                                     $1.54
                                     $5.83
                                    $1.37
                                    $5.15
                                    $0.07
                                    $0.25
                                     $1.44
                                     $5.40
                                       4
                                    20,354
                                    77,227
                                      926
                                     3,493
                                    21,280
                                    80,721
                                    $1.43
                                    $5.40
                                    $0.07
                                    $0.26
                                     $1.50
                                     $5.66
                                    $1.28
                                    $4.82
                                    $0.06
                                    $0.23
                                     $1.34
                                     $5.05
                                       5
                                    20,354
                                    77,227
                                      926
                                     3,493
                                    21,280
                                    80,721
                                    $1.39
                                    $5.24
                                    $0.07
                                    $0.26
                                     $1.46
                                     $5.50
                                    $1.20
                                    $4.50
                                    $0.06
                                    $0.22
                                     $1.26
                                     $4.72
                                       6
                                    20,354
                                    77,227
                                      926
                                     3,493
                                    21,280
                                    80,721
                                    $1.35
                                    $5.09
                                    $0.07
                                    $0.25
                                     $1.42
                                     $5.34
                                    $1.11
                                    $4.21
                                    $0.05
                                    $0.20
                                     $1.16
                                     $4.41
                                       7
                                    20,354
                                    77,227
                                      926
                                     3,493
                                    21,280
                                    80,721
                                    $1.31
                                    $4.95
                                    $0.06
                                    $0.24
                                     $1.37
                                     $5.19
                                    $1.04
                                    $3.94
                                    $0.05
                                    $0.19
                                     $1.09
                                     $4.13
                                       8
                                    20,354
                                    77,227
                                      926
                                     3,493
                                    21,280
                                    80,721
                                    $1.27
                                    $4.80
                                    $0.06
                                    $0.23
                                     $1.33
                                     $5.03
                                    $0.98
                                    $3.67
                                    $0.05
                                    $0.18
                                     $1.03
                                     $3.85
                                       9
                                    20,354
                                    77,227
                                      926
                                     3,493
                                    21,280
                                    80,721
                                    $1.23
                                    $4.66
                                    $0.06
                                    $0.23
                                     $1.29
                                     $4.89
                                    $0.91
                                    $3.44
                                    $0.04
                                    $0.17
                                     $0.95
                                     $3.61
                                      10
                                    20,354
                                    77,227
                                      926
                                     3,493
                                    21,280
                                    80,721
                                    $1.20
                                    $4.53
                                    $0.06
                                    $0.22
                                     $1.26
                                     $4.75
                                    $0.85
                                    $3.21
                                    $0.04
                                    $0.16
                                     $0.89
                                     $3.37
                                     Total
                                    366,352
                                   1,388,247
                                    16,647
                                    62,815
                                    382,999
                                    1.45 M

                                                               Annualized Costs
                                    $2.75
                                    $10.39
                                    $0.13
                                    $0.51
                                    $2.88
                                    $10.9
                                    $3.02
                                     $11.4
                                    $0.15
                                    $0.55
                                    $3.17
                                    $12.0

Annual Industry Growth Rate
In Chapter 3 and Chapter 4, EPA assumes that the number of manufacturer firms subject to the rule will remain static throughout the period of analysis. As an alternative analysis, EPA estimated the cost to industry and the Agency assuming an annual growth rate of 11.6 percent in the number of manufacturer firms subject to the rule. The growth rate of 11.6 percent was calculated using the number nanomaterials firms identified in the 2005 NMSP ICR (611) and the number of manufacturer firms estimated in this report (823), which was based on data from 2008. Growth rate was calculated using the formula below:
Growth Rate=∆Number of FirmsFirms year 1(Number of years)=823-611611(2008-2005)=0.116
Estimated Number of Reports
Manufacturers. To be consistent with the main analysis presented in Chapter 3 and Chapter 4 EPA assumes each manufacturer will submit 4.67 reports in its first year and 0.52 reports in each subsequent year (see Section 2.2.3). The total number of reports submitted each year is the sum of the first-year reports submitted by new firms and subsequent-year reports submitted by existing firms for a total of 3,316 reports over the 10-year period (see Table 6-6).

Table 6-6: Estimated Number of Manufacturer Reports (Increased Annual Growth Rate Sensitivity Analysis)
                                     Year
                                Number of Firms
                              Chemicals per Firm
                               Number of Reports

                                   New Firms
                                Existing Firms
                                     Total
                                  First Year
                               Subsequent Years
                                   New Firms
                                Existing Firms
                                     Total
                                       1
                                      165
                                       0
                                      165
                                     4.67
                                     0.52
                                      771
                                       0
                                      771
                                       2
                                      19
                                      165
                                      184
                                     4.67
                                     0.52
                                      89
                                      86
                                      175
                                       3
                                      21
                                      184
                                      205
                                     4.67
                                     0.52
                                      98
                                      96
                                      194
                                       4
                                      24
                                      205
                                      229
                                     4.67
                                     0.52
                                      112
                                      107
                                      219
                                       5
                                      27
                                      229
                                      256
                                     4.67
                                     0.52
                                      126
                                      119
                                      245
                                       6
                                      30
                                      256
                                      286
                                     4.67
                                     0.52
                                      140
                                      133
                                      273
                                       7
                                      33
                                      286
                                      319
                                     4.67
                                     0.52
                                      154
                                      149
                                      303
                                       8
                                      37
                                      319
                                      356
                                     4.67
                                     0.52
                                      173
                                      166
                                      339
                                       9
                                      41
                                      356
                                      397
                                     4.67
                                     0.52
                                      191
                                      185
                                      376
                                      10
                                      46
                                      397
                                      443
                                     4.67
                                     0.52
                                      215
                                      206
                                      421
                                     Total
                                       -
                                       -
                                       -
                                       -
                                       -
                                     2,069
                                     1,247
                                     3,316

Processors. As described in Section 2.3, we assume that there are 2.32 processors per nanomaterial, and that each processor submits one report. Under this manufacturer growth rate scenario, the total number of reports submitted by processors over the 10-year analysis period is 7,693 (see Table 6-7).

Table 6-7: Estimated Number of Processor Reports (Increased Annual Growth Rate Sensitivity Analysis)
                                     Year
                        Number of Manufacturer Reports
                     Number of Processors per Nanomaterial
                          Total Number of Processors
                             Reports per Processor
                          Number of Processor Reports
                                       1
                                      771
                                     2.32
                                     1,789
                                       1
                                     1,789
                                       2
                                      175
                                     2.32
                                      406
                                       1
                                      406
                                       3
                                      194
                                     2.32
                                      450
                                       1
                                      450
                                       4
                                      219
                                     2.32
                                      508
                                       1
                                      508
                                       5
                                      245
                                     2.32
                                      568
                                       1
                                      568
                                       6
                                      273
                                     2.32
                                      633
                                       1
                                      633
                                       7
                                      303
                                     2.32
                                      703
                                       1
                                      703
                                       8
                                      339
                                     2.32
                                      786
                                       1
                                      786
                                       9
                                      376
                                     2.32
                                      872
                                       1
                                      872
                                      10
                                      421
                                     2.32
                                      977
                                       1
                                      977
                                     Total
                                       -
                                       -
                                       -
                                       -
                                     7,693
INDUSTRY, Agency and Total Costs
Table 6-8 presents the annual industry labor burden for both new and existing firms. There are 165 manufacturing firms expected to submit reports in year 1, and a total of 443 manufacturers are estimated to submit reports by the end of the 10 year period. A total of 1,789 processors are expected to submit reports in the first year, and from 406 to 977 in the subsequent years. Each new manufacturing firm is estimated to incur 652 labor burden hours in their first year and 73 hours each subsequent year. Processing firms each incur 141 hours in the year of their report submission. The total industry labor burden is estimated to be 1,549,917 hours. The costs per firm and total industry costs are presented in Table 6-9. Total annualized industry costs are $11.07 million with a 3 percent discount rate and $11.35 million with a 7 percent discount rate.
Agency costs are derived following the method described in Chapter 4. As shown in Table 6-10, EPA expects that approximately 11,009 reports will be submitted over the next 10 years, resulting in a total Agency burden of 70,238 labor hours. Annualized costs are expected to be $0.54 million with a 3 percent discount rate and $0.55 million with a 7 percent discount rate.
As shown in Table 6-11, the increase in the number of nanomaterials firms over a 10-year period is expected to yield a total social burden of 1,620,155 hours and total annualized social costs of $11.61 million with a 3 percent discount rate ($11.90 million with a 7 percent discount rate).

Table 6-8: Total Annual Industry Labor Burden (Increased Annual Growth Rate Sensitivity Analysis)
                                     Year
                                Number of Firms
                           Total Number of Reportsa
                 Rule Familiarization Burden (Hours per Firm)b
Form Completion, CBI Substantiation and Recordkeeping Burden (Hours per Report)c
          Electronic Reporting Requirements Burden (Hours per Firm)d
                    Total Burden per Firm (Hours per Firm)
                          Total Industry Burden Hours

                                 Manufacturers
                                  Processors

                                 Manufacturers
                                  Processors

                                   Existing
                                      New

                                   Existing
                                      New

                                   Existing
                                      New
                                   Existing
                                      New

                                       1
                                       0
                                      165
                                     1789
                                     2,560
                                       0
                                     0.82
                                      144
                                       0
                                     1.42
                                       0
                                      652
                                      141
                                    360,371
                                       2
                                      165
                                      19
                                      406
                                      581
                                       0
                                     0.82
                                      144
                                     0.17
                                     1.42
                                      73
                                      652
                                      141
                                    81,733
                                       3
                                      184
                                      21
                                      450
                                      644
                                       0
                                     0.82
                                      144
                                     0.17
                                     1.42
                                      73
                                      652
                                      141
                                    90,645
                                       4
                                      205
                                      24
                                      508
                                      727
                                       0
                                     0.82
                                      144
                                     0.17
                                     1.42
                                      73
                                      652
                                      141
                                    102,321
                                       5
                                      229
                                      27
                                      568
                                      813
                                       0
                                     0.82
                                      144
                                     0.17
                                     1.42
                                      73
                                      652
                                      141
                                    114,542
                                       6
                                      256
                                      30
                                      633
                                      906
                                       0
                                     0.82
                                      144
                                     0.17
                                     1.42
                                      73
                                      652
                                      141
                                    127,637
                                       7
                                      286
                                      33
                                      703
                                     1,006
                                       0
                                     0.82
                                      144
                                     0.17
                                     1.42
                                      73
                                      652
                                      141
                                    141,605
                                       8
                                      319
                                      37
                                      786
                                     1,125
                                       0
                                     0.82
                                      144
                                     0.17
                                     1.42
                                      73
                                      652
                                      141
                                    158,410
                                       9
                                      356
                                      41
                                      872
                                     1,248
                                       0
                                     0.82
                                      144
                                     0.17
                                     1.42
                                      73
                                      652
                                      141
                                    175,833
                                      10
                                      397
                                      46
                                      977
                                     1,398
                                       0
                                     0.82
                                      144
                                     0.17
                                     1.42
                                      73
                                      652
                                      141
                                    196,821
                                     Total

                                    11,009

                                   1,549,917

Table 6-9: Annual Industry Labor Costs (Increased Annual Growth Rate Sensitivity Analysis)

                                     Year
                                Number of Firms
                            Total Number of Reports
                 Rule Familiarization Cost (per Firm) (2015$)
Form Completion and  CBI Substantiation, Record-keeping Cost (per Report)c (2015$)
           Electronic Reporting Requirements Cost (per Firm) (2015$)
                          Total Cost per Firm (2015$)
                     Total Industry Cost (Millions 2015$)
                       Discounted Cost (Millions 2015$)

                                 Manufacturers
                                  Processors

                                 Manufacturers
                                  Processors

                                   Existing
                                      New

                                   Existing
                                      New

                                   Existing
                                      New
                                   Existing
                                      New

                                3% Disc. Rate
                                7% Disc .Rate
                                       1
                                       0
                                      165
                                     1,789
                                     2,560
                                    $0.00
                                    $63.66
                                   $10,730
                                    $13.41
                                   $110.31
                                       0
                                   $50,285
                                   $10,904
                                    $27.80
                                    $27.80
                                    $27.80
                                       2
                                      165
                                      19
                                      406
                                      581
                                    $0.00
                                    $63.66
                                   $10,730
                                    $13.41
                                   $110.31
                                    $5,593
                                   $50,285
                                   $10,904
                                     $6.31
                                    $6.12
                                    $5.89
                                       3
                                      184
                                      21
                                      450
                                      644
                                    $0.00
                                    $63.66
                                   $10,730
                                    $13.41
                                   $110.31
                                    $5,593
                                   $50,285
                                   $10,904
                                     $6.99
                                    $6.59
                                    $6.11
                                       4
                                      205
                                      24
                                      508
                                      727
                                    $0.00
                                    $63.66
                                   $10,730
                                    $13.41
                                   $110.31
                                    $5,593
                                   $50,285
                                   $10,904
                                     $7.89
                                    $7.22
                                    $6.44
                                       5
                                      229
                                      27
                                      568
                                      813
                                    $0.00
                                    $63.66
                                   $10,730
                                    $13.41
                                   $110.31
                                    $5,593
                                   $50,285
                                   $10,904
                                     $8.84
                                    $7.85
                                    $6.74
                                       6
                                      256
                                      30
                                      633
                                      906
                                    $0.00
                                    $63.66
                                   $10,730
                                    $13.41
                                   $110.31
                                    $5,593
                                   $50,285
                                   $10,904
                                     $9.85
                                    $8.49
                                    $7.02
                                       7
                                      286
                                      33
                                      703
                                     1,006
                                    $0.00
                                    $63.66
                                   $10,730
                                    $13.41
                                   $110.31
                                    $5,593
                                   $50,285
                                   $10,904
                                    $10.92
                                    $9.15
                                    $7.28
                                       8
                                      319
                                      37
                                      786
                                     1,125
                                    $0.00
                                    $63.66
                                   $10,730
                                    $13.41
                                   $110.31
                                    $5,593
                                   $50,285
                                   $10,904
                                    $12.22
                                    $9.94
                                    $7.61
                                       9
                                      356
                                      41
                                      872
                                     1,248
                                    $0.00
                                    $63.66
                                   $10,730
                                    $13.41
                                   $110.31
                                    $5,593
                                   $50,285
                                   $10,904
                                    $13.56
                                    $10.71
                                    $7.89
                                      10
                                      397
                                      46
                                      977
                                     1,398
                                    $0.00
                                    $63.66
                                   $10,730
                                    $13.41
                                   $110.31
                                    $5,593
                                   $50,285
                                   $10,904
                                    $15.18
                                    $11.64
                                    $8.26
                                     Total

                                    11,009

                                                                Annualized Cost
                                    $11.07
                                    $11.35

Table 6-10: Agency Cost Estimate for the Final Rule (Increased Annual Growth Rate Sensitivity Analysis)
                                     Year
                               Hours per Report
                        Agency Cost per Report (2015$)
                           Total Number of Reportsa
                                     Total
                       Discounted Cost (Millions 2015$)

                                    Burden
                             Cost (Millions 2015$)
                               3% Discount Rate
                               7% Discount Rate
                                       1
                                    $6.38
                                     $525
                                     2,560
                                    16,331
                                    $1.34
                                    $1.34
                                    $1.34
                                       2
                                    $6.38
                                     $525
                                      581
                                     3,707
                                    $0.30
                                    $0.30
                                    $0.29
                                       3
                                    $6.38
                                     $525
                                      644
                                     4,109
                                    $0.34
                                    $0.32
                                    $0.30
                                       4
                                    $6.38
                                     $525
                                      727
                                     4,639
                                    $0.38
                                    $0.35
                                    $0.31
                                       5
                                    $6.38
                                     $525
                                      813
                                     5,189
                                    $0.43
                                    $0.38
                                    $0.33
                                       6
                                    $6.38
                                     $525
                                      906
                                     5,783
                                    $0.48
                                    $0.41
                                    $0.34
                                       7
                                    $6.38
                                     $525
                                     1,006
                                     6,418
                                    $0.53
                                    $0.44
                                    $0.35
                                       8
                                    $6.38
                                     $525
                                     1,125
                                     7,181
                                    $0.59
                                    $0.48
                                    $0.37
                                       9
                                    $6.38
                                     $525
                                     1,248
                                     7,964
                                    $0.66
                                    $0.52
                                    $0.38
                                      10
                                    $6.38
                                     $525
                                     1,398
                                     8,917
                                    $0.73
                                    $0.56
                                    $0.40
                                     Total
                                     63.80
                                       -
                                    11,009
                                    70,238
                                       -
                                       -
                                       -
                                                                Annualized Cost
                                    $0.54
                                    $0.55

Table 6-11: Total Social Costs for the Rule (Increased Annual Growth Rate Sensitivity Analysis)
                                     Year
                                Burden (Hours)
                           Discounted Costs (2015$)

                               3 % Discount Rate
                               7 % Discount Rate

                                   Industry
                                    Agency
                                    Total
                                   Industry
                                    Agency
                                    Total
                                   Industry
                                    Agency
                                    Total
                                       1
                                    360,371
                                    16,331
                                    376,702
                                    $27.80
                                    $1.34
                                    $29.15
                                    $27.80
                                    $1.34
                                    $29.15
                                       2
                                    81,733
                                     3,707
                                    85,440
                                    $6.12
                                    $0.30
                                    $6.42
                                    $5.89
                                    $0.29
                                    $6.18
                                       3
                                    90,645
                                     4,109
                                    94,754
                                    $6.59
                                    $0.32
                                    $6.91
                                    $6.11
                                    $0.30
                                    $6.40
                                       4
                                    102,321
                                     4,639
                                    106,960
                                    $7.22
                                    $0.35
                                    $7.57
                                    $6.44
                                    $0.31
                                    $6.76
                                       5
                                    114,542
                                     5,189
                                    119,732
                                    $7.85
                                    $0.38
                                    $8.23
                                    $6.74
                                    $0.33
                                    $7.07
                                       6
                                    127,637
                                     5,783
                                    133,419
                                    $8.49
                                    $0.41
                                    $8.90
                                    $7.02
                                    $0.34
                                    $7.36
                                       7
                                    141,605
                                     6,418
                                    148,023
                                    $9.15
                                    $0.44
                                    $9.59
                                    $7.28
                                    $0.35
                                    $7.63
                                       8
                                    158,410
                                     7,181
                                    165,590
                                    $9.94
                                    $0.48
                                    $10.42
                                    $7.61
                                    $0.37
                                    $7.98
                                       9
                                    175,833
                                     7,964
                                    183,797
                                    $10.71
                                    $0.52
                                    $11.23
                                    $7.89
                                    $0.38
                                    $8.28
                                      10
                                    196,821
                                     8,917
                                    205,738
                                    $11.64
                                    $0.56
                                    $12.20
                                    $8.26
                                    $0.40
                                    $8.66
                                     Total
                                   1,549,917
                                    70,238
                                   1,620,155

                                                               Annualized Costs
                                    $11.07
                                    $0.54
                                    $11.61
                                    $4.28
                                    $0.55
                                    $11.90

Number of Nanomaterials per Firm
Low and High-End Estimates for the Number of Nanomaterials per Firm
As described in Section 2.2.3, the median number of TSCA-related nanomaterials per firm is 12 (based on a subgroup of 19 firms), and after excluding those produced for R&D purposes (approximately 61 percent of all nanomaterials), EPA estimated 4.67 to be "commercially relevant" and therefore subject to the rule. The number of nanomaterials produced by the 19 businesses in the identified subgroup ranged from 1 to 66. As a sensitivity analysis, EPA has estimated industry and Agency burden associated with the rule using the high and low values from this range. Assuming a low-end estimate of 1 nanomaterial, on average each firm will report on 0.39 nanomaterials in the first year and 0.04 in the subsequent years. Using the high-end estimate of 66 nanomaterials, a firm will submit 25.67 reports in the first year and 2.85 reports in all future years (see Table 6-12). Consistent with the main analysis, we continue to assume that there are 2.32 processors per nanomaterial, and that processors submit one report each.
Table 6-12: Estimated High- and Low-End Estimated Number of Commercially Relevant Nanomaterials per Manufacturer
                              Estimation Category
                            Nanomaterials per Firm
                             R&D Exclusion (%)
                             R&D Exclusion (#)
                   "Commercial" Nano-materials per Firma

                                  First Year
                               Subsequent Years
Low-end
                                       1
                                    61.11%
                                     0.61
                                     0.39
                                     0.04
High-end
                                      66
                                    61.11%
                                     40.33
                                     25.67
                                     2.85

Industry, Agency and Total Costs
Low-end estimates. Based on the number of firms and the burden estimates derived in Chapter 2 and Section 3.2, and using the low-end estimate of 0.39 reports in the first year and 0.04 in the subsequent years, the total manufacturer burden is 9,321 hours in the first year and 947 hours in future years, with an annualized cost of $0.14 million with a 3 percent discount rate ($0.15 with a 7 percent discount rate). The total processor burden is 21,101 hours in the first year, and 1,091 hours in future years, with an annualized cost of $0.31 million with a 3 percent discount rate ($0.34 with a 7 percent discount rate). Table 6-13 and Table 6-14 present the manufacturer and processor burden estimates, respectively, while Table 6-15 and Table 6-16 present the manufacturer and processor cost estimates.

Table 6-17 shows the Agency burden estimate of 1,363 hours in the first year and 140 hours each subsequent year, and the annualized cost of estimates of $0.02 million with a 3 percent discount rate ($0.02 million with a 7 percent discount rate).

Table 6-18 contains the total social costs and burden estimates. The total social burden is 61,045 hours over the ten year period, and the annualized cost is $0.46 million with a 3 percent discount rate and $0.51 million with a 7 percent discount rate.

High-end estimates. Using the high end estimate of 25.67 reports in the first year, and 2.85 reports in each subsequent year, the manufacturer burden is 589,535 hours in the first year and 65,441 hours in each subsequent year, with an annualized cost of $8.9 million with a 3 percent discount rate ($9.77 with a 7 percent discount rate). The total processor burden is 1,388,874 hours in the first year, and 154,199 hours in future years, with an annualized cost of $20.96 million with a 3 percent discount rate ($23.01 with a 7 percent discount rate). Table 6-13 and Table 6-14 present the manufacturer and processor burden estimates, respectively, while Table 6-15 and Table 6-16 present the manufacturer and processor cost estimates. Table 6-17 presents the total Agency burden estimate of 89,716 hours in the first year and 9,961 hours in each subsequent year, and the annualized Agency cost estimate of $1.44 million with a 3 percent discount rate ($1.59 with a 7 percent discount rate).
Table 6-18 contains the total social costs and burden of using the high-end estimate. The total social burden is 4.13 million hours over the ten year period, and the annualized cost is $31.3 million with a 3 percent discount rate and $34.37 million with a 7 percent discount rate.

Table 6-13: Annual Manufacturer Burden Hours (Number of Nanomaterials Per Firm Sensitivity Analysis)
                                     Year
                            Number of Manufacturers
                               Reports per Firm
                    Rule Familiarization Burden (per Firm)
   Form Completion, CBI Substantiation and Recordkeeping Burden (per Report)
                    Electronic Reporting Burden (per Firm)d
                         Total Burden Per Manufacturer
                     Total Manufacturer Number of Reportsb
                           Total Manufacturer Burden

                                      Low
                                     High

                                      Low
                                     High
                                      Low
                                     High
                                      Low
                                     High
                                       1
                                      165
                                     0.39
                                     25.67
                                     0.82
                                      139
                                     1.42
                                     56.49
                                     3,573
                                      64
                                     4,236
                                     9,321
                                    589,535
                                       2
                                      165
                                     0.04
                                     2.85
                                     0.00
                                      139
                                     0.17
                                     5.74
                                      397
                                       7
                                      470
                                      947
                                    65,441
                                       3
                                      165
                                     0.04
                                     2.85
                                     0.00
                                      139
                                     0.17
                                     5.74
                                      397
                                       7
                                      470
                                      947
                                    65,441
                                       4
                                      165
                                     0.04
                                     2.85
                                     0.00
                                      139
                                     0.17
                                     5.74
                                      397
                                       7
                                      470
                                      947
                                    65,441
                                       5
                                      165
                                     0.04
                                     2.85
                                     0.00
                                      139
                                     0.17
                                     5.74
                                      397
                                       7
                                      470
                                      947
                                    65,441
                                       6
                                      165
                                     0.04
                                     2.85
                                     0.00
                                      139
                                     0.17
                                     5.74
                                      397
                                       7
                                      470
                                      947
                                    65,441
                                       7
                                      165
                                     0.04
                                     2.85
                                     0.00
                                      139
                                     0.17
                                     5.74
                                      397
                                       7
                                      470
                                      947
                                    65,441
                                       8
                                      165
                                     0.04
                                     2.85
                                     0.00
                                      139
                                     0.17
                                     5.74
                                      397
                                       7
                                      470
                                      947
                                    65,441
                                       9
                                      165
                                     0.04
                                     2.85
                                     0.00
                                      139
                                     0.17
                                     5.74
                                      397
                                       7
                                      470
                                      947
                                    65,441
                                      10
                                      165
                                     0.04
                                     2.85
                                     0.00
                                      139
                                     0.17
                                     5.74
                                      397
                                       7
                                      470
                                      947
                                    65,441
                                     Total
                                       -
                                     0.75
                                     51.32
                                       -
                                       -
                                       -
                                       -

                                      124
                                     8,468
                                    17,845
                                   1,178,501

Table 6-14: Annual Processor Burden Hours (Number of Nanomaterials Per Manufacturer Sensitivity Analysis)
                                     Year
                     Number of Processors per Nanomaterial
                             Number of Processors
                               Reports per Firm
                    Rule Familiarizationc Burden (per Firm)
   Form Completion, CBI Substantiation and Recordkeeping Burden (per Report)
                 Electronic Reporting Requirements (per Firm)d
                          Total Burden Per Processor
                      Total Processor Number of Reportsb
                            Total Processor Burden

                                      Low
                                     High

                                      Low
                                     High
                                      Low
                                     High
                                       1
                                     2.32
                                      149
                                     9,826
                                       1
                                     0.82
                                      139
                                     1.42
                                    141.34
                                      149
                                     9,826
                                    21,101
                                   1,388,874
                                       2
                                     2.32
                                      15
                                     1,091
                                       1
                                     0.82
                                      139
                                     1.42
                                    141.34
                                      15
                                     1,091
                                     2,164
                                    154,199
                                       3
                                     2.32
                                      15
                                     1,091
                                       1
                                     0.82
                                      139
                                     1.42
                                    141.34
                                      15
                                     1,091
                                     2,164
                                    154,199
                                       4
                                     2.32
                                      15
                                     1,091
                                       1
                                     0.82
                                      139
                                     1.42
                                    141.34
                                      15
                                     1,091
                                     2,164
                                    154,199
                                       5
                                     2.32
                                      15
                                     1,091
                                       1
                                     0.82
                                      139
                                     1.42
                                    141.34
                                      15
                                     1,091
                                     2,164
                                    154,199
                                       6
                                     2.32
                                      15
                                     1,091
                                       1
                                     0.82
                                      139
                                     1.42
                                    141.34
                                      15
                                     1,091
                                     2,164
                                    154,199
                                       7
                                     2.32
                                      15
                                     1,091
                                       1
                                     0.82
                                      139
                                     1.42
                                    141.34
                                      15
                                     1,091
                                     2,164
                                    154,199
                                       8
                                     2.32
                                      15
                                     1,091
                                       1
                                     0.82
                                      139
                                     1.42
                                    141.34
                                      15
                                     1,091
                                     2,164
                                    154,199
                                       9
                                     2.32
                                      15
                                     1,091
                                       1
                                     0.82
                                      139
                                     1.42
                                    141.34
                                      15
                                     1,091
                                     2,164
                                    154,199
                                      10
                                     2.32
                                      15
                                     1,091
                                       1
                                     0.82
                                      139
                                     1.42
                                    141.34
                                      15
                                     1,091
                                     2,164
                                    154,199
                                     Total
                                       -
                                      287
                                    19,645

                                      287
                                    19,645
                                    40,579
                                   2,776,666

Table 6-15: Annual Manufacturer Labor Costs (Number of Nanomaterials Per Firm Sensitivity Analysis)
                                     Year
                                Number of Firms
                               Reports per Firm
                     Rule Familiarization Cost (per Firm)
                                    (2015$)
Form Completion, CBI Substantiation and Recordkeeping Burden Cost (per Report)[b] (2015$)
                 Electronic Reporting Costs (per Firm) (2015$)
                          Total Cost Per Manufacturer
                     Total Number of Manufacturer Reports
                            Total Manufacturer Cost
                                (Millions 2015$)

                                      Low
                                     High

                                      Low
                                     High
                                      Low
                                     High
                               3% Discount Rate
                               7% Discount Rate

                                      Low
                                     High
                                      Low
                                     High
                                       1
                                      165
                                     0.39
                                     25.67
                                    $63.66
                                    $10,730
                                    $110.31
                                    $4,359
                                   $275,624
                                      64
                                     4,236
                                    $0.72
                                    $45.48
                                     $0.72
                                    $45.48
                                       2
                                      165
                                     0.04
                                     2.85
                                     $0.00
                                    $10,730
                                    $13.41
                                     $443
                                    $30,595
                                       7
                                      470
                                    $0.07
                                     $4.90
                                     $0.07
                                     $4.72
                                       3
                                      165
                                     0.04
                                     2.85
                                     $0.00
                                    $10,730
                                    $13.41
                                     $443
                                    $30,595
                                       7
                                      470
                                    $0.07
                                     $4.76
                                     $0.06
                                     $4.41
                                       4
                                      165
                                     0.04
                                     2.85
                                     $0.00