0.000
                                                                         12.000
                                                                          0.000
                                                                         12.000
                                                                          0.033
                                                                          0.400
                                                                        $30.50
                                                                         $0.00
                                                                        $30.50
Total, Recordkeeping
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                         $0.00
                                                                         $0.00
                                                                         $0.00
Total, Robust Summaries (Voluntary)
                                                                          0.000
                                                                         12.000
                                                                          0.000
                                                                         12.000
                                                                          0.033
                                                                          0.400
                                                                        $30.50
                                                                         $0.00
                                                                        $30.50
Footnotes:
[1] Unit costs are estimated by multiplying the clerical, technical, and managerial burdens by the corresponding wage rates in Table 37.

IC #12: Voluntary Data Submissions
EPA conservatively assumes that a voluntary submission consists of a final report for one chemical, as shown in Table 17. The description of this assumption is slightly revised from previous ICRs for simplification purposes.

Table 17. IC #12 Voluntary Data Submissions  -  Annual Per Chemical Unit Burden and Cost (2018$)
                                   Activity
                                  Unit Burden

                           Managerial Burden (hours)
                           Technical Burden (hours)
                            Clerical Burden (hours)
                              Unit Burden (hours)
                  Frequency of Occurrence (Average Per Year)
                         Adjusted Unit Burden (hours)
                              Labor Unit Cost[1]
                                Non-Labor Costs
                                   Unit Cost
Paper Submission of Final Reports
                                                                          0.000
                                                                          0.000
                                                                         10.000
                                                                         10.000
                                                                          1.000
                                                                         10.000
                                                                       $345.00
                                                                        $14.62
                                                                       $359.62
Total, Reporting
                                                                          0.000
                                                                          0.000
                                                                         10.000
                                                                         10.000
                                                                          1.000
                                                                         10.000
                                                                       $345.00
                                                                        $14.62
                                                                       $359.62
Total, Recordkeeping
                                                                          0.000
                                                                          0.000
                                                                          1.000
                                                                          1.000
                                                                          1.000
                                                                          1.000
                                                                        $34.50
                                                                         $0.00
                                                                        $34.50
Total, Voluntary Data Submissions
                                                                          0.000
                                                                          0.000
                                                                         11.000
                                                                         11.000
                                                                          1.000
                                                                         11.000
                                                                       $379.50
                                                                        $14.62
                                                                       $394.12
Footnotes:
[1] Unit costs are estimated by multiplying the clerical, technical, and managerial burdens by the corresponding wage rates in Table 37.

IC #13: Testing Costs (Non-Labor Costs)
Testing costs include laboratory costs and administrative costs. For purposes of this ICR, as in past ICRs, EPA assumes that the tests specified in a standard testing battery of seven tests are all likely to be performed on each chemical, although the specific tests actually performed could differ depending on specific circumstances and testing needs. Estimates include non-labor costs for analytical chemistry method development and validation where it was judged that such method development would be necessary to conform to good laboratory practices. Tests are assigned costs based on typical costs cited by industry experts and compiled by EPA. The overall laboratory costs of the "standard" testing battery (per chemical) is estimated at $58,177, (see Appendix A for further detail).
In addition to laboratory costs, there are also costs for consortium management and costs for technical experts. Consortium management costs, which includes activities such as identifying manufacturers, meetings, organizing payment for testing, developing contracts for testing, and employing toxicologists who may be hired to provide technical expertise, are estimated at 15 percent of total laboratory costs. Costs for technical experts working for the consortium by providing study review and site visits to the laboratory are estimated at 10 percent of total laboratory costs.

Table 18. IC #13 Testing Costs (Non-Labor Costs)  -  Annual Per Chemical Unit Burden and Cost (2018$)
                                   Activity
                                  Unit Burden

                           Managerial Burden (hours)
                           Technical Burden (hours)
                            Clerical Burden (hours)
                           Total Unit Burden (hours)
                  Frequency of Occurrence (Average Per Year)
                         Adjusted Unit Burden (hours)
                           Total Labor Unit Cost [1]
                             Total Non-Labor Cost
                                Total Unit Cost
Laboratory Costs
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.333
                                                                          0.000
                                                                         $0.00
                                                                    $19,392.33
                                                                    $19,392.33
Consortium Management
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.333
                                                                          0.000
                                                                         $0.00
                                                                     $2,908.85
                                                                     $2,908.85
Technical Experts
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.333
                                                                          0.000
                                                                         $0.00
                                                                     $1,939.23
                                                                     $1,939.23
Total, Testing Costs (Non-Labor Costs)
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.333
                                                                          0.000
                                                                         $0.00
                                                                    $24,240.41
                                                                    $24,240.41
Footnote:
[1] Unit costs are estimated by multiplying the clerical, technical, and managerial burdens by the corresponding wage rates in Table 37.

Respondent Universe, Total, and Bottom Line Burden Hours and Costs
The respondent universe for test rules, test orders, ECAs, and Voluntary Data Submissions, Exemption Applications and Robust Summaries are presented in Table 19 below.
Three-year to one-year scaling considerations for activities associated with Testing Exemption Applications, Voluntary Submissions, and CDR Registrations are handled slightly differently than the scaling for bundled activities, as depicted in Table 4. With the durations short and the activities themselves separate from the bundle associated with a chemical being tested, EPA assumes no need to apportion the activity over there years in the unit burden, but instead takes one third of the incidence rate to determine the counts in Table 19.
For Testing Exemption Applications, EPA revises the assumption from previous ICRs to a basis that three exemptions (yielding one annually) per chemical undergoing testing occur for Test Rules and Test Orders. The basis for this assumption uses information in the previous ICR (EPA, 2018a) stating that during Testing of Certain High Production Volume Chemicals; Second Group of Chemicals (76 FR 1067), 52 exemption applications were received for 19 chemicals subject to the test rule. Taking the ratio of exemption applications at 52 over 19 yields a factor of 2.8 exemption applications per chemical, rounded up to 3 exemption applications per chemical with each application assumed to involve one chemical. EPA also assumes that all tests are exempted in the exemption application. The newly structured assumption based on chemical testing provides ease of future maintenance as the number of exemptions is expected to vary according to the number of chemicals tested in actions.
Similarly, for Voluntary Data Submissions, EPA revises the assumption from previous ICRs to a basis that one submission (yielding one-third annually) per chemical tested occur for Test Rules and Test Orders. The newly structured assumption based on chemical testing provides ease of future maintenance as the number of exemptions is expected to vary according to number of chemicals tested in actions. The resultant number of submissions totals 24.5 for 77 chemicals tested, compared to a total of 10 for 92 chemicals reflecting HPV conditions (EPA, 2013). The newly structured assumption based on chemical testing provides ease of future maintenance as the number of exemptions is expected to vary according to number of chemicals tested in actions.
For CDX registrations, EPA assumes that 40 percent of sponsors, plus all exemption applicants, will produce new registrations.
In the sections that follow, each IC's total burden is estimated using universe information in Table 19 and the unit burdens presented in Section 5(b).
Table 19. Universe Information for this ICR Period
                                Type of Action
                                Program Input
                          Annual Number of Responses
                              Generic Assumptions

                             New Actions per Year
                        Associated Number of Chemicals

            (Standardized for All Types of TSCA Section 4 Actions)
Test Rule
                                      0.5
                                       7
                                      3.5
1 sponsor per chemical

2.8 overlap factor

7 tests per chemical undergoing testing

3 years testing duration overall
Test Order
                                      10
                                       7
                                      70

Enforceable Consent Agreement
                                      0.5
                                       7
                                      3.5

                                Inferred Inputs
                                  Assumptions
Exemption Application, Test Rule

                                      3.5
3 exemption applications per chemical undergoing testing in Test Rules and Test Orders

Duration of 1 year or less but occurs throughout the 3-year period

All tests exempted for a chemical exempted

2.8 overlap factor
Exemption Application, Test Order

                                     70.0
Same as above
Voluntary Data Submissions

                                     24.5
1 voluntary data submission involving one chemical per chemical undergoing testing in Test Rules and Test Orders

Duration of 1 year or less but occurs throughout the 3-year period
CDX Registration

                                     10.7
40% of sponsors plus exemption applicants produce registrations

Duration of 1 year or less but occurs throughout the 3-year period

2.8 overlap factor
General Note:
For Inputs with "duration of one year or less" the value per chemical is divided by three because the event can occur anytime in the three year period and does not need to be allocated across the three years, in contrast to activities that are part of the bundle presented in Table 5.

IC #1: CDX Registration for e-Reporting  -  Total Respondent Burden and Costs
Based on the unit burden estimates presented in Table 6, as well as the estimated number of responses presented in Table 19, the total respondent burden and costs for CDX registration for e-Reporting are presented below in Table 20. EPA assumes that some respondents are already registered in CDX, and only 40 percent of respondents would be required to register for CDX under this ICR. These respondents may be employees from sponsor companies that are new to EPA e-reporting or they may be employees new to e-reporting due to turnover within a company that has prior experience with e-reporting.
Table 20. IC #1: CDX Registration for e-Reporting  -  Annual Total Respondent Burden and Costs (2018$)
                                   Activity
                         Unit Burden per Registration
                    Number of Registrations/Registrants[1]
                                Overlap Factor
                             Total Burden (Hours)
                               Total Labor Cost
                             Total Non-Labor Cost
                                  Total Cost
CDX Registration
                                                                          0.180
                                                                           10.7
                                                                            2.8
                                                                          5.393
                                                                       $411.65
                                                                         $0.00
                                                                       $411.65
CDX Electronic Signature
                                                                          0.350
                                                                           10.7
                                                                            2.8
                                                                         10.486
                                                                       $800.23
                                                                         $0.00
                                                                       $800.23
Total, Reporting
                                                                          0.530
                                                                           10.7
                                                                            2.8
                                                                         15.879
                                                                     $1,211.88
                                                                         $0.00
                                                                     $1,211.88
Total, Recordkeeping
                                                                          0.000
                                                                            0.0

                                                                          0.000
                                                                         $0.00
                                                                         $0.00
                                                                         $0.00
Total, CDX Registration and e-Reporting and Recordkeeping
                                                                          0.530
                                                                           10.7
                                                                            2.8
                                                                         15.879
                                                                     $1,211.88
                                                                         $0.00
                                                                     $1,211.88
Footnotes:
1 Number of registrations is assumed to be 40 percent of the total number of sponsors for test rules, test orders, ECAs, and exemption applications assuming one sponsor per chemical.

IC #2: Initial Response, Test Rules  -  Total Respondent Burden and Costs
Based on the unit burden estimates presented in Table 7, as well as the estimated number of responses in Table 19, the total respondent burden and costs for initial response under test rules are presented below in Table 21.
Table 21. IC #2: Initial Response, Test Rules  -  Annual Total Respondent Burden and Costs (2018$)
                                   Activity
                         Adjusted Unit Burden (hours)
                     Number of Respondents (Sponsors) [1]
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                             Total Burden (hours)
                               Total Labor Cost
                             Total Non-Labor Cost
                                  Total Cost
Letter of Intent
                                                                          0.333
                                                                           3.50
                                                                           3.50
                                                                            2.8
                                                                          3.263
                                                                       $249.02
                                                                         $0.00
                                                                       $249.02
Subtotal, Letter of Intent Total
                                                                          0.333
                                                                           3.50
                                                                           3.50
                                                                            2.8
                                                                          3.263
                                                                       $249.02
                                                                         $0.00
                                                                       $249.02
OR

Prepare Exemption Application
                                                                          2.000
                                                                           3.50
                                                                           3.50
                                                                            2.8
                                                                         19.600
                                                                     $1,495.87
                                                                         $0.00
                                                                     $1,495.87
Corporate Review
                                                                          6.000
                                                                           3.50
                                                                           3.50
                                                                            2.8
                                                                         58.800
                                                                     $4,709.29
                                                                         $0.00
                                                                     $4,709.29
Subtotal, Exemption Application Reporting
                                                                          8.000
                                                                           3.50
                                                                           3.50
                                                                            2.8
                                                                         78.400
                                                                     $6,205.16
                                                                         $0.00
                                                                     $6,205.16
Subtotal, Recordkeeping
                                                                          0.500
                                                                           3.50
                                                                           3.50
                                                                            2.8
                                                                          4.900
                                                                       $169.05
                                                                         $0.00
                                                                       $169.05
Subtotal, Exemption Application
                                                                            8.5
                                                                           3.50
                                                                           3.50
                                                                            2.8
                                                                         83.300
                                                                     $6,374.21
                                                                         $0.00
                                                                     $6,374.21
Overall Total, Initial Response including Exemption Applications Reporting
                                                                          4.166
                                                                           7.00
                                                                           7.00
                                                                            2.8
                                                                         81.663
                                                                     $6,454.18
                                                                         $0.00
                                                                     $6,454.18
Overall Recordkeeping
                                                                          0.500
                                                                           3.50
                                                                           3.50
                                                                            2.8
                                                                          4.900
                                                                       $169.05
                                                                         $0.00
                                                                       $169.05
Overall Total, Initial Response including Exemption Applications
                                                                          4.416
                                                                            7.0
                                                                            7.0
                                                                            2.8
                                                                         85.563
                                                                     $6,323.23
                                                                         $0.00
                                                                     $6,623.23
Footnotes:
[1] Assumes one sponsor per chemical.

IC #3: Study Plan, Test Rules  -  Total Respondent Burden and Costs
Based on the unit burden estimates presented in Table 8, as well as the estimated number of responses in Table 19, the total respondent burden and costs for study plans under test rules are presented below in Table 22.
Table 22. IC #3 Study Plan, Test Rules  -  Annual Total Respondent Burden and Costs (2018$)
                                   Activity
                         Adjusted Unit Burden (hours)
                     Number of Respondents (Sponsors) [1]
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                             Total Burden (hours)
                               Total Labor Cost
                             Total Non-Labor Cost
                                  Total Cost
Study Plan
                                                                         12.987
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                         127.27
                                                                     $9,713.47
                                                                         $0.00
                                                                     $9,713.47
CBI Substantiation
                                                                          1.215
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                          11.91
                                                                       $923.36
                                                                         $0.00
                                                                       $923.36
Total, Reporting
                                                                         14.202
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                         139.18
                                                                    $10,636.83
                                                                         $0.00
                                                                    $10,636.83
Total, Recordkeeping
                                                                          0.000
                                                                           0.00
                                                                           0.00

                                                                           0.00
                                                                         $0.00
                                                                         $0.00
                                                                         $0.00
Total, Study Plan, Test Rules
                                                                         14.202
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                         139.18
                                                                    $10,636.83
                                                                         $0.00
                                                                    $10,636.83
Footnotes:
[1] Assumes one sponsor per chemical.

IC #4: Test Results, Test Rules  -  Total Respondent Burden and Costs
Based on the unit burden estimates presented in Table 9, as well as the estimated number of responses in Table 19, the total respondent burden and costs for test results under test rules are presented below in Table 23.
Table 23. IC #4 Test Results, Test Rules  -  Annual Total Respondent Burden and Costs (2018$)
                                   Activity
                         Adjusted Unit Burden (hours)
                     Number of Respondents (Sponsors) [1]
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                             Total Burden (hours)
                               Total Labor Cost
                             Total Non-Labor Cost
                                  Total Cost
Study Final Report
                                                                         93.320
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                         914.54
                                                                    $69,797.36
                                                                         $0.00
                                                                    $69,797.36
Study Corporate Review
                                                                         13.998
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                         137.18
                                                                    $10,986.78
                                                                         $0.00
                                                                    $10,986.78
Laboratory Review
                                                                         13.998
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                         137.18
                                                                    $10,469.63
                                                                         $0.00
                                                                    $10,986.78
Total, Reporting
                                                                        121.316
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                       1,188.90
                                                                    $91,253.77
                                                                         $0.00
                                                                    $91,253.77
Total, Recordkeeping
                                                                          1.167
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                          11.44
                                                                       $394.35
                                                                         $0.00
                                                                       $394.35
Total, Test Results, Test Rules
                                                                        122.483
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                       1,200.33
                                                                    $91,648.12
                                                                         $0.00
                                                                    $91,648.12
Footnotes:
[1] Assumes one sponsor per chemical.

IC #5: Initial Response, Test Orders  -  Total Respondent Burden and Costs
Based on the unit burden estimates presented in Table 10, as well as the estimated number of responses in Table 19, the total respondent burden and costs for initial response under test orders are presented below in Table 24.
Table 24. IC #5 Initial Response, Test Orders  -  Annual Total Respondent Burden and Costs (2018$)
                                   Activity
                         Adjusted Unit Burden (hours)
                     Number of Respondents (Sponsors) [1]
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                             Total Burden (hours)
                           Total Labor Cost (2018$)
                         Total Non-Labor Cost (2018$)
                              Total Cost (2018$)
Letter of Intent
                                                                          0.333
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                         65.268
                                                                     $4,980.36
                                                                         $0.00
                                                                     $4,980.36
Subtotal, Letter of Intent Total
                                                                          0.333
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                         65.268
                                                                     $4,980.36
                                                                         $0.00
                                                                     $4,980.36
OR

Prepare Exemption Application
                                                                          2.000
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                        392.000
                                                                    $29,917.44
                                                                         $0.00
                                                                    $29,917.44
Corporate Review
                                                                          6.000
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                      1,176.000
                                                                    $94,185.84
                                                                         $0.00
                                                                    $94,185.84
Subtotal, Exemption Application Reporting
                                                                          8.000
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                      1,568.000
                                                                   $124,103.28
                                                                         $0.00
                                                                   $124,103.28
Subtotal, Recordkeeping
                                                                          0.500
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                         98.000
                                                                    $3, 381.00
                                                                         $0.00
                                                                     $3,381.00
Subtotal, Exemption Application
                                                                          8.000
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                      1,666.000
                                                                   $127,484.28
                                                                         $0.00
                                                                   $124,103.28
Overall Total, Initial Response including Exemption Applications Reporting
                                                                          4.167
                                                                         140.00
                                                                         140.00
                                                                           2.80
                                                                      1,633.268
                                                                   $129,083.64
                                                                         $0.00
                                                                   $127,484.28
Overall Recordkeeping
                                                                          0.500
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                         98.000
                                                                     $3,381.00
                                                                         $0.00
                                                                     $3,381.00
Overall Total, Initial Response including Exemption Applications
                                                                          4.417
                                                                         140.00
                                                                         140.00
                                                                           2.80
                                                                      1,731.268
                                                                   $132,464.64
                                                                         $0.00
                                                                   $132,464.64
Footnotes:
[1] Assumes one sponsor per chemical.

IC #6: Study Plan, Test Orders  -  Total Respondent Burden and Costs
Based on the unit burden estimates presented in Table 11, as well as the estimated number of responses in Table 19, the total respondent burden and costs for study plans under test orders are presented below in Table 25.
Table 25. IC #6 Study Plan, Test Orders  -  Annual Total Respondent Burden and Costs (2018$)
                                   Activity
                         Adjusted Unit Burden (hours)
                     Number of Respondents (Sponsors) [1]
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                             Total Burden (hours)
                               Total Labor Cost
                             Total Non-Labor Cost
                                  Total Cost
Study Plan
                                                                         12.987
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                       2,545.45
                                                                   $194,269.32
                                                                         $0.00
                                                                   $194,269.32
CBI Substantiation
                                                                          1.215
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                         238.14
                                                                    $18,467.12
                                                                         $0.00
                                                                    $18,467.12
Total, Reporting
                                                                         14.202
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                       2,783.59
                                                                   $212,736.44
                                                                         $0.00
                                                                   $212,736.44
Total, Recordkeeping
                                                                          0.000
                                                                           0.00
                                                                           0.00
                                                                           2.80
                                                                           0.00
                                                                         $0.00
                                                                         $0.00
                                                                         $0.00
Total, Study Plan, Test Orders
                                                                         14.202
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                       2,783.59
                                                                   $212,736.44
                                                                         $0.00
                                                                   $212,736.44
Footnotes:
[1] Assumes one sponsor per chemical.

IC #7: Test Results, Test Orders  -  Total Respondent Burden and Costs
Based on the unit burden estimates presented in Table 12, as well as the estimated number of responses in Table 19, the total respondent burden and costs for test results under test orders are presented below in Table 26.
Table 26. IC #7 Test Results, Test Orders  -  Annual Total Respondent Burden and Costs (2018$)
                                   Activity
                         Adjusted Unit Burden (hours)
                      Number of Respondents (Sponsors)[1]
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                             Total Burden (hours)
                               Total Labor Cost
                             Total Non-Labor Cost
                                  Total Cost
Study Final Report
                                                                         93.320
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                      18,290.72
                                                                 $1,395,947.28
                                                                         $0.00
                                                                 $1,395,947.28
Study Corporate Review
                                                                         13.998
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                       2,743.61
                                                                   $219,735.60
                                                                         $0.00
                                                                   $219,735.60
Laboratory Review
                                                                         13.998
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                       2,743.61
                                                                   $209,392.68
                                                                         $0.00
                                                                   $209,392.68
Total, Reporting
                                                                        121.316
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                      23,777.94
                                                                 $1,825,075.56
                                                                         $0.00
                                                                 $1,825,075.56
Total, Recordkeeping
                                                                          1.167
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                         228.73
                                                                     $7,887.04
                                                                         $0.00
                                                                     $7,887.04
Total, Test Results, Test Orders
                                                                        121.316
                                                                          70.00
                                                                          70.00
                                                                           2.80
                                                                      24,006.67
                                                                 $1,832,962.60
                                                                         $0.00
                                                                 $1,832,962.60
Footnotes:
[1] Assumes one sponsor per chemical.

IC #8: Voluntary Initial Contact, ECAs  -  Total Respondent Burden and Costs
Based on the unit burden estimates presented in Table 13, as well as the estimated number of responses in Table 19, the total respondent burden and costs for voluntary initial contact under ECAs are presented below in Table 27.
Table 27. IC #8 Voluntary Initial Contact, ECAs  -  Annual Total Respondent Burden and Costs (2018$)
                                   Activity
                         Adjusted Unit Burden (hours)
                      Number of Respondents (Sponsors)[1]
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                             Total Burden (hours)
                           Total Labor Cost (2018$)
                         Total Non-Labor Cost (2018$)
                              Total Cost (2018$)
Request to Negotiate
                                                                          0.333
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                          3.263
                                                                       $249.02
                                                                         $0.00
                                                                       $249.02
Total, Reporting
                                                                          0.333
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                          3.263
                                                                       $249.02
                                                                         $0.00
                                                                       $249.02
Total, Recordkeeping
                                                                          0.000
                                                                           0.00
                                                                           0.00
                                                                           2.80
                                                                           0.00
                                                                         $0.00
                                                                         $0.00
                                                                         $0.00
Total, Voluntary Initial Contact, ECAs
                                                                          0.333
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                          3.263
                                                                       $249.02
                                                                         $0.00
                                                                       $249.02
Footnotes:
[1] Assumes one sponsor per chemical.

IC #9: Study Plan, ECAs
Based on the unit burden estimates presented in Table 14, as well as the estimated number of responses in Table 19, the total respondent burden and costs for study plans under ECAs are presented below in Table 28.
Table 28. IC #9 Study Plan, ECAs  -  Annual Total Respondent Burden and Costs (2018$)
                                   Activity
                         Adjusted Unit Burden (hours)
                      Number of Respondents (Sponsors)[1]
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                             Total Burden (hours)
                               Total Labor Cost
                             Total Non-Labor Cost
                                  Total Cost
Study Plan
                                                                         12.987
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                        127.273
                                                                     $9,713.47
                                                                         $0.00
                                                                     $9,713.47
CBI Substantiation
                                                                          1.215
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                         11.907
                                                                       $923.36
                                                                         $0.00
                                                                       $923.36
Total, Reporting
                                                                         14.202
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                        139.180
                                                                    $10,636.83
                                                                         $0.00
                                                                    $10,636.83
Total, Recordkeeping
                                                                          0.000
                                                                           0.00
                                                                           0.00
                                                                           2.80
                                                                          0.000
                                                                         $0.00
                                                                         $0.00
                                                                         $0.00
Total, Study Plan, ECAs
                                                                         14.202
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                        139.180
                                                                    $10,636.83
                                                                         $0.00
                                                                    $10,636.83
Footnotes:
[1] Assumes one sponsor per chemical.

IC #10: Test Results, ECAs
Based on the unit burden estimates presented in Table 15, as well as the estimated number of responses in Table 19, the total respondent burden and costs for test results under ECAs are presented below in Table 29.
Table 29. IC #10 Test Results, ECAs  -  Annual Total Respondent Burden and Costs
                                   Activity
                         Adjusted Unit Burden (hours)
                     Number of Respondents (Sponsors) [1]
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                             Total Burden (hours)
                               Total Labor Cost
                             Total Non-Labor Cost
                                  Total Cost
Study Final Report
                                                                         93.320
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                        914.536
                                                                    $69,797.36
                                                                         $0.00
                                                                    $69,797.36
Study Corporate Review
                                                                         13.998
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                        137.180
                                                                    $10,986.78
                                                                         $0.00
                                                                    $10,986.78
Laboratory Review
                                                                         13.998
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                        137.180
                                                                    $10,469.63
                                                                         $0.00
                                                                    $10,469.63
Total, Reporting
                                                                        121.316
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                      1,188.896
                                                                    $91,253.77
                                                                         $0.00
                                                                    $91,253.77
Total, Recordkeeping
                                                                          1.167
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                         11.437
                                                                       $394.35
                                                                         $0.00
                                                                       $394.35
Total, Test Results,  ECAs
                                                                        122.483
                                                                           3.50
                                                                           3.50
                                                                           2.80
                                                                      1,200.333
                                                                    $91,648.12
                                                                         $0.00
                                                                    $91,648.12
Footnotes:
[1] Assumes one sponsor per chemical.

IC #11: Voluntary Robust Summaries for Test Rules, Test Orders, and ECAs
Based on the unit burden estimates presented in Table 16, as well as the estimated number of responses in Table 19, the total respondent burden and costs for robust summaries are presented below in Table 30.

Table 30. IC #11 Voluntary Robust Summaries for Test Rules, Test Orders, and ECAs  -  Annual Total Respondent Burden and Costs (2018$)
                                   Activity
                         Adjusted Unit Burden (hours)
                     Number of Respondents (Sponsors) [1]
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                             Total Burden (hours)
                               Total Labor Cost
                             Total Non-Labor Cost
                                  Total Cost
Robust Summary
                                                                          0.400
                                                                          77.00
                                                                          77.00
                                                                           2.80
                                                                         86.240
                                                                     $6,575.80
                                                                         $0.00
                                                                     $6,575.80
Total, Reporting
                                                                          0.400
                                                                          77.00
                                                                          77.00
                                                                           2.80
                                                                         86.240
                                                                     $6,575.80
                                                                         $0.00
                                                                     $6,575.80
Total, Recordkeeping
                                                                          0.000
                                                                           0.00
                                                                           0.00
                                                                           2.80
                                                                          0.000
                                                                         $0.00
                                                                         $0.00
                                                                         $0.00
Total, Robust Summaries (Voluntary)
                                                                          0.400
                                                                          77.00
                                                                          77.00
                                                                           2.80
                                                                         86.240
                                                                     $6,575.80
                                                                         $0.00
                                                                     $6,575.80
Footnotes:
[1] Assumes one sponsor per chemical.

IC #12: Voluntary Data Submissions
Based on the unit burden estimates presented in Table 17, as well as the assumption that there is one voluntary data submission for one chemical each year, the total respondent burden and costs for voluntary data submissions are presented below in Table 31.
Table 31. IC #12 Voluntary Data Submissions - Annual Total Respondent Burden and Costs (2018$)
                                   Activity
                         Adjusted Unit Burden (hours)
                             Number of Respondents
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                             Total Burden (hours)
                               Total Labor Cost
                             Total Non-Labor Cost
                                  Total Cost
Paper Submission of Final Reports
                                                                         10.000
                                                                          24.50
                                                                          24.50
                                                                           2.80
                                                                        686.000
                                                                    $23,667.00
                                                                     $1,002.93
                                                                    $24,669.93
Total, Reporting
                                                                         10.000
                                                                          24.50
                                                                          24.50
                                                                           2.80
                                                                        686.000
                                                                    $23,667.00
                                                                     $1,002.93
                                                                    $24,669.93
Total, Recordkeeping
                                                                          1.000
                                                                          24.50
                                                                          24.50
                                                                           2.80
                                                                         68.600
                                                                     $2,366.70
                                                                         $0.00
                                                                     $2,366.70
Total, Voluntary Data Submissions
                                                                         11.000
                                                                          24.50
                                                                          24.50
                                                                           2.80
                                                                        754.600
                                                                    $26,033.70
                                                                     $1,002.93
                                                                    $27,036.63
Footnotes:
[1] Assumes one sponsor per chemical.

IC #13: Testing Costs (Non-Labor Costs)  -  Total Respondent Burden and Costs
Based on the unit non-labor cost estimates presented in Table 18, as well as the estimated number of responses in Table 19, the total respondent non-labor costs for testing costs are presented below in Table 32.
Table 32. IC #13 Testing Costs (Non-Labor Costs)  -  Annual Total Respondent Burden and Costs (2018$)
                                   Activity
                         Adjusted Unit Burden (hours)
                     Number of Respondents (Sponsors) [1]
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                             Total Burden (hours)
                               Total Labor Cost
                             Total Non-Labor Cost
                                  Total Cost
Laboratory Costs
                                                                          0.000
                                                                          77.00
                                                                          77.00
                                                                           2.80
                                                                         0.0000
                                                                         $0.00
                                                                 $4,180,986.35
                                                                 $4,180,986.35
Consortium Management
                                                                          0.000
                                                                          77.00
                                                                          77.00
                                                                           2.80
                                                                         0.0000
                                                                         $0.00
                                                                   $627,148.06
                                                                   $627,148.06
Technical Experts
                                                                          0.000
                                                                          77.00
                                                                          77.00
                                                                           2.80
                                                                         0.0000
                                                                         $0.00
                                                                   $418,097.99
                                                                   $418,097.99
Total, Testing Costs (Non-Labor Costs)
                                                                          0.000
                                                                          77.00
                                                                          77.00
                                                                           2.80
                                                                         0.0000
                                                                         $0.00
                                                                 $5,226,232.40
                                                                 $5,226,232.40
Footnotes:
[1] Assumes one sponsor per chemical.

Total Respondent Annual Hours and Costs
Table 33 summarizes the estimated total reporting burden and cost according to ICs on an annual basis. Similarly, the total burden and cost according to actions are summarized in Table 34.
With respect to reporting burden and cost, EPA estimates that this ICR will impose a total of 32,147 burden hours annually with an annual average respondent burden for a TSCA Section 4 action estimated at about 137 hours for test rules, test orders, or ECAs (response is on a per-chemical, or submission basis). For CDX registrations, the average annual respondent burden is 0.53 hours per registration.

Table 33. Summary of Annual Total Respondent Burden and Cost (2018$), by IC
                          Information Collection (IC)
                         Adjusted Unit Burden (Hours)
                      Number of Respondents (Sponsors)[1]
            Number of Responses (Chemicals Tested within an Action)
                                Overlap Factor
                          Total Annual Burden (Hours)
                           Total Annual Labor Costs
                         Total Annual Non-Labor Costs
                              Total Annual Costs
1. CDX Registration
                                                                          0.530
                                                                          10.70
                                                                          10.70
                                                                            2.8
                                                                          15.88
                                                                     $1,211.88
                                                                         $0.00
                                                                     $1,211.88
                                  Test Rules
2. Initial Response, Test Rules
                                                                          4.416
                                                                              7
                                                                              7
                                                                            2.8
                                                                          86.56
                                                                     $6,623.23
                                                                         $0.00
                                                                     $6,623.23
3. Study Plan, Test Rules
                                                                         14.202
                                                                            3.5
                                                                            3.5
                                                                            2.8
                                                                         139.18
                                                                    $10,636.83
                                                                         $0.00
                                                                    $10,636.83
4. Test Results, Test Rules
                                                                        122.483
                                                                            3.5
                                                                            3.5
                                                                            2.8
                                                                       1,200.33
                                                                    $91,648.12
                                                                         $0.00
                                                                    $91,648.12
                                  Test Orders
5. Initial Response, Test Orders
                                                                          4.417
                                                                            140
                                                                            140
                                                                            2.8
                                                                       1,731.77
                                                                   $132,464.64
                                                                         $0.00
                                                                   $132,464.64
6. Study Plan, Test Orders
                                                                         14.202
                                                                             70
                                                                             70
                                                                            2.8
                                                                       2,783.59
                                                                   $212,736.44
                                                                         $0.00
                                                                   $212,736.44
7. Test Results, Test Orders
                                                                        122.483
                                                                             70
                                                                             70
                                                                            2.8
                                                                      24,006.67
                                                                 $1,832,962.60
                                                                         $0.00
                                                                 $1,832,962.60
                     Enforceable Consent Agreements (ECAs)
8. Voluntary Initial Contact, ECAs
                                                                          0.333
                                                                            3.5
                                                                            3.5
                                                                            2.8
                                                                           3.26
                                                                       $249.02
                                                                         $0.00
                                                                       $249.02
9. Study Plan, ECAs
                                                                         14.202
                                                                            3.5
                                                                            3.5
                                                                            2.8
                                                                         139.18
                                                                    $10,636.83
                                                                         $0.00
                                                                    $10,636.83
10. Test Results, ECAs
                                                                        122.483
                                                                            3.5
                                                                            3.5
                                                                            2.8
                                                                       1,200.33
                                                                    $91,648.12
                                                                         $0.00
                                                                    $91,648.12
                              Voluntary  -  Other
11. Robust Summaries (Voluntary) for Test Rules, Test Orders, and ECAs
                                                                          0.400
                                                                           77.0
                                                                           77.0
                                                                            2.8
                                                                          86.24
                                                                     $6,575.80
                                                                         $0.00
                                                                     $6,575.80
12. Voluntary Data Submission
                                                                         11.000
                                                                           24.5
                                                                           24.5
                                                                            2.8
                                                                         754.60
                                                                    $26,033.70
                                                                     $1,002.93
                                                                    $27,036.63
                                    Testing
13. Laboratory Costs (Non-Labor Costs)
                                                                           0.00
                                                                             77
                                                                             77
                                                                            2.8
                                                                           0.00
                                                                         $0.00
                                                                 $5,226,232.40
                                                                 $5,226,232.40
Total

                                                                            175
                                                                          262.7
                                                                            2.8
                                                                         32,147
                                                                    $2,423,427
                                                                    $5,227,235
                                                                    $7,650,663
Notes: All ICs listed above include recordkeeping costs, where applicable
[1] Assumes one sponsor per chemical.

Table 34. Summary of Annual Total Burden and Costs (2018$), by Action

                   Adjusted Unit Burden per Response (Hours)
                             Number of Respondents
          Number of Responses (e.g., Chemicals Tested for an Action)
                                Overlap Factor
                          Total Annual Burden (Hours)
                           Total Annual Labor Costs
                         Total Annual Non-Labor Costs
                              Total Annual Costs
                            Section 4 Test Sponsors
Test Rules [1]
                                                                        137.418
                                                                            3.5
                                                                            3.5
                                                                            2.8
                                                                      1,346.70
                                                                   $102,832.87
                                                                         $0.00
                                                                   $102,832.87
Test Orders [2]
                                                                        137.418
                                                                           70.0
                                                                           70.0
                                                                            2.8
                                                                     26,933.93
                                                                 $2,056,657.40
                                                                         $0.00
                                                                 $2,056,657.40
Enforceable Consent Agreements (ECAs) 3
                                                                        137,418
                                                                            3.5
                                                                            3.5
                                                                            2.8
                                                                      1,346.70
                                                                   $102,832.87
                                                                         $0.00
                                                                   $102,832.87
Voluntary Data Submissions 4
                                                                         11.000
                                                                           24.5
                                                                           24.5
                                                                            2.8
                                                                        754.60
                                                                    $26,033.70
                                                                     $1,002.93
                                                                    $27,036.36
Testing Costs, Non-Labor (Test Rules, Test Orders, ECAs) [5]

                                                                          77.00
                                                                           77.0
                                                                            2.8
                                                                           0.00
                                                                         $0.00
                                                                 $5,226,232.40
                                                                 $5,226,232.40
Subtotal, Testing

                                                                          101.5
                                                                          178.5
                                                                            2.8
                                                                      30,381.93
                                                                 $2,288,356.84
                                                                 $5,227,235.33
                                                                 $7,515,592.17
                        Section 4 Exemption Applicants
Subtotal, Exemption Applications
                                                                          8.500
                                                                           73.5
                                                                           73.5
                                                                            2.8
                                                                      1,749.30
                                                                   $133,858.49
                                                                         $0.00
                                                                   $132,858.49
                                CDX Registrants
Subtotal, CDX Registration and e-Signature
                                                                          0.530
                                                                           10.7
                                                                           10.7
                                                                            2.8
                                                                         15.88
                                                                     $1,211.88
                                                                         $0.00
                                                                     $1,211.88
Total 6

                                                                          175.0
                                                                          262.7
                                                                            2.8
                                                                        32,147
                                                                    $2,423,427
                                                                    $5,227,235
                                                                    $7,650,663
                                   Universe
                          Total Number of Respondents
Total Number of Responses (Test Rules, Test Orders, ECAs, Voluntary Data Submissions, Exemption Applications, CDX)
                    Total Number of Chemicals Newly Tested
                                     175.0
                                     262.7
                                     101.5
General Notes:
1. All items listed above include recordkeeping activities, where applicable. Non-labor costs are not included.
2. Contributing sets of activities for each TSCA Section 4 Action are mapped as described in footnotes.
Footnotes:
[1] Includes Initial Response, Study Plan, Test Results, Voluntary Robust Summaries
[2] Includes Initial Response, Study Plan, and Test Results, Voluntary Robust Summaries
3 Includes Voluntary Initial Contact, Study Plan, and Test Results, Voluntary Robust Summaries
[4] Includes Voluntary Data Submission (final reports)
[5] Testing costs are incurred by the same respondents that are considered in test rules, test orders, and ECAs
[6] Note that the CDX Respondent count is not included in total respondent count because there are non-unique and already counted in other lines above.

PRA BURDEN STATEMENT
Under the PRA, burden is defined at 5 CFR 1320.3(b).
The annual public burden for this collection of information, which is approved under OMB Control No. 2070-0033, is estimated about 137 hours for the average response for a TSCA section 4 action on a per-chemical basis, not including CDX registration, and 0.53 hours per CDX registration. Burden is defined in 5 CFR 1320.3(b). An agency may not conduct or sponsor, and a person is not required to respond to a collection of information unless it displays a current and valid OMB control number. The OMB control numbers for EPA's regulations in title 40 of the CFR, after appearing in the Federal Register, are listed in 40 CFR part 9 and included on the related collection instrument or form, if applicable.
This request represents an increase of 29,020 hours from that currently in the OMB inventory (from 3,127 to 32,147 hours). As shown in Table 21, this increase is due to
 Changes in the number of actions
 CBI substantiation
 Methodological updates

Table 35. Summary of Changes in ICR Estimates
                            Type of Burden Estimate
                                 Previous ICR
                                    Changes
                                  ICR Renewal

    Changes in Number of Chemicals Tested within TSCA Section 4 Actions[1]
                              CBI Substantiation
                                Methodology[2]

                                     Unit
                                     Total
                                    Δ Unit
                                   Δ Total
                                    Δ Unit
                                   Δ Total
                                    Δ Unit
                                   Δ Total
                                     Unit
                                     Total
A. CDX Registration
                                                                           0.53
                                                                           4.45
                                                                           0.00
                                                                           1.22
                                                                           0.00
                                                                           0.00
                                                                           0.00
                                                                          10.21
                                                                           0.53
                                                                          15.88
B. Test Rules, including Robust Summaries, excluding Exemption Applications
                                                                         248.66
                                                                       2,486.60
                                                                           0.00
                                                                      -1,616.29
                                                                           1.22
                                                                           4.25
                                                                        -112.46
                                                                         472.14
                                                                         137.42
                                                                       1,346.70
C. Test Orders, including Robust Summaries, excluding Exemption Applications
                                                                         248.66
                                                                           0.00
                                                                           0.00
                                                                      17,406.20
                                                                           1.22
                                                                          85.05
                                                                        -112.46
                                                                       9,442.68
                                                                         137.42
                                                                      26,933.93
D. ECAs, including Robust Summaries
                                                                         248.66
                                                                         497.32
                                                                           0.00
                                                                         372.99
                                                                           1.22
                                                                           4.25
                                                                        -112.46
                                                                         472.14
                                                                         137.42
                                                                       1,346.70
E. Voluntary Data Submissions[3]
                                                                          11.00
                                                                         122.00
                                                                           0.00
                                                                         258.50
                                                                           0.00
                                                                           0.00
                                                                           0.00
                                                                         347.10
                                                                          11.00
                                                                         754.60
F. Exemption Applications
                                                                           8.50
                                                                          17.00
                                                                           0.00
                                                                         607.75
                                                                           0.00
                                                                           0.00
                                                                           0.00
                                                                       1,124.55
                                                                           8.50
                                                                       1,749.30
TOTAL
                                                                       3,127.37
                                                                      17,030.37
                                                                          93.56
                                                                      11,895.82
                                                                         32,147
Footnotes:
[1] Calculated according to methodology in previous ICR
[2] This ICR's methodology accounts for overlap and better captures the comprehensive view of the number of chemicals tested per year
3 Previous ICR reports 122 hours as the unit burden. The corrected number is 11 hours.

Reference Tables
      The tables in this section are provided for reference, as they contain supporting information for the analyses of Sections 4  -  5.

Table 36. Activity-Level Unit Burdens and Costs (2018$) by Activity and Type of Action
                                   Activity
                               Unit of Analysis
                               Managerial Burden
                                    (hours)
                               Technical Burden
                                    (hours)
                                Clerical Burden
                                    (hours)
                          Activity-Level Unit Burden
                                    (hours)
                               Average Wage Rate
                                  Labor Costs
                         Per-Activity Non-Labor Costs
                            Total per-Activity Cost

                                       a
                                       b
                                       c
                                 d = a + b + c
                                       e
                                   f = d x e
                                       g
                                   h = f + g
CDX

CDX Registration
Registration
                                                                          0.000
                                                                          0.180
                                                                          0.000
                                                                          0.180
                                                                        $76.33
                                                                        $13.74
                                                                         $0.00
                                                                        $13.74
CDX Electronic Signature
Registration
                                                                          0.000
                                                                          0.350
                                                                          0.000
                                                                          0.350
                                                                        $76.31
                                                                        $26.71
                                                                         $0.00
                                                                        $26.71
Initial Response (Test Rules, Test Orders, ECAs)
Letter of Intent
Chemical
                                                                          0.000
                                                                          1.000
                                                                          0.000
                                                                          1.000
                                                                        $76.32
                                                                        $76.32
                                                                         $0.00
                                                                        $76.32
Request to Negotiate
Chemical
                                                                          0.000
                                                                          1.000
                                                                          0.000
                                                                          1.000
                                                                        $76.32
                                                                        $76.32
                                                                         $0.00
                                                                        $76.32
Alternate Initial Response (Test Rules, Test Orders)

Prepare Exemption Application
Application
                                                                          0.000
                                                                          2.000
                                                                          0.000
                                                                          2.000
                                                                        $76.32
                                                                       $152.64
                                                                         $0.00
                                                                       $152.64
Corporate Review
Review
                                                                          6.000
                                                                          0.000
                                                                          0.000
                                                                          6.000
                                                                        $80.09
                                                                       $480.54
                                                                         $0.00
                                                                       $480.54
Recordkeeping
Record
                                                                          0.000
                                                                          0.000
                                                                          0.500
                                                                          0.500
                                                                        $34.50
                                                                        $17.25
                                                                         $0.00
                                                                        $17.25
Standardized Core Activities (Test Rules, Test Orders, ECAs)
Study Plan (ten tests)[1]
Chemical
                                                                          0.000
                                                                         39.000
                                                                          0.000
                                                                         39.000
                                                                        $76.32
                                                                     $2,976.48
                                                                         $0.00
                                                                     $2,976.48
CBI Substantiation[2]
Substantiation
                                                                          1.184
                                                                          2.465
                                                                          0.000
                                                                          3.649
                                                                        $77.54
                                                                       $282.96
                                                                         $0.00
                                                                       $282.96
Biannual Progress Report
(Long Duration Studies)
Report
                                                                          0.000
                                                                          8.000
                                                                          0.000
                                                                          8.000
                                                                        $76.32
                                                                       $610.56
                                                                         $0.00
                                                                       $610.56
Final Report
(Short Duration Studies)
Report
                                                                          0.000
                                                                         40.000
                                                                          0.000
                                                                         40.000
                                                                        $76.32
                                                                     $3,052.80
                                                                         $0.00
                                                                     $3,052.80
Final Report
(Long Duration Studies)
Report
                                                                          0.000
                                                                         80.000
                                                                          0.000
                                                                         80.000
                                                                        $76.32
                                                                     $6,105.60
                                                                         $0.00
                                                                     $6,105.60
Corporate Review
(Short Duration Studies)
Review
                                                                          6.000
                                                                          0.000
                                                                          0.000
                                                                          6.000
                                                                        $80.09
                                                                       $480.54
                                                                         $0.00
                                                                       $480.54
Corporate Review
(Long Duration Studies)
Review
                                                                          9.000
                                                                          0.000
                                                                          0.000
                                                                          9.000
                                                                        $80.09
                                                                       $720.81
                                                                         $0.00
                                                                       $720.81
Laboratory Review
Review
                                                                          0.000
                                                                          6.000
                                                                          0.000
                                                                          6.000
                                                                        $76.32
                                                                       $457.92
                                                                         $0.00
                                                                       $457.92
Recordkeeping
Record
                                                                          0.000
                                                                          0.000
                                                                          0.500
                                                                          0.500
                                                                        $34.50
                                                                        $17.25
                                                                         $0.00
                                                                        $17.25
Voluntary Robust Summaries (Test Rules, Test Orders, ECAs, Voluntary Data Submissions)
Robust Summary
Chemical
                                                                          0.000
                                                                         12.000
                                                                          0.000
                                                                         12.000
                                                                        $76.32
                                                                       $915.84
                                                                         $0.00
                                                                       $915.84
Voluntary Data Submission[3]
Paper Submission of Final Reports
Chemical
                                                                          0.000
                                                                          0.000
                                                                         10.000
                                                                         10.000
                                                                        $34.50
                                                                       $345.00
                                                                        $14.62
                                                                        $359.62
Recordkeeping
Record
                                                                          0.000
                                                                          0.000
                                                                          1.000
                                                                          1.000
                                                                        $34.50
                                                                        $34.50
                                                                         $0.00
                                                                        $34.50
Testing Costs (ten tests) [4]
Laboratory Costs
Chemical
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                              -
                                                                         $0.00
                                                                 $1,663,397.00
                                                                 $1,663,397.00
Consortium Management
Chemical
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                              -
                                                                         $0.00
                                                                   $249,509.55
                                                                   $249,509.55
Technical Experts
Chemical
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                              -
                                                                         $0.00
                                                                   $166,339.70
                                                                   $166,339.70
Footnotes:
[1] For test rules or orders and testing agreements, the estimates of this ICR Revision are developed for a battery of ten tests per chemical (see Table A-1 for list of tests; see Table 4 for activity frequencies per chemical). For labor costs, with the exception of the activity "Study Plans," the activity-level burdens of this table are unaffected by the number of tests. However, for the activity, "Study Plans" involving different test counts, the activity-level (and chemical-level) unit burden estimate for "Study Plans" is obtained by multiplying the number of tests by 3.9 hours per test-per chemical to obtain hours per chemical.
[2] Drawn from the burden and cost report for the final TSCA Inventory Notification Requirements rule (EPA, 2017a) with adjustments for number of applicable data elements and the list of substantiation questions
[3] Voluntary Submissions are the only type of TSCA Section 4 submission that are not required to be submitted electronically. Paper and postage costs for final reports and robust summaries are estimated under "Per-Activity Supply Cost." These costs assumed that a voluntary submission contains: ten final reports averaging 35 pages, plus a cover letter and robust summary, totaling 352 pages. Paper costs at $0.0112 per page total $3.94 (Staples, 2019). Postage via 2-day FedEx Ground for the 0.4 lb package totals $10.68 (FedEx, 2019).
[4] For test rules or orders and testing agreements, the estimates of this ICR Revision are developed for a battery of ten tests per chemical (see Table A-1 for list of tests). For testing costs, the activity-level (and chemical-level) unit burden is obtained based on the laboratory costs. Consortium management is estimated as 15 percent of laboratory costs, and technical experts is estimated as 10 percent of laboratory costs.

      Estimation of industry unit cost per submission involves combining the activity-level unit burdens identified in Section 5 with wage data for December 2018 (Bureau of Labor Statistics (BLS), 2019) from BLS, as converted from raw wage rate and benefit data to loaded wage rates. Table 37 presents the resultant loaded wage rates for managerial, professional/technical, and clerical staff.
Table 37. Industry Wage Rates (2018$)
                                Labor Category
                                 Data Series a
                                     Date
                                     Wage
                                Fringe Benefit
                               Fringes as % Wage
                              Overhead % wage [b]
                         Fringe + Overhead Factor [c]
                           Hourly Loaded Wages [d]

                                      (a)
                                      (b)
                                 (c) =(b)/(a)
                                      (d)
                                (e)= (c)+(d)+1
                                 (f)=(a)x(e)
Managerial
BLS ECEC, Private Manufacturing industries, "Mgt, Business, and Financial"
                                    Dec-18
                                    $48.73
                                    $23.08
                                      47%
                                      17%
                                     1.64
                                    $80.09
Professional / Technical
BLS ECEC, Private Manufacturing industries, "Professional and related"
                                    Dec-18
                                    $44.35
                                    $24.43
                                      55%
                                      17%
                                     1.72
                                    $76.32
Clerical
BLS ECEC, Private Manufacturing industries, "Office and Administrative Support"
                                    Dec-18
                                    $20.77
                                    $10.20
                                      49%
                                      17%
                                     1.66
                                    $34.50
Footnotes:
[a] Source: Employer Costs for Employee Compensation Historical Supplementary Tables: December 2006  -  March 2019. All rates are rounded to the nearest cent.
[b] An overhead rate of 17 percent is used based on assumptions in Wage Rates for Economic Analysis of the Toxics Release Inventory Program (Rice, 2002), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPA, 2002).
[c] The inflation factor of "1" in the formula for calculating the fringe + overhead factor means wage data are not escalated to reflect inflation.
[d] Wage data are rounded to the closest cent in this analysis.

      Agency costs are based on the assumption that the Agency collection procedures are accomplished, on average, by a GS-13, Step 1 employee for EPA Program Staff and a GS-13, Step 5 employee for EPA CBI Review Staff.
Table 38. Agency Wage Rate (2018$)
                                Labor Category
                       Data Source for Wage Information
                                 Wage ($/hour)
                                Fringe Benefit
                               Fringes as % Wage
                            Overhead as % wage [b]
                         Fringe + Overhead Factor [c]
                             Hourly Loaded Wages

                                      (a)
                                      (b)
                                 (c) =(b)/(a)
                                      (d)
                                (e)= (c)+(d)+1
                                 (f)=(a)x(e)
EPA Program Staff
Annual federal staff cost: OPM Washington-Baltimore-Northern Virginia, DC-MD-PA-VA-WV area, GS-13 Step 1 pay rates [a]
                                    $46.46
                           Included in 60% overhead
                                      N/A
                                    60% [b]
                                      1.6
                                    $74.34
EPA CBI Review Staff
Annual federal staff cost: OPM Washington-Baltimore-Northern Virginia, DC-MD-PA-VA-WV area, GS-13 Step 5 pay rates [a]
                                    $52.66
                           Included in 60% overhead
                                      N/A
                                    60% [b]
                                      1.6
                                    $84.26
Footnotes: