ECONOMIC
ANALYSIS
OF
PROPOSED
AMENDMENTS
TO
THE
TSCA
SECTION
8
INVENTORY
UPDATE
RULE
Economic
and
Policy
Analysis
Branch
Economics,
Exposure
and
Technology
Division
Office
of
Pollution
Prevention
and
Toxics
U.
S.
Environmental
Protection
Agency
March
1,
1999
Addendum,
Executive
Summary,
and
Summary
Revised
July
29,
1999
i
TABLE
OF
CONTENTS
Page
LIST
OF
TABLES
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FIGURES
AND
BOXES
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vi
EXECUTIVE
SUMMARY
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ES­
1
SUMMARY
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S­
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ADDENDUM
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AD­
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I.
INTRODUCTION
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A.
Statutory
Authority
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B.
Description
of
Rule
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I­
2
C.
Overview
of
the
Regulated
Community
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I­
8
D.
Purpose
and
Contents
of
Report
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I­
11
II.
STATEMENT
OF
PROBLEM
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II­
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A.
Statement
of
Need
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II­
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B.
Approaches
to
Regulation
and
Options
for
Collecting
Information
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II­
10
III.
INDUSTRY
COSTS
OF
THE
PROPOSAL
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III­
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A.
Overview
and
Methodology
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III­
1
B.
Baseline
Costs
of
Compliance
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III­
10
C.
Costs
of
the
Proposed
Amendments
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III­
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D.
Overview
of
Reporting
Options
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III­
35
IV.
AGENCY
COSTS
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IV­
1
A.
Overview
and
Methodology
of
Determining
Agency
Costs
of
Reporting
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IV­
1
B.
Agency
Tasks
and
Costs
Under
the
Original
IUR
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The
Baseline
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IV­
2
C.
Agency
Tasks
and
Costs
Under
the
Proposed
IUR
Amendments
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IV­
7
D.
Total
Agency
Costs
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IV­
10
V.
IUR
AMENDMENTS
BENEFITS
ASSESSMENT
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V­
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A.
Benefits
from
Use
and
Exposure
Data
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V­
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B.
Benefits
Due
to
Fewer
CBI
Claims
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V­
16
C.
Benefits
of
Changing
Certain
Exemptions
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V­
17
D.
Administrative
and
Related
Benefits
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V­
19
E.
Benefits
From
Reporting
Thresholds
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V­
19
F.
Benefits
From
Reporting
Cycle
Options
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V­
24
VI.
COST
BENEFIT
ANALYSIS
AND
COST­
EFFECTIVENESS
COMPARISONS
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VI­
1
VII.
SMALL
ENTITITY
AND
ENVIRONMENTAL
JUSTICE
IMPACT
DETERMINATIONS
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VII­
1
A.
Small
Entity
Analysis
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VII­
1
B.
Analysis
of
Economic
Impacts
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VII­
5
C.
Environmental
Equity
/
Justice
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VII­
9
REFERENCES
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R­
1
ii
Appendix
A.
Draft
Reporting
Form
for
the
Proposed
IUR
Amendments
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A­
1
Appendix
B.
Current
Data
Collection
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B­
1
Appendix
C.
Development
of
the
Estimated
Numbers
of
Expected
Submissions
for
the
Original
IUR
and
IUR
Amendments
Reporting
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C­
1
Appendix
D.
Industry
Survey
Results
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D­
1
Appendix
E.
Sensitivity
Analysis
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E­
1
iii
LIST
OF
TABLES
Table
S­
1:
Options
Summary
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S­
6
Table
S­
2:
Summary
of
Proposed
IUR
Amendments
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S­
13
Table
AD­
1:
Proposed
IUR
Amendments
­
Cost
and
Burden
Estimates
­
Variations
Based
on
Changes
in
Proposal
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AD­
4
Table
I­
1:
Standard
Industrial
Codes
for
Industries
Likely
to
Be
Subject
to
IUR
Reporting
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I­
9
Table
II­
1:
Components
of
Exposure
Assessments
and
Exposure­
Related
Data
Elements
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II­
6
Table
II­
2:
Options
for
the
Proposed
IUR
Amendments
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II­
14
Table
III­
1:
Loaded
Hourly
Wage
Rates
by
Labor
Category
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III­
4
Table
III­
2:
Estimate
of
Industry
Reporting
Burden
for
Sections
of
Revised
Form
U
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III­
9
Table
III­
3:
Baseline
Cost
of
Compliance
Determination
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III­
13
Table
III­
4:
Baseline
Cost
of
Rule
Familiarization
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III­
13
Table
III­
5:
Baseline
Cost
of
Report
Preparation
and
Submission
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III­
14
Table
III­
6:
Baseline
Cost
of
Recordkeeping
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III­
15
Table
III­
7:
Baseline
Cost
of
Compliance
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
16
Table
III­
8:
Annual
Baseline
Cost
by
Production
Volume
Category
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
17
Table
III­
9:
Baseline
First
Year,
Net
Present
Value,
and
Annualized
Costs
According
to
Chemical
Type,
Discounted
at
3
Percent
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
18
Table
III­
10:
Incremental
Burden
Per
Site
of
Rule
Familiarization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
20
Table
III­
11:
Incremental
Costs
of
Rule
Familiarization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
21
Table
III­
12:
First
Year
Incremental
Cost
of
Preparation
and
Submission
of
a
Report
Associated
with
the
Amendments
for
Sites
Already
Reporting
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
24
Table
III­
13:
Scaling
Factors
for
Unit
Cost
of
Preparation
and
Submission
of
Reports
in
Future
Reporting
Cycles
Under
Proposed
IUR
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
27
Table
III­
14:
Future
Years
Incremental
Cost
of
Preparation
and
Submission
of
a
Report
under
the
Proposed
IUR
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
28
Table
III­
15:
Incremental
Burden
Per
Report
of
Recordkeeping
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
29
Table
III­
16:
Incremental
Cost
of
Recordkeeping
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
30
Table
III­
17:
Summary
of
Incremental
Per
Report
Costs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
31
Table
III­
18:
Summary
of
Incremental
Per
Site
Costs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
31
iv
Table
III­
19:
Incremental
First
Year
Cost
of
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
33
Table
III­
20:
Total
First
Year
Cost
of
IUR
Compliance,
with
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
34
Table
III­
21:
Incremental
Annual
Cost
of
Amendments
in
Future
Years
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
34
Table
III­
22:
Total
Annual
Cost
of
IUR
Compliance,
with
Amendments,
in
Future
Years
.
.
.
.
.
.
III­
35
Table
III­
23:
Reporting
Options
for
the
Proposed
IUR
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
37
Table
III­
24a:
Numbers
of
Reports
Expected
for
Each
Option
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
38
Table
III­
24b:
Numbers
of
Reports
by
Chemical
Type
Expected
for
Each
Option
.
.
.
.
.
.
.
.
.
.
.
.
III­
39
Table
III­
25:
Numbers
of
Sites
Expected
for
Each
Option
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
40
Table
III­
26:
Numbers
of
Chemicals
Expected
to
be
Reported
for
Each
Option
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
41
Table
III­
27:
Incremental
Net
Present
Values
and
Annualized
Costs
of
Amendment
Options
Discounted
at
Three
Percent
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
43
Table
III­
28:
Total
Net
Present
Values
and
Annualized
Costs
of
IUR
Compliance,
with
Different
Amendment
Options
Discounted
at
Three
Percent
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
44
Table
III­
29:
Results
for
Sensitivity
Around
the
Number
of
Reports
per
Site
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
48
Table
III­
30:
Incremental
Net
Present
Values
and
Annualized
Costs
of
Amendment
Options
Discounted
at
Seven
Percent
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
49
Table
III­
31:
Total
Net
Present
Values
and
Annualized
Costs
of
IUR
Compliance,
with
Different
Amendment
Options
Discounted
at
Seven
Percent
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
50
Table
IV­
1:
Estimated
Annual
Costs
for
Determining
Agency
Costs
for
the
Original
IUR
.
.
.
.
.
.
IV­
5
Table
IV­
2:
Estimated
One­
Time
Costs
for
Determining
Agency
Costs
for
the
Original
IUR
.
.
.
IV­
6
Table
IV­
3:
Estimated
Incremental
Annual
Costs
for
Determining
Agency
Costs
for
the
Proposed
IUR
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
IV­
10
Table
IV­
4:
Estimated
Incremental
One­
Time
Costs
for
Determining
Agency
Costs
for
the
Proposed
IUR
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
IV­
10
Table
IV­
5:
Estimated
Total
Annual
Agency
Costs
for
the
Amended
IUR
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
IV­
11
Table
IV­
6:
Estimated
Total
One­
Time
Agency
Costs
for
the
Amended
IUR
.
.
.
.
.
.
.
.
.
.
.
.
.
.
IV­
11
Table
V­
1:
Benefits
to
Existing
OPPT
Programs
of
Chemical
Processing
and
Use
Information
Collected
Under
the
Proposed
IUR
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
V­
9
Table
V­
2:
Reporting
Threshold
Options
for
the
Proposed
IUR
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
V­
21
Table
VI­
1:
Comparison
of
Information
Collected
Under
Each
Regulatory
Option
.
.
.
.
.
.
.
.
.
.
.
VI­
3
Table
VI­
2:
Comparison
of
Incremental
First
Year
Industry
Costs
Under
Each
Regulatory
Option
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
VI­
5
v
Table
VII­
1:
Size
of
Manufacturing
Companies
Producing
Organic
Chemicals
Based
on
Annual
Sales
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
VII­
4
Table
VII­
2:
Effect
of
IUR
Amendments
on
Small
Businesses
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
VII­
8
Table
VII­
3:
Effect
of
IUR
Amendments
on
Small
Businesses
Assuming
Two
Sites
Per
Small
Business
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
VII­
9
vi
FIGURES
AND
BOXES
Figure
III­
1:
Allocation
of
IUR
Reporting
Costs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
46
Figure
V­
1:
Flow
of
Chemicals
Through
OPPT's
Screening
and
Risk
Management
Programs
.
.
.
V­
6
Box
I­
1:
Chemical­
specific
Information
EPA
is
Authorized
to
Collect
Under
Section
8(
a)
of
the
Toxic
Substances
Control
Act
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
I­
2
Box
I­
2:
Proposed
Function
Categories
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
I­
7
Box
I­
3:
Proposed
Commercial
and
Consumer
Product
Categories
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
I­
8
Box
I­
4:
Reporting
Processing
and
Use
Information
on
Chemicals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
I­
11
Box
II­
1:
Progress
on
Screening
Chemicals
for
Risks
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
II­
2
Box
II­
2:
Reasons
for
Lack
of
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
II­
3
Box
II­
3:
Risk
Screening
Activities
Lack
Important
Data
on
Exposure
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
II­
7
Box
II­
4:
Current
Existing
Chemical
Review
Process
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
II­
9
Box
III­
1:
Comparison
of
Data
Elements
for
Completion
of
the
Original
and
Amended
Form
U
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
8
Box
III­
2:
Reporting
Burden
of
Complying
with
CBI
Requirements
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
III­
26
Box
V­
1:
EPA
Tools
to
Evaluate
and
Manage
Chemical
Risk
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
V­
8
ES­
1
EXECUTIVE
SUMMARY
The
Environmental
Protection
Agency
(
EPA)
currently
requires
manufacturers
and
importers
of
certain
chemical
substances
to
report
plant
site
and
production
volume
information
to
the
Agency
every
four
years.
The
information
is
collected
under
reporting
requirements
known
as
the
Inventory
Update
Rule
(
IUR),
based
on
EPA's
authority
under
Section
8(
a)
of
the
Toxic
Substances
Control
Act
(
TSCA).
EPA
is
proposing
to
amend
these
reporting
requirements
to
collect
additional
information.

The
economic
analysis
presented
here
examines
changes
in
reporting
that
would
result
from
these
amendments
and
associated
costs,
benefits,
and
impacts.

The
proposed
rule
would
amend
the
IUR
data
collection
in
several
ways.
First,
it
would
collect
various
types
of
exposure­
related
data
about
certain
chemicals
(
such
as
the
number
of
workers
potentially
exposed,
the
types
of
industrial
processes
the
chemical
is
used
in,
the
number
and
type
of
processing
sites,
the
types
of
commercial
and
consumer
uses
of
the
chemical,
and
the
concentration
in
these
products).
The
IUR
amendments
would
also
make
inorganic
chemicals
reportable,
raise
the
reporting
threshold,
add
a
second
threshold
for
reporting
use
information,
reduce
inappropriate
or
unnecessary
CBI
claims,
improve
links
to
other
EPA
data,
and
make
administrative
changes
that
would
enhance
the
effectiveness
of
the
data
collected
under
the
existing
regulation.

EPA
would
use
the
information
collected
under
this
proposed
rule
to
screen
chemicals
based
on
relative
risk,
set
risk
assessment
priorities
among
chemical
substances
of
potential
concern,
and
support
EPA's
pollution
prevention
and
environmental
protection
activities.
The
data
collected
through
these
amendments
would
help
to
determine
potential
risks,
identify
opportunities
for
safer
substitutes,

target
specific
population
groups,
and
evaluate
the
need
for
risk
management.
The
data
would
allow
EPA
to
better
focus
its
programs
and
use
resources
more
efficiently.
Currently,
the
lack
of
nationwide
information
related
to
chemical
production
and
use
prevents
the
Agency
from
screening
large
numbers
of
chemicals
in
a
timely
manner.
The
amended
IUR
data
are
critical
if
EPA
is
to
meet
its
Government
Performance
and
Results
Act
(
GPRA)
goal
to
screen
all
chemicals
in
commerce
by
2005.
ES­
2
This
report
analyzes
multiple
regulatory
options
for
amending
the
IUR
by
varying
the
reporting
thresholds,
exemptions,
and
reporting
cycle.
The
proposed
IUR
amendments
would
collect
basic
information
on
about
8,900
chemicals
out
of
the
more
than
75,000
chemicals
on
the
TSCA
Inventory.

Approximately
1,000
chemical
manufacturers
or
importers
would
be
required
to
report.
These
companies
would
submit
25,500
reports
covering
approximately
3,050
sites.
Approximately
40
percent
of
the
reports
(
covering
forty­
five
percent
of
the
chemicals)
would
be
full
reports
(
i.
e.,
containing
exposure­
based
use
information),
while
the
remaining
60
percent
would
be
partial
reports.
Most
of
these
reports
must
already
be
submitted
under
the
existing
IUR
requirements,
and
companies
would
simply
be
providing
additional
information.
However
the
IUR
amendments
would
also
adjust
the
universe
of
reportable
chemicals.
There
are
over
1,200
inorganic
chemicals
that
would
be
reportable
to
the
IUR
for
the
first
time,
and
about
1,500
originally
reportable
chemicals
that
would
no
longer
be
reported
as
a
result
of
the
increase
in
the
reporting
threshold.
Please
note
that
the
proposed
rule
was
revised
substantially
during
the
interagency
review
process;
the
addendum
to
this
economic
report
that
appears
before
chapter
1
contains
important
information
on
these
changes.

EPA
estimates
the
incremental
cost
of
the
amendments
to
be
between
$
36
million
and
$
51
million
for
the
first
reporting
cycle.
Costs
would
be
lower
after
the
first
year,
and
are
estimated
at
$
27
million
to
$
41
million
in
each
subsequent
reporting
cycle
(
every
four
years).
These
startup
and
quadrennial
costs
are
equivalent
to
an
annual
cost
of
between
$
10
million
and
$
14
million.

EPA
has
taken
a
number
of
steps
to
reduce
reporting
burden,
including
raising
the
reporting
threshold
from
the
existing
level
of
10,000
pounds
up
to
25,000
pounds;
introducing
a
second
threshold
of
300,000
pounds
to
reduce
the
number
of
reports
for
which
processing
and
use
information
must
be
provided;
establishing
a
partial
exemption
for
inorganic
chemicals
(
at
least
in
the
first
reporting
cycle);

establishing
a
partial
exemption
for
petroleum
stream
chemicals,
and
a
full
exemption
for
natural
gas;

requiring
the
reporting
of
only
known
or
reasonably
ascertainable
facility
and
manufacturing
information
and
readily
obtainable
processing
and
use
information;
and
allowing
submitters
to
report
much
of
the
information
in
ranges.

The
small
business
impacts
of
the
rule
are
minimal.
Most
small
businesses
are
not
affected,

since
the
regulations
exempt
companies
meeting
certain
small
business
criteria.
The
costs
would
be
relatively
small
for
those
small
businesses
that
would
report.
For
the
roughly
200
to
350
small
ES­
3
businesses
expected
to
report,
the
cost
of
reporting
is
estimated
at
0.20
percent
or
less
of
sales.

Because
the
regulatory
costs
represent
a
small
fraction
of
a
typical
firm's
sales,
the
financial
impacts
of
the
regulation
would
not
be
significant.

Because
the
proposed
IUR
amendments
are
an
information
collection
exercise,
there
are
no
negative
environmental
equity
issues
associated
with
them.
Instead,
the
information
that
would
become
available
through
the
proposed
rule
would
enable
the
Agency
to
target
educational,
regulatory,

or
enforcement
activities
towards
industries
or
chemicals
that
pose
the
greatest
risks
and
to
target
programs
for
population
groups
that
are
at
the
highest
risk.
Thus,
the
information
proposed
to
be
gathered
under
the
IUR
amendments
would
help
EPA
to
make
decisions
that
would
benefit
potentiallyat
risk
communities,
some
of
which
may
be
disadvantaged.
S­
1
SUMMARY
Introduction
Based
on
its
authority
under
Section
8(
a)
of
the
Toxic
Substances
Control
Act
(
TSCA),
the
Environmental
Protection
Agency
(
EPA)
currently
requires
manufacturers
and
importers
of
certain
chemicals
to
report
limited
data,
including
production
volume,
every
four
years.
The
regulation
that
requires
the
reporting
is
known
as
the
Inventory
Update
Rule
(
IUR).
EPA
is
proposing
to
amend
the
IUR
to
change
the
reporting
threshold,
alter
certain
reporting
exemptions,
require
companies
to
provide
use
and
exposure
information
for
some
of
the
chemicals,
and
make
administrative
and
confidential
business
information
(
CBI)
reporting
changes
that
would
enhance
the
effectiveness
of
the
existing
regulation.
The
additional
data
would
assist
EPA
in
evaluating
potential
exposures
and
risks
resulting
from
industrial
chemical
operations
and
consumer
uses
of
chemical
substances.
EPA
would
use
the
information
collected
under
this
proposed
rule
to
set
risk
assessment
priorities
among
chemical
substances
of
potential
concern
and
to
support
EPA's
pollution
prevention
and
environmental
protection
activities.
The
information
would
also
be
valuable
to
other
public
and
private
sector
organizations
for
similar
purposes.
This
analysis
reviews
the
costs,
benefits,
and
impacts
of
the
proposed
rule
to
amend
the
TSCA
Inventory
Update
Rule
reporting
requirements.

Background
Congress
enacted
TSCA
in
1976
to
establish
a
number
of
new
requirements
and
authorities
for
identifying
and
controlling
toxic
chemical
risks
to
human
health
and
the
environment.
To
implement
its
responsibilities
under
TSCA,
EPA
must
identify
potential
chemical
risks,
assess
the
magnitude
of
the
identified
risks,
and
manage
risks
determined
to
be
unreasonable.
TSCA
provides
EPA
with
the
authority
to
gather
information
(
such
as
chemical
toxicity,
chemical
exposure,
and
other
related
data)

to
determine
whether
a
chemical
substance
may
present
an
unreasonable
risk
of
injury
to
human
health
or
the
environment.

Section
8(
b)
of
TSCA
requires
EPA
to
compile
and
keep
current
an
inventory
of
chemical
substances
in
commerce
(
excluding
pesticides,
tobacco,
nuclear
material
and
byproducts,
firearms
and
ammunition,
food
and
food
additives,
drugs,
and
cosmetics).
In
1977
EPA
collected
basic
information
1
It
should
be
noted
that
the
numbers
of
chemicals,
reports
and
facilities
presented
above
include
statistics
for
chemicals
with
a
production
volume
lower
than
10,000
pounds
that
reported
voluntarily.

S­
2
about
subject
chemicals,
including
the
chemical
identity,
the
identity
of
sites
that
were
manufacturing
or
importing
the
chemical,
and
the
chemical's
production
volume
(
in
a
range).
EPA
compiled
the
information
into
the
initial
TSCA
Inventory.
The
TSCA
Inventory
originally
contained
approximately
60,000
chemicals.
As
new
chemicals
enter
into
commerce
in
the
U.
S.,
they
are
added
to
the
Inventory.
As
a
result,
the
Inventory
currently
contains
more
than
75,000
chemicals.

Section
8(
a)
of
TSCA
authorizes
EPA
to
collect
a
broad
variety
of
information
about
chemicals
in
commerce.
EPA
exercised
this
authority
in
1986
when
it
promulgated
the
Inventory
Update
Rule
(
51
FR
21438;
June
12,
1986).
The
Inventory
Update
Rule
(
IUR),
codified
at
40
CFR
Part
710,
requires
chemical
manufacturers
and
importers
to
provide
updated
information
for
chemicals
in
the
TSCA
Inventory
meeting
specific
criteria.
IUR
reporting
is
limited
to
manufacturers
and
importers
of
chemical
substances.
Small
businesses
as
defined
in
TSCA
section
8
are
exempted
from
reporting.

There
is
a
production
volume
threshold
of
10,000
pounds
a
year,
and
exemptions
from
reporting
for
inorganic
chemicals,
polymers,
microorganisms,
and
naturally
occurring
substances.
EPA
created
the
thresholds
and
exemptions
in
the
IUR
to
focus
the
data
collection
on
the
chemicals
thought
at
the
time
to
be
most
likely
to
require
information
for
screening
and
risk
assessment
purposes
and
to
exclude
chemicals
for
which
screening
data
were
thought
unlikely
to
be
needed.

The
IUR
requires
companies
to
submit
reports
every
four
years;
data
have
been
collected
in
1986,
1990,
1994
and
1998.
Under
the
original
IUR,
companies
report
company,
plant
site,
and
chemical
identity
information;
whether
the
chemical
is
manufactured
or
imported;
whether
it
is
site
limited
or
is
distributed
off­
site;
and
the
production
volume.
Companies
can
claim
specific
data
elements
as
confidential
business
information
(
CBI)
by
using
a
check­
box,
although
CBI
claims
for
chemical
identity
require
up­
front
substantiation.
Companies
must
retain
records
that
support
their
submissions
for
four
years
following
the
reporting
period.
EPA
received
about
25,000
submissions
from
3,000
facilities
for
about
8,900
chemicals
in
the
1994
reporting
cycle.
1
EPA
enters
the
information
into
the
Chemical
Update
System
(
CUS),
a
confidential
database.
S­
3
Need
to
Amend
the
Inventory
Update
Rule
EPA
uses
the
IUR
data
to
identify
chemical
substances,
plant
sites,
and
exposures
of
most
concern
and
to
set
priorities
for
more
detailed
risk
assessment
and
potential
risk
management
actions.

Although
risk
is
based
on
hazard
and
exposure,
EPA's
past
approaches
to
chemical
risk
screening
have
primarily
used
production
volume
as
a
proxy
for
exposure.
Where
available,
this
is
supplemented
by
relatively
scarce
public
data
on
chemical
use
and
exposures.
To
make
more
accurate
estimates,
EPA
needs
better
information
on
exposure.
Information
such
as
how
chemicals
are
used,
how
many
sites
use
the
chemical,
and
how
many
workers
are
potentially
exposed
would
enable
EPA
and
others
to
develop
exposure
scenarios.

The
existing
public
data
sources
are
inadequate
because
they
are
very
spotty
in
coverage
and
are
often
outdated.
While
EPA
has
used
these
sources
in
the
past
(
because
they
do
contain
some
useful
data),
they
are
far
from
adequate
for
prioritizing,
identifying
chemicals
of
concern
to
specific
populations,
and
managing
risks
on
a
nationwide
basis.

Existing
EPA
data
collections
typically
do
not
provide
exposure­
related
information
that
the
Agency
needs
for
risk
screening,
such
as
industrial
and
commercial
uses,
the
number
of
workers
potentially
exposed,
or
levels
of
use
in
consumer
products.
Many
programs
cover
only
a
limited
set
of
chemical
substances,
or
a
limited
number
of
chemical
uses,
or
only
specific
industry
sectors.
Others
are
regional,
rather
than
national
in
scope.
Some
of
the
programs
collect
information
on
categories
of
pollutants
or
on
waste
streams
and
not
on
specific
chemical
substances,
making
it
difficult
to
use
data
in
chemical
risk
screening.
And
some
collect
monitoring
data
for
a
specific
media
(
e.
g.,
air
or
water),

but
do
not
collect
information
on
the
potential
sources
of
the
chemical
releases
to
the
environment.

Commercial
data
sources
are
very
limited
in
the
number
of
uses
and
detail
of
use
information,

and
generally
provide
information
only
on
large
volume
chemicals.
Although
the
sources
can
provide
some
useful
information
for
these
large
volume
chemicals,
none
of
these
information
sources
(
considered
individually
or
in
aggregate)
would
be
adequate
substitutes
for
the
information
EPA
is
proposing
to
collect
because
each
either
covers
a
narrow
set
of
reportable
chemicals,
was
a
one­
time
collection,
or
does
not
contain
adequate
exposure­
related
data
elements
for
risk
screening.

Information
specific
to
the
manufacture
and
use
of
chemicals,
including
information
on
the
potential
for
exposure
during
the
chemical's
life
cycle,
have
not
been
comprehensively
or
S­
4
systematically
collected
at
the
national
level.
Each
of
the
existing
data
sources
has
limited
utility
due
to
a
small
or
specialized
sample
size,
a
limited
number
of
chemicals,
or
age
of
the
data.
None
of
the
databases,
either
alone
or
combined,
provide
the
Agency
with
the
necessary
array
of
screening
level
data.

After
reviewing
the
data
available
from
existing
sources,
EPA
determined
that
the
best
way
to
address
the
lack
of
exposure­
related
data
was
to
collect
basic
information
related
to
potential
chemical
exposures
through
the
IUR.
EPA
has
also
identified
problems
associated
with
the
original
IUR
reporting
requirements,
including
incomplete
facility
identity
information
that
creates
difficulties
in
matching
the
IUR
data
to
other
Agency
databases
and
the
Agency's
inability
to
publicly
cite
useful
information
because
a
company
has
inappropriately
claimed
that
the
data
should
be
classified
as
TSCA
CBI.
The
Agency
determined
that
amending
some
of
the
IUR's
administrative
and
CBI
provisions
would
provide
EPA
and
others
with
needed
flexibility
in
using
these
data.

Options
for
IUR
Amendments
Analyzed
In
addition
to
those
options
analyzed
during
the
interagency
review
process,
and
presented
in
the
addendum,
this
report
analyzes
fourteen
regulatory
options
for
amending
the
IUR
reporting
requirements.
The
options
were
created
by
varying
the
reporting
threshold
for
facility
and
manufacturing
data,
the
threshold
for
processing
and
use
data,
exemptions
based
on
the
type
of
chemical,
and
the
reporting
cycle.
These
options
are
summarized
in
Table
S­
1,
below.

EPA
originally
considered
proposing
to
amend
the
IUR
based
on
Option
4,
which
raises
the
threshold
for
reporting
facility
and
manufacturing
information
from
10,000
to
25,000
pounds;
adds
a
requirement
to
provide
processing
and
use
data;
creates
a
100,000
pound
threshold
for
reporting
use
and
exposure
data;
retains
the
existing
four
year
reporting
cycle;
and
provides
a
partial
reporting
exemption
for
certain
petroleum
stream
chemicals.
However,
during
the
interagency
review
process,

the
proposed
option
was
revised
to
include
a
full
exemption
for
natural
gas,
a
partial
exemption
for
inorganic
chemicals,
and
a
300,000
pound
threshold
for
reporting
use
and
exposure
data.
In
particular,

the
revised
proposed
amendments
would:

!
Increase
reporting
threshold:
The
reporting
threshold
would
be
increased
from
10,000
to
25,000
pounds.
2
"
natural
gas"
includes
the
following
CAS
Registry
Numbers:
64741­
48­
6,
68919­
39­
1,
8006­
61­
9,
68425­
31­
0,
8006­
14­
2,
68410­
63­
9.

S­
5
!
Remove
inorganic
exemption:
Inorganic
chemicals
would
no
longer
be
exempted
from
reporting
(
inorganic
chemicals
would
not
be
required
to
report
exposure
and
use
data,
see
below).

!
Add
exposure­
related
data:
Two
types
of
exposure­
related
data
would
be
added:

°
All
reportable
chemicals
would
supply
exposure­
related
manufacturing
information
on
the
number
of
workers
potentially
exposed
during
manufacturing,
the
physical
state
of
the
chemical,
the
maximum
concentration
of
the
chemical
when
manufactured,
and
whether
production
volume
is
confidential
when
reported
in
a
range.

°
Large
volume
chemicals
would
also
report
exposure­
related
use
information
on
industrial
processing
and
use
and
commercial
and
consumer
use.
Industrial
processing
and
use
information
includes
process
or
use
codes,
5­
digit
North
American
Industry
Classification
System
(
NAICS)
codes,
industrial
function
categories,
the
percent
of
production
volume
in
each
category,
site­
limited
status,
number
of
sites
(
in
ranges),
and
number
of
potentially
exposed
workers
(
in
ranges).
Consumer
and
commercial
end
use
information
includes
commercial/
consumer
end
use
categories,
percent
of
production
volume
in
each
category,
and
maximum
concentration
(
in
ranges)
of
the
chemical
in
the
commercial/
consumer
end
use.

!
Create
reporting
exemptions.
Certain
petroleum
streams,
inorganic
chemicals,
and
any
chemicals
that
the
Agency
determines
to
be
low
priorities
for
assessment
would
be
exempted
from
providing
exposure­
related
use
data
(
industrial
processing
and
use
information,
and
commercial
and
consumer
use
information).
In
addition,
natural
gas2
would
be
fully
exempted
from
reporting.

!
Create
a
second
reporting
threshold.
Chemicals
produced
or
imported
at
volumes
less
than
300,000
pounds
would
complete
a
partial
reporting
form,
requiring
only
facility
and
manufacturing
information
and
CBI
reassertion.
Chemicals
with
production
volumes
greater
than
300,000
pounds
would
complete
the
full
form,
requiring
reporting
of
facility
and
manufacturing
information
as
well
as
exposure­
related
use
data.

!
Change
the
CBI
requirements:
Companies
would
be
required
to
provide
up­
front
substantiation
before
claiming
facility
identity
as
CBI,
and
to
resubstantiate
previous
CBI
claims.
Companies
would
be
required
to
determine
if
CBI
claims
for
production
volume
are
valid
if
the
information
is
presented
in
a
specified
range.

!
Make
certain
administrative
changes:
The
reporting
cycle
would
be
changed
from
the
current
fiscal
year
to
the
calendar
year.
As
part
of
the
facility
identification,
companies
would
be
required
to
report
the
EPA
Identification
Number
and
county
name
of
the
plant
site,
as
well
as
the
Dun
&
Bradstreet
Number
and
mailing
address
of
the
parent
company.
The
records
retention
period
would
be
lengthened
from
four
to
five
years.
S­
6
Table
S­
1.
Options
Summary
Option
Thresholds
Reporting
Cycles
New
Exemptions
Number
of
Chemicals
Number
of
Sites
Numbe
r
of
Report
s
Percent
of
Reports
First
Year
Cost
($
million)

Facility
and
Manufacturing
Information
Use
Information
Partial
Full
Reporting
Threshold
Options
1
10,000
lb
10,000
lb
4
yrs.
Partial
Exemption
Chemicalsa
10,439
3,670
30,598
19%
81%
$
69.2
­
91.2
2
25,000
lb
25,000
lb
4
yrs.
Partial
Exemption
Chemicalsa
8,904
3,485
26,811
21%
79%
$
58.3
­
76.6
3
10,000
lb
100,000
lb
4
yrs.
Partial
Exemption
Chemicalsa
10,439
3,670
30,598
42%
58%
$
47.9
­
65.4
4b
25,000
lb
100,000
lb
4
yrs.
Partial
Exemption
Chemicalsa
8,904
3,485
26,811
42%
58%
$
47.9
­
65.4
4ac
25,000
lb
300,000
lb
4
yrs.
Partial
Exemption
Chemicalsa,
c
8,898
3,045
25,586
61%
39%
$
36.0
­
51.4
5
10,000
lb
500,000
lb
4
yrs.
Partial
Exemption
Chemicalsa
10,439
3,670
30,598
67%
33%
$
42.3
­
62.0
6
25,000
lb
500,000
lb
4
yrs.
Partial
Exemption
Chemicalsa
8,904
3,485
26,811
62%
38%
$
38.1
­
54.8
7
25,000
lb
1,000,000
lb
4
yrs.
Partial
Exemption
Chemicalsa
8,904
3,485
26,811
69%
31%
$
35.1
­
51.4
8
25,000
lb
10,000,000
lb
4
yrs.
Partial
Exemption
Chemicalsa
8,904
3,485
26,811
84%
16%
$
27.7
­
43.4
9
25,000
lb
500,000
lb/

100,000
lbd
4
yrs.
Partial
Exemption
Chemicalsa
8,904
3,485
26,811
62%
38%
$
38.1
­
54.8
42%
58%

Reporting
Exemption
Option
4ac
25,000
lb
300,000
lb
4
yrs.
Partial
Exemption
Chemicalsa,
c
8,898
3,045
25,586
61%
39%
$
36.0
­
51.4
10
25,000
lb
100,000
lb
4
yrs.
Site­
Limited
Petroleum
Streams
8,617
3,365
25,577
23%
77%
$
54.4
­
71.5
11
25,000
lb
100,000
lb
4
yrs.
Partial
Exemption
Chemicalsa
7,796
2,945
22,309
46%
54%
$
36.8
­
50.4
Reporting
Cycle
Options
4ac
25,000
lb
300,000
lb
4
yrs.
Partial
Exemption
Chemicalsa,
c
8,898
3,045
25,586
61%
39%
$
36.0
­
51.4
12
25,000
lb
100,000
lb
2
yrs./
4yrs.
e
Partial
Exemption
Chemicalsa
8,904
3,485
26,811
42%
58%
$
47.9
­
65.4
13
25,000
lb
100,000
lb
2
yrs.
Partial
Exemption
Chemicalsa
8,904
3,485
26,811
42%
58%
$
47.9
­
65.4
14
25,000
lb
100,000
lb
one­
time
Partial
Exemption
Chemicalsa
8,904
3,485
26,811
42%
58%
$
47.9
­
65.4
a
Partial
exemption
chemicals
currently
include
only
petroleum
stream
chemicals.
These
chemicals
are
exempted
from
providing
processing
and
use
information.

b
Option
4
was
the
proposed
option.

c
Option
4a
was
added
during
Interagency
review
and
is
discussed
in
the
addendum
to
this
report.

d
Option
9
has
a
reporting
threshold
of
500,000
pounds
for
the
full
report
in
the
first
reporting
cycle
and
100,000
pounds
for
the
full
report
in
future
reporting
cycles.
S­
7
e
Option
12
has
a
2
year
reporting
cycle
for
facility
and
manufacturing
information
and
a
4
year
reporting
cycle
for
processing
and
use
information.
S­
8
Analysis
of
Options
Table
S­
1
also
summarizes
the
results
of
the
analysis
for
each
of
the
fourteen
different
options,

including
the
number
of
sites
that
would
report,
the
number
of
reports
that
would
be
submitted,
the
distribution
of
partial
and
full
reports,
and
the
cost
of
reporting.
Under
the
proposed
rule
(
not
shown
in
the
table),
the
amended
IUR
would
collect
basic
information
on
about
8,900
chemicals
out
of
the
more
than
75,000
chemicals
on
the
TSCA
Inventory.
Approximately
1,000
chemical
manufacturers
or
importers
would
be
required
to
report.
These
companies
would
submit
about
25,500
reports
covering
approximately
3,300
sites.
Approximately
40
percent
of
the
reports
(
covering
forty­
five
percent
of
the
chemicals)
would
be
full
reports
(
i.
e.,
containing
processing
and
use
information),
while
the
remainder
would
be
partial
reports.
Most
of
these
reports
must
already
be
submitted
under
the
existing
IUR
requirements
and
companies
would
simply
be
providing
additional
information.
There
are
more
than
1,200
inorganic
chemicals
that
would
be
reportable
to
the
IUR
for
the
first
time,
and
about
1,500
originally
reportable
chemicals
that
would
no
longer
be
reported
as
a
result
of
raising
the
reporting
threshold.

Costs
of
the
IUR
amendments
would
be
borne
by
the
chemical
industry
and
EPA.
Industry
costs
are
associated
with
complying
with
the
regulation,
while
EPA
costs
are
associated
with
administering
the
regulation
and
maintaining
the
collected
data.
EPA
estimated
industry
costs
based
on
the
time
required
for
companies
to
determine
if
they
must
comply
with
the
amended
IUR,
become
familiar
with
the
rule,
prepare
and
submit
reports,
and
maintain
records
of
the
submitted
data.
EPA
has
assumed
that
the
burden
associated
with
reporting
under
the
IUR
amendments
would
decrease
over
time
as
companies
become
more
familiar
with
the
new
requirements.
Burden
would
also
decrease
over
time
to
the
extent
that
the
information
being
reported
remains
somewhat
constant
from
one
reporting
period
to
the
next.
EPA
assumed
that
no
capital
costs
would
be
associated
with
this
rule.
EPA
estimated
the
total
cost
of
the
IUR
amendments
by
multiplying
these
estimated
costs
by
the
estimated
number
of
sites
and
submissions
that
would
be
affected
by
the
IUR
amendments.

The
estimated
cost
to
submit
a
report
depends
on
the
type
of
chemical
being
reported
(
e.
g.,

organic
chemical,
petroleum
stream
chemical,
or
inorganic
chemical)
and
the
production
volume
of
the
chemical
being
reported
(
e.
g.,
between
25,000
and
300,000
pounds,
or
greater
than
or
equal
to
300,000
pounds).
The
estimated
incremental
cost
or
savings
per
report
are
as
follows:
S­
9

Chemicals
produced
at
a
volume
between
10,000
pounds
and
25,000
pounds
are
exempt
from
reporting.
This
results
in
avoided
reporting
costs
(
i.
e.,
savings)
of
approximately
$
565
to
$
892
per
report
for
these
chemicals.


Chemicals
with
a
production
volume
between
25,000
and
300,000
pounds,
or
those
qualifying
for
one
of
the
partial
exemptions,
can
submit
a
partial
report
that
does
not
contain
use
information.
The
incremental
cost
for
a
partial
report
is
estimated
to
range
from
$
688
to
$
1,883
in
the
first
year
and
$
459
to
$
1,813
in
subsequent
reporting
cycles.


Chemicals
produced
at
over
300,000
pounds
that
do
not
qualify
for
one
of
the
partial
exemptions
must
file
a
full
report.
The
incremental
cost
for
a
full
report
is
estimated
at
$
2,520
to
$
3,872
in
the
first
year
and
$
2,036
to
$
3,267
in
subsequent
reporting
cycles.

In
all
of
these
cases
the
high
end
of
the
range
represents
inorganic
chemicals,
which
have
a
higher
incremental
cost
because
they
have
heretofore
been
exempt
from
reporting.
Companies
are
expected
to
file
an
average
of
8.4
reports
per
site.
An
estimate
of
the
average
cost
per
site
can
be
derived
by
multiplying
the
cost
per
report
by
the
estimated
8.4
reports
per
site.

EPA
estimates
the
incremental
cost
of
the
amendments
to
be
between
$
36
million
and
$
51
million
for
the
first
reporting
cycle.
Costs
for
subsequent
reporting
cycles
(
every
4
years)
are
estimated
at
$
27
million
to
$
41
million.
The
startup
and
quadrennial
costs
are
equivalent
to
an
annual
cost
of
$
10
million
to
$
14
million
per
year.
Projected
incremental
costs
to
EPA
are
relatively
small
and
are
estimated
at
$
524,879
in
the
first
year
of
reporting,
and
$
275,364
annually.

EPA
used
exemptions
or
partial
exemptions
to
reduce
the
number
of
reports
(
and
thus
costs),

where
this
did
not
conflict
with
the
utility
of
the
data
collection.
Specifically,
EPA
reduced
the
number
of
reports
by:


raising
the
reporting
threshold
from
10,000
pounds
to
25,000
pounds,
and
adding
a
full
exemption
for
natural
gas
(
reducing
the
number
of
reports
by
about
3,800
and
1,200,
repectively);


introducing
a
second
threshold
of
300,000
pounds
for
reporting
use
data
(
reducing
the
number
of
reports
for
which
full
information
must
be
provided
by
about
7,700);
and

establishing
a
partial
exemption
for
petroleum
streams,
and
inorganic
chemicals
(
reducing
the
number
of
full
reports
by
over
5,600
for
petroleum
streams
(
some
of
these
reports
would
have
been
for
chemicals
produced
in
volumes
above
100,000
pounds),
and
by
about
3,300
for
inorganic
chemicals).

The
result
is
that
full
reports
are
expected
on
only
about
4,000
chemicals
and
partial
reports
on
about
5,000
chemicals
(
out
of
the
more
than
75,000
chemicals
on
the
TSCA
Inventory).
EPA
also
reduced
the
specificity
of
the
information
required
by:
S­
10

requiring
the
reporting
of
only
known
or
reasonably
ascertainable
facility
and
manufacturing
information
and
readily
obtainable
processing
and
use
information;


requiring
that
submitters
report
much
of
the
information
in
ranges,
reducing
the
need
to
generate
precise
estimates;
and

requiring
processing
and
use
information
only
on
the
bulk
of
the
chemical's
volume,
not
necessarily
on
100
percent
of
the
volume
(
for
instance,
only
on
the
top
ten
NAICS
codes).

These
steps
limit
the
amount
of
information
required,
reducing
the
time
and
effort
spent
by
the
chemical
industry
on
complying
with
the
amendments.

Benefits
The
data
collected
through
this
rule
would
assist
EPA
in
evaluating
potential
exposures
and
risks
resulting
from
industrial
chemical
operations
and
commercial
and
consumer
uses
of
chemical
substances.
EPA
would
use
the
information
collected
under
this
proposed
rule
to
set
risk
assessment
priorities
among
chemical
substances
of
potential
concern
and
to
support
EPA's
pollution
prevention
and
environmental
protection
activities.
The
information
would
also
be
valuable
to
other
public
and
private
sector
organizations
for
similar
purposes.

Because
the
current
state
of
knowledge
about
the
economics
of
information
is
not
highly
developed,
this
analysis
does
not
attempt
to
assign
monetary
value
to
the
direct
benefits
of
the
information
collected
by
this
rule.
The
direct
benefits
are
the
improved
quality
and
timeliness
of
decision­
making
in
EPA's
risk
screening
process
and
EPA's
improved
ability
to
focus
its
programs
and
use
resources
more
efficiently.
Because
the
outcome
of
EPA's
screening
and
risk
management
programs
for
these
chemicals
cannot
be
predicted,
it
is
also
not
possible
to
quantitatively
estimate
the
indirect
benefits
of
the
rule
in
terms
of
lives
saved,
illness
averted,
or
ecosystem
damages
avoided.

While
the
benefits
cannot
be
monetized
or
quantified,
the
analysis
does
qualitatively
describe
the
types
of
benefits
that
are
expected.
The
benefits
of
some
of
the
major
changes
are
described
below
and
summarized
in
Table
S­
2.

The
proposed
amendments
are
directed
at
improving
the
data
available
for
risk
screening
of
existing
chemicals.
Improving
the
data
available
for
the
chemical
screening
process
provides
EPA
with
the
means
to
more
effectively
protect
human
health
and
the
environment.
At
present,
EPA
uses
hazard
information
in
conjunction
with
production
volume
(
as
a
proxy
for
exposure)
as
the
primary
tools
to
S­
11
focus
existing
chemical
resources.
The
addition
of
use
and
exposure­
related
information
would
provide
a
better
risk
characterization
and
allow
EPA
to
develop
priorities
based
on
that
risk.
Identifying
and
focusing
on
those
chemicals
with
greater
risks
earlier
in
the
process
reduces
the
health
care
and
environmental
costs
borne
by
society.
The
amendments
will
also
require
reporting
on
inorganic
chemicals,
which
will
enable
the
Agency
to
identify
and
target
risks
from
this
class
of
chemicals.

The
amendments
make
a
number
of
administrative
changes
that
would
increase
the
effectiveness
of
the
data
that
is
collected.
One
example
is
the
proposed
change
to
the
reporting
period.

Under
the
original
IUR,
companies
report
on
the
basis
of
their
fiscal
year,
which
varies
from
company
to
company.
Changing
the
reporting
period
to
coincide
with
the
calendar
year
as
opposed
to
a
company's
fiscal
year
would
make
the
data
set
internally
consistent.
It
would
also
make
the
reporting
period
for
the
IUR
data
consistent
with
other
EPA
databases,
most
of
which
are
on
a
calendar
year
basis.
Another
example
of
an
administrative
change
is
the
proposed
requirement
for
companies
to
provide
EPA
identification
numbers
on
the
IUR
report.
This
would
enable
the
Agency
to
more
readily
and
accurately
combine
site­
specific
information
from
various
databases.
As
one
benefit,
this
would
allow
EPA
to
check
the
validity
of
its
models,
and
improve
its
ability
to
predict
exposures
for
all
chemicals.

Much
of
the
information
reported
through
the
original
IUR
is
claimed
CBI,
which
reduces
the
usability
of
the
data.
Information
that
is
claimed
to
be
CBI
can
only
be
used
by
staff
with
a
security
clearance,
and
the
data
cannot
be
included
in
any
report
or
other
document
that
will
be
made
available
to
the
public.
As
a
result,
if
EPA
uses
this
information
(
for
instance
to
set
risk
management
priorities),

the
basis
for
the
decision
cannot
be
completely
shared
with
the
public.
If
EPA
only
uses
data
that
has
not
been
claimed
as
confidential,
the
results
will
be
incomplete
and
of
limited
usefulness.
Several
of
the
proposed
amendments
are
intended
to
limit
CBI
claims
to
only
those
that
are
necessary
to
protect
legitimate
business
interests.
For
instance,
since
companies
are
less
likely
to
claim
production
volume
as
CBI
if
the
data
is
presented
as
a
range
rather
than
a
point
estimate,
the
IUR
amendments
add
a
range
reporting
element.
Data
that
has
been
appropriately
claimed
as
CBI
would
continue
to
be
treated
as
confidential.
These
changes
would
allow
EPA
to
provide
answers
the
public
needs
without
breaching
the
confidentiality
of
legitimate
CBI
data.

Finally,
collecting
the
proposed
IUR
information
would
help
further
develop
and
measure
the
results
of
private­
sector
stewardship
programs.
The
data
would
help
to
identify
potential
risks
and
S­
12
opportunities
for
safer
substitutes,
target
specific
population
groups,
and
evaluate
the
need
for
risk
management.

In
general,
the
additional
information
collected
through
the
IUR
amendments
would
be
used
to
identify
and
manage
human
health
and
environmental
risks.
The
data
would
aid
in
identifying
chemicals
to
which
consumers,
children,
and
workers
are
exposed,
establishing
priority
chemicals
for
testing,
and
finding
areas
where
voluntary
programs
are
more
likely
to
provide
real
gains
in
environmental
protection.
Currently,
the
lack
of
nationwide
information
related
to
chemical
production
and
use
prevents
the
Agency
from
screening
large
numbers
of
chemicals
in
a
timely
manner.
These
amendments
are
critical
if
EPA
is
to
meet
its
GPRA
goal
to
screen
all
chemicals
in
commerce
by
2005.

As
presented
in
Table
S­
1,
EPA
considered
a
variety
of
options.
These
options
can
be
separated
into
three
categories
­
reporting
threshold,
reporting
exemption,
and
reporting
cycle
options.

In
determining
which
reporting
threshold
to
propose,
EPA
considered
the
number
of
chemicals
on
which
information
would
be
collected,
the
burden
associated
with
reporting
the
information,
comments
received
from
a
variety
of
sources,
and
the
future
direction
of
EPA's
program.
For
the
reporting
exemption
options,
EPA
considered
its
ability
to
use
the
information
and
the
information
otherwise
available
to
the
Agency.
For
the
reporting
cycle
options,
EPA
considered
the
dynamic
nature
of
the
chemical
industry
and
the
burden
associated
with
reporting
the
information.
Options
based
upon
the
information
collected
were
not
analyzed
in
this
economic
analysis.
Decisions
as
to
the
specific
information
collected
were
based
upon
EPA's
experience
and
information
needs
and
are
described
in
the
technical
support
documents.

Small
Entity
Analysis
Small
businesses
are
the
only
small
entities
expected
to
be
affected
by
the
IUR
amendments.

In
addition
to
the
reporting
thresholds
(
that
help
screen
out
small
businesses),
the
existing
regulation
contains
two
small
business
exemptions
(
40
CFR
704.3).
First,
companies
with
annual
sales
of
less
than
$
4
million
are
exempt
from
reporting
regardless
of
their
production
volume.
Second,
companies
with
annual
sales
less
than
$
40
million
are
exempt
from
reporting
if
they
produce
less
than
100,000
pounds
of
a
regulated
substance
at
a
single
site.
These
exemptions
are
not
being
changed
by
the
proposed
IUR
amendments.
For
the
purpose
of
the
small
entity
analysis,
firms
with
$
40
million
or
less
in
annual
sales
but
over
100,000
pounds
of
production
were
designated
as
small
businesses.
S­
13
The
rule
is
estimated
to
affect
between
202
and
336
small
businesses.
EPA
compared
the
first
year
cost
of
reporting
due
to
the
IUR
amendments
to
sales
at
these
small
businesses.
Even
using
conservative
assumptions,
the
average
cost
to
sales
ratio
in
the
first
year
of
reporting
is
estimated
to
be
0.20
percent
or
less.
Costs
will
be
an
even
smaller
percentage
of
sales
in
subsequent
reporting
cycles.

Because
regulatory
costs
represent
a
small
fraction
of
a
typical
firm's
sales,
the
financial
impacts
of
the
regulation
are
likely
to
be
minimal.

Environmental
Justice
Because
the
proposed
IUR
amendments
are
an
information
collection
exercise,
there
are
no
negative
environmental
equity
issues
associated
with
them.
Instead,
the
information
that
would
become
available
through
the
proposed
rule
would
enable
the
Agency
to
target
educational,
regulatory,
or
enforcement
activities
towards
industries
or
chemicals
that
pose
the
greatest
risks,
and
to
target
programs
to
geographic
areas
that
are
at
the
highest
risk.
Thus,
the
information
proposed
to
be
gathered
under
the
IUR
amendments
would
help
EPA
to
make
decisions
that
would
benefit
potentiallyat
risk
communities,
some
of
which
may
be
disadvantaged.
Of
the
121
million
people
who
live
within
10
miles
of
an
IUR
site,
almost
38
million
(
30
percent)
are
minorities.
This
number
is
greater
than
the
nationwide
rate
of
approximately
20
percent
minority
individuals.
Roughly
24
million
(
20
percent)
of
the
people
living
within
12
miles
of
an
IUR
site
are
at
or
below
150
percent
of
the
poverty
level,
which
is
consistent
with
the
nationwide
rate
of
21
percent.
S­
14
Table
S­
2.
Summary
of
Proposed
IUR
Amendments
ACTION
RESULT
BENEFIT
OR
RATIONALE
Raise
threshold
Raises
the
production
volume­
reporting
threshold
from
10,000
pounds
a
year
to
25,000
pounds
a
year.
Exempts
roughly
3,800
reports
for
1,535
chemicals,
at
a
savings
of
$
21.3
to
$
25.8
million
in
the
first
year
of
reporting.
Lowers
companies'
reporting
burden.

Remove
Inorganic
Exemption
Removes
the
exemption
for
inorganic
chemicals
in
the
original
IUR.
Adds
approximately
4,500
reports
for
over
1,200
chemicals,
at
a
cost
of
$
5.1­$
8.5
million
in
the
first
year
of
reporting,
and
an
annualized
cost
of
$
1.5­$
2.4
million.
Allows
EPA
to
make
informed
risk­
screening
decisions
about
inorganic
chemicals.

Production
Volume
Partial
Exemption
Adds
a
300,000
pound
production
volumereporting
threshold
on
processing
and
use
information.
This
eliminates
the
requirement
to
report
processing
and
use
information
for
chemicals
produced
between
25,000
and
300,000
pounds
each
year.
Eliminates
roughly
7,700
reports
for
3,200
chemicals
from
requirement
to
report
processing
and
use
information.
Reduces
the
reporting
burden
on
companies
that
manufacture
these
eliminated
chemicals.

Petroleum
Stream
Partial
Exemption
Eliminates
the
requirement
to
report
processing
and
use
information
for
petroleum
stream
chemicals
with
multiple
Chemical
Abstracts
Service
(
CAS)
numbers.
Exempts
roughly
5,600
reports
from
requirement
to
provide
processing
and
use
information,

saving
$
10.3
to
$
11.1
million
in
the
first
year
of
reporting.
EPA
does
not
feel
that
full
reporting
on
petroleum
streams
is
necessary
at
this
time.

The
exemption
reduces
the
reporting
burden
on
companies
that
manufacture
chemicals
whose
risks
are
difficult
to
quantify.

Inorganic
Partial
Exemption
Eliminates
the
requirement
to
report
processing
and
use
information
for
inorganic
chemicals,
at
least
in
the
first
reporting
cycle.
Exempts
roughly
3,300
reports
from
requirement
to
provide
processing
and
use
information,

saving
$
6.3­
6.
9
million
in
the
first
year
of
reporting.
EPA
lacks
even
basic
production
information
on
inorganic
chemicals,
and
will
need
to
assess
data
on
these
chemicals
before
requiring
processing
and
use
data.

Natural
Gas
Exemption
Eliminates
all
reporting
for
natural
gas
with
six
specific
Chemical
Abstracts
Service
(
CAS)

numbers.
Exempts
roughly
1,225
reports
from
all
reporting,

saving
$
1.6
to
$
2.8
million
in
the
first
year
of
reporting.
Reduces
burden
by
eliminating
a
large
number
of
reports
on
these
specific
chemicals
for
which
EPA
feels
current
IUR
data
is
adequate.
ACTION
RESULT
BENEFIT
OR
RATIONALE
S­
15
Low
Priority
Chemicals
Partial
Exemption
EPA
is
considering
eliminating
the
requirement
to
report
processing
and
use
information
on
those
chemicals
identified
by
EPA
as
low
priorities
for
assessment
(
See
discussion
in
Preamble,

Section
IV.
C).
Not
estimated,
because
the
number
of
chemicals
of
low
priority
has
not
yet
been
determined.
Reduces
the
reporting
burden
on
companies
that
manufacture
chemicals
that
are
currently
low
priorities
for
risk
assessment
as
determined
by
EPA.

Facility
&
Manufacturing
Information
Requires
additional
facility
and
manufacturing
information:


the
company's
Dun
&
Bradstreet
number
and
mailing
address;


the
location
of
the
plant
site
and
mailing
address;


the
number
of
exposed
workers;


the
physical
state
of
the
chemical;
and

the
maximum
concentration
of
the
chemical.
Does
not
change
the
number
of
reports
required.

Increases
costs
by
approximately
$
4.9
S$
9.6
million
in
the
first
year
of
reporting.
Increases
the
usefulness
of
information
and
improves
EPA's
ability
to
make
more
informed
risk­
screening
decisions.

Better
facility
and
company
identification
improves
EPA's
ability
to
link
information
with
other
databases.

Worker
exposure
and
chemical
concentration
information
gives
EPA
the
ability
to
complete
a
screening­
level
assessment
of
risks
during
the
manufacture
of
chemicals.

Processing
&
Use
Information
Requires
additional
processing
and
use
information:


process
or
use
code;


5­
digit
North
American
Industry
Classification
System
(
NAICS)
code
for
processing;


industrial
function
category;


percent
of
production
volume
in
function
category;


number
of
processing
sites
(
in
ranges);


number
of
potentially
exposed
workers
(
in
ranges);


end­
use
category;


percent
production
volume
in
end­
use
category;


maximum
concentration
(
in
ranges)
of
the
chemical
in
the
end­
use.
Results
in
an
increase
in
unit
costs;
does
not
change
the
number
of
reports
required.

Processing
and
use
exposure
information
is
collected
from
approximately
15,431
reports
on
roughly
6,046
chemicals,
at
an
estimated
cost
of
approximately
$
35.4­$
44.3
million
in
the
first
year
of
reporting.
Increases
EPA's
ability
to
make
informed
riskscreening
decisions.

The
earlier
identification
of
problems
and
fewer
misidentifications
improves
the
targeting
of
resources
by
EPA
and
industry.
ACTION
RESULT
BENEFIT
OR
RATIONALE
S­
16
Reporting
period
Changes
the
reporting
period
from
the
company's
fiscal
year
to
the
calendar
year.
Does
not
change
unit
costs
or
the
number
of
reports
required.
Reporting
is
easier
for
industry
because
the
time
frame
would
be
the
same
as
for
other
reporting
requirements.

All
data
within
the
IUR
database
would
reflect
a
consistent
time
frame,
which
would
make
data
inferences
more
reliable.

Reporting
period
consistent
with
other
EPA
data
collections.

Extend
record
retention
period
Extends
record
retention
period
from
4
to
5
years.
Does
not
change
the
number
of
reports
required.
Since
the
reporting
cycle
is
4
years,
this
will
make
records
from
prior
reporting
period
available
for
EPA
enforcement
activities.

Confidential
Business
Information
Requires
separate
confidentiality
claims
for
production
volume
(
PV)
ranges,
in
addition
to
exact
PV.

Requires
up­
front
substantiation
of
confidentiality
claims
for
plant
site
information.

Requires
the
reassertion
of
CBI
claims
for
each
reporting
period.
Results
in
an
increase
in
unit
costs;
does
not
change
the
number
of
reports
required.

Increases
first­
year
industry
costs
by
$
6.4­$
14.3
million
over
the
baseline.
Annualized
costs
increase
by
$
2.3
­
$
5.1
million.

Approximately
20
percent
of
submissions
received
during
the
1994
reporting
period
claimed
plant
site
information
as
CBI,
suggesting
that
a
comparable
percentage
would
provide
upfront
substantiation
under
the
amendments.

Approximately
64
percent
of
submissions
received
during
the
1994
reporting
period
claimed
some
data
element
as
CBI,
indicating
that
up
to
this
percent
may
have
to
reassert
claims
under
the
IUR
amendments.
Produces
greater
flexibility
in
the
use
of
the
data.

PV
ranges
are
less
likely
to
be
claimed
to
be
confidential
than
point
estimates.
PV
ranges
maintain
confidentiality
for
point
estimates,
while
allowing
greater
flexibility
in
the
use
of
the
information.

Up­
front
substantiation
of
plant
site
claims
reduces
the
frequency
of
inappropriate
CBI
claims
being
filed,
while
protecting
data
that
can
legitimately
be
claimed
as
CBI.
I­
1
CHAPTER
I.
INTRODUCTION
This
economic
analysis
provides
estimates
of
the
costs
and
benefits
expected
to
result
from
implementation
of
the
Inventory
Update
Rule
(
IUR)
amendments.
The
original
IUR
requires
chemical
manufacturers
and
importers
to
collect,
maintain,
and
submit
location
and
production
volume
information
for
chemicals
with
production
volumes
of
10,000
pounds
or
higher.
The
proposed
IUR
amendments
will
change
this
reporting
threshold
to
25,000
pounds
and
will
augment
the
required
facility
and
production
information.
In
addition,
the
amendments
will
require
sites
with
production
volumes
of
100,000
pounds
or
higher
to
collect,
maintain,
and
submit
additional
information
to
the
Agency
regarding
chemical
use
and
exposure.
Furthermore,
changes
in
administrative
requirements
and
exemption
status
for
various
chemical
groups
are
proposed.

The
costs
associated
with
these
amendments
include
industry
costs
due
to
collecting,

maintaining,
and
submitting
the
required
information
and
government
costs
attributable
to
data
management.
Benefits
of
the
amendments
include
providing
information
necessary
for
the
Agency
to
develop
chemical
screening
priorities,
streamline
regulatory
efforts,
and
make
informed
risk
assessment
and
management
decisions.
The
collected
information
will
improve
EPA's
understanding
of
potential
exposures
resulting
from
industrial
chemical
use,
allow
EPA
to
more
accurately
track
chemical
exposure
and
use,
and
permit
EPA
to
more
effectively
target
chemicals
that
pose
the
greatest
hazard
or
risk.

Ultimately,
society
will
benefit
from
EPA's
improved
programs.

The
remainder
of
this
chapter
provides
information
on
EPA's
statutory
authority
for
implementing
the
proposed
IUR
amendments,
a
discussion
of
the
regulatory
history,
a
description
of
the
original
rule
requirements
and
the
proposed
changes,
an
overview
of
the
regulated
community,
and
a
detailed
description
of
the
contents
of
this
report.

A.
Statutory
Authority
Congress
has
granted
EPA
broad
authority
to
collect
information
on
chemical
substances,

including
information
that
will
help
EPA
in
assessing
the
magnitude
and
extent
of
human
and
environmental
exposure
to
chemicals
used
in
commerce.
Specifically,
under
Section
8(
a)
of
the
Toxic
Substances
Control
Act
(
TSCA)
(
15
U.
S.
C.
2607(
a)),
EPA
is
authorized
to
promulgate
regulations
I­
2
Box
I­
1.
Chemical­
specific
Information
EPA
Is
Authorized
To
Collect
Under
Section
8(
a)
of
the
Toxic
Substances
Control
Act
1.
Common
or
trade
name,
chemical
identity,
and
molecular
structure
of
each
chemical
substance
or
mixture
for
which
reports
are
required.

2.
Categories
or
proposed
categories
of
use
for
each
substance
or
mixture
reported.

3.
The
total
amount
of
each
substance
and
mixture
manufactured
or
processed
and
each
of
its
categories
of
use;
reasonable
estimates
of
the
total
amount
to
be
manufactured
or
processed
and
each
of
its
categories
of
use.

4.
A
description
of
the
byproducts
resulting
from
the
manufacture,
processing,
use,
or
disposal
of
each
such
substance
or
mixture.

5.
All
existing
data
concerning
the
environmental
and
health
effects
of
such
substances
or
mixtures.

6.
The
number
of
individuals
exposed,
and
reasonable
estimates
of
the
number
who
will
be
exposed,
to
such
substances
or
mixtures
in
their
places
of
employment
and
the
duration
of
such
exposure.
requiring
chemical
industry
entities
to
report
production
and
use
information
on
various
types
and
classes
of
chemicals.
A
detailed
description
of
the
types
of
chemicalspecific
information
that
the
Agency
is
authorized
to
collect
is
provided
under
TSCA
§
8(
a)(
2);
a
summary
is
presented
in
Box
I­
1.

B.
Description
of
Rule
This
section
describes
the
regulatory
history
leading
to
the
TSCA
Inventory
Update
Rule,
the
original
requirements
of
the
rule,

and
the
proposed
changes
to
the
rule.

1.
Regulatory
History
The
TSCA
Chemical
Substances
Inventory
(
42
FR
64572,
December
23,
1977)
was
created
just
after
TSCA's
passage
into
law.
The
Inventory
lists
all
TSCA
chemicals
in
commerce
in
1977,
thereby
providing
a
snapshot
of
the
chemicals
manufactured
or
processed
in
the
United
States.

All
chemicals
are
included,
with
the
exception
of
pesticides,
tobacco,
nuclear
material,
firearms
and
ammunition,
food
and
food
additives,
drugs,
and
cosmetics.
Chemicals
completing
the
EPA's
New
3
Chemicals
listed
on
the
TSCA
Inventory
are
referred
to
as
Existing
Chemicals.
Chemicals
not
currently
listed
are
referred
to
as
New
Chemicals,
and
all
producers
intending
to
manufacture
or
import
a
new
chemical
must
comply
with
the
Agency's
New
Chemical
program.
The
New
Chemicals
Program
(
NCP)
screens
new
chemicals
to
determine
if
and
under
what
conditions
they
can
be
brought
into
the
United
States.
Once
a
chemical
passes
through
the
program,
the
manufacturer
or
importer
files
a
Notice
of
Commencement
indicating
that
the
chemical
will
now
be
in
commerce.

I­
3
Chemicals3
process
and
filing
a
Notice
of
Commencement
have
been
added
to
the
Inventory;
no
chemicals
have
been
removed.
There
are
currently
about
75,000
chemicals
listed.

Under
the
authority
of
TSCA
Section
8(
a),
EPA
promulgated
regulations
requiring
chemical
manufacturers
and
importers
to
submit
data
on
a
subset
of
the
chemical
substances
listed
in
the
TSCA
Inventory
(
51
FR
21447,
June
12,
1986).
These
regulations
are
commonly
called
the
TSCA
Inventory
Update
Rule
(
IUR).
Data
are
collected
every
four
years
on
an
average
of
9,200
discrete
chemicals.
This
collection
provides
a
more
up­
to­
date
picture
of
the
TSCA
chemicals
in
commerce,
generating
data
that
are
used,
with
the
TSCA
Inventory
data,
to
support
many
EPA
risk
management
activities.
The
data
also
provide
general
support
to
many
other
EPA
and
non­
EPA
program
activities.

After
analyzing
the
data
submitted
under
the
IUR
during
the
1986,
1990,
and
1994
reporting
periods,
EPA
identified
the
need
to
amend
the
IUR
to
provide
basic
information
related
to
potential
chemical
exposures.
EPA
plans
to
use
this
new
information
to
improve
its
chemical
screening,
risk
assessment,
and
risk
management
capabilities.
EPA
also
identified
the
need
to
amend
some
administrative
provisions
in
the
IUR
to
enhance
the
data's
usefulness.

2.
Original
IUR
Requirements
The
original
IUR
requires
that
members
of
the
regulated
community
submit
information
on
certain
TSCA
chemicals
once
every
four
years.
Reporting
is
mandatory
for
each
regulated
chemical
produced
or
imported
in
annual
quantities
of
10,000
pounds
or
greater,
although
inorganic
substances,

polymers,
microorganisms,
and
naturally
occurring
chemical
substances
are
exempt
from
reporting.

Reporters
are
required
to
provide
the
following
information:


Company
Information
requires
information
for
a
technical
contact
including
company
name,
contact
name,
company
street
address,
and
telephone
number;


Plant
Site
Identification
includes
reporting
the
identification
and
address
information
for
a
manufacturing
plant
site,
including
plant
site
name,
EPA
Identification
Number,
Dun
&
Bradstreet
number,
and
plant
site
street
address;
4
Site­
limited
chemicals
are
those
chemicals
that
are
produced
and
used
at
the
same
site.
These
chemicals
do
not
undergo
packaging
and
shipping.

I­
4

Chemical
Identifying
Number
involves
reporting
both
the
specific
chemical
name
and
the
Chemical
Abstracts
Service
(
CAS)
Registry
Number,
or
other
identifying
number,
of
the
chemical
substance;


Manufacturer/
Importer
Activity
requires
identifying
whether
the
chemical
is
produced
or
imported;


Site­
Limited
Activity
entails
indicating
whether
the
chemical
substance
reported
is
sitelimited
4

Production
Volume
must
be
reported
for
the
relevant
chemical
manufactured
at
the
plant
site;


Confidential
Business
Information
(
CBI)
status
(
claimed/
not
claimed)
must
be
indicated
for
plant
site
identification,
company
name,
chemical
identification,
manufacturer/
importer
activity,
sitelimited
activity,
and
production
volume.
For
chemical
identification,
up­
front
substantiation
of
CBI
claims
is
required;
and

Certification
Statement
requires
a
signature
certifying
that
complete
and
accurate
information
is
provided.

3.
Proposed
Reporting
Requirements
The
proposed
reporting
requirements
under
the
IUR
amendments
encompass
changes
in
the
reporting
thresholds,
timing
of
reports,
exemptions,
and
the
amount
and
type
of
information
that
must
be
collected
and
submitted
to
the
EPA.

a.
Reporting
Thresholds,
Reporting
Cycles,
and
Exemptions
The
amendments
propose
raising
the
reporting
threshold
from
10,000
to
25,000
pounds
and
adding
a
second
reporting
threshold
of
100,000
pounds
for
processing
and
use
information.

This
means
that
sites
producing
or
importing
TSCA
chemicals
at
annual
volumes
of
25,000
pounds
to
100,000
pounds
are
required
to
report
only
facility
and
manufacturing
information.
Sites
producing
or
importing
TSCA
chemicals
at
annual
volumes
of
100,000
pounds
or
greater
are
required
to
report
facility
and
manufacturing
as
well
as
processing
and
use
information.

The
amendments
retain
the
original
reporting
cycle
of
every
four
years.
The
amendments
propose
to
change
the
period
of
coverage
for
production
from
corporate
fiscal
year
to
calendar
year.

The
amendments
propose
certain
changes
to
the
original
reporting
exemptions.
Under
the
amendments
the
inorganic
chemical
exemption
is
deleted
and
a
partial
exemption
for
petroleum
stream
chemicals
is
added.
Inorganic
chemical
producers/
importers
will
follow
the
same
requirements
as
those
5
Low
priority
chemicals
would
be
defined
as
chemicals
for
which
EPA
has
reduced
concerns.
These
chemicals
would
be
partially
exempt
under
the
amended
IUR
and
would
be
considered
low
priority
under
this
rulemaking
only.
Low
priority
chemicals
for
this
purpose
would
be
those
chemicals:
(
1)
that
have
undergone
Agency
review
under
TSCA
and
are
believed
to
be
of
low
priority
for
further
risk
assessment
and
risk
management
and
(
2)
that
are
currently
being
assessed
by
the
Agency
and
for
which
information
is
available
and
that
is
similar
to
that
proposed
to
be
collected
under
the
amended
IUR.
The
list
of
chemical
substances
that
qualify
for
the
low
priority
chemical
substances
partial
reporting
exemption
would
be
expected
to
change
from
one
reporting
period
to
the
next.

I­
5
followed
by
organic
chemical
producers/
importers.
Manufacturers
of
most
petroleum
streams
will
be
exempt
from
reporting
processing
and
use
information,
but
will
still
need
to
report
facility
and
manufacturing
information.
EPA
is
considering
a
partial
reporting
exemption
for
low
priority
chemicals
and
plans
to
publish
a
list
of
all
the
chemicals
that
would
qualify
for
this
exemption
before
each
inventory
collection
period.
5
These
listed
chemicals
may
also
be
exempt
from
reporting
processing
and
use
information.

b.
Information
Collected
The
IUR
amendments
propose
to
add
additional
data
elements
to
the
information
collected.
Information
already
required
under
the
original
IUR
will
continue
to
be
collected.

Form
U,
the
instrument
used
to
collect
the
IUR
information,
has
been
revised;
a
copy
of
the
revised
form
is
provided
in
Appendix
A.
The
revised
Form
U
is
divided
into
four
parts:
Facility
Identification
Information,
Manufacturing
Information,
Processing
and
Use
Information,
and
Reassertion
of
Past
CBI
Claims.
An
overview
of
the
proposed
changes
in
the
types
of
information
to
be
reported
follows:

Facility
Identification
Information

Company
and
Plant
Site
Identification
would
include
more
detailed
information
to
determine
the
company
and
plant
site
identities.
The
most
notable
changes
include
the
addition
of
the
county
name
and
the
EPA
facility
identification
numbers
for
the
plant
site.
The
EPA
ID
is
a
12­
character
number
originally
developed
for
facilities
covered
by
hazardous
waste
regulations
under
RCRA.


Up­
front
CBI
Substantiation
for
plant
site
identification
is
also
being
added.
Under
the
original
IUR,
up­
front
substantiation
is
only
required
for
chemical
identification.

Manufacturing
Information

Exposure
Related
Data
include
the
number
of
workers
involved
in
manufacturing,
the
physical
form
as
the
chemical
leaves
the
site,
and
the
maximum
concentration
of
the
chemical
as
it
leaves
the
site.
Codes
representing
ranges
would
be
used
to
report
these
data.
I­
6

Production
Volume
Data
would
now
include
production
volume
ranges
and
a
CBI
range
check
box,
enabling
submitters
to
determine
if
the
production
volume
range
for
their
chemical
should
be
considered
confidential.
The
ranges
are
predetermined.

Processing
and
Use
Information

Industrial
Processing
and
Use
Exposure
Related
Data
would
be
reported
for
the
first
time.
These
data
include
process
or
use
codes,
NAICS
codes,
industrial
function
codes,
percent
of
production
volume,
number
of
sites,
and
number
of
workers
for
downstream
processing
and
uses
of
the
chemical.
Codes
representing
ranges
would
be
used
to
report
this
data
and
only
readily
obtainable
data
would
be
reported.
These
data
would
be
reported
for
the
top
ten
NAICS
codes.
In
addition,
a
de
minimis
reporting
exemption
for
these
data
is
being
proposed.
Processing
and
use
data
for
reportable
substances
need
not
be
reported
for
sites
where
the
concentration
of
the
substance
is
less
than
1
percent
by
weight,
unless
the
volume
not
reported
is
greater
than
100,000
pounds.


Consumer
and
Commercial
End­
use
Exposure
Related
Data
would
also
be
reported
for
the
first
time.
These
data
include
product
category
codes,
percent
of
production
volume,
and
maximum
concentration
of
the
chemical
in
each
final
product.
Codes
representing
ranges
would
be
used
to
report
these
data,
and
only
readily
obtainable
data
would
be
reported.

Reassertion
of
Past
CBI
Claims

Most
of
the
information
on
Form
U
can
be
claimed
confidential.
This
proposal
requires
the
reassertion
of
any
CBI
claims
made
in
the
previous
IUR
reporting.

c.
Definitions
of
Reporting
Terms
Definitions
of
several
terms
that
correspond
to
data
needs
for
the
proposed
regulatory
requirements
are
provided
below
to
give
a
general
background
for
the
new
requirements.


The
total
number
of
workers
reasonably
likely
to
be
exposed
to
each
reportable
chemical
substance
at
each
site
where
the
substance
is
manufactured
will
be
reported
under
the
proposed
changes.
"
Reasonably
likely
to
be
exposed"
is
defined
as
exposure
to
a
chemical
substance
under
foreseeable
conditions
of
manufacture
(
including
import),
processing,
distribution
in
commerce,
or
use
of
each
reportable
chemical,
that
is
more
likely
to
occur
than
not
to
occur.
This
definition
includes,
but
is
not
limited
to,
such
activities
as
charging
reactor
vessels;
drumming;
bulk
loading;
cleaning
equipment;
maintenance
operations;
materials
handling
and
transfers;
and
analytical
operations.
Accidental
or
merely
speculative
exposures
are
excluded.
EPA
is
proposing
to
require
reporting
of
exposure
through
the
use
of
the
range
code
corresponding
to
the
submitters'
estimate
of
the
total
number
of
potentially
exposed
workers.


Processing
is
1)
the
preparation
of
a
chemical
substance,
after
its
manufacture,
for
distribution
in
commerce
in
the
same
form
or
physical
state
or
in
a
different
form
or
physical
state
from
that
in
which
it
was
received,
2)
the
preparation
of
a
chemical
substance,
after
its
manufacture,
for
distribution
in
commerce
as
a
part
of
a
mixture
or
article
containing
the
substance,
or
3)
use
as
an
intermediate.
Based
on
this
definition,
processing
involves
the
incorporation
of
the
chemical
into
a
formulation,
an
article,
or
a
mixture.


North
American
Industry
Classification
System
(
NAICS)
codes
describe
the
industrial
activities
associated
with
each
reported
industrial
processing
or
use
operation.
If
more
than
ten
NAICS
codes
apply
to
a
reportable
chemical
substance,
only
the
ten
codes
for
6
The
Standard
Industrial
Classification
(
SIC)
system
has
recently
been
replaced
with
the
North
American
Industry
Classification
System
(
NAICS).
NAICS
is
a
six­
digit
coding
system,
therefore
allowing
for
more
detailed
specification
than
the
four
digit
SIC
system.

I­
7
Box
I­
2.
Proposed
Function
Categories
°
Adsorbents
and
absorbents;
°
Adhesives
and
binding
agents;
°
Aerosol
propellants;
°
Agricultural
chemicals
(
non­
pesticidal);
°
Anti­
adhesive
agents;
°
Bleaching
agents;
°
Coloring
agents,
dyes;
°
Coloring
agents,
pigments;
°
Corrosion
inhibitors
and
anti­
scaling
agents;
°
Fillers;
°
Fixing
agents;
°
Flame
retardants;
°
Flotation
agents;
°
Fuels;
°
Functional
fluids;
°
Intermediates;
°
Lubricants;
°
Odor
agents;
°
Oxidizing
agents;
°
pH­
regulating
agents;
°
Photosensitive
chemicals;
°
Plating
agents
and
metal
surface
treating
agents;
°
Processing
aid,
not
otherwise
listed;
°
Process
regulators,
used
in
vulcanization
or
polymerization
processes;
°
Process
regulators,
other
than
polymerization
or
vulcanization
processes;
°
Reducing
agents;
°
Solvents
(
for
cleaning
or
degreasing);
°
Solvents
(
which
become
part
of
product
formulation
or
mixture);
°
Solvents
(
for
chemical
manufacture
and
processing
and
are
not
part
of
the
end
product
at
greater
than
one
percent
by
weight);
°
Stabilizers;
°
Surface
active
agents;
°
Viscosity
adjustors;
and
°
Other.
the
substance
that
cumulatively
represent
the
largest
percentage
of
production
volume
(
measured
by
weight)
need
be
reported.
6

Industrial
function
category
codes
correspond
to
the
appropriate
functions
of
the
reportable
chemicals,
based
on
a
review
of
different
chemical
function
classification
systems
both
internal
and
external
to
EPA.
For
each
NAICS
code
that
is
reported,
the
functional
use
category
code
that
best
represents
the
specific
manner
in
which
the
reportable
chemical
substance
is
used
must
be
selected.
These
categories
were
developed
from
the
European
Organization
for
Economic
Cooperation
and
Development's
(
OECD's)
use
categories
and
EPA
experience
from
the
New
Chemicals
Program.
Box
I­
2
provides
a
listing
of
the
initial
Industrial
Function
Category
Codes
proposed
for
the
IUR
amendments.
There
is
significant
overlap
between
this
suggested
list
for
the
amended
IUR
and
the
industrial
function
codes
used
for
the
Premanufacture
Notifications
(
PMNs),
Use
Cluster
Scoring
System
(
UCSS),
Use
and
Exposure
Information
Project
(
UEIP),
Comprehensive
Assessment
Information
Rule
(
CAIR)
and
the
OECD's
programs
(
U.
S.
EPA
1996d).


Commercial
and
consumer
product
category
codes
must
be
reported
for
each
category
in
which
the
reportable
chemical
substance
is
used.
These
categories
have
been
developed
based
on
a
review
of
national
usage
surveys
of
consumer
products,
exposure
monitoring
data,
product
emissions
testing,
and
a
variety
of
other
data
sources.
This
review
provided
a
list
of
consumer
products
and
a
subsequent
categorization
of
these
products
by
common
characteristics,
such
as
use
scenarios,
into
major
groupings
of
consumer
and
commercial
products.
Box
I­
3
provides
a
listing
of
these
proposed
commercial
and
consumer
product
categories.
7
The
Office
of
Management
and
Budget
prepares
Standard
Industry
Classification
(
SIC)
Codes
corresponding
to
classified
industrial
activities.
These
SIC
codes
are
identified
at
the
2­
digit,
3­
digit,
4­
digit,
and
higher
levels
based
on
the
specificity
of
the
activities
undertaken.

I­
8
Box
I­
3.
Proposed
Commercial
and
Consumer
Product
Categories

Artists'
Supplies;


Adhesives
and
sealants;


Automotive
care
products;


Electrical
electronic
products;


Glass
and
ceramic
products;


Fabrics,
textiles
and
apparel;


Lawn
and
garden
products
(
non­
pesticidal);


Leather
products;


Lubricants,
greases
and
fuel
additives;


Metal
products;

Paper
products;


Paints
and
coatings;


Photographic
chemicals;


Polishes
and
sanitation
goods;


Rubber
and
plastic
products;


Soaps
and
detergents;


Transportation
products;


Wood
and
wood
furniture;


Other.

C.
Overview
of
the
Regulated
Community
The
regulated
community
consists
of
companies
manufacturing
or
importing
chemicals
listed
on
the
TSCA
Inventory
and
regulated
under
TSCA
§
8.
In
general,
the
industry
segments
that
compose
the
regulated
community
for
the
proposed
rule
are
those
that
produce
or
import
organic
and
inorganic
chemical
substances.
Manufacturers
and
importers
of
non­
TSCA
chemical
substances
(
such
as
pesticides,
tobacco,
nuclear
material,
firearms
and
ammunition,
food
and
food
additives,
drugs,
and
cosmetics)
are
not
required
to
report
on
those
chemicals.
Chemical
processors
are
also
exempt
from
all
reporting.
The
sections
below
describe
the
industries
affected
by
the
proposed
rule
and
the
types
of
information
that
they
would
be
required
to
report.

1.
Chemical
Industry
Segments
Likely
to
be
Subject
to
the
IUR
Amendments
The
SIC
codes
correlating
with
the
industry
groups
likely
to
be
affected
by
the
proposed
IUR
amendments
are
identified
in
Table
I­
1.7
These
SIC
codes
show
the
primary
activities
for
establishments
within
industries
that
manufacture
or
import
chemicals
listed
on
the
TSCA
Inventory.
The
8
These
segments
of
the
chemical
industry
represent
those
most
likely
to
be
subject
to
TSCA
§
8
reporting,
but
other
industry
sectors
(
not
listed
here)
may
also
manufacture
certain
subject
chemicals.

I­
9
sectors
of
the
U.
S.
economy
affected
by
the
proposed
rule
can
be
classified
into
the
10
major
industry
groups
briefly
described
below
(
EOP
1987)
8:
I­
9
Major
Group
10.
Metal
Mining
Group
102:
Copper
Ores
1021
Copper
Ores
Major
Group
13.
Oil
and
Gas
Extraction
Group
131:
Crude
Petroleum
and
Natural
Gas
1311
Crude
Petroleum
and
Natural
Gas
Group
132:
Natural
Gas
Liquids
1321
Natural
Gas
Liquids
Group
138:
Oil
and
Gas
Field
Services
1382
Oil
and
Gas
Field
Exploration
Services
1389
Oil
and
Gas
Field
Services,
Not
Elsewhere
Classified
(
NEC)

Major
Group
14.
Mining
and
Quarrying
of
Nonmetallic
Minerals
Except
Fuels
Group
145:
Clay
Ceramic
and
Refractory
Minerals
1459
Kaolin
and
Ball
Clay
Group
147:
Chemical
and
Fertilizer
Mineral
Mining
1474
Potash,
Soda,
and
Borate
Minerals
1475
Phosphate
Rock
Major
Group
20.
Food
and
Kindred
Products
Group
207:
Fats
and
Oil
Mills
2074
Cottonseed
Oil
Mills
2075
Soybean
Oil
Mills
2076
Vegetable
Oil
Mills,
Except
Corn,

Cottonseed,
and
Soybean
2077
Animal
and
Marine
Fats
and
Oils
Major
Group
26.
Paper
and
Allied
Products
Group
261:
Pulp
Mills
2611
Pulp
Mills
Group
262:
Paper
Mills
2621
Paper
Mills
Group
263:
Paperboard
Mills
2631
Paperboard
Mills
Group
265:
Paperboard
Containers
and
Boxes
2653
Corrugated
and
Solid
Fiber
Boxes
Group
267:
Converted
Paper
and
Paperboard
Products,

Except
Containers
and
Boxes
2672
Coated
and
Laminated
Paper,
(
NEC)
Major
Group
28.
Chemicals
and
Allied
Products
Group
281
Industrial
Inorganic
Chemicals
2812
Alkalies
and
Chlorine
2813
Industrial
Gases
2816
Industrial
Pigments
2819
Industrial
Inorganic
Chemicals,
NEC
Group
282
Plastics
Materials
and
Synthetic
Resins,

Synthetic
Rubber,
Cellulosic
and
Other
Manmade
Fibers,
Except
Glass
2821
Plastics
Materials,
Synthetic
Resins
and
Nonvulcanizable
Elastomers
2822
Synthetic
Rubber
(
Vulcanizable
Elastomers)

2823
Cellulosic
Manmade
Fibers
2824
Manmade
Organic
Fibers,
Except
Cellulosic
Group
283:
Drugs
2833
Medicinal
Chemicals
and
Botanical
Products
2834
Pharmaceutical
Preparations
2835
In
Vitro
and
In
Vivo
Diagnostic
Substances
2836
Biological
Products,
Except
Diagnostic
Substance
Group
284
Soap,
Detergents,
and
Cleaning
Preparations;
Perfumes,
Cosmetics,
and
Other
Toilet
Preparations
2841
Soap
and
Other
Detergents,
Except
Specialty
Cleaners
2842
Specialty
Cleaning,
Polishing,
and
Sanitation
Preparations
2843
Surface
Active
Agents,
Finishing
Agents,

Sulfonated
Oils,
and
Assistants
2844
Perfumes,
Cosmetics,
and
Other
Toilet
Preparations
Group
285
Paints,
Varnishes,
Lacquers,
Enamels,
and
Allied
Products
2851
Paints,
Varnishes,
Lacquers,
Enamels,
and
Allied
Products
Group
286
Industrial
Organic
Chemicals
2861
Gum
and
wood
Chemicals
2865
Cyclic
Organic
Crudes
and
Intermediates,

and
Organic
Dyes
and
Pigments
2869
Industrial
Organic
Chemicals,
NEC
Group
287
Agricultural
Chemicals
2873
Nitrogenous
Fertilizers
2874
Phosphate
Fertilizers
2879
Pesticides
and
Agricultural
Chemicals,
NEC
Group
289
Miscellaneous
Chemical
Products
2891
Adhesives
and
Sealants
2892
Explosives
2893
Printing
Ink
2895
Carbon
Black
2899
Chemicals
and
Chemical
Preparations,
NEC
Table
I­
1.
Standard
Industrial
Codes
for
Industries
Likely
to
Be
Subject
to
IUR
Reporting
Source:
EOP
1987.
I­
11

Major
Group
10
­
Metal
Mining
includes
establishments
primarily
concerned
with
mining,
developing
mines,
or
exploring
for
metallic
minerals
(
ores).
These
ores
are
valued
for
the
metals
contained,
to
be
recovered
for
use
as
such
or
as
constituents
of
alloys,
chemicals,
pigments
or
other
products.


Major
Group
13
­
Oil
and
Gas
Extraction
includes
establishments
primarily
engaged
in
the
production
of
crude
petroleum
and
natural
gas,
extraction
of
oil
from
oil
sands
and
oil
shale,
production
of
natural
gasoline
and
cycle
condensate,
and
production
of
gas
and
hydrocarbon
liquids
from
coal
at
the
mine
site.


Major
Group
26
­
Paper
and
Allied
Products
includes
establishments
primarily
engaged
in
the
manufacture
of
pulps
from
wood
and
other
cellulose
fibers
and
from
rags;
the
manufacture
of
paper
and
paperboard;
and
the
manufacture
of
paper
and
paperboard
into
converted
products.


Major
Group
28
­
Chemicals
and
Allied
Products
include
establishments
producing
basic
chemicals
and
establishments
manufacturing
products
by
predominantly
chemical
processes.
Major
group
28
establishments
manufacture
three
general
classes
of
products:
basic
chemicals,
chemical
products
to
be
used
in
further
manufacture,
and
finished
chemical
products
to
be
used
for
ultimate
consumption.


Major
Group
29
­
Petroleum
Refining
includes
establishments
that
participate
in
petroleum
refining,
petroleum
manufacturing,
paving
and
roofing
materials,
and
compounding
lubricating
oils
and
greases
from
purchased
materials.
Establishments
providing
gas
to
consumers
are
not
included
in
this
category,
but
rather
are
classified
with
Public
Utilities
Industries
(
Major
Group
49).


Major
Group
51
­
Wholesale
Trade
­
Nondurable
Goods
includes
establishments
primarily
engaged
in
the
wholesale
distribution
of
nondurable
goods.
This
group
includes
the
wholesale
distribution
of
plastics
materials
and
of
chemicals
and
allied
products,
not
elsewhere
classified.

The
major
groups
identified
above
and
the
more
detailed
4­
digit
groups
presented
in
Table
I­
1
represent
the
designation
of
sites
that
would
likely
be
subject
to
IUR
amendment
reporting.
However,
many
factors
relate
to
the
nature
of
these
sites,
making
identification
of
the
regulated
community
more
difficult.
For
example,
SIC
codes
reflect
a
site's
primary
activity,
omitting
substantial
participation
a
company
may
have
in
other
industry
activities.

Secondly,
SIC
codes
assigned
to
parent
companies
reflect
the
parent
company's
primary
activity,
although
many
parent
companies
are
primarily
holding
companies
with
small
subsidiaries.
Each
of
these
small
subsidiaries
may
belong
in
a
completely
different
industry
classification
based
on
its
own
primary
activity.
Therefore,
sites
considered
to
fit
into
other
SIC
codes
due
to
their
primary
activities
or
to
their
parent
company
activities
may
be
subject
to
this
rule.
Likewise,
sites
whose
parent
companies
fit
into
these
SIC
codes
may
not
be
subject
to
this
rule.
I­
12
Box
I­
4.
Reporting
Processing
and
Use
Information
on
Chemicals
The
regulated
community
will
be
expected
to
provide
readily
obtainable
information
on
downstream
processing
and
use
of
subject
chemicals.
Reporting
this
information
could
be
straightforward
for
companies
that
manufacture
a
chemical
for
a
single
customer
for
a
specific
commercial
end­
use.
For
example,
a
small
volume,
proprietary
use
chemical
(
e.
g.,
a
specialty
adhesive
for
aerospace
applications)
might
have
only
one
processor,
very
few
users,
no
consumer
use,
and
a
limited
exposure
profile.
By
comparison,
the
nuances
associated
with
distribution
of
a
large
volume
chemical
within
and
outside
of
a
particular
site
will
place
a
greater
burden
on
the
portion
of
the
regulated
community
that
provides
chemicals
to
a
wide
range
of
sites
and
for
a
variety
of
end­
uses.
An
example
of
this
might
be
a
company
distributing
chemicals
for
use
in
various
perfumes
and
fragranced
toiletries,
thereby
reaching
hundreds
of
processing
sites.
In
either
case,
however,
manufacturers
and
importers
are
required
only
to
provide
information
considered
to
be
readily
obtainable;
therefore,
more
complicated
scenarios
should
require
only
a
marginally
greater
effort
than
small
volume,
limited
use
2.
Information
to
be
Reported
In
addition
to
the
information
required
under
the
original
IUR,
companies
reporting
under
the
proposed
amendments
will
be
reporting
additional
information
on
facility
and
company
identification,
chemical
use
and
exposure,
and
status
of
CBI
claims.
In
addition
to
reporting
information
on
their
own
site,
the
company
will
also
report
estimates
of
downstream
uses
and
exposures,
as
well
as
provide
information
on
commercial
and
consumer
end­
uses
of
a
particular
chemical.
Reported
facility
and
manufacturing
information
is
to
be
supplied
as
far
as
it
is
known
to
or
reasonably
ascertainable
by
the
submitter,
and
reported
processing
and
use
information
is
to
be
supplied
as
far
as
it
is
readily
obtainable
by
the
submitter.
As
such,

supplying
these
data
elements
should
not
entail
a
particularly
burdensome
level
of
effort
(
see
Box
I­
4).
Furthermore,

EPA
proposes
that
some
information
should
be
reported
in
ranges,
and
that
only
the
majority
of
the
production
volume
be
accounted
for
when
reporting
use
information.
Allowing
for
reporting
in
ranges
will
reduce
the
potential
burden
to
submitters
of
developing
a
precise
point
estimate
of
their
chemical
production,
but
will
provide
information
that
is
sufficiently
precise
for
the
Agency's
risk­
screening
purposes.

D.
Purpose
and
Contents
of
Report
1.
Purpose
and
Scope
of
Report
This
report
presents
an
economic
analysis
of
the
costs
and
benefits
associated
with
the
proposed
IUR
amendments.
EPA
expects
these
amendments
to
have
cost
impacts
for
both
industry
and
EPA.
In
addition,
the
rule
is
expected
to
generate
substantial
benefits
by
providing
needed
screening
level
information
on
TSCA
chemical
substances
currently
in
commerce.

This
economic
analysis
compares
the
costs
and
benefits
of
the
proposed
regulation.
This
report
also
presents
an
analysis
of
selected
regulatory
alternatives.
For
each
alternative,
the
expected
impacts
on
anticipated
costs
and
benefits
are
assessed.
The
following
analyses
are
provided
in
this
report:

­­
an
overview
of
changes
in
the
reporting
requirements;
I­
13
­­
an
assessment
of
the
industry
groups
considered
in
this
analysis
(
i.
e.,
regulated
community);

­­
a
compilation
and
estimation
of
industry
and
Agency
unit
and
total
costs;

­­
an
assessment
of
the
benefits
that
will
result
from
the
information
collected;
and
­­
a
comparison
of
the
costs
and
the
benefits
of
the
proposed
rule.

This
report
also
discusses
the
impacts
of
the
proposed
amendments
on
small
businesses
and
addresses
other
congressional
mandates
(
e.
g.,
Paperwork
Reduction
Act).

2.
Contents
of
the
Report
The
contents
of
the
six
remaining
chapters
and
five
appendices
contained
in
this
report
are
organized
as
follows:


Chapter
II
describes
the
need
for
this
rulemaking,
existing
data
sources,
and
regulatory
options
considered.
The
statement
of
need
explains
the
economic
reasons
for
these
amendments;


Chapter
III
presents
original
IUR
reporting
requirements
(
i.
e.,
the
baseline)
and
quantifies
industry
and
agency
costs
associated
with
the
original
rule.
This
chapter
also
presents
an
analysis
of
the
industry
burden
expected
to
result
from
the
implementation
of
the
IUR
amendments.
This
chapter
provides
a
detailed
analysis
of
the
incremental
costs
to
industry
for
complying
with
requirements
for
submission
of
required
reports
for
each
of
the
proposed
reporting
options
relative
to
the
original
(
baseline)
requirements;


Chapter
IV
provides
estimates
of
the
government
costs
attributable
to
additional
data
collection
and
processing
activities
for
each
of
the
proposed
reporting
options
relative
to
costs
incurred
for
original
requirements;


Chapter
V
qualitatively
describes
the
benefits
that
will
be
generated
from
the
collection
of
additional
information
under
the
IUR
amendments.
This
chapter
describes
how
the
information
will
be
used
by
the
Agency
and
how
use
of
this
information
will
generate
societal
benefits
by
reducing
risks
and
improving
government
risk
management
activities;


Chapter
VI
presents
a
cost­
benefit
comparison
for
each
of
the
proposed
reporting
options;


Chapter
VII
provides
a
discussion
of
small
business
impacts
and
environmental
equity
considerations;


Appendix
A
provides
the
latest
draft
version
of
the
Form
U,
the
reporting
form
for
the
Inventory
Update
Rule;


Appendix
B
provides
information
on
the
types
of
data
that
are
currently
available
to
EPA,
demonstrating
the
need
for
further
collection
of
data
under
the
IUR
amendments;


Appendix
C
presents
basic
data
regarding
the
number
of
chemicals,
reports,
and
sites
involved
in
IUR
reporting,
as
well
as
the
methodology
used
to
generate
numbers
of
reports
expected
to
be
submitted
for
each
reporting
cycle;


Appendix
D
describes
the
survey
administered
to
determine
the
industry
burden
of
reporting
under
the
original
IUR
and
the
proposed
IUR
amendments
and
presents
an
analysis
of
the
survey
results;
and

Appendix
E
provides
a
sensitivity
analysis
of
several
cost
assumptions
used
in
determining
the
industry
cost
of
reporting.
The
analyzed
cost
assumptions
include
the
number
of
chemicals
reported
per
site
and
the
discount
rate
used
to
calculate
the
net
present
value
and
annualized
costs
of
the
amendments.
II­
1
CHAPTER
II.
STATEMENT
OF
PROBLEM
The
production,
processing,
and
use
of
chemicals
can
result
in
negative
environmental
externalities.
(
An
externality
is
usually
defined
as
an
unintentional
side­
effect
of
production
and
consumption
that
affects
a
third
party
either
positively
or
negatively.)
Negative
externalities
may
remain
unidentified
due
to
the
lack
of
available
information
on
the
hazards
of
and
exposures
to
chemicals.
The
market
has
not
provided
the
public
or
the
government
with
information
on
risks
associated
with
chemicals.
Because
of
these
externalities,
and
because
the
market
does
not
necessarily
provide
needed
information
to
interested
parties,
socially
suboptimal
levels
of
human
health
and
environmental
quality
exist.

This
chapter
describes
the
underlying
problem
and
market
failure
that
the
proposed
IUR
amendments
are
designed
to
address
and
discusses
how
the
proposed
regulatory
option
addresses
the
problem.
The
chapter
is
divided
into
two
parts.
Section
A
describes
the
market
failure,
the
need
for
information,
and
the
manner
in
which
the
proposed
rule
addresses
these
information
needs.
Section
B
discusses
alternative
approaches,
both
regulatory
and
non­
regulatory,
and
summarizes
the
regulatory
options
under
consideration.

A.
Statement
of
Need
Under
Executive
Order
Number
12866,
EPA
is
required
to
identify
whether
or
not
the
proposed
rule
addresses
a
significant
market
failure.
The
major
types
of
market
failure
are
identified
as
externality,

natural
monopoly,
market
power
and
inadequate
or
asymmetric
information.
This
proposed
rule
uses
the
information
gathering
process
as
a
means
to
develop
policies
to
address
a
problem
of
externality.

1.
Market
Failure:
Externalities
and
the
Need
for
Information
A
defining
feature
of
a
market
failure
is
the
inequality
between
the
social
consequences
of
an
action
and
its
purely
private
perception
of
benefits
and
costs.
For
environmental
problems
resulting
from
market
failures,
this
divergence
between
private
and
social
perspectives
is
normally
called
an
externality
or
external
cost.
Such
divergences
occur
when
the
actions
of
one
economic
entity
impose
costs
on
parties
that
are
external
to,
or
not
accounted
for
in,
a
market
transaction
or
activity.
Although
many
different
types
of
environmental
externalities
exist,
regulations
under
TSCA
and
other
OPPT
II­
2
Box
II­
1.
Progress
on
Screening
Chemicals
for
Risks
Identifying
chemical
substances,
plant
sites,
and
exposures
of
most
concern
and
setting
priorities
for
more
detailed
risk
assessment
and
potential
risk
management
actions
are
important
components
of
a
successful
chemical
risk
management
program.
As
indicated
in
EPA's
TSCA
Inventory,
there
are
more
than
75,000
chemicals
in
commerce.
Screening
the
potential
risks
of
these
chemical
substances,
and
setting
priorities
for
more
detailed
risk
assessment
and
possible
risk
management,
is
an
enormous
challenge
given
the
extremely
large
number
of
manufacturing,
processing,
and
use
sites
and
exposure
scenarios.
However,
of
these
75,000
chemicals,
EPA
has
determined
that
the
majority
of
the
chemicals
are
likely
to
be
of
low
concern
and
is
focusing
attention
on
the
top
10%
­
15%
of
the
chemicals.

Additional
information
is
required
to
adequately
assess
the
risks
of
these
top
chemicals
(
about
10,000
chemicals)
on
which
EPA
would
like
to
focus
attention.
EPA
plans
to
begin
screening
the
top
6,000
of
these
chemicals
and
requires
additional
use
and
exposure
information
to
adequately
screen
their
risks.
Without
the
additional
information
EPA
may
not
identify
the
potential
risks
posed
by
these
chemicals.
If
the
potential
risks
are
not
identified,
EPA
may
not
be
able
to
evaluate
nor
address
the
risks
associated
with
the
chemical
or
use.
In
the
future,
EPA
plans
to
expand
this
evaluation
to
include
other
TSCA
chemicals.
EPA
believes
that
collecting
the
slightly
augmented
facility
and
manufacturing
information
for
the
remaining
chemicals
provides
sufficient
information
to
maintain
a
profile
of
the
chemical
industry
and
to
react
to
unanticipated
risks.

A
key
benefit
of
the
IUR
amendments
for
these
programs
will
result
from
the
reduction
in
time
required
to
collect
and
process
data
and
to
develop
exposure
estimates.
Because
the
process
by
which
chemicals
enter
and
proceed
through
EPA's
risk
management
programs
is
hindered
by
the
lack
of
data
on
exposure,
the
risks
posed
by
these
chemicals
cannot
be
dealt
with
efficiently.
Therefore,
detrimental
worker
and
consumer
exposures
and
releases
to
the
environment
cannot
be
mitigated
in
a
timely
manner,
resulting
in
continued
negative
consequences
for
human
and
ecosystem
health.

This
shortfall
was
highlighted
in
a
GAO
report
entitled
"
Toxic
Substances
Control
Act:
Legislative
Changes
Could
Make
the
Act
More
Effective."
The
report
states
that,
in
total,
EPA
has
reviewed
about
16
percent
of
the
Inventory,
either
as
new
or
existing
chemicals.
EPA
has
been
reviewing
about
100
existing
chemicals
per
year.
(
New
chemicals
are
evaluated
through
the
New
Chemicals
Program
prior
to
becoming
part
of
the
Inventory.)
At
this
rate
it
seems
clear
that
EPA
cannot
effectively
screen
and
manage
chemical
risks
for
the
6,000
chemicals
for
which
there
are
significant
concerns
without
additional
information.
Adding
the
information
collected
through
the
proposed
IUR
amendments
provides
the
information
needed
by
the
Agency
to
determine
which
chemicals
or
chemicals
and
use
scenarios
are
likely
to
pose
significant
risks,
to
determine
which
chemicals
are
selected
for
more
detailed
analysis,
and,
ultimately,
to
determine
which
initiatives
typically
focus
on
those
related
to
chemical
production
and
use.
In
this
area,
exposure
of
humans
and
the
environment
to
hazardous
substances
typically
results
in
market
outcomes
that
are
less
than
optimal.
A
common
example
would
be
a
manufacturing
process
that
emits
some
amount
of
a
chemical
while
producing
or
using
that
chemical.
As
a
result
of
this
activity,
environmental
and
health
risks
are
imposed
on
its
employees,
the
public
at
large,
and
the
environment.
These
risks
are
created
by
the
manufacturing
facility,
but
it
is
society
(
employees
and
the
public)
that
bears
the
cost
of
these
risks.

Given
the
host
of
substances
and
potentially
risky
activities
within
OPPT's
purview,
the
number
of
environmental
externalities
possibly
requiring
EPA's
investigation
and
intervention
is
quite
large.

Because
of
the
diverse
character
of
the
chemical
industry,
its
products,
and
the
uses
of
those
products,

the
first
crucial
step
in
remedying
market
failures
is
to
identify
instances
in
which
these
externalities
are
II­
3
Box
II­
2.
Reasons
for
Lack
of
Information
Negative
incentives
­­
Manufacturers
have
an
incentive
not
to
provide
information
that
highlights
the
negative
characteristics
of
the
product
or
job
for
consumers
or
workers.
Such
information
would
lessen
the
attractiveness
of
purchasing
the
product
or
accepting
employment.

Information
production/
dissemination
costs
­­
The
production
and
dissemination
of
information
has
a
cost
which
may
or
may
not
be
expensive.
Someone
has
to
be
willing
to
pay
this
cost
for
the
information
to
be
made
available.

Causation
difficult
to
establish
­­
Often
substantial
distance
may
separate
the
original
polluting
event
and
subsequent
human
or
environmental
damage;
frequently
many
possible
sources
exist.
Moreover,
often
the
linkages
from
a
pollution
or
exposure
event
may
be
extremely
numerous
and
hard
to
trace.
For
example,
the
impact
of
toxics
released
in
one
part
of
a
wetland
on
oceanic
aquatic
species
is
difficult
to
determine.
If
establishing
a
chain
of
causation
from
the
harm
to
the
responsible
party
and
event
is
hard,
the
market
and
even
extra­
market
systems
(
such
a
conventional
legal
remedies)
may
not
adequately
address
these
risks.

Exposures
not
perceptible
­­
If
exposure
to
harmful
substances
are
not
perceptible
when
they
occur,
individuals
may
have
difficulty
taking
action
to
ensure
that
these
exposures
are
adequately
reflected
in
market
demands
and
prices.

Long
time
lags
between
exposure
and
effects
­­
Long
latency
periods
and
other
factors
that
cause
harms
to
occur
far
after
the
exposure
event
can
also
hinder
the
market's
attempts
to
establish
and
enforce
responsibility
for
environmental
consequences
of
some
activities.
likely
to
occur.
Thus,
identifying
situations
in
which
externalities
are
present
 
and
where
the
potential
risks
posed
by
these
externalities
are
sufficiently
large
as
to
warrant
further
investigation
 
is
a
key
goal
of
the
chemical
screening
that
EPA
performs
as
part
of
its
risk
management
activities.
In
order
to
improve
internalization
of
environmental
externalities,
EPA
must
first
identify
these
risks
of
concern.
Information
about
exposure
is
a
critical
component
of
this
screening.
The
detailed
and
accurate
information
required
to
identify
relevant
externalities
is
not
currently
available
to
EPA's
risk
management
process
(
See
Box
II­

1).
The
question
thus
arises:
"
why
does
the
market
fail
to
provide
the
information
needed
to
identify
these
externalities?"

There
are
several
causes
of
this
information
void.
There
is
little
incentive
to
provide
information,

the
provision
of
information
is
not
costless
in
the
real
world,
and
providing
the
information
may
have
negative
consequences
for
the
company
by
either
dissuading
customers
from
purchasing
the
product
or
by
providing
competitors
with
information.
In
part,
the
lack
of
information
is
a
motivation
for
the
activities
that
EPA
undertakes
(
examples
of
the
reasons
there
is
a
lack
of
information
are
discussed
in
Box
II­
2
and
the
text
below).
EPA's
mission
is
to
act
in
the
public's
interest,
undertaking
actions
to
correct
the
lack
of
information,
and
thereby
enble
the
identification
of
existing
externalities
that
cause
a
suboptimal
level
of
protection
for
the
environment
and
the
public.
II­
4
Market
forces
encourage
the
provision
of
some
types
of
information.
For
example,
consumers
and
job
seekers
are
able
to
obtain
information
on
some
types
of
product
and
job
characteristics
relatively
easily.
In
particular,
producers
of
products
have
an
incentive
to
provide
information
if
it
encourages
a
potential
consumer
of
the
product
to
purchase
it.
Similarly,
employers
have
an
incentive
to
entice
potential
employees
to
join
by
highlighting
attractive
and
safe
features
of
the
work
environment.

Consumers
and
workers
can
also
seek
out
some
types
of
relevant
information
that
is
not
readily
provided
in
the
market
through
indirect
sources
such
as
consumer
magazines
and
labor
unions.
However,
not
all
the
information
that
consumers
and
workers
could
use
to
make
safety
decisions
or
that
EPA
needs
to
determine
the
existence
and
magnitude
of
potential
externalities
is
readily
provided
by
the
market.

For
example,
manufacturers
do
not
have
an
incentive
to
provide
information
that
would
dissuade
consumers
from
purchasing
the
product
or
workers
from
choosing
employment
in
the
manufacturing
firm.

Such
information
might
be
information
on
the
safety
characteristics
of
the
product
or
job.
In
some
cases
manufacturers
may
feel
that
alerting
consumers
or
workers
to
such
characteristics,
even
in
the
context
of
improvements
that
have
been
made
or
steps
that
individuals
can
take
to
minimize
risks,
would
negatively
affect
the
attractiveness
of
the
product
or
employment.
Thus,
they
may
not
have
incentives
to
provide
such
information,
and
they
may
have
an
incentive
not
to
provide
it.

A
potential
failure
to
provide
adequate
information
can
occur
for
the
simple
reason
that
information
may
be
costly
to
generate
and
disseminate.
Moreover,
there
may
be
economies
of
scale
associated
with
information
provision,
interpretation,
and
use.
From
society's
point
of
view,
the
benefits
of
collecting
the
information
extend
beyond
one
person
to
all
potential
consumers
of
the
product
or
to
workers
manufacturing
the
product.
Even
if
information
could
be
collected,
it
may
not
be
in
any
individual's
best
interest
to
do
so.
Thus,
government's
role
(
in
this
case
EPA's)
is
to
collect
and
maintain
this
information,
and
to
interpret
it
in
order
to
identify
the
externalities
and
determine
if
action
is
warranted
to
protect
the
public's
interest
2.
Data
Required
to
Conduct
Risk
Screening
and
Management
Currently,
the
process
of
collecting
information
on
chemical
effects
and
exposures
to
support
risk
management
actions
is
a
resource­
intensive
and
time­
consuming
process.
EPA's
ability
to
II­
5
improve
priority
setting
and
resource
allocation
activities
is
dependent
on
the
availability
of
exposure
data
that
is
not
currently
collected
on
a
comprehensive
basis.
Consequently,
the
primary
goal
of
this
rule
is
to
enhance
the
quality
and
quantity
of
information
about
chemical
uses
and
exposures
that
EPA
may
use
to
identify
risks
under
TSCA,
with
the
ultimate
goal
of
protecting
the
public.

To
fully
assess
human
exposure
to
a
chemical,
EPA
needs
to
know
how
many
workers,

consumers,
and
others
are
exposed,
the
mechanism
through
which
exposure
occurs,
and
the
amount
and
duration
of
exposures.
The
Agency
has
systematically
defined
the
components
of
exposure
assessment
in
its
Guidelines
for
Exposure
Assessment,
which
discuss
the
information
requirements
for
several
different
approaches
to
exposure
assessment,
ranging
from
initial
risk
screening
to
full­
scale
risk
assessments
(
U.
S.
EPA
1992).
Specific
data
needs
include:


Estimates
of
the
number
of
workers
potentially
exposed
to
specific
chemicals;


Information
on
whether
a
chemical
substance
is
used
in
consumer
products;


Information
on
frequency
and
duration
of
exposure
or
time­
of­
contact;


Information
to
enable
EPA
to
sort
and
screen
information
by
industry
sector;


Information
on
the
industrial
function
of
a
chemical
substance;
and

Standard
facility
identifiers
to
allow
linkages
of
data
with
other
sources
of
information.

Table
II­
1
below
lists
the
three
components
of
risk
assessment,
examples
of
variables
affecting
these
components,
and
specific
exposure­
related
data
elements
to
be
collected
under
the
amended
IUR
for
initial
screening
assessments.
These
data
elements
provide
a
variety
of
useful
information
for
estimating
potential
exposures.
For
example,
industrial
process
and
use
activity,
production
volume,

function
code,
and
industry
sector
information
can
aid
in
the
determination
of
the
frequency,
magnitude,

and
duration
of
potential
worker
exposures.
Similarly,
consumer
use
information
and
the
number
of
chemical
processing
and
manufacturing
sites
will
provide
information
on
the
nature
and
size
of
the
general
population
that
may
potentially
be
exposed.
II­
6
Table
II­
1.
Components
of
Exposure
Assessments
and
Exposure­
Related
Data
Elements
Component
of
Exposure
Assessmentsa
Examples
of
Variables
Effecting
Component
for
Exposure
Assessments
Exposure­
Related
Screening
Data
Elements
in
IUR
Amendments
Source
and
concentration
of
chemical
substances
°
Industrial
process/
use
activity
°
Unit
operations
°
Process
type
°
Industry
practices
°
Industrial
function
°
Application
methods
°
Throughput
rates
°
Use
concentrations
°
Physical
and
chemical
properties
°
Efficiency
°
Control
technologies
°
Treatment
and
disposal
options
°
Ventilation
design
°
Use
of
personal
protective
equipment
°
Regulations
°
Production
volume
°
Industrial
process/
use
activities
and
volumes
°
Industry
sectors
°
Industrial
chemical
function
°
Physical
form
°
Maximum
concentration
Population
and
receptor
information
°
Number
of
workers
°
Size
of
general
population
exposed
(
consumer
products
are
assumed
to
have
widespread
potential
exposures)
°
Time­
activity
patterns
°
Physical
characteristics
°
Age
°
Number
of
workers
°
Number
of
sites
°
Consumer
use
information
Frequency
and
duration
of
exposure
or
time­
of­
contact
°
Default
values
are
typically
used
(
i.
e.
250
days/
yr,
8
hrs/
day
for
workers)
Default
values
(
not
collected)

a
Source:
U.
S.
EPA
1992
3.
Existing
Data
Sources
and
Data
Gaps
The
specific
information
that
OPPT
needs
to
provide
more
accurate
preliminary
screens
of
chemicals
in
commerce,
to
identify
chemicals
of
concern,
to
identify
potentially
safer
substitute
chemicals,
and
to
properly
allocate
resources
and
set
priorities
for
its
programs
is
currently
not
available
(
see
Box
II­
3).
Currently,
chemical
data
collection
efforts
occurring
within
various
EPA
offices
do
not
systematically
or
comprehensively
collect
chemical
use
and/
or
worker
exposure
data.
The
information
collected
by
these
EPA
offices
is
described
in
Appendix
B.

Additionally,
chemical
information
is
collected
at
the
state
level
to
support
a
variety
of
state
and
federal
programs
and
regulations,
including
EPCRA,
state
Right­
to­
Know
programs,
state
permitting
requirements,
and
other
state
programs.
According
to
EPA
regional
offices
and
state
environmental
II­
7
Box
II­
3.
Risk
Screening
Activities
Lack
Important
Data
on
Exposure
Currently,
EPA
often
must
conduct
its
screening
activities
based
on
assumed
conditions,
outdated
information,
or
incomplete
data
sets.
For
instance,
EPA's
major
source
of
data
on
the
number
of
workers
exposed
is
the
National
Occupational
Exposure
Survey
conducted
by
the
National
Institute
for
Occupational
Safety
and
Health
in
the
early
1980s.
This
survey
contains
estimates
of
the
number
of
workers
exposed
nationally
to
over
10,000
chemicals.
It
also
contains
data
such
as
the
number
of
sites
at
which
a
chemical
is
manufactured
or
used.
Although
EPA
officials
recognize
that
the
survey
is
old
and
probably
outdated,
it
is
often
the
only
available
data
on
the
number
of
workers
exposed
to
a
particular
chemical.

Exposure
assessments
can
also
be
conducted
using
data
on
chemical
release
such
as
those
provided
by
the
TRI.
However,
few
release
data
are
available
for
chemicals
not
included
in
the
TRI,
which
contains
estimates
of
annual
releases
to
the
air,
water,
and
land
for
only
about
600
chemicals.
Many
other
potentially
harmful
chemicals
are
produced
in
large
quantities.
Even
for
the
TRI
chemicals,
information
such
as
the
numbers
of
workers
potentially
exposed,
the
functions
of
the
chemical,
and
the
uses
of
the
chemical
is
often
not
available.
Considering
the
diversity
of
release
sources,
the
large
number
of
associated
parameters,
and
the
limited
availability
of
existing
data,
the
effort
needed
to
perform
an
exposure
assessment
for
thousands
of
agencies,
chemical
use
and
worker
exposure
information
generally
is
not
collected
at
the
state
level
(
Codina
1996,
Layne
1996,
Fried
1996,
Browning
1996,
Hope
1996,
Larmee
1996).
For
example,
under
EPCRA
§
311
and
§
312,
states
collect
data
on
the
maximum
and
average
amount
of
a
chemical
on­
site
for
the
purposes
of
emergency
response
planning.
Information
on
total
annual
volume,
function
of
the
chemical,
or
use
of
the
chemical,
however,
is
not
available
from
this
source.

Although
several
states
and
other
federal
agencies
have
or
are
developing
programs
to
collect
information
related
to
chemical
manufacturing,
processing,
storage,
and
distribution
(
OSPIRG
1993),

the
information
typically
is
used
to
support
waste
reduction
programs
and/
or
emergency
management
plans
and
is
not
designed
to
rank
chemical
exposure
and
use
concerns
at
the
manufacturing
level.

None
of
these
groups
collect
the
data
needed
to
effectively
conduct
chemical
risk
screening
at
the
national
level.
Information
on
these
programs
is
provided
in
Appendix
B.

The
available
commercial
data
sources
characterizing
chemical
use
are
generally
not
comprehensive
in
nature.
Such
data
sources
include
the
following:


chemical
industry
journals,
such
as
Chemical
and
Engineering
News
and
the
Chemical
Marketing
Reporter;


chemical
and
business
directories,
including
the
Directory
of
Chemical
Produces
and
the
Thomas
Register;


chemical
reference
documents,
including
the
Kirk­
Othmer
Encyclopedia
of
Chemical
Technology,
SRI
International's
Chemical
Economics
Handbook,
the
Freedonia
Market
Research
database,
and
the
Frost
&
Sullivan
Market
Intelligence
database;
and
II­
8

publications
from
chemical
trade
associations,
such
as
the
Chemical
Manufactures
Association,
and
the
American
Chemical
Society.

These
sources
are
sometimes
useful
for
characterizing
production
volume,
use
categories,
physical
form,
and
chemical
function
information.
For
instance,
once
EPA
has
determined
that
a
particular
chemical
has
a
high
potential
risk,
EPA
searches
these
data
sources
for
information
on
the
chemical.

However,
these
data
sources
do
not
provide
information
useful
for
screening
large
numbers
of
chemicals.
Some
of
these
sources
provide
only
general
chemical
information
that
cannot
be
used
to
determine
production
and
use
at
the
plant
level.
Other
sources
only
specify
production
and
use
information
for
particular
companies,
and
do
not
provide
data
on
industry­
wide
chemical
production.

These
sources
typically
lack
useful
information
on
potential
worker
and
consumer
exposures.
Further
information
on
these
sources
can
be
found
in
the
EPA
report
A
Review
of
Existing
Exposure­
Related
Data
Sources
and
Approaches
to
Screening
Chemicals:
A
Response
to
CMA
(
U.
S.
EPA
1998a).

Overall,
it
has
become
increasingly
evident
that
the
information
routinely
made
available
to
EPA
through
the
available
sources
falls
short
of
the
information
needed
to
identify
potential
risks
swiftly
and
accurately.
In
particular,
the
Inventory
and
Inventory
Update
process
provides
very
limited
information
 
only
the
volume
of
production
 
to
screen
chemicals
for
exposure
risks.
However,
actual
human
health
and
other
risks
posed
by
a
chemical
depend
critically
on
its
uses
and
other
exposure
scenarios.
Without
such
data,
EPA
cannot
adequately
or
accurately
predict
the
magnitude
and
nature
of
ecosystems
and
human
populations
potentially
exposed;
the
concentrations,
frequency,
and
duration
of
exposures;
and
a
host
of
other
specific
factors
related
to
potential
chemical
exposures.

4.
Current
Risk
Screening
Approach
To
implement
its
responsibilities
for
managing
chemical
risks
under
TSCA,
EPA
identifies
or
screens
potential
chemical
risks,
assesses
identified
potential
risks
in
more
detail,
and,
if
necessary,

manages
risks
determined
to
be
unreasonable.
There
are
tens
of
thousands
of
chemicals
in
use
and
many
ways
that
exposures
can
occur.
OPPT's
past
approaches
to
chemical
risk
screening
have
been
primarily
based
on
relative
chemical
hazard,
coupled
with
IUR
production
volume
data.
This
approach,

used
because
large
scale,
national
level
data
on
worker
and
consumer
use
and
exposure
are
generally
not
available,
has
proven
inadequate
for
screening
the
large
number
of
chemicals
in
commerce.
II­
9
Box
II­
4.
Current
Existing
Chemical
Review
Process
Since
there
is
no
adequate
current
system
available
for
screening
all
of
the
chemicals
in
commerce,
EPA
relies
of
various
methods
to
determine
which
chemicals
enter
the
existing
chemical
review
process,
including
referrals
from
the
European
Union,
the
Interagency
Testing
Committee
(
ITC),
state
agencies,
and
environmental
groups.
Once
a
chemical
or
group
of
chemicals
is
determined
to
have
a
potential
for
risk,
the
chemical
enters
the
existing
chemical
review
process.
The
existing
chemical
review
process
typically
takes
from
12
to
16
weeks
and
requires
about
100
staff
hours
per
chemical,
although
the
required
level
of
effort
to
complete
the
process
may
vary.
Despite
EPA's
attempts
to
prioritize
chemical
review
efforts
according
to
the
potential
for
risk,
under
the
current
system
there
is
no
guarantee
that
those
chemicals
chosen
for
review
necessarily
pose
the
greatest
risk.
The
proposed
changes
to
the
IUR
would
provide
EPA
with
more
information
to
effectively
determine
which
chemicals
pose
the
greatest
potential
for
risk.

During
the
review
process,
the
Agency
searches
its
files
and
public
data
bases
for
information
on
the
chemical's
effects,
physical
properties,
production
volumes,
manufacturing
processes,
uses,
releases
to
the
environment,
and
other
data,
such
as
the
number
of
workers
exposed
to
the
chemical.
Because
limited
information
is
generally
available,
EPA
uses
various
computer
models
to
estimate
or
project
certain
data,
such
as
the
amounts
and
types
of
environmental
releases.
A
further
complication
is
that
a
chemical
may
have
various
potential
health
and
environmental
effects
that
EPA
needs
to
consider
in
evaluating
its
risks.
In
addition,
chemicals
often
have
multiple
uses,
each
of
which
needs
to
be
examined
to
determine
the
amount
of
exposure
(
GAO
1994).
EPA
uses
the
chemical
hazard/
production
volume
approach,
among
others,
to
initially
screen
many
chemical
substances
for
potential
risks
to
select
candidate
chemicals
for
inclusion
in
its
Existing
Chemical
review
program
(
see
Box
II­
4).
Other
approaches
include
recommendations
from
the
Interagency
Testing
Committee
(
ITC),
the
European
Union,
States,
or
environmental
groups.
The
initial
screening
is
designed
to
select
chemical
substances
in
commerce
that
appear
to
present
the
greatest
potential
risk
to
human
health
and
the
environment.
At
the
close
of
the
review,
there
are
three
possible
outcomes:
a
testing
recommendation,
a
recommendation
for
further
evaluation,
or
closure.
"
Closure"

may
include
referrals
to
other
programs
or
agencies;
dissemination
of
screening
results;
or
the
decision
to
discontinue
further
evaluation
based
on
the
chemical
substance's
low
hazard
or
low
risk
reduction
potential,
or
because
it
will
be
considered
as
part
of
a
broader
cluster
of
chemical
substances.

5.
Advantages
of
the
New
Information
Collection
The
need
for
EPA
to
properly
allocate
resources
and
set
priorities
for
its
programs
has
been
widely
recognized
and
documented.
Two
reports,
the
EPA
Science
Advisory
Board's
"
Reducing
Risk:
Setting
Priorities
and
Strategies
for
Environmental
Protection"
and
the
National
Academy
of
Public
Administration's
"
Setting
Priorities,
Getting
Results,
A
New
Direction
for
EPA"
recognize
that
EPA's
ability
to
improve
its
priority
setting
and
resource
allocation
activities
has
been
limited
by
the
lack
of
exposure
data.
By
collecting
the
exposure­
related
data
included
in
the
proposed
IUR
amendments,
II­
10
the
Agency
would
acquire
the
necessary
information
to
improve
identification,
prioritization,
and
chemical
risk
screening
capabilities.

EPA
recognizes
that
production
volume
information,
supplemented
by
relatively
scarce
public
sources
of
information,
generally
is
not
sufficient
for
identifying
chemical
exposures
and
human
risks.

This
recognition
motivates
the
revised
and
more
detailed
data
collection
proposed
under
the
IUR
amendments.
EPA
anticipates
that
the
collection
of
additional
use
and
exposure
information,
when
combined
with
hazard
data,
will
provide
the
means
to
develop
a
better
risk­
based
screening
mechanism
that
will
benefit
workers,
consumers,
the
general
population,
and
the
environment.

The
primary
goal
of
this
rule
is
to
enhance
the
quality
and
quantity
of
information
about
chemical
uses
and
exposures
that
EPA
may
use
to
identify
risks
under
TSCA
and
to
protect
and
inform
the
public.
The
information
proposed
to
be
collected
under
the
IUR
amendments
will
enable
EPA
to
evaluate
the
potential
risks
associated
with
chemical
production
and
use,
and
will
improve
EPA's
consequent
ability
to
conduct
risk
management
activities
(
especially
screening),
in
a
more
comprehensive
and
timely
manner.
It
will
also
enable
EPA
to
be
knowledgeable
about
a
wider
variety
of
chemicals
and
to
be
proactive,
rather
than
reactive,
in
identifying
risks.

B.
Approaches
to
Regulation
and
Options
for
Collecting
Information
This
section
provides
information
on
regulatory
approaches
and
options
considered
for
collecting
information
necessary
to
EPA's
risk
management
programs
under
TSCA.
The
first
subsection
presents
the
approaches
considered
for
implementation
of
the
information
collection.
The
second
subsection
presents
specific
details
on
the
levels
of
information
required
under
different
regulatory
options.

1.
Approaches
to
Regulation
In
the
case
of
a
significant
market
failure,
public
intervention
is
often
required
to
override
the
market
directly
or
to
configure
market
incentives
to
achieve
a
more
socially
efficient
outcome.
Several
alternative
approaches
are
available
to
address
market
failures
and
thereby
correct
the
results
of
environmental
externalities.
These
fall
into
three
broad
categories:
command­
and­
control
approaches,
incentive­
based
strategies,
and
information­
based
remedies.
In
addition,
EPA
may
choose
II­
11
to
take
no
regulatory
action
in
response
to
market
failures,
if
it
is
determined
that
failures
are
not
significant
or
if
costs
of
the
action
overwhelm
benefits.

Command
and
control
approaches
are
the
most
specific
forms
of
regulation.
Command
and
control
approaches
addressing
environmental
problems
include
product
or
process
bans
and
controls,

standards
for
the
manner
in
which
a
chemical
may
be
manufactured
or
used,
and
other
measures
directly
mandated
by
EPA
or
other
environmental
authorities.
Incentive­
based
strategies
seek
to
alter
the
incentives
of
private
sector
market
participants
to
consider
environmental
externalities
in
decision
making.
This
is
accomplished
by
changing
price
or
cost
conditions
related
to
polluting­
or
riskgenerating
activities.
Incentive­
based
strategies
include
charges,
subsidies,
tradeable
permit
systems,

financial
assurance,
and
other
market­
related
mechanisms.
Information­
based
strategies
are
the
third
general
class
of
approaches
for
addressing
environmental
risks
to
human
health
and
the
environment.

These
strategies
seek
to
alter
decisions
indirectly
by
improving
the
information
base
upon
which
those
decisions
are
made.

The
relative
efficacy
of
each
approach
for
addressing
market
failures
depends
on
the
specific
circumstances
surrounding
different
risk
and
pollution
problems.
Sometimes,
outright
product
or
process
bans,
mandatory
exposure
controls,
or
other
direct
interventions
might
best
achieve
the
goal
of
improved
environmental
protection
and
maximizing
net
benefits.
In
others,
economic
incentive­
based
strategies
might
do
better,
especially
when
a
substantial
variation
in
the
costs
of
pollution
control
exists
across
many
sources.

The
issues
of
concern
here
are
best
suited
to
information­
related
remedies,
such
as
the
information
provision
required
by
the
IUR
amendments.
The
other
regulatory
remedies
focus
on
controlling
specific
sources
of
risk,
and
would
normally
come
into
play
after
a
particular
risk
management
problem
has
been
identified.
The
IUR
amendments,
however,
are
focused
on
collecting
data
which
will
allow
EPA
to
identify
instances
of
potential
market
failures
and
environmental
externalities.
Thus,
the
goal
is
to
supplement
EPA's
current
chemical
risk
management
strategies
by
enhancing
the
volume
and
detail
of
information
available
to
EPA
concerning
chemical
characteristics,

uses,
and
exposures.

Clearly,
improved
information
on
chemical
exposure
will
allow
EPA
to
more
effectively
and
accurately
identify
and
initially
assess
the
extent
of
market
failures
and
the
resulting
externalities
II­
12
associated
with
chemical
exposures
and
risks.
In
addition,
information
disseminated
to
chemical
producers,
consumers,
and
the
public
will
help
to
achieve
more
efficient
solutions
to
risk
management
problems
specific
to
their
particular
circumstances.

EPA
also
has
the
option
of
taking
no
regulatory
action.
Under
a
"
no­
action"
approach,
EPA
would
continue
to
rely
on
production
volume
information
and
public
data
sources
to
screen
human
health
and
other
risks.
However,
EPA
believes
that
the
relatively
scarce
body
of
information
currently
available
is
not
sufficient
to
accurately
identify
chemical
exposures
and
risks,
and
hence,
that
some
regulatory
action
is
required.

One
alternative
to
a
mandatory
information
collection
rule
might
be
a
voluntary
survey
approach
under
which
the
added
information
targeted
under
the
IUR
amendments
would
be
collected
on
a
non­
mandatory
basis.
This
would
entail
EPA
sending
a
survey
to
all
or
some
portion
of
chemical
manufacturers
and
allowing
the
manufacturers
to
decide
what
information
to
include
in
the
response.

However,
despite
the
apparent
advantages
of
a
purely
voluntary
data
reporting
program,
the
value
of
the
additional
information
provided
to
EPA
would
be
far
lower
compared
with
a
mandatory
information
collection
program.
In
particular,
no
clear
way
would
exist
to
determine
the
extent
to
which
responses
span
the
entire
universe
of
relevant
chemicals
and
their
uses,
so
data
gaps
of
perhaps
substantial
proportions
would
continue
to
exist.
Moreover,
uncompleted
surveys
might
not
be
random
in
the
sense
that
risks
may
be
higher
for
chemicals
and
uses
for
which
surveys
are
not
returned.

Finally,
EPA
would
not
have
a
systematic
method
to
ensure
quality
control
and
timeliness
of
the
survey
responses.
Because
of
these
shortcomings,
this
voluntary
survey
alternative
is
unlikely
to
produce
the
volume,
scope,
and
detail
of
information
ultimately
required
by
EPA.

2.
Regulatory
Options
­­
Levels
of
Information
Collected
The
Agency
has
considered
various
regulatory
options
that
would
alter
the
scope
of
coverage
under
the
IUR
reporting
requirements.
Three
basic
parameters
for
the
options
are
reporting
thresholds,
exemptions
based
on
type
of
chemical,
and
reporting
cycles.
Within
the
reporting
threshold
parameter,
two
categories
of
reporting
thresholds
are
used
in
the
proposed
IUR
amendments;
the
two
reporting
thresholds
determine
submission
of
facility
and
manufacturing
data
and
submission
of
use
and
exposure
data,
respectively.
The
options
are
summarized
below
and
presented
in
detail
in
Table
II­
2.

Note
that
these
are
the
differences
between
the
options
and
do
not
represent
all
of
the
changes
from
II­
13
the
baseline.
The
first
10
options
are
based
on
different
reporting
thresholds
and
a
four­
year
reporting
cycle.


Option
4
is
the
proposed
Option
and
sets
the
reporting
threshold
at
25,000
pounds
for
facility
and
manufacturing
data
and
100,000
pounds
for
processing
and
use
data.
Manufacturers
of
most
petroleum
streams
will
be
exempt
from
reporting
processing
and
use
information.


Options
1­
3
and
5­
8
vary
the
thresholds
for
both
facility
and
manufacturing
data
and
for
processing
and
use
data.


Option
9
contains
a
staged
threshold
for
processing
and
use
information;
the
threshold
for
the
first
year
of
reporting
is
500,000
pounds
and
for
subsequent
reporting
years
is
100,000
pounds.
This
option
retains
the
25,000
pound
threshold
for
facility
and
manufacturing
information.


Option
10
assumes
the
reporting
thresholds
are
the
same
as
those
in
the
proposed
option,
and
includes
an
exemption
from
all
reporting
requirements
for
site­
limited
petroleum
stream
chemicals
rather
than
the
petroleum
stream
partial
exemption
in
the
proposed
option.


Option
11
requires
the
reporting
thresholds
used
in
Option
4,
but
this
option
examines
the
continued
exemption
of
inorganic
chemicals
under
the
proposed
IUR
amendments.


Options
12­
14
vary
the
reporting
cycle.
Option
12
assumes
a
two
year
reporting
cycle
for
facility
and
manufacturing
information
and
four
years
for
processing
and
use
information.
Option
13
uses
a
two
year
reporting
cycle
for
all
information,
while
Option
14
uses
one­
time
reporting
.
II­
14
Table
II­
2.
Options
for
the
Proposed
IUR
Amendments
Option
#
Thresholds
Reporting
Cycles
New
Exemptions
Facility
and
Manufacturin
g
Information
Processin
g
and
Use
Information
Facility
and
Manufacturin
g
Information
Processin
g
and
Use
Information
Facility
and
Manufacturin
g
Information
Processing
and
Use
Informationa
Proposed
Option
4
25,000
lb
100,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
Alternate
Threshold
Options
1
10,000
lb
10,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
2
25,000
lb
25,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
3
10,000
lb
100,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
5
10,000
lb
500,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
6
25,000
lb
500,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
7
25,000
lb
1,000,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
8
25,000
lb
10,000,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
9
25,000
lb
500,000
lb/
100,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
Reporting
Exemption
Option
10
25,000
lb
100,000
lb
4
yrs.
4
yrs.
Site­
Limited
Petroleum
Streams
11
25,000
lb
100,000
lb
4
yrs.
4
yrs.
Inorganic
Chemicals
­­­­
Partial
Exemption
Chemicals
Reporting
Cycle
Options
12
25,000
lb
100,000
lb
2
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
13
25,000
lb
100,000
lb
2
yrs.
2
yrs.
­­­­
Partial
Exemption
Chemicals
14
25,000
lb
100,000
lb
one­
time
one­
time
­­­­
Partial
Exemption
Chemicals
a
Partial
exemption
chemicals
currently
include
only
petroleum
stream
chemicals.
II­
15
III­
1
CHAPTER
III.
INDUSTRY
COSTS
OF
THE
PROPOSAL
This
chapter
analyzes
the
costs
to
industry
associated
with
the
original
Inventory
Update
Rule
(
IUR)
and
EPA's
proposed
IUR
amendments.
This
chapter
is
organized
as
follows:


Section
A
presents
an
overview
of
the
approach
used
to
determine
industry
costs,
including
the
determination
of
tasks
required
to
comply,
the
development
of
unit
costs
of
compliance,
the
determination
of
the
number
of
forms
and
reports,
and
the
development
of
the
total
costs
of
compliance.


Section
B
discusses
the
costs
associated
with
the
original
IUR,
defined
as
the
"
baseline"
costs.
This
section
also
presents
the
reporting
requirements
and
exemptions
and
the
number
of
submissions
under
the
original
IUR.


Section
C
outlines
the
requirements
and
costs
under
the
proposed
IUR
amendments.
Both
incremental
and
total
costs
for
the
first
and
future
years
of
the
amended
rule
are
presented.
The
incremental
cost
is
defined
as
the
difference
between
the
original
and
proposed
IUR,
and
the
total
cost
is
defined
as
the
overall
cost
of
compliance
to
industry
under
the
amended
IUR
(
the
sum
of
the
baseline
cost
and
incremental
cost).


Section
D
presents
an
overview
of
the
proposed
threshold
and
reporting
cycle
options,
the
estimated
costs
associated
with
each
option,
and
the
sensitivity
analysis.
This
section
also
discusses
issues
of
uncertainty
and
limitations
that
affect
the
quantified
costs.

A.
Overview
and
Methodology
The
general
methodology
employed
for
estimating
the
costs
to
industry
of
the
original
IUR
and
the
proposed
IUR
amendments
is
described
below.
The
expected
costs
include
those
attributable
to
compliance
determination,
rule
familiarization,
preparation
and
submission
of
forms,
and
recordkeeping.

The
following
methodology
was
used:

Step
1:
Identify
the
tasks
that
sites
perform
to
comply
with
reporting
requirements
for
both
the
original
IUR
and
for
the
proposal;

Step
2:
Determine
the
unit
costs
for
all
activities
identified
in
Step
1,
based
on
requirements
for
managerial,
technical,
and
clerical
labor
hours;

Step
3:
Determine
the
number
of
forms
and
reports
filed
under
the
original
IUR
and
the
number
expected
to
be
reported
under
the
proposed
amendments;
and
Step
4:
Determine
the
estimated
total
costs
of
compliance
for
the
original
and
the
amended
IUR
and
calculate
incremental
costs.

1.
Determination
of
Tasks
10
The
burden
of
compliance
determination
for
chemicals
produced
in
quantities
less
than
25,000
pounds
is
assumed
to
be
zero.
Although
chemicals
produced
in
volumes
close
to
this
threshold
may
also
require
staff
time
to
determine
whether
compliance
with
the
rule
is
necessary,
the
cost
associated
with
this
time
is
expected
to
be
minimal,
and
is
therefore
not
considered
in
the
quantified
cost
estimates.
Furthermore,
because
this
is
a
site­
based
cost
rather
than
a
report
or
chemical
cost,
the
number
of
sites
not
captured
would
be
low.

III­
2
Compliance
with
the
original
IUR
and
with
the
proposed
amendments
requires
the
completion
of
certain
steps.
These
steps
can
be
broken
down
into
compliance
determination,
rule
familiarization,
preparation
and
submission
of
reports,
and
recordkeeping.
The
amount
of
effort
(
and
therefore
cost)
required
for
each
of
these
steps
varies
depending
upon
the
type
of
chemical,
company
size,
and
the
variety
of
uses
of
the
chemical.
The
steps
for
compliance
with
the
original
IUR
and
the
proposed
amendments
are
described
below.
A
detailed
comparison
of
the
information
required
under
the
original
rule
with
that
required
under
the
amendments
is
provided
in
Section
A.
5
of
this
chapter.


Compliance
Determination
­­
For
chemicals
produced
at
or
imported
through
a
site,
a
determination
of
the
need
for
compliance
must
be
completed,
by
ascertaining
the
following
information
for
each
chemical
produced
or
imported
at
a
particular
site:
(
1)
does
the
chemical
being
manufactured
or
imported
meet
the
requirements
under
any
exemptions,
(
2)
is
the
annual
production
or
import
volume
above
the
reporting
threshold,
and
(
3)
does
the
site's
parent
company
meet
the
small
business
criteria
as
set
forth
in
the
TSCA
§
8(
a)
Small
Manufacturer
Exemption
Rule
(
40
CFR
704.3)?
10

Rule
Familiarization
­­
Once
the
need
for
compliance
has
been
determined,
sites
must
familiarize
themselves
with
the
rule.
Sites
that
previously
reported
must
become
familiar
with
new
requirements
and
sites
new
to
reporting
must
become
familiar
with
all
requirements.
This
entails
reading
the
rule,
understanding
the
various
reporting
and
administrative
requirements,
and
determining
the
manner
in
which
the
reporting
requirements
will
be
met.
The
proposal
adds
exposure­
related
information
to
the
original
reporting
requirements,
changes
the
reporting
cycle,
and
amends
certain
other
parts
of
the
rule.


Preparation
and
Submission
of
Reports
­­
Once
a
site
has
determined
that
its
chemical
output
must
be
reported
and
has
become
familiar
with
the
rule,
the
required
information
must
be
collected
and
a
Form
U
must
be
completed,
reviewed,
and
submitted
to
EPA.
New
requirements,
including
chemical
use
and
exposure
information,
up­
front
substantiation
for
plant
site
identification
CBI
claims,
and
reassertion
of
previous
CBI
claims,
are
included
in
this
task.


Recordkeeping
­­
Under
the
proposal,
submitters
must
retain
records
for
5
years.
III­
3
2.
Development
of
Unit
Costs
To
calculate
costs
of
compliance
associated
with
these
amendments,
it
is
necessary
to
estimate
both
the
costs
associated
with
original
requirements
and
costs
anticipated
when
the
proposed
IUR
amendments
would
go
into
effect.
Unit
costs
of
reporting
for
both
the
proposed
IUR
amendments
and
the
original
IUR
were
developed
based
on
estimates
of
the
wage
rates
and
labor
requirements,
by
labor
category,
for
various
activities.


Estimates
of
Wage
Rates:
Estimates
for
wage
rates
were
developed
for
clerical,
technical,
and
managerial
staff.
A
more
detailed
description
of
the
analysis
by
which
these
estimates
were
developed
is
presented
below.


Estimates
of
Labor
Hours:
Estimates
of
labor
hours
were
divided
among
clerical,
technical,
and
managerial
staff
for
each
task
described
above.
The
methodology
for
developing
labor
hour
estimates
is
presented
below.
Actual
estimates
are
developed
later
in
this
chapter.

This
section
presents
first
the
estimates
of
wage
rates
for
employment
categories
followed
by
estimates
of
labor
hours
for
each
of
the
listed
activities.
The
labor
hours,
when
combined
with
the
labor
rates,
result
in
an
average
basic
cost
of
information
for
each
activity.
This
analysis
assumes
that
all
industry
compliance
costs
are
incurred
in
the
year
in
which
reporting
occurs.

a.
Estimates
of
Wage
Rates
Standard
wage
rates
for
managerial,
technical,
and
clerical
levels
were
developed
from
information
published
by
the
Bureau
of
Labor
Statistics
(
BLS)
and
an
analysis
adopted
from
the
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313
(
U.
S.
EPA
1997a).
Data
used
to
develop
basic
wage
rates
were
derived
from
1993
salary
information
published
by
BLS
for
all
goods­
producing,
private
industries.
Four
BLS
occupation
categories
were
analyzed:
Engineers,
Accountants,
Attorneys,
and
Secretaries.

As
presented
in
Table
III­
1,
the
managerial
and
technical
level
composite
salaries
used
for
the
analysis
are
composites
of
the
BLS
average
salaries
for
several
occupation
categories
and
levels.

Weighting
factors
were
applied
to
the
average
salaries
for
each
of
the
occupation
categories
within
the
managerial
and
technical
labor
categories
to
develop
the
composite
salary.
The
weighting
factors
were
based
on
information
provided
by
the
chemical
industry
and
chemical
industry
trade
associations
for
the
typical
fraction
of
total
reporting
effort
that
is
accounted
for
by
each
specific
BLS
occupation
category
(
U.
S.
EPA
1997a).
III­
4
The
1993
composite
annual
salary
estimates
were
adjusted
to
first­
quarter
1997
dollars
using
the
Employment
Cost
Index
(
ECI)
for
white­
collar
occupations
in
private
industries.
The
1997
adjusted,

composite
salaries
for
the
managerial,
technical,
and
clerical
labor
categories
were
then
multiplied
by
benefits
and
overhead
factors
to
estimate
1997
loaded,
annual
salaries.
Detailed
benefits
data
for
white­
collar
occupations
in
private,
goods­
producing
industries
were
used
to
account
for
the
additional
cost
of
benefits
for
managerial,
technical,
and
clerical
labor.
The
overhead
factor
of
17
percent
is
based
on
information
provided
by
the
chemical
industry
and
chemical
industry
trade
associations.
The
loaded
annual
salary
was
then
divided
by
2,080
hours
(
i.
e.,
the
average
annual
number
of
hours
worked
per
year
by
a
full­
time
employee)
to
derive
the
loaded,
hourly
wage
rates
used
in
this
analysis
for
each
labor
category.

Table
III­
1.
Loaded
Hourly
Wage
Rates
by
Labor
Category
Labor
Category
Occupation
(
levels)
Average
Salary
($
1993)
Weightin
g
Factor
Comp.
Salarya
($
1993)
ECI
Ratio
6/
93:
3/
9
7b
Adjuste
d
Salary
($
1997)
1997
Benefits
(%
Salary)
1997
Overhead
(%
Salary)
Loaded
Annual
Salary
($
1997)
Loaded
Hourly
Rate
($
1997)

Managerial
Engineer
(
6­
8)
$
93,981
10/
17
$
55,28
3
Attorney
(
4­
6)
$
111,263
5/
17
$
32,72
4
Account
(
5­
6)
$
73,528
2/
17
$
8,650
Composite
17/
17
$
96,65
8
1.136
$
109,803
37.6
17.0
$
169,756
$
81.61
Technical
Engineer
(
3­
8)
$
74,802
5/
6
$
62,33
5
Account.(
3­
6)
$
59,436
1/
6
$
9,906
Composite
6/
6
$
72,24
1
1.11
$
80,188
37.4
17.0
$
123,810
$
59.52
Clerical
Sec.
(
1­
5)
$
28,850
1/
1
$
28,85
0
Composite
1/
1
$
28,85
0
1.12
$
32,312
39.6
17.0
$
50,601
$
24.33
a
1993
Composite
Salaries
are
determined
by
multiplying
average
salaries
by
the
weighting
factor
and
summing
across
occupations.
b
The
ECI
ratio
measures
the
percent
change
in
wages,
salaries
and
employee
benefits
between
June
1993
and
March
1997,
controlling
for
inflation.

Sources:
U.
S.
EPA
1997a,
BLS
1997.
III­
5
b.
Methodology
for
Estimates
of
Labor
Hours
and
Associated
Costs
Estimates
of
the
industry
reporting
burden
developed
for
compliance
determination,
rule
familiarization,
report
preparation
and
submission,
and
recordkeeping
were
based
on
previously
prepared
economic
analyses
and
new
EPA
estimates.
New
estimates
were
developed
in
cases
where
previously
prepared
data
did
not
accurately
reflect
the
specific
reporting
requirements
contained
in
the
proposal.
The
procedures
used
to
develop
the
industry
reporting
burden
estimates
are
as
follows:


review
comparable
reporting
requirements
for
other
rules;


develop
assumptions
concerning
the
relationship
between
previous
industry
reporting
burden
estimates
and
the
IUR
amendments
reporting
requirements
and
adjust
the
estimates
accordingly;


develop
new
estimates
as
necessary;
and

present
the
total
burden
estimates
(
by
staff
level)
for
each
task
associated
with
the
proposed
and
original
reporting
requirements.
Note
that
the
analysis
of
burden
is
segmented
between
organic
chemicals,
partially
exempt
chemicals,
and
inorganic
chemicals
to
indicate
the
differential
impact
of
the
changes
to
the
IUR
on
the
reporting
requirements
for
each
chemical
type
and
production
level
threshold.

3.
Determination
of
Number
of
Forms
and
Reports
Currently,
about
8,800
chemicals
are
reportable
under
the
original
Inventory
Update
Rule
(
CUS
Database
1997).
In
1994,
more
than
25,000
submissions
were
received
during
the
IUR
reporting
cycle.
The
reporting
instrument
for
the
IUR
is
the
Form
U.
Each
reporting
site
files
one
Form
U,
regardless
of
the
number
of
reportable
chemicals
it
manufactures
or
imports.
Information
such
as
site
and
company
identification
are
common
to
all
chemicals
produced
at
a
single
site,
and
therefore
this
information
need
only
be
reported
one
time
on
Form
U.
Contained
within
the
Form
U
are
any
number
of
individual
chemical
reports.
The
site
prepares
a
report
for
each
subject
chemical
produced
at
or
imported
through
the
site.
If
there
are
multiple
chemicals
produced
at
a
single
site,
multiple
reports
are
prepared,
and
the
reports
are
submitted
together
on
one
Form
U.
EPA
therefore
estimated
some
costs
on
a
per
report
basis
and
some
on
a
per
site
basis.
Per
report
costs
are
those
costs
which
are
incurred
through
completion
of
the
individual
reports
for
each
reportable
chemical.
Per
site
costs
are
those
which
are
incurred
one
time
for
each
site
through
completion
of
the
Form
U.
III­
6
Costs
associated
with
rule
compliance
are
either
site­
or
report­
based.
Each
site
must
determine
whether
it
must
comply
with
the
IUR
and
then
must
familiarize
itself
with
the
requirements
of
the
rules.
The
costs
associated
with
these
tasks
are
calculated
as
per
site.
For
each
reportable
chemical,
a
report
must
be
prepared
and
submitted
and
a
record
of
it
must
be
kept,
therefore
the
costs
associated
with
these
tasks
are
calculated
as
per
report.

Estimates
of
the
total
number
of
reports
expected
under
the
proposed
IUR
Amendments
were
determined
using
data
complied
from
EPA's
Chemical
Update
System
(
CUS)
and
EPA's
Chemicals
in
Commerce
Information
System
(
CICIS).
The
CUS
databases
contain
information
collected
under
the
IUR
for
the
1986,
1990,
and
1994
reporting
cycles,
and
were
used
to
generate
estimates
of
expected
reports
for
organic
chemicals
and
petroleum
stream
chemicals.
The
CICIS
database
was
used
to
determine
the
number
of
inorganic
chemicals
likely
to
be
reported,
because
these
chemicals
are
currently
exempt
and
therefore
are
not
included
in
the
CUS.
The
CICIS
contains
information
collected
by
EPA
on
TSCA
chemicals
in
commerce
in
the
United
States
in
1977,
including
company
and
chemical
identification,
site
location,
manufactured
or
imported
status,
and
production
volume
in
ranges.
Appendix
C
contains
a
detailed
description
of
the
analysis
used
to
determine
the
expected
number
of
reports
under
the
proposed
amendments.

4.
Determination
of
Total
Costs
of
Compliance
The
total
industry
cost
of
reporting
under
both
the
original
IUR
and
proposed
amendments
is
calculated
by
first
determining
the
unit
cost
for
each
task
involved
in
reporting
and
then
multiplying
those
unit
costs
by
the
number
of
occurrences
(
i.
e,
reporting
forms
submitted
or
number
of
sites
submitting
reporting
forms
under
the
IUR).
The
costs
associated
with
reporting
under
both
the
original
IUR
and
proposed
amendments
consist
of
(
1)
compliance
determination,
(
2)
rule
familiarization,

(
3)
preparation
and
submission
of
reports,
including
CBI
determination
and
substantiation,
and
(
4)

recordkeeping.

5.
Development
of
Burden
Estimates
The
baseline,
total,
and
incremental
costs
of
the
IUR
were
developed
through
an
analysis
and
comparison
of
the
type
of
information
required
for
compliance
with
both
the
original
and
11
These
data
elements
are
discussed
in
more
detail
in
Chapter
I,
Section
B.

12
The
contents,
administration,
and
results
of
the
survey
are
described
in
detail
in
Appendix
D.

III­
7
amended
rule,
as
detailed
in
Box
III­
1.11
The
time
required
by
industry
to
prepare
and
submit
information
for
each
of
these
data
elements
provides
a
basis
for
determining
the
total
cost
of
reporting.

To
examine
this
issue,
the
Agency
developed
a
survey
to
assess
the
labor
hours
required
to
complete
each
section
of
the
proposed
Form
U.
The
survey
was
administered
to
81
chemical
manufacturers
in
the
spring/
summer
of
1996.12
Table
III­
2
presents
the
estimates
of
reporting
burden
for
each
section
of
the
revised
Form
U
(
see
Appendix
A)
as
determined
from
the
survey
(
see
Appendix
D).
Requirements
of
the
original
Form
U
are
represented
by
the
shaded
areas
of
the
table.
The
unshaded
portion
of
Table
III­
2
represents
the
parts
of
Form
U
added
by
the
proposal.
For
chemicals
produced
between
25,000
and
100,000
pounds
and
for
chemicals
meeting
the
partial
exemptions,
only
sections
I,
II,
and
IV
of
the
revised
Form
U
would
be
completed.
III­
8
Box
III­
1.
Comparison
of
Data
Elements
for
Completion
of
the
Original
and
Amended
Form
U
Baseline
Data
Elements
Additions
from
Proposal
Certification

signature

date

name
and
title
of
the
representative
responsible
for
the
accuracy
of
the
information
provided.

Company
Information

technical
company
name

contact
name

company
street
address

telephone
number
Plant
Site
Identification

plant
site
name

Dun
&
Bradstreet
Number

plant
site
street
address
Chemical
Specific
Information

CAS
Number
or
other
identifying
number

ID
code

chemical
name

site­
limited
status
(
yes
or
no)


activity
(
manufacturing
or
import)


production
volume
Confidential
Business
Information

up­
front
substantiation
for
chemical
identity
CBI
claims

substantiation
of
CBI
claims
in
the
event
of
a
Freedom
of
Information
Act
(
FOIA)
request
III­
9
Table
III­
2.
Estimate
of
Industry
Reporting
Burden
for
Sections
of
Revised
Form
U
(
hours)

Task
Clerical
Hours
Technical
Hours
Managerial
Hours
I.
Facility
Identification
Informationa
0.57
­
1.03
0.95
­
1.03
1.03
­
1.10
1.
Certification
0.46
­
0.89
0.81
­
0.89
0.97
­
1.05
2.
Company
Information
Company
Name,
Contact,
Address
0.03
­
0.04
0.04
­
0.04
0.02
­
0.02
D
&
B
Number,
Mailing
Address
3.
Plant
Site
Identification
0.08
­
0.10
0.10
­
0.11
0.04
­
0.04
Plant
Name,
D
&
B
Number,
Address
EPA
ID
Number,
Mailing
Address
II.
Manufacturing
Information
1.36
­
1.41
6.03
­
9.63
1.79
­
4.68
1.
Chemical
Identification
2.
Site
Limited
0.49
­
0.55
1.97
­
2.59
0.28
­
0.84
3.
Activity

4.
Production
Volume
(
lbs)

5.
Chemical
Identification
Up­
front
CBI
Substantiation
0.26
­
0.26
1.08
­
1.82
0.48
­
1.05
6.
Plant
Site
Up­
front
CBI
Substantiation
0.12
­
0.12
0.54
­
1.12
0.23
­
0.79
7.
Production
Volume
Range
CBI
0.14
­
0.14
0.49
­
1.09
0.24
­
0.85
8.
Total
Number
of
Workers
0.21
­
0.21
1.13
­
1.73
0.29
­
0.88
9.
Physical
Stateb
­­
­­
­­
10.
Maximum
Concentration
0.14
­
0.14
0.82
­
1.28
0.27
­
0.27
III.
Processing
and
Use
Information
3.29
­
3.43
21.11
­
23.12
6.08
­
6.48
A.
Industrial
Processing
and
Use
Exposure
Related
Data
2.58
­
2.72
16.22
­
17.69
4.61
­
4.89
1.
Determination
of
Applicability
0.21
­
0.21
1.71
­
1.83
0.45
­
0.45
2.
Process
and
Use
Codec
­­
­­
­­
3.
5­
Digit
NAICS
Coded
0.33
­
0.39
2.17
­
2.32
0.61
­
0.61
4.
Function
Code
0.35
­
0.35
1.53
­
1.72
0.77
­
0.79
5.
Percent
Production
Volume
0.45
­
0.45
3.34
­
3.63
0.81
­
0.95
6.
Total
number
of
processing
and
use
sites
0.54
­
0.60
2.85
­
3.22
0.88
­
0.91
7.
Total
number
of
potentially
exposed
workers
0.71
­
0.73
4.64
­
4.97
1.09
­
1.17
B.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
0.71
­
0.71
4.89
­
5.43
1.47
­
1.59
1.
Determination
of
Applicability
0.17
­
0.17
1.07
­
1.13
0.28
­
0.31
2.
Identification
of
end­
use
0.17
­
0.17
0.92
­
1.05
0.28
­
0.30
3.
Percent
production
volume
0.24
­
0.24
1.40
­
1.56
0.51
­
0.55
4.
Estimated
weight
percent
in
consumer
0.13
­
0.13
1.51
­
1.69
0.39
­
0.42
IV.
Reassertion
of
Past
CBI
Claimse
0.50
­
1.00
1.00
­
2.00
2.00
­
4.00
Note:
1.
Shaded
area
represents
original
requirements;
the
unshaded
area
represents
the
proposed
additional
requirements.
2.
The
sum
of
the
components
under
a
particular
information
category
may
not
add
due
to
rounding.
a
The
burden
associated
with
determining
Facility
Identification
Information
has
been
adjusted
to
account
for
the
additional
information
required
under
the
proposed
amendments.
The
baseline
burden
associated
with
providing
Facility
Identification
Information
is
presented
in
Table
III­
5.
b
The
burden
associated
with
determining
the
physical
state
of
manufactured
chemicals
was
subsumed
under
the
task
of
determining
chemical
identification
(
Task
II(
1))
in
the
industry
survey.
c
The
burden
associated
with
determining
the
Process
and
Use
Code
was
subsumed
under
the
task
of
determining
the
total
number
of
processing
and
use
sites
and
potentially
exposed
workers
(
Tasks
III(
I.
e)
and
(
I.
f))
in
the
industry
survey.
d
The
SIC
system
has
recently
been
replaced
with
the
North
American
Industry
Classification
System
(
NAICS).
The
IUR
survey
and
the
cost
information
developed
in
this
report
are
based
on
requirements
for
providing
SIC
information.
For
purposes
of
this
analysis,
it
has
been
assumed
that
the
burden
associated
with
providing
an
NAICS
identification
number
would
be
the
same
as
for
providing
an
SIC
code.
e
See
discussion
in
Section
C.
3.
b.
Sources:
U.
S.
EPA
1994,
Appendix
D.
III­
10
Survey
respondents
provided
low
and
high
estimates
of
labor
hours
required
to
complete
each
task
for
each
of
three
staff
levels.
These
estimates
were
then
weighted,
based
on
company
size,
to
provide
an
average
low
and
high
burden
estimate
that
would
reflect
the
range
of
companies
expected
to
report
under
the
proposed
amendments.
The
estimates
in
Table
III­
2
are
the
foundation
of
the
estimates
of
baseline,
total,
and
incremental
costs
of
the
proposal.
These
costs
are
presented
in
Sections
B
and
C
of
this
chapter.
A
sensitivity
analysis
is
discussed
in
Section
D.

B.
Baseline
Costs
of
Compliance
The
costs
of
compliance
under
the
original
IUR
requirements
are
estimated
in
this
section.

Original
reporting
requirements,
exemptions,
and
number
of
submissions
received
are
presented.

Industry
baseline
costs
by
category
for
compliance
with
the
requirements
of
the
rule
are
determined.

Compliance
determination
(
per
site),
rule
familiarization
(
per
site),
report
preparation
and
submission
(
per
report),
and
recordkeeping
(
per
report)
costs
are
presented.
These
costs
are
then
combined
with
the
numbers
of
reports
and
sites
to
estimate
the
per
year,
net
present
value,
and
annual
baseline
costs
by
chemical
type
(
i.
e.,
organic,
inorganic,
and
partial
exemption
chemicals).

1.
Original
Inventory
Update
Rule
Requirements
The
original
IUR
requires
chemical
manufacturers
and
importers
to
submit
information
on
certain
chemical
substances
listed
on
the
TSCA
Chemical
Substances
Inventory.
Companies
must
submit
a
report
every
four
years
and
maintain
records
that
support
their
submission
for
four
years
following
the
reporting
year.
The
requirements
and
exemptions
of
the
original
IUR
are
detailed
below.

a.
Original
Reporting
Requirements
The
IUR
requires
manufacturers
and
importers
of
subject
chemicals
to
report
data
on
production
volume,
plant
site
and
chemical
identification,
and
site­
limited
status
for
the
subject
chemicals.
These
data
are
reported
on
a
four
year
reporting
cycle
and
should
reflect
manufacturing
and
importing
activities
over
the
last
complete
corporate
fiscal
year
preceding
the
reporting
year.

b.
Original
Exemptions
The
TSCA
Inventory
includes
approximately
75,000
substances,
but
exemptions
and
reporting
thresholds
reduce
the
number
of
TSCA
chemicals
reportable
under
the
III­
11
original
IUR
to
about
8,800
discrete
chemicals.
The
specific
exemptions
to
the
original
IUR
are
briefly
described
below.

i.
Low­
Volume
Threshold
Exemption
Chemicals
produced
at
a
manufacturing
site
in
a
volume
less
than
10,000
pounds
during
the
last
corporate
fiscal
year
preceding
the
reporting
period
are
exempt
from
reporting
under
the
original
IUR.
This
reporting
threshold
applies
equally
to
importers
and
refers
to
a
single
site
that
contains
an
operating
unit
responsible
for
the
import.

ii.
Small
Business
Exemption
Small
businesses,
as
defined
by
TSCA
§
8(
a),
are
exempt
from
reporting
under
the
original
IUR
requirements.
Small
businesses
are
those
whose
annual
sales
are
less
than
$
40
million
and
whose
annual
production
volume
is
less
than
100,000
pounds.
The
annual
sales
level
is
for
the
overall
parent
company
and
the
production
volume
is
site­
specific.
Any
company
with
annual
sales
less
than
or
equal
to
$
4
million
is
considered
to
be
a
small
business
regardless
of
production
volume.

iii.
Chemical
Substance
Exemption
Certain
chemical
substances
are
exempt
from
the
original
IUR
requirements.
These
substances
include
polymers,
microorganisms,
naturally
occurring
substances,

and
inorganic
chemicals.
Chemicals
falling
into
these
categories
are
not
required
to
be
reported,

regardless
of
production
volume
or
small
business
status.

c.
Number
of
Submissions
The
number
of
submissions
received
under
the
original
IUR
requirements
has
hovered
around
25,000
for
each
of
the
three
reporting
periods
(
i.
e.,
1986,
1990,
and
1994).
The
number
of
discrete
chemicals
reported
during
a
single
reporting
period
increased
by
3.4
percent
between
1986
and
1990,
but
the
number
reported
in
1994
was
6.7
percent
fewer
than
the
number
reported
in
1990.
Averaging
the
information
from
these
three
reporting
periods,
25,614
reports
were
13
It
should
be
noted
that
the
numbers
of
reports
and
sites
presented
above
include
statistics
for
chemicals
with
a
production
volume
lower
than
10,000
pounds
that
reported
voluntarily.

14
Note
that
the
analysis
of
burden
is
segmented
between
organic
chemicals,
partial
exemption
chemicals,
and
inorganic
chemicals,
to
indicate
the
differential
impact
of
the
amendments
to
the
IUR
on
the
reporting
requirements
for
each
chemical
type.

15
Costs
were
translated
between
per
site
and
per
report
using
the
average
of
8.4
reports
per
site
for
the
1994
CUS
reporting
period.
This
average
was
calculated
based
on
the
25,058
reports
filed
from
2,981
sites
in
the
1994
reporting
period
(
these
numbers
include
chemicals
with
a
production
volume
lower
than
10,000
pounds
that
reported
voluntarily).

III­
12
filed
from
2,894
sites.
These
statistics
produce
an
average
of
about
8.85
reports
per
site
for
the
original
IUR.
13
2.
Industry
Baseline
Costs
The
costs
of
reporting
under
the
original
IUR
are
defined
as
the
"
baseline"
costs.
These
costs
consist
of
the
four
steps
for
compliance
with
the
requirements
of
the
rule,
as
defined
above:
(
1)

compliance
determination,
(
2)
rule
familiarization,
(
3)
preparation
and
submission
of
reports,
including
CBI
determination
and
substantiation,
and
(
4)
recordkeeping.

Costs
associated
with
compliance
determination
and
rule
familiarization
are
incurred
by
each
site,
regardless
of
the
number
of
reports
submitted.
Costs
for
preparation
and
submission
of
reports,
as
well
as
recordkeeping
costs,
are
incurred
separately
for
each
report
that
is
submitted.
The
original
reporting
form,
the
Form
U,
may
consist
of
a
number
of
individual
chemical
reports
from
one
submitter
site
(
see
discussion
in
Section
A.
3
above).
Table
III­
3
presents
the
baseline
burden14
of
compliance
determination
per
site
of
between
one
and
four
technical
staff
hours
for
organic
and
partial
exemption
chemicals.
These
burden
estimates
are
presented
as
a
range
to
reflect
the
variation
in
the
reporting
community.
Sites
that
produce
fewer
chemicals
may
only
need
one
hour
to
determine
compliance,

while
sites
that
produce
numerous
chemicals
may
require
up
to
four
hours
(
U.
S.
EPA
1990).
The
baseline
cost
of
compliance
determination
is
between
$
59.52
and
$
238.08
per
site,
and
between
$
7.09
and
$
28.34
per
report
for
organic
and
partial
exemption
chemicals.
15
Inorganic
chemicals
are
not
required
to
report
under
the
original
IUR,
and
therefore
the
baseline
burden
and
cost
of
all
reporting
requirements
is
zero
for
this
chemical
type.
Table
III­
4
presents
the
baseline
burden
of
rule
familiarization
per
site
of
two
technical
and
two
managerial
staff
hours
for
organic
chemicals
and
partial
III­
13
exemption
chemicals.
The
total
cost
of
rule
familiarization
is
$
282.26
per
site,
and
$
33.60
per
report,

for
organic
and
partial
exemption
chemicals.
III­
14
Table
III­
3.
Baseline
Cost
of
Compliance
Determination
(
1997$)

Type
of
Chemical
Clerical
($
24.33/
hr)
Technical
($
59.52/
hr)
Managerial
($
81.61/
hr)

Low
High
Low
High
Low
High
Organic
Chemicals
and
Partial
Exemption
Chemicals
Burden
per
Site
(
hours)
0
0
1
4
0
0
Cost
per
Site
($)
$
0
$
0
$
59.52
$
238.08
$
0
$
0
Total
Cost
for
Compliance
Determination
Per
Site
$
59.52
­
$
238.08
Per
Reporta
$
7.09
­
$
28.34
Inorganic
Chemicals
Burden
per
Site
(
hours)
0
0
0
0
0
0
Cost
per
Site
($)
$
0
$
0
$
0
$
0
$
0
$
0
Total
Cost
for
Compliance
Determination
Per
Site
$
0
Per
Reporta
$
0
a
Assumes
an
average
of
8.4
reports
per
site
(
CUS
Database
1997).
III­
15
Table
III­
4.
Baseline
Cost
of
Rule
Familiarization
(
1997$)

Type
of
Chemical
Clerical
($
24.33/
hr)
Technical
($
59.52/
hr)
Managerial
($
81.61/
hr)

Low
High
Low
High
Low
High
Organic
Chemicals
and
Partial
Exemption
Chemicals
Burden
per
Site
(
hours)
0
0
2
2
2
2
Cost
per
Site
($)
$
0
$
0
$
119.04
$
119.0
4
$
163.22
$
163.22
Total
Cost
for
Rule
Familiarization
Per
Site
$
282.26
Per
Reporta
$
33.60
Inorganic
Chemicals
Burden
per
Site
(
hours)
0
0
0
0
0
0
Cost
per
Site
($)
$
0
$
0
$
0
$
0
$
0
$
0
Total
Cost
for
Rule
Familiarization
Per
Site
$
0
Per
Reporta
$
0
16
The
original
Form
U
does
not
include
Sections
III
and
IV,
and
therefore
the
baseline
burden
for
these
categories
is
zero.

III­
16
a
Assumes
an
average
of
8.4
reports
per
site
(
CUS
Database
1997).
Table
III­
5
presents
the
cost
of
report
preparation
and
submission
for
the
original
IUR.
As
the
table
indicates,
burden
is
distributed
by
labor
category
among
the
four
sections
of
the
proposed
Form
U.
16
The
total
cost
is
estimated
to
be
between
$
412
and
$
605
per
report,
and
between
$
3,460
and
$
5,079
per
site.
It
should
be
noted
that
the
baseline
burden
estimates
for
Facility
Identification
Information
are
not
equivalent
to
those
presented
in
Table
III­
2,
because
of
the
difference
in
the
number
of
reports
per
Form
U
under
the
baseline
versus
the
amendments,
and
because
of
adjustments
made
to
account
for
the
additional
information
required
under
the
amended
IUR.

Table
III­
5.
Baseline
Cost
of
Report
Preparation
and
Submissiona
(
1997$)

Clerical
($
24.33/
hr)
Technical
($
59.52/
hr)
Managerial
($
81.61/
hr)

Low
High
Low
High
Low
High
Reporting
Form
Section
(
Hours)

I.
Facility
ID
0.40
0.73
0.94
1.02
1.02
1.10
II.
Manufacturing
Information
0.75
0.81
3.05
4.41
0.77
1.89
III
.
Use
and
Exposure
Information
0
0
0
0
0
0
IV
.
CBI
Reassertion
0
0
0
0
0
0
Total
Hours
per
Report
1.15
1.54
3.99
5.43
1.79
2.99
Costs
per
Report
$
28.10
$
37.45
$
237.70
$
323.12
$
146.09
$
244.12
Total
Cost
for
Report
Preparation
and
Submission
Per
Report
$
411.89
­
$
604.68
Per
Siteb
$
3,460
­
$
5,079
a
For
sites
reporting
under
the
original
IUR.
b
Assumes
an
average
of
8.4
reports
per
site
(
CUS
Database
1997).
Source:
Table
III­
1
and
Table
III­
2.
III­
17
Table
III­
6
presents
the
per
report
recordkeeping
burden
for
the
original
IUR.
Estimated
burden
is
between
one
half
hour
and
one
hour
of
clerical
staff
time,
one
and
two
hours
of
technical
staff
time,

and
one
half
hour
and
one
hour
of
managerial
staff
time.
Total
cost
of
recordkeeping
is
between
$
112
and
$
225
per
report,
and
between
$
945
and
$
1,890
per
site.

Table
III­
6.
Baseline
Cost
of
Recordkeeping
(
1997$)

Type
of
Chemical
Clerical
($
24.33/
hr)
Technical
($
59.52/
hr)
Managerial
($
81.61/
hr)

Low
High
Low
High
Low
High
Organic
Chemicals
and
Partial
Exemption
Chemicals
Burden
per
Report
(
hours)
0.5
1
1
2
0.5
1
Cost
per
Report
($)
$
12.16
$
24.33
$
59.52
$
119.0
4
$
40.80
$
81.61
Total
Cost
for
Recordkeeping
Per
Report
$
112.48
­
$
224.98
Per
Sitea
$
945
­
$
1,890
Inorganic
Chemicals
Burden
per
Report
(
hours)
0
0
0
0
0
0
Cost
per
Report
($)
$
0
$
0
$
0
$
0
$
0
$
0
Total
Cost
for
Recordkeeping
Per
Report
$
0
Per
Sitea
$
0
a
Assumes
an
average
of
8.4
reports
per
site
(
CUS
Database
1997).
Source:
U.
S.
EPA
1994,
U.
S.
EPA
1997a.

The
total
cost
of
compliance
is
estimated
by
summing
the
costs
of
individual
compliance
determination,
rule
familiarization,
report
preparation
and
submission,
and
recordkeeping
activities.

The
baseline
total
cost
is
between
$
565
and
$
892
per
report,
and
between
$
4,700
and
$
7,500
per
site
(
on
average).
These
costs
are
presented
in
Table
III­
7.
17
An
average
of
25,614
submissions
were
received
during
the
1986,
1990,
and
1994
reporting
periods.
This
total
includes
some
reports
for
chemicals
produced
below
10,000
pounds,
which
some
companies
voluntarily
submitted.
Removing
reports
for
chemical
submissions
that
do
not
meet
the
10,000
pound
threshold
results
in
an
estimate
of
25,324
reports
for
future
reporting
periods.
This
average
estimate
is
comparable
to
the
number
of
submissions
(
24,774)
received
under
the
1994
reporting
period,
indicating
that
the
CUS
1994
data
are
a
reasonable
source
for
determining
the
total
industry
baseline
cost.

III­
18
Table
III­
7.
Baseline
Cost
of
Compliance
(
1997$)

Compliance
Task
Per
Report
Per
Sitea
Low
High
Low
High
Compliance
Determination
$
7
$
28
$
60
$
238
Rule
Familiarization
$
34
$
282
Report
Preparation
and
Submission
$
412
$
605
$
3,46
0
$
5,07
9
Recordkeeping
$
112
$
225
$
945
$
1,89
0
Total
$
565
$
892
$
4,74
7
$
7,48
9
a
Assumes
an
average
of
8.4
reports
per
site
(
CUS
Database
1997).
Source:
Tables
III­
3,
III­
4,
III­
5,
and
III­
6.

The
total
industry
baseline
cost
associated
with
the
original
IUR
requirements
has
been
calculated
based
on
the
number
of
submissions
(
24,774)
received
during
the
1994
reporting
period.
17
Based
on
this
number
of
reports,
Table
III­
8
presents
first
year
baseline
costs
by
chemical
type
and
production
volume
category.
The
total
baseline
industry
cost
for
the
1998
reporting
period
is
expected
to
be
between
$
13.9
million
and
$
21.9
million,
as
presented
in
Table
III­
9.
The
annualized
cost
of
reporting
under
the
original
IUR
is
estimated
to
be
$
4.3
million
to
$
6.8
million,
and
the
net
present
value
for
reporting
under
the
original
IUR
over
a
20­
year
period
is
estimated
to
be
between
$
63.7
million
and
$
100.5
million.

Because
the
benefits
resulting
from
the
proposed
regulation
will
not
occur
simultaneously
with
the
costs,
it
is
necessary
to
discount
the
future
streams
of
costs
and
benefits
before
comparing
them.

The
time
horizon
over
which
costs
and
benefits
are
discounted
in
this
analysis
is
20
years.
A
3
percent
discount
rate
is
used
in
this
chapter,
and
the
results
of
an
analysis
using
a
7
percent
discount
rate
are
presented
in
Appendix
E
for
comparison.
There
is
considerable
debate
in
the
economics
discipline
18
Further
discussion
of
the
approach
used
to
develop
the
appropriate
discount
rate
is
presented
in
Appendix
E.

III­
19
whether
to
use
the
social
rate
of
time
preference
or
the
rate
of
return
on
investment
when
discounting.

The
debate
between
using
a
rate
of
return
on
investment
capital
and
the
consumption
rate
of
return
focuses
on
whether
investment
or
consumption
is
being
displaced.
The
issues
involving
the
appropriate
discount
rates
and
procedures
are
complex,
and
are
not
likely
to
be
resolved
soon.
Much
of
the
recent
economic
literature
summarizing
the
discounting
debate
concludes
that
it
is
appropriate
to
use
either
the
social
rate
of
time
preference
or
the
rate
of
return
on
investments;
there
is
not
much
difference
between
the
rates.
For
example,
Moore
and
Viscusi
(
1990)
find
no
evidence
that
the
rate
of
time
preference
for
environmental­
related
health
effects
differs
from
financial
rates
of
return
and
cite
evidence
that
a
2
percent
rate
is
appropriate.
Lind
(
1990)
recommends
a
range
of
one
to
3
percent,
and
Freeman
(
1993)

recommends
2
to
3
percent.
Based
on
this
information,
this
analysis
uses
a
3
percent
discount
rate.
18
Table
III­
8.
Annual
Baseline
Cost
by
Production
Volume
Category
(
1997$)
a
Type
of
Chemical
Reports
with
Production
Volumes
10K
­
25K
lbs.
Reports
with
Production
Volumes
25K
­
100K
lbs.
Reports
with
Production
Volumes
>
100K
lbs.

Low
High
Low
High
Low
High
Organic
Chemicals
$
1,521,23
1
$
2,406,83
2
$
2,296,26
7
$
3,633,06
4
$
10,090,52
7
$
15,910,07
6
Partial
Exemption
$
0
$
0
$
0
$
0
$
0
$
0
Inorganic
Chemicals
$
0
$
0
$
0
$
0
$
0
$
0
Total
$
1,521,23
$
2,406,83
$
2,296,26
$
3,633,06
$
10,090,52
$
15,910,07
a
Costs
are
incurred
only
in
the
reporting
year
(
i.
e.,
every
four
years).
III­
20
Table
III­
9.
Baseline
First
Year,
Net
Present
Value,
and
Annualized
Costs
According
to
Chemical
Type,
Discounted
at
3
Percent
(
million
1997$)

Type
of
Chemical
First
Year
Cost
Net
Present
Value
Annualized
Cost
Low
High
Low
High
Low
High
Organic
Chemicals
$
13.9
$
21.9
$
63.7
$
100.5
$
4.3
$
6.8
Partial
Exemption
$
0
$
0
$
0
$
0
$
0
$
0
Inorganic
Chemicals
$
0
$
0
$
0
$
0
$
0
$
0
Total
$
13.9
$
21.9
$
63.7
$
100.5
$
4.3
$
6.8
C.
Costs
of
the
Proposed
Amendments
The
costs
of
compliance
under
the
proposed
IUR
amendments
are
estimated
in
this
section.

Unit
costs
are
presented
based
on
the
four
steps
for
compliance
(
see
Section
A.
1):
compliance
determination;
rule
familiarization;
report
preparation
and
submission;
and
recordkeeping.
Costs
per
site
and
per
report
are
estimated,
followed
by
discussions
of
the
number
of
reports
and
sites
under
the
proposed
IUR
amendments.
Unit
costs
are
then
multiplied
by
the
number
of
reports
and
sites
to
estimate
the
first
year
costs,
net
present
value,
and
annual
costs
by
chemical
type.

Under
the
proposed
amendments,
submitters
of
certain
categories
of
chemicals
complete
a
partial
reporting
form,
reporting
only
the
facility
and
manufacturing
information
and
completing
the
reassertion
of
past
CBI
claims.
These
categories
of
chemicals
are
those
with
annual
production
volumes
of
25,000
to
100,000
pounds
and
chemicals
meeting
the
partial
exemption
requirements
(
e.
g.

multiple
chemical
petroleum
stream
chemicals).
The
remaining
chemicals,
with
annual
production
volumes
greater
than
100,000
pounds,
must
complete
the
full
form,
requiring
reporting
of
additional
information
on
industrial
use
and
exposure
and
consumer/
commercial
use.

1.
Costs
of
Compliance
Determination
The
labor
requirements
for
compliance
determination
under
the
amendments
are
the
same
as
the
requirements
under
the
original
IUR.
Essentially,
each
site
incurs
costs
to
determine
whether
compliance
is
necessary.
Therefore,
the
cost
of
compliance
attributable
to
the
amendments,
III­
21
for
those
sites
already
reporting
under
the
original
IUR,
is
zero.
For
sites
not
reporting
under
the
original
IUR
(
such
as
inorganic
chemical
companies),
the
cost
of
compliance
for
a
typical
site
is
between
$
60
and
$
238
for
each
reporting
period.
As
described
in
the
baseline
section,
this
cost
is
derived
from
the
estimated
1
­
4
hours
of
technical
labor
necessary
for
a
compliance
determination,

consisting
of
a
review
of
production
and
import
data
for
all
chemicals.

The
burden
of
compliance
determination
is
estimated
to
remain
constant
for
first
and
future
year
reporting,
given
the
length
of
the
time
lag
between
reporting
cycles
and
the
potential
for
changes
in
a
site's
chemical
output
over
that
time
period.

2.
Costs
of
Rule
Familiarization
Once
a
site
determines
that
reporting
is
required
under
either
the
IUR
or
the
amendments,
it
is
necessary
for
one
or
more
individuals
at
the
site
to
become
familiar
with
the
rule.

Rule
familiarization
entails
reading
the
rule,
understanding
the
various
reporting
and
administrative
requirements,
and
determining
the
manner
in
which
the
reporting
requirements
will
be
met.

EPA
estimates
that
rule
familiarization
for
the
amendments
would
require
between
16
and
18
hours
of
technical
labor
and
6
to
8
hours
of
managerial
labor
in
the
first
year
of
reporting
for
sites
already
reporting
under
the
original
IUR.
For
sites
new
to
reporting
(
such
as
those
reporting
inorganic
chemicals),
EPA
estimates
that
between
18
and
20
hours
of
technical
labor
and
8
to
10
hours
of
managerial
labor
are
required.
These
estimates
are
based
on
EPA's
estimate
that
rule
familiarization
for
TRI
requires
an
average
of
22.5
hours
of
technical
review
and
12
hours
of
managerial
review
(
U.
S.

EPA
1997a).
The
scope
of
the
reporting
requirements
under
the
TRI
program
is
similar
to
the
proposed
IUR
amendments.
However,
the
requirements
under
the
TRI
program
are
more
complicated
and
therefore
the
burden
estimate
for
the
IUR
amendments
should
be
slightly
lower.
It
is
assumed
therefore,
that
the
time
required
for
familiarization
with
the
amended
IUR
will
be
reduced
by
2.5­
4.5
hours
of
technical
time
and
2­
4
hours
of
managerial
time
relative
to
the
estimates
developed
for
rule
familiarization
with
the
TRI
requirements.
19
The
following
tables
categorize
the
burden
and
cost
estimates
for
the
various
compliance
steps
according
to
chemical
type
and
the
type
of
Form
U
completed.
Chemicals
with
production
volumes
less
than
25,000
pounds
are
denoted
by
"
PV<
25K
lbs.,"
chemicals
with
production
volumes
between
25,000
and
100,000
pounds
and
chemicals
meeting
the
partial
exemption
requirements
are
denoted
by
"
Partial
Form,"
and
chemicals
with
production
volumes
greater
than
100,000
pounds
are
denoted
by
"
Full
Form."

III­
22
In
future
reporting
years,
the
burden
of
rule
familiarization
under
the
amendments
is
estimated
to
be
equal
to
the
burden
under
the
original
IUR.
For
sites
currently
reporting,
there
is
no
incremental
burden
associated
with
the
amendments.
For
sites
new
to
reporting,
the
burden
is
estimated
to
be
two
hours
of
technical
labor
and
two
hours
of
managerial
labor.
EPA
has
assumed
that
the
burden
of
rule
familiarization
is
incurred
in
both
first
and
future
reporting
due
to
the
length
of
the
time
between
reporting
cycles.
EPA
recognizes,
however,
that
the
burden
of
familiarization
in
future
years
is
significantly
less
than
the
initial
first
year
burden.

Multiplying
by
the
appropriate
labor
costs,
EPA
estimates
incremental
rule
familiarization
costs
for
the
proposed
amendments
of
$
1,442
to
$
1,724
per
site
in
the
first
year
of
reporting
for
typical
sites
reporting
under
the
original
IUR.
For
those
sites,
and
assuming
an
average
of
8.4
reports
per
site,
rule
familiarization
costs
are
between
$
172
and
$
205
per
report.
For
sites
new
to
reporting,
first
year
costs
of
rule
familiarization
are
slightly
higher.
Those
costs
are
estimated
to
be
between
$
1,724
and
$
2,006
per
site,
or
between
$
205
and
$
239
per
report.
The
incremental
labor
requirements
and
estimated
costs
associated
with
rule
familiarization
are
presented
in
Tables
III­
10
and
III­
11
below.
19
III­
23
Table
III­
10.
Incremental
Burden
Per
Site
of
Rule
Familiarization
(
hours)

Type
of
Chemical
First
Year
Reporting
Future
Year
Reporting
Clerical
Technical
Managerial
Clerical
Technical
Managerial
Lo
Hig
Lo
Hig
Lo
Hig
Lo
Hig
Lo
Hig
Lo
Hig
Organic
and
Partial
Exemption
Chemicals
PV
<
25K
0
0
(
2)
(
2)
(
2)
(
2)
0
0
(
2)
(
2)
(
2)
(
2)

Partial
Form
0
0
16
18
6
8
0
0
0
0
0
0
Full
Form
0
0
16
18
6
8
0
0
0
0
0
0
Inorganic
Chemicals
PV
<
25K
0
0
0
0
0
0
0
0
0
0
0
0
Partial
Form
0
0
18
20
8
10
0
0
2
2
2
2
Full
Form
0
0
18
20
8
10
0
0
2
2
2
2
Source:
U.
S.
EPA
1990
and
U.
S.
EPA
1997a.

Table
III­
11.
Incremental
Costs
of
Rule
Familiarization
(
1997$)

Type
of
Chemical
Per
Site
Cost
Per
Report
Costa
First
Year
Future
Years
First
Year
Future
Years
Low
High
Low
High
Low
High
Low
High
Organic
and
Partial
Exemption
Chemicals
PV
<
25K
($
282)
($
282)
($
282)
($
282)
($
34)
($
34)
($
34)
($
34)

Partial
Form
$
1,442
$
1,724
$
0
$
0
$
172
$
205
$
0
$
0
Full
Form
$
1,442
$
1,724
$
0
$
0
$
172
$
205
$
0
$
0
Inorganic
Chemicals
PV
<
25K
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
Partial
Form
$
1,724
$
2,006
$
282
$
282
$
205
$
239
$
34
$
34
Full
Form
$
1,724
$
2,006
$
282
$
282
$
205
$
239
$
34
$
34
a
Assumes
an
average
of
8.4
reports
per
site
(
CUS
Database
1997).
Note:
Parentheses
denote
negative
estimates
(
i.
e.,
savings
instead
of
costs).

3.
Costs
of
Preparation
and
Submission
of
Report
Once
a
site
has
determined
that
its
chemical
output
must
be
reported
and
has
become
familiar
with
the
rule,
the
required
information
must
be
collected
and
a
Form
U
must
be
completed,

reviewed,
and
submitted
to
EPA.
This
section
presents
the
burden
and
cost
estimates
associated
with
20
Although
average
unit
costs
of
submissions
are
expected
to
fall
within
the
ranges
presented
in
Tables
III­
2
and
III­
12,
individual
submissions
with
especially
few
or
numerous
customers,
processing,
and/
or
use
sites
may
have
costs
outside
the
presented
ranges.

21
This
analysis
assumes
an
average
of
8.4
reports
per
site
of
one
type
of
chemical.
A
more
typical
scenario
would
involve
a
mixture
of
chemical
types.

III­
24
this
process.
A
more
detailed
description
of
the
survey
results
upon
which
these
burden
estimates
are
based
is
provided
in
Appendix
D.

a.
Data
Requirements
The
original
IUR
requires
the
provision
of
certain
basic
production
and
manufacturer
identification
information.
The
costs
associated
with
these
data
elements
comprise
the
baseline
cost
of
preparation
and
reporting.
The
proposed
amendments
add
requirements
for
information
related
to
worker
exposure
and
chemical
use.
The
costs
associated
with
these
additional
data
elements
comprise
the
costs
of
the
proposal.
Box
III­
1,
at
the
beginning
of
this
chapter,
presents
these
additional
data
requirements.
Chapter
I,
Section
B
presents
a
more
detailed
discussion.

b.
Estimates
of
Labor
Hours
and
Associated
Costs
Estimates
for
the
amount
of
time
required
to
complete
and
submit
the
amended
Form
U
were
developed
from
the
results
of
the
survey
described
in
Appendix
D.
Survey
results
were
adjusted
to
account
for
changes
in
the
draft
Form
U
prior
to
proposal
and
were
weighted
based
on
company
size
to
reflect
the
universe
of
companies
expected
to
report
under
the
proposed
amendments.

The
final
estimates
are
presented
in
Table
III­
2
at
the
beginning
of
this
chapter.

Table
III­
12
presents
the
incremental
costs
of
preparation
and
submission
of
a
report
under
the
proposed
amendments.
20
For
chemicals
produced
between
25,000
and
100,000
pounds
and
for
chemicals
meeting
the
partial
exemptions,
the
incremental
cost
is
estimated
to
be
between
$
404
and
$
809
per
report
for
each
organic
and
partially
exempt
chemical
and
$
692
to
$
1,166
per
report
for
each
inorganic
chemical.
The
incremental
per
site
cost
is
estimated
to
be
between
$
3,393
and
$
6,793
for
organic
and
partially
exempt
chemical
reporting
and
between
$
5,815
and
$
9,796
for
inorganic
chemical
reporting.
21
For
the
first
year
of
reporting
under
the
proposed
amendments,
the
incremental
cost
for
inorganic
chemicals
is
expected
to
be
higher
because
reporting
of
inorganic
chemicals
is
not
required
III­
25
under
the
original
IUR;
therefore
the
full
cost
of
reporting
is
attributable
to
the
amendments.
This
is
slightly
offset
by
the
lack
of
need
for
CBI
reassertion
for
the
first
year.

For
chemicals
not
partially
exempt
and
produced
at
volumes
greater
than
100,000
pounds,
all
sections
of
the
form
would
be
completed.
The
incremental
unit
cost
for
those
large
volume
chemicals
is
expected
to
range
from
$
2,236
to
$
2,797
per
report
for
each
organic
chemical
and
from
$
2,524
to
$
3,155
for
each
inorganic
chemical.
The
incremental
per
site
cost
is
estimated
to
be
between
$
18,782
and
$
23,498
for
organic
chemical
reporting
and
between
$
21,205
and
$
26,502
for
inorganic
chemical
reporting.
13
Note
that
these
costs
are
overestimated
because
not
all
reports
contained
CBI
claims
in
the
last
reporting
period,
and
therefore
not
all
will
bear
the
burden
of
reassertion
of
past
claims.

The
burden
associated
with
CBI
claims
is
accounted
for
in
a
variety
of
ways.
For
the
basic
CBI
claim,
the
estimated
burden
is
included
with
the
burden
estimates
for
each
data
element.

Upfront
substantiation
burdens
are
accounted
for
separately,
as
reported
in
Table
III­
2.
The
burden
of
complying
with
these
requirements
and
the
frequency
of
CBI
claims
is
discussed
further
in
Box
III­
2,

below.
Reassertion
of
CBI
claims
is
identified
as
Section
IV
of
the
reporting
form.
For
the
first
year
of
reporting
under
the
proposed
amendments,
reassertion
applies
to
claims
made
under
the
original
IUR.

This
means
two
things:
(
1)
that
the
first
year
burden
estimates
for
CBI
reassertion
are
roughly
equal
to
the
estimated
reassertion
burden
associated
with
chemicals
reporting
only
facility
identification
and
manufacturing
information
and
(
2)
that
the
first
year's
estimates
do
not
depend
upon
production
volume
or
chemical
type
(
except
for
inorganic
chemicals,
which
were
not
reported
under
the
original
IUR).
The
estimated
burden
of
reassertion
in
the
first
year
of
reporting
is
0.5
to
1.0
hours
of
clerical
time,
0.5
to
1.0
hours
of
technical
time,
and
1.0
to
2.0
hours
of
managerial
time
(
U.
S.
EPA
1994,
U.
S.
EPA
1996c,
U.
S.

EPA
1996f).
III­
26
Table
III­
12.
First
Year
Incremental
Cost
of
Preparation
and
Submission
of
a
Report
Associated
with
the
Amendments
for
Sites
Already
Reporting
($
1997)

Clerical
($
24.33/
hr)
Technical
($
59.52/
hr)
Managerial
($
81.61/
hr)

Low
High
Low
High
Low
High
Reporting
Form
Section
(
Hours)

I.
Facility
Identification
0.17
0.30
Minimal
Minimal
Minimal
Minimal
II.
Manufacturing
Information
0.61
0.61
2.98
5.22
1.02
2.79
III
.
Processing
and
Use
Information
3.29
3.43
21.11
23.12
6.07
6.48
IV
CBI
0.50
1.00
0.50
1.00
1.00
2.00
Total
Hours
per
Report,
by
Labor
Category
Partial
Form
1.27
1.90
3.49
6.23
2.02
4.79
Full
Form
4.56
5.34
24.60
29.35
8.10
11.28
Total
Costs
per
Report,
by
Labor
Category
Partial
Form
$
30.93
$
46.26
$
207.84
$
371.09
$
165.11
$
391.31
Full
Form
$
110.98
$
129.82
$
1,464.3
$
1,747.1
$
660.72
$
920.34
Total
Cost
per
Report
Partial
Form
$
404
­
$
809b,
c
Full
Form
$
2,236
­
$
2,797b
Total
Cost
per
Sited
Partial
Form
$
3,393
­
$
6,793b,
c
Full
Form
$
18,782
­
$
23,498b
Note:
Numbers
may
not
calculate
exactly
due
to
rounding.
a
The
burden
of
CBI
reassertion
for
reporting
in
the
first
year
is
less
than
the
burden
incurred
in
future
years,
because
reassertion
applies
only
to
the
information
required
under
the
original
IUR.
The
burden
of
CBI
reassertion
for
future
year
reporting
is
presented
in
Table
III­
14.
b
Total
cost
for
inorganic
chemicals
reporting
the
partial
form
is
$
692
to
$
1,166
per
report
and
the
cost
for
the
full
form
is
$
2,524
to
$
3,155
per
report.
The
per
site
costs
for
inorganic
chemicals
are
$
5,815
to
$
9,796
for
completion
of
the
partial
form
and
$
21,205
to
$
26,502
for
completion
of
the
full
form.
The
difference
in
cost
from
the
other
chemicals
is
due
to
the
lack
of
any
baseline
costs
(
therefore
the
full
cost
of
reporting
is
due
to
the
amendments)
and
the
lack
of
first
year
CBI
reassertion
costs.
In
future
years,
reassertion
costs
for
inorganic
chemicals
will
be
incurred
(
see
Table
III­
14).
c
This
is
also
the
first
year
per
report
cost
for
chemicals
meeting
the
partial
exemption
requirements.
d
Assumes
an
average
of
8.4
reports
of
one
type
per
site.
Please
note
that
a
more
typical
scenario
would
involve
a
mixture
of
report
types.
Sources:
Tables
III­
1,
III­
2,
and
III­
5.
22
Analysis
is
entitled
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313
(
U.
S.
EPA
1997a).

23
Note
that
there
are
no
first
year
CBI
reassertion
costs
for
inorganic
chemicals
because
these
chemicals
did
not
previously
report,
and,
therefore,
have
no
information
to
reassert
as
CBI.
In
future
years,
reassertion
costs
for
inorganic
chemicals
will
be
incurred.

III­
27
c.
Unit
Cost
Scaling
Factors
Unit
costs
for
future
reporting
cycles
are
expected
to
be
lower
than
unit
costs
attributed
to
first
year
reporting
because
of
efficiencies
achieved
through
the
establishment
of
compliance
processes,
the
availability
of
data
from
previous
reporting
cycles,
and
familiarity
with
reporting
requirements.
To
account
for
these
efficiencies,
EPA
has
incorporated
a
set
of
scaling
factors
for
the
unit
cost
of
preparation
and
substantiation
of
future
year
reports.
The
remainder
of
this
section
focuses
on
the
methodology
and
assumptions
used
to
determine
these
scaling
factors.

The
unit
cost
of
preparation
and
submission
of
reports
in
future
years
is
assumed
to
be
lower
than
the
cost
of
reporting
in
the
first
year
due
to
efficiencies
of
repeated
reporting.
These
efficiencies
vary
based
on
the
types
of
information
reported
and
whether
or
not
that
information
changes
significantly
from
year
to
year.
Based
on
these
assumptions
and
a
cost
analysis
for
a
similar
reporting
rule22,
scaling
factors
have
been
developed
for
each
section
of
the
reporting
form
under
the
proposed
IUR
amendments.
These
scaling
factors,
presented
in
Table
III­
13,
are
applied
to
each
reporting
period
following
the
first.
For
reassertion
of
past
CBI
claims,
first
year
costs
do
not
include
reassertion
for
exposure
and
use
information
(
because
this
information
has
not
been
previously
reported).
However,

the
second
reporting
year
would
include
CBI
claims
for
exposure
and
use
information,
and,
hence,
the
full
burden
of
reassertion
is
first
incurred
during
the
second
reporting
period.
23
Table
III­
14
presents
the
estimated
incremental
burden
and
cost
of
preparation
and
submission
of
a
report
in
future
years.
As
shown,
the
expected
incremental
cost
for
chemicals
required
to
complete
the
partial
form
is
between
$
347
and
$
696
per
report
for
organic
and
partial
exemption
chemicals,
and
between
$
759
and
$
1,301
per
report
for
inorganic
chemicals.
The
incremental
per
site
costs
for
partial
reporters
are
between
$
2,915
and
$
5,846
for
organic
and
partial
exemption
reporting,
and
between
$
6,376
and
$
10,928
for
inorganic
chemical
reporting.
The
estimated
incremental
cost
of
completing
the
full
form
is
between
$
1,924
and
$
2,510
per
report
for
organic
and
partial
exemption
chemicals,
and
between
$
2,336
and
$
3,115
per
report
for
inorganic
chemicals.
The
incremental
per
site
cost
for
full
III­
28
Box
III­
2.
Reporting
Burden
of
Complying
with
CBI
Requirements
The
calculations
used
to
develop
CBI
compliance
costs
for
the
Economic
Analysis
(
EA)
are
based
on
information
from
the
industry
survey
(
ICF
1996).
As
derived
from
the
survey,
Table
III­
2
presents
typical
costs
associated
with
compliance
for
various
CBI
substantiation
issues
attributable
to
the
proposed
IUR
amendments.
The
costs
range
from
$
215
to
$
472,
as
compared
to
$
110
to
$
200
under
the
current
IUR
requirements,
resulting
in
incremental
costs
of
between
$
105
and
$
272.
Survey
respondents
indicated
that
chemical
identification,
plant
site
identification,
and
production
volume
range
information
would
be
claimed
confidential
by
58
percent,
36
percent,
and
78
percent
of
reporting
companies,
respectively.
Companies
that
indicated
no
CBI
claims
were
estimated
to
have
zero
compliance
costs
for
each
appropriate
element.

Costs
of
CBI
substantiation
for
an
individual
company
claiming
CBI
status
for
chemical
identification,
plant
site
identification,
and
production
volume
range
may
be
higher
than
the
average
values
used
in
the
analysis,
however.
Hence,
typical
costs
may
be
more
accurately
characterized
by
excluding
burden
estimates
of
zero
for
companies
that
do
not
claim
CBI
status.
Using
only
the
non­
zero
entries,
the
cost
of
CBI
compliance
ranges
from
$
181
to
$
322
for
the
baseline
scenario,
and
from
$
391
to
$
840
under
the
amendments.
Based
on
these
values,
the
incremental
cost
of
meeting
CBI
related
requirements
is
estimated
to
be
between
$
210
and
$
518,
or
about
twice
as
much
as
used
in
the
cost
analysis.

To
place
this
discrepancy
in
perspective,
it
is
worth
noting
that,
historically,
companies
have
claimed
information
CBI
less
often
than
survey
responses
suggested.
Information
from
the
CUS
database
for
the
1986,
1990,
and
1994
reporting
cycles
indicates
significantly
lower
percentages
of
CBI
claims
for
each
type
of
data.
According
to
the
CUS
database,
the
fraction
of
companies
claiming
CBI
status
for
chemical
identification,
plant
site
identification,
and
production
volume
was
3
percent,
20
percent,
and
65
percent,
respectively.
The
difference
between
the
percentage
of
companies
claiming
CBI
as
derived
from
the
CUS
database
and
the
percentage
indicated
by
the
survey
data
suggests
that
survey
respondents
may
have
been
concerned
about
providing
detailed
information
on
uses,
and
hence,
were
conservative
in
their
estimates
of
the
frequency
of
CBI
claims.
EPA
is
aware
of
companies'
potential
reluctance
to
disclose
such
data
and
has
elected,
therefore,
to
ask
for
some
information
(
e.
g.,
production
volume)
in
ranges
to
reduce
potential
confidentiality
concerns.
In
particular,
by
adding
check
boxes
for
production
volume
range
information
and
using
this
information
for
analysis
and
in
public
reports,
EPA
expects
to
reduce
companies'
confidentiality
concerns.

Because
of
the
considerations
identified
here,
the
costs
presented
in
this
analysis
may
tend
to
overestimate
the
number
of
CBI
claims
and
therefore,
the
average
cost
of
CBI
substantiation,
both
under
the
baseline
and
the
proposal.
This
is
somewhat
offset
by
the
higher
rate
of
claims
identified
in
the
survey
as
compared
to
historical
rates
identified
from
the
CUS
database.
The
costs
used
in
the
development
of
CBI
compliance
impacts
are
not
expected
to
greatly
influence
costs
presented
in
the
EIA
because
confidentiality
costs
are
small
compared
to
overall
costs.
form
reporters
is
between
$
16,162
and
$
21,084
for
organic
and
partial
exemption
chemical
reporting
and
between
$
19,622
and
$
26,166
for
inorganic
chemical
reporting.
III­
29
Table
III­
13.
Scaling
Factors
for
Unit
Cost
of
Preparation
and
Submission
of
Reports
in
Future
Reporting
Cycles
Under
Proposed
IUR
Amendments
Part­
Section
of
Reporting
Form
Description
of
Information
Incurred
Percent
of
First
Year
Cost
Comments
2­
Year
Reportin
g
Cycle
4­
Year
Reportin
g
Cycle
Facility
Identification
and
Manufacturing
Information
I­
1
Certification
100
100
No
reduction
expected.

I­
2
Company
Information
20
20
Technical
contact
may
change,
but
other
information
unlikely
to
change.

I­
3
Plant
Site
Identification
20
20
Information
unlikely
to
change.

II­
1
Chemical
Identification
20
20
Information
unlikely
to
change.

II­
6,
II­
7,
II­
8,
II­
9,
II­
10
Manufacturing
70
80
Information
may
change.

Processing
and
Use
Information
III­
A
Industrial
Use
and
Exposure
Related
Data
70
80
Information
may
change.

III­
B
Consumer
and
Commercial
End­
Use
Exposure
Related
Data
70
80
Information
may
change.

Reassertion
of
Past
CBI
Claims
IV
Reassertion
100
100
No
reduction
expected.
However,
cost
is
not
incurred
for
reassertion
of
exposure
and
use
information
in
the
first
reporting
year.
III­
30
Table
III­
14.
Future
Years
Incremental
Cost
of
Preparation
and
Submission
of
a
Report
under
the
Proposed
IUR
Amendments
(
1997$)

Clerical
($
24.33/
hr)
Technical
($
59.52/
hr)
Managerial
($
81.61/
hr)

Low
High
Low
High
Low
High
Reporting
Form
Section
(
Hours)

I.
Facility
Identification
0.14
0.26
Minimal
Minimal
Minimal
Minimal
II.
Manufacturing
Information
0.48
0.48
2.38
4.18
0.82
2.23
III.
Processing
and
Use
Information
2.63
2.75
16.89
18.50
4.86
5.19
IV.
CBI
Reassertiona
0.50
1.00
1.00
2.00
2.00
4.00
Total
Hours
per
Report,
by
Labor
Category
Partial
Form
1.12
1.74
2.89
5.18
1.82
4.23
Full
Form
3.75
4.49
20.28
24.68
7.67
11.42
Total
Costs
per
Report,
by
Labor
Category
Partial
Form
$
27.25
$
42.41
$
171.84
$
308.37
$
148.20
$
345.48
Full
Form
$
91.29
$
109.26
$
1,206.7
7
$
1,468.7
6
$
626.30
$
931.93
Total
Cost
per
Report
Partial
Form
$
347
­
$
696b
Full
Form
$
1,924
­
$
2,510b
Total
Cost
per
Sitec
Partial
Form
$
2,915
­
$
5,846b
Full
Form
$
16,162
­
$
21,084b
Note:
Numbers
may
not
calculate
exactly
due
to
rounding.
a
CBI
reassertion
burden
estimates
for
completion
of
the
partial
form
in
future
years
are
equal
to
CBI
reassertion
burden
estimates
in
the
first
year
of
reporting
under
the
amendments,
as
detailed
in
Table
III­
12.
b
The
future
years
cost
for
inorganic
chemicals
reporting
the
partial
form
is
$
759
to
$
1,301
and
the
cost
for
the
full
form
is
$
2,336
to
$
3,115.
The
per
site
future
years
costs
for
inorganic
chemicals
are
$
6,376
to
$
10,928
for
completion
of
the
partial
form
and
$
19,622
to
$
26,166
for
completion
of
the
full
form.
These
costs
are
higher
than
for
organic
chemicals
because
inorganic
chemicals
are
not
required
to
report
under
the
original
IUR.
CBI
reassertion
costs
for
inorganic
chemicals
are
included
in
estimates
of
future
year
costs.
c
Assumes
an
average
of
8.4
reports
per
site.
Please
note
that
a
more
typical
scenario
would
involve
a
mixture
of
report
types.
III­
31
Sources:
Tables
III­
1,
III­
2,
III­
5,
and
III­
13.
24
Recordkeeping
costs
for
completion
of
the
partial
form
may
be
overstated
because
the
level
of
information
required
to
be
maintained
is
slightly
lower
than
for
completion
of
the
full
form.
It
is
assumed
however
that
because
these
overstated
costs
are
small
relative
to
other
costs,
they
will
have
a
minimal
impact
on
total
cost
estimates.

III­
32
4.
Costs
of
Recordkeeping
The
original
IUR
requires
that
sites
maintain
records
of
reported
information
for
at
least
4
years
from
the
effective
date
of
the
reporting
period.
The
quantified
costs
associated
with
these
original
recordkeeping
requirements
consist
of
the
costs
of
labor
to
compile
and
maintain
collected
information.
Sites
may
maintain
records
such
as
invoices,
receiving
tickets,
and
incident
and
operating
logs.
EPA
assumes
that
the
average
burden
of
recordkeeping
under
the
proposed
amendments
will
be
somewhat
greater
than
the
burden
under
the
original
IUR
because
it
is
likely
submitters
under
the
proposal
would
maintain
additional
records,
and
the
records
must
be
maintained
for
five
years,
one
year
longer
than
the
original
requirements.
It
is
expected
that
recordkeeping
of
files
is
an
on­
going
activity
and
that
the
cost
associated
with
maintaining
these
records
will
be
constant
for
each
reporting
period.

Based
on
the
labor
requirements
presented
in
Table
III­
15,
the
estimated
incremental
cost
of
recordkeeping
incurred
under
the
proposal
is
between
$
112
and
$
225
per
report
for
organic
and
partial
exemption
chemicals,
24
and
between
$
225
and
$
450
per
report
for
inorganic
chemicals.
The
per
site
incremental
recordkeeping
cost
III­
33
Table
III­
15.
Incremental
Burden
Per
Report
of
Recordkeeping
(
hours)

Type
of
Chemical
Clerical
Technical
Managerial
Low
High
Low
High
Low
High
Organic
and
Partial
Exemption
Chemicals
PV
<
25K
(
0.5)
(
1)
(
1)
(
2)
(
0.5)
(
1)

Partial
Form
0.5
1
1
2
0.5
1
Full
Form
0.5
1
1
2
0.5
1
Inorganic
Chemicals
PV
<
25K
0
0
0
0
0
0
Partial
Form
1
2
2
4
1
2
Full
Form
1
2
2
4
1
2
Note:
Parentheses
denote
savings
instead
of
costs.

is
between
$
945
and
$
1,890
for
organic
and
partial
exemption
chemical
reporting,
and
between
$
1,890
and
$
3,780
for
inorganic
chemical
reporting
for
completion
of
either
the
full
or
partial
form.
Costs
are
higher
for
inorganic
chemicals
since
they
currently
do
not
report.
Table
III­
16
presents
the
incremental
costs
per
report
associated
with
these
routine
recordkeeping
activities
(
U.
S.
EPA
1994,
U.
S.
EPA
1997a).
III­
34
Table
III­
16.
Incremental
Cost
of
Recordkeeping
(
1997$)

Type
of
Chemical
Per
Report
Cost
Per
Site
Costa
First
Year
Future
Years
First
Year
Future
Years
Low
High
Low
High
Low
High
Low
High
Organic
and
Partial
Exemption
Chemicals
PV
<
25K
($
112
)
($
225
)
($
112
)
($
225
)
($
945)
($
1,890
)
($
945)
($
1,890)

Partial
Form
$
112
$
225
$
112
$
225
$
945
$
1,890
$
945
$
1,890
Full
Form
$
112
$
225
$
112
$
225
$
945
$
1,890
$
945
$
1,890
Inorganic
Chemicals
PV
<
25K
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
Partial
Form
$
225
$
450
$
225
$
450
$
1,89
0
$
3,780
$
1,89
0
$
3,780
Full
Form
$
225
$
450
$
225
$
450
$
1,89
0
$
3,780
$
1,89
0
$
3,780
a
Assumes
an
average
of
8.4
reports
per
site
(
CUS
Database
1997).
Note:
Parentheses
denote
savings
instead
of
costs.
25
Translations
between
per
site
and
per
report
assumed
that
all
reports
at
a
site
were
of
the
same
type
(
i.
e.,
full
form
versus
partial
form).
In
reality,
a
mix
of
report
types
would
be
expected.

III­
35
5.
Summary
of
Estimated
Unit
Costs
This
section
summarizes
the
incremental
costs
of
compliance
with
the
IUR
amendments.
Costs
are
presented
for
three
categories
of
reporting
(
production
volume
less
than
25,000
pounds,
partial
form
U
reporting,
and
full
form
U
reporting)
and
for
two
types
of
chemicals
(
organic
and
inorganic).
Table
III­
17
presents
the
summary
on
a
per
report
basis.
Table
III­
18
presents
the
summary
on
a
per
site
basis.
As
discussed
previously,
numbers
were
translated
based
upon
an
average
of
8.4
reports
per
site.
25
Table
III­
17.
Summary
of
Incremental
Per
Report
Costs
(
1997$)

Type
of
Chemical
First
Year
Future
Years
Low
High
Low
High
Organic
and
Partial
Exemption
Chemicals
PV
<
25K
lbs.
($
565)
($
892)
($
565)
($
892)

Partial
Form
$
688
$
1,239
$
459
$
921
Full
Form
$
2,520
$
3,227
$
2,036
$
2,735
Inorganic
Chemicals
PV
<
25K
lbs.
$
0
$
0
$
0
$
0
Partial
Form
$
1,129
$
1,883
$
1,025
$
1,813
Full
Form
$
2,961
$
3,872
$
2,602
$
3,267
Sources:
Tables
III­
11,
III­
12,
III­
14,
and
III­
16.
III­
36
Table
III­
18.
Summary
of
Incremental
Per
Site
Costs
(
1997$)

Type
of
Chemical
First
Year
Future
Years
Low
High
Low
High
Organic
and
Partial
Exemption
Chemicals
PV
<
25K
lbs.
($
4,747)
($
7,489)
($
4,747)
($
7,489)

Partial
Form
$
5,780
$
10,407
$
3,860
$
7,736
Full
Form
$
21,169
$
27,112
$
17,107
$
22,974
Inorganic
Chemicals
PV
<
25K
lbs.
$
0
$
0
$
0
$
0
Partial
Form
$
9,489
$
15,820
$
8,608
$
15,228
Full
Form
$
24,879
$
32,526
$
21,854
$
30,466
Sources:
Tables
III­
11,
III­
12,
III­
14,
and
III­
16.

6.
Numbers
of
Reports
To
calculate
the
industry­
wide
incremental
and
total
expected
costs,
EPA
estimated
the
anticipated
number
of
reports
for
the
first
and
future
reporting
cycles.
EPA
first
examined
the
historical
levels
of
submissions
during
the
1986,
1990,
and
1994
reporting
periods.
The
number
of
reports
submitted
over
those
three
periods
varied
from
the
average
submission
level
of
25,614
by
only
0.3
to
2.5
percent.
Since
the
number
of
reports
previously
submitted
has
remained
fairly
constant,
EPA
held
the
yearly
number
of
reports
constant
over
the
20­
year
period
covered
by
the
cost
analysis.
EPA
then
estimated
the
number
of
inorganic
chemicals
using
historical
proportions
of
organic
to
inorganic
chemicals
from
the
Chemical
in
Commerce
Information
System
(
CICIS)
database.
Details
on
the
development
of
these
estimates
can
be
found
in
Appendix
C.
Accounting
for
the
changes
in
exemptions
and
reporting
threshold
under
the
amendments,
EPA
estimates
that
the
total
number
of
reports
submitted
under
the
proposal
would
be
26,811.
Approximately
58
percent
of
those
reports
would
be
for
chemicals
produced
in
excess
of
100,000
pounds
and
not
eligible
for
partial
exemption.
26
The
proposed
amendments
currently
include
a
partial
exemption
for
petroleum
stream
chemicals.
Additionally,
EPA
is
considering
an
expansion
of
the
set
of
chemicals
eligible
for
this
exemption.
Chemicals
deemed
by
EPA
to
be
of
low
priority
would
be
eligible
for
the
same
reduced
level
of
reporting.
These
chemicals
would
be
considered
to
be
low
priority
for
further
risk
assessment
and
management.
At
the
time
of
this
analysis,
EPA
has
not
determined
the
chemicals
that
would
be
eligible
for
the
low
priority
exemption
and
hence
they
are
not
included
in
this
economic
analysis.
However,
EPA
feels
that
the
number
of
chemicals
that
would
be
eligible
for
this
exemption
is
likely
to
be
small
and
therefore
any
effect
on
the
burden
would
also
be
small.

27
Tables
III­
24a,
III­
24b
and
III­
25
present
the
estimated
number
of
reports
and
reporting
sites
under
the
proposed
amendments.
The
estimates
in
these
tables
were
used
to
develop
industry­
wide
incremental
and
total
costs
of
the
proposed
amendments
in
Tables
III­
19
through
III­
22,
however
they
have
been
placed
in
Section
D
below
for
organizational
purposes.

III­
37
Reports
for
these
chemicals
would
require
that
the
entire
Form
U
be
completed.
The
remaining
42
percent
would
be
required
to
complete
only
the
partial
Form
U.
26
7.
Number
of
Sites
There
are
an
estimated
3,485
sites
that
manufacture
or
import
a
reportable
chemical
at
a
volume
greater
than
25,000
pounds
annually.
These
sites
would
have
to
report
under
the
IUR
amendments
(
CUS
Database
1997,
CICIS
Database
1986).
This
estimate
reflects
the
number
of
sites
that
would
be
reporting
organic
chemicals,
including
petroleum
streams,
and
inorganic
chemicals,
as
outlined
in
the
proposed
amendments.

8.
Total
Cost
for
Proposed
IUR
Amendments
The
total
costs
to
industry
of
the
proposed
IUR
amendments
are
estimated
for
the
first
year
of
reporting
and
for
future
reporting
years
in
constant
1997
dollars.
Total
costs
are
calculated
based
on
the
unit
costs
and
the
number
of
reports
and
sites
estimated
earlier
in
this
chapter.
These
costs
were
developed
based
on
costs
for
each
type
of
chemical
(
i.
e.,
inorganic
chemicals,
organic
chemicals,
or
partial
exemption)
and
for
each
reporting
threshold
(
i.
e.,
completing
a
full
or
partial
form,

based
on
production
volume
and
exemption
status).

a.
First
Year
Costs
of
Proposed
Amendments
Incremental
first
year
costs
for
the
proposed
amendments
were
developed
by
combining
information
from
Tables
III­
17,
III­
18,
III­
24a,
III­
24b
and
III­
25.27
These
costs
are
presented
28
Although
Tables
III­
17
and
III­
18
indicate
a
negative
per
report
and
per
site
cost
for
partial
exemption
chemicals
with
production
volumes
less
than
25,000,
the
costs
associated
with
partial
exemption
chemicals
under
this
production
threshold
are
zero.
This
is
because
there
are
no
partial
exemption
chemicals
under
the
baseline.
Chemicals
that
were
reported
under
the
baseline,
such
as
petroleum
stream
chemicals,
but
that
would
be
eligible
for
the
partial
exemption
under
the
amendments,
have
been
included
with
the
totals
for
organic
chemicals
under
the
baseline.

III­
38
in
Table
III­
19
below.
28
Table
III­
20
presents
the
sum
of
the
baseline
and
incremental
costs,
or
the
total
costs
of
the
amended
IUR.
As
shown,
incremental
first
year
industry
cost
for
the
proposal
is
approximately
$
47.9
million
to
$
65.4
million.
For
the
full
amended
IUR,
the
total
estimated
first
year
industry
cost
is
approximately
$
61.8
million
to
$
87.4
million.

Table
III­
19.
Incremental
First
Year
Cost
of
Amendments
(
million
1997$)

Type
of
Chemical
PV<
25K
Partial
Form
Full
Form
Total
Low
High
Low
High
Low
High
Low
High
Organic
Chemicals
($
1.5
)
($
2.4)
$
2.3
$
4.6
$
29.1
$
36.3
$
29.
9
$
38.5
Partial
Exemption
Chemicals
$
0
$
0
$
6.9
$
11.9
$
0
$
0
$
6.9
$
11.9
Inorganic
Chemicals
$
0
$
0
$
1.1
$
2.0
$
10.0
$
13.0
$
11.
1
$
15.0
Total
($
1.5
)
($
2.4)
$
10.3
$
18.4
$
39.1
$
49.4
$
47.
9
$
65.4
Source:
Tables
III­
17,
III­
18,
III­
24a,
24b,
and
III­
25.

Table
III­
20.
Total
First
Year
Cost
of
IUR
Compliance,
with
Amendments
(
million
1997$)

Type
of
Chemical
PV<
25K
Partial
Form
Full
Form
Total
Low
High
Low
High
Low
High
Low
High
Organic
Chemicals
$
0
$
0
$
4.6
$
8.2
$
39.2
$
52.2
$
43.
$
60.5
Partial
Exemption
Chemicals
$
0
$
0
$
6.9
$
11.9
$
0
$
0
$
6.9
$
11.9
Inorganic
$
0
$
0
$
1.1
$
2.0
$
10.0
$
13.0
$
11.
$
15.0
Total
$
0
$
0
$
12.6
$
22.1
$
49.2
$
65.3
$
61.
8
$
87.4
Source:
Tables
III­
17,
III­
18,
III­
24a,
III­
24b,
and
III­
25.

b.
Future
Costs
of
Proposed
Amendments
III­
39
The
annual
incremental
industry
costs
associated
with
the
proposed
IUR
amendments
in
each
future
reporting
year
are
presented
in
Table
III­
21;
the
total
costs
are
presented
in
Table
III­
22.

Table
III­
21.
Incremental
Annual
Cost
of
Amendments
in
Future
Years
(
million
1997$)

Type
of
Chemical
PV<
25K
Partial
Form
Full
Form
Total
Low
High
Low
High
Low
High
Low
High
Organic
Chemicals
($
1.5)
($
2.4)
$
2.0
$
4.1
$
21.9
$
28.7
$
22.
4
$
30.4
Partial
Exemption
Chemicals
$
0
$
0
$
5.8
$
10.3
$
0
$
0
$
5.8
$
10.3
Inorganic
Chemicals
$
0
$
0
$
1.2
$
2.1
$
8.6
$
12.0
$
9.8
$
14.1
Total
($
1.5)
($
2.4)
$
9.1
$
16.6
$
30.4
$
40.6
$
38.
0
$
54.8
Source:
Tables
III­
17,
III­
18,
III­
24a,
III­
24b,
and
III­
25.

Table
III­
22.
Total
Annual
Cost
of
IUR
Compliance,
with
Amendments,
in
Future
Years
(
million
1997$)

Type
of
Chemical
PV<
25K
Partial
Form
Full
Form
Total
Low
High
Low
High
Low
High
Low
High
Organic
Chemicals
$
0
$
0
$
4.4
$
7.7
$
32.0
$
44.6
$
36.
3
$
52.3
Partial
Exemption
Chemicals
$
0
$
0
$
5.8
$
10.3
$
0
$
0
$
5.8
$
10.3
Inorganic
Chemicals
$
0
$
0
$
1.2
$
2.1
$
8.6
$
12.0
$
9.8
$
14.1
Total
$
0
$
0
$
11.4
$
20.2
$
40.5
$
56.5
$
51.
9
$
76.7
Source:
Tables
III­
17,
III­
18,
III­
24a,
III­
24b,
and
III­
25.

D.
Overview
of
Reporting
Options
EPA
examined
a
variety
of
options
to
the
proposed
amendments,
including
changes
in
reporting
thresholds,
reporting
exemptions,
and
reporting
cycles.
Overall,
fourteen
options
were
analyzed.
For
all
but
two
options,
the
partial
exemption
of
petroleum
stream
chemicals
and
the
elimination
of
the
III­
40
inorganic
chemical
exemption
were
held
constant.
Table
III­
23
summarizes
the
options.
Options
1­
9
assumed
a
four­
year
reporting
cycle,
but
each
option
incorporated
a
different
reporting
threshold
scheme.

The
options
use
a
reporting
threshold
for
the
partial
form
(
facility
identification
and
manufacturing
information),
of
either
the
original
10,000
pounds
or
25,000
pounds.
The
reporting
threshold
for
the
full
form
was
varied
from
10,000
pounds
to
ten
million
pounds.
Option
9
incorporated
a
stepped
threshold
for
the
full
form
­
for
the
first
reporting
period,
the
threshold
is
500,000
pounds
and
for
subsequent
reporting
periods
the
threshold
drops
to
100,000
pounds.
Option
10
incorporated
the
reporting
thresholds
outlined
in
the
proposed
option,
but
proposes
a
full
exemption
from
reporting
for
certain
petroleum
streams
(
those
that
are
site­
limited),
rather
than
the
proposed
petroleum
stream
partial
exemption.
Option
11
used
the
same
reporting
thresholds
as
Option
4,
but
continued
the
existing
exemption
for
inorganic
chemicals.

Options
12,
13,
and
14
used
the
same
reporting
thresholds
as
the
proposed
option
(
25,000
pounds
for
the
partial
form
and
100,000
pounds
for
the
full
form),
but
incorporate
different
reporting
cycles.
Option
12
used
a
reporting
cycle
of
two
years
for
the
partial
form
(
which
must
be
completed
by
all
sites)
and
four
years
for
the
full
form,
Option
13
called
for
a
reporting
cycle
of
two
years
for
all
information,
and
Option
14
required
only
one­
time
reporting.

1.
Numbers
of
Reports
and
Sites
Table
III­
24a
presents
the
number
of
reports
expected
for
each
option,
and
Table
III­

24b
details
these
reports
by
chemical
type.
Under
the
proposed
amendments,
partial
forms
will
be
completed
for
4,421
organic
chemicals,
5,733
partial
exemption
chemicals,
and
1,226
inorganic
chemicals.
Of
these
5,733
partial
exemption
chemicals,
131
are
produced
at
volumes
less
than
the
100,000
pound
threshold.
The
partial
exemption
provides
a
smaller
degree
of
benefit
for
these
chemicals,
because
the
lower
production
volume
already
exempts
them
from
completion
of
the
full
form.
Full
forms
will
be
completed
for
12,155
organic
chemicals
and
3,276
inorganic
chemicals
under
the
proposed
option.
III­
41
Table
III­
23.
Reporting
Options
for
the
Proposed
IUR
Amendments
Optio
n
Thresholds
Reporting
Cycles
Exemptions
Facility
Identification
and
Manufacturin
g
Information
Processin
g
and
Use
Informatio
n
Facility
Identification
and
Manufacturin
g
Information
Processin
g
and
Use
Informatio
n
Facility
Identification
and
Manufacturin
g
Information
Processing
and
Use
Information
Proposed
Option
4
25,000
lb
100,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
Alternate
Threshold
Options
1
10,000
lb
10,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
2
25,000
lb
25,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
3
10,000
lb
100,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
5
10,000
lb
500,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
6
25,000
lb
500,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
7
25,000
lb
1,000,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
8
25,000
lb
10,000,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
9
25,000
lb
500,000
lb/
100,000
lb
4
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
Reporting
Exemption
Options
10
25,000
lb
100,000
lb
4
yrs.
4
yrs.
Site­
Limited
Petroleum
Streams
11
25,000
lb
100,000
lb
4
yrs.
4
yrs.
Inorganic
Chemicals
­­­­
Partial
Exemption
Chemicals
Reporting
Cycle
Options
12
25,000
lb
100,000
lb
2
yrs.
4
yrs.
­­­­
Partial
Exemption
Chemicals
13
25,000
lb
100,000
lb
2
yrs.
2
yrs.
­­­­
Partial
Exemption
Chemicals
14
25,000
lb
100,000
lb
One­
time
Reporting
One­
time
Reporting
­­­­
Partial
Exemption
III­
42
The
number
of
partial
and
full
forms
completed
for
organic,
partial
exemption,
and
inorganic
chemicals
varies
by
option.
Under
Options
1
and
2,
a
greater
number
of
full
forms
are
completed
than
under
the
proposed
option,
because
these
options
have
lower
thresholds
for
facility
and
manufacturing
information.
The
total
number
of
reports
completed
is
greater
under
the
proposed
option
than
under
Option
1,
while
under
Option
2
the
total
number
of
reports,
and
their
allocation
by
chemical
type,
is
equal
to
the
proposed
option.
Under
Option
3,
the
number
of
full
forms
completed,
and
the
allocation
of
these
forms
by
chemical
type,
is
the
same
as
under
the
proposed
option.
The
number
of
partial
forms
completed
under
this
option,
and
the
number
of
partial
exemption
chemicals
produced
at
volumes
under
100,000
pounds,
are
greater
than
under
the
proposed
option.
Under
Options
5,
6,
7,
and
8,
and
the
first
reporting
period
under
Option
9,
the
number
of
partial
forms
completed
and
the
number
of
partial
exemption
chemicals
produced
under
the
100,000
pound
threshold
are
greater
than
under
the
proposed
option,
because
of
the
higher
thresholds
for
facility
and
manufacturing
information
under
these
options.
For
all
of
the
options
except
Option
5,
the
allocation
of
the
total
number
of
reports
by
chemical
type
is
equal
to
the
allocation
under
the
proposed
option.
III­
43
Table
III­
24a.
Number
of
Reports
Expected
for
Each
Option
Option
Total
#
of
Report
s
Partial
Form
Full
Form
Threshol
d
Level
Number
of
Reports
%
of
Total
Threshol
d
Level
Number
of
Reports
%
of
Total
Baselin
24,774
10,000
24,774
100
N/
A
0
0
1
30,598
10,000
5,833
19.1
10,000
24,765
80.9
2
26,811
25,000
5,733
21.4
25,000
21,078
78.6
3
30,598
10,000
15,167
49.6
100,000
15,431
50.4
4
26,811
25,000
11,380
42.4
100,000
15,431
57.6
5
30,598
10,000
20,511
67.0
500,000
10,087
33.0
6
26,811
25,000
16,724
62.4
500,000
10,087
37.6
7
26,811
25,000
18,393
68.6
1,000,000
8,418
31.4
8
26,811
25,000
22,435
83.7
10,000,00
4,376
16.3
9a
26,811
25,000
16,724
62.4
500,000
10,087
37.6
11,380
42.4
100,000
15,431
57.6
10b
25,577
25,000
5,763
22.5
100,000
19,814
77.5
11
22,309
25,000
10,154
45.5
100,000
12,155
54.5
12
26,811
25,000
11,380
42.4
100,000
15,431
57.6
13
26,811
25,000
11,380
42.4
100,000
15,431
57.6
14
26,811
25,000
11,380
42.4
100,000
15,431
57.6
a
This
option
would
have
a
reporting
threshold
of
500,000
pounds
for
the
full
form
in
the
first
year
and
100,000
pounds
for
the
full
form
in
future
reporting
years.
b
Site­
limited
petroleum
streams
are
exempt
from
all
reporting
under
this
option.
The
number
of
organic
chemical
reports
includes
all
reportable
petroleum
stream
chemicals
except
site­
limited
petroleum
streams.
Sources:
CUS
Database
1996,
CUS
Database
1997,
and
CICIS
Database
1986.
III­
44
Table
III­
24b.
Number
of
Reports
by
Chemical
Type
Expected
for
Each
Option
Option
Partial
Form
Full
Form
Threshol
d
Level
Number
of
Reports
Threshol
d
Level
Number
of
Reports
Organic
Chemical
s
Partial
Exemption
Chemicals
Inorganic
Chemical
s
Organic
Chemical
s
Partial
Exemption
Chemicals
Inorganic
Chemical
s
Baselin
10,000
24,774
0
0
N/
A
0
0
0
1
10,000
0
5,833
0
10,000
19,490
0
5,275
2
25,000
0
5,733
0
25,000
16,576
0
4,502
3
10,000
7,335
5,833
1,999
100,000
12,155
0
3,276
4
25,000
4,421
5,733
1,226
100,000
12,155
0
3,276
5
10,000
11,474
5,833
3,204
500,000
8,016
0
2,071
6
25,000
8,560
5,733
2,431
500,000
8,016
0
2,071
7
25,000
9,844
5,733
2,816
1,000,000
6,732
0
1,686
8
25,000
12,989
5,733
3,713
10,000,00
3,587
0
789
9a
25,000
8,560
5,733
2,431
500,000
8,016
0
2,071
4,421
5,733
1,226
100,000
12,155
0
3,276
10b
25,000
4,537
NA
1,226
100,000
16,538
0
3,276
11
25,000
4,421
5,733
0
100,000
12,155
0
0
12
25,000
4,421
5,733
1,226
100,000
12,155
0
3,276
13
25,000
4,421
5,733
1,226
100,000
12,155
0
3,276
14
25,000
4,421
5,733
1,226
100,000
12,155
0
3,276
a
This
option
would
have
a
reporting
threshold
of
500,000
pounds
for
the
full
form
in
the
first
year
and
100,000
pounds
for
the
full
form
in
future
reporting
years.
b
Site­
limited
petroleum
streams
are
exempt
from
all
reporting
under
this
option.
The
number
of
organic
chemical
reports
includes
all
reportable
petroleum
stream
chemicals
except
site­
limited
petroleum
streams.
Source:
Appendix
C.

Under
Option
10,
the
number
of
reports
completed
for
organic
chemicals
is
greater
than
under
the
proposed
option;
however,
the
number
of
partial
and
full
forms
completed
for
inorganic
chemicals
is
the
same
as
for
the
proposed
option.
Under
Option
11,
the
number
of
full
and
partial
forms
completed
for
organic
chemicals
and
partial
exemption
chemicals
is
the
same
as
under
the
proposed
option,

however
no
inorganic
chemical
reports
are
completed
under
this
option.
Under
Options
12,
13,
and
14,

and
subsequent
reporting
periods
under
Option
9,
the
total
number
of
reports
and
their
allocation
by
chemical
type
are
the
same
as
under
the
proposed
option
(
because
there
are
no
changes
to
the
reporting
thresholds
or
exemptions).

The
expected
number
of
sites
that
would
report
under
each
option
for
the
proposed
amendments
is
presented
in
Table
III­
25
below.
Additionally,
Table
III­
26
presents
the
number
of
III­
45
chemicals
expected
to
be
reported.
Although
information
on
number
of
chemicals
is
not
used
to
calculate
the
estimates
of
industry
costs,
the
table
provides
a
useful
comparison
of
the
expected
number
of
chemicals
for
each
option.

Table
III­
25.
Numbers
of
Sites
Expected
for
Each
Option
Option
Threshold
Level
Number
of
Sites
Organic
Chemicals
Partial
Exemption
Chemicals
Inorganic
Chemicals
Total
Baselin
10,000
2,683
0
0
2,683
1
10,000
2,511
526
633
3,670
2
25,000
2,416
529
540
3,485
3
10,000
2,511
526
633
3,670
4
25,000
2,416
529
540
3,485
5
10,000
2,511
526
633
3,670
6
25,000
2,416
529
540
3,485
7
25,000
2,416
529
540
3,485
8
25,000
2,416
529
540
3,485
9
25,000
2,416
529
540
3,485
10a
25,000
2,825
NA
540
3,365
11
25,000
2,416
529
0
2,945
12
25,000
2,416
529
540
3,485
13
25,000
2,416
529
540
3,485
14
25,000
2,416
529
540
3,485
a
Site­
limited
petroleum
streams
are
exempt
from
all
reporting
under
this
option.
The
number
of
organic
chemical
reports
in
this
option
includes
all
reportable
petroleum
stream
chemicals
except
site­
limited
petroleum
streams.
Source:
Appendix
C.
29
Net
present
values
for
the
amendment
options
were
calculated
over
a
twenty
year
period
using
a
discount
rate
of
three
percent.
Additional
discussion
on
the
basis
for
using
this
discount
rate
is
provided
in
Appendix
E.

III­
46
Table
III­
26.
Number
of
Chemicals
Expected
to
be
Reported
for
Each
Option
Option
Total
#
of
Chemicals
Partial
Form
Full
Form
Threshol
d
Level
Number
of
Chemicals
Threshold
Level
Number
of
Chemicals
Baselin
8,809
10,000
8,809
N/
A
0
1
10,439
10,000
431
10,000
10,008
2
8,904
25,000
430
25,000
8,474
3
10,439
10,000
4,393
100,000
6,046
4
8,904
25,000
2,858
100,000
6,046
5
10,439
10,000
6,780
500,000
3,659
6
8,904
25,000
5,245
500,000
3,659
7
8,904
25,000
6,000
1,000,000
2,904
8
8,904
25,000
7,745
10,000,000
1,159
9a
8,904
25,000
5,245
500,000
3,659
2,858
100,000
6,046
10b
8,617
25,000
2,431
100,000
6,186
11
7,796
25,000
2,556
100,000
5,240
12
8,904
25,000
2,858
100,000
6,046
13
8,904
25,000
2,858
100,000
6,046
14
8,904
25,000
2,858
100,000
6,046
a
This
option
would
have
a
reporting
threshold
of
500,000
pounds
for
the
full
form
in
the
first
year
and
100,000
pounds
for
the
full
form
in
future
reporting
years.
b
Site­
limited
petroleum
streams
are
exempt
from
all
reporting
under
this
option.
The
number
of
organic
chemical
reports
includes
all
reportable
petroleum
stream
chemicals
except
site­
limited
petroleum
streams.
Sources:
CUS
Database
1996,
CUS
Database
1997,
and
CICIS
Database
1986.

2.
Estimates
of
Industry
Costs
EPA
has
estimated
incremental
and
total
costs
to
industry
associated
with
the
proposal
and
with
the
other
options
analyzed.
Incremental
costs
associated
with
the
amendment
are
presented
in
Table
III­
27.
EPA
estimates
incremental
first
year
costs
for
the
proposed
amendments,
relative
to
original
requirements,
to
be
between
$
48
million
and
$
65
million.
The
estimated
annualized
incremental
cost
for
this
proposal
is
between
$
12
million
and
$
18
million,
and
the
estimated
net
present
value
over
a
twenty
year
period
ranges
from
$
184
million
to
$
261
million.
29
These
costs
are
attributed
to
the
time
required
for
compliance
determination,
rule
familiarization,
preparation
and
submission
of
III­
47
reports,
and
recordkeeping.
The
largest
portion
of
the
incremental
cost
corresponds
to
the
new
requirement
to
provide
processing
and
use
information.
Total
costs,
combining
baseline
and
incremental
costs,
are
presented
in
Table
III­
28.

Industry
costs
for
Options
1
through
3
are
higher
than
the
costs
for
the
proposed
option
because
information
would
be
collected
for
more
chemicals
and/
or
more
information
would
be
collected.

Industry
costs
for
Options
5
through
9
have
lower
costs
than
the
proposed
option
because
fewer
numbers
of
reports
would
be
expected
under
the
higher
reporting
threshold
options.
Industry
costs
for
Option
10
are
higher
than
the
costs
for
the
proposed
option
because
more
reports
containing
use
and
exposure
information
are
expected
under
this
option
than
under
the
proposed
option.
Industry
costs
for
Option
11
are
less
than
for
the
proposed
option
because
all
inorganic
chemicals
would
be
exempt
from
reporting
either
facility
identification
and
manufacturing
information
or
processing
and
use
information.

While
first
year
costs
for
the
three
reporting
cycle
options
(
Options
12,
13,
14)
are
the
same
as
for
the
proposal,
net
present
value
and
annualized
costs
are
significantly
higher
for
Options
12
and
13
because
information
would
be
collected
more
frequently.
Net
present
values
and
annualized
costs
are
significantly
less
for
Option
14
because
information
would
be
collected
only
once.
III­
48
Table
III­
27.
Incremental
Net
Present
Values
and
Annualized
Costs
of
Amendment
Options
Discounted
at
Three
Percent
(
million
1997$)

Option
First
Year
Cost
Net
Present
Valuea
Annualized
Cost
Low
High
Low
High
Low
High
Threshold
Options
Option
1
$
69.2
$
91.2
$
271.1
$
371.7
$
18.2
$
25.0
Option
2
$
58.3
$
76.6
$
225.8
$
309.1
$
15.2
$
20.8
Option
3
$
52.1
$
72.7
$
201.4
$
292.6
$
13.5
$
19.7
Option
4
$
47.9
$
65.4
$
183.7
$
261.2
$
12.3
$
17.6
Option
5
$
42.3
$
62.0
$
161.5
$
247.3
$
10.8
$
16.6
Option
6
$
38.1
$
54.8
$
143.8
$
215.9
$
9.7
$
14.5
Option
7
$
35.1
$
51.4
$
131.3
$
201.8
$
8.8
$
13.6
Option
8
$
27.7
$
43.4
$
101.1
$
167.5
$
6.8
$
11.3
Option
9
$
38.1
$
54.8
$
174.2
$
250.9
$
11.7
$
16.9
Reporting
Exemption
Options
Option
4
$
47.9
$
65.4
$
183.7
$
261.2
$
12.3
$
17.6
Option
10
$
54.4
$
71.5
$
210.4
$
287.9
$
14.1
$
19.3
Option
11
$
36.8
$
50.4
$
137.6
$
195.8
$
9.2
$
13.2
Reporting
Cycle
Options
Option
4
$
47.9
$
65.4
$
183.7
$
261.2
$
12.3
$
17.6
Option
12
$
47.9
$
65.4
$
268.8
$
413.2
$
18.1
$
27.8
Option
13
$
47.9
$
65.4
$
353.6
$
512.8
$
23.8
$
34.5
Option
14
$
47.9
$
65.4
$
46.5
$
63.5
$
3.1
$
4.3
Note:
Incremental
costs
may
not
calculate
exactly
due
to
rounding.
a
NPV
determined
for
a
20
year
period.
III­
49
Table
III­
28.
Total
Net
Present
Values
and
Annualized
Costs
of
IUR
Compliance,
with
Different
Amendment
Options
Discounted
at
Three
Percent
(
million
1997$)

Option
First
Year
Cost
Net
Present
Valuea
Annualized
Cost
Low
High
Low
High
Low
High
Baseline
$
13.9
$
21.9
$
63.7
$
100.5
$
4.3
$
6.8
Threshold
Options
Option
1
$
83.1
$
113.2
$
334.8
$
472.2
$
22.5
$
31.7
Option
2
$
72.2
$
98.6
$
289.6
$
409.6
$
19.5
$
27.5
Option
3
$
66.0
$
94.6
$
265.1
$
393.1
$
17.8
$
26.4
Option
4
$
61.8
$
87.4
$
247.4
$
361.8
$
16.6
$
24.3
Option
5
$
56.2
$
84.0
$
225.2
$
347.8
$
15.1
$
23.4
Option
6
$
52.0
$
76.7
$
207.4
$
316.4
$
13.9
$
21.3
Option
7
$
49.0
$
73.4
$
195.0
$
302.3
$
13.1
$
20.3
Option
8
$
41.6
$
65.4
$
164.8
$
268.0
$
11.1
$
18.0
Option
9
$
52.0
$
76.7
$
237.9
$
351.4
$
16.0
$
23.6
Reporting
Exemption
Options
Option
4
$
61.8
$
87.4
$
274.4
$
361.8
$
16.6
$
24.3
Option
10
$
68.4
$
93.5
$
274.1
$
388.4
$
18.4
$
26.1
Option
11
$
50.7
$
72.4
$
201.3
$
296.3
$
13.5
$
19.9
Reporting
Cycle
Options
Option
4
$
61.8
$
87.4
$
274.4
$
361.8
$
16.6
$
24.3
Option
12
$
61.8
$
87.4
$
329.0
$
508.2
$
22.1
$
34.2
Option
13
$
61.8
$
87.4
$
413.8
$
607.8
$
27.8
$
40.8
Option
14
$
61.8
$
87.4
$
60.0
$
84.8
$
4.0
$
5.7
Note:
Total
Costs
may
not
calculate
exactly
due
to
rounding.
a
NPV
determined
for
a
20
year
period.
III­
50
2.
Cost
Analysis
for
Threshold
and
Reporting
Cycle
Options
A
model
was
developed
to
calculate
compliance
costs
for
future
reporting
cycles
in
real
terms
for
the
baseline
case
and
for
each
of
the
regulatory
options
under
the
proposed
IUR
amendments.
To
calculate
industry
burden,
the
estimated
number
of
reports
and
sites
for
the
baseline
and
for
each
option
was
multiplied
by
the
unit
costs
for
completing
each
of
the
tasks
identified
in
Section
B
of
this
chapter.
Incremental
costs
were
then
determined
by
subtracting
the
compliance
costs
associated
with
the
baseline
from
the
compliance
costs
for
each
reporting
option.

Figure
III­
1
provides
a
graphic
representation
of
the
allocation
of
IUR
Reporting
Costs
expected
under
the
proposed
amendments
in
relation
to
the
original
IUR.
The
relative
costs
for
industry
for
reporting
facility
and
manufacturing
information
and
use
and
exposure
information
are
presented
in
relation
to
the
expected
number
of
reports
at
the
10,000
pound,
25,000
pound,
and
100,000
pound
reporting
thresholds.
As
the
figure
indicates,
some
chemicals
that
are
originally
reported
under
the
IUR
(
those
with
a
production
volume
between
10,000
pounds
and
25,000
pounds)
would
not
be
required
to
report
under
the
proposed
IUR
amendments.
In
addition,
chemicals
manufactured
above
a
25,000
pound
threshold
would
be
required
to
report
additional
facility
and
manufacturing
information
and
those
above
a
100,000
pound
threshold
would
report
processing
and
use
information,
as
well
as
the
facility
and
manufacturing
information.

Other
aspects
of
the
industry
burden
calculation
are
as
follows:


all
industry
compliance
costs
are
incurred
in
the
year
in
which
reporting
occurs;


the
reporting
cycle
for
the
baseline
and
each
of
the
threshold
options
is
four
years;
and,


all
costs
are
presented
in
first­
quarter
1997
dollars,
costs
begin
to
be
incurred
in
1998,
and
are
analyzed
for
a
period
of
twenty
years
(
i.
e.,
only
compliance
costs
between
1998
and
2017
are
considered).

3.
Limitations
of
the
Industry
Burden
Analysis
There
are
a
number
of
uncertainties
that
result
from
the
approach
and
methodology
used
to
model
the
industry
costs
associated
with
the
IUR
amendments.
Some
of
these
uncertainties
lead
to
III­
51
Identification
of
Information
Reporting
Costs:

A:
Processing
and
use
information
reporting
costs
for
production
volumes
between
10,000
and
25,000
pounds.
These
costs
are
not
incurred
under
either
the
existing
or
amended
IUR
information
requirements.

B:
Additional
facility
and
manufacturing
information
reporting
costs
for
production
volumes
between
10,000
and
25,000
pounds.
These
costs
are
not
incurred
under
either
the
existing
or
amended
IUR
information
requirements.

C:
Baseline
reporting
costs
for
production
volumes
between
10,000
and
25,000
pounds
under
the
existing
IUR
requirements.
These
chemicals
are
excluded
from
reporting
under
the
amended
IUR
information
requirements.

D:
Processing
and
use
information
reporting
costs
for
companies
completing
the
partial
form.
These
costs
are
not
incurred
under
either
the
existing
or
amended
IUR
information
requirements
due
to
either
the
production
volume
(
under
100,000
lbs)
or
the
partial
exemptions.

E:
Facility
and
manufacturing
information
reporting
costs
for
companies
completing
the
partial
form.
These
costs
are
incurred
under
the
proposal
but
are
not
incurred
under
the
existing
IUR
information
requirements.

F:
Reporting
costs
for
companies
completing
the
partial
form
that
are
incurred
under
both
the
existing
and
the
amended
IUR
information
requirements.

G:
Processing
and
use
information
reporting
costs
for
companies
completing
the
full
form.
These
costs
are
incurred
under
the
proposal
but
are
not
incurred
under
the
existing
IUR
information
requirements.

H:
Facility
and
manufacturing
information
reporting
costs
for
companies
completing
the
full
form.
These
costs
are
incurred
under
the
proposal
but
are
not
incurred
under
the
existing
IUR
information
requirements.

I:
Reporting
costs
for
companies
completing
the
full
form
that
are
incurred
under
both
the
existing
and
the
amended
IUR
information
requirements.

Summary
of
Reporting
Costs:

Baseline
Costs:
C+
F+
I
Incremental
Costs
of
Proposed
Amendments:
E+
H+
G
Total
Reporting
Costs:
E+
F+
G+
H+
I
Savings:
C
Figure
III­
1
30
ICF.
1996.
Survey
for
Estimating
the
Industry
Burden
Associated
With
Collecting
Additional
Chemical
Use
Data
Under
TSCA
Section
8
(
IUR
Amendments).
OMB
Control
No.
2070­
0034.
Conducted
for
EPA
by
ICF
Incorporated,
Washington,
D.
C.

31
As
discussed
in
Appendix
D,
small
companies
were
identified
as
having
annual
sales
less
than
or
equal
to
$
40
million,
medium­
sized
companies
as
having
annual
sales
greater
than
$
40
million
and
less
than
or
equal
to
$
200
million,
and
large
companies
as
having
annual
sales
greater
than
$
200
million.

III­
52
overestimates
of
quantified
industry
costs.
The
following
points
discuss
some
uncertainties
that
could
significantly
impact
the
results
of
the
analysis:


The
analysis
may
overestimate
the
costs
of
compliance
for
smaller
companies.
According
to
the
survey30
(
see
Appendix
D),
the
average
cost
of
preparing
and
submitting
a
report
for
a
large
company
is
$
3,101
to
$
4,368,
for
a
medium
company
is
$
3,162
to
$
3,509
and
for
a
small
company
is
$
1,408
to
$
1,683.31
The
burden
estimates
for
completion
of
the
other
tasks
associated
with
compliance
may
also
be
more
appropriate
for
a
typical
large
company.
Large
companies
may
have
to
coordinate
various
levels
of
management
and
technical
personnel
to
prepare
the
required
information,
while
smaller
companies
are
likely
to
have
less
variation
in
their
chemical
output
and
use
and
a
more
contained
managerial
and
technical
staff.
Given
the
differences
between
small
and
large
companies,
the
unit
cost
estimates
presented
in
this
analysis
are
probably
somewhat
high
for
a
typical
small
company.


It
is
possible
that
the
cost
of
supplying
the
exposure
and
use
information
for
a
small
volume
chemical
with
few
uses
is
lower
than
for
a
large
volume
and
widely
used
chemical.
For
example,
if
compliance
costs
for
a
small­
use,
low­
volume
chemical
are
1/
3
of
the
compliance
costs
for
a
larger­
volume,
multi­
use
chemical,
a
substantial
drop
in
the
total
expected
costs
could
be
possible.
Although
this
analysis
attempts
to
account
for
this
by
scaling
the
burden
estimates
reported
in
the
industry
survey
according
to
company
size
categories,
the
average
unit
cost
of
compliance
presented
in
this
analysis
still
may
not
entirely
account
for
these
two
different
scenarios.


The
weighting
factors
that
have
been
applied
to
future
unit
costs
are
based
on
an
assumed
reduction
in
reporting
burden
in
future
reporting
cycles.
These
factors
may
be
high
if
information
for
many
of
the
reportable
chemicals
does
not
change
significantly
over
time,
resulting
in
overestimates
of
the
industry
reporting
burden.
Conversely,
these
factors
may
be
too
low
if
changes
to
the
industry
are
greater
than
expected
or
if
there
is
a
large
turnover
in
companies
reporting
or
chemicals
being
reported.


The
estimated
number
of
reports
in
future
reporting
cycles,
which
is
an
average
of
the
past
three
IUR
reporting
cycles,
may
be
an
overestimate.
The
number
of
reports
submitted
under
the
original
IUR
has
continually
decreased
slightly
from
reporting
cycle
to
reporting
cycle;
insufficient
data
exist
to
determine
if
this
decrease
will
continue.


Insufficient
data
exist
to
determine
how
many
sites
currently
subject
to
reporting
will
be
affected
by
the
proposal
to
remove
the
exemption
on
inorganic
chemicals.
It
is
assumed
that
in
response
to
this
change
there
will
be
an
increase
in
the
number
of
sites
reporting,
rather
than
an
increase
in
the
number
of
chemicals
reported
per
site.
This
assumption
may
overestimate
the
total
cost
of
the
rule,
but
underestimate
the
per
site
cost.


The
analysis
assumes
that
a
site
only
submits
one
type
of
report
(
i.
e.,
full
form
or
partial
form).
In
reality,
it
is
likely
that
sites
will
report
both
full
and
partial
forms.
This
assumption
may
significantly
over­
or
underestimate
the
costs
of
compliance
for
a
given
site,
depending
on
the
particular
mix
of
report
types.
III­
53
4.
Sensitivity
Analysis
Appendix
E
presents
a
detailed
sensitivity
analysis
that
varies
certain
assumptions
used
in
the
cost
analysis
to
assess
the
sensitivity
of
those
assumptions.
For
example,
changing
the
number
of
reports
completed
per
site
affects
the
costs
presented
for
the
proposed
option.
As
shown
in
Table
III­

29,
the
sensitivity
analysis
for
Scenarios
1a
and
1b
is
based
on
variations
in
the
assumed
number
of
reports
per
site.
For
these
scenarios,
incremental
costs
are
presented
only
in
terms
of
the
effect
on
per
site
costs.
In
addition,
Tables
III­
30
and
III­
31
present
the
impacts
on
incremental,
baseline,
and
total
net
present
value
and
annualized
costs
of
the
proposed
IUR
amendments
using
a
7
percent
instead
of
a
3
percent
discount
rate.
More
detail
on
the
basis
for
varying
the
discount
rate
is
provided
in
Appendix
E.

Table
III­
29.
Results
for
Sensitivity
Around
the
Number
of
Reports
per
Site
Scenario
Reports
Per
Site
Incremental
Cost
Per
Site
(
1997$)

Low
High
Proposal
8.4
Organic
Chemicals
$
21,169
$
27,112
Petroleum
Streams
$
5,780
$
10,407
Inorganic
$
24,878
$
32,526
Scenario
1a
1
Organic
Chemicals
$
3,790
$
4,747
Petroleum
Streams
$
1,958
$
2,758
Inorganic
$
4,533
$
5,849
Scenario
1b
20
Organic
Chemicals
$
48,412
$
62,171
Petroleum
Streams
$
11,769
$
22,397
Inorganic
$
56,771
$
74,343
III­
54
Table
III­
30.
Incremental
Net
Present
Values
and
Annualized
Costs
of
Amendment
Options
Discounted
at
Seven
Percent
(
million
1997$)

Option
Net
Present
Valuea
Annualized
Cost
Low
High
Low
High
Threshold
Options
Option
1
$
243.6
$
333.6
$
23.0
$
31.5
Option
2
$
203.0
$
277.5
$
19.2
$
26.2
Option
3
$
181.0
$
262.7
$
17.1
$
24.8
Option
4
$
165.1
$
234.6
$
15.6
$
22.1
Option
5
$
145.2
$
222.0
$
13.7
$
21.0
Option
6
$
129.3
$
194.0
$
12.2
$
18.3
Option
7
$
118.1
$
181.3
$
11.1
$
17.1
Option
8
$
91.0
$
150.6
$
8.6
$
14.2
Option
9
$
155.9
$
224.6
$
14.7
$
21.2
Reporting
Exemption
Options
Option
4
$
165.1
$
234.6
$
15.6
$
22.1
Option
10
$
189.1
$
258.4
$
17.8
$
24.4
Option
11
$
123.8
$
175.9
$
11.7
$
16.6
Reporting
Cycle
Options
Option
4
$
165.1
$
234.6
$
15.6
$
22.1
Option
12
$
226.2
$
347.1
$
21.4
$
32.8
Option
13
$
297.0
$
430.2
$
28.0
$
40.6
Option
14
$
44.8
$
61.1
$
4.2
$
5.8
Note:
1.
Option
4
is
the
proposed
option.
2.
Incremental
costs
may
not
calculate
exactly
due
to
rounding.
a
NPV
determined
for
a
20
year
period.
III­
55
Table
III­
31.
Total
Net
Present
Values
and
Annualized
Costs
of
IUR
Compliance,
with
Different
Amendment
Options
Discounted
at
Seven
Percent
(
million
1997$)

Option
Net
Present
Valuea
Annualized
Cost
Low
High
Low
High
Baseline
$
57.0
$
90.0
$
5.4
$
8.5
Threshold
Options
Option
1
$
300.6
$
423.6
$
28.4
$
40.0
Option
2
$
260.0
$
367.5
$
24.5
$
34.7
Option
3
$
238.0
$
352.7
$
22.5
$
33.3
Option
4
$
222.1
$
324.6
$
21.0
$
30.6
Option
5
$
202.2
$
312.0
$
19.1
$
29.4
Option
6
$
186.3
$
284.0
$
17.6
$
26.8
Option
7
$
175.1
$
271.3
$
16.5
$
25.6
Option
8
$
148.0
$
240.6
$
14.0
$
22.7
Option
9
$
213.0
$
314.6
$
20.1
$
29.7
Reporting
Exemption
Options
Option
4
$
222.1
$
324.6
$
21.0
$
30.6
Option
10
$
246.1
$
348.4
$
23.2
$
32.9
Option
11
$
180.8
$
265.9
$
17.1
$
25.1
Reporting
Cycle
Options
Option
4
$
222.1
$
324.6
$
21.0
$
30.6
Option
12
$
276.7
$
426.8
$
26.1
$
40.3
Option
13
$
347.5
$
509.9
$
32.8
$
48.1
Option
14
$
57.8
$
81.6
$
5.4
$
7.7
a
NPV
determined
for
a
20
year
period.
IV­
1
CHAPTER
IV.
AGENCY
COSTS
This
chapter
provides
an
analysis
of
the
costs
associated
with
the
proposed
amendments
to
the
Inventory
Update
Rule
(
IUR
amendments)
expected
to
be
incurred
by
EPA
for
establishing
and
maintaining
IUR
amendments
data.
The
activities
associated
with
the
proposed
IUR
amendments
and
the
attendant
costs
are
discussed
below.
The
remainder
of
the
chapter
is
organized
as
follows:


Section
A
outlines
the
approach
used
to
determine
Agency
costs,
including
a
description
of
the
methodology;


Section
B
discusses
the
tasks
and
develops
costs
attributable
to
requirements
under
the
original
IUR;


Section
C
discusses
the
tasks
and
incremental
costs
that
would
be
attributed
to
requirements
under
the
proposed
IUR
amendments;


Section
D
provides
an
estimate
of
total
expected
Agency
costs.

A.
Overview
and
Methodology
of
Determining
Agency
Costs
of
Reporting
This
section
describes
the
assumptions
and
general
methodology
employed
for
estimating
Agency
costs
associated
with
both
the
original
IUR
and
the
proposed
IUR
amendments.
The
expected
costs
include
costs
attributable
to
systems
development,
document
processing,
contract
oversight
and
management,
and
publication
of
forms
and
materials.
Costs
related
to
using
the
data
are
not
included.

The
following
methodology
for
developing
estimated
costs
for
both
the
original
IUR
and
proposed
IUR
amendments
was
used:

Step
1:
Identify
the
tasks
performed
for
both
the
original
IUR
and
the
proposed
IUR
amendments;

Step
2:
Determine
the
costs
for
each
activity
under
the
original
IUR
and
the
proposed
IUR
amendments;

Step
3:
Determine
the
estimated
total
costs
for
the
original
IUR
and
the
proposed
IUR
amendments.

In
addition,
it
should
be
noted
that
in
developing
the
cost
estimates
for
determining
Agency
burden,

activities
associated
with
one­
time
events
were
distinguished
from
costs
that
are
incurred
annually.

This
distinction
was
considered
throughout
the
discussion
of
individual
tasks
and
is
handled
directly
in
the
presentation
of
Agency
costs.
IV­
2
B.
Agency
Tasks
and
Costs
Under
the
Original
IUR
­
The
Baseline
This
section
describes
the
Agency
tasks
required
for
processing
submissions
under
the
original
IUR.

These
tasks,
described
below
in
Section
1,
include
database
systems
development,
Form
U
processing,

document
development,
and
mailings.
Section
2
presents
an
account
of
the
costs
incurred
by
the
Agency
for
each
identified
task.

1.
Description
of
Tasks
Associated
with
the
Original
IUR
The
tasks
associated
with
the
original
IUR
for
which
the
Agency
is
responsible
are
presented
under
four
main
categories:
database
systems
development,
guidance
document
development,
Form
U
processing,
and
additional
tasks.


Database
Systems
Development
and
Maintenance
­­
The
Agency
is
responsible
for
having
adequate
information
systems
in
place
to
support
the
Chemical
Update
System
(
CUS)
that
serves
as
the
primary
data
storage
medium
for
IUR
collections.
For
the
1994
collection
period,
the
Agency
incurred
capital
expenses
associated
with
redeveloping
CUS
for
operation
on
a
PC
LAN
environment,
replacing
the
CBI
Mainframe
environment
of
the
past.
Systems
development
is
a
one­
time
cost
for
the
original
IUR.

File
servers
with
appropriate
backup
are
used
to
contain
the
IUR
databases.
In
addition,
IUR
data
are
tracked
via
the
correspondence
tracking
system
utilized
by
the
Confidential
Business
Information
Tracking
System
(
CBITS)
located
within
the
Confidential
Business
Information
Center
(
CBIC).
Hence,
a
portion
of
the
CBIC
overhead
is
attributable
to
IUR.

The
Agency
has
plans
to
improve
the
quality
control
of
these
databases.
These
plans
range
from
the
development
of
computer
programs
to
check
information
against
previously
submitted
information
and
to
look
for
abnormalities
in
the
submitted
data
to
the
use
of
electronic
submissions
to
increase
the
speed
and
accuracy
of
adding
information
to
the
database.
The
cost
of
these
improvements
are
not
included
in
this
analysis
as
the
Agency
plans
to
make
these
changes
regardless
of
the
status
of
these
amendments.

Additional
costs
associated
with
recordkeeping
include
purchasing
and
maintaining
file
cabinets
and
office
space
to
store
accumulated
records.
Estimates
of
the
costs
attributable
to
these
activities
have
not
been
developed
because
costs
are
expected
to
result
from
both
original
IUR
and
IUR
amendments
requirements
and
because
these
costs
are
expected
to
be
small.


Guidance
Document
Development
­­
The
Agency
is
responsible
for
developing
guidance
for
the
IUR
to
assist
reporters
in
complying
with
IUR
requirements.
The
guidance
documents
usually
are
developed
by
a
contractor
with
oversight
by
Agency
personnel.
The
costs
associated
with
guidance
document
development
are
discussed
below
under
both
Extramural
Tasks
and
Tasks
Performed
by
Agency
Personnel.


Form
U
Processing
­­
The
Agency
is
responsible
for
handling
processing
of
IUR
submissions.
This
includes
developing
standard
operating
procedures
and
documentation
for
all
stages
in
the
IUR
document
life
cycle,
document
receipt
and
tracking,
data
input,
quality
control,
file
and
database
maintenance,
information
security,
CBI
aggregation
policy,
data
dissemination,
and
staff
training.
The
various
tasks
associated
with
document
processing
are
performed
by
both
Agency
personnel
and
contractors.


Additional
Activities
­­
The
Agency
undertakes
the
publication
and
printing
of
the
IUR
form
and
other
miscellaneous
materials.
In
addition,
the
Agency
is
responsible
for
providing
the
TSCA
*
One
time
costs
of
approximately
$
328,515
have
been
incurred
for
development
of
the
current
guidance
document,
development
of
the
current
database
systems,
and
hardware
and
software
expenses.
These
costs
are
not
part
of
the
baseline
annual
Agency
costs.

33
Based
on
an
additional
41
percent
of
the
salary
for
fringe
benefits
and
17
percent
of
the
salary
plus
fringe
benefits
for
overhead
(
U.
S.
EPA
1997a).

IV­
3
Hotline
with
standardized
responses
for
frequently
asked
questions;
preparing
mailings,
mailing
lists,
and
labels;
and
developing
outgoing
informational
materials.

2.
Costs
of
Tasks
Associated
with
the
Original
IUR
The
Agency
incurs
costs
associated
with
the
original
IUR
that
are
attributable
to
the
task
areas
described
above.
Costs
for
tasks
in
these
categories
can
be
divided
into
those
performed
by
Agency
personnel,
those
performed
by
contractors,
and
additional
tasks.
The
costs
associated
with
the
development
of
a
database
system
and
the
development
of
a
guidance
document
are
assumed
to
be
one­
time
costs32
that
have
already
been
incurred
by
the
Agency.

a.
Tasks
Performed
by
Agency
Personnel
To
estimate
the
cost
of
tasks
performed
by
Agency
personnel,
in
terms
of
full
time
equivalents
(
FTEs),
the
number
of
FTEs
and
the
GS­
level
required
to
perform
each
task
were
determined.
The
salary
rates
were
taken
from
Salary
Table
No.
96­
DCB
from
the
U.
S.
Office
of
Personnel
Management
(
OPM
1996).
The
salary
rates
are
presented
by
GS­
level
and
Step.
For
this
analysis,
a
Step
3
is
assumed
for
all
FTEs.

The
original
IUR
requires
one
FTE,
GS­
12
at
a
salary
of
$
47,423
to
perform
quality
control
of
data
entry.
One
FTE,
GS­
13
at
a
salary
of
$
56,392
is
required
to
perform
data
processing,
systems
development,
and
contract
oversight
&
management.
The
annual
cost
of
tasks
performed
by
Agency
personnel
sums
to
two
FTEs
for
a
total
of
$
103,815.
In
addition,
0.5
FTE,
GS­
13
at
a
salary
of
$
56,392
is
required
to
oversee
the
development
of
a
guidance
document
for
the
IUR.
The
cost
associated
with
this
task
is
a
one­
time
cost.
After
accounting
for
fringe
benefits
and
overhead,
agency
personnel
tasks
cost
$
171,264
annually,
with
one­
time
costs
of
$
46,515
(
IMD
1996a,
U.
S.
EPA
1996b).
33
b.
Extramural
Tasks
Extramural
tasks
are
described
as
those
performed
by
contractors.
Under
the
original
IUR,
annual
document
receipt
and
tracking
and
data
entry
costs
amount
to
$
40,000;
backup
systems
IV­
4
operations
costs
are
$
25,000,
annually.
Hence,
the
total
annual
costs
associated
with
extramural
tasks
for
the
original
IUR
are
equal
to
about
$
65,000.
In
addition,
hardware
and
software
costs,
systems
development,
and
the
development
of
a
guidance
document
for
the
original
IUR
represented
a
one­
time
cost
of
approximately
$
282,000
(
IMD
1996a,
U.
S.
EPA
1996b).

c.
Additional
Tasks
Additional
tasks
include
publication
and
printing
of
forms
and
materials,
provision
of
supplies
and
materials
for
the
hotline,
staffing,
and
costs
associated
with
mailings.
IUR
informational
materials
that
would
need
to
be
printed
include
guidance
documents,
policy
letters,
and
current
and
past
forms.
The
hotline
staff
(
contractor)
are
responsible
for
responding
to
phone
calls,
faxes,
letters,
and
email
regarding
questions
about
the
IUR
and
requests
for
materials.
In
addition,
the
hotline
staff
performs
all
activities
associated
with
mailing
requested
materials
and
bulk
mailings.

Under
the
original
IUR,
it
is
estimated
that
the
cost
of
publishing
forms,
developing
other
materials,

including
guidance
documents
and
policy
letters,
is
approximately
$
1,000
annually.
In
addition,

approximately
seven
percent
of
the
calls
received
and
handled
by
the
TSCA
hotline
can
be
attributed
to
the
IUR.
Therefore,
the
portion
of
hotline
costs
that
are
attributable
to
the
IUR
is
estimated
to
be
about
seven
percent
of
the
hotline
budget,
or
approximately
$
40,200,
annually.
Costs
associated
with
preparing
mailings
in
response
to
information
requests
under
the
original
IUR
are
approximately
$
400
annually.
This
cost
is
based
on
approximately
21
mailings
per
month
at
a
cost
of
$
1.50
each.

Therefore,
the
total
estimated
cost
for
provision
of
supplies
and
materials,
as
well
as
operation
of
the
hotline
to
handle
IUR
related
calls,
is
estimated
to
be
$
41,600
(
U.
S.
EPA
1996g,
U.
S.
EPA
1998b).

3.
Total
Baseline
Agency
Costs
Baseline
Agency
costs
are
divided
into
two
categories:
total
annual
costs
and
total
one­
time
costs.
The
total
one
time
costs
under
the
original
IUR
are
sunk
costs.
The
annual
costs
of
the
original
IUR
are
incurred
each
year
reports
are
submitted.
The
total
annual
costs
under
the
original
IUR
are
presented
in
Table
IV­
1.

The
total
annual
cost
associated
with
the
original
IUR
is
approximately
$
280,000.
This
cost
includes
the
cost
of
Agency
tasks
(
quality
control
of
data
entry,
data
processing,
systems
development,
IV­
5
Table
IV­
1.
Estimated
Annual
Costs
for
Determining
Agency
Costs
for
the
Original
IUR
Task
Original
IUR
Costs
Tasks
Performed
by
Agency
Personnel
Quality
Control
of
Data
Entry
$
78,234
(
1
FTE,
GS­
12)

Data
Processing,
Systems
Development,
and
Contract
Oversight
&
Management
$
93,030
(
1
FTE,
GS­
13)

Sub­
total
$
171,264
Extramural
Tasks
(
contractor)

Document
Receipt
&
Tracking
and
Data
Entry
$
40,000
Backup
Systems
Operations
$
25,000
Sub­
total
$
65,000
Additional
Tasks
Publication
and
Printing
Forms
&
Materials
$
1,000
Hotline
$
40,200
Mailing
$
400
Sub­
total
$
41,600
Total
Annual
Cost
$
277,864
Note:
All
costs
associated
with
FTEs
include
41
percent
fringe
benefits
and
17
percent
overhead.

Sources:
OPM
1996,
U.
S.
EPA
1997a,
IMD
1996a,
U.
S.
EPA
1996g,
U.
S.
EPA
1998b.

Table
IV­
2.
Estimated
One­
Time
Costs
for
Determining
Agency
Costs
for
the
Original
IURa
Task
Original
IUR
Costs
Tasks
Performed
by
Agency
Personnel
Guidance
Document
Development
$
46,515
(
0.5
FTE,
GS­
13)

Sub­
total
$
46,515
Extramural
Tasks
(
contractor)

Systems
Development
$
190,000
Hardware
&
Software
$
42,000
Guidance
Document
Development
$
50,000
Sub­
total
$
282,000
Total
One­
Time
Cost
$
328,515
Note:
All
costs
associated
with
FTEs
include
41
percent
fringe
benefits
and
17
percent
overhead.

a
Systems
development,
hardware/
software,
and
guidance
document
development
costs
under
the
original
IUR
are
considered
to
be
sunk
costs
and
are
not
included
in
the
estimates
of
total
costs
associated
with
the
original
IUR.
These
costs
are
presented,
however,
for
the
purposes
of
developing
incremental
costs
for
the
IUR
amendments
relevant
to
current
requirements.
These
one­
time
costs
total
$
328,515.

Sources:
U.
S.
EPA
1996b,
OPM
1996,
IMD
1996a,
U.
S.
EPA
1997a.
IV­
6
and
contract
oversight
and
management),
extramural
tasks
(
document
receipt
and
tracking,
data
entry,

and
backup
systems
operations),
and
additional
tasks
(
publication
and
printing
forms
and
materials,
the
hotline,
and
mailings).
The
total
one­
time
cost
of
$
328,515
is
attributable
to
guidance
document
development
and
costs
associated
with
systems
hardware
and
software,
as
presented
in
Table
IV­
2
(
IMD
1996a,
U.
S.
EPA
1996b).

C.
Agency
Tasks
and
Costs
Under
the
Proposed
IUR
Amendments
This
section
describes
the
Agency
tasks
required
for
processing
submissions
under
the
proposed
IUR
amendments.
These
tasks,
described
below,
include
database
systems
development,

Form
U
processing,
document
development,
and
mailings.
Section
2
presents
an
account
of
the
costs
incurred
by
the
Agency
for
each
identified
task.

1.
Description
of
Tasks
Associated
with
the
IUR
Amendments
The
tasks
that
must
be
performed
under
the
proposed
IUR
amendments
consist
largely
of
an
expanded
effort
for
tasks
already
undertaken
for
the
original
IUR.
Thus,
the
task
descriptions
presented
in
Section
B.
1
generally
do
not
change.
However,
the
magnitude
of
any
specific
task
may
change.
One
change
worthy
of
explanation
involves
database
systems
development
and
maintenance.

A
description
of
particular
modifications
required
by
the
IUR
amendments
is
provided
below:


Database
Systems
Development
and
Maintenance
­­
In
addition
to
the
tasks
identified
for
this
category
under
Section
B.
1,
the
IUR
amendments
would
require
that
the
database
be
expanded
to
handle
the
additional
reporting
requirements
of
the
IUR
amendments.
The
cost
estimate
for
the
IUR
amendments
accounts
for
further
expenses
associated
with
the
expansion
of
the
database
system.
Recreating
the
CUS
entails
the
following
tasks:

­­
procurement
of
new
hardware
and
software;
­­
contractor­
supported
programming
for
database
redesign;
­­
development
of
new
input
modules
to
facilitate
scanning
and
text
recognition
of
paper
versions,
these
include
a
manual
data
entry
module,
an
electronic
(
ASCII)
version
of
the
form,
and
subsequent
upload
modules;
­­
creation
of
retrieval
modules
that
standardize
reports;
and
­­
incorporation
of
CBI
protection
into
the
design
of
the
system.

A
change
in
the
magnitude
of
each
task
described
in
Section
B.
1
is
reflected
in
the
number
of
Agency
personnel
or
contractors
required
and/
or
in
the
incremental
cost.

2.
Incremental
Costs
of
Tasks
Associated
with
the
IUR
Amendments
IV­
7
This
section
describes
the
costs
associated
with
the
additional
tasks
performed
under
the
IUR
amendments.
Because
tasks
are
performed
by
both
Agency
personnel
and
contractors,
the
costs
are
organized
as:
tasks
performed
by
Agency
personnel,
extramural
tasks
performed
by
contractors,
and
additional
tasks
(
e.
g.,
hotline
administration
and
production
of
informational
materials).

a.
Tasks
Performed
by
Agency
Personnel
(
FTEs)

As
mentioned
in
an
earlier
section,
the
cost
of
tasks
performed
by
Agency
personnel,

in
terms
of
full
time
equivalents
(
FTEs),
was
estimated
using
the
number
of
FTEs
and
the
GS­
level
required
to
perform
each
task.
The
salary
rates
were
taken
from
Salary
Table
No.
96­
DCB
from
the
U.
S.
Office
of
Personnel
Management
(
OPM
1996).
The
salary
rates
are
presented
by
GS­
level
and
Step.
For
this
analysis,
a
Step
3
is
assumed
for
all
FTEs.

The
IUR
amendments
would
require
one
additional
FTE,
GS­
12
at
a
salary
of
$
47,423,
to
perform
quality
control
of
data
entry
and
an
additional
FTE,
GS­
13
at
a
salary
of
$
56,392,
to
perform
data
processing,
systems
development,
and
contract
oversight
and
management,
relative
to
the
original
IUR.
The
cost
of
tasks
performed
by
these
personnel
for
the
proposed
IUR
amendments
would
amount
to
incremental
salary
costs
of
$
103,815.
The
development
of
a
guidance
document
for
the
amended
IUR
would
require
0.5
FTE
at
a
salary
of
$
56,392.
This
cost
would
be
a
one­
time
cost.
Once
fringe
benefits
and
overhead
are
added,
this
represents
incremental
annual
costs
of
$
171,264
(
IMD
1996a,

U.
S.
EPA
1996b,
U.
S.
EPA
1997a).

b.
Extramural
Tasks
As
explained
in
Section
B.
2.
b,
extramural
tasks
are
described
as
those
performed
by
contractors.
For
the
proposed
IUR
amendments,
document
receipt
and
tracking
and
data
entry
would
increase
by
approximately
$
40,000;
backup
systems
operations
cost
would
double,
causing
an
incremental
cost
of
$
25,000.
Hence,
the
annual
incremental
costs
of
extramural
activities
for
the
IUR
amendments
is
estimated
to
be
about
$
65,000.
Compared
to
the
original
systems
development
and
hardware/
software
costs,
the
one­
time
costs
of
hardware
and
software
acquisition,
systems
development,
and
the
development
of
a
new
guidance
document
would
require
a
one­
time
incremental
cost
of
$
203,000.
This
incremental
cost
is
the
one­
time
cost
for
conducting
the
necessary
systems
and
IV­
8
hardware/
software
upgrades
to
handle
submissions
under
the
IUR
amendments
(
IMD
1996a,
U.
S.
EPA
1996b).

c.
Additional
Tasks
Additional
tasks
associated
with
the
proposed
IUR
amendments
include
publication
and
printing
of
forms
and
materials,
provision
of
supplies
and
materials
for
the
hotline,

staffing,
and
costs
associated
with
mailings.
IUR
informational
materials
that
would
need
to
be
printed
include
guidance
documents,
policy
letters,
and
current
and
past
forms.
As
with
the
original
IUR,
the
hotline
staff
(
contractor)
is
responsible
for
responding
to
phone
calls,
faxes,
letters,
and
e­
mail
regarding
questions
about
the
IUR
and
requests
for
materials.
In
addition,
the
hotline
staff
performs
all
activities
associated
with
mailing
requested
materials
and
bulk
mailings.

Under
the
proposed
IUR
amendments,
it
is
estimated
that
the
incremental
costs
of
providing
forms
and
materials
would
be
approximately
$
4,000.
In
addition
to
these
costs,
it
is
anticipated
that
the
costs
associated
with
operating
the
TSCA
hotline
to
handle
IUR­
related
calls
will
increase
by
$
30,000
in
the
first
year
of
reporting
under
the
proposed
amendments.
No
incremental
costs
are
expected
for
every
year
thereafter
because
it
is
estimated
that
the
annual
hotline
cost
associated
with
the
IUR
will
return
to
$
40,200
(
the
original
cost
of
this
activity
under
the
original
IUR).
The
cost
associated
with
preparing
mailings
under
the
IUR
amendments
is
estimated
to
increase
by
$
5,100
in
the
first
year,

based
on
approximately
3,400
more
mailings
than
the
original
IUR
at
$
1.50
each
for
a
peak
period
of
6
months
and
then
a
return
to
the
current
rate
of
mailings
for
the
remainder
of
the
year.
Thus,
the
annual
incremental
costs
of
preparing
mailings
under
the
proposed
IUR
amendments
is
estimated
to
be
zero
in
future
years.
Therefore,
the
incremental
costs
for
additional
tasks
under
the
IUR
amendments
is
approximately
$
4,000
annually
while
the
costs
estimated
for
the
first
reporting
year
are
$
39,100
(
U.
S.

EPA
1996g,
U.
S.
EPA
1998b).

3.
Incremental
Agency
Costs
of
the
Proposed
IUR
Amendments
Agency
costs
are
divided
into
two
categories:
total
annual
costs
and
total
one­
time
costs.
Under
the
proposed
IUR
amendments,
the
one­
time
costs
would
be
incurred
in
the
first
reporting
year.
The
annual
cost
would
be
incurred
for
every
year
thereafter.
The
total
annual
incremental
costs
under
the
proposed
IUR
amendments
are
presented
in
Tables
IV­
3
and
IV­
4.
34
The
values
in
Table
IV­
6
are
identical
to
the
values
in
Table
IV­
4,
because
the
baseline
one­
time
costs
are
considered
sunk
costs
and
are
not
included
in
the
calculation
of
total
one­
time
costs
under
the
amended
IUR.
Incremental
one­
time
Agency
costs
and
total
one­
time
Agency
costs
are
therefore
equal.

IV­
9
The
incremental
Agency
cost
associated
with
the
proposed
IUR
amendments
in
the
first
year
of
reporting
is
$
524,879
(
this
includes
the
one
time
costs
associated
with
the
amendments).
The
annual
incremental
cost
is
$
275,364.

D.
Total
Agency
Costs
The
total
annual
Agency
cost
associated
with
the
proposed
amended
IUR
is
estimated
to
be
approximately
$
550,000,
attributable
to
the
same
tasks
as
the
total
annual
costs
under
the
original
IUR.

The
total
first
year
cost,
including
one­
time
costs,
associated
with
the
proposed
IUR
amendments
is
estimated
at
approximately
$
802,743.
This
cost
would
be
incurred
in
the
first
year
of
reporting
under
the
amendments.
Total
Agency
costs
for
each
of
the
tasks
described
in
this
chapter
are
presented
in
Tables
IV­
5
and
IV­
6.34
IV­
10
Table
IV­
3.
Estimated
Incremental
Annual
Costs
for
Determining
Agency
Costs
for
the
Proposed
IUR
Amendments
Task
IUR
Amendment
Costs
Tasks
Performed
by
Agency
Personnel
Quality
Control
of
Data
Entry
$
78,234
(
1
FTE,
GS­
12)

Data
Processing,
Systems
Development,
and
Contract
Oversight
&
Management
$
93,030
(
1
FTE,
GS­
13)

Sub­
total
$
171,264
Extramural
Tasks
(
contractor)

Document
Receipt
&
Tracking
and
Data
Entry
$
40,000
Backup
Systems
Operations
$
25,000
Sub­
total
$
65,000
Additional
Tasks
Publication
and
Printing
Forms
&
Materials
$
4,000
Hotlinea
$
30,000
Mailinga
$
5,100
Sub­
total
$
39,100
Total
Annual
Cost
$
275,364
Note:
All
costs
associated
with
FTEs
include
41
percent
fringe
benefits
and
17
percent
overhead.

a
These
costs
are
the
costs
that
would
be
incurred
in
the
first
year
of
reporting
under
the
proposed
IUR
amendments.
No
incremental
costs
are
expected
for
these
tasks
in
subsequent
years.

Sources:
U.
S.
EPA
1997a,
OPM
1996,
IMD
1996a,
U.
S.
EPA
1996g,
U.
S.
EPA
1998b.

Table
IV­
4.
Estimated
Incremental
One­
Time
Costs
for
Determining
Agency
Costs
for
the
Proposed
IUR
Amendments
Task
IUR
Amendment
Costs
Tasks
Performed
by
Agency
Personnel
Guidance
Document
Development
$
46,515
(
0.5
FTE,
GS­
13)

Sub­
total
$
46,515
Extramural
Tasks
(
contractor)

Systems
Development
$
95,000
Hardware
&
Software
$
8,000
Guidance
Document
Development
$
100,000
Sub­
total
$
203,000
Total
One
Time
Cost
$
249,515
Note:
All
costs
associated
with
FTEs
include
41
percent
fringe
benefits
and
17
percent
overhead.

Sources:
U.
S.
EPA
1997a,
OPM
1996,
IMD
1996a,
U.
S.
EPA
1996b.
IV­
11
Table
IV­
5.
Estimated
Total
Annual
Agency
Costs
for
the
Amended
IUR
Task
Total
Amended
IUR
Costs
Tasks
Performed
by
Agency
Personnel
Quality
Control
of
Data
Entry
$
156,468
(
2
FTE,
GS­
12)

Data
Processing,
Systems
Development,
and
Contract
Oversight
&
Management
$
186,060
(
2
FTE,
GS­
13)

Sub­
total
$
342,528
Extramural
Tasks
(
contractor)

Document
Receipt
&
Tracking
and
Data
Entry
$
80,000
Backup
Systems
Operations
$
50,000
Sub­
total
$
130,000
Additional
Tasks
Publication
and
Printing
Forms
&
Materials
$
5,000
Hotlinea
$
70,200
Mailinga
$
5,500
Sub­
total
$
80,700
Total
Annual
Cost
$
553,228
Note:
All
costs
associated
with
FTEs
include
41
percent
fringe
benefits
and
17
percent
overhead.

a
These
costs
are
the
costs
that
would
be
incurred
in
the
first
year
of
reporting
under
the
proposed
IUR
amendments.
Costs
are
expected
to
be
equal
to
costs
under
the
original
IUR
in
subsequent
years.

Sources:
U.
S.
EPA
1997a,
OPM
1996,
IMD
1996a,
U.
S.
EPA
1996g,
U.
S.
EPA
1998b.

Table
IV­
6.
Estimated
Total
One­
Time
Agency
Costs
for
the
Amended
IUR
Task
Total
Amended
IUR
Costs
Tasks
Performed
by
Agency
Personnel
Guidance
Document
Development
$
46,515
(
0.5
FTE,
GS­
13)

Sub­
total
$
46,515
Extramural
Tasks
(
contractor)

Systems
Development
$
95,000
Hardware
&
Software
$
8,000
Guidance
Document
Development
$
100,000
Sub­
total
$
203,000
Total
One
Time
Cost
$
249,515
Note:
All
costs
associated
with
FTEs
include
41
percent
fringe
benefits
and
17
percent
overhead.

Sources:
U.
S.
EPA
1997a,
OPM
1996,
IMD
1996a,
U.
S.
EPA
1996b.
V­
12
CHAPTER
V.
IUR
AMENDMENTS
BENEFITS
ASSESSMENT
As
discussed
in
Chapter
II,
neither
EPA
nor
the
public
have
access
to
the
information
needed
to
effectively
and
accurately
identify
the
potential
risks
of
chemicals
in
production
or
use
in
the
United
States.
The
benefits
from
this
proposed
rule
stem
from
filling
this
information
void.
Some
of
the
benefits
are
immediate
­
information
is
provided
which
enables
EPA
and
others
to
identify
chemicals
of
potential
concern.
Some
of
the
benefits
are
in
the
future
­
once
the
chemicals
of
concern
are
identified,

EPA
or
others
must
take
additional
action
to
further
characterize
and
to
address
the
associated
risks,

thereby
garnering
the
benefits
associated
with
reducing
those
risks.

Effective
screening
of
human
health
and
other
risks
potentially
posed
by
chemicals
depends
critically
on
having
sufficient
information
to
characterize
a
chemical's
uses
and
to
predict
or
model
potential
exposure.
The
current
approach,
using
production
volume
information
supplemented
by
relatively
scarce
public
sources
of
information,
is
not
sufficient
for
identifying
chemical
exposures
and
human
risks,
even
at
the
screening
level.
EPA
expects
that
the
collection
and
compilation
of
additional
manufacturing,
processing,
use,
and
exposure
information,
when
combined
with
hazard
data,
will
provide
EPA
with
the
data
it
needs
to
conduct
effective
risk­
based
screening.
EPA
believes
that
a
better
compilation
of
use
and
exposure
data
will
enable
its
programs
to
more
accurately
predict
the
magnitude
and
nature
of
ecosystems
and
human
populations
potentially
exposed;
the
concentrations,
frequency,

and
duration
of
exposures;
and
a
host
of
other
specific
factors
related
to
potential
chemical
exposures.

With
the
additional
information,
EPA
will
be
able
to
pre­
screen
chemicals
to
identify
whether
additional
risk
screening
and
management
steps
may
be
needed.

Ultimately,
because
the
process
by
which
chemicals
enter
and
proceed
through
EPA's
risk
screening
programs
will
be
enhanced
by
the
availability
of
data
on
exposure,
EPA
expects
to
more
effectively
and
expeditiously
reduce
the
risks
posed
by
these
chemicals,
which
will
have
positive
consequences
for
human
and
ecosystem
health.

Additional
benefits
accrue
from
certain
changes
in
report
timing
and
information
elements
that
enhance
consistency
and
linkages
with
other
EPA
databases.
EPA
also
expects
a
reduction
in
the
number
of
CBI
claims
by
submitters,
more
accurate
chemical
tracking,
and
an
increased
ability
to
35
Databases
and
the
literature
sources
commonly
reviewed
by
EPA
are
described
in
Appendix
B.

V­
13
anticipate
industry
trends.
Finally,
the
proposed
removal
of
one
reporting
exemption
and
the
addition
of
other
partial
reporting
exemptions
are
expected
to
provide
an
increase
in
net
benefits
by
reducing
costs
more
than
any
benefits
are
reduced.
In
other
words,
benefits
associated
with
information
collected
on
the
partial
reporting
exemption
chemicals
is
expected
to
be
less
than
the
costs
associated
with
collecting
that
information,
therefore
resulting
in
an
increase
in
net
benefits.

The
social
benefits
resulting
from
the
proposed
amendments
are
qualitatively
discussed
in
this
chapter.
This
chapter
is
organized
as
follows:


Section
A
contains
a
review
of
the
benefits
associated
with
improving
EPA's
chemical
screening
accuracy
and
timeliness,
Section
B
focuses
on
the
benefits
of
less
frequent
CBI
claims,
Section
C
contains
an
analysis
of
the
benefits
associated
with
proposed
changes
in
certain
exemptions,
Section
D
focuses
on
certain
administrative
changes
and
related
benefits,

andSection
E
contains
a
brief
analysis
of
the
impact
of
each
specific
option
on
the
benefits
of
the
amendments.

A.
Benefits
from
Use
and
Exposure
Data
The
use
and
exposure
data
collected
through
these
amendments
will
fill
an
existing
information
void;
neither
the
EPA
nor
the
public
have
access
to
these
data.
35
Use
and
exposure
data
will
allow
EPA
to
improve
its
chemical
screening
process,
enabling
the
identification
of
chemicals
of
potential
concern
due
to
specific
uses
or
exposures,
the
earlier
identification
of
potentially
risky
chemicals,
and
a
more
effective
screening
process
and
chemical
management
program.
EPA
will
be
able
to
provide
the
public
with
any
non­
CBI
information
and
with
the
results
of
any
analyses.
The
public
will
get
risk
information
they
previously
did
not
have
­
and
they
will
get
it
sooner.

The
amended
IUR
data
will
allow
EPA
to
pre­
screen
chemicals,
allowing
a
quicker
and
more
comprehensive
risk
screening
to
occur.
In
addition,
because
better
data
will
be
available
for
the
prescreening
process,
EPA
will
be
able
to
effectively
target
the
chemicals
referred
to
a
more
detailed
screening
process,
thereby
reducing
the
number
of
more
detailed
reviews
that
result
in
chemicals
dropping
out
of
the
risk
management
process
due
to
a
low
level
of
concern.
Consequently,
appropriate
V­
14
chemicals
will
enter
EPA's
risk
management
programs
sooner,
enabling
EPA
to
disseminate
risk
information
to
the
public
that
they
otherwise
would
not
have
had
or
allowing
EPA
to
take
other
necessary
actions
to
reduce
the
incidence
of
morbidity
and
mortality
from
chemical
exposures.
In
addition
to
identifying
potential
risk
situations
in
a
more
effective
manner,
this
information
allows
EPA
to
operate
more
efficiently,
making
better
use
of
the
available
resources.
Not
only
will
better
targeting
of
projects
occur,
but
EPA
will
reduce
the
resources
spent
on
the
projects
which
do
not
lead
to
real
risk
reduction.

Other
risk
management
programs
and
activities
will
also
benefit
from
the
available
use
and
exposure
data.
Although
EPA
expects
that
OPPT
will
be
the
largest
user
of
the
data,
a
number
of
other
Federal,

state,
public
group,
and
industry
programs
will
benefit
from
the
information,
as
well.

Another
benefit
of
the
IUR
amendments
is
the
facilitation
of
database
linkages.
The
enhanced
facility
identification
information
and
the
changes
to
calendar
year
reporting
will
improve
the
ability
to
combine
IUR
data
with
other
information.
This
will
lead,
in
some
cases,
to
the
development
of
a
more
complete
picture
of
the
risks
posed
by
these
chemicals.
In
addition
to
identifying
risks,
EPA
will
be
able
to
use
the
use
and
exposure­
related
data,
combined
with
a
source
of
release
data
such
as
TRI,
to
check
the
validity
of
various
models.
This
will
allow
EPA
to
do
a
better
job
of
predicting
exposures
for
all
the
other
chemicals
that
do
not
have
exposure
data.
As
EPA
improves
its
use
of
data
and
improves
the
accuracy
of
its
exposure
predictions,
society
benefits
through
the
EPA's
use
and
dissemination
of
improved
information,
enabling
both
the
EPA
and
the
public
to
make
decisions
based
upon
that
improved
risk
information.

Another
benefit
of
the
IUR
amendments
is
the
reduction
in
the
number
of
CBI
claims.
Currently,

a
great
deal
of
the
information
reported
through
the
IUR
is
claimed
as
TSCA
CBI.
These
claims
restrict
the
usefulness
of
information
to
EPA
and
other
users.
Two
proposals
are
expected
to
reduce
the
number
of
CBI
claims.
The
proposed
up­
front
substantiation
requirement
forces
the
reporter
to
more
carefully
consider
the
facility
identification
CBI
claim.
The
proposed
production
volume
range
CBI
checkbox
allows
the
reporter
to
determine
if
the
production
volume
range
is
CBI,
separate
from
the
CBI
status
of
the
exact
production
volume.
The
third
proposal
reduces
the
amount
of
information
remaining
CBI
over
time.
The
proposed
reassertion
requirement
requires
the
reporter
to
review
past
CBI
claims
and
determine
if
they
are
still
valid.
If
CBI
protection
is
no
longer
required,
the
information
will
no
longer
be
treated
as
CBI.
These
changes
increase
the
amount
of
information
available
to
the
public
and
other
V­
15
users
and
gives
the
EPA
more
flexibility
in
its
use
of
the
information.
EPA
expects
that
the
remaining
CBI
claims
will
be
essential
and
will
address
real
concerns,
as
opposed
to
some
past
CBI
claims
that
were
based
more
on
habit
than
necessity.

The
following
sections
review
OPPT's
current
risk­
screening
programs
and
chemical
management
programs,
and
describe
the
benefits
these
programs
will
gain
from
the
enhanced
information.
They
also
describe
how
the
information
can
be
used
by
other
programs
and
other
agencies.

1.
Benefits
to
OPPT
Risk
Pre­
Screening,
Screening,
and
Management
Programs
OPPT
has
a
multifaceted
approach
to
managing
chemical
risks,
as
illustrated
in
Figure
V­
1.

Chemicals
enter
OPPT's
system
by
a
number
of
methods
­
pre­
screening
by
OPPT,
a
request
by
the
Interagency
Testing
Committee,
or
a
request
by
the
public.
The
chemicals
then
go
through
one
of
several
more
detailed
screening
programs,
such
as
the
RM1,
Master
Testing
List
(
MTL)
or
Use
Cluster
Scoring
System
(
UCSS)
programs.
Depending
on
the
outcome
of
these
screening
processes,
next
steps
may
include
entering
one
of
EPA's
risk
management
programs.
Each
of
these
phases,
and
the
benefits
derived
from
the
proposed
use
and
exposure
information,
are
examined
below.

a.
Expected
Use
of
Data
EPA
will
use
the
exposure
related
data
to
estimate
potential
exposures.
Some
of
the
ways
in
which
the
specific
information
collected
through
these
amendments
would
assist
in
the
risk
prescreening
screening,
and
management
processes
are
identified
below.
Additional
information
on
the
usefulness
of
this
information
can
be
found
in
the
EPA
report
entitled
"
Inventory
Update
Rule
(
IUR)

Technical
Support
Document:
Exposure­
Related
Data
Useful
for
Chemical
Risk
Screening,
Volume
I."


Number
of
Potentially
Exposed
Workers
­­
Estimates
of
the
number
of
workers
potentially
exposed
to
specific
chemicals
would
be
used
to
develop
worker
exposure
scenarios.
The
number
of
workers
is
combined
with
the
chemical
function,
the
chemical
form,
the
chemical
concentration,
and
other
information
to
develop
these
scenarios.


NAICS
Code
­­
The
NAICS
code
enables
EPA
to
sort
and
screen
information
by
industry
sector.
Specific
industry
sectors
often
have
particular
ways
in
which
they
handle,
use
or
manage
chemicals;
these
ways
affect
the
potential
for
exposures.
As
part
of
the
risk
screening
process,
EPA
can
also
identify
those
industries
which
might
be
good
candidates
for
pollution
prevention
and
control
activities.


Function
Code
­­
The
industrial
function
of
a
chemical
substance
can
be
an
important
indicator
of
potential
chemical
exposures
­
to
the
workers,
the
environment,
and
the
general
population.
It
will
also
be
useful
for
estimating
the
potential
frequency
and
duration
of
exposure.
V­
16

Known
Commercial
or
Consumer
End­
uses
­­
Information
on
the
use
of
chemicals
in
commercial
and
consumer
end­
use
categories
would
be
used
to
estimate
the
potential
exposure.
Generally,
these
populations
are
regarded
as
large
and
not
well
protected.


Maximum
Concentration
­­
Information
on
the
maximum
concentration
of
a
chemical
present
at
a
manufacturing
or
processing
site,
or
used
for
commercial
or
consumer
purposes,
would
be
used
to
estimate
the
potential
level
of
exposure.


Number
of
Sites
­­
Information
on
the
number
of
sites
where
a
chemical
is
manufactured
or
processed
will
provide
information
on
the
level
of
exposure
potential
for
workers
and
the
community
in
general.

b.
Benefits
to
Chemical
Risk
Screening
and
Management
Programs
OPPT
uses
a
number
of
tools
to
manage
and
evaluate
chemical
risk.
These
tools
include
various
levels
of
risk
screening
and
subsequent
management.
Risk
screening
involves
a
broad
look
at
potential
hazards,
exposures,
and
releases
based
on
production
volume,
patterns
of
use,

and
the
number
and
types
of
potentially
exposed
populations.
Risk
screening
is
less
detailed
and
focussed,
and
requires
less
data,
than
risk
assessment.
V­
17
Figure
V­
1.
Flow
of
Chemicals
Through
OPPT's
Screening
and
Risk
Management
Programs
Modes
of
Entrance
to
the
OPPT
Screening
System
OPPT
Pre­
screening
Interagency
Testing
Committee
Request
Public
Request
Risk
Management
Programs
Existing
Chemical
Review
Program
Design
for
the
Environment


Current
Screening
Programs
New
Chemical
Review
Program
Existing
Chemical
Review
Program
Master
Testing
List
Use
Cluster
Scoring
System
Environmental
Indicators
OPPT
uses
two
levels
of
screening
­
pre­
screening
and
screening,
as
depicted
in
Figure
V­
1.
In
these
efforts,
OPPT
currently
combines
hazard
(
when
known)
and
production
volume
information
to
evaluate
chemicals
for
risk.
By
using
production
volume
as
a
proxy
for
exposure,
however,
EPA
is
not
incorporating
other
factors
involved
in
determining
exposure.
These
factors
include
chemical
use,
the
number
of
potentially
exposed
workers
and
consumers,
the
number
of
use
sites,
chemical
concentration,

and
production
and
use
exposure
controls.
Consequently,
EPA
has
recognized
that
additional
data
including
detailed
information
on
exposure
scenarios
are
needed
to
adequately
pre­
screen
and
screen
V­
18
chemicals
on
the
basis
of
risk.
As
described
in
Box
V­
1,
the
proposed
IUR
amendments
will
allow
for
enhanced
information
collection,
thereby
benefitting
EPA's
chemical
risk
screening
programs
and
increasing
the
efficiencies
of
the
tools
used
in
these
programs.

Better
risk
screening
ultimately
generates
opportunities
for
improved
risk
management
by
EPA
and
other
entities.
Box
V­
1
also
presents
OPPT
risk
management
programs
that
might
benefit
from
the
greater
scope
and
depth
of
data
the
IUR
amendments
will
produce,
including
the
Existing
Chemical
review
process
and
various
pollution
prevention,
risk
reduction,
and
chemical
testing
programs,
such
as
the
Design
for
the
Environment
(
DfE),
and
the
Chemical
Testing
Program.
EPA
expects
that
the
exposure
data
collected
through
the
proposed
amendments
also
would
be
useful
to
a
variety
of
other
OPPT
programs
or
initiatives,
including
the
Source
Reduction
Review
Project,
§
8(
e)/
CAP
activities,
the
New
Chemicals
Program,
and
TSCA
§
9
referrals.

The
additional
data
generated
by
the
proposed
IUR
amendments
can
expedite
and
improve
risk
determinations
and
help
OPPT's
chemical
risk
screening
and
risk
management
programs
to
become
better
focussed
and
more
efficient.
Table
V­
1
summarizes
the
potential
benefits
to
EPA's
pre­
screening,

screening,
and
risk
management
programs
from
the
data
proposed
to
be
collected
under
the
IUR
amendments.
The
importance
of
each
information
element
to
each
of
the
programs
is
indicated
by
the
number
of
check
marks
in
the
table.
Agency
activities
could
achieve
risk
reductions
and
cost
savings
through:


more
rapid
identification
of
potentially
high
risk
situations,
and
more
effective
goal
setting
and
targeting
of
resources
in
regulatory
and
non­
regulatory
activities;
V­
19
Box
V­
1.
EPA
Tools
to
Evaluate
and
Manage
Chemical
Risk
Risk
Pre­
Screening.
OPPT
pre­
screens
chemicals
on
the
TSCA
Inventory
to
identify
potential
risks
and
determine
whether
more
detailed
screening
analyses
should
be
undertaken
through
the
RM1
program.
With
the
data
currently
available,
EPA
does
not
have
the
information
needed
to
effectively
and
systematically
pre­
screen
some
of
the
chemicals
on
the
inventory.
Data
collected
as
a
result
of
this
proposal
would
improve
the
Agency's
ability
to
provide
a
more
accurate
pre­
screen
of
chemicals
in
commerce,
allowing
the
Agency
to
focus
its
chemical
screening
programs
and
to
identify
risky
situations
earlier
than
otherwise
possible.
This
would
allow
EPA
to
expend
resources
more
efficiently
and
reduce
the
number
of
occasions
where
resources
are
allocated
for
assessment
of
chemicals
that
ultimately
pose
low
risk.

Existing
Chemicals
Review
Program.
The
Existing
Chemicals
review
program
conducts
detailed
analyses
of
high
risk
chemicals
and
develops
strategies
to
reduce
or
eliminate
the
exposure
risks.
Chemicals
are
first
screened
to
identify
those
that
(
1)
require
additional
testing,
(
2)
present
potentially
significant
risk­
management
concerns,
or
(
3)
do
not
currently
require
further
review.
Use
and
exposure
data
collected
through
the
proposed
IUR
amendments
would
contribute
to
this
risk
management
program
in
several
ways.
First,
improved
screening
prior
to
RM1
would
lead
to
a
quicker
identification
of
chemicals
of
concern
and
more
appropriate
entry
into
EPA's
chemical
management
programs.
Second,
the
proposed
IUR
amendments
would
provide
readily
obtainable
initial
use
and
exposure
information
for
these
chemicals,
significantly
improving
the
efficiency
and
effectiveness
of
RM1
screening.
Finally,
by
effectively
weeding
out
the
lower
risk
chemicals
sooner,
EPA
would
be
able
to
focus
efforts
on
higher
risk
chemicals.

Environmental
Indicators.
The
OPPT
has
created
a
computer
model
that
can
trace
the
potential
impacts
of
Toxic
Release
Inventory
(
TRI)
chemical
emissions
on
human
health
and
the
environment.
The
model
can
aid
in
the
identification
of
chemicals
of
significant
risk.
The
Indicators
reveal
how
the
impacts
of
the
TRI
chemical
releases
change
each
year.
Factors
considered
in
the
model
include
TRI
release
and
transfer
volumes,
chronic
toxicity,
exposure
potential,
and
affected
populations.
The
proposed
IUR
amendments
would
provide
another
source
of
the
chemical
data
that
are
used
by
the
model
to
determine
outputs
such
as
pounds
of
release
and
surrogate
exposure.

Use
Cluster
Scoring
System
(
UCSS).
The
Use
Cluster
Scoring
System
(
UCSS)
identifies
potential
risks
of
chemical
substances
used
in
similar
applications,
or
"
use
clusters."
This
system
enables
the
Agency
to
view
the
risks
of
a
given
chemical
substance
in
the
context
of
the
risks
presented
by
related
products
on
the
market
and
allows
the
Agency
to
establish
regulatory
review
priorities
for
those
use
clusters.
However
some
of
the
UCSS
data
sources
are
outdated
and
estimating
methodologies
are
speculative.
The
proposed
amendments
would
create
a
database
providing
additional
information
that
would
allow
the
Agency
to
provide
more
accurate
screening
level
estimates
for
use
clusters,
targeting
Agency
programs
to
areas
currently
needing
attention.
It
will
also
enable
the
Agency
to
more
easily
conduct
broader
chemical
screening
analyses
across
several
industries.

Existing
Chemicals
Testing.
TSCA
§
4
empowers
EPA
to
require
manufacturers
and
processors
of
chemicals
to
test
the
chemicals
they
manufacture
and
process
to
obtain
hazard
data
necessary
to
assess
the
chemical's
risks.
EPA
must
make
findings
under
either
§
4(
a)(
1)(
A)
("
A"
finding)
or
§
4(
a)(
1)(
B)
("
B"
finding)
before
testing
may
be
required
of
a
manufacturer
or
processor.
The
A
finding
permits
EPA
to
require
testing
on
a
"
may
present"
risk
basis;
the
B
finding
can
be
made
on
an
exposure
basis.
For
the
B
finding,
use
and
exposure
data
would
be
a
critical
input
when
no
hazard
data
are
available
to
indicate
a
chemical's
toxicity.
In
addition,
OPPT
uses
the
Master
Testing
List
(
MTL)
of
chemicals
identified
by
the
Agency
as
having
inadequate
data
for
health
and/
or
environmental
risk
assessments.
OPPT
uses
the
MTL
to
establish
priorities
for
chemical
testing,
keep
the
public
informed,
and
solicit
input
from
industries
on
specific
chemical
exposure
and
risk
assessment
needs
and
encourage
them
to
perform
testing.
IUR
data
would
facilitate
these
efforts
by
targeting
testing
needs
to
situations
in
which
potential
risky
exposures
are
known
to
occur,
thereby
increasing
the
efficiency
of
efforts
in
these
programs
and
facilitating
earlier
completion
of
critical
testing
needs.

Screening
Information
Data
Set
(
SIDS).
SIDS
is
a
voluntary
program,
conducted
under
the
auspices
of
the
OECD,
which
allows
member
countries
to
share
the
burden
of
testing
internationally
traded
large
production
volume
chemicals.
The
U.
S.
is
responsible
for
testing
of
25
percent
of
the
chemicals
identified
for
the
Program.
The
information
needed
is
collected
by
industry
sponsors,
however
the
data
elements
collected
may
not
be
consistent
across
sponsors,
and
some
companies
may
not
participate
in
developing
information.
The
proposed
amendments
would
provide
many
key
needs
for
exposure
data
and
would
provide
a
consistent
database
of
information
from
manufacturers
and
importers.
This
information
would
increase
the
program's
efficiency
by
helping
to
identify
chemicals
requiring
additional
testing
or
assessment
while
excluding
those
with
low
domestic
exposure.
A
better
exposure
database
would
also
improve
evaluation
of
potential
risk
in
the
assessment
reports
prepared
at
the
end
of
the
SIDS
process.

Design
for
the
Environment
(
DfE).
The
Design
for
the
Environment
(
DfE)
program
incorporates
principles
and
strategies
from
both
the
Existing
Chemicals
review
program
and
the
UCSS,
by
focusing
on
specific
chemical
uses
and
establishing
partnerships
with
industry
to
develop
voluntary
long­
range
plans
for
risk
management.
The
exposure­
related
data
collected
through
the
proposed
IUR
amendments
would
help
to
identify
use
cluster
candidates
for
this
program.
It
would
also
provide
the
initial
assessment
of
exposures
and
help
identify
potential
substitutes,
and
could
be
used
to
assist
in
ranking
activities,
identifying
high
risk
areas,
and
developing
realistic
approaches
for
reducing
risk.
V­
20

identification
of
potentially
high
risk
situations
which
otherwise
might
not
be
identified;


rapid
deployment
of
resources
to
initiate
or
expand
pollution
prevention
efforts
in
the
private
sector;


timely
and
effective
identification
and
development
of
safer
substitutes
and
alternative
chemicals,
processes,
and
technologies;


development
of
more
complete
data
for
public
use;
and

identification
of
opportunities
to
avoid
costly
regulatory
analyses
or
rulemakings
by
developing
voluntary
agreements,
by
delegating
authority
to
state
governments
for
situations
in
which
high
risk
exposures
are
limited
to
a
few
sites
or
a
single
site,
or
by
engaging
other
regulatory
agencies
such
as
OSHA,
CPSC,
and
DOT
to
control
risks
that
they
are
best
able
to
address.

Table
V­
1.
Benefits
to
Existing
OPPT
Programs
of
Chemical
Processing
and
Use
Information
Collected
under
the
Proposed
IUR
Amendmentsa
Program
Chemical
ID
Company
ID
Industrial
Processing
and
Use
Information
End­
Use
Data
Exposure
Data
Production
Volume
and
Import
Data
RM1
Process








Use
Cluster
Scoring
System
(
UCSS)








Design
for
the
Environment
(
DfE)










Master
Testing
List
(
MTL)










Screening
Information
Data
Set
(
SIDS)










Existing
Chemicals
Review
Program









Other
Federal
Risk
Management
Programs












State
and
Local
Programs






Responsible
Care










a
One
check
in
the
box
signifies
that
the
information
is
important,
two
checks
indicate
that
the
data
are
critical.

c.
Illustrative
Quantitative
Assessment
of
Benefits
From
Processing
and
Use
Data
The
primary
benefit
of
the
new
use
and
exposure­
related
information
is
derived
from
OPPT's
ability
to
facilitate
pre­
screening
activities
for
chemicals
that
may
require
intervention
to
mitigate
risks.
The
information
also
benefits
downstream
risk
screening
and
management
activities
under
RM1
and
other
programs.
The
sections
below
provide
a
qualitative
and
quantitative
assessment
of
how
the
proposed
information
collection
would
improve
the
efficiency
and
outcome
of
these
programs.
V­
21
i.
More
Rapid
and
Effective
Pre­
screening:
Real
Resource
Savings
As
described
in
Section
b
above,
pre­
screening
of
chemicals
is
an
essential
first
step
in
determining
priorities
for
more
detailed
risk
screening
and
later
risk
management
activities.
The
proposed
rule
will
make
the
process
by
which
chemicals
enter
EPA
screening
and
management
programs
more
effective
and
rapid.
By
eliminating
from
consideration
chemicals
that
pose
lesser
risks,
EPA
can
focus
resources
on
chemicals
posing
higher
risk.
More
effective
pre­
screening
of
chemicals
will
not
only
prioritize
the
chemicals
entering
screening
and
risk
management
programs,
but
will
also
better
target
the
resources
devoted
to
these
activities,
as
described
below.

Equally
important,
the
information
on
uses
and
exposures
will
allow
EPA
to
make
determinations
for
some
chemicals
for
which
determinations
currently
are
not
possible.
Because
of
the
paucity
of
data,

these
chemicals
are
never
identified
for
later
risk
screening
or
management
activities,
nor
are
they
eliminated
from
consideration.
These
chemicals
pose
the
greatest
obstacle
for
EPA
because
no
action
is
possible.
By
making
available
the
use
and
exposure
information
proposed
under
the
IUR
amendments,
OPPT
can
make
pre­
screening
determinations
for
these
chemicals
and
thereby
identify
potential
risk
concerns
to
human
health
and
the
environment.

The
resources
that
could
be
saved
by
improving
the
pre­
screening
process
and
thereby
reducing
the
number
of
chemicals
entering
the
screening
process
can
be
roughly
estimated
by
examining
the
TSCA
Inventory
and
screening
needs.
The
Inventory
and
Inventory
Update
processes
provide
production
volume
information
for
chemicals
that
is
then
used
to
screen
chemicals
for
exposure
risks.

Based
on
these
data,
EPA
has
been
able
to
determine
that
further
information
is
not
needed
at
this
time
for
a
large
portion
of
the
75,000
chemicals
on
the
TSCA
Inventory.
However,
for
about
ten
to
fifteen
percent
of
those
chemicals,
additional
information
is
required
to
adequately
assess
the
potential
risks
at
a
screening
level.
This
proposed
amendment
will
collect
manufacturing
level
information
on
8,900
of
these
chemicals
and
detailed
use
and
exposure
for
approximately
6,000
of
these
8,900
chemicals.

By
allowing
EPA
to
pre­
screen
these
chemicals
more
effectively,
the
proposed
IUR
would
reduce
the
number
of
chemicals
entering
screening
processes
(
including
RM1)
and
thereby
reduce
the
resources
required
to
screen
and
evaluate
chemicals.
Assuming,
as
per
Box
II­
4
(
See
Chapter
II),
that
these
activities
require
100
hours
per
chemical,
reducing
the
number
of
chemicals
that
enter
the
screening
process
could
result
in
savings
of
many
FTEs,
over
time.
For
example,
if,
as
a
result
of
the
V­
22
prescreening
due
to
this
new
information,
the
number
of
chemicals
entering
RM1
is
reduced
from
6,000
to
3,000,
savings
of
300,000
hours
or
144
FTEs
would
result.
In
addition,
savings
in
extramural
(
contract)
dollars
and
savings
in
industry
costs
(
due
to
EPA
not
contacting
industry
to
determine
information
on
those
3,000
chemicals)
would
also
be
realized.
The
resources
required
to
conduct
both
the
pre­
screening
and
the
RM1
screening
on
a
per
chemical
basis
will
fall
as
a
result
of
the
proposed
rule,
thus
further
conserving
government
resources.
Even
after
the
prescreening
step,
it
is
unlikely
that
these
remaining
3,000
chemicals
of
significant
risk
would
complete
a
screening
in
the
near
future,

considering
that
the
present
rate
of
review
is
approximately
100
chemicals
per
year.
It
would
take
30
years
for
3,000
chemicals
to
enter
and
complete
the
RM1
process.
The
use
and
exposure
information
available
under
the
proposed
IUR
amendments
would
accelerate
this
process.
In
the
absence
of
the
prescreening
step,
the
original
6,000
chemicals
would
not
receive
a
detailed
evaluation
within
a
feasible
time
period.

ii.
More
Rapid
and
Effective
RM1
Screening:
Time
Savings
EPA
established
the
TSCA
Inventory
and,
subsequently,
the
Inventory
Update
process
to
collect
production
and
facility
information
on
chemical
substances
in
support
of
EPA's
efforts
to
satisfy
TSCA
requirements
of
protecting
human
health
and
the
environment.
The
information
collected
through
these
programs
is
central
to
EPA's
efforts
to
screen
chemical
substances
to
identify
those
that
might
pose
unreasonable
risks,
ultimately
supporting
EPA's
efforts
to
mitigate
those
risks
using
a
variety
of
regulatory
and
non­
regulatory
mechanisms.

The
time
and
effort
required
to
collect
and
process
data
or
to
develop
exposure
estimates
will
also
be
reduced
with
the
availability
of
information
proposed
to
be
collected
under
the
IUR
amendments.

EPA
will
also
be
able
to
conserve
resources
and
focus
efforts
on
chemicals
that
potentially
pose
higher
risks.
Under
the
amendments,
EPA
will
be
prescreening
reported
chemicals
with
production
levels
above
25,000
pounds
every
four
years.
At
each
data
collection,
the
top
100
chemicals
with
the
greatest
potential
for
risk
can
be
subject
to
more
indepth
evaluation.
Between
data
collections,
EPA
will
examine,

at
minimum,
the
top
400
chemicals
with
potential
for
risk.
The
frequency
of
reporting
cycles
under
the
proposed
amendments
allows
EPA
to
track
changes
in
the
usage
of
high
priority
chemicals.
This
approach
offers
advantages
over
a
one­
time
data
collection
and
certainly
provides
better
information
V­
23
than
relying
on
previously
collected
chemical
use
data
that
may
be
outdated.
The
potential
magnitude
of
the
benefits
of
more
rapid
screening
and
risk
reduction
resulting
from
IUR
reporting
under
the
amendments
can
therefore
be
illustrated
using
the
RM
process
as
an
example.
Between
1990
and
1994,

1,924
chemicals
were
identified
as
candidates
for
the
RM
process
and
561
chemicals
proceeded
through
RM1­­
an
average
of
112
chemicals
annually.
It
is
reasonable
to
assume
that
a
similar
number
of
chemicals
will
be
reviewed
in
future
years
if
the
IUR
is
not
amended.

As
in
the
case
of
pre­
screening
activities,
there
would
be
government
resource
savings
associated
with
the
facilitated
and
more
rapid
review
of
chemicals
that
do
enter
the
process.
Moreover,

the
additional
use
and
exposure
data
would
facilitate
subsequent
risk
management
activities
as
well,

potentially
allowing
EPA
to
keep
pace
with
the
increased
outflow
from
RM1
decisions.
Consequently,

throughout
the
pre­
screening,
screening,
and
risk
management
processes,
EPA
would
be
able
to
make
better,
more
efficient
use
of
public
dollars
in
OPPT
programs.

iii.
More
Rapid
and
Effective
RM1
Screening:
Potential
Lives
Saved
By
speeding
up
the
process
by
which
chemicals
are
screened
and
evaluated
through
the
risk
reduction
process,
the
additional
use
and
exposure
information
could
result
in
human
and
ecosystem
risk
reductions
occurring
years
earlier,
with
concomitant
reductions
in
mortality,

morbidity,
and
ecosystem
damages.

Based
on
the
above
discussion,
it
appears
reasonable
that,
as
a
result
of
the
proposed
IUR
reporting
rule,
risk
management
processes
at
EPA
could
result
in
real
reductions
in
mortality,
morbidity,

and
ecosystem
damages
because
results
would
be
available
many
years
earlier
than
otherwise.

Because
the
ultimate
outcome
of
the
chemicals
to
be
evaluated
or
managed
in
EPA's
screening
and
risk
management
programs
in
the
future
is
unknown,
it
is
difficult
to
translate
the
benefits­­
in
terms
of
a
more
rapid
process­­
into
a
quantitative
estimate
of
lives
saved,
illnesses
averted,
or
ecosystem
damages
avoided.
Moreover,
risk
management
activities
result
in
both
costs
and
benefits
to
society.
Thus,
in
addition
to
improving
the
effectiveness
and
timeliness
of
screening,
the
downstream
benefits
of
the
proposed
IUR
are
the
net
benefits
of
risk
management
activities
that
occur
sooner
than
they
would
have
occurred
in
the
absence
of
the
rule.
V­
24
Ideally,
the
net
benefits
of
the
proposed
rule
would
be
assessed
in
several
steps.
The
first
step
is
to
determine
the
likely
outcomes
of
risk
management
activities
that
might
be
undertaken
in
the
absence
of
the
proposed
rule,
and
the
annual
costs
(
in
terms
of
industry
actions)
and
benefits
(
in
terms
of
lives
saved
and
other
environmental
and
health
benefits,
such
as
reduced
morbidity)
associated
with
these
activities.
This
step
would
produce
a
measure
of
present
value
net
benefits
associated
with
risk
management
activities,
in
the
absence
of
the
proposed
rule.
The
second
step
is
to
duplicate
the
present
value
net
benefit
calculation,
but
assume
that
risk
management
activities
occur
earlier
under
the
proposed
rule
than
they
would
occur
in
its
absence.
The
third
step
is
to
calculate
the
incremental
benefit
of
earlier
risk
management
activities
that
occur
under
the
proposed
rule,
i.
e.,
the
difference
between
present
value
net
benefits
calculated
with
and
without
the
proposed
rule.
This
incremental
benefit
results
from
the
additional
years
of
risk
management
activities
that
occur
because
the
activities
begin
earlier.

Finally,
the
net
benefits
of
the
proposed
rule
would
be
calculated
by
subtracting
the
present
value
of
the
costs
of
the
rule
from
the
incremental
benefits
of
earlier
risk
management
activities.

Data
limitations,
however,
make
this
ideal
approach
difficult
to
implement.
In
particular,
it
is
difficult
to
assess
what
the
net
benefits
would
be
of
any
activities
to
address
or
mitigate
risks
subsequent
to
the
screening
activities.
Although
a
number
of
existing
chemical
rules
have
been
promulgated
under
TSCA
or
other
authorities
(
e.
g.,
EPCRA),
and
other
programs
such
as
DfE
are
ongoing,
it
is
difficult
to
generate
an
estimate
of
net
benefits,
or
even
non­
monetized
reductions
in
morbidity
and/
or
mortality,
per
chemical
addressed.
Furthermore,
not
all
chemicals
that
enter
the
risk
management
process
ultimately
warrant
actions
to
reduce
risks.
For
both
these
reasons,
it
is
difficult
to
quantify
the
net
benefits
that
are
likely
to
result
from
any
risk
management
activities
that
could
be
accelerated
by
the
proposed
rule.

2.
Benefits
to
Non­
OPPT
Risk
Management
Programs
In
addition
to
OPPT,
other
public
and
private
organizations
are
actively
involved
in
managing
chemical
risks.
These
include
other
EPA
programs,
the
Consumer
Product
Safety
Commission
(
CPSC),
the
National
Institute
of
Occupational
Safety
and
Health
(
NIOSH),
the
Occupational
Health
and
Safety
Administration
(
OSHA),
Department
of
Defense
(
DoD),
state
and
local
governments,
and
the
private
sector.
Given
the
large
number
of
chemicals
and
potential
exposure
scenarios
at
the
industrial,
occupational,
and
consumer
level,
these
organizations
also
require
more
complete
use
and
exposure
information
to
effectively
and
efficiently
manage
chemical
risks.
Because
of
V­
25
CBI
claims,
not
all
of
the
information
will
be
available
to
these
other
potential
users.
This
is
mitigated,
in
part,
by
proposals
in
the
amendments
to
change
CBI
reporting
such
that
the
Agency
expects
a
decrease
in
the
number
of
CBI
claims,
thereby
enabling
EPA
to
provide
a
greater
amount
of
the
information
to
these
various
stakeholders.
In
addition,
EPA
will
provide
analyses
of
the
amended
IUR
information
and
anticipates
that
other
organizations
will
use
the
results.
Through
efforts
made
by
these
various
stakeholders,
the
data
to
be
collected
under
the
proposed
IUR
amendments
could
reduce
risks
and
costs
to
society
in
addition
to
the
reductions
gained
by
the
programs
conducted
by
OPPT.

a.
Other
Federal
Risk
Management
Programs
Federal
efforts
other
than
OPPT's
would
benefit
from
new
exposure
information
for
IUR
chemicals.
For
example,
OSHA
currently
manages
occupational
exposure
to
chemicals
by
setting
a
variety
of
chemical
and
personal
protection
standards,
by
requiring
preparation
of
emergency
response
and
process
safety
management
plans,
and
by
requiring
provision
of
health
and
safety
data
to
workers
for
chemicals
used
in
the
workplace.
OSHA
would
be
able
to
use
the
amended
IUR
data
to
identify
chemicals
with
large
numbers
of
potentially
exposed
workers
or
with
uses
that
suggest
greater
exposure
potential.
The
amended
IUR
information
could
increase
OSHA's
ability
to
manage
chemical
hazards,
exposures,
and
risks
in
occupational
settings.

NIOSH
would
also
benefit
from
the
updated
exposure­
related
information
collected
under
the
IUR
amendments.
Currently,
the
exposure
information
that
NIOSH
uses
to
determine
occupational
safety
and
health
in
businesses
nationwide
is
primarily
based
on
outdated
information
collected
under
the
National
Occupational
Exposure
Survey
(
NOES).
Completed
in
1983,
NOES
collected
information
such
as
plant
site
location,
plant
site
SIC,
information
on
the
plant
site's
occupational
safety
and
health
programs,
occupational
titles
of
workers
potentially
exposed,
the
number
of
employees
per
occupational
title,
information
on
process
steps,
and
trade
names
of
products.
Amended
IUR
data
could
be
used
by
NIOSH
in
place
of
the
NOES
data
to
identify
chemicals
with
large
numbers
of
potentially
exposed
workers
or
with
uses
that
suggest
greater
exposure
potential.

CPSC
also
could
directly
use
the
proposed
data
in
conducting
its
exposure
and
risk
assessment
activities
­­
screening
consumer
products
for
chemical
hazards.
The
primary
risk
information
used
by
CPSC
to
screen
chemical
hazards
is
information
obtained
from
a
network
of
hospital
emergency
rooms,

and
this
is
limited
to
injuries
and
illnesses
resulting
from
acute
exposures
only.
Information
identifying
V­
26
the
chemicals
used
in
consumer
products
is
not
readily
available
to
CPSC
at
this
time.
The
IUR
amendments
would
provide
a
source
of
reliable
information
on
the
chemicals
used
in
consumer
products,
enabling
CPSC
to
identify
the
chemicals
used
in
consumer
products
and,
with
consideration
of
hazard
data,
to
identify
chemical­
consumer
use
situations
presenting
greater
potential
risk.
The
information
could
improve
CPSC's
ability
to
meet
its
program
objective
of
protecting
the
public
from
chemical
hazards
in
consumer
products.

b.
State
and
Local
Programs
The
proposed
IUR
amendments
data
would
also
help
state
and
local
authorities
with
rulemaking,
information
collection,
and
voluntary
program
activities.
Because
state
and
local
governments
must
address
chemicals,
use
patterns,
and
exposure
scenarios
that
may
be
unique
or
isolated,
state
and
local
agency
access
to
the
enhanced
data
would
assist
in
identifying
situations
that
pose
potentially
high
risks
for
individual
states
or
locations
within
those
states.
The
information
added
to
the
IUR
includes
county
data,
which
would
enable
states
to
identify
which
counties
are
likely
to
have
specific
issues
or
which
counties
may
have
multiple
chemical
problems.
The
additional
data
also
could
be
used
to
assist
with
setting
goals,
targeting
actions,
and
developing
or
expanding
pollution
prevention
activities.
Several
state
environmental
protection
agencies,
including
those
in
Illinois,
Georgia,

California,
and
New
Jersey,
have
expressed
interest
in
having
access
to
data
collected
by
OPPT
and
to
results
of
risk
screening
conducted
by
OPPT.

c.
Non­
Governmental
Organization
(
NGO)
Initiatives
and
Private
Sector
Stewardship
Many
private
sector
organizations
proactively
reduce
risks
and
provide
leadership
in
preventing
pollution
while
still
maintaining
productive
economic
enterprises.
These
organizations
can
improve
their
programs
by
developing
a
better
understanding
of
how
chemicals
are
used
in
general,
thus
encouraging
more
effective
participation
in
community,
regional,
and
national
priority
setting
for
chemicals.
Activities
typically
undertaken
by
NGOs
involve
tracking
industry
trends,

organizing
grassroots
involvement
in
risk­
based
decision
making,
and
conducting
outreach
and
educational
programs.
The
proposed
data
could
be
used
by
these
organizations
to
identify
and
establish
priorities
for
risks,
to
evaluate
chemicals
and
chemical
use
patterns
to
determine
areas
of
concern,
to
V­
27
identify
and
promote
pollution
prevention
opportunities,
and
to
focus
pollution
prevention,
public
outreach,
and
education
initiatives
and
activities.

Industry
can
use
the
amended
IUR
information
to
improve
corporate
product
stewardship
programs
through
access
to
use
information
reported
by
multiple
companies.
The
Chemical
Manufacturers
Association's
(
CMA)
Responsible
Care
Program
is
one
example
of
a
corporate
product
stewardship
program
that
could
use
this
information.
Currently,
the
CMA
cites
"
emission
reductions
as
measured
by
TRI"
and
a
growth
in
the
number
of
Community
Advisory
Panels
as
strengths
in
its
Responsible
Care
Program.
Use
information
supplied
through
an
amended
IUR
could
be
used
to
further
strengthen
this
program.
The
Responsible
Care
Program
requires
companies
to
take
responsibility
for
their
products
from
cradle
to
grave,
which
requires
an
understanding
of
how
their
product
is
being
used
not
only
by
their
customers,
but
further
down
the
chain.
Despite
this
private
effort,
companies
have
told
EPA
that
they
don't
know
how
their
chemicals
are
used.
Information
provided
by
multiple
companies
could
give
an
individual
company
a
better
understanding
of
the
downstream
uses
of
their
product,

therefore
enabling
more
effective
implementation
of
the
Responsible
Care
concepts.

B.
Benefits
Due
to
Fewer
CBI
Claims
A
second
category
of
benefits
attributable
to
the
proposed
IUR
amendments
stems
from
changes
in
the
requirements
for
claiming
information
as
CBI;
these
changes
are
expected
to
enhance
the
utility
of
the
data
and
the
public's
access
to
that
data.
Three
basic
changes
are
proposed.
First,
EPA
is
proposing
to
add
a
requirement
to
provide
up­
front
substantiation
for
facility
identification,
as
well
as
the
original
requirement
for
up­
front
substantiation
for
chemical
identity.
EPA
has
found
that
CBI
claims
have
been
made
for
facility
identification
when
that
information
has
already
been
made
public
through
the
reporting
requirements
under
EPCRA
and
other
public
documents.

Second,
under
the
proposal,
submitters
could
claim
a
non­
CBI
status
for
production
volume
information
in
ranges
while
continuing
to
claim
specific
production
volume
as
CBI.
This
change
is
expected
to
reduce
claims
because
although
some
submitters
may
continue
to
claim
production
volume
information
in
ranges
as
CBI,
it
is
expected
that
other
submitters
will
not
feel
the
need
to
claim
this
information
as
confidential.
Third,
a
reassertion
of
previous
CBI
claims
is
proposed.
The
EPA
believes
that
information
that
is
four
years
old
or
more
would
typically
have
lost
its
proprietary
value
and
would
V­
28
not
need
to
be
maintained
as
CBI.
This
change
provides
a
mechanism
to
ensure
that
older
CBI
claims
would
be
reviewed
by
the
submitter;
companies
would
have
to
restate
a
claim
or
else
confidentiality
would
lapse.
EPA
expects
this
change
to
decrease
the
amount
of
information
that
would
have
to
remain
under
CBI
protection.

The
Agency
expects
these
changes
to
reduce
the
number
of
CBI
claims,
increasing
the
amount
of
information
available
to
the
public.
This
has
several
benefits.
The
Agency's
would
be
able
to
more
publicly
support
its
actions
and
decisions.
Currently,
support
for
Agency
decisions
is
often
CBI
and
cannot
therefore
be
included
in
any
publicly
available
support
document.
The
public
will
be
better
informed
and
better
able
to
provide
comment
on
Agency
actions.
Second,
the
Agency
will
be
able
to
provide
the
public
with
information
to
make
its
own
decisions.
These
benefits
were
discussed
in
more
detail
in
earlier
sections
of
this
chapter
and
center
around
the
fact
that
increasing
the
amount
of
information
available
for
the
public
allows
for
improved
understanding
of
potential
exposure
and
risk
concerns.

C.
Benefits
of
Changing
Certain
Exemptions
A
third
category
of
expected
benefits
of
the
IUR
amendments
relates
to
proposed
changes
to
the
exemptions
under
the
original
IUR.
One
major
change
is
the
elimination
of
the
inorganic
chemical
exemption,
which
was
originally
developed
based
on
EPA's
belief
that
the
hazard
potential
of
many
inorganic
chemicals
was
relatively
well­
established
and
therefore
production
information
was
not
needed.
Recent
findings
with
lead
and
other
inorganic
chemicals
have
brought
EPA
to
the
conclusion
that
hazard
information
alone
is
not
enough
to
protect
human
health
and
the
environment
­
use,

exposure,
and
volume
information
for
inorganic
chemicals
is
also
needed.
Collecting
information
on
inorganic
chemicals
through
the
proposed
amended
IUR
would
provide
EPA
with
better
knowledge
of
the
chemicals
being
manufactured,
what
their
production
characteristics
are,
and
the
extent
of
potential
exposures.
As
a
result,
the
addition
of
this
information
on
inorganic
chemicals
will
enable
the
Agency
to
consider
exposure
to
inorganic
chemicals
when
evaluating
risk
potential.
This
information
would
improve
OPPT's
ability
to
conduct
risk
screens
and
develop
management
activities
for
those
chemicals.

EPA
will
be
able
to
make
decisions
about
this
class
of
chemicals
that
heretofore
have
been
difficult
or,
in
some
cases,
not
possible.
V­
29
The
Agency
has
considered
an
option
of
continuing
the
exemption
for
inorganic
chemicals.
This
option,
referred
to
as
Option
11
in
Chapter
III,
would
limit
EPA's
ability
to
effectively
screen
risks
for
all
potentially
hazardous
or
risky
inorganic
chemicals.
As
discussed
above,
by
eliminating
the
inorganic
chemical
exemption
under
the
proposed
option
EPA
will
gain
access
to
additional
production
volume
and
exposure­
related
data
that
could
potentially
aid
in
risk
management
and
prescreening
of
inorganic
chemicals.
Option
11
would
result
in
use
and
exposure
information
in
approximately
12,155
reports
on
approximately
5,240
discrete
chemicals,
while
the
proposed
option
would
result
in
approximately
15,400
reports
for
approximately
6,000
discrete
chemicals.

The
second
major
change
in
exemptions
is
the
addition
of
a
partial
reporting
exemption
for
petroleum
stream
chemicals.
This
exemption
is
being
proposed
because
petroleum
streams
tend
to
be
complex
chemical
mixtures
with
variable
constituents.
As
such,
these
chemicals
tend
to
be
of
low
priority
for
EPA
risk
assessments.
These
factors
have
led
the
Agency
to
the
decision
that
the
collection
of
this
information
is
not
a
priority
at
this
time.

The
Agency
has
also
considered
an
option
of
exempting
only
site­
limited
petroleum
streams
from
reporting
under
the
IUR
amendments.
This
option,
referred
to
as
Option
10
in
Chapter
III,
would
reduce
the
information
EPA
would
be
collecting
by
eliminating
information
for
site­
limited
petroleum
stream
chemicals.
The
Agency
settled
on
the
broader
proposed
option,
which
exempts
reporting
of
use
and
exposure
information
for
multi­
chemical
petroleum
process
streams,
as
discussed
in
the
previous
paragraph.
The
proposed
option
would
exempt
about
140
more
discrete
chemicals
from
reporting
use
and
exposure
information
than
the
site­
limited
petroleum
stream
exemption.
The
site­
limited
petroleum
stream
exemption
would
result
in
use
and
exposure
information
in
approximately
19,800
reports
on
approximately
6,200
discrete
chemicals,
while
the
proposed
option
would
result
in
approximately
15,400
reports
for
approximately
6,000
discrete
chemicals.

D.
Administrative
and
Related
Benefits
The
fourth
category
of
benefits
from
the
proposed
IUR
amendments
stems
from
changes
to
several
administrative
requirements,
each
of
which
will
facilitate
data
exchange
and
increase
data
comprehensiveness.
Overall,
the
administrative
changes
would
enhance
the
utility
of
the
data
by
allowing
linkages
between
various
Agency
databases.
In
addition,
these
changes
would
change
the
V­
30
reporting
time
frame
to
make
IUR
reporting
more
consistent
within
itself
and
with
other
EPA
reporting
requirements.

Specific
benefits
attributable
to
administrative
changes
under
the
IUR
amendments
flow
from
several
sources.
One
of
the
proposed
IUR
amendments
would
require
submission
of
EPA
facility
identity
(
EPA
ID)
numbers
and
the
county
in
which
the
facility
is
located.
These
data
would
increase
consistency
with
the
identification
systems
of
other
EPA
information
collection
efforts
and
is
one
step
in
the
direction
of
"
one­
stop
reporting,"
an
existing
Agency
initiative
under
development.
Consistent
facility
identification
information
reported
across
the
Agency
would
help
to
link
data,
providing
both
an
important
analysis
tool
and
an
important
enforcement
tool.
State
and
other
potential
users
of
the
data
will
also
be
able
to
examine
the
chemicals
produced
in
a
specific
locality
such
as
a
county.

In
addition,
changing
the
reporting
time
frame
from
fiscal
year
to
calendar
year
for
all
reporting
sites
would
make
the
information
collected
more
amenable
to
use
as
the
information
covers
the
same
time
frame.
Another
benefit
to
this
comes
from
the
improved
ability
to
combine
IUR
information
with
information
from
other
data
sources
using
calendar
reporting.
For
instance,
a
calendar
year
reporting
cycle
would
correspond
with
the
TRI
reporting
period,
enhancing
the
Agency's
ability
to
develop
linkages
between
the
two
databases.
With
all
information
provided
covering
the
same
time
frame,
more
accurate
assessments
of
the
status
of
the
industry
would
be
possible.
For
those
submitters
already
reporting
information
on
a
calendar
year
basis
for
other
collections,
this
change
may
result
in
greater
efficiency
of
company
information
collection
and
recordkeeping.

E.
Benefits
From
Reporting
Thresholds
From
the
perspective
of
benefits,
the
most
significant
elements
of
the
proposed
option
are
(
1)

the
addition
of
exposure
information
to
the
reporting
requirements
and
(
2)
the
adjustment
to
reporting
thresholds
for
facility
and
manufacturing
information
and
for
exposure
and
use
information.
The
addition
of
exposure­
related
information
has
been
discussed
in
Section
A.
1.
Benefits
resulting
from
the
threshold
options
are
discussed
below.
It
should
be
noted
that
because
the
actual
risk
reductions
that
will
occur
as
a
result
of
this
proposed
rule
have
not
been
quantified,
a
qualitative
argument
is
developed
to
illustrate
the
paths
of
risk
reduction
and
the
extent
to
which
reduced
mortality
and
morbidity
might
result.

There
are
two
reporting
thresholds
proposed
in
these
amendments
­­
a
reporting
threshold
for
facility
and
manufacturing
information
(
e.
g.,
facility
location
and
information
associated
with
producing
V­
31
the
chemical)
and
a
reporting
threshold
for
use
and
exposure
data
(
e.
g.,
numbers
of
exposed
employees
at
use
sites,
number
of
use
sites,
percent
of
production
volume).
Reporting
threshold
options
considered
by
EPA
are
presented
in
Table
V­
4.
Of
the
options
presented,
Option
4
is
the
option
proposed
for
the
IUR
amendments
and
sets
the
annual
production
threshold
at
25,000
pounds
for
facility
and
manufacturing
data
and
100,000
pounds
for
use
and
exposure
information.
The
original
IUR
requirements
have
a
reporting
threshold
of
10,000
pounds.
With
the
exception
of
the
first
option,
all
of
the
options
increase
the
threshold
for
use
and
exposure
information
from
this
baseline
threshold,
while
either
maintaining
the
baseline
or
increasing
to
the
proposed
threshold
level
for
the
facility
and
manufacturing
information.

The
choice
of
threshold
level
is
very
important.
The
amount
of
information,
and
therefore
the
benefits,
vary
greatly
depending
upon
the
number
of
chemicals
for
which
reports
are
submitted.
The
more
reports,
the
more
information
EPA
and
others
have
for
input
into
their
decisions.
However,
there
is
a
cost
associated
with
the
submission
of
this
information.
In
considering
the
threshold
levels,
EPA
balanced
information
needs
and
associated
benefits
with
the
cost
of
the
information.
EPA
has
determined
that
the
threshold
levels
proposed
provide
the
level
of
data
necessary
to
provide
EPA
with
the
information
necessary
to
screen
the
thousands
of
larger
volume
chemicals,
develop
risk
management
initiatives,
and
track
changes
in
the
marketplace
(
and
therefore
in
exposure
scenarios)

while
not
unduly
burdening
industry.

To
estimate
changes
in
the
amount
of
information
provided
under
each
of
the
reporting
threshold
options,
historical
IUR
data
regarding
the
number
of
report
submissions
was
sorted
by
production
volume.
The
remainder
of
this
section
discusses
the
effect
that
the
proposed
reporting
thresholds
and
the
other
options
considered
would
have
on
the
benefits
associated
with
use
of
the
data
collected
though
the
proposed
amended
IUR.

1.
Reporting
Threshold
Options
for
Facility
and
Manufacturing
Information
As
shown
in
Table
V­
4,
the
two
reporting
threshold
options
considered
for
submission
of
facility
and
manufacturing
information
are
10,000
and
25,000
pounds.
The
original
reporting
threshold
requirement
is
10,000
pounds;
the
IUR
amendments
propose
to
raise
the
reporting
threshold
to
25,000
pounds.
This
increase
in
the
reporting
threshold
has
been
proposed
to
help
reduce
societal
costs
V­
32
resulting
from
the
proposed
IUR
amendments,
as
discussed
in
Chapter
III.
Possible
impacts
on
the
generation
of
societal
benefits
posed
by
these
two
options
are
briefly
discussed
below.

Table
V­
2.
Reporting
Threshold
Options
for
the
Proposed
IUR
Amendments
Option
#
Facility
Identification
and
Manufacturing
Information
Processing
and
Use
Information
1
10,000
lb
10,000
lb
2
25,000
lb
25,000
lb
3
10,000
lb
100,000
lb
4
25,000
lb
100,000
lb
5
10,000
lb
500,000
lb
6
25,000
lb
500,000
lb
7
25,000
lb
1,000,000
lb
8
25,000
lb
10,000,000
lb
9
25,000
lb
500,000
lb/
100,000
lb
a.
10,000
Pound
Threshold
for
Facility
and
Manufacturing
Data
This
threshold
option
is
equivalent
to
the
original
reporting
threshold
for
submission
of
facility
and
manufacturing
data.
Taking
into
account
the
changes
in
exemptions
included
in
the
proposed
IUR
amendments
(
addition
of
inorganic
chemicals),
information
on
approximately
10,400
chemicals
would
be
reported.
Benefits
associated
with
the
addition
of
inorganic
chemicals
and
with
the
addition
of
the
new
information
requirements
was
discussed
previously.
As
this
threshold
is
the
same
as
the
baseline
level,
there
are
no
changes
to
the
benefits
due
to
the
level.
However,
this
option
does
maximize
the
amount
of
useful
facility
and
manufacturing
information
collected
by
EPA.
In
particular,

data
for
chemicals
with
low
production
volumes
would
be
more
readily
available
for
use
in
risk
prescreening
and
in
conducting
other
activities,
such
as
use
and
substitutes
analyses.
Without
access
to
this
level
of
facility
and
manufacturing
data,
data
on
production
of
chemicals
with
low
production
volumes
would
no
longer
be
available
to
OPPT
risk
managers.

b.
25,000
Pound
Threshold
for
Facility
and
Manufacturing
Data
V­
33
The
reporting
threshold
for
the
facility
and
manufacturing
data
proposed
in
the
IUR
amendments
is
25,000
pounds.
It
is
estimated
that
by
increasing
the
reporting
threshold
to
25,000
pounds,
information
on
approximately
8,900
discrete
chemicals
would
be
collected.
This
is
15
percent
fewer
chemicals
than
those
estimated
to
be
reported
for
the
10,000
pound
threshold
under
Option
1.

With
this
change,
benefits
would
decrease
because
EPA
risk
managers
would
no
longer
have
access
to
current
data
on
small
volume
chemicals
(
i.
e.,
those
produced
between
10,000
and
25,000
pounds).
This
loss
of
data
would
potentially
affect
EPA's
ability
to
undertake
risk
pre­
screening
activities,
as
well
as
the
preparation
of
certain
important
analyses,
including
use,
substitutes,
and
use
cluster
analyses.
Without
the
data
on
these
chemicals,
information
that
would
help
to
reduce
exposure
risks
for
chemicals
may
no
longer
be
readily
available
to
OPPT.
It
is
expected,
however,
that
reductions
in
societal
benefits
associated
with
a
change
from
10,000
pounds
to
25,000
pounds
for
facility
and
manufacturing
data
would
not
be
significant
compared
to
those
associated
with
changes
in
thresholds
for
use
and
exposure
data,
as
described
below.

EPA
chose
this
threshold
level
in
order
to
reduce
the
burden
on
submitters.
EPA
acknowledges
that
information
on
the
lower
volume
chemicals
would
be
useful
and
may
find
it
necessary
to
collect
this
information
in
the
future.

2.
Reporting
Threshold
Options
for
Use
and
Exposure
Information
EPA
considered
reporting
thresholds
for
the
submission
of
use
and
exposure
data
by
ranging
from
10,000
to
10,000,000
pounds,
as
presented
in
Table
V­
4.
Because
submission
of
use
and
exposure
data
is
not
required
under
the
original
IUR,
all
of
the
reporting
threshold
options
considered
would
result
in
a
more
complete
data
set.
However,
each
reporting
threshold
option
considered
during
the
development
of
amendments
makes
available
to
the
OPPT
significantly
different
levels
of
use
and
exposure
data.
Again,
EPA
balanced
data
needs
and
associated
benefits
with
the
cost
of
information
submission.
EPA
determined
that
a
threshold
of
100,000
pounds
best
balances
the
needs
of
EPA,
the
public,
and
industry
at
this
time.
The
overall
extent
and
magnitude
of
the
effects
on
societal
benefits
for
each
of
the
reporting
options
considered
is
discussed
below.

a.
10,000
Pound
Threshold
for
Use
and
Exposure
Data
V­
34
The
lowest
reporting
threshold
option
considered
for
requiring
submission
of
use
and
exposure
information
is
10,000
pounds.
This
option
would
serve
to
maximize
the
amount
of
use
and
exposure
data
collected.
Use
and
exposure
information
on
approximately
10,000
discrete
chemicals
would
be
reported.
Greater
benefits
would
be
generated
at
this
threshold
than
under
the
higher
threshold
options
because
there
would
be
more
comprehensive
data
on
small
volume
chemicals.
EPA
historically
has
believed
that,
in
general,
a
larger
production
volume
indicates
a
more
likely
risk
concern.
However,

the
information
on
lower
volume
chemicals
often
provides
data
on
substitutes
for
larger
production
chemicals.
In
addition,
information
on
the
lower
volume
chemicals
is
most
unlikely
to
be
publicly
available;
it
is
often
the
case
that,
for
lower
volume
chemicals,
little
to
no
mention
of
them
is
made
in
the
published
literature.
This
situation
limits
EPA's
ability
to
identify
the
lower
volume
chemicals
and
makes
any
analyses
of
those
chemicals
highly
improbable.
This
lack
of
information
also
reduces
the
effectiveness
of
analyses
of
larger
volume
chemicals
as
the
likelihood
of
substitute
information
could
be
either
eliminated
or
greatly
diminished.

b.
25,000
Pound
Threshold
for
Use
and
Exposure
Data
With
the
exception
of
Option
1,
this
option
would
result
in
the
greatest
number
of
submissions
containing
use
and
exposure
information.
It
is
estimated
that
this
option
would
result
in
the
collection
of
use
and
exposure
information
on
approximately
8,500
discrete
chemicals.
As
is
the
case
for
the
10,000
pound
threshold
described
above,
collection
of
valuable
use
and
exposure
data
for
low
volume
chemicals,
albeit
somewhat
less
than
under
the
10,000
pound
threshold,
would
be
possible
under
this
production
volume
threshold.
Benefits
derived
from
this
threshold,
as
compared
to
the
proposed
option,
are
similar
to
those
discussed
under
the
10,000
pound
option.

c.
100,000
Pound
Threshold
for
Use
and
Exposure
Data
This
is
the
proposed
option
for
the
IUR
amendments
for
reporting
requirements
for
use
and
exposure
information.
This
option
will
result
in
a
level
of
submissions
that
will
provide
an
effective
level
of
coverage.
EPA
estimates
that
this
option
will
result
in
the
collection
of
use
and
exposure
information
on
approximately
6,000
discrete
chemicals.

EPA
has
determined
that
this
is
the
optimum
level
of
information.
Collection
of
this
level
of
data
would
provide
valuable
input
to
OPPT
risk
screening
activities,
streamlining
EPA's
efforts
to
correctly
V­
35
identify
chemicals
needing
further
review
and
subsequently
improving
later
risk
management
efforts.

This
level
of
coverage
also
allows
EPA
to
track
changes
in
chemical
use
over
time,
enabling
EPA
to
react
to
the
dynamic
environment
of
the
chemical
industry.

d.
500,000,
1,000,000,
and
10,000,000
Pound
Reporting
Threshold
Options
The
500,000,
1,000,000,
and
10,000,000
pound
reporting
threshold
options
would
all
significantly
reduce
the
benefits
resulting
from
use
and
exposure
data
for
chemicals
reported
under
the
IUR.
Compared
to
the
100,000
pound
reporting
threshold,
these
options
would
reduce
the
number
of
submissions
containing
use
and
exposure
information
by
between
35
and
72
percent.
Use
and
exposure
information
would
be
collected
on
fewer
chemicals,
ranging
from
a
decrease
of
approximately
2,400
chemicals
at
the
500,000
pound
threshold
to
a
decrease
of
approximately
4,900
chemicals
at
the
10
million
pound
threshold.
As
the
reporting
threshold
increases,
the
information
available
for
EPA
decision­
makers
would
become
increasingly
limited
and
would
generate
proportionately
fewer
benefits.
EPA's
efforts
to
protect
human
health
and
the
environment
would
be
restricted
to
those
chemicals
with
very
large
production
volumes.
Hence,
under
these
higher
threshold
options,
EPA's
ability
to
effectively
screen
risks
for
a
large
number
of
potentially
risky
chemicals
would
be
impeded
by
a
lack
of
information.

F.
Benefits
From
Reporting
Cycle
Options
The
baseline
reporting
cycle
is
being
retained
for
this
proposal.
Reporting
currently
is
required
every
four
years.
EPA
considered
three
alternatives
to
this
cycle.
The
first
alternative,
referred
to
as
Option
12
in
Chapter
III,
would
require
all
reportable
chemicals
to
report
facility
and
manufacturing
information
every
two
years
and
use
and
exposure
information
every
four
years.
This
would
allow
EPA
to
collect
manufacturing
information
for
chemicals
that
are
produced
periodically,
and
hence,
may
not
be
captured
in
a
four
year
reporting
cycle.
EPA
would
also
be
collecting
information
that
would
more
closely
track
the
changing
chemical
industry.
The
second
alternative,
referred
to
as
Option
13
in
Chapter
III,
would
require
all
information
to
be
reported
every
two
years.
Past
experience
with
reporting
shows
the
dynamic
nature
of
the
chemical
industry
(
about
30%
of
the
chemicals
reporting
in
1990
were
not
reported
in
1994),
providing
justification
for
collecting
information
on
a
more
frequent
basis.

However,
EPA
also
felt
that
the
information
would
not
be
put
to
sufficient
use
to
justify
the
additional
V­
36
expense
to
industry
to
supply
this
information.
The
third
alternative,
Option
14,
would
require
one­
time
reporting.
While
this
option
reduces
costs
significantly,
it
does
not
allow
EPA
to
develop
a
stream
of
information
over
time
to
assess
risks
on
an
ongoing
basis
and
it
would
quickly
become
out­
of­
date.
VI­
1
CHAPTER
VI.
COST
BENEFIT
ANALYSIS
AND
COST­
EFFECTIVENESS
COMPARISONS
Cost
benefit
analysis
is
performed
for
proposed
rules
in
order
to
ensure
that
the
social
benefits
of
a
regulation
outweigh
the
costs
imposed
on
the
regulated
community
and
EPA,
and
to
select
the
proposed
regulatory
option
that
offers
the
highest
cost­
benefit
reward.
For
the
proposed
IUR
amendments,
however,
a
quantitative
cost
benefit
analysis
is
far
from
straightforward.
This
is
because
many
of
the
benefits,
as
described
in
Chapter
V
of
this
report,
have
to
do
with
information
collection
rather
than
the
direct
avoidance
of
harm.

As
a
result,
EPA
has
used
a
cost­
effectiveness
criterion
to
compare
options.
This
approach,

described
in
more
detail
below,
looks
at
the
amount
of
data
collected
and
its
cost,
without
quantifying
the
benefit
of
each
option.
The
new
information
proposed
to
be
collected
under
the
IUR
amendments
would
assist
the
Agency
in
developing
chemical
screening
priorities,
streamlining
regulatory
efforts,
and
making
informed
risk
assessment
and
management
decisions.
This
information
would
improve
EPA's
understanding
of
potential
exposures
resulting
from
industrial
chemical
use,
allow
EPA
to
more
accurately
track
chemical
use
and
exposure,
and
permit
EPA
to
more
effectively
target
chemicals
that
pose
the
greatest
hazard
or
risk.
In
the
case
of
the
IUR
amendments,
lowering
the
costs
to
society
while
maximizing
and
targeting
the
information
collected
leads
to
cost­
effective
regulation.

The
value
of
the
information
alone
cannot
be
determined,
especially
given
that
the
exposure
and
use
information
has
yet
to
be
collected.
Thus,
in
contrast
to
many
RIAs,
the
benefits
of
this
regulation
cannot
be
directly
expressed
in
terms
of
avoided
harm
or
other
conventional
measures.
Nevertheless,

the
incremental
costs
of
the
proposed
IUR
amendments
are
justified
by
the
potential
longer
term
savings
for
industry
reporting
and
EPA
adminstration,
and
the
higher
cost­
benefit
performance
of
future
regulation.

In
order
to
evaluate
potential
options
for
the
IUR
amendments,
EPA
has
used
a
measure
of
cost­
effectiveness
rather
than
a
cost
benefit
analysis.
Cost­
effectiveness
is
a
measure
of
the
efficiency
of
a
regulatory
option
in
achieving
a
level
of
benefits.
It
is
generally
calculated
by
dividing
the
costs
of
a
36
Some
chemicals
are
partially
exempt,
in
that
manufacturers
need
only
submit
partial
reports
regardless
of
the
production
volume.
This
explains
why
Options
1
and
2,
which
have
the
same
level
for
both
thresholds,
still
have
some
partial
reports
being
submitted.

VI­
2
regulatory
option
by
the
benefits.
For
this
analysis,
therefore,
cost­
effectiveness
is
described
in
terms
of
the
relative
amount
of
IUR
data
collected
and
the
cost
of
collecting
those
data.

The
remainder
of
this
section
presents
the
proposed
option,
and
then
describes
and
discusses
each
of
the
other
options
compared
to
the
proposed
option.
As
discussed
in
Chapter
2,
the
regulatory
options
vary
along
several
parameters.
The
most
important
parameters
are
the
two
chemical
production
thresholds,
which
determine
when
producers
must
report
only
facility
and
manufacturing
data
("
partial
form")
and
when
they
must
report
use
and
exposure
data
("
full
form").
36
Other
parameters
include
the
length
of
the
reporting
cycle,
and
additional
exemptions
from
reporting
for
various
classes
of
chemicals.

Table
VI­
1
presents
an
analysis
of
the
amount
of
information
that
will
be
collected
and
Table
VI­
2
presents
the
first
year
cost
of
each
option
relative
to
the
proposed
option.
VI­
3
Table
VI­
1.
Comparison
of
Information
Collected
Under
Each
Regulatory
Option
Option
Number
of
Reports
Partial
Form
Percent
of
Proposed
Option
Full
Form
Percent
of
Proposed
Option
Total
Percent
of
Proposed
Option
Option
1
5,833
51
24,765
160
30,598
114
Option
2
5,733
50
21,078
136
26,811
100
Option
3
15,167
133
15,431
100
30,598
114
Option
4
11,380
100
15,431
100
26,811
100
Option
5
20,511
180
10,087
65
30,598
114
Option
6
16,724
147
10,087
65
26,811
100
Option
7
18,393
162
8,418
54
26,811
100
Option
8
22,435
197
4,376
28
26,811
100
Option
9
16,724
147
10,087
65
26,811
100
11,380
100
15,431
100
Option
10
5,763
51
19,814
128
25,577
95
Option
11
10,154
89
12,155
79
22,309
83
Option
12
11,380
100
15,431
100
26,811
100
Option
13
11,380
100
15,431
100
26,811
100
Option
14
11,380
100
15,431
100
26,811
100
The
proposed
option
for
the
IUR
amendments,
Option
4,
would
require
subject
chemicals
to
be
reported
if
they
are
produced
in
quantities
greater
than
an
annual
production
volume
of
25,000
pounds.

For
those
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
25,000
pounds
but
less
than
100,000
pounds,
only
the
partial
form
(
facility
identification
and
manufacturing
information)
would
be
required.
With
the
exception
of
partially
exempt
chemicals,
for
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
100,000
pounds,
the
reporter
would
be
required
to
submit
the
full
form,

providing
use
and
exposure
information
in
addition
to
the
facility
identification
and
manufacturing
information.
This
option
would
result
in
the
submission
of
26,811
reports.
Fifty­
eight
percent
of
the
reports
(
15,431)
would
include
both
IUR
and
IUR
amendment
information.
The
incremental
first
year
cost
of
the
proposed
option
relative
to
the
original
IUR
is
expected
to
range
from
$
47.9
million
to
$
65.4
million.
VI­
4
Option
4
is
among
the
most
cost­
effective
options
considered.
That
is,
it
has
low
incremental
costs
for
the
number
of
full
and
partial
forms
that
would
be
submitted.
Option
4
has
two
other
advantages
relative
to
other
similarly
cost­
effective
options.
First,
its
lower
threshold
(
i.
e.,
the
level
at
which
a
partial
form
is
required)
is
25,000
lbs
and
not
10,000
lbs.
In
the
experience
of
EPA,
for
TSCA
reporting
and
other
programs,
the
data
gathered
for
low
production
volume
chemicals
between
roughly
10,000
and
25,000
pounds
tends
to
be
less
valuable
than
that
for
larger
production
chemicals.
This
is
because
low
production
chemicals
tend
to
have
specialty
applications
that
limit
the
amount
of
exposure.

Second,
Option
4
collects
full
information
for
chemicals
in
excess
of
100,000
lbs
of
production.

Chemicals
below
this
level
tend
to
be
less
of
a
priority
for
risk
management,
so
a
higher
upper
threshold
can
reduce
the
cost
(
relative
to
an
upper
threshold
lower
than
100,000)
without
losing
much
high­
priority
data
for
risk
management
purposes.
In
addition
to
being
highly
cost
­
effective,
therefore,
Option
4
is
likely
to
yield
important
benefits
that
will
make
the
IUR
amendments
more
effective.

Option
1
would
require
full
forms
for
all
subject
chemicals
if
they
are
produced
over
an
annual
production
volume
of
10,000
pounds.
This
option
would
result
in
the
submission
of
24,765
full
reports,
as
well
as
5,833
partial
reports
for
the
partially
exempt
chemicals.
This
yields
a
total
of
30,598
reports
(
1.14
times
as
many
as
the
proposed
option)
for
an
incremental
first­
year
cost
to
society
of
between
$
69.2
million
and
$
91.2
million,
or
between
39
and
44
percent
more
expensive
than
the
proposed
option.

This
option
is
similarly
cost­
effective
to
Option
4.
Although
more
expensive
than
the
proposed
option,
it
collects
more
data
overall
and
considerably
more
exposure
and
use
data
(
full
forms)
on
small
VI­
5
Table
VI­
2.
Comparison
of
Incremental
First
Year
Industry
Costs
Under
Each
Regulatory
Option
Options
Incremental
First
Year
Industry
Costs
Low
High
Incremental
First
Year
Cost
($
M)
Percent
of
Proposed
Option
Incremental
First
Year
Cost
($
M)
Percent
of
Proposed
Option
Option
1
$
69.2
144
$
91.2
139
Option
2
$
58.3
122
$
76.6
117
Option
3
$
52.1
109
$
72.7
111
Option
4
$
47.9
100
$
65.4
100
Option
5
$
42.3
88
$
62.0
95
Option
6
$
38.1
80
$
54.8
84
Option
7
$
35.1
73
$
51.4
78
Option
8
$
27.7
58
$
43.4
66
Option
9
$
38.1
80
$
54.8
84
Option
10
$
54.4
114
$
71.5
109
Option
11
$
36.8
77
$
50.4
77
Option
12
$
47.9
100
$
65.4
100
Option
13
$
47.9
100
$
65.4
100
Option
14
$
47.9
100
$
65.4
100
volume
chemicals.
Prior
experience
leads
EPA
to
believe
that
full
information
for
small
volume
chemicals
is
not
as
important
as
for
large
volume
chemicals,
making
Option
1
less
preferable
to
Option
4.

Option
2
is
similar
to
Option
1,
but
with
a
higher
threshold
level.
Full
reports
are
required
for
subject
chemicals
if
they
are
produced
over
an
annual
production
volume
of
25,000
pounds.
Partial
reports
are
also
required
for
partially
exempt
chemicals.
This
option
would
require
the
submission
of
26,811
reports,
the
same
as
for
the
recommended
option,
but
with
36
percent
more
full
reports
providing
exposure
and
use
information.
This
increase
in
total
data
collected
is
offset
by
17
to
22
percent
higher
costs;
incremental
first
year
costs
for
Option
2
are
expected
to
range
from
about
$
58.3
million
to
$
76.6
million.
Option
4
is
preferred
over
Option
2
because
it
focuses
reporting
on
higher
priority
chemicals
produced
at
levels
over
100,000
pounds.
VI­
6
Option
3
would
require
subject
chemicals
to
be
reported
if
they
are
produced
over
an
annual
production
volume
of
10,000
pounds.
For
those
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
10,000
pounds
but
less
than
100,000
pounds,
only
facility
and
manufacturing
information
would
be
required.
For
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
100,000
pounds,
the
reporter
would
be
required
to
provide
use
and
exposure
information,
as
well
as
facility
and
manufacturing
information.
This
option
would
result
in
the
submission
of
the
same
amount
of
use
and
exposure
data,
but
would
generate
significant
information
on
production
of
chemicals
produced
between
10,000
pounds
and
25,000
pounds
for
an
incremental
cost
of
approximately
$
52.1
million
to
$
72.7
million,
only
9
to
11
percent
higher
than
the
proposed
option.
This
option
is
less
cost­
effective
than
Option
4
and
collects
data
for
very
low
production
chemicals
that
are
not
seen
as
a
high
priority.

Option
5
would
require
subject
chemicals
to
be
reported
if
they
are
produced
over
an
annual
production
volume
of
10,000
pounds.
For
those
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
10,000
pounds
but
less
than
500,000
pounds,
only
facility
and
manufacturing
information
would
be
required.
For
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
500,000
pounds,
the
reporter
would
be
required
to
provide
use
and
exposure
information
as
well
as
facility
and
manufacturing
information.
This
option
would
result
in
submission
of
10,087
reports
containing
use
and
exposure
information,
or
about
65
percent
of
the
amount
that
would
be
collected
under
the
proposed
option.
This
option
has
an
incremental
cost
of
about
$
42.3
million
to
$
62.0
million,
or
88
percent
to
95
percent
of
the
proposed
option.
Although
this
option
collects
facility
and
manufacturing
information
on
small
volume
chemicals
(
i.
e.,
those
produced
between
10,000
lbs
and
25,000
lbs.),
it
is
less
cost­
effective
than
the
proposed
option
because
it
reduces
the
amount
of
use
and
exposure
information
collected
by
about
35
percent
while
only
reducing
costs
by
about
5
to
12
percent.

Option
6
would
require
subject
chemicals
to
be
reported
if
they
are
produced
over
an
annual
production
volume
of
25,000
pounds.
For
those
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
25,000
pounds,
but
less
than
500,000
pounds,
only
facility
and
manufacturing
information
would
be
required.
For
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
500,000
pounds,
the
reporter
would
be
required
to
provide
use
and
exposure
information,
as
well
as
facility
and
manufacturing
information.
This
option
is
similar
to
Option
5
except
that
it
would
not
require
VI­
7
facility
and
manufacturing
information
to
be
collected
on
chemicals
produced
in
quantities
less
than
25,000
pounds.
Although
it
is
more
cost­
effective
than
Option
5
in
that
incremental
first
year
costs
are
expected
to
be
about
80
to
84
percent
as
much
as
the
proposed
option,
it
less
cost­
effective
than
the
proposed
option.
Approximately
65
percent
of
the
use
and
exposure
information
would
be
collected
under
this
option,
compared
to
the
proposed
option.

Option
7
would
require
subject
chemicals
to
be
reported
if
they
are
produced
over
an
annual
production
volume
of
25,000
pounds.
For
those
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
25,000
pounds,
but
less
than
1
million
pounds,
only
facility
and
manufacturing
information
would
be
required.
For
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
1
million
pounds,
the
reporter
would
be
required
to
provide
both
use
and
exposure
information
as
well
as
facility
and
manufacturing
information.
In
comparison
to
the
proposal,
this
option
collects
about
54
percent
of
the
use
and
exposure
data
at
an
incremental
first
year
cost
of
about
73
to
78
percent
of
the
proposed
option.
This
option
is
less
cost­
effective
and
significantly
reduces
the
amount
of
use
and
exposure
information
that
would
be
collected
on
an
important
class
of
chemicals
(
i.
e.,
those
chemicals
produced
in
volumes
up
to
1
million
pounds).
By
not
having
access
to
data
for
these
chemicals,
the
Agency's
ability
to
perform
screening
assessments
and
other
risk
management
activities
would
be
seriously
impaired.

Option
8
would
require
subject
chemicals
to
be
reported
if
they
are
produced
over
an
annual
production
volume
of
25,000
pounds.
For
those
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
25,000
pounds
but
less
than
10
million
pounds,
only
facility
and
manufacturing
information
would
be
required.
For
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
10
million
pounds,
the
reporter
would
be
required
to
provide
use
and
exposure
information
as
well
as
facility
and
manufacturing
information.
This
option
collects
only
about
28
percent
of
the
use
and
exposure
data
compared
to
the
proposed
option.
The
incremental
first
year
cost
of
this
option
ranges
from
$
27.7
million
to
$
43.4
million,
or
about
58
to
66
percent
of
the
costs
of
the
proposed
option.

Because
only
chemicals
produced
at
levels
above
10
million
pounds
would
have
use
and
exposure
data
reported,
this
option
provides
only
marginally
useful
data
and
is
not
considered
cost­
effective.
The
amount
of
data
in
the
general
literature
on
chemicals
produced
in
volumes
above
10
million
pounds
VI­
8
tends
to
be
greater
than
for
small
volume
chemicals
and
the
Agency
would
be
able
to
discover
much
of
the
information
for
these
large
volume
chemicals
through
other
means.
While
the
level
of
information
would
not
be
as
comprehensive
as
that
which
would
be
collected
under
the
IUR
amendments,
collecting
this
information
for
such
a
small
subset
of
chemicals
is
not
cost­
effective.

Option
9
would
require
subject
chemicals
to
report
if
they
are
produced
over
a
threshold
volume
of
25,000
pounds.
This
option
incorporates
characteristics
of
Option
6
and
the
proposed
option.
In
the
first
reporting
period,
only
chemicals
produced
over
a
threshold
volume
of
500,000
pounds
would
be
required
to
report
use
and
exposure
information.
For
the
second
reporting
period,
the
reporting
threshold
for
use
and
exposure
information
would
be
reduced
to
100,000
pounds.
This
option
would
result
in
estimated
incremental
first
year
costs
of
between
$
38.1
million
and
$
54.8
million,
or
80
percent
to
84
percent
of
the
proposed
option.

Option
10
would
require
the
same
threshold
volumes
and
reporting
cycles
as
the
proposed
option,
but
would
provide
different
chemical
reporting
exemptions.
Under
this
option,
site­
limited
petroleum
streams
would
be
exempt
from
reporting
any
information
and
the
petroleum
stream
exemption
outlined
in
the
proposed
option
would
not
apply.
Option
10
would
increase
the
incremental
first
year
cost
by
approximately
9
to
14
percent
compared
to
the
proposed
option
and
would
collect
28
percent
more
exposure
and
use
information
than
the
proposed
option.
However,
EPA
feels
the
information
on
the
petroleum
stream
chemicals
would
only
be
marginally
useful
at
this
time
and
concludes
that
collecting
this
information
would
not
be
cost­
effective.

Option
11
would
require
the
same
threshold
volumes
and
reporting
cycles
as
the
proposed
option,
but
would
provide
different
chemical
reporting
exemptions.
Under
this
option,
inorganic
chemicals
would
be
exempt
from
reporting
any
information.
Option
11
would
reduce
the
incremental
first
year
cost
by
approximately
23
percent
compared
to
the
proposed
option
and
would
collect
21
percent
less
use
and
exposure
information
than
the
proposed
option.
However,
EPA
feels
that
information
on
inorganic
chemicals
would
be
extremely
useful
and
concludes
that
collecting
this
information
is
cost­
effective.

Options
12,
13,
and
14
would
require
subject
chemicals
to
be
reported
over
the
same
threshold
volumes
as
the
proposed
option,
but
over
different
reporting
cycles.
Option
12
would
require
that
facility
VI­
9
and
manufacturing
information
be
collected
every
2
years
and
use
and
exposure
data
every
4
years.

Option
13
would
require
that
all
information
be
collected
every
two
years.
Option
14
would
require
one­
time
reporting
of
all
information.
These
options
do
not
impact
first
year
costs
or
the
amount
of
information
that
is
collected
relative
the
proposed
option,
but
the
more
frequent
reporting
increases
costs
incurred
in
future
years.
Option
12
increases
incremental
net
present
value
costs
by
about
46
to
58
percent,
while
Option
13
increases
incremental
net
present
value
costs
by
about
92
percent
to
96
percent.
One­
time
reporting
under
Option
14
would
reduce
net
present
value
and
annualized
costs
significantly,
to
about
25
percent
of
the
proposed
option.
37
Because
the
intent
of
the
proposed
amendments
is
to
collect
information
from
manufacturers
and
importers
only,
there
would
be
no
impact
on
small
businesses
that
only
process
or
distribute
chemicals
or
products,
but
do
not
manufacture
or
import
the
chemicals.

VII­
1
CHAPTER
VII.
SMALL
ENTITY
AND
ENVIRONMENTAL
JUSTICE
IMPACT
DETERMINATIONS
This
chapter
presents
the
estimated
impacts
of
the
IUR
amendments
on
small
entities
and
presents
a
discussion
of
environmental
equity
and
justice
concerns.

The
Regulatory
Flexibility
Act
of
1980
requires
Federal
Agencies
to
assess
the
effects
of
proposed
regulations
on
small
entities
(
P.
L.
96­
354).
The
Act
requires
agencies
to
evaluate
all
proposed
rulemakings
to
determine
if
an
Initial
Regulatory
Flexibility
Analysis
(
IRFA)
is
necessary.
If
the
regulation
will
result
in
significant
impacts
on
a
substantial
number
of
small
entities,
the
Agency
must
examine
alternatives
that
may
reduce
adverse
economic
effects
on
significantly
impacted
entities.
The
Regulatory
Flexibility
Act
was
Amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
of
1996.
Section
A
of
this
chapter
contains
an
examination
of
the
effect
of
these
proposed
amendments
on
small
entities,
and
Section
B
presents
an
analysis
determining
that
an
IRFA
is
not
necessary.

Executive
Order
12898,
Federal
Actions
to
Address
Environmental
Justice
in
Minority
Populations
and
Low­
Income
Populations,
requires
that
each
Federal
agency
examine
the
effect
of
its
regulations
on
minority
and
low­
income
populations,
and
address
disproportionately
high
and
adverse
human
health
or
environmental
effects.
Section
C
below
contains
an
examination
of
the
effect
of
these
proposed
amendments
on
minority
and
low­
income
populations.

A.
Small
Entity
Analysis
The
term
"
small
entities"
includes
small
businesses,
small
not­
for­
profit
organizations,
and
small
governmental
jurisdictions,
but
since
not­
for­
profit
organizations
and
governmental
jurisdictions
will
not
be
affected
by
this
proposed
rule,
"
small
entity"
in
this
analysis
is
synonymous
with
small
business.
For
the
proposed
IUR
amendments,
small
businesses
are
limited
to
small
chemical
manufactures
and
importers.
37
Section
605(
b)
of
the
Regulatory
Flexibility
Act
requires
the
Agency
to
either
certify
that
the
regulatory
action
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities
or
38
It
is
important
to
note
that
the
$
40
million
level
is
for
parent
company
sales,
not
individual
site
sales.

VII­
2
prepare
an
Initial
Regulatory
Flexibility
Analysis
(
IRFA).
The
basis
for
the
determination
that
there
is
no
significant
economic
impact
is
provided
in
the
sections
below.

1.
Determination
of
the
Number
of
Small
Businesses
The
following
sections
present
(
1)
the
definition
of
small
businesses
under
the
requirements
of
the
original
IUR
and
the
proposed
IUR
amendments,
(
2)
the
definition
of
small
businesses
that
is
used
for
the
purposes
of
this
report,
and
(
3)
the
methodology
for
determining
the
number
of
small
businesses
expected
to
report
under
the
IUR
amendments.

a.
Definition
of
Small
Business
The
definition
of
small
businesses
under
TSCA
§
8(
a)
includes
those
firms
whose
annual
sales
are
less
than
or
equal
to
$
40
million
and
produce
less
than
100,000
pounds
of
a
regulated
substance
at
a
single
manufacturing
site
(
the
original
IUR
exempts
small
businesses
that
manufacture
less
than
100,000
pounds
of
a
chemical
in
a
reporting
year
from
all
reporting;
this
exemption
will
remain
unchanged
under
the
proposed
IUR
amendments).
Firms
that
generate
$
4
million
or
less
in
annual
sales
are
considered
small
businesses
regardless
of
production
volume
(
40
CFR
704.3).
For
purposes
of
this
analysis,
it
is
assumed
that
any
firm
with
sales
less
than
or
equal
to
$
40
million
is
small,
regardless
of
production
volume.
38
This
assumption
may
tend
to
overestimate
the
number
of
small
businesses
affected
because
it
includes
entities
that
may
not
meet
all
small
business
requirements
under
TSCA
§
8(
a).

b.
Number
of
Small
Businesses
The
expected
number
of
small
businesses
reporting
under
the
proposed
IUR
amendments
was
estimated
according
to
the
following
methodology.
First,
the
expected
number
of
businesses
producing
organic
chemicals
that
would
be
required
to
report
was
estimated
based
on
information
in
the
CUS
Database
for
the
1994
reporting
cycle.
Second,
the
expected
number
of
businesses
producing
inorganic
chemicals
that
would
be
required
to
report
was
estimated.
Because
the
CUS
contains
no
data
for
inorganic
chemicals,
the
number
of
businesses
producing
inorganic
chemicals
that
are
expected
to
report
was
estimated
based
on
the
relationship
between
the
number
of
organic
VII­
3
chemicals
and
inorganic
chemicals
identified
in
the
CICIS
Database
(
1986)
maintained
by
EPA.

Together,
these
two
estimates
represent
the
number
of
small
businesses
affected.

i.
Organic
Chemicals
Businesses
To
determine
the
number
of
small
businesses
producing
organic
chemicals
that
may
be
affected
by
the
proposed
rule,
annual
sales
information
was
sought
for
the
758
companies
that
submitted
production
volume
and
company
identification
information
for
the
IUR
in
1994
(
CUS
Database
1996,
CUS
Database
1997).
Of
these
companies,
information
on
parent
company
annual
sales
was
obtained
for
627
companies
from
the
Thomas
Register
(
1990),
Dun
and
Bradstreet
(
D&
B
1996,
D&
B
1992),
and
Ward's
Business
Directory
(
1996).
Annual
sales
data
were
unavailable
for
the
remaining
131
companies.

There
are
several
possible
explanations
for
the
unavailability
of
information
for
these
remaining
companies.
First,
these
businesses
may
be
too
small
to
be
listed
in
the
directories
that
were
consulted.

Second,
the
IUR
database
may
be
out­
of­
date
because
it
is
based
on
TSCA
reporting
for
1994
(
e.
g.,
some
companies
may
have
gone
out
of
business
or
changed
hands
since
the
information
was
reported).
Finally,
certain
companies
may
have
requested
to
be
"
delisted"
or
may
have
declined
to
provide
information
to
the
various
directories.

Because
the
missing
company
information
could
not
be
obtained,
these
companies
have
been
allocated
to
the
small,
medium,
and
large
size
categories
according
to
two
methodologies.
In
the
first
approach,
each
of
the
remaining
131
companies
has
been
distributed
according
to
the
relative
distribution
established
for
the
627
companies
for
which
data
were
available.
The
second
approach
placed
all
131
companies
in
the
small
business
category
based
on
the
assumption
that
these
companies
were
too
small
to
be
listed.
Table
VII­
1
presents
company
size
information
for
the
estimated
758
parent
companies
that
submitted
IUR
information
in
1994.
The
table
identifies
the
proportion
of
small,
medium,

and
large
companies,
as
defined
by
annual
sales,
that
are
likely
to
be
affected
by
the
proposed
rule.
As
the
table
indicates,
a
range
of
between
21
percent
and
35
percent
of
the
regulated
community
may
be
considered
to
be
small
(
i.
e.,
annual
parent
company
sales
less
than
or
equal
to
$
40
million).
VII­
4
Table
VII­
1.
Size
of
Manufacturing
Companies
Producing
Organic
Chemicals
Based
on
Annual
Sales
Information
Company
Size
Based
on
Annual
Salesa
Basisb
Method
1:
Allocated
by
Proportionsc
Method
2:
Allocated
as
Small
Businessesd
Companies
Companies
Companies
Number
Percent
Number
Percent
Number
Percent
Small
(
annual
sales
less
than
or
equal
to
$
40
million)
132
21
159
21
264
35
Medium
(
annual
sales
greater
than
$
40
million
and
less
than
or
equal
to
$
200
million)
133
21
159
21
133
18
Large
(
annual
sales
greater
than
$
200
million)
362
58
440
58
362
48
Total
627
100
758
100
758
100
a
Annual
sales
are
for
the
parent
company,
when
applicable.
b
The
actual
breakdown
by
size
of
the
627
companies
that
reported
for
the
IUR
in
1994
for
which
company
sales
data
were
available.
c
The
estimated
breakdown
by
size
of
all
758
companies
that
reported
for
the
IUR
in
1994
if
the
sizes
of
the
131
companies
for
which
sales
data
were
unavailable
are
assumed
to
be
in
the
same
proportion
as
the
sizes
of
the
companies
for
which
sales
data
were
available.
d
The
estimated
breakdown
by
size
of
all
758
companies
that
reported
for
the
IUR
in
1994
if
all
of
the
131
companies
for
which
sales
data
were
unavailable
are
assumed
to
be
small
businesses.

Sources:
Ward's
Business
Directory
1996,
D&
B
1996,
D&
B
1992,
Thomas
Register
1990,
CUS
Database
1996,
CUS
Database
1997.

ii.
Inorganic
Chemicals
Businesses
EPA
next
accounted
for
businesses
that
will
submit
inorganic
chemical
reports
under
the
IUR
amendments.
The
number
of
these
businesses
was
estimated
indirectly
based
on
the
projected
number
of
reports
for
organic
chemicals
and
inorganic
chemicals
under
the
IUR
amendments,
as
reported
in
Chapter
III.
EPA
assumed
that
the
ratio
of
the
number
of
businesses
reporting
for
inorganic
chemicals
to
the
number
of
businesses
reporting
for
organic
chemicals,
based
on
the
CUS
Database,
was
the
same
as
the
ratio
of
the
number
of
reports
for
inorganic
chemicals
(
based
on
the
CICIS
Database)
to
the
number
of
reports
for
organic
chemicals.
In
other
words:

#
Inorganic
Businesses
=
(#
Inorganic
Reports/#
Organic
Reports)
x
(#
Organic
Businesses)
#
Inorganic
Businesses
=
(
4,502/
16,576)
x
758
Number
of
Inorganic
Businesses
=
206
39
Please
note
that
sums
may
not
add
due
to
rounding.

VII­
5
Based
on
the
analysis
of
sales
information
for
small
businesses
producing
organic
chemicals,
the
number
of
inorganic
businesses
can
be
broken
down
into
small,
medium
and
large
companies.
Using
the
percentages
derived
through
the
proportional
allocation
method
and
presented
in
Table
VII­
1,
the
breakdown
of
inorganic
businesses
is
calculated
as
120
large
companies,
43
medium
companies
and
43
small
companies.
Using
the
percentages
derived
through
the
second
method,
placing
all
companies
for
which
information
was
unavailable
into
the
small
business
category,
the
breakdown
of
inorganic
businesses
is
calculated
as
99
large
companies,
37
medium
companies,
and
72
small
companies.
39
iii.
Total
Number
of
Businesses
The
total
number
of
businesses
submitting
reports
for
organic
and
inorganic
chemicals
combined
is
estimated
to
be
964
businesses.
Under
the
proportional
allocation
method,
there
are
estimated
to
be
560
large,
202
medium,
and
202
small
businesses.
Under
the
small
business
allocation
method,
there
are
estimated
to
be
461
large,
170
medium,
and
336
small
businesses.

However,
964
may
be
an
overestimate
of
the
total
number
of
businesses
expected
to
report
under
the
proposed
IUR
amendments
because
some
businesses
may
submit
a
form
for
both
organic
chemicals
and
inorganic
chemicals.
These
companies
would
tend
to
be
double
counted,
once
as
an
inorganic
chemical
business
and
once
as
an
organic
chemical
business,
according
to
the
approach
presented
in
this
analysis.

B.
Analysis
of
Economic
Impacts
According
to
the
1997
EPA
Interim
Guidance
for
Implementing
the
Small
Business
Regulatory
Enforcement
Fairness
Act
and
Related
Provisions
of
the
Regulatory
Flexibility
Act
(
U.
S.
EPA
1997b),
the
RFA
does
not
define
"
significant
economic
impact
on
a
substantial
number"
of
small
entities.
The
criteria
recommended
by
the
guidance
for
evaluating
the
impact
on
small
businesses
is
the
annualized
compliance
cost
of
the
rule
as
a
percentage
of
sales.
If
the
cost
is
less
than
1
percent
for
all
affected
small
entities,
regardless
of
the
total
number
of
small
entities
affected,
then
the
rule
is
presumed
not
to
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
40
The
contents,
administration,
and
results
of
the
survey
are
described
in
detail
in
Appendix
D.

VII­
6
The
RFA
requires
that
EPA
consider
only
the
effects
of
the
IUR
amendments
(
i.
e.,
the
amendment
to
the
existing
rule).
Throughout
the
development
of
the
estimates,
the
following
assumptions
were
used:


each
site
produces
an
average
of
8.4
reports
(
CUS
Database
1997);
and

each
small
business
has
one
site.

The
assumption
of
one
site
per
small
business
is
supported
by
the
results
of
the
industry
survey.
40
Small
companies
that
were
surveyed
reported
that
an
average
of
1.2
sites
manufacture
a
single
IUR­
reportable
chemical.
This
chapter
also
presents
a
sensitivity
analysis
examining
the
impact
on
costs
if
more
than
one
site
per
small
business
is
assumed.

1.
Determination
of
Individual
Small
Business
Impact
a.
IUR
Amendments
­
Small
Business
Compliance
for
Partial
Form
Completion
of
a
partial
form
is
required
for
chemicals
with
volumes
of
between
25,000
pounds
and
100,000
pounds
or
for
chemicals
meeting
one
of
the
partial
exemptions.
Because
small
businesses
are
exempt
from
reporting
chemicals
with
volumes
under
100,000
pounds,
only
those
meeting
the
partial
exemptions
with
production
volumes
of
100,000
pounds
or
greater
will
be
required
to
report.
It
is
not
known
how
many
small
businesses
would
complete
the
partial
form,
because
the
methodology
for
determining
the
total
number
of
small
businesses
is
based
on
data
of
previous
reporting
under
the
IUR.
Data
are
therefore
not
available
for
those
companies
that
are
currently
exempt.
Because
estimates
of
the
number
of
small
business
completing
only
the
partial
form
are
unavailable,
it
is
assumed
that
all
will
complete
the
full
form.
This
assumption
will
tend
to
overestimate
the
total
costs
of
compliance.

In
the
event
that
there
are
small
businesses
that
would
complete
the
partial
form,
estimates
of
the
costs
of
compliance
are
presented.
For
organic
chemicals,
the
average
incremental
cost
of
compliance
with
the
amendments
is
estimated
to
be
between
$
5,780
and
$
10,407.
Dividing
this
cost
by
the
average
annual
sales
of
$
16.5
million,
the
average
burden
to
sales
ratio
is
0.04
percent
to
0.06
percent
for
organic
chemical
small
businesses
filing
the
partial
form.
For
small
businesses
manufacturing
inorganic
chemicals
volumes
between
25,000
and
100,000
pounds,
the
average
VII­
7
incremental
cost
of
compliance
with
the
IUR
amendments
is
estimated
to
be
between
$
9,489
and
$
15,820
(
note
that
the
baseline
costs
for
inorganic
chemicals
is
zero).
Dividing
this
cost
by
the
average
annual
sales
of
$
16.5
million,
the
average
burden
to
sales
ratio
for
small
businesses
reporting
to
the
IUR
is
approximately
0.06
percent
to
0.10
percent
for
inorganic
chemical
small
businesses
filing
the
partial
form.

b.
IUR
Amendments
­
Small
Business
Compliance
for
Full
Form
Completion
of
a
full
form
is
required
for
chemicals
produced
at
volumes
of
100,000
pounds
or
greater
and
not
meeting
one
of
the
partial
exemptions.
For
analytical
purposes,
EPA
has
assumed
that
all
of
the
small
businesses
fit
into
this
category.
The
average
incremental
cost
of
compliance
for
completing
the
full
form
for
organic
chemicals
is
between
$
21,169
and
$
27,112.
Dividing
this
cost
by
the
average
sales
of
$
16.5
million
for
small
businesses,
the
average
burden
to
sales
ratio
is
approximately
0.13
percent
to
0.16
percent.
For
inorganic
chemicals
manufactured
at
volumes
above
100,000
pounds,
the
average
incremental
cost
of
compliance
with
the
IUR
amendments
for
an
average
small
company
was
estimated
to
be
between
$
24,879
and
$
32,526.
Dividing
this
cost
by
the
average
sales
figure
of
$
16.5
million,
the
average
burden
to
sales
ratio
for
small
businesses
reporting
on
inorganic
chemicals
to
the
IUR
is
approximately
0.15
percent
to
0.20
percent.

It
has
been
assumed
for
this
analysis
that
there
is,
on
average,
one
site
per
company
for
small
businesses.
As
mentioned
earlier
in
the
chapter,
this
assumption
is
supported
by
the
results
of
the
industry
survey,
which
indicated
an
average
of
1.2
sites
per
small
business.
Even
though
the
assumption
of
one
site
per
small
business
may
tend
to
marginally
underestimate
the
number
of
sites
per
company,
it
is
important
to
note
that
small
businesses
would
have
to
average
between
5
and
28
sites
per
company
in
order
for
a
cost
greater
than
1
percent
of
annual
sales
to
be
incurred.

Additionally,
the
assumption
of
one
site
per
small
business
is
offset
by
another
assumption
that
may
tend
to
overestimate
costs.
Specifically,
the
estimated
number
of
reports
(
8.4
reports)
per
site
used
in
the
analysis
may
be
an
overestimate
of
the
expected
number
of
reports
per
site
for
small
businesses
because
smaller
sites
tend
to
produce
fewer
chemicals
(
ICF
1996).

The
impact
of
the
proposed
IUR
amendments
on
small
businesses
that
produce
inorganic
chemicals
only
(
as
opposed
to
those
that
produce
organic
and
inorganic
chemicals
or
only
organic
chemicals)
will
be
slightly
higher
than
the
incremental
cost
of
the
amendments
for
small
businesses
as
a
VII­
8
whole,
attributable
to
the
fact
that
the
baseline
costs
for
inorganic
chemicals
are
zero.
These
additional
costs
are
small,
however,
and
the
increased
burden
as
a
percentage
of
sales
is
approximately
one
hundredth
of
a
percent.
Table
VII­
2
summarizes
the
effect
of
the
IUR
amendments
on
small
businesses.

As
the
table
indicates,
approximately
43
to
72
small
businesses
that
produce
only
inorganic
chemicals
would
be
required
to
report
under
the
proposed
IUR
amendments.

As
presented
in
Table
VII­
2,
the
economic
burden
of
the
IUR
amendments
on
small
businesses
does
not
exceed
1
percent
of
the
annual
sales
for
an
average
small
business.
In
fact,
small
businesses
producing
organic
chemicals
and
completing
the
full
form
would
need
to
have
annual
sales
of
less
than
$
2.7
million
($
27,112
divided
by
one
percent)
to
experience
a
significant
economic
impact.
Small
businesses
producing
inorganic
chemicals
and
completing
the
full
form
would
need
to
have
annual
sales
of
less
than
$
3.2
million
($
32,526
divided
by
one
percent).
Given
the
estimated
mean
annual
sales
of
$
16.5
million
for
small
businesses
potentially
reporting
to
the
original
IUR,
the
typical
small
business
will
not
experience
a
significant
economic
impact
from
the
proposed
changes
to
the
rule.
Because
the
amendments
will
not
significantly
impact
a
substantial
number
of
small
entities,
EPA
has
determined
that
an
Initial
Regulatory
Flexibility
Analysis
(
IRFA)
is
not
necessary
for
the
proposed
IUR
amendments.

Table
VII­
2.
Effect
of
IUR
Amendments
on
Small
Businesses
Allocation
Strategy
Facility,
Manufacturing,
Processing,
and
Use
Information
(
Production
volume
greater
than
100,000
pounds)

Organic
Chemical
Reporters
Inorganic
Chemical
Reporters
Number
Affected
Percent
of
Sales
Number
Affected
Percent
of
Sales
Allocated
by
Proportions
159
0.13
­
0.16
43
0.15
­
0.20
Allocated
as
Small
Businesses
264
0.13
­
0.16
72
0.15
­
0.20
Notes:
Impacts
are
overestimated
because
it
is
assumed
that
all
small
businesses
would
complete
the
full
form.
The
incremental
cost
as
a
percentage
of
sales
for
completion
of
the
partial
form
is
lower
than
for
the
full
form.
These
numbers
are
presented
in
the
text
above.
Sums
may
not
add
due
to
rounding.

Sources:
CICIS
Database
1986,
CUS
Database
1996,
CUS
Database
1997,
ICF
1996,
Ward's
Business
Directory
1996,
D&
B
1996,
D&
B
1992,
Thomas
Register
1990.

2.
Sensitivity
Analysis
The
analysis
above
assumes
an
average
of
one
site
per
small
business.
As
mentioned,

this
assumption
is
confirmed
by
the
survey
results
indicating
an
average
of
1.2
sites
per
small
business.

To
determine
the
impact
of
varying
the
assumption
of
one
site
per
small
business,
this
section
presents
a
sensitivity
analysis
assessing
the
effect
on
incremental
costs
of
assuming
two
sites
per
small
business.
VII­
9
Again,
because
only
small
businesses
meeting
the
partial
exemptions
with
production
volumes
of
100,000
pounds
or
greater
will
be
required
to
report,
it
is
assumed
that
all
will
complete
the
full
form.
In
the
event
that
there
are
small
business
that
would
complete
the
partial
form,
estimates
of
the
costs
of
compliance
are
presented.

The
cost
of
reporting
under
the
IUR
amendments
assuming
two
sites
per
business
is
double
the
cost
of
reporting
under
the
assumption
of
one
site
per
business.
However,
as
presented
in
Table
VII­
3,
the
economic
burden
on
small
businesses
still
does
not
exceed
1
percent
of
the
annual
sales
for
an
average
small
business.
Therefore,
the
results
of
this
sensitivity
analysis
confirm
that
an
Initial
Regulatory
Flexibility
Analysis
(
IRFA)
is
not
necessary
for
the
proposed
IUR
amendments.

Table
VII­
3.
Effect
of
IUR
Amendments
on
Small
Businesses
Assuming
Two
Sites
Per
Small
Business
Allocation
Strategy
Facility,
Manufacturing,
Processing,
and
Use
Information
(
Production
volume
greater
than
100,000
pounds)

Organic
Chemical
Reporters
Inorganic
Chemical
Reporters
Number
Affected
Percent
of
Sales
Number
Affected
Percent
of
Sales
Allocated
by
Proportions
159
0.26
­
0.33
43
0.30
­
0.39
Allocated
as
Small
Businesses
264
0.26
­
0.33
72
0.30
­
0.39
C.
Environmental
Equity/
Justice
Executive
Order
12898,
Federal
Actions
to
Address
Environmental
Justice
in
Minority
Populations
and
Low­
Income
Populations
requires
that
all
federal
agencies
address
the
issue
of
environmental
justice
by
identifying
and
revising
programs,
policies,
and
activities
that
may
disproportionately
and
adversely
affect
the
health
of
minority
or
low
income
populations
or
their
environments.

Because
the
proposed
IUR
amendments
are
an
information
collection
exercise,
there
are
no
negative
environmental
equity
issues
associated
with
them.
Instead,
the
information
that
would
become
available
through
the
proposed
rule
would
enable
the
Agency
to
target
educational,
regulatory,
or
enforcement
activities
towards
industries
or
chemicals
that
pose
the
greatest
risks
and/
or
to
target
programs
for
geographic
areas
that
are
at
the
highest
risk.
Thus,
the
information
proposed
to
be
gathered
under
the
IUR
amendments
would
help
EPA
to
make
decisions
that
will
benefit
potentially­

atrisk
communities,
some
of
which
may
be
disadvantaged.
41
High
site
reporting
is
defined
as
100
or
more
reports
from
IUR
submitting
sites.

VII­
10
To
illustrate
the
way
in
which
information
proposed
to
be
collected
under
the
IUR
amendments
would
benefit
minority
and
economically
disadvantaged
persons
and
communities,
geographic
areas
with
high
site
reporting41
have
been
compared
with
social
and
economic
characteristics
of
the
populations
potentially
affected
by
the
proposed
amendments.
A
significant
portion
of
low
income
and
minority
communities
are
in
proximity
to
IUR
sites.
Specifically,
of
the
121.2
million
people
who
lived
within
10
miles
of
an
IUR
site
(
49
percent
of
the
1990
U.
S.
population),
almost
38
million
(
30
percent)
were
minorities.
This
number
is
greater
than
the
nationwide
figure
of
approximately
49
million
(
20
percent)

minority
individuals,
out
of
the
total
1990
U.
S.
population
of
248.7
million.
Roughly
24
million
(
20
percent)
of
the
people
living
within
12
miles
of
an
IUR
site
were
at
or
below
150
percent
of
the
poverty
level.
This
is
consistent
with
the
census
figure
of
52.5
million
(
21
percent)
individuals
at
or
below
150
percent
of
the
poverty
level
nationwide
(
U.
S.
Census
1990).

The
information
proposed
to
be
collected
through
the
IUR
amendments
would
allow
EPA
to
focus
risk
screening
and
assessment
activities
on
chemicals
with
high
exposure
profiles
and
risks.

Additionally,
because
the
IUR
amendments
data
would
allow
EPA
to
view
chemical
exposures
and
uses
on
a
regional
or
local
level,
it
is
possible
that
analyses
could
be
undertaken
that
would
benefit
disadvantaged
groups.
Specific
activities
to
benefit
these
groups
could
include
information
dissemination,
community
awareness,
exposure
mitigation,
pollution
prevention,
outreach
and
educational
programs,
and
consumer
protection
programs.
In
addition,
EPA
may
share
aggregated
information
with
non­
governmental
organizations
(
NGOs),
private
sector
stewardship
programs,
other
federal
programs
such
as
OSHA
and
CPSC,
and
other
federal
and
state
government
agencies,
resulting
in
worker
or
consumer
oriented
programs
or
local,
state,
and
regional
programs
targeting
disadvantaged
groups.

Additionally,
as
discussed
in
Chapter
V,
the
information
that
would
be
collected
under
the
proposed
IUR
amendments
would
aid
in
targeting
potential
health
and
ecosystem
risks.
Minority
and
economically
disadvantaged
groups
would
benefit
from
these
potential
risk
reductions
even
if
programs
specifically
targeting
disadvantaged
persons
do
not
exist.
Because
the
production
volume
information
currently
available
to
EPA
is
not
always
sufficient
for
identifying
chemical
exposures
and
human
risks,
VII­
11
better
compilation
of
use
and
exposure
data
would
enable
EPA
to
predict
more
accurately
the
magnitude
and
nature
of
ecosystem
and
human
population
exposure.
This
better
information
on
uses
and
exposures
would
potentially
benefit
minority
and
economically
disadvantaged
groups
by
alerting
them
to
the
chemical
exposure
risks
in
their
workplaces
and
communities.

Additionally,
the
availability
of
better
information
would
also
enable
EPA
to
conserve
resources
and
focus
efforts
on
chemicals
that
pose
higher
risks,
and
thereby
potentially
more
effectively
and
expeditiously
reduce
the
risks
posed
by
these
chemicals.
For
example,
worker
exposure
information
would
be
used
to
develop
priorities
and
to
determine
chemicals
or
uses
that
require
a
more
detailed
risk
screening
or
assessment.
The
rapid
identification
of
potentially
high
risk
situations
would
also
allow
for
a
more
timely
and
efficient
identification
and
development
of
safer
substitutes
and
alternative
chemicals,

processes,
and
technologies,
thereby
benefiting
all
potentially
exposed
employees
(
including
disadvantaged
ones)
that
work
at
chemical
manufacturing,
importing,
and
processing
sites.
Although
programs
and
safety
measures
would
not
have
been
targeted
to
a
specific
subset
of
workers,

disadvantaged
persons
employed
at
these
sites
would
benefit
from
EPA's
improved
ability
to
target
risks
and
thereby
more
efficiently
implement
the
programs
and
safety
measures
necessary
to
reduce
these
risks.
R­
1
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BLS
(
Bureau
of
Labor
Statistics).
1997
(
April
5).
Transcribed
Telephone
Conversation
with
Wayne
Shelley,
Office
of
Compensation
Levels
and
Trends,
Bureau
of
Labor
and
Statistics,
Washington,
DC.

Browning.
1996
(
March
8).
Adam
Browning,
TRI
Coordinator,
U.
S.
Environmental
Protection
Agency,

Region
9.
Transcribed
telephone
conversation
with
Ellie
Stewart,
ICF
Incorporated,
Washington,
D.
C.

CICIS
Database.
1986.
Information
from
the
Chemical
in
Commerce
Information
System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.

Environmental
Protection
Agency,
Washington,
D.
C.

Codina.
1996
(
March
7).
Thelma
Codina,
Pesticides
and
Toxics
Branch,
U.
S.
Environmental
Protection
Agency,
Region
5.
Transcribed
telephone
conversation
with
Ellie
Stewart,
ICF
Incorporated,

Washington,
D.
C.

Cropper
and
Freeman.
1991.
Maureen
Cropper
and
A.
Myrick
Freeman
III.
"
Environmental
Health
Effects,"
in
Measuring
the
Demand
for
Environmental
Quality.
J.
Braden
and
C.
Kolstad
(
eds.).
North­

Holland,
New
York.
1991.
pp.
165
­
211.

CUS
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1996.
Information
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maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
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Washington,
D.
C.

CUS
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1997.
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the
Chemical
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System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
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Washington,
D.
C.
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2
D&
B
(
Dun
and
Bradstreet).
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(
March).
Duns
Market
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Dun
and
Bradstreet
Information
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Parsippany,
N.
J.

D&
B
(
Dun
and
Bradstreet).
1992.
Million
Dollar
Directory:
America's
Leading
Public
and
Private
Companies,
Top
50,000
Companies.
Dun
and
Bradstreet
Information
Services,
Murray
Hill,
N.
J.

EOP
(
Executive
Office
of
the
President).
1987.
Standard
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the
President,
Office
of
Management
and
Budget.
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D.
C.

Fisher
et
al.
1989.
Ann
Fisher,
Lauraine
Chestnut
and
Daniel
Violette.
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Value
of
Reducing
Risks
of
Death:
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New
Evidence."
Journal
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No.
1.
pp.
88
­
100.

Freeman
A.
M.
1993.
A.
Myrick
Freeman
III.
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and
Resource
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Theory
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the
Future,
Washington,
D.
C.
pp.
199­
216.

Fried.
1996
(
March
7).
Fred
Fried,
Toxics
Release
Inventory
Program,
U.
S.
Environmental
Protection
Agency,
Region
8.
Transcribed
telephone
conversation
with
Ellie
Stewart,
ICF
Incorporated,
Washington,

D.
C.

GAO
(
General
Accounting
Office).
1994
(
September
26).
Toxic
Substances
Control
Act:
Legislative
Changes
Could
Make
the
Act
More
Effective.
General
Accounting
Office,

http://
www.
mapcruzin.
com/
scruztri/
docs/
gao94103.
htm.
RCED­
94­
103.

Glynn.
1996
(
June
26
and
July
16).
John
Glynn,
Department
of
Energy,
Washington
D.
C.
Transcribed
telephone
conversations
with
Ellie
Stewart,
ICF
Incorporated,
Washington,
D.
C.

Hope.
1996
(
March
7).
Walter
Hope,
Massachusetts
Department
of
Environmental
Protection.

Transcribed
telephone
conversation
with
Ellie
Stewart,
ICF
Incorporated,
Washington,
D.
C.
R­
3
ICF.
1996.
Survey
for
Estimating
the
Industry
Burden
Associated
With
Collecting
Additional
Chemical
Use
Data
Under
TSCA
Section
8
(
IUR
Amendments).
OMB
Control
No.
2070­
0034.
Conducted
for
EPA
by
ICF
Incorporated,
Washington,
D.
C.

IMD
(
Information
Management
Division).
1996.
Questions
for
Branches
within
OPPT
with
Responsibility
for
IUR
Data
Collection,
Processing,
and
Storage,
Information
Management
Division,
U.
S.

Environmental
Protection
Agency,
Washington,
D.
C.

Kolb
and
Scheraga.
1990.
Jeffrey
A.
Kolb
and
Joel
D.
Scheraga.
"
Discounting
the
Benefits
and
Costs
of
Environmental
Regulations."
Journal
of
Policy
Analysis
and
Management.
Volume
9,
No.
3.
pp.
381­

390.

Larmee.
1996
(
March
8
and
March
11).
Stan
Larmee,
Chemical
Release
Information
Division,
New
Jersey
Department
of
Environmental
Protection.
Transcribed
telephone
conversation
with
Ellie
Stewart,

ICF
Incorporated,
Washington,
D.
C.

Layne.
1996
(
March
7).
Warren
Layne,
Toxics
Section,
U.
S.
Environmental
Protection
Agency,
Region
6.
Transcribed
telephone
conversation
with
Ellie
Stewart,
ICF
Incorporated,
Washington,
D.
C.

Lind.
1990.
Robert
C.
Lind.
"
Reassessing
the
Government's
Discount
Rate
Policy
in
Light
of
New
Theory
and
Data
in
a
World
Economy
with
a
High
Degree
of
Capital
Mobility."
Journal
of
Environmental
Economics
and
Management.
Volume
18.
pp.
S­
8
­
S­
28.

McBride.
1996
(
April
1).
Allan
McBride,
Office
of
Solid
Waste
and
Emergency
Response
(
OSWER),

U.
S.
Environmental
Protection
Agency.
Transcribed
telephone
conversation
with
Julie
Bedford,
ICF
Incorporated,
Washington,
D.
C.
R­
4
MADEP
(
Massachusetts
Department
of
Environmental
Protection).
1995.
Toxics
Use
Reduction:
1994
Reporting
Package.
Massachusetts
Department
of
Environmental
Protection,
Bureau
of
Waste
Prevention,
Boston,
Massachusetts.

Miller.
1989.
"
Willingness
to
Pay
Comes
of
Age:
Will
the
System
Survive?"
Northwestern
University
Law
Review.
Volume
83.
pp.
876
­
907.

Moore
and
Viscusi.
1990.
Michael
J.
Moore
and
W.
Kip
Viscusi.
"
Discounting
Environmental
Health
Risks:
New
Evidence
and
Policy
Implications."
Journal
of
Environmental
Economics
and
Management.

Volume
18.
pp.
S­
51
­
S­
62.

NAPA
(
National
Academy
of
Public
Administration).
1995
(
April).
Setting
Priorities,
Getting
Results:
A
New
Direction
for
EPA.
National
Academy
of
Public
Administration,
Washington,
D.
C.

OPM
(
Office
of
Personnel
Management).
1996.
Salary
Table
No.
96­
DCB.
Incorporating
the
2.00%

General
Schedule
Increase
and
a
Locality
Payment
of
6.04%
for
the
Locality
Pay
Area
of
Washington­

Baltimore,
DC­
MD­
VA­
WV.
Personnel
Systems
and
Oversight
Group,
Office
of
Compensation
Policy,

Compensation
Administration
Division.

OSPIRG
(
Oregon
State
Public
Interest
Research
Group).
1993
(
November).
Breaking
the
Chemical
Dependency:
The
First
Data
on
Oregon's
Industrial
Toxics
Use.
Prepared
by
the
Oregon
State
Public
Interest
Research
Group,
Portland,
Oregon.

Rozell
and
Brower.
1993
(
Summer).
David
K.
Rozell
and
Roy
W.
Brower.
Pollution
Prevention
Facility
Planning:
The
Oregon
Experience.
Pollution
Prevention
Review.
Volume
3,
No.
3.
277­
283.
R­
5
Rubin.
1996
(
March
20).
Steve
Rubin,
Office
of
Wastewater
Enforcement
and
Compliance,
Office
of
Water,
U.
S.
Environmental
Protection
Agency.
Transcribed
telephone
conversation
with
Julie
Bedford,

ICF
Incorporated,
Washington,
D.
C.

SAB
(
Science
Advisory
Board).
1990
(
September).
Reducing
Risk:
Setting
Priorities
and
Strategies
for
Environmental
Protection.
U.
S.
Environmental
Protection
Agency.
September,
1990.

Strasler.
1996
(
March
23).
Eric
Strasler,
Office
of
Water,
Office
of
Science
and
Technology,

Engineering
and
Analysis
Division,
U.
S.
Environmental
Protection
Agency.
Transcribed
telephone
conversation
with
Julie
Bedford,
ICF
Incorporated,
Washington,
D.
C.

Thomas
Register.
1990.
1990
Thomas
Register
of
American
Manufacturers,
Vols.
15
and
16.
Thomas
Publishing
Company,
New
York.

U.
S.
Census.
1990.
1990
Census
of
Population
and
Housing.
U.
S.
Department
of
Commerce,

Economics
and
Statistics
Administration
Bureau
of
the
Census,

http://
venus.
census.
gov/
cdrom/
lookup/
885912463,
Washington,
D.
C.

U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1990
(
February).
Economic
Analysis
for
the
TSCA
Inventory
Update
Final
Rule.
Mark
K.
Dreyfus,
James
W.
Long.
Office
of
Toxic
Substances,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency.

U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1992
(
May
29).
Guidelines
for
Exposure
Assessment;
Notice.
U.
S.
Environmental
Protection
Agency.
Federal
Register
57(
104):
22888­
22938.

U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1994
(
April
14).
Regulatory
Impact
Analysis
of
Amendments
to
Regulations
for
TSCA
Section
5
Premanufacture
Notifications.
Regulatory
Impacts
Branch,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency.
R­
6
U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1996a.
Access
EPA.
Office
of
Information
Research
Management,
U.
S.
Environmental
Protection
Agency,
Chapter
5.

U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1996b
(
July
30).
IUR
Amendments
­
Agency
Costs
Question.
Memorandum
from
Ward
Penberthy
to
Susan
Krueger,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency.

U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1996c
(
May
16).
IUR
Amendments
­
FOIA
Requests.
Memorandum
from
Scott
Sherlock,
Information
Management
Division,
U.
S.
Environmental
Protection
Agency,
to
Susan
Krueger,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency.

U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1996d
(
July
19).
Inventory
Update
Rule
(
IUR)

Amendment
Technical
Support
Document:
Exposure­
Related
Data
Useful
for
Chemical
Screening.

Prepared
for
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency.

U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1996e
(
July).
The
Medical
Costs
of
Selected
Illnesses
Related
to
Pollutant
Exposure.
Prepared
for
Nicolaas
Bouwes.
Regulatory
Impacts
Branch,

Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency.

U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1996f
(
July
2).
Regulatory
Impact
Analysis
of
Regulations
on
Microbial
Products
of
Biotechnology.
Economics,
Exposure,
and
Technology
Division,

Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency.

U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1996g
(
August
29).
Transcribed
Telephone
Conversation
with
Ruth
Heikkinen
on
Hotline
and
Mailing
Costs,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency.
R­
7
U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1997a
(
April).
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313.
Regulatory
Impacts
Branch,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency.

U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1997b
(
February
5).
EPA
Interim
Guidance
for
Implementing
the
Small
Business
Regulatory
Enforcement
Fairness
Act
and
Related
Provisions
of
the
Regulatory
Flexibility
Act.
Prepared
by
EPA
SBREFA
Task
Force,
U.
S.
Environmental
Protection
Agency.

U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1998a.
A
Review
of
Existing
Exposure­
Related
Data
Sources
and
Approaches
to
Screening
Chemicals:
A
Response
to
CMA.
Economic
and
Policy
Analysis
Branch,
Economics,
Exposure,
and
Technology
Division,
U.
S.
Environmental
Protection
Agency.

U.
S.
EPA
(
U.
S.
Environmental
Protection
Agency).
1998b
(
August
26).
1994
IUR.
Memorandum
from
Rob
Esworthy,
U.
S.
Environmental
Protection
Agency,
to
Susan
Krueger,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency.

Viscusi.
1992.
W.
Kip
Viscusi.
Fatal
Tradeoffs:
Public
and
Private
Responsibilities
for
Risk.
Oxford
University
Press,
New
York.

Ward's
Business
Directory.
1996.
Ward's
Business
Directory
of
U.
S.
Private
and
Public
Companies
1996.
Information
Access
Co.,
Gale
Research
Inc.,
New
York.
A­
1
APPENDIX
A.

DRAFT
REPORTING
FORM
FOR
THE
PROPOSED
IUR
AMENDMENTS
B­
1
APPENDIX
B.
CURRENT
DATA
COLLECTION
There
are
currently
a
number
of
chemical
data
sources
maintained
by
EPA
and
other
federal
and
state
agencies,
as
well
as
publicly
available
databases,
that
contain
limited
information
on
production,

processing,
emissions,
and
other
chemical
data.
However,
these
sources
generally
do
not
contain
the
type
of
chemical
use
and/
or
exposure
data
necessary
for
EPA
to
conduct
more
effective
chemical
risk
screening.
The
more
detailed
collection
of
use
and
exposure
information
proposed
under
the
IUR
amendments
would
provide
EPA
with
the
means
to
better
determine
those
chemicals
with
the
greatest
potential
for
risk,
and
thereby
conduct
more
effective
risk
management
activities.
This
appendix
describes
the
information
available
in
each
of
the
currently
available
sources
as
compared
to
the
data
that
is
proposed
to
be
collected
under
the
IUR
amendments.
Additional
information
can
be
found
in
"
A
Review
of
Existing
Exposure­
Related
Data
Sources
and
Approaches
to
Screening
Chemicals:
A
Response
to
CMA"
(
U.
S.
EPA
1998a).

1.
Air
Programs
and
Datasets

The
Office
of
Air
Quality
Planning
and
Standard
(
OAQPS)
maintains
the
Aerometric
Information
Retrieval
System
(
AIRS),
a
national
repository
for
information
on
seven
types
of
airborne
pollution
in
the
United
States.
The
AIRS
Facility
Subsystem
(
AFS),
one
of
the
four
AIRS
components,
is
used
to
track
point
source
emissions
and
compliance
data
from
industries.

Information
collected
includes
plant
compliance
summaries,
emissions
by
SIC­
code,
and
the
extent
and
distribution
of
emissions
(
U.
S.
EPA
1996a).
This
collection
focuses
on
air
emissions
and
does
not
contain
information
on
specific
chemical
production
volume,
uses,
or
worker
exposure
scenarios.


The
Office
of
Air
and
Radiation
(
OAR)
tracks
chemical
use,
hazard,
and
risk
information
for
approximately
150
chemicals
that
are
replacements
for
ozone
depleting
substances
(
ODS).
The
B­
2
information
is
collected
under
the
Significant
New
Alternatives
Policy
(
SNAP)
Program.
This
data
set
does
not
collect
the
detailed
chemical
exposure
and
use
information
called
for
by
the
IUR
amendments.

2.
Solid
and
Hazardous
Waste
Programs
and
Datasets

The
Office
of
Solid
Waste
and
Emergency
Response
(
OSWER)
manages
the
Biennial
Reporting
System
(
BRS).
The
BRS
data
describes
the
aspects
of,
and
monitors
the
trends
in,
hazardous
waste
generation,
management,
and
minimization
for
RCRA
large­
quantity
generators
and
for
treatment,
storage,
and
disposal
facilities
subject
to
RCRA
permitting
requirements.
Although
the
data
set
contains
information
on
the
chemical
constituents
in
hazardous
waste
from
the
paint,

petroleum,
and
pesticides
industries
(
U.
S.
EPA
1996a,
McBride
1996),
it
does
not
contain
information
on
specific
chemical
use,
worker
exposure
scenarios,
production
volumes,
or
production
locations.


The
Office
of
Emergency
and
Remedial
Response
(
OERR)
is
responsible
for
compiling
the
Oil
and
Hazardous
Material
Technical
Assistance
Data
System
(
OHMTADS),
which
contains
information
on
hazardous
substances
including:
chemical
name,
physical/
chemical
properties,

lists
of
regulations
covering
production
and
use
data,
safety
and
toxicity
data,
and
response
information
(
U.
S.
EPA
1996a)
for
large
volume
industrial
chemicals
transported
in
bulk
quantities.
This
data
set
does
not
contain
the
data
proposed
to
be
collected
under
the
IUR
amendments.


The
Office
of
Solid
Waste
(
OSW)
maintains
the
Resource
Conservation
and
Recovery
Information
System
(
RCRIS),
a
national
system
supporting
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
program.
This
system
tracks
events
and
activities
related
to
facilities
that
generate,
transport,
treat,
store,
or
dispose
of
hazardous
waste
(
U.
S.
EPA
1996a);
however,
the
dataset
does
not
collect
detailed
chemical
use
or
exposure
information
at
the
level
called
for
by
B­
3
the
IUR
amendments.
Additionally,
RCRA
reporting
does
not
account
for
chemicals
used
within
a
facility
that
are
not
disposed
of
or
treated
as
hazardous
waste.

3.
Water
Programs
and
Datasets

The
Office
of
Ground
Water
and
Drinking
Water
(
OGWDW)
maintains
the
Federal
Reporting
Data
System
(
FRDS),
a
repository
of
information
about
Public
Water
Supplies
(
PWS)
and
their
compliance
with
requirements
of
the
Safe
Drinking
Water
Act
(
SDWA)
of
1986
(
U.
S.
EPA
1996a).
This
database
does
not
include
chemical
exposure,
end
use,
manufacturer,
or
production
information
as
would
be
required
under
the
IUR
amendments.


The
Office
of
Water
(
OW)
compiles
the
Permit
Compliance
System
(
PCS),
a
computerized
management
information
system
containing
data
on
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit­
holding
facilities.
Each
permit
record
contains
information
that
identifies
permits,
pollutant
discharge
limits,
pollutants
discharged
in
wastewater,
and
facility
compliance
schedules
and
violations.
This
database
only
contains
industry­
specific
information
about
the
amount
and
type
of
chemicals
discharged
from
various
manufacturing
and
service
industries,
not
information
on
site­
specific
chemical
production,
worker
exposure,
or
chemical
end
use
(
Rubin
1996,
Strasler
1996,
U.
S.
EPA
1996a).

4.
Pollution
Prevention
and
Toxic
Substances
Programs
and
Datasets

The
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
administers
the
Toxic
Release
Inventory
(
TRI),
which
contains
site­
specific
information
on
the
amounts
of
approximately
540
individually
listed
toxic
chemicals
and
22
categories
of
chemical
compounds
released
directly
to
air,
water,

or
land
or
transferred
off­
site.
Because
the
database
only
collects
information
on
chemical
releases,
it
does
not
contain
site­
specific
information
on
chemical
production,
use,
or
worker
exposure
(
U.
S.
EPA
1996a).
B­
4

The
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
maintains
the
Premanufacture
Notification
(
PMN)
database
under
the
TSCA
§
5
New
Chemicals
Program.
The
database
contains
physical/
chemical
properties,
use
and
predicted
production
information,
worker
exposure
information,
and
process
related
information
for
"
new"
chemicals
submitted
for
approval
to
begin
commercialization.
This
data
set
provides
information
only
on
new
chemicals
and,
therefore,

has
a
negligible
overlap
with
the
data
proposed
to
be
collected
under
the
IUR
amendments.


The
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
developed
a
joint
voluntary
program
in
cooperation
with
CMA,
SOCMA,
CSMA,
and
API.
The
program,
entitled
the
Use
and
Exposure
Information
Voluntary
Project,
allows
EPA
to
collect
chemical
use,
exposure,
and
release
information
for
certain
chemicals
targeted
under
EPA's
Risk
Management
(
RM)
program.

Information
has
been
collected
in
three
groups
(
two
in
1994
and
one
in
1996)
for
15­
20
chemicals
per
group
from
a
total
of
approximately
100
facilities.
Because
of
the
voluntary
nature
of
the
program
and
the
limited
number
of
chemicals
examined,
the
data
are
not
collected
for
most
manufactured
chemicals.
Therefore,
data
generated
from
this
project
would
have
limited
usefulness
for
initial
risk
screening
activities.
Rather,
the
data
serves
to
inform
the
second
step
of
risk
characterization,
after
an
initial
risk
screening.
In
other
words,
UEIP
provides
detailed
information
on
a
small
number
of
chemicals
for
a
select
number
of
facilities,
but
it
would
be
difficult
to
extrapolate
from
this
data
set
to
develop
a
nationwide
picture
of
use
and
exposure.


The
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
requires
that
chemical
manufacturers
and
importers
report
facility
identification,
manufacturing,
use,
and
exposure
information
as
part
of
the
Primary
Assessment
Information
Rule
(
PAIR).
The
type
of
information
collected
under
the
PAIR
is
similar
to
the
type
of
information
proposed
to
be
collected
under
the
IUR
amendments.

However,
the
PAIR
information
is
collected
for
only
a
very
small,
select
set
of
chemicals
during
each
reporting
period,
and
the
chemicals
that
are
targeted
by
PAIR
change
from
year
to
year
based
on
the
priorities
of
the
Interagency
Testing
Committee.
Therefore,
the
information
collected
under
the
PAIR
provides
only
a
snapshot
of
the
use
and
exposure
of
a
small
set
of
B­
5
chemicals
each
year
rather
than
a
periodically
updated
record
of
toxic
chemical
manufacture,

exposure,
and
use.
B­
6
5.
Research
and
Development
Programs
and
Datasets

The
Office
of
Health
and
Environmental
Assessment
(
OHEA)
maintains
the
Integrated
Risk
Information
System
(
IRIS),
a
database
that
contains
summaries
of
health
risk
and
EPA
regulatory
information
on
more
than
500
specific
chemicals.
The
database
is
not
linked
to
chemical
use
and
does
not
provide
site­
specific
characterizations
of
workplace
exposure
scenarios
or
production
volumes.

6.
State
Agency
Data
Collection
Efforts

Massachusetts
maintains
a
database
of
emission
and
process
information
(
i.
e.,
quantity
produced,
process
and
end
product
description,
and
certain
chemical
identification
and
property
information)
from
manufacturers,
users,
and
processors
within
Massachusetts
only.
This
database
is
part
of
an
effort
to
reduce
toxic
wastes
in
the
state
(
Hope
1996).
The
information
is
collected
under
the
Toxic
Use
Reduction
Act
(
TURA);
however,
no
exposure
information
regarding
the
number
of
potentially
exposed
workers
or
uses
of
the
chemical
(
NAICS
codes,

consumer
uses,
etc)
is
collected
under
TURA
(
MADEP
1995).


New
Jersey
collects
production
volume
and
end­
use
information
under
the
NJ
state
Toxic
Catastrophe
Prevention
Act
(
TCPA),
supporting
a
risk
management
program
for
companies
that
manufacture,
process,
possess
or
use
chemicals
above
certain
chemical­
specific
threshold
levels.
The
threshold
levels
are
developed
for
each
individual
chemical
covered
under
the
program
based
on
volatility
and
toxicity,
and
may
range
from
as
low
as
100
pounds
to
greater
than
100,000
pounds.
The
information
collected
is
specific
only
to
production
and
end­
uses
within
the
state
of
New
Jersey.
Although
companies
are
required
to
report
chemical
information
as
part
of
the
state's
risk
management
program,
chemicals
shipped
in
or
out
of
a
site
as
product
are
not
tracked.
Information
reported
primarily
relates
to
release
scenarios
(
i.
e.,
quantity
of
chemical
released
from
the
site
into
the
air
or
water
or
as
solid/
hazardous
waste).
Additionally,

no
worker
exposure
data
is
collected
under
this
program
(
Larmee
1996).
B­
7

Oregon
gathers
facility
and
chemical­
specific
data
on
the
volume
of
toxic
materials
used
or
brought
on­
site
as
part
of
the
Toxics
Use
Reduction
and
Hazardous
Waste
Reduction
Act
(
TURHWRA)
of
1989.
The
primary
component
of
this
law
is
that
all
facilities
in
Oregon
that
report
under
the
Federal
Community
Right
to
Know
TRI
requirements
or
are
hazardous
waste
generators
must
develop
and
submit
facility
plans
to
reduce
toxic
chemicals
use
and
hazardous
waste
generation.
TURHWRA
does
not
contain
information
on
the
number
of
potentially
exposed
workers
or
provide
detailed
information
on
chemical
production
or
use
pathways.

However,
the
requirements
under
TURHWRA
do
provide
a
snap
shot
of
on­
site
use
of
toxic
chemicals
for
key
facilities
in
Oregon
(
Rozell
and
Brower
1993,
OSPIRG
1993).

7.
Other
Federal
Agencies
and
Data
Collection

The
Emergency
Response
Notification
System
(
ERNS)
is
maintained
by
the
U.
S.
Department
of
Transportation
and
is
used
to
store
information
on
notifications
of
releases
of
oil
and
hazardous
substances
into
the
environment.
ERNS
combines
data
from
the
National
Response
Center's
Database
with
data
from
the
10
EPA
Regions
(
U.
S.
EPA
1996a).
Release
reports
are
available
for
(
1)
substances
designated
as
hazardous
under
the
Comprehensive
Environmental
Response,

Compensation,
and
Liability
Act
(
CERCLA),
as
amended,
(
2)
oil
and
petroleum
products,
as
defined
by
the
Clean
Water
Act
of
1972
(
CWA)
and
amended
by
the
Oil
Pollution
Act
of
1990,

and
(
3)
all
other
types
of
materials.
Information
that
can
be
found
in
the
ERNS
database
includes,
but
is
not
limited
to
the
following:
the
material
and
quantity
released,
where
and
when
the
release
occurred,
the
agency
notified,
and
any
information
about
property
damage,
injuries,

and/
or
deaths
which
occurred
due
to
the
release.
However,
there
are
several
limitations
to
these
data.
ERNS
data
are
focused
on
information
about
releases
and
not
on
manufacturing
and
use
of
chemicals.
Secondly,
the
data
are
subject
to
a
certain
degree
of
uncertainty
because
ERNS
contains
primarily
initial
accounts
of
release
made
when
exact
details
are
often
unknown.
Lastly,

these
data
are
usually
not
updated
unless
an
EPA
region
is
involved
in
the
response
action.
B­
8

The
Occupational
Safety
and
Health
Administration
(
OSHA)
maintains
data
on
the
safety
and
health
of
workers,
including
worker
exposure
to
potentially
hazardous
chemicals
used
in
the
workplace.
This
data
focuses
primarily
on
site­
specific/
problematic
worker
exposures.
The
data
does
not
contain
information
regarding
the
number
of
workers
across
an
industry
that
may
be
exposed
to
toxic
chemicals
in
the
workplace
and
does
not
track
chemical
use
information.

Further,
it
does
not
track
chemicals
in
every
workplace
where
they
may
be
used,
and
only
focuses
on
those
where
problems
may
have
occurred
in
the
past.


The
U.
S.
Consumer
Product
Safety
Commission
(
CPSC)
collects
information
on
the
safety
and
potential
product
hazards
of
more
than
15,000
types
of
consumer
products
used
in
and
around
the
home.
Generic
safety
information,
such
as
product
labeling
and
packaging
requirements,
is
collected,
but
the
CPSC
does
not
maintain
the
type
or
level
of
information
that
would
be
required
under
the
IUR
amendments.
It
is
not
within
CPSC's
jurisdiction
to
develop
information
on
production
volume
and
actual
concentration
of
a
chemical
that
is
contained
within
a
product.

Information
on
consumer
use
and
potential
exposure
to
chemicals,
as
collected
under
the
IUR
amendments,
may
be
useful
to
CPSC.


The
Department
of
Energy
(
DOE)
maintains
data
on
natural
gas
exports
and
imports,
including
volume,
price,
and
point
of
entry
or
exit
of
the
natural
gas.
The
information
is
collected
and
made
available
to
the
public
quarterly.
Data
are
not
collected
for
natural
gas
after
it
moves
beyond
the
importation
site
or
for
natural
gas
that
is
both
produced
and
used
within
the
United
States.
Additionally,
data
are
not
collected
on
types
of
use
or
exposures
and
covers
only
a
small
subset
of
the
chemicals
potentially
subject
to
the
IUR
amendments
reporting
(
Glynn
1996).
DOE
also
maintains
data
on
petroleum
products
at
the
state
level
using
broad
categories
such
as
motor
gasoline
and
residual
fuel.


United
Nations
Environment
Programme
(
UNEP)
maintains
the
International
Register
of
Potentially
Toxic
Chemicals
(
IRPTC),
a
database
of
more
than
8,000
chemical
profiles
covering
subject
areas
ranging
from
hazard
identification
to
risk
assessment.
Chemical
and
product
type,
B­
9
use,
and
production
information
are
among
the
17
categories
of
data
entered
into
the
register
for
each
chemical
profile.
However,
the
data
are
international
in
focus
and
coverage
is
spotty.
In
addition,
site­
specific
information
is
not
included.

8.
Publicly
Available
Databases

Publicly
available
chemical
data
sources
include
chemical
industry
journals
(
e.
g.,
Chemical
Engineering
News
and
the
Chemical
Marketing
Reporter),
chemical
and
business
directories
(
e.
g.,
the
Directory
of
Chemical
Produces
and
the
Thomas
Register),
chemical
reference
documents
(
e.
g.,
the
Kirk­
Othmer
Encyclopedia
of
Chemical
Technology,
SRI
International's
Chemical
Economics
Handbook,
the
Freedonia
Market
Research
database,
and
the
Frost
&

Sullivan
Market
Intelligence
Database),
and
publications
from
chemical
trade
associations
(
e.
g.,

the
Chemical
Manufactures
Association,
and
the
American
Chemical
Society).
These
sources
may
be
somewhat
useful
for
characterizing
production
volume,
chemical
function,
and
use
category
information
once
individual
chemicals
have
been
identified,
but
this
information
is
often
either
too
general
to
be
used
to
determine
production
and
use
at
the
plant
level
or
too
specific
to
provide
data
on
industry­
wide
chemical
production.
In
addition,
often
the
information
in
these
databases
is
outdated.
In
general,
these
sources
do
not
contain
the
type
of
worker
and
consumer
exposure
information
that
would
be
collected
under
the
proposed
IUR
amendments.

Publicly
available
databases
are
described
in
more
detail
in
the
EPA
report
entitled
"
A
Review
of
Existing
Exposure­
Related
Data
Sources
and
Approaches
to
Screening
Chemicals:
A
Response
to
CMA"
(
U.
S.
EPA
1998a).
42
Data
maintained
by
EPA
in
the
CUS
database
system.

43
The
CUS
databases
maintained
by
the
Agency
contain
information
collected
under
the
IUR
every
4
years.
Three
data
collection
cycles
have
been
completed
­­
1986,
1990,
and
1994.
The
databases
contain
information
on
company
and
chemical
identification,
facility
location,
and
annual
production
volume.

44
The
CICIS
database
maintained
by
the
Agency
contains
information
collected
by
the
EPA
on
chemicals
in
commerce
in
the
United
States
in
1977.
The
data
includes
company
and
chemical
identification,
facility
location,
manufactured
or
imported
status,
and
production
volume
in
ranges
for
both
organic
and
inorganic
chemicals.
The
TSCA
Inventory
of
chemicals
is
updated
twice
a
year
based
on
information
from
the
Master
Inventory
File,
which
is
maintained
by
CAS.
Chemicals
are
added
periodically
to
the
Master
Inventory
File
through
the
New
Chemicals
Program.

C­
1
APPENDIX
C.
DEVELOPMENT
OF
THE
ESTIMATED
NUMBERS
OF
EXPECTED
SUBMISSIONS
FOR
THE
ORIGINAL
IUR
AND
IUR
AMENDMENTS
REPORTING
This
appendix
describes
the
process
used
to
develop
estimates
of
the
number
of
reports
that
would
be
submitted
if
the
proposed
IUR
amendments
were
adopted.
The
total
number
of
reports
was
estimated
for
each
proposed
threshold
based
on
data
submitted
in
1986,
1990,
and
1994
under
the
original
IUR
reporting
requirements.
42
This
appendix
contains
the
following
sections:


Section
A
describes
the
input
data
and
data
sources
that
were
used
as
a
basis
for
the
estimated
number
of
reports
and
presents
the
methodology
used
to
develop
the
estimates.


Section
B
presents
the
estimated
number
of
reports
for
each
of
the
proposed
options.

A.
Input
Data
and
Methodology
Data
compiled
from
EPA's
Chemical
Update
System
(
CUS)
43
and
EPA's
Chemicals
in
Commerce
Information
System
(
CICIS)
44
were
used
to
determine
the
estimated
number
of
reports
expected
under
the
proposed
IUR
amendments.
The
categories
of
input
data
refer
to
chemicals
reported
to
the
original
IUR,
and
organic
and
inorganic
chemicals
reported
under
CICIS.
When
referring
to
the
CICIS
data,
organic
chemicals
refers
to
all
non­
inorganic
chemicals
reported
under
CICIS.

The
CUS
database
was
used
to
determine
the
total
number
of
reportable
chemicals
under
the
IUR,
while
the
CICIS
database
was
used
to
develop
information
on
the
relative
number
of
inorganic
chemicals
in
commerce
as
compared
to
the
number
of
organic
chemicals.
This
ratio
was
then
used
to
estimate
the
number
of
reports
for
inorganic
chemicals
that
would
be
submitted
under
the
proposed
IUR
amendments.
45
The
total
number
of
sites
that
reported
under
the
1994
CUS
reporting
cycle
was
2,981.
Note
that
the
number
of
sites
for
each
reporting
threshold
as
reported
in
Tables
C­
1
and
C­
2
also
comes
directly
from
the
1994
CUS.
The
number
of
sites
values
presented
in
the
tables
do
not
sum
to
2,981
because
individual
sites
produce
multiple
types
of
chemicals
at
various
production
volumes.

C­
2
1.
Organic
Chemicals
and
Multiple
CAS
Number
Petroleum
Stream
Chemicals
Data
from
the
CUS
database
were
used
to
generate
the
estimates
of
expected
reports
for
organic
chemicals
and
petroleum
stream
chemicals.
The
data
are
based
on
the
actual
numbers
of
reports,
by
threshold
cut­
off,
received
during
the
1994
reporting
cycle.
These
input
data
include
the
number
of
individual
reports,
the
number
of
discrete
chemicals
reported,
the
number
of
Form
Us,
and
the
number
of
reporting
sites.
45
The
values
were
derived
for
each
of
the
various
production
volume
thresholds
to
facilitate
analysis
of
the
threshold
options
proposed
for
the
IUR
amendments.
The
data
are
presented
in
Tables
C­
1
and
C­
2
below.

Table
C­
1.
Organic
Chemicals
Reporting
Data
from
EPA's
CUS
Database
(
1994)

Threshold
(
lbs)
Reports
Discrete
Chemicals
Form
U's
Sites
Total
Reported
18,940
8,443
3,508
2,427
PV>
25K
15,909
7,070
3,363
2,319
PV>
100K
11,666
5,029
3,052
2,108
PV>
500K
7,694
3,023
2,456
1,789
PV>
1M
6,461
2,389
2,190
1,625
PV>
10M
3,443
926
1,364
1,114
Source:
CUS
Database
1996,
CUS
Database
1997.
C­
3
Table
C­
2.
Multiple
CAS
Number
Petroleum
Stream
Chemicals
Reporting
Data
from
EPA's
CUS
Database
(
1994)

Threshold
(
lbs)
Reports
Discrete
Chemicals
Form
U's
Sites
Total
Reported
6,118
451
1,554
1,167
PV>
25K
5,964
447
1,524
1,146
PV>
100K
5,828
441
1,476
1,116
PV>
500K
5,642
434
1,422
1,069
PV>
1M
5,542
426
1,398
1,048
PV>
10M
4,952
391
1,225
904
Source:
CUS
Database
1996,
CUS
Database
1997.

2.
Inorganic
Chemicals
The
number
of
inorganic
chemicals
likely
to
be
reported
under
the
IUR
amendments
was
derived
from
the
CICIS
data
presented
in
Table
C­
3.
The
CICIS
data
is
based
on
data
for
organic
and
inorganic
chemicals
and
is
presented
by
the
production
volume
categories
used
in
the
original
data
collection.
Those
reported
production
volume
categories
are
different
than
those
required
to
evaluate
the
various
IUR
amendments
options.
Therefore,
it
was
necessary
to
manipulate
the
data
to
reflect
the
thresholds
examined
by
the
IUR
amendments
reporting
options
(
e.
g.,
greater
than
10,000
lbs.,
greater
than
25,000
lbs.,
greater
than
100,000
lbs.,
etc.).
To
perform
this
manipulation,
the
ratio
of
inorganic
chemicals
to
organic
chemicals
in
the
CICIS
data
for
each
reported
threshold
was
applied
to
the
projected
numbers
of
chemicals
and
reports
developed
from
the
CUS
1994
data,
generating
numbers
of
reports
and
chemicals
for
inorganic
chemicals
corresponding
to
the
IUR
amendment
threshold
categories.
C­
4
Table
C­
3.
Reporting
Data
From
EPA's
CICIS
Database
(
1986)

Threshold
(
lbs)
Inorganic
Chemicals
Organic
Chemicals
Reports
Discrete
Chemicals
Sites
Reports
Discrete
Chemicals
Sites
PV
<
1K
6,338
2,595
811
52,799
32,520
2,433
PV
1K­
10K
1,364
649
458
11,219
7,557
1,391
PV
10K­
100K
1,614
651
660
11,586
7,352
1,709
PV
100­
1M
2,103
621
985
8,568
4,933
2,073
PV
1M­
10M
2,115
497
1,211
5,661
2,532
2,011
PV
10M­
50M
1,539
283
987
3,624
1,069
1,477
PV
50M­
100M
616
148
462
1,595
431
792
PV
100M­
500M
1,292
150
758
3,421
436
1,008
PV
500M­
1B
333
64
270
1,261
184
421
PV
>
1B
408
52
239
1,589
169
370
Source:
CICIS
Database
1986.

B.
Estimated
Number
of
Reports
in
Future
Reporting
Cycles
Estimates
of
the
number
of
reports
expected
under
the
IUR
amendments
in
future
years
were
generated
based
on
CUS
data
from
the
three
past
reporting
periods
(
i.
e.,
1986,
1990,
and
1994).
There
was
little
variation
in
the
number
of
reports
over
those
three
periods;
EPA
therefore
assumed
that
the
number
of
reports
expected
in
any
given
future
reporting
period
would
remain
constant.
The
average
number
of
reports
from
the
past
three
reporting
periods
is
used
in
this
analysis
to
calculate
the
expected
costs
for
reporting
under
the
proposed
IUR
amendments.
The
assumption
of
consistency
in
the
number
of
reports
may
be
conservative
because,
as
illustrated
in
Table
C­
4,
the
number
of
reports
has
actually
been
on
a
slight
downward
trend.
C­
5
IC
1

(
IC
2/
OC
2)
xOC
1
Table
C­
4.
Number
of
Reports
Submitted
Under
the
Original
IUR
in
1986,
1990,
and
1994
Reporting
Year
Number
of
Reports
1986
26,250
1990
25,535
1994
25,058
Average
25,614
Source:
CUS
Database
1997.

The
CICIS
data
were
used
to
determine
a
ratio
of
the
historical
number
of
organic
chemicals
and
the
number
of
inorganic
chemicals.
This
ratio,
when
applied
to
the
information
available
through
the
CUS
database,
enabled
EPA
to
estimate
the
expected
number
of
inorganic
chemicals
that
would
be
reported
under
the
IUR
amendments.
First,
the
number
of
discrete
inorganic
chemicals
was
estimated
as
if
these
chemicals
had
been
reported
in
1994.
This
was
accomplished
by
multiplying
the
ratio
of
inorganic
to
organic
chemicals
reported
to
the
CICIS
database
in
1986
by
the
total
number
of
chemicals
reported
to
the
CUS
database
in
1994
(
See
Equation
1).
This
estimate
(
i.
e.,
the
number
of
discrete
inorganic
chemicals
in
1994)
was
then
used
to
determine
the
number
of
reports
for
inorganic
chemicals
as
if
they
had
been
reported
in
1994,
based
on
the
ratio
of
inorganic
reports
to
inorganic
chemicals
in
the
1986
CICIS
data
(
See
Equation
2).
The
future
number
of
inorganic
chemical
reports
was
then
estimated
by
multiplying
the
estimate
of
1994
inorganic
chemical
reports
by
the
ratio
of
future
chemical
reports
to
1994
chemical
reports
in
the
CUS
database
(
See
Equation
3).
Based
on
this
methodology,
estimated
numbers
of
discrete
chemicals
and
reports
for
inorganic
chemicals
were
developed,
as
presented
in
Table
C­
5.

Equation
1:
Determination
of
the
Estimated
Number
of
Discrete
Inorganic
Chemicals
as
if
Reported
in
1994
46
Ratios
were
calculated
using
data
for
production
volumes
greater
than
10,000
pounds.

C­
6
RIC
1

(
RIC
2/
IC
2)
xIC
1
RIC
3

RIC
1
x(
FTR)/(
TR)
Equation
2:
Determination
of
the
Estimated
Number
of
Inorganic
Chemical
Reports
as
if
Reported
in
1994
Equation
3:
Determination
of
the
Expected
Number
of
Inorganic
Reports
(
Future)

IC
1
=
Estimated
Number
of
Discrete
Inorganic
Chemicals
as
if
reported
in
1994
IC
2
=
Discrete
Inorganic
Chemicals
reported
to
the
CICIS
database
IC
3
=
Expected
Number
of
Organic
Chemicals
(
Future)
OC
2
=
Discrete
Organic
Chemicals
reported
to
the
CICIS
database
OC
1
=
Total
Number
of
Discrete
Chemicals
reported
to
the
CUS
(
Organic
and
Multiple
CAS
Number
Petroleum
Stream
Chemicals)
RIC
1
=
Estimated
Number
of
Reports
for
Inorganic
Chemicals
as
if
reported
in
1994
RIC
2
=
Reports
for
Inorganic
Chemicals
reported
to
the
CICIS
database
RIC
3
=
Expected
Number
of
Reports
for
Inorganic
Chemicals
(
Future)

Ratios46:
(
IC
2)/(
OC
2)
=
CICIS
Inorganic
Chemicals/
Organic
Chemicals
=
0.144
(
RIC
2)/(
IC
2)
=
CICIS
Inorganic
Reports/
Inorganic
Chemicals
=
4.063
(
FTR)/(
TR)
=
CUS
Future
Total
Reports/
CUS
1994
Total
Reports
=
1.022
C­
7
T

ROC
1

RIC
1

RPS
1
Table
C­
5.
Estimated
Number
of
Chemicals
and
Reports
Expected
for
Inorganic
Chemicalsa
Threshold
(
lbs)
Total
Number
of
Discrete
Chemicals
Reported
to
the
CUS
in
1994
Inorganic
Discrete
Chemicals
(
Estimated
as
if
reported
in
1994)
Inorganic
Reports
(
Estimated
as
if
reported
in
1994)
Estimated
Inorganic
Chemical
Reports
(
Future)

PV>
10K
8,809
1,270
5,160
5,275
PV>
25K
7,518
1,084
4,404
4,502
PV>
100K
5,471
789
3,205
3,276
PV>
500K
3,458
499
2,026
2,071
PV>
1M
2,816
406
1,649
1,686
PV>
10M
1,318
190
772
789
a
Numbers
may
not
calculate
exactly
because
of
rounding.

Source:
CUS
Database
1996,
CUS
Database
1997,
CICIS
Database
1986,
U.
S.
EPA
estimates.

1.
Calculation
of
Total
Expected
Numbers
of
Reports
Under
Proposed
IUR
Amendments
The
proposed
IUR
amendments
would
require
reporting
for
both
organic
and
inorganic
chemicals,
and
would
provide
a
partial
exemption
for
certain
chemicals
(
i.
e.,
multiple
petroleum
stream
chemicals)
from
reporting
requirements.
The
following
equation
was
used
to
calculate
the
total
number
of
reports
expected
under
the
proposed
IUR
amendments
for
all
types
of
subject
chemicals:

Equation
3:
Determination
of
the
Total
Expected
Number
of
Reports
T
=
Total
expected
number
of
reports
ROC
1
=
Reports
for
organic
chemicals
RIC
1
=
Reports
for
inorganic
chemicals
RPS
1
=
Reports
for
petroleum
stream
chemicals
2.
Total
Expected
Numbers
of
Reports
in
the
Future
As
described
above,
the
numbers
of
reports
submitted
under
the
IUR
has
remained
relatively
constant
over
time.
Based
on
this
observation,
it
has
been
assumed
that
future
reporting
will
C­
8
also
remain
constant
(
i.
e.,
the
numbers
of
submissions
expected
in
each
future
reporting
period
will
remain
constant).
Hence,
the
average
of
25,614
reports
is
used
as
the
basis
for
calculating
future
costs.

Table
C­
6
presents
estimates
of
the
number
of
expected
reports
for
each
proposed
reporting
threshold.

In
the
event
that
this
assumption
is
not
completely
accurate,
an
analysis
of
the
effect
of
a
ten
percent
increase
or
decrease
in
the
number
of
expected
submissions
is
presented
in
Tables
C­
7a
and
C­
7b.

Table
C­
6.
Estimated
Numbers
of
Reports
for
the
IUR
Amendments
Threshold
(
lbs)
Organic
Chemical
Reports
Inorganic
Chemical
Reports
Petroleum
Stream
Reports
Total
Reports
Total
Reports
Containing
Processing
and
Use
Info
PV>
10K
19,490
5,275
5,833
30,598
24,765
PV>
25K
16,576
4,502
5,733
26,811
21,078
PV>
100K
12,155
3,276
5,602
21,033
15,431
PV>
500K
8,016
2,071
5,423
15,510
10,087
PV>
1M
6,732
1,686
5,327
13,745
8,418
PV>
10M
3,587
789
4,760
9,136
4,376
Note:
The
numbers
in
this
table
illustrate
the
estimated
number
of
reports
for
various
threshold
levels,
but
do
not
represent
the
number
of
reports
expected
under
the
proposed
option.

Source:
CICIS
Database
1986,
CUS
Database
1996,
CUS
Database
1997,
U.
S.
EPA
estimates.

Table
C­
7a.
Sensitivity
Analysis
Around
the
Estimated
Total
Numbers
of
Reports
Threshold
(
lbs)
Total
Reports
Total
Reports
(+
10%)
Total
Reports
(­
10%)

PV>
10K
30,598
33,657
27,537
PV>
25K
26,811
29,491
24,129
PV>
100K
21,033
23,136
18,930
PV>
500K
15,510
17,061
13,959
PV>
1M
13,745
15,120
12,371
PV>
10M
9,136
10,050
8,222
Source:
CICIS
Database
1986,
CUS
Database
1996,
CUS
Database
1997,
U.
S.
EPA
estimates.
C­
9
Table
C­
7b.
Sensitivity
Analysis
Around
the
Estimated
Numbers
of
Reports
Containing
Processing
and
Use
Information
Threshold
(
lbs)
Total
Reports
Total
Reports
(+
10%)
Total
Reports
(­
10%)

PV>
10K
24,765
27,242
22,289
PV>
25K
21,078
23,186
18,970
PV>
100K
15,431
16,974
13,888
PV>
500K
10,087
11,096
9,078
PV>
1M
8,418
9,260
7,576
PV>
10M
4,376
4,814
3,938
Source:
CICIS
Database
1986,
CUS
Database
1996,
CUS
Database
1997,
U.
S.
EPA
estimates.
47
The
survey
was
conducted
for
EPA
by
ICF
Incorporated,
an
EPA
contractor
supporting
TSCA
initiatives.
This
work
was
performed
under
EPA
Contract
No.
68­
02­
0064.

48
EPA
maintains
the
Chemical
Update
System
(
CUS)
Database
to
track
IUR
information.

D­
1
APPENDIX
D.
INDUSTRY
SURVEY
RESULTS
During
the
spring/
summer
of
1996,
the
Agency
conducted
a
survey
(
under
Office
of
Management
and
Budget
clearance
#
2070­
0034)
to
assess
the
potential
burden
associated
with
reporting
for
the
proposed
Inventory
Update
Rule
(
IUR)
amendments
under
TSCA
§
8.47
The
survey
was
distributed
to
previous
IUR
reporters
selected
from
the
CUS
database.
48
The
survey
was
designed
to
collect
information
regarding
the
amount
of
labor
required
to
complete
each
task
identified
in
the
proposed
IUR
amendments.
Survey
respondents
were
asked
to
estimate
the
burden
associated
with
collecting
various
data
for
each
of
three
labor
categories:
clerical,

technical,
and
managerial.
The
results
of
this
survey
provide
the
basis
for
determining
the
burden
associated
with
the
proposed
IUR
amendments.
All
analysis
presented
in
this
appendix
focuses
on
the
burden
associated
with
completing
the
full
reporting
form.
The
analysis
in
Chapter
III
of
this
report
further
dissagregates
the
data
to
estimate
the
burden
associated
with
reports
covering
only
part
of
the
reporting
form
(
i.
e.,
facility
identification
and
manufacturing
information).
The
remainder
of
this
appendix
presents
an
overview
of
the
results
of
the
survey
and
is
organized
as
follows:


Section
A
provides
an
introduction
including
a
description
of
the
survey,
the
draft
reporting
form,
and
a
discussion
of
the
survey
respondents;


Section
B
presents
a
discussion
of
the
estimates
of
industry
reporting
burden
per
chemical,
including
the
calculation
of
the
mean
total
industry
reporting
burden,
and
the
total
reporting
burden
for
large,
medium,
and
small
companies;
and

Section
C
presents
average
reporting
parameters
for
the
survey
participants,
including
the
number
of
sites
per
company
producing
a
reportable
chemical,
number
of
processing
and
use
sites,
and
the
number
of
end
uses.

A.
Introduction
The
survey
was
administered
to
81
companies
over
a
period
of
four
months,
from
March
through
June
1996.
The
survey
was
sent
to
potential
respondents
along
with
a
copy
of
the
draft
reporting
form
and
instructions.
Potential
respondents
were
informed
that
participation
was
voluntary.
Attachment
49
Appendix
A
contains
a
copy
of
the
revised
draft
reporting
form.

D­
2
1
provides
a
copy
of
the
survey
and
the
introduction
letter
that
were
sent
to
potential
participants,
and
Attachment
2
contains
a
copy
of
the
draft
reporting
form
sent
with
the
survey.
49
Participants
were
asked
to
estimate
the
amount
of
time
that
would
be
required
to
report
distinct
pieces
of
information
about
the
manufacture
and
use
of
TSCA
Inventory
chemicals.

The
following
three
sections
describe
the
industry
burden
survey,
the
draft
reporting
form,
and
the
make­
up
of
the
survey
respondents.

1.
Survey
Description
The
survey
was
developed
based
on
a
draft
reporting
form
incorporating
the
proposed
IUR
amendments
as
well
as
the
original
reporting
requirements.
Generally,
the
survey
was
structured
so
that
each
question
corresponded
to
a
data
element
on
the
reporting
form.
Most
of
the
questions
requested
estimates
of
the
amount
of
time
that
the
reporting
company
would
need
to
compile
specific
information
concerning
a
typical
chemical
produced
at
their
site,
dividing
the
time
among
clerical,

technical,
and
managerial
staff.
Additional
questions
asked
for
information
about
the
number
of
reportable
chemicals
produced
at
a
given
site
and
the
number
of
sites
producing
a
reportable
chemical,

as
well
as
the
number
of
processing
and
use
sites
and
the
number
of
end
uses
of
a
typical
chemical.

These
ancillary
questions
were
designed
to
develop
a
better
understanding
of
the
reporting
parameters
and
to
assist
in
properly
interpreting
the
results
of
the
reporting
burden
questions.

In
addition
to
providing
answers
for
each
survey
question,
participants
were
encouraged
to
provide
comments
regarding
the
survey,
the
reporting
form,
and
the
processes
that
would
be
used
by
the
company
to
complete
the
reporting
form.
These
comments
were
considered
by
the
Agency
during
the
development
of
the
proposed
IUR
amendments
and
in
redesigning
the
reporting
form.

2.
Draft
Reporting
Form
Description
The
survey
was
developed
from
a
preliminary
version
of
the
revised
Form
U
(
i.
e.,
the
IUR
amendments
reporting
form)
covering
both
the
original
IUR
reporting
requirements
and
the
proposed
changes
associated
with
the
IUR
amendments.
The
draft
reporting
form
used
in
this
survey
is
different
from
the
form
included
with
the
proposal;
however,
the
data
elements
are
similar.
The
draft
form
used
in
the
survey
was
divided
into
five
parts,
as
follows:
D­
3
Part
1.
Facility
Identification
Information
Part
2.
Chemical
Specific
Information
Part
3.
Information
on
Chemical
Processing
­
Incorporative
Activities
Part
4.
Information
on
Chemical
Use
­
Non­
Incorporative
Activities
Part
5.
Known
Commercial
and
Consumer
End
Uses
of
Chemical
Generally,
the
information
included
in
Parts
1
and
2
of
the
reporting
form
corresponds
to
the
information
collected
under
the
original
IUR,
supported
by
the
addition
of
three
data
elements
regarding
company
information,
plant
site
identification,
and
manufacturing
information.
Parts
3
through
5
of
the
proposed
reporting
form
include
the
chemical
use
and
exposure
information
that
constitutes
the
majority
of
new
requirements
under
the
proposed
IUR
amendments.

The
original
IUR
requires
that
certain
basic
production
and
manufacturer
identification
information
be
provided.
The
specific
data
required
are
as
follows:


Certification
including
a
signature,
date,
and
name
and
title
of
the
representative
responsible
for
the
accuracy
of
the
information
provided;


Company
Information
including
technical
contact
name,
company
name,
company
street
address,
and
telephone
number;


Plant
Site
Identification
including
plant
site
name,
Dun
&
Bradstreet
Number,
and
plant
site
street
address;


Chemical
Specific
Information
including
chemical
identity
CBI
substantiation,
CAS
Number
or
other
identifying
number,
ID
code,
chemical
name,
site­
limited
status,
activity
(
manufacturing
or
import),
and
production
volume;
and

Confidential
Business
Information
including
up­
front
substantiation
of
CBI
claims
for
chemical
identity
information
and
substantiation
of
CBI
claims
in
the
event
of
a
Freedom
of
Information
Act
(
FOIA)
request.

In
addition
to
the
information
required
for
the
original
IUR,
the
proposed
IUR
amendments
require
information
on
worker
exposure
and
use,
as
well
as
limited
new
information
relating
to
plant
site
identification.
The
information
proposed
to
be
collected
under
the
IUR
amendments
is
as
follows:


Company
Information
adding
the
company
Dun
&
Bradstreet
Number
and
mailing
address;


Plant
Site
Identification
adding
the
county
location
of
the
plant
site
and
the
plant
site
mailing
address,
EPA
Identification
Number,
and
provision
of
CBI
substantiation;


Manufacturing
Information
adding
the
confidentiality
status
of
the
production
volume
range,
number
of
workers
potentially
exposed
during
manufacturing,
the
physical
state
of
the
chemical,
and
the
maximum
concentration
of
the
chemical
when
manufactured;


Industrial
Processing
and
Use
Exposure
Related
Information
adding
information
regarding
processing
and
use
of
the
chemical,
including
process
or
use
codes,
5­
digit
50
Small
companies
were
identified
as
having
annual
sales
less
than
or
equal
to
$
40
million,
medium­
sized
companies
have
annual
sales
greater
than
$
40
million
and
less
than
or
equal
to
$
200
million,
and
large
companies
have
annual
sales
greater
than
$
200
million.

D­
4
NAICS
codes,
industrial
function
categories,
percent
production
volume,
site­
limited
status,
number
of
sites
(
in
ranges),
and
number
of
potentially
exposed
workers
(
in
ranges);


Consumer
and
Commercial
End
Use
Exposure
Related
Information
adding
commercial/
consumer
end
use
categories,
percent
production
volume,
and
maximum
concentration
(
in
ranges)
of
the
chemical
in
the
commercial/
consumer
end
use;
and

Confidential
Business
Information
adding
up­
front
substantiation
of
CBI
plant
site
identification
claims
and
reassertion
of
CBI
claims
made
in
the
previous
reporting
period,
which
includes
completion
of
the
check
boxes
in
Section
IV
of
the
Form
U
and
may
also
include
additional
paperwork
to
explain
the
reassertion.

3.
Discussion
of
Survey
Respondents
Potential
participants
in
the
survey
were
identified
through
the
EPA's
Chemical
Update
System
(
CUS)
Database,
which
contains
data
collected
under
the
original
IUR.
Companies
were
then
grouped
by
size
using
information
from
Dun
&
Bradstreet's
Duns
Market
Identifiers
online
service.
A
stratified
random
sampling
method
was
employed
to
ensure
that
a
representative
cross
section
of
the
chemical
manufacturing
industry
was
surveyed.
The
stratification
of
the
chemical
manufacturing
industry
into
small,
medium,
and
large
manufacturers
was
based
on
the
annual
sales
of
the
parent
company.
50
A
total
of
207
companies
were
sent
a
copy
of
the
survey
with
a
cover
letter
requesting
that
they
participate
in
the
survey.
An
attempt
was
made
to
contact
each
company
by
telephone
to
confirm
the
contact
information
and
coordinate
a
telephone
appointment
to
administer
the
survey
instrument.

Of
the
companies
contacted,
81
chose
to
participate
in
the
survey.
Three
of
these
companies'

responses
are
not
included
in
the
burden
estimates
because
their
results
indicated
a
burden
more
than
19
times
greater
than
the
average
burden
estimated
by
all
other
survey
respondents
(
See
Section
B.
2
of
this
appendix
for
further
discussion).
The
78
remaining
survey
respondents
included
20
small,
17
medium,
and
41
large
companies,
25.6
percent,
21.8
percent,
and
52.6
percent,
respectively.
The
distribution
of
small,
medium,
and
large
companies
that
report
to
the
IUR,
based
on
the
CUS
94
Database,
compares
favorably
to
the
distribution
of
companies
that
participated
in
the
survey.
Based
on
the
CUS
94
database,
the
distribution
of
companies
reporting
to
the
IUR
in
1994
was
approximately
21
51
Surveys
sent
to
the
Agency
were
identified
as
such
and
transferred
directly
to
ICF.

D­
5
percent
small
companies,
21
percent
medium
companies,
and
58
percent
large
companies
(
see
Table
VII­
1
in
the
main
body
of
this
report
for
more
information).
Table
D­
1
presents
a
comparison
of
these
results.

Table
D­
1.
Distribution
of
Survey
Participants
and
IUR
Reporters
By
Company
Size
Company
Size
(
Percent)

Small
Medium
Large
Total
Survey
Participants
25.6
21.8
52.6
100
IUR
Reporters
21.1
21.2
57.7
100
Of
the
remaining
126
companies
that
were
sent
the
survey,
but
did
not
participate,
20
declined
to
participate,
5
determined
that
the
survey
was
not
applicable
to
their
business,
and
32
could
not
be
contacted
because
of
incomplete
or
out­
of­
date
contact
information.
The
remaining
69
companies
either
did
not
acknowledge
phone
calls
or
did
not
find
a
convenient
appointment
time
to
complete
the
survey.

For
the
most
part,
individual
survey
results
were
compiled
over
the
telephone
so
that
definitions
could
be
explained
in
a
consistent
manner
to
all
participants
and
unique
interpretations
of
the
survey
questions
could
be
avoided.
Several
survey
participants
chose
not
to
review
the
survey
over
the
telephone
and
mailed
a
completed
survey
to
either
the
Agency51
or
to
ICF
Incorporated
(
the
Agency's
contractor
for
this
work).
Responses
from
these
companies
were
included
in
the
data
set.

Following
completion
of
the
interview
process,
the
survey
responses
were
entered
into
a
Paradox
©
database
maintained
by
ICF
Incorporated.
Queries
of
the
data
were
prepared
and
executed
to
determine
average
reporting
burden
estimates
and
average
reporting
parameters
for
the
survey
participants.

B.
Reporting
Burden
Survey
Results
This
section
presents
the
reporting
burden
results
of
the
survey.
Reporting
burden
results
are
the
answers
to
those
questions
directly
relating
to
the
amount
of
effort
required
to
complete
Form
U
for
a
D­
6
typical
chemical.
Results
are
presented
in
four
ways
­
for
all
reporters,
for
small
company
reporters,
for
medium
company
reporters,
and
for
large
company
reporters.

In
general,
the
breakdown
of
small,
medium,
and
large
companies
in
the
set
of
survey
participants
accurately
reflects
the
actual
breakdown
of
reporters
under
the
original
IUR
in
the
chemical
manufacturing
industry
as
a
whole.
The
following
sections
discuss
the
methodology
for
estimating
the
average
industry
burden
associated
with
the
proposed
IUR
amendments,
the
distribution
of
small,

medium,
and
large
companies
within
the
set
of
survey
participants
and
within
the
set
of
reporters
under
the
original
IUR,
and
a
comparison
of
the
average
estimated
reporting
burdens
for
small,
medium
and
large
companies.

1.
Methodology
for
Calculation
of
the
Reporting
Burdens
The
survey
results
were
compiled
and
reporting
burdens
calculated
separately
for
small,

medium,
and
large
firms
to
determine
the
effect
that
company
size
may
have
on
(
1)
the
level
of
effort
required
to
develop
IUR
amendment
data
and
(
2)
the
average
numbers
of
sites,
chemicals,
and
reports
per
company.

High
and
low
burden
estimates
for
each
survey
data
element
were
provided
by
respondents.

The
high
estimates
were
used
to
develop
an
average
high
estimate
for
each
data
element.
The
same
methodology
was
used
to
develop
an
average
low
estimate
for
each
data
element.
Each
average
high
estimate
was
then
weighted
to
reflect
the
correct
distribution
of
small,
medium,
and
large
companies
(
according
to
the
CUS
database).
The
same
was
done
for
each
average
low
estimates.
Weighted
average
high
burden
estimates
for
each
data
element
were
then
added
together
to
yield
a
high
total
burden
estimate
for
completing
the
entire
form.
Similarly,
weighted
average
low
burden
estimates
were
then
added
together
to
yield
a
low
total
burden
estimate.

2.
Overall
Burden
Results
This
section
summarizes
the
overall
burden
results,
as
developed
from
survey
responses.
Survey
results
indicate
that
70
percent
of
the
companies
reported
a
total
per
chemical
reporting
burden
of
between
0
and
50
hours.
Of
the
remaining
30
percent
of
companies,
46
percent
reported
an
average
per
chemical
reporting
burden
of
between
50
and
100
hours,
29
percent
reported
an
average
burden
of
between
100
to
200
hours,
and
13
percent
reported
an
average
burden
of
between
D­
7
200
and
300
hours.
As
mentioned
above,
burden
estimates
provided
by
three
survey
respondents
were
not
included
in
the
calculation
of
reporting
burden
estimates
because
their
responses
deviated
statistically
from
the
mean.
As
shown
in
Exhibit
D­
1,
these
3
companies
reported
average
per
chemical
burdens
of
over
1,000
hours,

more
than
19
times
greater
than
the
average
burden
for
the
other
81
responses.
The
following
three
sections
describe
the
burden
results
for
small,
medium,
and
large
companies.
Section
6
presents
a
comparison
of
burden
results
based
on
company
size.

Exhibit
D­
1.
Distribution
of
Companies
Based
on
Total
Estimated
Reporting
Burden
Hours
D­
8
3.
Small
Company
Burden
Results
The
average
reporting
burden
for
small
companies
under
the
proposed
amendments
was
22.8
to
27.0
hours
per
report.
On
average,
small
companies
estimated
1.9
to
2.4
hours
of
clerical
time,
15.6
to
17.3
hours
of
technical
time,
and
5.3
to
7.3
hours
of
managerial
time
for
each
report.

Burden
results
for
individual
data
elements,
as
estimated
by
small
companies,
are
shown
in
Table
D­
2.

4.
Medium
Company
Burden
Results
The
average
reporting
burden
for
medium
companies
under
the
proposed
amendments
was
53.0
to
58.4
hours
per
report.
On
average,
medium
companies
estimated
7.9
to
8.8
hours
of
clerical
time,
32.2
to
34.2
hours
of
technical
time,
and
12.8
to
15.4
hours
of
managerial
time
for
each
report.

Burden
results
for
individual
data
elements,
as
estimated
by
medium
companies,
are
shown
in
Table
D­

3.

5.
Large
Company
Burden
Results
The
average
reporting
burden
for
large
companies
under
the
proposed
amendments
was
51.3
to
70.6
hours
per
report.
On
average,
large
companies
estimated
6.3
to
7.8
hours
of
clerical
time,

32.8
to
43.1
hours
of
technical
time,
and
12.2
to
19.8
hours
of
managerial
time
for
each
report.
Burden
results
for
individual
data
elements,
as
estimated
by
large
companies,
are
shown
in
Table
D­
4.
D­
9
Table
D­
2.
Small
Company
Reporting
Burden
for
Sections
of
Form
U
Task
Clerical
Hours
Technical
Hours
Managerial
Hours
I.
Facility
Identification
Information
0.04
­
0.04
0.79
­
0.79
1.25
­
1.25
1.
Certification
0.02
­
0.02
0.72
­
0.72
1.22
­
1.22
2.
Company
Information
0.01
­
0.01
0.04
­
0.04
0.01
­
0.01
Company
Name,
Contact,
Address
D
&
B
Number,
Mailing
Address
3.
Plant
Site
Identification
0.01
­
0.01
0.03
­
0.03
0.01
­
0.01
Plant
Name,
D
&
B
Number,
Address
EPA
ID
Number,
Mailing
Address
II.
Manufacturing
Information
0.52
­
0.52
3.79
­
3.95
0.63
­
0.66
1.
Chemical
Identification
2.
Site
Limited
3.
Activity
4.
Production
Volume
(
lbs)

0.30
­
0.30
1.83
­
1.86
0.16
­
0.16
5.
Chemical
Identification
Up­
front
CBI
Substantiation
0.05
­
0.05
0.53
­
0.58
0.18
­
0.18
6.
Plant
Site
Up­
front
CBI
Substantiation
0.05
­
0.05
0.36
­
0.41
0.07
­
0.07
7.
Production
Volume
Range
CBI
0.06
­
0.06
0.32
­
0.32
0.11
­
0.14
8.
Total
Number
of
Workers
0.06
­
0.06
0.40
­
0.40
0.07
­
0.07
9.
Physical
State
0.00­
0.00
0.00
­
0.00
0.00
­
0.00
10.
Maximum
Concentration
0.00­
0.00
0.35
­
0.38
0.04
­
0.04
III.
Processing
and
Use
Information
0.87
­
0.87
10.06
­
10.52
1.40
­
1.40
A.
Industrial
Processing
and
Use
Exposure
Related
Data
0.66
­
0.66
7.23
­
7.63
0.73
­
0.73
1.
Determination
of
Applicability
0.11
­
0.11
0.80
­
0.81
0.14
­
0.14
2.
Process
and
Use
Code
0.00
­
0.00
0.00
­
0.00
0.00
­
0.00
3.
5­
Digit
NAICS
Code
0.06
­
0.06
0.46
­
0.47
0.03
­
0.03
4.
Function
Code
0.16
­
0.16
0.80
­
0.85
0.13
­
0.13
5.
Percent
Production
Volume
0.26
­
0.26
1.64
­
1.75
0.15
­
0.15
6.
Total
Number
of
Processing
and
Use
Sites
0.06
­
0.06
0.95
­
1.01
0.07
­
0.07
7.
Total
Number
of
Potentially
Exposed
Workers
0.01
­
0.01
2.59
­
2.75
0.21
­
0.21
B.
Commercial
and
Consumer
End
Use
Exposure
Related
Data
0.21
­
0.21
2.82
­
2.89
0.67
­
0.67
1.
Determination
of
Applicability
0.00
­
0.00
0.44
­
0.44
0.06
­
0.06
2.
Identification
of
End
Use
0.10
­
0.10
0.66
­
0.66
0.22
­
0.22
3.
Percent
Production
Volume
0.05
­
0.05
0.63
­
0.65
0.13
­
0.13
4.
Estimated
Weight
Percent
in
Consumer
Product
0.06
­
0.06
1.09
­
1.14
0.26
­
0.26
IV.
Reassertion
of
Past
CBI
Claims
0.50
­
1.00
1.00
­
2.00
2.00
­
4.00
D­
10
Table
D­
3.
Medium
Company
Reporting
Burden
for
Sections
of
Form
U
Task
Clerical
Hours
Technical
Hours
Managerial
Hours
I.
Facility
Identification
Information
0.97
­
0.97
1.08
­
1.08
1.14
­
1.14
1.
Certification
0.90
­
0.90
1.02
­
1.02
1.12
­
1.12
2.
Company
Information
0.04
­
0.04
0.04
­
0.04
0.01
­
0.01
Company
Name,
Contact,
Address
D
&
B
Number,
Mailing
Address
3.
Plant
Site
Identification
0.03
­
0.03
0.02
­
0.02
0.01
­
0.01
Plant
Name,
D
&
B
Number,
Address
EPA
ID
Number,
Mailing
Address
II.
Manufacturing
Information
0.83
­
0.83
5.19
­
5.83
1.31
­
1.34
1.
Chemical
Identification
2.
Site
Limited
3.
Activity
4.
Production
Volume
(
lbs)

0.30
­
0.30
1.31
­
1.37
0.23
­
0.23
5.
Chemical
Identification
Up­
front
CBI
Substantiation
0.12
­
0.12
1.41
­
1.94
0.38
­
0.38
6.
Plant
Site
Up­
front
CBI
Substantiation
0.09
­
0.09
0.29
­
0.32
0.06
­
0.06
7.
Production
Volume
Range
CBI
0.15
­
0.15
0.55
­
0.55
0.18
­
0.18
8.
Total
Number
of
Workers
0.08
­
0.08
0.94
­
0.94
0.28
­
0.28
9.
Physical
State
0.00
­
0.00
0.00
­
0.00
0.00
­
0.00
10.
Maximum
Concentration
0.09
­
0.09
0.69
­
0.71
0.18
­
0.21
III.
Processing
and
Use
Information
5.64
­
6.05
24.97
­
25.33
8.40
­
8.87
A.
Industrial
Processing
and
Use
Exposure
Related
Data
4.19
­
4.60
18.71
­
18.95
6.07
­
6.48
1.
Determination
of
Applicability
0.41
­
0.41
3.09
­
3.09
0.80
­
0.80
2.
Process
and
Use
Code
0.00
­
0.00
0.00
­
0.00
0.00
­
0.00
3.
5­
Digit
NAICS
Code
1.06
­
1.36
1.36
­
1.41
0.90
­
0.90
4.
Function
Code
0.16
­
0.16
0.90
­
0.95
0.33
­
0.33
5.
Percent
Production
Volume
0.41
­
0.41
3.02
­
3.08
0.89
­
0.95
6.
Total
Number
of
Processing
and
Use
Sites
0.90
­
0.90
4.64
­
4.70
1.57
­
1.68
7.
Total
Number
of
Potentially
Exposed
Workers
1.25
­
1.37
5.71
­
5.71
1.59
­
1.82
B.
Commercial
and
Consumer
End
Use
Exposure
Related
Data
1.45
­
1.45
6.26
­
6.38
2.33
­
2.39
1.
Determination
of
Applicability
0.29
­
0.29
1.41
­
1.41
0.32
­
0.32
2.
Identification
of
End
Use
0.37
­
0.37
0.97
­
0.97
0.39
­
0.39
3.
Percent
production
Volume
0.56
­
0.56
1.62
­
1.68
0.62
­
0.68
4.
Estimated
Weight
Percent
in
Consumer
Product
0.23
­
0.23
2.25
­
2.31
1.00
­
1.00
IV.
Resassertion
of
Past
CBI
Claims
0.50
­
1.00
1.00
­
2.00
2.00
­
4.00
D­
11
Table
D­
4.
Large
Company
Reporting
Burden
for
Sections
of
Form
U
Task
Clerical
Hours
Technical
Hours
Managerial
Hours
I.
Facility
Identification
Information
0.62
­
1.41
0.96
­
1.10
0.91
­
1.04
1.
Certification
0.46
­
1.20
0.77
­
0.90
0.83
­
0.96
2.
Company
Information
0.09
­
0.12
0.11
­
0.12
0.04
­
0.04
Company
Name,
Contact,
Address
D
&
B
Number,
Mailing
Address
3.
Plant
Site
Identification
0.06
­
0.08
0.08
­
0.08
0.03
­
0.03
Plant
Name,
D
&
B
Number,
Address
EPA
ID
Number,
Mailing
Address
II.
Manufacturing
Information
1.84
­
1.93
7.15
­
13.07
2.38
­
7.33
1.
Chemical
Identification
2.
Site
Limited
3.
Activity
4.
Production
Volume
(
lbs)

0.63
­
0.72
2.26
­
3.30
0.35
­
1.31
5.
Chemical
Identification
Up­
front
CBI
Substantiation
0.38
­
0.38
1.17
­
2.22
0.63
­
1.61
6.
Plant
Site
Up­
front
CBI
Substantiation
0.15
­
0.15
0.69
­
1.67
0.34
­
1.32
7.
Production
Volume
Range
CBI
0.16
­
0.16
0.52
­
1.57
0.31
­
1.34
8.
Total
Number
of
Workers
0.31
­
0.31
1.47
­
2.49
0.37
­
1.37
9.
Physical
State
0.00
­
0.00
0.00
­
0.00
0.00
­
0.00
10.
Maximum
Concentration
0.21
­
0.21
1.04
­
1.82
0.38
­
0.38
III.
Processing
and
Use
Information
3.32
­
3.42
23.72
­
26.89
6.92
­
7.46
A.
Industrial
Processing
and
Use
Exposure
Related
Data
2.69
­
2.79
18.57
­
20.88
5.48
­
5.82
1.
Determination
of
Applicability
0.17
­
0.17
1.53
­
1.74
0.43
­
0.44
2.
Process
and
Use
Code
0.00
­
0.00
0.00
­
0.00
0.00
­
0.00
3.
5­
Digit
NAICS
Code
0.16
­
0.16
3.08
­
3.32
0.72
­
0.72
4.
Function
Code
0.49
­
0.49
2.02
­
2.31
1.16
­
1.20
5.
Percent
Production
Volume
0.53
­
0.53
4.06
­
4.51
1.03
­
1.25
6.
Total
Number
of
Processing
and
Use
Sites
0.58
­
0.68
2.89
­
3.48
0.92
­
0.94
7.
Total
Number
of
Potentially
Exposed
Workers
0.76
­
0.76
4.99
­
5.52
1.22
­
1.27
B.
Commercial
and
Consumer
End
Use
Exposure
Related
Data
0.63
­
0.63
5.15
­
6.01
1.44
­
1.64
1.
Determination
of
Applicability
0.19
­
0.19
1.18
­
1.27
0.34
­
0.39
2.
Identification
of
End
Use
0.13
­
0.13
0.99
­
1.23
0.26
­
0.31
3.
Percent
production
Volume
0.18
­
0.18
1.59
­
1.84
0.61
­
0.66
4.
Estimated
Weight
Percent
in
Consumer
Product
0.13
­
0.13
1.38
­
1.66
0.22
­
0.28
IV.
Reassertion
of
Past
CBI
Claims
0.50
­
1.00
1.00
­
2.00
2.00
­
4.00
52
The
weighted
burden
is
calculated
as
the
sum
of
the
products
of
the
average
burden
for
small,
medium,
and
large
companies
multiplied
by
the
proportion
of
all
IUR
reporters
as
determined
from
the
1994
CUS
Database
(
see
Table
D­
1).

D­
12
6.
Burden
Comparison
Based
on
Company
Size
This
section
presents
an
analysis
of
the
average
total
reporting
burden
for
small,

medium,
and
large
companies
to
determine
if
company
size
plays
any
clear
role
in
the
per
chemical
reporting
burden.
The
average
unweighted
reporting
burden
based
on
actual
survey
responses
is
between
45.1
and
58.5
hours
per
report
for
the
proposed
IUR
amendment
requirements
as
presented
in
Table
D­
5.
Taking
into
account
the
historical
proportion
of
small,
medium,
and
large
companies,
as
reported
in
the
1994
CUS
Database,
the
weighted
average
reporting
burden52
was
reported
as
being
between
46.6
and
61.0
hours
per
report.

Table
D­
5.
Per
Chemical
Reporting
Burden
Results
for
Small,
Medium,
and
Large
Company
Sites
Average
Total
Reporting
Burden
(
Hours)

Clerical
Technical
Managerial
Total
Median
Range
Low
High
Low
High
Low
High
Low
High
Low
High
Low
High
Small
2.0
2.5
15.
9
17.
6
5.3
7.4
23.
2
27.
4
12.
8
17.
8
5.8
88.8
Medium
8.0
8.9
32.
2
34.
3
12.8
15.
4
53.
1
58.
5
35.
8
39.
3
5.6
163.
4
Large
6.3
7.7
32.
4
43.
4
12.2
20.
7
50.
4
71.
9
31.
0
35.
7
8.4
513.
8
All
Companies
(
unweighted)
5.6
6.7
28.
7
35.
4
10.8
16.
3
45.
1
58.
5
27.
9
32.
4
5.6
513.
8
All
Companies
(
weighted)
a
5.8
7.0
29.

6
36.

9
11.1
17.

1
46.

6
61.

0
­­­­
­­­­
­­­­
­­­­

a
Weighting
refers
to
the
distribution
of
average
reporting
burden
by
company
size
based
on
the
proportion
of
companies
within
each
size
class
for
the
set
of
1994
IUR
reporting
companies.

Sources:
CUS
Database
1996,
ICF
1996.

Table
D­
5
also
presents
various
statistics
related
to
the
median
values
and
ranges
of
estimates
as
determined
from
the
survey.
Based
on
the
estimated
number
of
reports
per
site
(
8.4
reports
per
site
53
According
to
the
survey
results,
participants
estimated
an
average
of
24
to
33
chemicals
that
are
reported
per
site
(
see
Section
3.
b.
of
this
appendix).
These
estimates
have
not
been
used
in
the
burden
analysis
because
actual
data
for
the
entire
data
set
of
IUR
reports
from
the
last
reporting
period
is
available
from
the
1994
CUS
Database.

54
These
results
are
for
the
complete
Form
U,
based
upon
the
draft
version
under
consideration
at
the
time
of
the
survey.
These
results
were
adjusted
to
reflect
the
requirements
contained
in
the
amendments
at
the
time
of
the
proposal,
which
were
somewhat
different
from
the
requirements
at
the
time
of
the
survey.

D­
13
from
the
1994
CUS
Database),
53
and
the
weighted
reporting
burdens
presented
in
Table
D­
5,
the
average
weighted
reporting
burden
per
site
is
39.2
to
45.1
hours
of
clerical
time,
219.3
to
269.7
hours
of
technical
time,
and
80.1
to
121.2
hours
of
managerial
time,
or
a
total
of
between
338.6
hours
and
436.0
hours
per
site
for
all
reportable
IUR
chemicals.
54
C.
Reporting
Parameters
Results
and
Discussion
This
section
presents
the
reporting
parameters
used
as
a
means
of
providing
a
better
understanding
of
the
relationship
between
sites
and
chemicals
being
reported.
Two
questions
on
the
survey
requested
information
aimed
at
better
characterizing
the
reporting
burden
for
an
average
company
and
an
average
site.
The
first
of
these
questions
asked
for
the
number
of
sites
that
manufacture
the
same
chemical
subject
to
IUR
reporting.
The
second
question
asks
for
the
number
of
IUR
chemicals
that
are
manufactured
at
a
typical
site.
Averaged
values
for
responses
to
these
survey
questions
have
been
developed
by
weighting
according
to
the
stratification
of
the
reporters
under
the
1994
IUR
reporting
period.
The
results
are
discussed
in
Sections
1
and
2
below.

In
addition
to
the
questions
mentioned
above,
Sections
3
through
5
of
the
survey
asked
participants
to
estimate
the
number
of
incorporative
use
sites,
non­
incorporative
use
sites,
and
end
uses
for
a
typical
chemical
that
would
be
reported
under
the
IUR.
These
sections
include
Chemical
Processing,
Chemical
Use,
and
Known
Commercial
and
Consumer
End
Uses
of
the
Chemical,

respectively,
and
can
be
further
interpreted
based
on
the
results
of
the
average
reporting
parameters
developed
in
the
survey.
The
total
burden
estimates
for
Section
3
of
the
draft
reporting
form,
covering
information
on
incorporative
uses
of
the
chemical,
can
be
divided
by
the
number
of
incorporative
use
sites
to
determine
the
relationship
between
total
burden
and
number
of
sites.
The
same
approach
can
D­
14
be
followed
to
create
parallel
estimates
for
the
chemical
use
and
known
commercial
and
consumer
end
use
categories.
The
results
of
these
calculations
are
presented
in
Sections
3,
4,
and
5
below.

1.
Number
of
Sites
per
Company
Producing
a
Particular
Chemical
For
a
single
chemical
subject
to
IUR
reporting,
the
weighted
average
number
of
sites
per
company
was
estimated
to
be
between
2.9
and
3.1
sites.
Survey
results
illustrate
that
these
averages
vary
based
on
the
size
of
the
company.
For
example,
small
companies
reported
that
an
average
of
1.2
sites
manufacture
a
single
IUR­
reportable
chemical.
For
medium­
sized
companies,
a
single
IURreportable
chemical
is
manufactured
at
approximately
1.6
sites,
while
for
large
companies,
a
single
IURreportable
chemical
is
manufactured
at
between
3.9
and
4.2
sites.
The
mean,
median,
and
range
for
the
survey
results
are
presented
in
Table
D­
6.
Nearly
52
percent
of
the
companies
surveyed
reported
that
one
site
produces
a
single
reportable
chemical,
while
39
companies
(
48
percent)
estimated
greater
than
one
site
per
reportable
chemical.

Table
D­
6.
Mean,
Median,
and
Range
of
Sites
per
Chemical
for
Small,
Medium,
and
Large
Companies
Sites
per
Chemical
Mean
Median
Range
Low
High
Low
High
Low
High
Small
1.2
1.2
1
1
1
4
Medium
1.6
1.6
1
1
1
3
Large
3.9
4.2
2
2
1
30
All
Companies
(
unweighted)
2.7
2.8
1
1
1
30
All
Companies
(
weighted)
a
2.8
3.0
­­­­
­­­­
­­­­
­­­­

a
Weighting
refers
to
the
distribution
of
average
reporting
burden
by
company
size
based
on
the
proportion
of
companies
within
each
size
class
for
the
set
of
1994
IUR
reporting
companies.

Sources:
CUS
Database
1996,
ICF
1996.

2.
Number
of
IUR
Reportable
Chemicals
per
Site
The
weighted
average
estimate
of
the
number
of
IUR
chemicals
manufactured
at
an
annual
production
volume
greater
than
10,000
pounds
at
a
typical
site
was
reported
to
be
between
24.8
and
34.3
chemicals
per
site
for
all
survey
participants.
Small
companies
averaged
13.0
to
15.0
IUR
D­
15
chemicals
manufactured
at
a
typical
site,
while
medium­
sized
companies
averaged
between
27.2
and
46.5
chemicals
and
large
companies
averaged
between
27.6
and
36.0
chemicals
per
site.
Table
D­
7
presents
the
mean,
median,
and
range
for
these
parameters
for
all
survey
participants
by
size
class.

For
purposes
of
comparison,
it
is
important
to
note
that
the
number
of
chemicals
per
site,
as
reported
by
survey
respondents,
corresponds
to
the
number
of
reports
per
site
derived
from
the
1994
CUS
Database.
This
is
because
survey
respondents
estimated
the
number
of
chemicals
per
site
is
a
number
consistent
with
the
number
of
reports
per
site,
as
reported
in
the
CUS
Database.
However,
it
is
worth
noting
that
the
average
values
developed
from
the
survey
do
not
correlate
well
with
the
historical
information
from
the
1994
CUS
Database
(
8.4
reports
per
site).
Because
the
historical
data
provide
an
extremely
reliable
value
for
this
data
point,
the
survey
data
are
not
used
for
determining
the
number
of
chemicals
per
site.
Reviewing
the
median
survey
data,
however,
shows
a
better
comparison
with
the
1994
CUS
number.
The
median
value
of
the
survey
is
between
8.0
and
10.0
chemicals
per
site,
which
is
in
line
with
the
value
of
8.4
reports
per
site
derived
from
the
1994
CUS
data
set.
The
median
value
indicates
that
at
least
one
half
of
the
respondents
reported
numbers
of
chemicals
per
site
that
were
equal
to
or
less
than
the
averages
developed
from
the
CUS
data.
The
extremely
high
values
provided
by
a
few
companies
in
the
survey
have
skewed
the
average
significantly
and
suggest
that
the
mean
may
not
be
representative.
Table
D­
7.
Mean,
Median,
and
Range
of
Chemicals
per
Site
for
Small,
Medium,
and
Large
Company
Sites
Chemicals
per
Site
Mean
Median
Range
Low
High
Low
High
Low
High
Small
13.0
15.0
5.0
5.0
1.0
100.0
Medium
27.2
46.5
7.0
9.0
1.0
500.0
Large
27.6
36.0
10.0
12.5
1.0
300.0
All
Companies
(
unweighted)
23.7
32.9
8.0
10.0
1.0
500.0
All
Companies
(
weighted)
a
24.4
33.8
­­­­
­­­­
­­­­
­­­­

a
Weighting
refers
to
the
distribution
of
average
reporting
burden
by
company
size
based
on
the
proportion
of
companies
within
each
size
class
for
the
set
of
1994
IUR
reporting
companies.
Sources:
CUS
Database
1996,
ICF
1996.
D­
16
Ave
ra
ge
Reporting
Burden
vs.
Ave
rage
Numbe
r
of
P
roce
ssing
S
i
te
s
for
Al
l
Com
pa
nie
s
S
urve
ye
d
0.0
10.0
20.0
30.0
40.0
50.0
60.0
70.0
80.0
90.0
1­
5
6­
20
21­
50
>
50
Ave
rage
Num
be
r
of
Proce
s
s
ing
Site
s
Average
Reporting
Burden
(
hours)
3.
Number
of
Processing
Sites
The
number
of
processing
sites
per
chemical
affects
the
burden
for
developing
processing
information
for
reportable
chemicals.
If
there
are
a
large
number
of
processing
sites
per
chemical,
the
burden
will
be
higher
than
if
there
are
comparatively
fewer
sites.
This
relationship
is
strongly
supported
by
the
survey
responses
and
is
presented
in
Exhibit
D­
2.
Table
D­
8
presents
the
mean,
median,
and
range
estimates
developed
from
the
survey
responses
for
this
data.
As
the
table
indicates,
the
weighted
average
number
of
processing
sites
per
chemical
is
between
27.6
and
53.3
sites.

These
average
values
may
be
somewhat
misleading
because
of
the
extremely
wide
range
of
reported
values
and
as
such,
the
median
(
2.5
to
6.0
sites
per
chemical)
values
may
be
a
more
accurate
representation
of
the
typical
number
of
processing
sites
per
chemical.

Exhibit
D­
2.
Relationship
Between
Average
Reporting
Burden
and
Average
Number
of
Processing
Sites
for
all
Companies
Surveyed
D­
17
Table
D­
8.
Mean,
Median,
and
Range
of
Processing
Sites
per
Chemical
for
Small,
Medium,
and
Large
Company
Sites
Processing
Sites
per
Chemical
Mean
Median
Range
Low
High
Low
High
Low
High
Small
31.0
57.3
1.5
2.0
0.0
1,000.0
Medium
11.3
19.7
2.0
5.0
0.0
150.0
Large
32.3
64.0
8.0
12.5
0.0
1,000.0
All
Companies
(
unweighted)
27.4
53.0
2.5
6.0
0.0
1,000.0
All
Companies
(
weighted)
a
27.6
53.3
­­­­
­­­­
­­­­
­­­

a
Weighting
refers
to
the
distribution
of
average
reporting
burden
by
company
size
based
on
the
proportion
of
companies
within
each
size
class
for
the
set
of
1994
IUR
reporting
companies.

Sources:
CUS
Database
1996,
ICF
1996.

4.
Number
of
Use
Sites
Information
on
the
number
of
use
sites
per
chemical
can
be
examined
in
the
same
manner
as
the
information
on
processing
sites
presented
in
the
previous
section.
However,
according
to
the
survey
data,
the
relationship
between
number
of
use
sites
and
reporting
burden
is
not
as
clear
as
the
relationship
established
between
number
of
processing
sites
and
reporting
burden.
As
is
shown
in
Exhibit
D­
3,
there
is
an
increase
in
burden
for
companies
reporting
on
6
or
more
use
sites
per
chemical
compared
to
those
that
report
on
less
than
6
use
sites
per
chemical.
The
results
for
companies
reporting
more
than
21
use
sites
per
chemical
are
less
certain
because
of
the
relatively
few
survey
responses
in
these
ranges.

As
presented
in
Table
D­
9,
the
average
number
of
use
sites
per
chemical
as
reported
by
all
companies
is
between
21.0
and
45.5
sites.
The
reported
survey
values
range
from
0
to
1,000
sites,
with
a
weighted
average
number
for
all
companies
of
between
22.9
and
49.3
use
sites
per
chemical.
Large
companies,
on
average,
reported
significantly
more
use
sites
per
chemical
than
small
and
medium
companies.
While
the
average
number
of
use
sites
is
high
because
of
the
large
range
presented
in
the
D­
18
Average
Reporting
Burden
vs.
Average
Number
of
Use
Sites
for
All
Companies
Surveyed
0.0
10.0
20.0
30.0
40.0
50.0
60.0
70.0
80.0
1­
5
6­
20
21­
50
>
50
Average
Number
of
Us
e
Site
s
Average
Reporting
Burden
(
hours)
survey
results,
the
median
values
are
much
lower,
indicating
that
for
many
companies
this
data
comp
onent
is
not
partic
ularly
burde
nsom
e.

Exhi
bit
D­
3.
Relat
ions
hip
Betw
een
Aver
age
Reporting
Burden
and
Average
Number
of
Use
Sites
for
All
Companies
Surveyed
D­
19
Table
D­
9.
Mean,
Median,
and
Range
of
Use
Sites
per
Chemical
for
Small,
Medium,
and
Large
Company
Sites
Use
Sites
per
Chemical
Mean
Median
Range
Low
High
Low
High
Low
High
Small
3.2
4.1
0.0
0.0
0.0
20.0
Medium
8.1
51.3
1.0
1.0
0.0
500.0
Large
35.4
65.0
2.0
5.0
0.0
1,000.0
All
Companies
(
unweighted)
21.0
45.5
1.0
1.0
0.0
1,000.0
All
Companies
(
weighted)
a
22.9
49.3
­­­­
­­­­
­­­­
­­­­

a
Weighting
refers
to
the
distribution
of
average
reporting
burden
by
company
size
based
on
the
proportion
of
companies
within
each
size
class
for
the
set
of
1994
IUR
reporting
companies.

Sources:
CUS
Database
1996,
ICF
1996.

5.
Number
of
End
Uses
Information
developed
from
the
survey
on
end
uses
was
analyzed
to
determine
the
average
number
of
end
uses
per
chemical
for
small,
medium,
and
large
companies.
The
weighted
average
number
of
end
uses
per
chemical
as
reported
by
all
surveyed
companies
is
between
3.2
and
5.1
end
uses,
with
estimates
ranging
from
0
to
100,
as
presented
in
Table
D­
10.
While
the
ranges
presented
in
Table
D­
10
are
broad,
both
the
mean
and
median
estimates
for
all
company
sizes
within
a
consistent
band
of
between
1
and
7
end
uses
per
chemical.
D­
20
Table
D­
10.
Mean,
Median,
and
Range
of
End
Uses
per
Chemical
for
Small,
Medium,
and
Large
Company
Sites
End
Uses
per
Chemical
Mean
Median
Range
Low
High
Low
High
Low
High
Small
2.4
2.5
1.5
2.0
1.0
8.0
Medium
2.9
3.3
3.0
3.0
1.0
6.0
Large
3.6
6.8
3.0
4.0
0.0
100.0
All
Companies
(
unweighted)
3.1
4.9
3.0
3.0
0.0
100.0
All
Companies
(
weighted)
a
3.2
5.1
­­­­
­­­­
­­­­
­­­­

a
Weighting
refers
to
the
distribution
of
average
reporting
burden
by
company
size
based
on
the
proportion
of
companies
within
each
size
class
for
the
set
of
1994
IUR
reporting
companies.

Sources:
CUS
Database
1996,
ICF
1996.
D­
21
Attachment
1.
Industry
Burden
Survey
and
Cover
Letter
Sent
to
Survey
Participants.
OMB
Control
No.
2070­
0034
D­
22
SURVEY
FOR
ESTIMATING
THE
INDUSTRY
BURDEN
ASSOCIATED
WITH
COLLECTING
ADDITIONAL
CHEMICAL
USE
DATA
UNDER
TSCA
SECTION
8
(
IUR
AMENDMENTS)

Name
of
Respondent
_________________________________

Position/
Title
_________________________________

Name
of
Company
_________________________________

Address
_________________________________

_________________________________

_________________________________

_________________________________

Phone
Number
_________________________________

Fax
Number
_________________________________
Page
1
of
25
***********
IMPORTANT
***********

This
survey
has
been
developed
to
determine
the
industry
effort
associated
with
collecting
chemical
exposure
data
under
TSCA
Section
8.
When
completing
the
following
questions,
please
mark
all
answers
according
to
a
base
case
scenario
in
which
the
data
being
reported
applies
to
one
typical
chemical
being
produced
at
one
typical
manufacturing
site,
unless
otherwise
instructed
in
the
question.
If
possible,
please
provide
a
breakout
of
the
burden
estimate
by
labor
category
for
each
question.
Please
note
that
staff
from
all
labor
categories
may
not
be
required
to
complete
each
individual
data
element.
Any
and
all
connection
between
the
identity
of
the
respondent
and
the
answers
to
the
survey
will
be
kept
confidential
and
will
not
be
provided
to
EPA.
PROPOSED
SURVEY
FOR
ESTIMATING
THE
INDUSTRY
BURDEN
ASSOCIATED
WITH
COLLECTING
ADDITIONAL
CHEMICAL
USE
DATA
UNDER
TSCA
SECTION
8
(
IUR
AMENDMENTS)

PART
1.
FACILITY
IDENTIFICATION
INFORMATION
Section
1.1.
Certification
1.
The
reporting
form
requires
a
signature
certifying
that
the
information
provided
is
complete
and
accurate.
Please
estimate
the
amount
of
time
that
will
be
required
to
complete
this
certification,
including
the
time
needed
for
final
review
(
legal
and
technical)
and
verification
of
information
(
note:
do
not
include
time
that
is
covered
in
other
survey
questions):

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
(
including
legal)

Certification
Section
1.2.
Plant
Site
Identification
2.
This
section
of
the
reporting
form
requires
identification
and
address
information
for
a
typical
manufacturing
plant
site.
Please
indicate
the
estimated
amount
of
time
required
to
provide
this
information
(
including
plant
site
name,
CBI,
Dun
&
Bradstreet
number,
and
plant
site
address):
Page
2
of
25
Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Plant
Site
Identification
3.
The
reporting
form
requires
indication
of
the
EPA
Identification
Number
(
EPA
ID)
that
corresponds
to
the
facility
being
reported.
The
EPA
ID
is
a
12­
character
number
assigned
to
facilities
covered
by
RCRA.
Facilities
not
covered
by
RCRA
are
not
likely
to
have
an
assigned
EPA
ID.
Please
indicate
the
estimated
time
to
determine
the
EPA
ID
for
the
facility
being
reported
(
in
the
case
that
a
typical
facility
at
your
company
does
not
have
an
EPA
ID,
enter
the
estimated
time
to
determine
that
an
EPA
ID
does
not
exist,
and
check
the
Not
Applicable
box
below):

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
EPA
Identification
Number
EPA
Identification
Number
Not
Applicable
Section
1.3.
Company
Information
4.
This
section
of
the
reporting
form
requires
the
contact
information
for
a
technical
contact
including
address
and
telephone
number.
Please
estimate
the
amount
of
time
that
would
be
necessary
to
provide
this:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Company
Information
Page
3
of
25
5.
To
calculate
the
amount
of
time
that
may
be
needed
to
provide
company­
and
site­
specific
information
for
all
chemicals
and
associated
plant
sites,
it
is
necessary
to
determine
the
number
of
reportable
chemicals
produced
at
a
typical
facility
and
how
many
facilities
may
produce
one
typical
chemical.

a.
Please
provide
an
estimate
of
the
number
of
plant
sites
that
manufacture
a
typical
chemical:

Estimated
Number
of
Plant
Sites
That
Manufacture
a
Typical
Chemical
b.
Please
provide
an
estimate
of
the
number
of
chemicals
with
annual
volume
greater
than
10,000
pounds
manufactured
at
a
typical
plant
site:

Estimated
Number
of
Chemicals
Manufactured
at
a
Typical
Plant
Site
Page
4
of
25
PART
2.
CHEMICAL
SPECIFIC
INFORMATION
Section
2.1.
Manufacturing
Information
6.
This
section
of
the
reporting
form
requires
information
(
subsections
a
­
f)
regarding
manufacturing
specifications.
Please
provide
burden
estimates
in
the
box
below
based
on
the
following
data
requirements:

a.
Identifying
Number:
Provide
the
CAS
number
of
the
chemical.

b.
ID
Code:
Indicate
the
correct
tracking
code
from
a
list
on
the
back
of
the
reporting
form.

c.
Activity
(
M
or
I)
and
CBI:
Provide
information
on
the
production
of
the
chemical
by
indicating
"
M"
(
manufacture)
or
"
I"
(
import);
indicate
if
this
is
CBI.

d.
Site
Limited
and
Indication
of
CBI:
Indicate
if
the
chemical
is
distributed
for
commercial
purposes
outside
of
the
plant
site;
also,
indicate
if
this
is
CBI.

e.
Production
Volume
in
Pounds
and
Indication
of
CBI:
Provide
the
production
volume,
in
pounds,
of
the
relevant
chemical
manufactured
at
this
plant
site;
also,
indicate
if
this
is
CBI.

f.
Specific
Chemical
Name:
Indicate
the
name
of
the
chemical
for
which
information
is
being
provided.

Please
indicate
the
estimated
amount
of
time
necessary
to
complete
subsections
a
­
f
for
one
typical
chemical
at
a
typical
manufacturing
plant
site:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Manufacturing
Information
(
a
­
f)
Page
5
of
25
PART
2.
(
Continued)

7.
This
section
of
the
reporting
form
requires
indication
of
CBI
status
for
Chemical
Identity.
A
CBI
claim
for
this
information
requires
up­
front
substantiation,
including
a
justification
of
why
release
of
this
information
would
jeopardize
the
market
position
of
the
company.
Indicate
the
estimated
amount
of
time
to
indicate
CBI
status
and
provide
substantiation
for
a
CBI
claim,
if
applicable,
for
chemical
identity:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Chemical
Identity
a.
If
this
information
is
not
typically
claimed
CBI,
please
indicate
that
by
checking
the
box
below.

Chemical
Identity
CBI
Substantiation
Not
Applicable
8.
This
section
of
the
reporting
form
requires
indication
of
CBI
status
for
Facility
Identity.
A
CBI
claim
for
this
information
requires
up­
front
substantiation,
including
a
justification
of
why
release
of
this
information
would
jeopardize
the
market
position
of
the
company.
Indicate
the
estimated
amount
of
time
to
indicate
CBI
status
and
provide
substantiation
for
a
CBI
claim,
if
applicable,
for
facility
identity:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Facility
Identification
a.
If
this
information
is
not
typically
claimed
CBI,
please
indicate
that
by
checking
the
box
below.

Facility
Identification
CBI
Substantiation
Not
Applicable
Page
6
of
25
PART
2.
(
Continued)

9.
This
section
of
the
reporting
form
requires
indication
of
CBI
status
of
production
volume
range
information.
The
ranges
are:

10,000
­
100,000
lbs/
yr
50,000,000
­
100,000,000
lbs/
yr
100,000
­
1,000,000
lbs/
yr
100,000,000
­
500,000,000
lbs/
yr
1,000,000
­
10,000,000
lbs/
yr
500,000,000
­
1,000,000,000
lbs/
yr
10,000,000
­
50,000,000
lbs/
yr
If
the
production
volume
range
is
not
indicated
to
be
CBI,
the
information
may
be
made
available
to
the
public.
Please
indicate
the
estimated
amount
of
time
required
to
indicate
CBI
status
of
the
production
volume
in
ranges:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
CBI
Status
of
Production
Volume
in
Ranges
a.
For
what
percentage
of
the
chemicals
reported
by
your
company
would
the
production
volume
range
be
claimed
CBI?

Percent
of
Chemicals
Whose
Production
Volume
Range
Would
Be
Claimed
CBI
10.
This
section
of
the
reporting
form
requires
indication
of
the
appropriate
range
of
the
total
number
of
workers
potentially
exposed
to
the
chemical
being
reported
and
indication
of
CBI
status
for
that
information.
The
ranges
are:
Fewer
than
10
workers
10
to
20
workers
25
to
100
workers
100
to
250
workers
250
to
1,000
workers
More
than
1,000
workers
Please
indicate
the
estimated
amount
of
time
required
to
provide
this
information:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Estimated
Total
Number
of
Potentially
Exposed
Workers
Page
7
of
25
PART
3.
INFORMATION
ON
CHEMICAL
PROCESSING
­
INCORPORATIVE
ACTIVITIES
Please
be
advised
that
the
reporting
form
requires
some
information
in
this
section
to
be
provided
by
indicating
ranges
rather
than
exact
numbers.
The
ranges
are
as
follows:

number
of
processing
sites
number
of
potentially
exposed
workers
Fewer
than
10
Fewer
than
10
10
to
20
10
to
20
25
to
100
25
to
100
100
to
250
100
to
250
250
to
1,000
250
to
1,000
More
than
1,000
More
than
1,000
maximum
concentration
(
wt
%)
Fewer
than
1%
1
to
30%
30
to
60%
60
to
90
%
Less
than
90%

Please
note
that
codes
will
be
designated
to
stand
for
various
ranges
(
e.
g.,
the
letter
`
b'
will
mean
between
10
and
20
processing
sites).

11.
Not
Applicable:

The
first
step
in
this
section
requires
determination
of
whether
or
not
the
chemical
being
reported
undergoes
chemical
processing.
Please
indicate
the
estimated
amount
of
time
necessary
to
determine
whether
chemical
processing
is
applicable
for
the
chemical
being
reported:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Not
Applicable
If
chemical
processing
does
not
apply
to
any
chemicals
that
your
company
reports
under
TSCA
Section
8
,
please
skip
to
PART
4.

If
chemical
processing
does
apply
to
one
or
more
of
the
chemicals
that
your
company
reports,
please
continue
with
PART
3.
Page
8
of
25
PART
3.
(
Continued)

12.
Function
Codes:

This
section
requires
determination
of
the
functions
and
function
codes
(
provided
in
Attachment
1)
for
the
chemical
being
reported.
Although
the
information
required
for
each
category
is
the
same,
the
reporting
form
divides
the
functions
into
two
categories
­
incorporation
into
a
formulation,
mixture,
or
reaction
product
and
incorporation
into
an
article.
Please
indicate
the
estimated
amount
of
time
necessary
to
determine
and
report
the
function
codes
for
a
typical
chemical:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Function
Codes
13.
SIC
Code:

For
each
function
code
of
the
chemical
that
is
reported,
SIC
codes
must
be
reported
for
processing
sites.
It
has
not
been
determined
whether
a
3­
digit
or
a
4­
digit
SIC
code
will
be
required.
Please
indicate
separately
the
estimated
amount
of
time
required
to
determine
and
report
a
chemical's
4­
digit
and
3­
digit
SIC
codes
for
one
function
category:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
3­
Digit
SIC
Code
4­
Digit
SIC
Code
14.
Percent
Production
Volume:
Page
9
of
25
The
reporting
form
requires
a
determination
of
the
percentage
of
production
volume
of
the
chemical
that
is
processed
in
each
specific
combination
of
SIC
code
and
function
code.
The
percent
production
volume
is
required
to
be
reported
within
±
10%
of
the
actual
percentage.
Since
the
total
production
volume
of
the
chemical
has
already
been
determined
in
Part
2
of
the
reporting
form,
the
information
necessary
for
the
calculations
required
here
includes
only
the
amount
of
the
chemical
that
is
used
in
each
industry
classification
(
SIC
code).
Please
indicate
the
estimated
amount
of
time
required
to
calculate
and
report
the
appropriate
range
for
the
percentage
of
production
volume
for
a
single
function
code
and
SIC
code
combination
for
a
typical
chemical:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Percent
Production
Volume
PART
3.
(
Continued)

15.
Number
of
Processing
Sites:

The
reporting
form
requires
information
on
the
appropriate
range
for
the
number
of
processing
sites
that
receive
the
chemical
from
the
specific
production
plant
for
each
combination
of
function
code
and
SIC
code.
Please
indicate
the
estimated
amount
of
time
necessary
to
provide
the
appropriate
range
for
the
number
of
processing
sites
for
a
single
function
code
and
SIC
code
combination
for
a
typical
chemical:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Number
of
Processing
Sites
16.
Number
of
Potentially
Exposed
Workers:

The
appropriate
range
for
the
number
of
potentially
exposed
workers
at
all
processing
sites
for
each
combination
of
function
code
and
SIC
code
is
also
required
in
this
section
of
the
form.
Please
indicate
the
estimated
amount
of
time
necessary
to
determine
the
appropriate
range
for
the
number
of
potentially
exposed
workers
for
a
single
function
code
and
SIC
code
combination
for
a
typical
chemical:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Number
of
Potentially
Exposed
Workers
Page
10
of
25
17.
Maximum
Concentration
(
wt%):

The
appropriate
range
for
the
maximum
concentration,
by
weight
percentage,
of
the
chemical
that
is
incorporated
into
a
formulation,
mixture,
or
reaction
product
or
into
an
article
is
also
required
in
this
section
of
the
form.
Please
indicate
the
estimated
amount
of
time
necessary
to
determine
the
appropriate
range
for
the
maximum
concentration,
by
weight
percentage,
for
a
single
function
code
and
SIC
code
combination
for
a
typical
chemical:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Maximum
Concentration
(
wt%)
Page
11
of
25
PART
3.
(
Continued)

18.
Repackaging:

Some
percentage
of
the
chemical
may
be
repackaged
rather
than
processed
or
used
in
another
product
after
manufacture.
Please
indicate
the
estimated
amount
of
time
that
would
be
necessary
to
complete
the
following
data
for
information
about
repackaging
for
a
typical
chemical:

Required
Information
(
Reported
in
Ranges)
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Percent
of
Production
Volume
Number
of
Repackaging
Sites
Number
of
Exposed
Workers
Maximum
Concentration
(
wt%)

CBI
Claims
Page
12
of
25
PART
4.
INFORMATION
ON
CHEMICAL
USE
­
NON­
INCORPORATIVE
ACTIVITIES
Please
be
advised
that
the
reporting
form
requires
some
information
in
this
section
to
be
provided
by
indicating
ranges
rather
than
exact
numbers.
The
ranges
are
as
follows:

number
of
processing
sites
number
of
potentially
exposed
workers
Fewer
than
10
Fewer
than
10
10
to
20
10
to
20
25
to
100
25
to
100
100
to
250
100
to
250
250
to
1,000
250
to
1,000
More
than
1,000
Less
than
1,000
maximum
concentration
(
wt
%)
Fewer
than
1%
1
to
30%
30
to
60%
60
to
90
%
More
than
90%

Please
note
that
codes
will
be
designated
to
stand
for
various
ranges
(
e.
g.,
the
letter
`
b'
will
mean
between
10
and
20
non­
incorporative
use
sites).

19.
Not
Applicable:

The
first
step
in
this
section
requires
determination
of
whether
or
not
use
in
non­
incorporative
activities
occurs
for
the
chemical
being
reported.
Please
indicate
the
estimated
amount
of
time
necessary
to
determine
whether
chemical
use
information
must
be
reported:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Not
Applicable
If
chemical
use
in
non­
incorporative
activities
does
not
apply
to
any
chemicals
that
your
company
reports
under
TSCA
Section
8,
please
skip
to
PART
5.

If
chemical
use
in
non­
incorporative
activities
does
apply
to
one
or
more
of
the
chemicals
that
your
company
reports,
please
continue
with
PART
4.
Page
13
of
25
PART
4.
(
Continued)

20.
Function
Codes:

The
first
step
in
this
section
requires
determination
of
the
functions
and
function
codes
(
provided
in
Attachment
1)
for
the
chemical
being
reported.
Please
indicate
the
estimated
amount
of
time
necessary
to
determine
and
report
the
function
codes
for
a
typical
chemical
at
all
use
sites:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Function
Codes
21.
SIC
Code:

For
each
function
code
of
the
chemical
that
is
reported,
SIC
codes
must
be
reported
for
use
sites.
It
has
not
been
determined
whether
a
3­
digit
or
a
4­
digit
SIC
code
will
be
required.
Please
indicate
separately
the
estimated
amount
of
time
required
to
determine
and
report
a
chemical's
4­
digit
and
3­
digit
SIC
codes
for
one
function
category:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
3­
Digit
SIC
Code
4­
Digit
SIC
Code
22.
Percent
Production
Volume:

The
reporting
form
requires
a
determination
of
the
percentage
of
production
volume
of
the
chemical
that
is
used
in
each
specific
industry
category
by
SIC
and
function
code
combination.
The
percent
production
volume
is
required
to
be
reported
within
±
10%
of
the
actual
percentage.
Since
the
total
production
volume
of
the
chemical
has
already
been
determined
in
Part
2
of
the
reporting
form,
the
information
necessary
for
the
calculations
required
here
includes
only
the
amount
of
the
chemical
that
is
used
in
each
industry
classification
(
SIC
code).
Please
indicate
the
estimated
amount
of
time
required
to
calculate
and
report
the
appropriate
range
for
the
percentage
of
production
volume
for
a
single
function
code
and
SIC
code
combination
for
a
typical
chemical:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Percent
Production
Volume
Page
14
of
25
23.
Number
of
Use
Sites:

The
reporting
form
requires
information
on
the
number
of
use
sites
that
receive
the
chemical
from
the
specific
production
plant
for
each
combination
of
function
code
and
SIC
code.
Please
indicate
the
estimated
amount
of
time
necessary
to
provide
the
appropriate
range
for
the
number
of
use
sites
for
a
single
function
code
and
SIC
code
combination
for
a
typical
chemical:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Number
of
Use
Sites
24.
Number
of
Potentially
Exposed
Workers:

The
number
of
potentially
exposed
workers
at
all
of
the
use
sites
for
each
combination
of
function
code
and
SIC
code
is
also
required
in
this
section
of
the
form.
Please
indicate
the
estimated
amount
of
time
necessary
to
determine
the
appropriate
range
for
the
number
of
potentially
exposed
workers
for
a
single
function
code
and
SIC
code
combination
for
a
typical
chemical:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Number
of
Potentially
Exposed
Workers
Page
15
of
25
PART
5.
KNOWN
COMMERCIAL
AND
CONSUMER
END­
USES
OF
CHEMICAL
Please
be
advised
that
the
reporting
form
requires
some
information
in
this
section
to
be
provided
by
indicating
ranges
rather
than
exact
numbers.
The
ranges
are
as
follows:

maximum
concentration
(
wt
%)
number
of
potentially
exposed
workers
Less
than
1%
Fewer
than
10
1
to
30%
10
to
20
30
to
60%
25
to
100
60
to
90
%
100
to
250
250
to
1,000
250
to
1,000
Greater
than
90%
More
than
1,000
Please
note
that
codes
will
be
designated
to
stand
for
various
ranges
(
e.
g.,
the
letter
`
b'
will
mean
between
10
and
20
potentially
exposed
workers).

25.
Not
Applicable:

The
first
step
in
this
section
requires
determination
of
the
existence
of
commercial
and
consumer
end­
uses
involving
the
chemical
being
reported.
Please
indicate
the
estimated
amount
of
time
necessary
to
determine
whether
known
end­
uses
for
the
chemical
must
be
reported:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Not
Applicable
If
commercial
and
consumer
end­
uses
do
not
apply
to
any
chemicals
that
your
company
reports
under
TSCA
Section
8,
please
skip
to
PART
6.

If
commercial
and
consumer
end­
uses
do
apply
to
one
or
more
of
the
chemicals
that
your
company
reports,
please
continue
with
PART
5.
Page
16
of
25
PART
5.
(
Continued)

26.
End­
Use
Categories:

The
reporting
form
provides
the
following
end­
use
categories
and
requires
that
all
of
the
appropriate
uses
be
designated
on
the
form.
Please
indicate
the
estimated
amount
of
time
that
would
be
necessary
to
determine
the
use
categories
of
a
typical
chemical:

Adhesives
and
Sealants
Cosmetics
and
Toiletries
Automotive
Care
Products
Electrical/
Electronic
Products
Glass/
Ceramic
Products
Fabric/
Textiles/
Apparel
Leather
Products
Lubricants,
Greases,
&
Fuel
Additives
Metal
Products
Paper
Products
Paint
and
Coatings
Pesticides
and
Lawn/
Garden
Products
Polishes
and
Sanitation
Rubber/
Plastic
Products
Soaps
and
Detergents
Transportation
Products
Wood/
Wood
Furniture
Other
Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
End­
Use
Categories
27.
Percent
of
Production
Volume:

The
reporting
form
requires
that
the
percentage
of
production
volume
for
each
end­
use
be
determined.
The
percent
of
production
volume
is
required
to
be
reported
within
±
10%
of
the
actual
percentage.
Please
indicate
the
estimated
amount
of
time
that
would
be
necessary
to
provide
percent
of
production
volume
information
for
a
typical
chemical:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Percent
of
Production
Volume
Page
17
of
25
PART
5.
(
Continued)

28.
Percent
by
Weight
of
Chemical
in
Product:

The
reporting
form
requires
an
estimate
of
the
appropriate
range
of
the
percentage
(
by
weight)
of
the
chemical
in
the
designated
end­
use
category.
Please
indicate
the
estimated
amount
of
time
that
would
be
necessary
to
indicate
the
appropriate
range
for
a
typical
chemical
in
a
typical
end­
use
category:

Required
Information
Estimated
Hours
Required
By
Each
Staff
Level
Clerical
Technical
Management
Percent
by
Weight
of
Chemical
in
End­
Use
Page
18
of
25
Page
19
of
25
PART
6.
GENERAL
QUESTIONS
ON
REPORTING
The
following
questions
request
information
about
all
of
the
Parts
and
Sections
of
the
reporting
form
as
a
whole.
However,
please
continue
to
mark
all
answers
according
to
a
base
case
scenario
in
which
the
data
being
reported
applies
to
one
typical
chemical
being
produced
at
one
typical
manufacturing
site,
unless
otherwise
instructed
in
the
question.

29.
Please
provide
numerical
estimates
that
correspond
to
the
following
statements
assuming
the
base
case
scenario:

DATA
ELEMENT
RESPONSE
(
Please
provide
a
numerical
response)

Average
number
of
function
codes
per
chemical
produced
at
a
typical
manufacturing
site
Average
number
of
3­
digit
SIC
codes
per
function
code
Average
number
of
4­
digit
SIC
codes
per
function
code
Average
total
number
of
incorporative
processing
sites
to
which
a
typical
chemical
is
distributed
from
one
manufacturing
plant
Average
total
number
of
non­
incorporative
use
sites
to
which
a
typical
chemical
is
distributed
from
one
manufacturing
plant
Average
number
of
end­
uses
of
a
typical
chemical
that
would
be
reported
based
upon
categories
listed
in
Question
26
Page
20
of
25
PART
6.
(
Continued)

30.
Indicate
the
data
elements
below
that
are
required
in
the
reporting
form
that
are
presently
available
in
a
company
database
or
otherwise
readily
available:

DATA
ELEMENT
AVAILABLE
(
check
if
yes)

PART
1:
FACILITY
IDENTIFICATION
INFORMATION
Manufacturing
Plant
Site
Name
Company
Technical
Contact
Name
PART
2:
CHEMICAL
SPECIFIC
INFORMATION
Manufacturing
Activity
(
M
or
I)

Manufacturing
Plant
Site
Limited
Chemical
Use
Total
Production
Volume
Plant
Link
to
Chemical
Chemical
Link
to
Plant
Total
Number
of
Potentially
Exposed
Workers
Process
Category
PART
3.
INFORMATION
ON
CHEMICAL
PROCESSING
­
INCORPORATIVE
ACTIVITIES
Function
Code
3­
Digit
SIC
Code
4­
Digit
SIC
Code
Percent
Production
Volume
Numbers
of
Potentially
Exposed
Workers
Numbers
of
Processing
Sites
PART
4.
INFORMATION
ON
CHEMICAL
USE
­
NON­
INCORPORATIVE
ACTIVITIES
Function
Code
3­
Digit
SIC
Code
4­
Digit
SIC
Code
Percent
Production
Volume
Numbers
of
Potentially
Exposed
Workers
Numbers
of
Use
Sites
PART
5.
KNOWN
COMMERCIAL
AND
CONSUMER
END­
USES
OF
CHEMICAL
End­
Use
Category
Percent
Production
Volume
Estimated
Weight
Percentage
in
Consumer
Product
Page
21
of
25
PART
6.
(
Continued)

31.
Indicate
which
of
the
required
data
elements
your
company
is
likely
to
claim
CBI:

DATA
ELEMENT
CLAIM
CBI
(
check
if
yes)

PART
1:
FACILITY
IDENTIFICATION
INFORMATION
Manufacturing
Plant
Site
Name
Company
Technical
Contact
Name
PART
2:
CHEMICAL
SPECIFIC
INFORMATION
Manufacturing
Activity
(
M
or
I)

Manufacturing
Plant
Site
Limited
Chemical
Use
Total
Production
Volume
Total
Production
Volume
Within
a
Range
Plant
Link
to
Chemical
Chemical
Link
to
Plant
Total
Number
of
Potentially
Exposed
Workers
Process
Category
PART
3.
INFORMATION
ON
CHEMICAL
PROCESSING
­
INCORPORATIVE
ACTIVITIES
Function
Code
3­
Digit
SIC
Code
4­
Digit
SIC
Code
Percent
Production
Volume
Numbers
of
Potentially
Exposed
Workers
Numbers
of
Processing
Sites
PART
4.
INFORMATION
ON
CHEMICAL
USE
­
NON­
INCORPORATIVE
ACTIVITIES
Function
Code
3­
Digit
SIC
Code
4­
Digit
SIC
Code
Percent
Production
Volume
Numbers
of
Potentially
Exposed
Workers
Numbers
of
Use
Sites
PART
5.
KNOWN
COMMERCIAL
AND
CONSUMER
END­
USES
OF
CHEMICAL
End­
Use
Category
Percent
Production
Volume
Estimated
Weight
Percentage
in
Consumer
Product
Page
22
of
25
PART
6.
(
Continued)

32.
Please
indicate
if
your
company
has
a
schedule
for
the
retention
of
records,
including
chemical
production
information:

Yes
No
a.
If
yes,
for
how
long
does
your
company
retain
records?

b.
Please
explain:

33.
Please
indicate
if
your
company
has
a
policy
for
the
destruction
of
records:

Yes
No
b.
Please
explain:

34.
We
welcome
any
suggestions
you
may
have
concerning
improvements
in
the
reporting
form
that
has
been
provided
here.
You
may
provide
comments
by
telephone
or
mail
to:

Mark
Wagner
ICF
Incorporated
1850
K
Street,
NW,
Suite
1000
Washington
DC
20006­
2213
phone:
202­
862­
1155
fax:
202­
862­
1144
Page
23
of
25
ATTACHMENT
1
Proposed
List
of
Function
Codes
for
IUR
Reporting
Intermediates
(
Only
valid
for
incorporation
into
product)
Lubricants
and
Lubricant
Additives
Adsorbents
and
Absorbents
Odor
Agents
Adhesive
and
Binding
Agents
Oxidizing
Agents
Aerosol
Propellants
Photosensitive
Chemicals
Agricultural
Chemicals
pH­
Regulating
Agents
Anti­
Adhesive
Agents
Process
Regulators,
used
in
Polymerization
or
Vulcanization
Processes
Bleaching
Agents
Process
Regulators
other
than
Polymerization
or
Vulcanization
Chemical
Processing
Aids,
not
otherwise
listed
Reducing
Agents
Coloring
Agents
Reprographic
Agents
Corrosion
Inhibitors
and
Anti­
Scaling
Agents
Solvents,
Cleaning/
Degreasing
Electroplating
Agents
Solvents,
Become
Part
of
Product
Formulation
Fillers
Solvents,
For
Chemical
manufacture
and
Processing
that
are
Not
Part
of
the
End
Product
Fixing
Agents
Stabilizers
Flame
Retardants
Surface
Active
Agents,
Cleaning
Agents
Flotation
Agents
Surface
Active
Agents,
Emulsifying
Agents
Fuel
and
Fuel
Additives
Viscosity
Adjustors
Functional
Fluids,
Hydraulic
and
Transmission
Fluids
Sterilants/
Disinfectants/
Biocides
Functional
Fluids,
Heat
Transfer
Agents
Other
Functional
Fluids,
Electrical
Conductive
and
Semiconductive
Agents
Page
24
of
25
Attachment
2.
Draft
IUR
Amendments
Reporting
Form
Sent
to
Survey
Participants.
E­
1
APPENDIX
E.
SENSITIVITY
ANALYSIS
To
examine
the
effects
of
two
parameters
on
the
expected
costs
of
the
IUR
amendments,
a
sensitivity
analysis
has
been
performed.
The
sensitivity
cases
presented
in
this
appendix
assess
the
impacts
on
costs
of
certain
assumptions
presented
in
the
cost
analysis.
The
cost
analysis
presented
in
Chapter
III
of
this
report
incorporates
several
assumptions
regarding
the
average
chemical
that
would
be
reported
under
the
proposed
IUR
amendments.
Those
assumptions
include
the
number
of
reports
per
site
(
8.4
reports
per
site
under
the
amendments),
the
types
of
chemicals
reported
under
the
amendments
(
organic
and
inorganic
chemicals),
the
length
of
a
reporting
cycle
under
the
amendments
(
4
years),
and
a
discount
rate
of
three
percent.

Sensitivity
cases
were
developed
for
two
of
these
parameters
by
examining
the
effect
that
they
have
on
the
quantified
costs.
The
sensitivity
cases
are
as
follows:

Number
of
Reports
per
Site
Scenario
1a
assumes
that
each
site
would
submit
one
report.

Scenario
1b
assumes
that
each
site
would
submit
20
reports.

Variation
in
Discount
Rate
Scenario
2
changes
the
discount
rate
used
to
calculate
costs
of
the
proposed
IUR
amendments
from
three
percent
to
seven
percent.

A
cost
analysis
has
been
developed
for
each
case
presented
in
the
sensitivity
analysis.
Table
E­

1
presents
the
assumptions
for
each
of
these
sensitivity
cases.
As
shown
in
Table
E­
2,
the
sensitivity
analysis
for
Scenarios
1a
and
1b
was
based
on
variations
in
the
assumed
number
of
reports
per
site.

For
these
options,
incremental
costs
are
presented
only
in
terms
of
the
effect
on
cost
per
site.
Tables
E­

3
and
E­
4
present
the
first
year
incremental,
baseline,
and
total
net
present
values
and
annualized
costs
for
all
of
the
reporting
threshold
options
under
Scenario
2
(
i.
e.,
using
a
seven
percent
discount
rate).
The
costs
for
the
IUR
amendments
proposed
option
(
Option
4)
are
also
presented
in
each
table.

1.
Changing
the
Number
of
Reports
per
Site
An
increase
in
the
assumed
average
number
of
reports
per
site
will
significantly
increase
the
overall
average
cost
burden
per
site
of
the
IUR
amendments.
Under
Scenario
1a
per
site
costs
are
approximately
3
to
6
times
lower
than
the
costs
of
the
proposed
option
because
of
the
decrease
in
the
E­
2
number
of
reports
per
site.
Conversely,
increasing
the
number
of
reports
per
site
to
20
increases
per
site
costs
by
more
than
a
factor
of
2.
Based
on
the
data
presented
in
Chapter
III,
it
is
clear
that
these
estimates
(
i.
e.,
one
report
and
20
reports
per
site)
under­
and
over­
estimate,
respectively,
the
costs
for
a
typical
site.

Table
E­
1.
Assumptions
Incorporated
in
the
Sensitivity
Cases
Scenario
Sites
Reports
Reporting
Cycle
Comments
Proposal
1
8.4
4
years
proposed
option
1a
1
1
4
years
one
report
per
site
1b
1
20
4
years
twenty
reports
per
site
2
1
8.4
4
years
seven
percent
discount
rate
Table
E­
2.
Results
for
Sensitivity
Around
the
Number
of
Reports
per
Site
Scenario
Reports
Per
Site
Incremental
Cost
Per
Site
(
1997$)

Low
High
Proposal
8.4
Organic
Chemicals
$
21,169
$
27,112
Petroleum
Streams
$
5,780
$
10,407
Inorganic
Chemicals
$
24,878
$
32,526
Scenario
1a
1
Organic
Chemicals
$
3,790
$
4,747
Petroleum
Streams
$
1,958
$
2,758
Inorganic
Chemicals
$
4,533
$
5,849
Scenario
1b
20
Organic
Chemicals
$
48,412
$
62,171
Petroleum
Streams
$
11,769
$
22,397
Inorganic
Chemicals
$
56,771
$
74,343
E­
3
Table
E­
3.
Incremental
Net
Present
Values
and
Annualized
Costs
of
Threshold
Options
Discounted
at
Seven
Percent
(
million
1997$)

Option
Net
Present
Valuea
Annualized
Cost
Low
High
Low
High
Threshold
Options
Option
1
$
243.6
$
333.6
$
23.0
$
31.5
Option
2
$
203.0
$
277.5
$
19.2
$
26.2
Option
3
$
181.0
$
262.7
$
17.1
$
24.8
Option
4
$
165.1
$
234.6
$
15.6
$
22.1
Option
5
$
145.2
$
222.0
$
13.7
$
21.0
Option
6
$
129.3
$
194.0
$
12.2
$
18.3
Option
7
$
118.1
$
181.3
$
11.1
$
17.1
Option
8
$
91.0
$
150.6
$
8.6
$
14.2
Option
9
$
155.9
$
224.6
$
14.7
$
21.2
Reporting
Exemption
Options
Option
4
$
165.1
$
234.6
$
15.6
$
22.1
Option
10
$
189.1
$
258.4
$
17.8
$
24.4
Option
11
$
123.8
$
175.9
$
11.7
$
16.6
Reporting
Cycle
Options
Option
4
$
165.1
$
234.6
$
15.6
$
22.1
Option
12
$
226.2
$
347.1
$
21.4
$
32.8
Option
13
$
297.0
$
430.2
$
28.0
$
40.6
Option
14
$
44.8
$
61.1
$
4.2
$
5.8
Note:
1.
Option
4
is
the
proposed
option.
2.
Incremental
costs
may
not
calculate
exactly
due
to
rounding.
a
NPV
determined
for
a
20
year
period.
E­
4
Table
E­
4.
Total
Net
Present
Values
and
Annualized
Costs
of
Threshold
Options
Discounted
at
Seven
Percent
(
million
1997$)

Option
Net
Present
Valuea
Annualized
Cost
Low
High
Low
High
Baseline
$
57.0
$
90.0
$
5.4
$
8.5
Threshold
Options
Option
1
$
300.6
$
423.6
$
28.4
$
40.0
Option
2
$
260.0
$
367.5
$
24.5
$
34.7
Option
3
$
238.0
$
352.7
$
22.5
$
33.3
Option
4
$
222.1
$
324.6
$
21.0
$
30.6
Option
5
$
202.2
$
312.0
$
19.1
$
29.4
Option
6
$
186.3
$
284.0
$
17.6
$
26.8
Option
7
$
175.1
$
271.3
$
16.5
$
25.6
Option
8
$
148.0
$
240.6
$
14.0
$
22.7
Option
9
$
213.0
$
314.6
$
20.1
$
29.7
Reporting
Exemption
Options
Option
4
$
222.1
$
324.6
$
21.0
$
30.6
Option
10
$
246.1
$
348.4
$
23.2
$
32.9
Option
11
$
180.8
$
265.9
$
17.1
$
25.1
Reporting
Cycle
Options
Option
4
$
222.1
$
324.6
$
21.0
$
30.6
Option
12
$
276.7
$
426.8
$
26.1
$
40.3
Option
13
$
347.5
$
509.9
$
32.8
$
48.1
Option
14
$
57.8
$
81.6
$
5.4
$
7.7
a
NPV
determined
for
a
20
year
period.

2.
Changing
the
Discount
Rate
Since
the
benefits
resulting
from
the
proposed
regulation
will
not
occur
simultaneously
with
the
costs,
it
is
necessary
to
discount
the
future
streams
of
costs
and
benefits
before
comparing
them.
The
time
horizon
over
which
costs
and
benefits
are
discounted
in
this
analysis
is
20
years.
A
discount
rate
of
three
percent
is
used
in
Chapter
III,
however,
this
sensitivity
scenario
explores
the
effect
of
a
seven
percent
discount
rate
on
the
incremental
and
total
costs
of
the
fourteen
threshold
options.
E­
5
There
is
considerable
debate
in
the
economics
discipline
whether
to
use
the
social
rate
of
time
preference
or
the
rate
of
return
on
investment
when
discounting.
According
to
recent
literature,
the
rates
are
quite
similar
so
choosing
one
or
the
other
will
not
make
much
difference
in
the
magnitude
of
the
present
value
estimate.
The
debate
between
using
a
rate
of
return
on
investment
capital
and
the
consumption
rate
of
return
focuses
on
whether
investment
or
consumption
is
being
displaced.
Some
discounting
theory
emphasizes
that
one
dollar
diverted
from
productive
investment
reduces
the
stream
of
production
created
by
that
marginal
investment,
while
a
dollar
diverted
from
consumption
would
only
substitute
one
type
of
consumption
for
another.
This
diverted
capital
argument
is
the
basis
of
the
"
shadow
price
of
capital"
approach
to
discounting,
which
treats
displaced
investment
as
"
costing"
more
than
displaced
consumption.
The
practical
difficulty
in
implementing
this
approach
is
to
identify
which
costs
are
diverted
investments,
and
which
are
diverted
consumption.
Various
pragmatic
approaches
to
solving
this
dilemma
have
been
proposed
and
used
by
EPA
and
other
government
agencies
for
regulatory
analysis,
including
the
"
two­
staged"
discounting
approach
(
Kolb
and
Scheraga
1990),
or
a
single
"
blended
rate"
somewhere
between
the
rate
of
investment
return
and
the
consumption
return.

Recent
developments
in
the
economic
literature
have
raised
serious
questions
about
the
extent
to
which
capital
is
actually
"
displaced"
today.
The
displaced
capital
theory
maintains
that
because
regulation
diverts
funds
from
alternative
investments,
some
investment
opportunities
are
not
undertaken.

The
pool
of
available
capital
is
assumed
to
be
fixed,
forcing
some
investment
to
be
foregone
when
capital
is
diverted.
While
the
pool
of
available
capital
is
relatively
fixed
(
at
least
in
the
short
run)
in
a
closed
economy,
in
an
open
economy
capital
can
flow
in
from
other
countries.
The
increased
demand
for
investment
capital
in
the
United
States
(
created
in
part
to
finance
the
federal
deficit)
has
attracted
large
amounts
of
capital
into
the
country,
and
many
economists
feel
this
has
significantly
reduced
the
pressure
that
federal
borrowing
has
had
on
real
interest
rates.
While
the
supply
of
capital
is
not
perfectly
elastic,
neither
is
it
perfectly
inelastic.
An
elastic
supply
of
capital
reduces
the
difference
between
investment
rates
of
return
and
consumer
rates
of
return.

Estimates
of
real
rates
of
return
on
investment
are
lower
than
many
people
believe.
The
real
rate
of
return
on
United
States
government
bonds
has
been
near
zero
percent
for
most
of
this
century,

while
the
annual
return
on
a
broad
portfolio
of
stocks
has
averaged
near
four
percent.
In
general,
stocks
have
done
better
since
1980
(
averaging
4.26
percent)
than
in
the
other
periods
this
century,
but
the
rate
E­
6
of
return
may
return
to
historic
norms
in
the
future
(
Freeman
1993).
Thus,
the
real
rates
of
return
on
investment
opportunities
range
from
near
zero
to
four
percent.

The
issues
involving
the
appropriate
discount
rates
and
procedures
are
complex,
and
are
not
likely
to
be
resolved
soon.
Much
of
the
recent
economic
literature
summarizing
the
discounting
debate
concludes
that
discount
rates
reflecting
either
the
social
rate
of
time
preference
or
the
rate
of
return
on
investments
are
the
appropriate
discount
rates
to
use,
and
also
concludes
that
there
is
not
much
difference
between
the
rates.
For
example,
Moore
and
Viscusi
(
1990)
find
no
evidence
that
the
rate
of
time
preference
for
environmental­
related
health
effects
differs
from
financial
rates
of
return
and
cite
evidence
that
a
two
percent
rate
is
appropriate.
Lind
(
1990)
recommends
a
range
of
one
to
three
percent,
and
Freeman
(
1993)
recommends
two
to
three
percent.

Based
on
the
information
presented
above,
a
three
percent
discount
rate
has
been
adopted
as
the
most
appropriate
rate
for
use
in
this
analysis.
However,
the
results
of
discounting
costs
at
a
seven
percent
rate
are
presented
in
Tables
E­
3
and
E­
4.
A
comparison
of
these
tables
with
Tables
III­
27
and
III­
28
reveals
an
increase
in
incremental
annualized
costs
by
approximately
26
percent
and
a
decrease
in
incremental
net
present
values
by
approximately
10
percent
for
most
of
the
options.
For
example,

using
a
seven
percent
discount
rate,
the
incremental
annualized
costs
for
Option
4
(
the
proposed
option)

increase
by
approximately
26
to
27
percent
for
both
low
and
high
estimates,
while
incremental
net
present
value
costs
decrease
by
10
percent
for
both
low
and
high
estimates
with
respect
to
the
three
percent
discount
rate.
