Revised
Economic
Analysis
for
the
Amended
Inventory
Update
Rule
(
IUR)

Final
Report
Prepared
for
U.
S.
Environmental
Protection
Agency
Economics,
Exposure,
and
Technology
Division
Economics
and
Policy
Analysis
Branch
Ariel
Rios
Building
(
7406)
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
Prepared
by
Brian
C.
Murray
Robert
H.
Beach
George
L.
Van
Houtven
Research
Triangle
Institute
Health,
Social,
and
Economics
Research
Research
Triangle
Park,
NC
27709
EPA
Contract
Number
68­
W7­
0018
RTI
Project
Number
6807­
500­
503
August
7,
2001
ACKNOWLEDGMENTS
EPA
acknowledges
the
analytical
support
of
Research
Triangle
Institute
of
Research
Triangle
Park,
NC,
provided
under
EPA
Contract
No.
68­
W7­
0018
in
the
preparation
of
this
report.
This
page
intentionally
left
blank.
i
CONTENTS
Section
Page
Executive
Summary
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ES­
1
Summary
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S­
1
1
Introduction
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1­
1
1.1
Statutory
Authority
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1­
2
1.2
Description
of
the
IUR
Rule
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1­
3
1.2.1
Regulatory
History
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1­
3
1.2.2
Current
IUR
Requirements
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1­
4
1.2.3
Changes
in
Reporting
Requirements
under
the
IUR
Amendments
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1­
4
1.2.3.1
Reporting
Thresholds,
Reporting
Cycles,
and
Exemptions
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1­
5
1.2.3.2
Information
Collected
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1­
5
1.2.3.3
Definitions
of
Reporting
Terms
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1­
6
1.3
Overview
of
the
Regulated
Community
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1­
8
1.3.1
Chemical
Industry
Segments
Likely
to
be
Affected
by
the
IUR
Amendments
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1­
8
1.3.2
Information
to
be
Reported
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1­
12
1.4
Organization
of
this
Report
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1­
13
2
Statement
of
the
Problem
and
Regulatory
Options
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2­
1
2.1
Problem
Addressed
by
IUR
Amendments
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2­
1
2.1.1
Data
Required
to
Conduct
Risk
Screening
and
Management
2­
3
2.1.2
Current
Risk­
Screening
Approach
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2­
3
2.2
Market
Failure
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2­
4
2.2.1
Externalities
and
the
Need
for
Information
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2­
5
2.3
Potential
Need
for
Federal
Regulation
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2­
7
2.3.1
Existing
Data
Sources
and
Data
Gaps
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2­
7
2.3.2
Advantages
of
the
New
Information
Collection
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2­
9
2.3.3
Approaches
to
Regulation
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2­
9
2.4
Original
IUR
Requirements
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2­
11
ii
2.4.1
Original
Reporting
Requirements
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2­
11
2.4.2
Original
Exemptions
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2­
12
2.5
Regulatory
Options
for
Amending
the
IUR
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2­
12
2.5.1
Number
of
Reports
Received
under
Different
Options
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2­
13
3
Social
Costs
of
Regulatory
Options
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3­
1
3.1
Compliance
Costs
for
IUR
Submitters
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3­
2
3.1.1
Methodology
for
Compliance
Cost
Analysis
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3­
4
3.1.1.1
Identify
Tasks
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3­
4
3.1.1.2
Determine
Unit
Costs
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3­
5
3.1.1.3
Determine
Number
of
Forms
and
Reports
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3­
6
3.1.1.4
Determine
Total
Costs
of
Compliance
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3­
7
3.1.2
Data
for
Compliance
Cost
Analysis
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3­
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3.1.2.1
Estimates
of
Wage
Rates
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3­
8
3.1.2.2
Estimates
of
Labor
Hours
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3­
9
3.1.2.3
Estimates
of
the
Number
of
Sites
and
Reports
3­
11
3.1.3
Compliance
Cost
Calculations
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3­
11
3.1.3.1
Labor
Hours
Required
for
Compliance
Tasks
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3­
12
3.1.3.2
Incremental
Costs
of
Compliance
Tasks
under
IUR
Amendments
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3­
18
3.1.4
Summary
of
Compliance
Costs
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3­
22
3.1.4.1
Compliance
Costs
under
Amendments
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3­
23
3.1.4.2
Compliance
Costs
under
Regulatory
Options
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3­
23
3.1.4.3
Average
Compliance
Costs
per
Site
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3­
27
3.1.5
Limitations
of
the
Compliance
Cost
Analysis
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3­
27
3.2
Agency
Costs
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3­
31
3.2.1
Overview
of
and
Methodology
for
Determining
Agency
Costs
of
Reporting
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3­
31
3.2.2
Agency
Cost
Calculations
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3­
32
3.2.2.1
Agency
Costs
Under
the
IUR
Amendments
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3­
32
3.3
Social
Cost
Summary
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3­
34
4
The
Benefits
of
the
IUR
Amendments
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4­
1
4.1
Benefits
of
Information­
Based
Policies
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4­
2
4.2
Benefits
from
Processing
and
Use
Data
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4­
3
4.2.1
Benefits
through
OPPT
Risk­
Screening
and
Management
Programs
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4­
5
4.2.1.1
Risk­
Screening
Programs
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4­
5
iii
4.2.1.2
Risk
Management
Programs
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4­
9
4.2.1.3
Benefits
from
Cost
Savings
Associated
with
Pre­
screening
and
Screening
Activities
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4­
9
4.2.1.4
Benefits
from
Improved
Risk
Screening
and
Risk
Management
Decisions
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4­
10
4.2.2
Benefits
to
Non­
OPPT
Risk
Management
Programs
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4­
11
4.2.2.1
Other
Federal
Risk
Management
Programs
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4­
12
4.2.2.2
State
and
Local
Programs
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4­
12
4.2.2.3
Nongovernmental
Organization
(
NGO)
Initiatives
and
Private­
Sector
Stewardship
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4­
13
4.3
Benefits
Due
to
Changes
in
CBI
Reporting
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4­
13
4.4
Benefits
of
Changing
Certain
Reporting
Exemptions
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4­
14
4.5
Benefits
of
Administrative
Changes
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4­
15
4.6
Benefits
From
Changes
to
Reporting
Thresholds
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4­
16
4.7
Benefits
From
Alternative
Reporting
Cycle
Options
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4­
17
5
Benefit­
Cost
Analysis,
Cost­
Effectiveness
Comparisons,
and
Rationale
for
the
Selected
Option
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5­
1
5.1
Benefits
and
Costs
of
the
Selected
Option
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5­
1
5.2
Comparing
the
Benefits
and
Costs
of
Regulatory
Alternatives
to
the
Selected
Option
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5­
3
5.3
Benefit­
Cost
Summary
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5­
3
5.3.1
Rationale
for
Selecting
Option
1
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5­
3
5.3.2
Rationale
for
the
IUR
Amendments:
Positive
Net
Benefits
of
the
Selected
Option
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5­
5
6
Small
Entity
and
Environmental
Justice
Impact
Determinations
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6­
1
6.1
Small
Entity
Analysis
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6­
1
6.1.1
Determination
of
the
Number
of
Small
Businesses
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6­
1
6.1.1.1
Definition
of
a
Small
Business
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6­
1
6.1.1.2
Number
of
Small
Businesses
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6­
2
6.1.2
Estimation
of
Impacts
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6­
3
6.1.2.1
Cost­
to­
Sales
Ratios
for
Small
Businesses
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6­
5
6.2
Environmental
Equity/
Justice
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6­
7
iv
References
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.
R­
1
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
of
the
Original
IUR
and
IUR
Amendments
Reporting
.
.
.
.
.
.
.
.
.
C­
1
Appendix
D
Baseline
Costs
.
.
.
.
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.
D­
1
Appendix
E
Industry
Survey
Results
.
.
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.
E­
1
Appendix
F
Sensitivity
Analysis
.
.
.
.
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.
.
F­
1
v
LIST
OF
FIGURES
Number
Page
3­
1
Allocation
of
Incremental
IUR
Amendments
Reporting
Costs
.
.
.
.
.
.
.
.
3­
3
4­
1
Flow
of
Chemicals
Through
OPPT's
Screening
and
Risk
Management
Programs
.
.
.
.
.
.
.
.
.
.
.
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.
.
4­
5
vi
LIST
OF
TABLES
Number
Page
1­
1
North
American
Industrial
Classification
System
for
Industries
Likely
to
be
Subject
to
IUR
Reporting
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1­
9
2­
1
Components
of
Exposure
Assessments
and
Exposure­
Related
Data
Elements
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
2­
4
2­
2
Options
Considered
for
the
IUR
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
13
2­
3
Number
of
Reports
Expected
for
Each
Option
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
14
2­
4
Number
of
Full
and
Partial
Reports
Expected
for
Each
Option
by
Chemical
Type
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
2­
15
2­
5
Number
of
Chemicals
Expected
to
be
Reported
for
Each
Option
.
.
.
.
2­
17
3­
1
Loaded
Hourly
Wage
Rates
by
Labor
Category
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
8
3­
2
Estimated
First­
Year
Industry
Reporting
Burden
for
Sections
of
Revised
Form
U
(
hours
per
section
for
each
report)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
10
3­
3
Estimated
Number
of
Sites,
Reports,
and
Discrete
Chemicals
by
Chemical
Type
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
3­
11
3­
4
Incremental
Labor
Hours
for
Compliance
Determination
(
hours
per
site)
3­
13
3­
5
Incremental
Labor
Hours
Required
for
Rule
Familiarization
(
hours
per
site)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
3­
14
3­
6
Scaling
Factors
for
Unit
Cost
of
Preparation
and
Submission
of
Reports
in
Future
Reporting
Cycles
Under
the
IUR
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
3­
18
3­
7
Incremental
Labor
Hours
for
Report
Preparation
and
Submission
(
hours
per
report)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
19
3­
8
Incremental
Labor
Hours
for
Recordkeeping
(
hours
per
report)
.
.
.
.
.
3­
20
3­
9
Incremental
Costs
of
Compliance
Determination
(
2000$)
.
.
.
.
.
.
.
.
.
.
3­
21
3­
10
Incremental
Costs
of
Rule
Familiarization
Per
Site
(
2000$)
.
.
.
.
.
.
.
.
3­
21
3­
11
Incremental
Costs
of
Report
Preparation
and
Submission
Per
Report
(
2000$)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
.
.
.
.
.
.
3­
22
3­
12
Incremental
Costs
of
Recordkeeping
per
Report
(
2000$)
.
.
.
.
.
.
.
.
.
.
3­
22
3­
13
Summary
of
Incremental
Costs
of
IUR
Amendments
for
Organic
Chemicals
(
2000$)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
24
3­
14
Summary
of
Incremental
Costs
of
IUR
Amendments
for
Inorganic
Chemicals
(
2000$)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
25
3­
15
Total
Incremental
Costs
of
IUR
Amendments
(
million
2000$)
.
.
.
.
.
.
3­
26
vii
3­
16
Total
Incremental
Burden
Hours
of
IUR
Amendments
(
thousands
of
hours)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
.
.
.
.
.
3­
26
3­
17
Flow
of
Compliance
Costs
Over
the
Next
20
Years
(
million
2000$)
Under
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
27
3­
18
Incremental
Net
Present
Values
and
Annualized
Costs
of
Amendment
Options
Discounted
at
3
Percent
(
million
2000$)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
28
3­
19
Average
Incremental
Compliance
Costs
per
Site
for
Organic
Chemicals
(
2000$)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
29
3­
20
Average
Incremental
Compliance
Costs
per
Site
for
Inorganic
Chemicals
(
2000$)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
30
3­
21
Estimated
Incremental
Agency
Costs
for
the
IUR
Amendments
(
recurring
every
four
years)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
35
3­
22
Flow
of
Agency
Costs
Over
the
Next
20
Years
(
2000$)
under
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
36
3­
23
Measures
of
Incremental
Social
Costs
(
both
Industry
and
Agency
Costs)
Associated
with
Amendment
Options
(
million
2000$)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
37
3­
24
Measures
of
Incremental
Social
Costs
(
both
Industry
and
Agency
Costs)
Associated
with
Amendment
Options
(
million
2000$)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
37
4­
1
Options
Considered
for
the
IUR
Amendments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
4
5­
1
Benefits
and
Costs
of
Selected
Option
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
2
5­
2
Incremental
Benefits
and
Costs
of
Regulatory
Alternatives
(
Relative
to
Selected
Option
1)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
4
6­
1
Size
of
Manufacturing
Companies
Producing
Organic
Chemicals
Based
on
Annual
Sales
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
4
6­
2
Effect
of
IUR
Amendments
on
Small
Businesses
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
6
6­
3
Effect
of
IUR
Amendments
on
Small
Businesses
Assuming
Two
Sites
Per
Small
Business
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
8
viii
LIST
OF
BOXES
Number
Page
1­
1
Chemical­
Specific
Information
EPA
is
Authorized
to
Collect
Under
Section
8(
a)
of
the
Toxic
Substances
Control
Act
.
.
.
.
.
.
.
.
.
.
.
1­
3
1­
2
Industrial
Function
Categories
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1­
7
1­
3
Proposed
Commercial
and
Consumer
Product
Categories
.
.
.
.
.
.
.
.
.
.
1­
7
1­
4
Reporting
Processing
and
Use
Information
on
Chemicals
.
.
.
.
.
.
.
.
.
1­
12
2­
1
Progress
on
Screening
Chemicals
for
Risks
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
2
2­
2
Current
Existing
Chemicals
Program
Review
Process
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
5
2­
3
Reasons
for
Lack
of
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
6
2­
4
Risk­
Screening
Activities
Lack
Important
Data
on
Exposure
.
.
.
.
.
.
.
.
2­
8
3­
1
Comparison
of
Data
Elements
for
Completion
of
the
Original
and
Amended
Form
U
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
15
3­
2
Burden
of
Complying
with
CBI
Substantiation
Requirements
.
.
.
.
.
.
.
3­
17
4­
1
An
Example
of
How
the
Amended
IUR
Data
can
be
Useful
in
Supporting
EPA's
Day­
to­
Day
Operations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
4
4­
2
EPA
Tools
to
Evaluate
and
Manage
Chemical
Risk
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
6
ES­
1
EXECUTIVE
SUMMARY
The
U.
S.
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
seeking
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
rule
will
amend
the
IUR
data
collection
in
several
ways.
First,
it
will
require
the
collection
of
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
will
also
make
inorganic
chemicals
reportable,
raise
the
reporting
threshold,
add
a
second
threshold
for
reporting
chemical
processing
and
use
information,
add
requirements
that
will
reduce
inappropriate
or
unnecessary
confidential
business
information
(
CBI)
claims,
and
make
administrative
changes
that
would
enhance
the
effectiveness
of
the
data
collected
under
the
IUR.
EPA
will
use
the
information
collected
under
these
amendments
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
will
help
to
determine
potential
risks,
identify
opportunities
for
safer
substitutes,
target
specific
population
groups,
and
evaluate
the
need
for
risk
management.
The
data
will
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
data
to
be
produced
by
the
amended
IUR
are
critical
if
EPA
is
to
meet
its
Government
Performance
and
Results
Act
(
GPRA)
goal
to
screen
all
chemicals
in
commerce
by
2005.
This
report
analyzes
multiple
regulatory
options
for
amending
the
IUR
by
varying
the
reporting
thresholds,
exemptions,
and
reporting
cycle.
Please
note
that
the
results
of
the
economic
analysis
here
differ
from
earlier
drafts.
First,
the
IUR
amendments
were
revised
substantially
during
the
interagency
review
process
prior
to
proposal.
The
economic
results
reflect
those
changes
in
content.
Moreover,
EPA
has
carefully
considered
the
comments
on
the
economic
analysis
rendered
in
the
public
comment
period
for
the
proposed
rule
and
has
accordingly
revised
the
rule,
as
well
as
the
economic
analysis
methods
and
assumptions.
In
addition,
the
passage
of
time
in
the
rulemaking
process
has
allowed
EPA
to
update
the
data
used
to
perform
the
analysis
ES­
2
and
the
base
year
for
which
costs
are
reported
(
Year
2000
dollars).
The
selected
IUR
amendments
will
collect
basic
information
on
roughly
8,900
chemicals
out
of
the
more
than
75,000
chemicals
on
the
TSCA
Inventory.
Approximately
1,000
chemical
manufacturers
or
importers
will
be
required
to
report.
These
companies
are
expected
to
submit
about
26,800
reports
covering
approximately
3,000
sites.
In
the
first
year
of
reporting,
approximately
36
percent
of
the
reports
(
covering
45
percent
of
the
chemicals)
are
expected
to
be
full
reports
(
i.
e.,
containing
exposure­
based
use
information),
while
the
remaining
64
percent
will
be
partial
reports.
Most
of
these
reports
must
already
be
submitted
under
the
existing
IUR
requirements,
and
companies
will
simply
be
providing
additional
information.
However,
the
IUR
amendments
will
also
adjust
the
universe
of
reportable
chemicals.
Approximately
1,100
inorganic
chemicals
will
be
reportable
to
the
IUR
for
the
first
time,
and
about
1,200
originally
reportable
chemicals
will
no
longer
be
reported
as
a
result
of
the
increase
in
the
reporting
threshold.
EPA
estimates
the
incremental
cost
of
the
amendments
to
be
between
$
74
million
and
$
90
million
for
each
reporting
cycle
(
every
four
years).
These
startup
and
quadrennial
costs
are
equivalent
to
an
annual
cost
of
between
$
19.5
million
and
$
23.3
million
for
the
first
20
years
of
the
rule.
EPA
has
taken
a
number
of
steps
to
reduce
the
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
in
the
first
reporting
cycle;
establishing
a
partial
exemption
for
petroleum
process
stream
chemicals
and
a
full
exemption
for
certain
forms
of
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
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
are
not
expected
to
be
significant.
Because
the
IUR
amendments
are
an
information
collection
exercise,
no
negative
environmental
equity
issues
are
associated
with
them.
Instead,
the
information
that
will
become
available
will
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
to
be
gathered
under
the
IUR
amendments
will
help
EPA
to
make
decisions
that
will
benefit
potentially
at­
risk
communities,
some
of
which
may
be
disadvantaged.
Taking
together
the
factors
analyzed
in
this
report,
EPA
believes
that
amending
ES­
3
the
IUR
will
generate
benefits
to
society
of
improved
public
and
private
decisions
related
to
chemical
risks
that
more
than
justify
the
costs
of
data
collection
and
administration.
1Only
non­
CBI
info
will
be
publicly
available.

S­
4
SUMMARY
S.
1
Introduction
Based
on
its
authority
under
Section
8(
a)
of
the
Toxic
Substances
Control
Act
(
TSCA),
the
U.
S.
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
amending
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
will
enhance
the
effectiveness
of
the
existing
regulation.
The
additional
data
will
assist
EPA
in
evaluating
potential
exposures
and
risks
resulting
from
industrial
chemical
operations
and
consumer
uses
of
chemical
substances.
EPA
will
use
the
information
collected
under
this
rule
to
set
risk
assessment
priorities
among
chemical
substances
of
potential
concern,
to
more
efficiently
manage
these
risks,
and
to
support
EPA's
pollution
prevention
and
environmental
protection
activities.
The
information
will
also
be
valuable
to
other
public­
and
private­
sector
organizations
for
similar
purposes.
1
The
data
to
be
produced
by
the
amended
IUR
are
critical
if
EPA
is
to
meet
its
Government
Performance
and
Results
Act
(
GPRA)
goal
to
screen
all
chemicals
in
comments
by
2005.
This
analysis
reviews
the
costs,
benefits,
and
impacts
of
the
amendments
to
the
TSCA
IUR
reporting
requirements.

S.
2
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
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
2It
should
be
noted
that
the
numbers
of
chemicals,
reports,
and
facilities
presented
above
do
not
include
statistics
for
chemicals
with
a
production
volume
lower
than
10,000
pounds
that
reported
voluntarily.

S­
5
information
into
the
initial
TSCA
Inventory.
The
TSCA
Inventory
originally
contained
approximately
60,000
chemicals.
As
new
chemicals
enter
into
commerce
in
the
United
States,
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
IUR
(
51
FR
21438)
(
Federal
Register,
1986a).
The
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.
The
IUR
includes
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
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.
About
26,000
required
submissions
from
about
2,700
sites,
roughly
8,900
chemicals,
were
reported
to
EPA
in
the
1998
reporting
cycle.
2
EPA
enters
the
information
into
the
Chemical
Update
System
(
CUS),
a
confidential
database.

S.
3
Need
to
Amend
the
IUR
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
information
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
poor
in
S­
6
coverage
and
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,
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
scope
and
detail
of
use
information,
and
generally
provide
information
only
on
larger­
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,
has
not
been
comprehensively
or
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
an
inconsistent
reporting
period
(
i.
e.,
company
fiscal
year)
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.

S.
4
Options
Analyzed
for
the
IUR
Amendments
This
report
analyzes
eight
regulatory
options
for
amending
the
IUR
reporting
requirements.
The
options
were
created
by
varying
the
threshold
for
processing
and
use
data,
the
exemptions
based
on
the
type
of
chemical,
and
the
reporting
cycle.
Table
S­
1
summarizes
these
options.
S­
7
As
a
result
of
the
various
analyses
performed
and
feedback
received
throughout
the
regulatory
development
process,
EPA
has
chosen
to
amend
the
IUR
based
on
Option
1.
In
particular,
the
selected
option
will
make
the
following
changes
to
the
IUR:


Increase
the
reporting
threshold:
The
reporting
threshold
will
be
increased
from
10,000
to
25,000
pounds.


Create
a
second
reporting
threshold:
Chemicals
produced
or
imported
at
volumes
less
than
300,000
pounds
will
complete
a
partial
reporting
form,
requiring
only
facility
and
manufacturing
information
and
CBI
reassertion.
Chemicals
with
production
volumes
greater
than
300,000
pounds
will
complete
the
full
form,
requiring
reporting
of
facility
and
manufacturing
information
as
well
as
processing
and
use
data.
S­
8
Table
S­
1.
Regulatory
Options
Summary
Option
Thresholds
Reporting
Cycles
Number
of
Chemical
s
Numbe
r
of
Sites
Number
of
Reports
Percentage
of
Reportsa
Annualized
Cost
(
million
2000$)

Facility
and
Manufacturin
g
Information
Processing
and
Use
Informatio
n
Facility
and
Manufacturin
g
Information
Processing
and
Use
Informatio
n
Partial
Full
Low
High
Threshold
Options
1
(
Selected)
25,000
lbs
300,000
lbs
4
yrs.
4
yrs.
8,865
3,026
26,797
63.6/
54.0%
36.4/
46.0%
$
19.5
$
23.3
2
25,000
lbs
100,000
lbs
4
yrs.
4
yrs.
8,865
3,026
26,797
51.7/
38.9%
48.3/
61.1%
$
24.4
$
27.7
3
25,000
lbs
500,000
lbs
4
yrs.
4
yrs.
8,865
3,026
26,797
68.1/
59.9%
31.9/
40.1%
$
17.6
$
20.3
4
25,000
lbs
1,000,000
lbs
4
yrs.
4
yrs.
8,865
3,026
76,797
73.7/
67.0%
26.3/
33.0%
$
15.3
$
17.8
5b
25,000
lbs
500,000
lbs/

100,000
lbs
4
yrs.
4
yrs.
8,865
3,026
26,797
68.1/
38.9%
31.9/
61.1%
$
22.9
$
26.0
Reporting
Exemption
Optionc
6
25,000
lbs
100,000
lbs
4
yrs.
4
yrs.
7,748
2,482
22,260
41.8/
41.8%
58.2/
58.2%
$
19.8
$
22.2
Reporting
Cycle
Options
7
25,000
lbs
100,000
lbs
2
yrs.
2
yrs.
8,865
3,026
26,797
51.7/
38.9%
48.3/
61.1%
$
47.6
$
53.9
8
25,000
lbs
100,000
lbs
one­
time
one­
time
8,865
3,026
26,797
51.7/
38.9%
48.3/
61.1%
$
6.0
$
6.8
a
These
percentages
are
reported
as
first
reporting
year/
future
reporting
years.

b
This
option
has
a
threshold
of
500,000
lbs
for
processing
and
use
information
in
the
first
reporting
year
and
a
threshold
of
100,000
lbs
for
reporting
this
information
in
all
future
reporting
years.

c
Inorganic
chemicals
are
fully
exempt
from
reporting.
3"
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
9

Remove
the
inorganic
exemption:
Inorganic
chemicals
will
no
longer
be
exempt
from
reporting.
Inorganic
chemicals
will
not
be
required
to
report
exposure
and
use
data
in
the
first
reporting
year,
but
in
subsequent
years
they
will
be
subject
to
the
same
threshold
for
processing
and
use
data
as
organic
chemicals.


Add
exposure­
related
data:
Two
types
of
exposure­
related
data
will
be
added:

B
All
reportable
chemicals
will
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.

B
Larger­
volume
chemicals
will
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,
five­
digit
North
American
Industry
Classification
System
(
NAICS)
codes,
industrial
function
categories,
the
percentage
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,
maximum
concentration
(
in
ranges)
of
the
chemical
in
the
commercial/
consumer
end
use,
and
an
indication
of
whether
the
chemical
is
intended
for
children's
use.


Create
reporting
exemptions:
Certain
petroleum
streams
will
be
exempted
from
providing
processing
and
use
data
(
industrial
processing
and
use
information,
and
commercial
and
consumer
use
information).
Inorganic
chemicals
are
also
exempt
from
reporting
this
information
in
the
first
reporting
year;
although
in
future
years,
they
are
subject
to
the
same
threshold
for
full
reports
as
organic
chemicals.
In
addition,
some
forms
of
natural
gas3
will
be
fully
exempted
from
reporting.


Change
the
CBI
requirements:
Companies
will
be
required
to
provide
upfront
substantiation
before
claiming
facility
identity
as
CBI
and
to
reassert
previous
CBI
claims.


Make
certain
administrative
changes:
The
reporting
cycle
will
be
changed
from
the
current
fiscal
year
to
the
calendar
year.
As
part
of
the
facility
identification,
companies
will
be
required
to
report
the
county
name
of
the
plant
site,
as
well
as
the
Dun
&
Bradstreet
number,
the
postal
mailing
4As
used
here,
the
number
of
"
reports"
refers
to
the
number
of
individual
chemical­
plant
combinations
reported
nationwide.
Companies
generally
submit
one
Form
U
per
site,
addressing
multiple
chemicals,
and
therefore
multiple
chemical
"
reports"
per
site.

5The
information
requirements
imposed
by
the
amendments
can,
in
principle,
lead
to
additional
welfare
losses
from
associated
reductions
in
output
in
affected
markets.
Those
welfare
costs
are
likely
to
be
quite
small
relative
to
the
burden
estimates
and
are
not
estimated
separately
in
this
report.

S­
10
address,
and
e­
mail
address
of
the
parent
company.
The
records
retention
period
will
be
lengthened
from
four
to
five
years.

S.
5
Analysis
of
Options
Table
S­
1
also
summarizes
the
results
of
the
analysis
for
each
of
the
eight
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
selected
option,
the
amended
IUR
will
collect
basic
information
on
about
8,900
chemicals
out
of
the
more
than
75,000
chemicals
on
the
TSCA
Inventory.
This
information
will
be
collected
from
about
26,800
reports
covering
approximately
3,000
sites.
4
In
the
first
reporting
year,
approximately
36
percent
of
the
reports
(
covering
45
percent
of
the
chemicals)
are
expected
to
be
full
reports
(
i.
e.,
containing
processing
and
use
information),
while
the
remainder
will
be
partial
reports.
The
proportion
of
full
reports
rises
in
future
reporting
periods
as
inorganic
chemicals
become
fully
reportable
under
the
amendments.
Most
of
the
partial
reports
must
already
be
submitted
under
the
existing
IUR
requirements
and
companies
would
simply
be
providing
additional
information.
There
are
more
than
1,100
inorganic
chemicals
that
would
be
reportable
to
the
IUR
for
the
first
time,
and
about
1,200
originally
reportable
chemicals
that
would
no
longer
be
reported
as
a
result
of
raising
the
reporting
threshold.
Costs
of
the
IUR
amendments
will
be
borne
by
the
chemical
industry
and
the
taxpayers
who
fund
EPA.
5
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.
To
determine
burden
estimates
for
report
preparation
and
submission,
EPA
surveyed
industry
respondents.
There
are
two
important
factors
to
note
in
interpreting
the
burden
estimates
obtained
through
this
survey.
First,
the
IUR
amendments
only
require
that
industry
report
"
reasonably
ascertainable"
information
for
most
data
elements
and
"
readily
available"
information
for
downstream
processing
and
use
information.
However,
these
standards
for
reporting
information
were
developed
after
the
survey
was
executed.
Thus,
survey
respondents
were
reporting
burden
estimates
assuming
a
much
higher
standard
of
information.
Second,
the
UEIP
program,
which
asked
respondents
to
report
chemical
information
very
similar
to
that
required
by
the
S­
11
IUR,
also
asked
respondents
to
report
the
time
spent
preparing
the
UEIP
form
for
submission
(
EPA,
1997b).
Companies
reported
a
median
burden
of
8
hours
per
chemical
report,
with
a
mean
of
12
hours
per
chemical
report.
Both
of
these
factors
indicate
that
the
burden
estimates
derived
from
the
survey
may
overestimate
the
actual
burden.
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.
However,
in
future
reporting
periods,
respondents
must
begin
to
reassert
CBI
claimed
in
previous
reporting
periods.
This
requirement
partially
offsets
the
reduction
in
burden
over
time.
In
addition,
the
burden
on
inorganic
chemical
producers
will
be
higher
in
future
years
than
in
the
first
reporting
year
due
to
the
removal
of
the
inorganic
partial
exemption
even
though
the
cost
per
partial
report
will
have
fallen.
Taken
together,
the
factors
that
raise
and
lower
future
reporting
costs
essentially
offset
each
other;
thus,
costs
in
future
reporting
years
are
similar
to
first­
year
costs.
More
detail
on
cost
estimates
is
given
below.
EPA
assumed
that
no
capital
costs
would
be
associated
with
this
rule.
EPA
estimated
the
total
industry
cost
of
the
IUR
amendments
by
multiplying
these
estimated
costs
by
the
estimated
number
of
sites
and
submissions
that
will
be
affected
by
the
IUR
amendments.
A
separate
estimate
of
EPA
costs
to
administer
the
rule
was
added
to
the
industry
costs
to
derive
the
total
cost
to
society.
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
are
as
follows:


Chemicals
produced
at
a
volume
between
10,000
pounds
and
25,000
pounds
will
now
be
exempt
from
reporting.
This
results
in
avoided
reporting
costs
(
i.
e.,
savings)
of
approximately
$
589
to
$
936
per
report
for
these
chemicals
for
sites
that
must
continue
to
report
other
chemicals
under
the
IUR
amendments.
The
estimated
reduction
in
cost
for
a
site
that
no
longer
must
report
(
because
it
does
not
manufacture
or
import
any
reportable
chemicals
in
volumes
greater
than
or
equal
to
25,000
pounds)
is
between
$
6,213
and
$
9,843.


For
sites
manufacturing
or
importing
organic
chemicals
that
must
report
under
the
amendments,
the
estimated
incremental
cost
of
compliance
determination
and
rule
familiarization
(
costs
incurred
at
the
site
level)
is
$
1,629
to
$
1,952
in
the
first
reporting
year
and
$
0
in
subsequent
years.
Sites
manufacturing
or
importing
inorganic
chemicals
are
estimated
to
have
an
incremental
cost
of
compliance
determination
and
rule
familiarization
of
$
2,018
to
$
2,539
in
the
first
reporting
year
and
$
389
to
$
587
in
subsequent
years.
S­
12

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
processing
and
use
information.
The
incremental
cost
for
preparation
and
submission
of
a
partial
report
and
recordkeeping
for
that
report
is
estimated
to
range
from
$
578
to
$
941
in
both
the
first
reporting
year
and
future
years
for
organic
chemicals,
while
the
incremental
cost
for
inorganic
chemicals
is
estimated
at
about
$
1,160
to
$
1,870
in
both
the
first
reporting
year
and
future
years.
Based
on
the
CUS
database,
EPA
expects
that
57
percent
of
reports
filed
on
organic
chemicals
will
be
partial
reports.
For
inorganic
chemicals,
EPA
expects
100
percent
to
be
partial
reports
in
the
first
reporting
year,
because
inorganic
chemicals
are
exempt
from
full
reporting
in
the
first
year,
but
only
43
percent
in
future
reporting
periods.


Chemicals
produced
in
volumes
over
300,000
pounds
that
do
not
qualify
for
one
of
the
partial
exemptions
must
file
a
full
report.
The
incremental
cost
for
preparation
and
submission
of
a
full
report
and
recordkeeping
for
that
report
is
estimated
to
range
from
$
6,009
to
$
6,803
for
organic
chemicals
and
from
$
6,598
to
$
7,731
for
inorganic
chemicals
in
the
first
reporting
year.
In
future
reporting
years,
the
incremental
cost
is
estimated
to
be
$
5,349
to
$
6,085
for
organic
chemicals
and
$
5,938
to
$
7,021
for
inorganic
chemicals.
Inorganic
chemicals
generally
have
a
higher
incremental
cost
because
they
have
heretofore
been
exempt
from
reporting.
An
estimate
of
the
average
cost
per
site
can
be
derived
based
on
the
estimated
number
of
full
and
partial
reports
per
site.
Organic
chemical
manufacturers
are
expected
to
file
an
average
of
9.0
reports
per
site,
while
inorganic
chemical
manufacturers
are
expected
to
file
an
average
of
8.3
reports
per
site.
Combining
the
costs
incurred
on
a
per­
site
level
with
the
costs
per
report,
the
number
of
reports
per
site,
and
the
percentage
of
reports
expected
to
be
full
and
partial
reports,
EPA
estimates
the
incremental
cost
per
site
for
an
organic
chemical
manufacturer
to
be
between
$
27,609
and
$
32,563
in
the
first
reporting
year,
and
between
$
23,343
and
$
27,719
in
future
reporting
years.
A
similar
calculation
for
inorganic
chemical
manufacturers
yields
an
estimated
incremental
cost
per
site
of
$
11,749
to
$
18,194
in
the
first
reporting
year
and
$
32,638
to
$
40,502
in
subsequent
reporting
years.
Projected
incremental
costs
for
EPA
operations
are
relatively
small
and
are
estimated
at
about
$
576,000
in
the
first
year
of
reporting,
and
about
$
270,000
for
each
subsequent
reporting
period.
These
Agency
costs
annualize
to
about
$
90,500
per
year.
EPA
estimates
the
incremental
cost
of
the
amendments
to
be
between
$
74.4
million
and
$
89.5
million
for
the
first
reporting
cycle.
Costs
for
subsequent
reporting
cycles
(
every
four
years)
are
estimated
at
$
74.8
million
to
$
89.3
million.
The
startup
and
quadrennial
costs
are
equivalent
to
an
annual
cost
of
$
19.5
million
to
$
23.3
million
per
year
over
the
first
20
years
of
the
rule.
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
S­
13

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
3,100
and
1,000,
respectively);


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
7,800
in
the
first
reporting
year
and
9,800
in
future
years,
when
compared
with
requiring
this
information
for
all
reports);
and

establishing
a
partial
exemption
for
petroleum
process
streams
and
inorganic
chemicals
(
reducing
the
number
of
full
reports
by
over
4,400
for
petroleum
process
streams
[
relative
to
the
case
without
the
partial
exemptions],
and
by
about
2,600
for
inorganic
chemicals
in
the
first
year
of
reporting).
The
result
is
that
full
reports
are
expected
on
only
about
4,000
chemicals
and
partial
reports
on
about
4,900
chemicals
(
out
of
the
more
than
75,000
chemicals
on
the
TSCA
Inventory).
EPA
also
reduced
the
specificity
of
the
information
required
by

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
industry
on
complying
with
the
amendments.

S.
6
Benefits
The
data
collected
through
this
rule
will
assist
EPA
in
evaluating
potential
exposures
and
risks
resulting
from
industrial
chemical
operations
and
commercial
and
consumer
uses
of
chemical
substances.
EPA
will
use
the
information
collected
under
this
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
(
non­
CBI
portions)
will
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.
S­
14
The
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
focus
existing
chemical
resources.
The
addition
of
use
and
exposure­
related
information
will
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
reduce
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
will
increase
the
effectiveness
of
the
data
collected.
One
example
is
the
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
will
make
the
data
set
internally
consistent.
It
will
also
make
the
reporting
period
for
the
IUR
data
consistent
with
other
EPA
databases,
most
of
which
are
on
a
calendar
year
basis.
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
have
not
been
claimed
as
confidential,
the
results
will
be
incomplete
and
of
limited
usefulness.
Several
of
the
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
are
presented
as
a
range
rather
than
a
point
estimate,
the
IUR
amendments
add
a
range
reporting
element.
Data
that
have
been
appropriately
claimed
as
CBI
would
continue
to
be
treated
as
confidential.
S­
15
Table
S­
2.
Summary
of
IUR
Amendments
Action
Result
Benefit
or
Rationale
Raise
Threshold
Raises
the
production
volumereporting
threshold
from
10,000
pounds
a
year
to
25,000
pounds
a
year.
Exempts
75
sites
and
roughly
3,100
reports
for
1,200
chemicals,
at
a
savings
of
$
1.8
to
$
2.9
million
per
reporting
cycle.
Lowers
companies'
reporting
burden.

Remove
Inorganic
Exemption
Removes
the
exemption
for
inorganic
chemicals
in
the
original
IUR.
Adds
approximately
4,500
reports
for
over
1,100
chemicals,
including
about
2,600
full
reports
in
future
reporting
cycles
at
a
cost
of
$
6.4B$
9.9
million
in
the
first
year
of
reporting,
$
17.8B$
22.0
million
in
future
reporting
years,
and
an
annualized
cost
of
$
3.9B$
5.0
million.
Allows
EPA
to
make
informed
risk­
screening
decisions
about
inorganic
chemicals.

Natural
Gas
Exemption
Eliminates
all
reporting
for
natural
gas
substances
with
six
specific
Chemical
Abstracts
Service
(
CAS)
numbers.
Exempts
approximately
99
sites
and
roughly
1,000
reports
from
all
reporting,
saving
$
0.6
to
$
1.0
million
per
reporting
cycle.
Reduces
burden
by
eliminating
a
large
number
of
reports
on
these
specific
chemicals
for
which
EPA
feels
available
data
are
adequate.
S­
16
Table
S­
2.
Summary
of
IUR
Amendments
(
continued)

Action
Result
Benefit
or
Rationale
Processing
and
Use
Information
Requires
additional
processing
and
use
information
for
chemicals
with
production
volumes
greater
than
300,000
pounds
that
do
not
qualify
for
a
partial
exemption:

$
process
or
use
code;

$
five­
digit
NAICS
code
for
processing;

$
industrial
function
category;

$
percentage
of
production
volume
in
function
category;

$
number
of
processing
sites
(
in
ranges);

$
number
of
potentially
exposed
workers
(
in
ranges);

$
end­
use
category;

$
percentage
production
volume
in
end­
use
category;

$
indication
of
children's
use
$
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
on
organic
chemicals
is
collected
from
approximately
9,800
reports
on
roughly
4,000
chemicals,
at
an
estimated
cost
of
approximately
$
53.0B$
57.2
million
in
the
first
year
of
reporting,
and
$
42.4B$
45.8
million
in
future
reporting
cycles.
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.

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
for
industry
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.
S­
17
Table
S­
2.
Summary
of
IUR
Amendments
(
continued)

Action
Result
Benefit
or
Rationale
Confidential
Business
Information
Requires
separate
confidentiality
claims
for
production
volume
ranges,
in
addition
to
exact
production
volume.

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.

Approximately
20
percent
of
submissions
received
during
the
1994
reporting
period
claimed
plant
site
information
as
CBI,
suggesting
that
a
comparable
percentage
would
provide
up­
front
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
percentage
may
have
to
reassert
claims
under
the
IUR
amendments.
Reassertion
is
not
required
in
the
first
reporting
period,
but
it
increases
costs
by
approximately
$
6.1B$
7.3
million
in
future
reporting
years
for
organic
chemicals.
Produces
greater
flexibility
in
the
use
of
the
data.

Production
volume
ranges
are
less
likely
to
be
claimed
to
be
confidential
than
point
estimates.
Production
volume
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.

CBI
reassertion
ensures
full
access
to
data
that
companies
no
longer
deem
to
be
confidential.

These
changes
will
allow
EPA
to
provide
more
information
to
the
public
without
breaching
the
confidentiality
of
legitimate
CBI
data.
Finally,
collecting
the
additional
IUR
information
will
help
further
develop
and
measure
the
results
of
private­
sector
stewardship
programs.
The
data
will
help
to
identify
potential
risks
and
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
will
be
used
to
identify
and
manage
human
health
and
environmental
risks.
The
data
will
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.
S­
18
As
presented
in
Table
S­
1,
EPA
considered
a
variety
of
options
in
developing
its
selected
approach.
These
options
can
be
separated
into
three
categories
C
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.
Decisions
as
to
the
specific
information
collected
were
based
on
EPA's
experience
and
information
needs
and
are
described
in
the
technical
support
documents.

S.
7
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
IUR
amendments.
For
the
purpose
of
the
small
entity
analysis,
all
firms
with
$
40
million
or
less
in
annual
sales
were
assumed
to
be
small
businesses.
The
rule
is
estimated
to
affect
between
202
and
335
small
businesses.
EPA
compared
the
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
0.19
percent
or
less.
In
future
reporting
years,
costs
are
estimated
to
be
0.19
to
0.23
percent
of
sales
for
inorganic
chemical
manufacturers
and
slightly
less
for
organic
chemical
manufacturers.
Because
regulatory
costs
represent
a
small
fraction
of
a
typical
firm's
sales,
the
financial
impacts
of
the
regulation
are
likely
to
be
minimal.

S.
8
Environmental
Justice
Because
the
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
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
to
be
gathered
under
the
IUR
amendments
will
help
EPA
make
decisions
that
will
benefit
potentially
at
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
S­
19
(
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.
9
Differences
in
Economic
Analysis
Results
between
the
Final
and
Proposed
Rule
The
results
of
the
economic
analysis
for
the
final
rule
are
materially
different
than
the
results
of
the
economic
analysis
for
the
proposed
rule
(
EPA,
1999a).
Of
particular
note
is
the
difference
in
the
estimates
of
the
total
cost
of
the
rule.
The
costs
of
the
selected
option
reported
here
are
approximately
$
74
to
$
89
million
every
four
years.
The
annualized
cost
over
the
first
20
years
of
the
rule
is
$
19
to
$
23
million
per
year.
By
comparison,
the
cost
of
the
rule
at
proposal
was
estimated
to
be
$
36
to
$
51
million
in
the
first
year,
$
27
to
$
41
million
in
future
reporting
years,
and
an
annualized
total
cost
of
the
proposed
rule
was
$
10
to
$
14
million.
Several
reasons
contribute
to
the
difference
in
cost
estimates.


The
selected
option
in
this
report
differs
from
the
proposed
rule.
Notable
differences
between
the
proposed
and
final
rule
include
the
fact
that
the
partial
exemption
for
inorganic
chemicals
now
applies
only
in
the
first
year.
Thus
the
cost
of
the
rule
in
future
years
is
higher
under
the
final
rule
than
under
the
proposed
rule.


The
costing
methodology
was
modified.
The
methodology
to
estimate
the
costs
of
the
rule
was
modified
to
account
for
feedback
provided
to
EPA
in
the
public
comment
period.
Notable
among
these
changes
was
an
increase
in
the
burden
estimate
for
CBI
reassertion
cost.
Also,
after
careful
reassessment
of
the
connection
between
the
costing
methodology
used
in
the
EA
for
the
proposed
rule
and
the
industry
survey
data
from
which
the
burden
estimates
are
made,
the
methodology
was
modified
to
better
reflect
the
data
provided
in
industry
survey
responses.


The
final
rule
analysis
employs
data
from
the
1998
CUS
database.
Compared
to
the
previous
data
from
1994
and
before,
the
new
data
provide
a
more
accurate
assessment
of
current
IUR
reporting
volume,
the
distribution
of
chemicals
reported,
and
the
distribution
of
reporting
sites.
Using
the
1998
data
increased
the
number
of
reports
used
in
the
analysis
by
about
1,000
relative
to
the
data
used
at
proposal,
which
led
to
an
increase
in
the
cost
of
the
rule.


Costs
are
now
expressed
in
year
2000
dollars.
The
costs
of
the
rule
at
proposal
stage
were
expressed
in
1997
dollars.
Costs
are
now
expressed
in
2000
dollars
(
first
quarter).
This
base
year
adjustment
inflates
costs
about
13
percent.

These
modifications
provide
a
more
accurate
assessment
of
the
social
costs
of
the
rule.
While
the
estimated
cost
of
the
rule
is
higher,
EPA
believes
that
the
rule's
S­
20
benefits
to
society,
derived
from
improvements
in
risk
screening
and
risk
management,
justify
the
costs
borne
to
obtain
the
information
and
administer
the
program.
Benefitcost
comparisons
are
addressed
in
Section
5
of
the
report.
6According
to
EO
12866,
a
significant
regulatory
action
is
any
regulatory
action
that
is
likely
to
(
1)
have
an
annual
effect
on
the
economy
of
$
100
million
or
more
or
adversely
affect
in
a
material
way
the
economy,
a
sector
of
the
economy,
productivity,
competition,
jobs,
the
environment,
public
health
or
safety,
or
state,
local,
or
tribal
governments
or
communities;
(
2)
create
a
serious
inconsistency
or
otherwise
interfere
with
an
action
taken
or
planned
by
another
agency;
(
3)
materially
alter
the
budgetary
impact
of
entitlements,
grants,
user
fees,
or
loan
programs
or
the
rights
and
obligations
of
recipients
thereof;
or
(
4)
raise
novel
legal
or
policy
issues
arising
out
of
legal
mandates,
the
President's
priorities,
or
the
principles
set
forth
in
EO
12866.

1­
1
SECTION
1
INTRODUCTION
The
U.
S.
Environmental
Protection
Agency's
(
EPA's)
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
conducts
economic
analyses
of
planned
regulatory
actions
to
inform
Agency
decisionmakers
about
the
effects
of
the
regulatory
action
on
society
at
large
and
on
specific
subpopulations.
An
economic
analysis
is
typically
composed
of
both
a
benefit­
cost
analysis
and
impact
analyses.
The
former
refers
to
analyses
of
the
overall
benefits
and
costs
of
an
action
and
its
alternatives,
while
the
latter
analyses
are
often
intended
to
supplement
a
traditional
benefit­
cost
analysis
and
usually
involve
analyzing
the
distribution
of
benefits
and
costs
across
different
segments
of
society.
In
addition
to
informing
decisionmakers
within
the
Agency,
economic
analyses
meet
numerous
statutory
and
administrative
requirements
imposed
by
Congress
and
the
White
House.
The
White
House,
through
Executive
Order
(
EO)
12866,
requires
Executive
Branch
agencies
to
assess
the
benefits
and
costs
of
all
rules
it
deems
to
be
"
significant"
6
and
to
submit
these
analyses
to
the
Office
of
Management
and
Budget
(
OMB)
for
review.
In
addition
to
benefit­
cost
analysis,
impact
analyses
are
required
in
certain
circumstances
by
both
EOs
and
statutes.
Of
particular
relevance
to
this
report,
the
Regulatory
Flexibility
Act
(
RFA)
requires
agencies
to
consider
the
effects
of
their
regulations
on
small
entities
(
businesses,
governments,
and
nonprofit
organizations),
and
EO
12898
requires
agencies
to
consider
the
effects
of
their
actions
on
minority
and
low­
income
populations.
This
report
assesses
the
benefits
and
costs
expected
to
result
from
implementing
amendments
to
the
Inventory
Update
Rule
(
IUR).
The
existing
IUR,
which
has
been
in
place
since
1986,
requires
chemical
manufacturers
and
importers
to
collect,
maintain,
and
submit
location
and
production
volume
information
for
chemicals
with
annual
production
volumes
of
10,000
pounds
or
higher.
The
IUR
amendments
will
change
this
reporting
threshold
to
25,000
pounds
and
will
augment
the
required
site
and
production
information.
In
addition,
the
amendments
will
require
sites
with
production
volumes
of
300,000
pounds
or
higher
of
a
reportable
chemical
to
collect,
maintain,
and
submit
additional
information
to
EPA
regarding
chemical
processing
and
use
.
Furthermore,
the
amendments
change
administrative
requirements
and
1­
2
exemption
status
for
various
chemical
groups.
Moreover,
the
amendments
will
include
new
provisions
for
confidential
business
information
(
CBI)
data
claims
that
(
1)
require
up­
front
substantiation
of
CBI
claims
for
plant
site
identification,
(
2)
allow
production
volume
to
be
specified
in
(
non­
CBI)
ranges
while
maintaining
CBI
status
for
specific
production
volumes,
and
(
3)
require
reassertion
of
CBI
claims
from
previous
reporting
cycles.
The
data
elements
required
by
the
amendments
will
provide
information
to
populate
an
exposure
and
use
information
database,
which
will
provide
the
information
necessary
for
EPA's
everyday
decisionmaking
and
will
enable
EPA
to
develop
chemical
screening
priorities
and
streamline
regulatory
efforts.
This
will
benefit
society
by
enabling
public
and
private
parties
to
make
more
informed
risk
assessment
and
management
decisions.
The
collected
information
will
improve
understanding
of
potential
exposures
resulting
from
industrial
chemical
use,
allow
more
accurate
tracking
of
chemical
exposure
and
use,
and
permit
more
effective
targeting
of
chemicals
that
pose
the
greatest
exposure
or
risk.
The
costs
associated
with
these
amendments
include
the
costs
for
private
entities,
generally
firms
in
the
targeted
industries,
to
collect,
maintain,
and
submit
the
required
information
and
the
cost
to
taxpayers
for
financing
government
expenditures
attributable
to
data
management.
This
economic
analysis
assesses
and
compares
the
benefits
and
costs
of
the
planned
amendments
to
the
IUR.
This
report
also
analyzes
alternatives
to
the
selected
regulatory
approach.
The
following
analyses
are
provided
in
this
report:


an
overview
of
changes
in
the
reporting
requirements,


a
characterization
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
benefits
and
the
costs
of
the
IUR
amendments.
This
report
also
discusses
the
impacts
of
the
IUR
amendments
on
small
businesses
pursuant
to
the
RFA
and
the
impacts
on
minority
and
low­
income
populations
in
conformance
with
EO
12898,
and
it
addresses
impacts
emphasized
by
other
relevant
congressional
mandates
(
e.
g.,
Paperwork
Reduction
Act).
The
remainder
of
this
section
provides
information
on
EPA's
statutory
authority
for
implementing
the
IUR
amendments,
a
discussion
of
the
regulatory
history
and
a
description
of
the
original
rule
requirements
and
the
planned
changes,
an
overview
of
the
regulated
community,
and
a
description
of
the
contents
of
this
report.

1.1
Statutory
Authority
Congress
has
granted
EPA
broad
authority
to
collect
information
on
chemical
substances,
including
information
that
will
help
EPA
and
others
assess
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
requiring
manufacturers
and
processors
of
chemicals
to
report
production
and
use
information
on
various
types
and
7Chemicals
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
Chemicals
Program
(
NCP).
The
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.

1­
3
Box
1­
1.
Chemical­
Specific
Information
EPA
is
Authorized
to
Collect
Under
Section
8(
a)
of
the
Toxic
Substances
Control
Act
(
not
a
comprehensive
list)

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.

7.
The
manner
or
method
of
disposal,
and
in
any
subsequent
report
on
such
substance
or
mixture,
any
change
in
the
manner
or
method.
classes
of
chemicals.
Examples
of
the
types
of
chemical­
specific
information
that
the
Agency
is
authorized
to
collect
is
provided
under
TSCA
§
8(
a)(
2).
Box
1­
1
presents
a
summary
of
this
information.

1.2
Description
of
the
IUR
Rule
This
section
describes
the
regulatory
history
of
the
TSCA
IUR,
the
original
requirements
of
the
rule,
and
the
planned
changes
to
the
rule
through
the
IUR
amendments.

1.2.1
Regulatory
History
The
TSCA
Chemical
Substances
Inventory
(
42
FR
64572)
(
Federal
Register,
1977)
was
created
just
after
TSCA's
passage
into
law.
The
Inventory
lists
all
TSCA
chemicals
in
commerce,
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.
The
Inventory
initially
included
chemicals
in
commerce
in
1977.
Chemicals
for
which
manufacturers
complete
EPA's
New
Chemicals7
process
and
file
a
Notice
of
Commencement
have
been
added
to
the
Inventory.
Currently,
the
Inventory
lists
over
75,000
chemicals.
Under
the
authority
of
TSCA
Section
8(
a),
EPA
promulgated
regulations
requiring
chemical
manufacturers
and
importers
to
submit
data
on
certain
chemical
substances
listed
in
the
TSCA
Inventory
(
51
FR
21447)
(
Federal
Register,
1986b)
that
1­
4
they
produce
in
volumes
over
10,000
pounds
per
site.
These
regulations
are
commonly
called
the
TSCA
IUR.
Data
are
collected
every
four
years
on
an
average
of
9,200
separate
chemicals.
This
collection
provides
a
more
up­
to­
date
picture
of
a
subset
of
the
TSCA
chemicals
in
commerce,
generating
data
that
are
used
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
and
publicly
available
data,
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
CBI
reporting
requirements
and
administrative
provisions
in
the
IUR
to
enhance
the
data's
usefulness.

1.2.2
Current
IUR
Requirements
The
existing
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,
Dun
&
Bradstreet
number,
and
plant
site
street
address.


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
at
the
site
or
is
imported.


Site­
limited
activity
entails
indicating
whether
the
chemical
substance
is
produced
and
used
at
the
same
site.
These
chemicals
do
not
undergo
packaging
and
shipping.


Production
volume
must
be
reported
for
the
chemical
manufactured
at
the
plant
site.


CBI
status
(
claimed/
not
claimed)
must
be
indicated
for
each
data
element
reported.
For
chemical
identification,
up­
front
substantiation
of
CBI
claims
is
required.


Certification
statement
requires
a
signature
certifying
that
complete
and
accurate
information
is
provided.
1.2.3
Changes
in
Reporting
Requirements
under
the
IUR
Amendments
1­
5
The
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
EPA.
This
section
defines
several
terms
that
correspond
to
data
needs
for
the
new
requirements.
1.2.3.1
Reporting
Thresholds,
Reporting
Cycles,
and
Exemptions
The
amendments
raise
the
reporting
threshold
from
10,000
to
25,000
pounds
and
add
a
second
reporting
threshold
of
300,000
pounds
for
processing
and
use
information.
This
means
that
sites
producing
or
importing
TSCA
chemicals
at
annual
volumes
of
25,000
pounds
up
to
300,000
pounds
are
required
to
report
only
site
and
manufacturing
information
(
Parts
I
and
II
of
Form
U)
and
to
complete
the
CBI
reassertion
section
(
Part
IV
of
Form
U).
Sites
producing
or
importing
TSCA
chemicals
at
annual
volumes
of
300,000
pounds
or
greater
are
required
to
report
site
and
manufacturing
data,
to
reassert
CBI,
and
to
report
processing
and
use
information
(
Part
III
of
Form
U).
The
amendments
retain
the
original
reporting
cycle
of
every
four
years
but
change
the
period
of
coverage
for
production
from
corporate
fiscal
year
to
calendar
year.
Additionally,
the
amendments
change
the
recordkeeping
period
from
four
years
to
five
years.
The
amendments
include
certain
changes
to
the
original
reporting
exemptions.
Under
the
amendments,
the
inorganic
chemical
exemption
is
eliminated
and
reporting
for
these
chemicals
is
phased­
in.
For
the
first
reporting
period,
inorganic
chemicals
are
subject
to
a
partial
exemption,
but
are
subject
to
full
reporting
requirements
in
all
future
reporting
periods.
A
partial
exemption
stipulates
that
only
site
and
manufacturing
information
(
Parts
I
and
II
of
Form
U),
but
not
processing
and
use
information
(
Part
III
of
Form
U),
must
be
reported.
A
partial
exemption
is
also
granted
for
petroleum
process
stream
chemicals.
Certain
natural
gas
substances
will
be
fully
exempt
from
reporting.
1.2.3.2
Information
Collected
The
IUR
amendments
add
new
data
elements
to
the
information
currently
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
changes
in
the
types
of
information
to
be
reported
follows:


Facility
Identification
Information
B
Company
and
plant
site
identification
would
include
more
detailed
information
to
determine
the
company
and
plant
site
identities.
The
most
notable
change
is
the
addition
of
the
county
name.

B
Up­
front
CBI
substantiation
for
plant
site
identification
is
also
being
added.
Under
the
existing
IUR,
up­
front
substantiation
is
only
required
for
chemical
identification.
8The
Standard
Industrial
Classification
(
SIC)
system
has
recently
been
replaced
with
the
NAICS.
NAICS
is
a
sixdigit
coding
system,
therefore
allowing
for
more
detailed
specification
than
the
four­
digit
SIC
system.

1­
6

Manufacturing
Information
B
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.
Submitters
must
also
report
all
physical
forms
of
the
chemical
and
the
percentage
of
production
volume
in
each
physical
form.

B
Production
volume
data
will
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
B
Industrial
processing
and
use
exposure­
related
data
would
be
reported
for
the
first
time.
These
data
include
process
or
use
codes,
North
American
Industrial
Classification
System
(
NAICS)
codes,
industrial
function
codes,
percentage
of
production
volume
attributable
to
each
processing
or
use
activity
reported,
number
of
sites,
and
number
of
workers
for
downstream
processing
and
uses
of
the
chemical.
8
Codes
representing
ranges
would
be
used
to
report
these
data,
and
only
"
readily
obtainable"
data
would
be
reported.
These
data
would
be
reported
for
up
to
ten
uses
most
applicable
to
each
chemical
(
by
volume).

B
Consumer
and
commercial
end­
use
exposure­
related
data
would
also
be
reported
for
the
first
time.
These
data
include
product
category
codes,
percentage
of
production
volume,
maximum
concentration
of
the
chemical
in
each
final
product,
and
an
indication
of
whether
the
chemical
is
intended
for
children's
use.
Codes
representing
ranges
would
be
used
to
report
these
data,
and
only
"
readily
obtainable"
data
would
be
reported.
These
data
would
be
reported
for
up
to
ten
uses
most
applicable
to
each
chemical
(
by
volume).


Reassertion
of
Past
CBI
Claims
B
Most
of
the
information
on
Form
U
can
be
claimed
confidential.
The
amendments
require
the
reassertion
of
any
CBI
claims
made
in
the
previous
IUR
reporting.
The
second
reporting
period
will
be
the
first
time
reassertion
is
required.
1­
7
1.2.3.3
Definitions
of
Reporting
Terms
Several
terms
are
defined
below
to
provide
some
general
background
for
the
new
requirements.


Submitters
will
now
report
the
total
number
of
workers
reasonably
likely
to
be
exposed
to
each
reportable
chemical
substance
at
each
site
where
the
substance
is
manufactured.
"
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.
The
amendments
require
reporting
of
exposure
using
the
range
code
corresponding
to
the
submitter's
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
of
a
chemical
substance
as
an
intermediate.


NAICS
codes
describe
the
industrial
activities
associated
with
each
reported
industrial
processing
or
use
operation.


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
Organisation
for
Economic
Cooperation
and
Development's
(
OECD's)
use
categories
and
EPA
experience
from
the
NCP.
Box
1­
2
lists
the
initial
Industrial
Function
Categories
for
the
IUR
amendments.
There
is
significant
1­
8
Box
1­
2.
Industrial
Function
Categories
$
Adsorbents
and
absorbents
$
Adhesives
and
binding
agents
$
Aerosol
propellants
$
Agricultural
chemicals
(
nonpesticidal)

$
Antiadhesive
agents
$
Bleaching
agents
$
Coloring
agents,
dyes
$
Coloring
agents,
pigments
$
Corrosion
inhibitors
and
antiscaling
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
1
percent
by
weight)

$
Stabilizers
$
Surface
active
agents
$
Viscosity
adjustors
$
Other
Box
1­
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
(
nonpesticidal)


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
overlap
between
this
suggested
list
for
the
amended
IUR
and
the
industrial
function
codes
used
for
the
Premanufacture
Notification
(
PMN),
Use
Cluster
Scoring
System
(
UCSS),
Use
and
Exposure
Information
Project
(
UEIP),
and
the
OECD's
programs
(
EPA,
1996d).
If
more
than
ten
NAICS­
industrial
function
code
combinations
apply
to
a
reportable
chemical
substance,
only
the
ten­
code
combinations
for
the
substance
that
cumulatively
represent
the
largest
percentage
of
production
volume
(
measured
by
weight)
need
to
be
reported.


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
9These
segments
of
the
chemical
industry
represent
those
most
likely
to
be
subject
to
TSCA
§
8
reporting,
but
other
industry
sectors
(
as
indicated
by
Table
1­
1)
may
also
manufacture
certain
subject
chemicals
and
thus
may
also
be
affected
by
the
IUR
amendments.

1­
9
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
1­
3
provides
a
listing
of
these
commercial
and
consumer
product
categories.

1.3
Overview
of
the
Regulated
Community
The
regulated
community
for
the
IUR
amendments
consists
of
companies
manufacturing
or
importing
chemicals
in
amounts
of
25,000
pounds
or
more
annually
that
are
listed
on
the
TSCA
Inventory
and
regulated
under
TSCA
§
8.
In
general,
the
industry
segments
that
compose
the
regulated
community
for
the
IUR
amendments
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
under
the
IUR.
Chemical
processors
are
also
exempt
from
all
reporting.
The
sections
below
describe
the
industries
likely
to
be
affected
by
the
amendments.
This
list
is
not
intended
to
be
exhaustive,
rather
it
is
intended
to
describe
those
entities
likely
to
be
affected
by
the
IUR
amendments.
Companies
must
review
the
rule
to
determine
whether
they
are
subject.

1.3.1
Chemical
Industry
Segments
Likely
to
be
Affected
by
the
IUR
Amendments
The
NAICS
codes
correlating
with
the
industry
groups
likely
to
be
affected
by
the
IUR
amendments
are
identified
in
Table
1­
1.
These
NAICS
codes
show
the
primary
activities
for
establishments
within
industries
that
manufacture
or
import
chemicals
listed
on
the
TSCA
Inventory.
The
six
sectors
of
the
U.
S.
economy
likely
to
be
most
affected
by
the
rule
amendments
can
be
classified
and
described
as
follows
(
EOP,
1987):
9

Major
Group
211
C
Oil
and
Gas
Extraction
includes
establishments
primarily
engaged
in
producing
crude
petroleum
and
natural
gas,
extracting
oil
from
oil
sands
and
oil
shale,
producing
natural
gasoline
and
cycle
condensate,
and
producing
gas
and
hydrocarbon
liquids
from
coal
at
the
mine
site.


Major
Group
2122
C
Metal
Ore
Mining
includes
establishments
primarily
concerned
with
mining,
developing
mines,
or
exploring
for
metallic
minerals
(
ores).
These
ores
are
valued
for
the
metals
contained
and
the
metals
to
be
recovered
for
use
as
such
or
as
constituents
of
alloys,
chemicals,
pigments,
or
other
products.
1­
10

Major
Group
322
C
Paper
Manufacturing
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
324
C
Petroleum
and
Coal
Products
Manufacturing
includes
establishments
that
participate
in
petroleum
refining,
petroleum
manufacturing,
manufacturing
of
paving
and
roofing
materials,
and
compounding
of
lubricating
oils
and
greases
from
purchased
materials.
Establishments
providing
gas
to
consumers
are
not
included
in
this
category,
but
rather
are
classified
with
Utilities
Industries
(
Major
Group
221).
1­
11
Table
1­
1.
North
American
Industrial
Classification
System
for
Industries
Likely
to
be
Subject
to
IUR
Reporting
NAICS
Description
211
Oil
and
Gas
Extraction
2111
Oil
and
Gas
Extraction
21111
Oil
and
Gas
Extraction
211111
Crude
Petroleum
and
Natural
Gas
211112
Natural
Gas
Liquid
Extraction
212
Mining
(
Except
Oil
and
Gas)
2122
Metal
Ore
Mining
21223
Copper,
Nickel,
Lead
and
Zinc
Mining
212234
Copper
Ore
and
Nickel
Ore
Mining
2123
Nonmetallic
Mineral
Mining
and
Quarrying
21232
Sand,
Gravel,
Clay,
and
Ceramic
and
Refractory
Minerals
Mining
and
Quarrying
212325
Clay
and
Ceramic
and
Refractory
Minerals
Mining
21239
Other
Nonmetallic
Mineral
Mining
and
Quarrying
212391
Potash,
Soda,
and
Borate
Mineral
Mining
212392
Other
Chemical
and
Fertilizer
Mineral
Mining
213
Support
Activities
for
Mining
2131
Support
Activities
for
Mining
21311
Support
Activities
for
Mining
213111
Drilling
Oil
and
Gas
Wells
213112
Support
Activities
for
Oil
and
Gas
Operations
311
Food
Manufacturing
3112
Grain
and
Oilseed
Milling
31122
Starch
and
Vegetable
Fats
and
Oils
Manufacturing
311222
Soybean
Processing
311223
Other
Oil
Seed
Processing
311225
Fats
and
Oils
Refining
and
Blending
3116
Animal
Slaughtering
and
Processing
31161
Animal
Slaughtering
and
Processing
311613
Rendering
and
Meat
Byproduct
Processing
3117
Seafood
Product
Preparation
and
Packaging
31171
Seafood
Product
Preparation
and
Packaging
311711
Seafood
Canning
311712
Fresh
and
Frozen
Seafood
Processing
3119
Other
Food
Manufacturing
31194
Seasoning
and
Dressing
Manufacturing
311942
Spice
and
Extract
Manufacturing
1­
12
Table
1­
1.
North
American
Industrial
Classification
System
for
Industries
Likely
to
be
Subject
to
IUR
Reporting
(
continued)

NAICS
Description
Chemical
Manufacturing
(
continued)
32519
Other
Basic
Organic
Chemical
Manufacturing
325191
Gum
and
Wood
Manufacturing
325192
Cyclic
Crude
and
Intermediate
Manufacturing
325193
Ethyl
Alcohol
Manufacturing
325199
All
Other
Basic
Organic
Chemical
Manufacturing
3252
Resin,
Synthetic
Rubber,
and
Artificial
and
Synthetic
Fibers
and
Filaments
Manufacturing
32521
Resin
and
Synthetic
Rubber
Manufacturing
325211
Plastics
Material
and
Resin
Manufacturing
325212
Synthetic
Rubber
Manufacturing
32522
Artificial
and
Synthetic
Fibers
and
Filaments
Manufacturing
325221
Cellulosic
Organic
Fiber
Manufacturing
325222
Noncellulosic
Organic
Fiber
Manufacturing
3253
Pesticide,
Fertilizer,
and
Other
Agricultural
Chemical
Manufacturing
32531
Fertilizer
Manufacturing
325311
Nitrogenous
Fertilizer
Manufacturing
325312
Phosphatic
Fertilizer
Manufacturing
32532
Pesticide
and
Other
Agricultural
Chemical
Manufacturing
3259
Other
Chemical
Product
and
Preparation
Manufacturing
32599
All
Other
Chemical
Product
and
Preparation
Manufacturing
325998
All
Other
Miscellaneous
Chemical
Product
and
Preparation
Manufacturing
3254
Pharmaceutical
and
Medicine
Manufacturing
32541
Pharmaceutical
and
Medicine
Manufacturing
325411
Medicinal
and
Botanical
Manufacturing
325412
Pharmaceutical
Preparation
Manufacturing
325413
In­
Vitro
Diagnostic
Substance
Manufacturing
325414
Biological
Product
(
except
Diagnostic)
Manufacturing
NAICS
Description
Chemical
Manufacturing
(
continued)
3255
Paint,
Coating,
and
Adhesive
Manufacturing
32551
Pain
and
Coating
Manufacturing
32552
Adhesive
Manufacturing
3256
Soap,
Cleaning
Compound,
and
Toilet
Preparation
Manufacturing
32561
Soap
and
Cleaning
Compound
Manufacturing
325611
Soap
and
Other
Detergent
Manufacturing
325612
Polish
and
Other
Sanitation
Good
Manufacturing
325613
Surface
Active
Agent
Manufacturing
32562
Toilet
Preparation
Manufacturing
3259
Other
Chemical
Product
and
Preparation
Manufacturing
32591
Printing
Ink
Manufacturing
32592
Explosives
Manufacturing
327
Nonmetallic
Mineral
Manufacturing
3274
Lime
and
Gypsum
Product
Manufacturing
32741
Lime
Manufacturing
331
Primary
Metal
Manufacturing
3311
Iron
and
Steel
Mills
and
Ferroalloy
Manufacturing
33111
Iron
and
Steel
Mills
and
Ferroalloy
Manufacturing
331111
Iron
and
Steel
Mills
3312
Steel
Product
Manufacturing
from
Purchased
Steel
33122
Rolling
and
Drawing
of
Purchased
Steel
331221
Rolled
Steel
Shape
Manufacturing
3313
Alumina
and
Aluminum
Production
and
Processing
33131
Alumina
and
Aluminum
Production
and
Processing
331311
Alumina
Refining
1­
13

Major
Group
325
C
Chemicals
Manufacturing
includes
establishments
producing
basic
chemicals
and
establishments
manufacturing
products
by
predominantly
chemical
processes.
Major
Group
325
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
422
C
Wholesale
Trade
C
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
four­
digit
groups
presented
in
Table
1­
1
represent
the
designation
of
examples
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
entire
regulated
community
more
difficult.
For
example,
NAICS
codes
reflect
a
site's
primary
activity,
omitting
substantial
participation
a
company
may
have
in
other
industry
activities.
Secondly,
NAICS
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
Table
1­
1.
North
American
Industrial
Classification
System
for
Industries
Likely
to
be
Subject
to
IUR
Reporting
(
continued)

NAICS
Description
332
Fabricated
Metal
Product
Manufacturing
3329
Other
Fabricated
Metal
Product
Manufacturing
33299
All
Other
Fabricated
Metal
Product
Manufacturing
332999
All
Other
Miscellaneous
Fabricated
Metal
Product
Manufacturing
32791
Abrasive
Product
Manufacturing
327125
Nonclay
Refractory
Manufacturing
422
Wholesale
Trade,
Nondurable
Goods
4226
Chemical
and
Allied
Products
Wholesalers
42269
Other
Chemical
and
Allied
Products
Wholesalers
4227
Petroleum
and
Petroleum
Products
Wholesalers
42271
Petroleum
Bulk
Stations
and
Terminals
42272
Petroleum
and
Petroleum
Products
Wholesalers
(
except
Bulk
Stations
and
Terminals)
NAICS
Description
Wholesale
Trade,
Nondurable
Goods
(
continued)
4229
Chemical
and
Allied
Products
Wholesalers
42291
Farm
Supplies
Wholesalers
42295
Paint,
Varnish,
and
Supplies
Wholesalers
444
Building
Materials
and
Garden
Supplies
Dealers
4442
Lawn
and
Garden
Equipment
and
Supplies
Stores
44422
Nursery
and
Garden
Centers
C
Retail
454
Nonstore
Retailers
4543
Direct
Selling
Establishments
45431
Fuel
Dealers
454311
Heating
Oil
Dealers
454312
Liquified
Petroleum
Gas
(
Bottled
Gas)
Dealers
1­
14
Box
1­
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
distributing
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
downstream
information
considered
to
be
readily
obtainable;
therefore,
more
complicated
scenarios
should
require
only
a
marginally
greater
effort
than
small­
volume,
limited­
use
chemicals.
Processors
are
not
required
to
report.
small
subsidiaries
may
belong
in
a
completely
different
industry
classification
based
on
its
own
primary
activity.
Therefore,
sites
considered
to
fit
into
other
NAICS
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
NAICS
codes
may
not
be
subject
to
this
rule.

1.3.2
Information
to
be
Reported
In
addition
to
the
information
required
under
the
existing
IUR,
companies
reporting
under
the
amended
IUR
will
be
reporting
additional
information
on
site
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
site
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.
The
purpose
in
specifying
the
term
"
reasonably
ascertainable"
is
to
ensure
that
supplying
these
data
elements
will
not
entail
a
highly
burdensome
level
of
effort
(
see
Box
1­
4).
Furthermore,
EPA
requires
that
some
information
will
be
reported
in
ranges,
and
that
only
the
majority
of
the
production
volume
will
be
accounted
for
when
reporting
use
information.
Allowing
for
reporting
in
ranges
is
intended
to
reduce
the
potential
burden
to
submitters
of
developing
a
precise
point
estimate
of
their
chemical
production,
but
it
will
provide
information
that
is
sufficiently
precise
for
the
Agency's
risk­
screening
purposes.

1.4
Organization
of
this
Report
The
contents
of
the
five
remaining
chapters
and
six
appendices
contained
in
this
report
are
organized
as
follows:
1­
15

Section
2
describes
the
need
for
amendments
to
the
IUR,
existing
data
sources,
and
regulatory
options
considered.
The
statement
of
need
explains
the
economic
rationale
for
these
amendments.


Section
3
analyzes
and
presents
the
social
costs
of
the
selected
amendments
and
the
nonselected
regulatory
alternatives.
Social
costs
include
both
the
industry
costs
to
comply
with
the
reporting
requirements
and
the
Agency
costs
to
administer
the
amended
IUR
program.


Section
4
qualitatively
describes
the
benefits
that
will
be
generated
from
collecting
additional
information
under
the
IUR
amendments.
This
section
describes
how
the
Agency
will
use
the
information
and
how
use
of
this
information
will
generate
societal
benefits
by
improving
public
and
private
risk
management
decisionmaking.


Section
5
compares
the
nonmonetized
benefits
of
the
amendments
with
the
associated
costs.
Comparisons
are
made
for
the
selected
option
to
address
whether
the
rule
is
likely
to
generate
benefits
for
society
that
justify
its
costs.
Comparisons
are
also
made
between
the
selected
option
and
regulatory
alternatives
to
assess
whether
the
most
cost­
effective
option
is
selected.


Section
6
provides
a
discussion
of
small
business
impacts
and
environmental
equity
considerations.


Appendix
A
includes
Form
U,
the
revised
IUR
reporting
form.


Appendix
B
provides
information
on
the
types
of
data
that
are
currently
available
to
EPA,
demonstrating
the
need
for
collecting
additional
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
presents
the
cost
of
the
existing
IUR
to
use
as
a
point
of
comparison
for
the
costs
of
the
IUR
amendments
estimated
in
Section
3.


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


Appendix
F
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.
2­
1
SECTION
2
STATEMENT
OF
THE
PROBLEM
AND
REGULATORY
OPTIONS
The
production,
processing,
and
use
of
chemicals
can
generate
residuals
that,
when
introduced
into
the
environment,
can
cause
great
harm
to
humans
and
ecosystems.
The
market
has
not
provided
the
public
or
the
government
with
adequate
information
on
risks
associated
with
the
production,
processing,
and
use
of
chemicals.
Because
the
market
does
not
necessarily
provide
all
of
the
information
for
affected
parties
to
optimally
modify
their
behaviors
and
reduce
environmental
risks,
socially
suboptimal
levels
of
human
health
and
environmental
quality
persist.
This
section
describes
the
underlying
market
failure
that
the
IUR
amendments
are
designed
to
address,
and
discusses
how
this
new
regulation
helps
to
solve
the
problem.
It
summarizes
the
difficulties
related
to
a
lack
of
information
on
the
risks
associated
with
these
chemicals.
This
section
explains
the
market
failure,
the
need
for
information,
and
the
manner
in
which
the
IUR
amendments
address
these
information
needs.
It
also
discusses
the
reasons
why
there
is
a
potential
need
for
federal
regulation
in
cases
such
as
this
one.
To
show
how
the
problem
is
currently
being
addressed,
the
original
IUR
requirements
are
presented.
Finally,
the
regulatory
options
that
were
considered
for
this
rule
are
summarized.

2.1
Problem
Addressed
by
IUR
Amendments
Effective
screening
of
the
risks
posed
by
chemicals
requires
sufficient
information
to
predict
potential
exposure
to
humans
and
the
ecosystem.
Because
of
resource
constraints,
EPA
can
provide
detailed
risk
assessment
for
a
limited
number
of
chemicals
in
a
given
year.
Therefore,
it
is
important
for
EPA
to
have
enough
information
to
select
efficiently
the
chemicals
that
will
be
subjected
to
detailed
assessment
of
the
risk
associated
with
their
use.
Risk
is
a
function
of
both
hazard
and
exposure,
and
EPA
needs
information
on
both
variables.
Other
things
being
equal,
chemicals
that
are
thought
to
be
highly
toxic
to
humans
and/
or
ecosystems
would
have
priority
for
detailed
risk
assessment.
However,
exposure
also
plays
an
important
part
in
determining
assessment
priorities.
For
a
given
level
of
suspected
hazard,
chemicals
that
humans
and
the
environment
are
exposed
to
in
large
quantities
(
as
measured
by
a
combination
of
chemical
concentration,
duration,
and
frequency
of
exposure)
are
a
higher
priority
for
detailed
examination
than
those
chemicals
to
which
humans
and
the
environment
are
rarely
exposed.
For
most
chemicals,
though,
the
market
makes
little
information
relevant
to
exposure
readily
available.
Therefore,
it
is
not
necessarily
clear
how
to
optimally
prioritize
more
detailed
chemical
testing.
This
lack
of
market
information
about
chemical
exposure
is
one
of
the
primary
justifications
for
the
government
to
collect
information
through
the
IUR.
However,
the
current
IUR
and
other
public
sources
of
information
do
not
provide
enough
exposure
information
to
effectively
aid
in
EPA's
risk­
screening
process
for
chemicals.
10Under
this
scenario,
the
negative
externality
would
now
be
identified,
but
this
does
not
imply
that
market
forces
will
always
act
to
eliminate
this
externality.

2­
2
Box
2­
1.
Progress
on
Screening
Chemicals
for
Risks
A
successful
chemical
risk
management
program
requires
EPA
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.
EPA's
TSCA
Inventory
lists
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
is
focusing
the
IUR
on
the
10
percent
to
15
percent
of
chemicals
that
are
the
highest
priority.
This
is
based
on
the
fact
that
many
chemicals
are
produced
in
very
low
volumes,
not
at
all,
or
belong
to
larger
classes
of
chemicals,
such
as
polymers,
that
present
little
risk.

Additional
information
is
required
to
adequately
assess
the
risks
of
these
chemicals
(
about
10,000
chemicals)
on
which
EPA
would
like
to
focus
attention.
EPA
plans
to
implement
a
more
thorough
screening
of
these
chemicals
and
requires
additional
use
and
exposure
information
to
adequately
screen
their
risks.
Without
the
additional
information
to
be
collected
with
the
amended
IUR,
EPA
and
others
may
not
be
able
to
identify
the
potential
risks
posed
by
these
chemicals
and
their
use.
If
the
potential
risks
are
not
identified,
EPA
may
not
be
able
to
evaluate
or
address
the
severity
of
these
risks
associated
with
the
chemicals
and
their
use.
EPA
believes
that
collecting
augmented
site
and
manufacturing
information
for
the
remaining
chemicals
provides
sufficient
information
to
maintain
a
profile
of
the
chemical
industry
and
to
react
to
unanticipated
risks.

Key
benefits
of
the
IUR
amendments
are
that
EPA
will
be
able
to
collect
and
process
data
to
develop
more
accurate
exposure
estimates,
and
they
will
be
able
to
develop
these
estimates
more
quickly.
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
only
about
16
percent
of
the
Inventory,
either
as
new
or
existing
chemicals.
(
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
chemicals
for
which
there
are
significant
concerns
without
additional
information.
Adding
the
information
collected
through
the
IUR
amendments
provides
the
information
needed
by
the
Agency
to
determine
which
chemical
use
scenarios
are
likely
to
pose
significant
risks,
to
determine
which
chemicals
are
selected
for
more
detailed
analysis,
and,
ultimately,
to
determine
which
chemicals
enter
the
risk
management
program.
With
sufficient
risk
information,
individuals
can
better
respond
to
the
risks
from
chemical
exposure
by
changing
their
behavior.
These
behavioral
responses
would
lead
to
changes
in
market
demands
and
prices
so
that
the
market
would
more
accurately
reflect
the
risk
involved
with
chemical
use
and
exposure.
In
addition,
EPA
could
take
actions
to
mitigate
the
risks
to
public
health
and
the
environment
where
needed.
This
intervention
is
necessary
because,
even
under
perfect
information,
negative
externalities
may
still
exist
in
the
absence
of
government
intervention.
10
2­
3
In
the
absence
of
such
risk
data,
individuals
cannot
correctly
account
for
the
risk
of
chemical
exposure
in
decisionmaking,
and
EPA
cannot
effectively
decide
where
regulation
is
most
appropriate.
This
results
in
suboptimal
levels
of
risk,
where
the
suboptimal
level
may
be
either
too
high
or
too
low.
Obtaining
more
data
concerning
exposure
is
vital
(
see
Box
2­
1)
to
improve
EPA's
ability
to
conduct
efficient
chemical
screenings
so
that
information
concerning
the
risks
associated
with
using
various
chemicals
is
made
available
in
the
most
appropriate
order.

2.1.1
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
priority
setting
and
resource
allocation
depends
on
the
availability
of
exposure
data
that
are
not
currently
collected
on
a
comprehensive
basis.
Consequently,
this
rule's
primary
goal
is
to
enhance
the
quality
and
quantity
of
information
about
chemical
uses
and
exposures
that
EPA
can
use
to
identify
risks
under
TSCA
and
ultimately
to
protect
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
(
EPA,
1992).
Specific
data
needs
include
the
following:


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;
and

information
on
the
industrial
function
of
a
chemical
substance.
Table
2­
1
lists
the
three
components
of
exposure
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
determining
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.

2.1.2
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.
However,
2­
4
tens
of
thousands
of
chemicals
are
currently
in
use,
and
exposures
can
occur
in
many
different
ways.
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
(
see
Box
2­
1).
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
Chemicals
Program
(
see
Box
2­
2).
Other
approaches
include
recommendations
from
Table
2­
1.
Components
of
Exposure
Assessments
and
Exposure­
Related
Data
Elements
Component
of
Exposure
Assessmentsa
Examples
of
Variables
Affecting
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.
Environmental
Protection
Agency.
1992.
"
Guidelines
for
Exposure
Assessment."
Notice.
Federal
Register
57(
104):
22888­
22938.
2­
5
Box
2­
2.
Current
Existing
Chemicals
Program
Review
Process
Because
there
is
no
adequate
current
system
available
for
screening
all
of
the
chemicals
in
commerce,
EPA
relies
on
various
methods
to
determine
which
chemicals
enter
the
Existing
Chemicals
Program
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,
the
current
system
offers
no
guarantee
that
the
chemicals
chosen
for
review
necessarily
pose
the
greatest
risk.
The
IUR
amendments
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).
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.

2.2
Market
Failure
Under
Executive
Order
12866,
EPA
is
required
to
identify
whether
the
regulation
addresses
a
significant
market
failure.
The
major
types
of
market
failure
are
externalities,
natural
monopoly,
market
power,
and
inadequate
or
asymmetric
information.
This
rule
deals
with
two
types
of
market
failure.
First,
the
information
gathered
under
the
rule
reduces
the
problems
associated
with
inadequate
and
asymmetric
information.
When
affected
parties
have
more
complete
information,
they
can
make
better
decisions.
Second,
one
of
the
most
important
expected
outcomes
of
the
rule
is
that
the
information
gathered
can
be
used
to
identify
and
address
externalities
arising
from
chemical
production
and
use.
2­
6
2.2.1
Externalities
and
the
Need
for
Information
A
defining
feature
of
a
market
failure
is
the
inequality
between
the
social
consequences
of
an
action
and
a
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
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
from
a
social
welfare
perspective.
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
the
company's
employees,
the
public
at
large,
and
ecosystems.
These
risks
are
created
by
the
manufacturing
site,
but
it
is
society
(
employees
and
the
public)
that
bears
the
cost
of
these
risks.
When
these
externalities
can
be
internalized
to
the
parties
(
firms)
making
the
decision
that
generate
the
risks,
the
problem
can
be
mitigated.
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
likely
to
occur.
Thus,
identifying
situations
in
which
externalities
are
present
C
and
where
the
potential
risks
posed
by
these
externalities
are
sufficiently
large
as
to
warrant
further
investigation
C
is
a
key
goal
of
the
chemical
screening
that
EPA
performs
as
part
of
its
risk
management
activities.
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
information
required
to
identify
relevant
externalities
is
not
currently
available
to
EPA's
risk
management
process.
The
question
thus
arises:
"
why
does
the
market
fail
to
provide
the
information
needed
to
identify
these
externalities?"
Several
reasons
cause
this
information
void.
One
of
the
primary
reasons
is
that
companies
have
little
incentive
to
provide
information.
Providing
information
is
not
costless,
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.
This
lack
of
information
provides
motivation
for
many
activities
that
EPA
undertakes
(
Box
2­
3
and
the
text
below
provide
examples
of
reasons
for
the
lack
of
information).
EPA's
mission
is
to
act
in
the
public's
interest.
In
the
absence
of
adequate
information,
EPA
fulfills
this
mission
by
undertaking
actions
to
correct
the
lack
of
information.
The
information
collected
by
EPA
permits
identification
of
existing
externalities
that
cause
a
suboptimal
level
of
protection
for
the
environment
and
the
public.
2­
7
Box
2­
3.
Reasons
for
Lack
of
Information
Negative
incentivesCManufacturers
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
costsCThe
production
and
dissemination
of
information
has
a
cost
that
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
establishCOften
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
extramarket
systems
(
such
as
conventional
legal
remedies)
may
not
adequately
address
these
risks.

Exposures
not
perceptibleCIf
exposures
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
effectsCLong
latency
periods
and
other
factors
that
cause
harm
to
occur
long
after
the
exposure
event
can
also
hinder
the
market's
attempts
to
establish
and
enforce
responsibility
for
environmental
consequences
of
some
activities.
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
have
an
incentive
to
provide
information
if
it
encourages
a
potential
consumer
to
purchase
the
product.
Similarly,
employers
have
an
incentive
to
entice
potential
employees
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,
the
market
does
not
readily
provide
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.
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
about
the
safety
characteristics
of
the
product
or
job.
In
some
cases,
manufacturers
may
think
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.
2­
8
A
potential
failure
to
provide
adequate
information
can
occur
for
the
simple
reason
that
information
may
be
costly
to
generate
and
disseminate.
Moreover,
economies
of
scale
may
be
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
an
individual's
best
interest
to
do
so.
Thus,
government's
role
(
in
this
case,
EPA's)
is
to
collect
and
maintain
information
and
to
interpret
it
to
identify
the
externalities
and
determine
if
action
is
warranted
to
protect
the
public's
interest.

2.3
Potential
Need
for
Federal
Regulation
2.3.1
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
2­
4).
Ongoing
chemical
data
collection
efforts
occurring
within
various
EPA
offices
do
not
systematically
or
comprehensively
collect
chemical
use
and/
or
worker
exposure
data.
Appendix
B
describes
the
information
collected
by
these
EPA
offices,
and
other
publicly
available
data.
In
addition
to
data
collected
by
EPA,
chemical
information
is
collected
at
the
state
level
to
support
a
variety
of
state
and
federal
programs
and
regulations,
including
Emergency
Planning
and
Community
Right­
to­
Know
Act
(
EPCRA),
state
Right­
to­
Know
programs,
state
permitting
requirements,
and
other
state
programs.
According
to
EPA
regional
offices
and
state
environmental
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
is
typically
used
to
support
waste
reduction
programs
and/
or
emergency
management
plans,
and
is
not
designed
to
2­
9
Box
2­
4.
Risk­
Screening
Activities
Lack
Important
Data
on
Exposure
Currently,
EPA
often
must
conduct
its
screening
activities
based
on
assumed
conditions,
outdated
information,
and
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
somewhat
outdated,
it
is
often
the
only
available
source
of
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
Toxic
Release
Inventory
(
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
chemicals
listed
on
the
TSCA
Inventory
would
be
enormous
and
would
be
based
upon
an
unreasonable
number
of
assumptions.
assist
in
ranking
chemical
exposure
and
use
concerns.
None
of
these
groups
collect
the
data
needed
to
effectively
conduct
chemical
risk
screening
at
the
national
level.
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
Products
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

publications
from
chemical
trade
associations,
such
as
the
Chemical
Manufacturers
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
2­
10
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
(
EPA,
1998a).
Overall,
it
is
evident
that
the
information
currently
available
to
EPA
falls
short
of
the
information
needed
to
identify
potential
risks
swiftly
and
accurately.
In
particular,
the
current
IUR
provides
very
limited
information
C
only
the
volume
of
production
C
to
screen
chemicals
for
exposure.
However,
impacts
on
human
health
and
other
risks
posed
by
a
chemical
depend
critically
on
its
level
of
exposure
to
the
public
and
the
environment.
While
exposure
and
production
volume
can
be
related,
the
correlation
is
not
close
enough
to
ensure
an
acceptable
estimate
of
risk.
Without
more
comprehensive
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.

2.3.2
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
IUR
amendments,
the
Agency
will
acquire
the
necessary
information
to
improve
identification,
prioritization,
and
chemical
risk
screening
capabilities.
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
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
collected
under
the
IUR
amendments
will
enable
EPA
to
better
evaluate
the
potential
risks
associated
with
chemical
production
and
use,
and
will
improve
EPA's
consequent
ability
to
conduct
risk
management
activities,
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.
2.3.3
Approaches
to
Regulation
2­
11
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
the
following
three
broad
categories:
command­
and­
control
approaches,
incentivebased
strategies,
and
information­
based
remedies.
In
addition,
EPA
may
choose
to
take
no
regulatory
action,
or
investigate
non­
regulatory
approaches,
in
response
to
market
failures
if
it
is
determined
that
failures
are
not
significant
or
if
costs
of
regulatory
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
decisionmaking.
This
aim
is
accomplished
by
changing
price
or
cost
conditions
related
to
polluting­
or
risk­
generating
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
to
addressing
environmental
risks
to
human
health
and
the
environment.
These
strategies
seek
to
indirectly
alter
decisions
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,
an
outright
ban
of
products
or
processes,
mandatory
exposure
controls,
or
other
direct
interventions
might
best
achieve
the
goal
of
improved
environmental
protection
and
maximizing
net
benefits.
In
other
situations,
economic
incentive­
based
strategies
might
be
the
better
choice,
especially
when
a
substantial
variation
in
the
costs
of
pollution
control
exists
across
many
sources.
In
this
case,
improved
information
on
chemical
exposure
will
clearly
allow
EPA
to
more
effectively
and
accurately
identify
and
initially
assess
the
extent
of
market
failures
and
the
resulting
externalities
associated
with
chemical
exposures
and
risks.
In
addition,
information
disseminated
to
chemical
producers,
consumers,
and
the
public
will
help
achieve
more
efficient
solutions
to
risk
management
problems
specific
to
particular
circumstances.
Based
on
the
data
collected,
EPA
may
choose
to
implement
command
and
control
and/
or
incentive­
based
strategies
in
cases
that
warrant
regulations.
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
meager
body
of
information
currently
available
is
not
sufficient
to
accurately
identify
chemical
exposures
and
risks,
and
hence,
that
some
additional
information
collection
is
required.
2­
12
One
alternative
to
a
mandatory
information
collection
rule
is
a
voluntary
survey
approach
under
which
the
added
information
targeted
under
the
IUR
amendments
would
be
collected
on
a
voluntary
basis.
This
approach
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
their
responses.
One
such
program
is
the
voluntary
Use
and
Exposure
Information
Project
(
UEIP).
This
program,
jointly
developed
by
EPA
and
industry,
provides
a
method
for
chemical
manufacturers
to
voluntarily
send
use
and
exposure
information
to
OPPT
for
chemicals
entering
EPA's
Existing
Chemicals
risk
management
screening
assessment.
In
this
program,
manufacturers
and
importers
voluntarily
report
production
volume,
site
location,
percentage
of
production
volume
for
a
given
use,
environmental
releases,
worker
exposure,
and
industrial
and
consumer
uses
for
chemicals
selected
for
the
project
based
on
their
potential
toxicity.
Under
this
program,
EPA
is
able
to
gain
access
to
exposure
data
more
quickly
and
avoids
resorting
to
additional
regulation.
Chemical
manufacturers
become
aware
of
chemicals
that
EPA
is
concerned
about
and
can
help
ensure
accurate
assessments
of
chemical
risks.
However,
despite
some
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.
Information
has
been
collected
under
UEIP
in
three
groups
(
two
in
1994
and
one
in
1996)
for
15
to
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.
No
clear
method
exists
to
determine
the
extent
to
which
these
voluntary
responses
span
the
entire
universe
of
relevant
chemicals
and
their
uses.
Consequently,
data
gaps
of
perhaps
substantial
proportions
would
continue
to
exist.
Moreover,
incomplete
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.

2.4
Original
IUR
Requirements
2.4.1
Original
Reporting
Requirements
The
original
IUR
requires
chemical
manufacturers
and
importers
to
submit
information
on
certain
chemical
substances
listed
on
the
TSCA
Chemical
Substances
Inventory.
Manufacturers
and
importers
of
subject
chemicals
must
report
data
on
production
volume,
plant
site
and
chemical
identification,
and
site­
limited
status
for
the
subject
chemicals.
These
data
must
be
provided
on
a
four­
year
reporting
cycle
and
reflect
manufacturing
and
importing
activities
over
the
last
complete
corporate
fiscal
year
preceding
the
reporting
year.
Companies
can
claim
specific
data
elements
as
confidential
business
information
(
CBI)
by
using
a
check­
box,
although
CBI
claims
for
11As
used
in
this
analysis,
the
number
of
"
reports"
refers
to
the
total
number
of
individual
chemical­
site
combinations
reported
nationwide.
Companies
generally
submit
one
Form
U
per
site,
addressing
multiple
chemicals,
and
therefore
multiple
chemical
"
reports"
per
site.

12The
total
number
of
reports
received
was
26,667
from
2,675
sites,
but
this
includes
reports
for
chemicals
with
a
production
volume
of
less
than
10,000
pounds
that
reported
voluntarily.
These
voluntary
reports
were
not
included
in
calculating
the
costs
associated
with
the
current
IUR
or
the
IUR
amendments.

2­
13
chemical
identity
require
up­
front
substantiation.
Firms
must
retain
records
that
support
their
submissions
for
four
years
following
the
reporting
period.
The
number
of
reports11
received
under
the
original
IUR
requirements
has
hovered
around
26,000
for
each
of
the
four
reporting
periods
to
date
(
i.
e.,
1986,
1990,
1994,
and
1998).
This
analysis
assumes
that
1998
is
a
representative
year
and
that
reports
in
future
years
will
have
similar
characteristics
in
terms
of
the
number
of
reports,
number
of
sites,
etc.
The
reporting
data
from
1998
was
used
because
it
includes
the
most
recent
IUR
data
and
presumably
best
reflects
the
current
population
of
chemical
manufacturers
and
importers.
In
1998,
26,365
reports
on
chemicals
with
production
volumes
of
10,000
pounds
or
greater
were
filed
from
2,666
sites.
12
2.4.2
Original
Exemptions
The
TSCA
Inventory
includes
more
than
75,000
substances,
but
exemptions
and
reporting
thresholds
reduce
the
number
of
TSCA
chemicals
reportable
under
the
original
IUR
to
about
8,800
discrete
chemicals.
The
exemptions
under
the
IUR
include
a
low­
volume
threshold
exemption,
a
small
business
exemption,
and
certain
chemical
substance
exemptions.
Chemicals
produced
at
a
manufacturing
site
in
a
volume
of
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.
Small
businesses,
as
defined
by
TSCA
§
8(
a),
are
also
exempt
from
reporting
under
the
original
IUR
requirements.
Small
businesses
are
defined
for
this
purpose
as
those
companies
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.
The
IUR
also
exempts
certain
chemical
substances.
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.
Finally,
chemical
processors
are
not
subject
to
the
IUR.

2.5
Regulatory
Options
for
Amending
the
IUR
After
determining
that
a
non­
regulatory
approach
would
not
fulfill
its
needs,
the
Agency
considered
various
regulatory
options
that
would
alter
the
scope
of
coverage
under
the
IUR
reporting
requirements.
Three
basic
parameters
for
the
options
are
13Note
that
in
an
earlier
version
of
this
report
(
EPA,
1999b),
14
options
were
analyzed.
The
correspondence
between
previous
option
numbers
and
current
option
numbers
is
as
follows:
current
Options
2
through
8
were
previously
Options
4,
6,
7,
8,
11,
13,
and
14,
respectively.
Option
1,
the
option
selected
for
the
final
rule,
was
not
included
in
the
previous
report.
In
all
cases,
the
options
are
not
identical
to
the
previous
options,
however,
because
of
several
changes
in
the
rule.
For
example,
the
rule
now
includes
a
full
exemption
from
reporting
for
natural
gas
that
was
not
included
in
the
earlier
version.

2­
14
reporting
thresholds,
exemptions
based
on
the
type
of
chemical,
and
reporting
cycles.
Within
the
reporting
threshold
parameter,
two
categories
of
reporting
thresholds
are
used
in
the
IUR
amendments;
the
two
reporting
thresholds
determine
submission
of
site
and
manufacturing
data,
and
submission
of
processing
and
use
data,
respectively.
However,
only
changes
in
the
upper
threshold
are
examined.
A
total
of
eight
options
were
analyzed
and
are
summarized
in
Table
2­
2.13
Note
that
this
table
displays
the
differences
between
the
options,
and
does
not
show
all
of
the
changes
from
the
baseline.
The
changes
from
the
baseline
that
apply
to
all
options
are
presented
in
Section
1.
The
first
five
options
are
based
on
different
reporting
thresholds
for
processing
and
use
information,
but
include
the
same
exemptions
and
a
common
four­
year
reporting
cycle.
Option
1
is
the
option
selected
for
the
final
rule,
and
it
sets
the
reporting
threshold
at
25,000
pounds
for
site
and
manufacturing
data
and
300,000
pounds
for
processing
and
use
data.
Options
2
through
4
vary
the
threshold
for
processing
and
use
data
from
100,000
pounds
to
1,000,000
pounds.
Option
5
also
varies
this
threshold,
but
does
so
in
a
staged
manner
such
that
the
threshold
for
the
first
year
of
reporting
is
500,000
pounds
and
for
subsequent
reporting
years
is
100,000
pounds.
Option
6
uses
the
same
reporting
thresholds
as
Option
2,
but
includes
a
continuation
of
the
present
full
reporting
exemption
for
inorganic
chemicals.
Options
7
2­
15
and
8
also
use
the
same
reporting
thresholds
as
in
Option
2,
but
incorporate
different
reporting
cycles.
Option
7
assumes
a
two­
year
reporting
cycle
for
all
information,
and
Option
8
requires
only
one­
time
reporting.

2.5.1
Number
of
Reports
Received
under
Different
Options
Because
the
lower
threshold
is
constant
across
all
of
the
options,
the
total
number
of
reports
expected
under
each
option
is
also
constant
with
the
exception
of
Option
6,
which
exempts
inorganic
chemicals
from
reporting.
For
all
options
other
than
Option
6,
22,260
reports
for
organic
chemicals
and
4,537
reports
for
inorganic
chemicals
are
expected.
For
Option
6,
it
is
expected
that
22,260
organic
chemical
reports
and
no
inorganic
chemical
reports
will
be
received.
Although
the
total
number
of
reports
is
generally
expected
to
remain
constant
across
options,
differences
in
the
upper
threshold
lead
to
different
numbers
of
full
and
partial
reports
for
the
various
options.
Table
2­
3
presents
the
total
number
of
full
and
partial
reports
expected
for
each
option,
and
Table
2­
4
details
these
reports
by
chemical
type
(
organic
or
inorganic).
The
breakdown
between
full
and
partial
form
reports
differs
between
the
first
year
and
all
future
years
because
inorganic
chemicals
are
exempt
from
reporting
processing
and
use
information
in
the
first
year
but
are
subject
to
the
300,000
pound
Table
2­
2.
Options
Considered
for
the
IUR
Amendments
Option
Thresholds
Reporting
Cycles
Site
and
Manufacturing
Information
Processing
and
Use
Information
Site
and
Manufacturing
Information
Processing
and
Use
Information
Threshold
Options
1
(
Selected)
25,000
lbs
300,000
lbs
4
yrs.
4
yrs.
2
25,000
lbs
100,000
lbs
4
yrs.
4
yrs.
3
25,000
lbs
500,000
lbs
4
yrs.
4
yrs.
4
25,000
lbs
1,000,000
lbs
4
yrs.
4
yrs.
5a
25,000
lbs
500,000
lbs/
100,000
lbs
4
yrs.
4
yrs.

Reporting
Exemption
Optionb
6
25,000
lbs
100,000
lbs
4
yrs.
4
yrs.
Reporting
Cycle
Options
7
25,000
lbs
100,000
lbs
2
yrs.
2
yrs.
8
25,000
lbs
100,000
lbs
one­
time
one­
time
a
This
option
has
a
threshold
of
500,000
pounds
for
processing
and
use
information
in
the
first
reporting
year
and
a
threshold
of
100,000
pounds
for
reporting
this
information
in
all
future
reporting
years.
b
Inorganic
chemicals
are
fully
exempt
from
reporting.
2­
16
upper
threshold
for
reporting
this
information
in
all
future
years.
Under
the
IUR
amendments,
partial
forms
will
be
completed
for
12,501
organic
chemicals
(
including
petroleum
process
stream
chemicals),
and
4,537
inorganic
chemicals
in
the
2­
17
Table
2­
3.
Number
of
Reports
Expected
for
Each
Option
Option
Total
Number
of
Reports
Partial
Form
Full
Form
Threshol
d
Level
(
lbs)
Number
of
Reports
%
of
Total
Threshold
Level
(
lbs)
Number
of
Reports
%
of
Total
First
Reporting
Year
Baseline
26,365
10,000
26,365
100.0
N/
A
0
0
1
(
Selected)
26,797
25,000
17,038
63.6
300,000
9,759
36.4
2
26,797
25,000
13,851
51.7
100,000
12,946
48.3
3
26,797
25,000
18,262
68.1
500,000
8,535
31.9
4
26,797
25,000
19,745
73.7
1,000,000
7,052
26.3
5a
26,797
25,000
18,262
68.1
500,000
8,535
31.9
6
22,260
25,000
9,314
41.8
100,000
12,946
58.2
7
26,797
25,000
13,851
51.7
100,000
12,946
48.3
8
26,797
25,000
13,851
51.7
100,000
12,946
48.3
Future
Reporting
Years
Baseline
26,365
10,000
26,365
100.0
N/
A
0
0.0
1
(
Selected)
26,797
25,000
14,467
54.0
300,000
12,330
46.0
2
26,797
25,000
10,418
38.9
100,000
16,379
61.1
3
26,797
25,000
16,039
59.9
500,000
10,758
40.1
4
26,797
25,000
17,941
67.0
1,000,000
8,856
33.0
5a
26,797
25,000
10,418
38.9
100,000
16,379
61.1
6
22,260
25,000
9,314
41.8
100,000
12,946
58.2
7
26,797
25,000
10,418
38.9
100,000
16,379
61.1
8
26,797
25,000
10,418
38.9
100,000
16,379
61.1
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.

Sources:
CUS
Database.
2000.
Information
from
the
Chemical
Update
System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

CICIS
Database.
1986.
Information
from
the
Chemical
in
Commerce
Information
System
2­
18
Table
2­
4.
Number
of
Full
and
Partial
Reports
Expected
for
Each
Option
by
Chemical
Type
Option
Partial
Form
Full
Form
Threshold
Level
(
lbs)
Number
of
Reports
Threshold
Level
(
lbs)
Number
of
Reports
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)
Inorganic
Chemical
s
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)
Inorganic
Chemicals
First
Reporting
Year
Baseline
10,000
26,365
0
N/
A
0
0
1
(
Selected)
25,000
12,501
4,537
300,000
9,759
0
2
25,000
9,314
4,537
100,000
12,946
0
3
25,000
13,725
4,537
500,000
8,535
0
4
25,000
15,208
4,537
1,000,000
7,052
0
5a
25,000
13,725
4,537
500,000
8,535
0
6
25,000
9,314
0
100,000
12,946
0
7
25,000
9,314
4,537
100,000
12,946
0
8
25,000
9,314
4,537
100,000
12,946
0
Future
Reporting
Years
Baseline
10,000
26,365
0
N/
A
0
0
1
(
Selected)
25,000
12,501
1,966
300,000
9,759
2,571
2
25,000
9,314
1,104
100,000
12,946
3,433
3
25,000
13,725
2,314
500,000
8,535
2,223
4
25,000
15,208
2,733
1,000,000
7,052
1,804
5a
25,000
9,314
1,104
100,000
12,946
3,433
6
25,000
9,314
0
100,000
12,946
0
7
25,000
9,314
1,104
100,000
12,946
3,433
8
25,000
9,314
1,104
100,000
12,946
3,433
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.
2­
19
first
reporting
year.
Of
the
partial
exemption
chemicals
(
either
petroleum
process
stream
chemicals
or
inorganic
chemicals),
2,253
are
produced
at
volumes
of
less
than
the
300,000
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
an
estimated
9,759
organic
chemicals
and
no
inorganic
chemicals
under
the
selected
option.
In
future
reporting
years,
partial
forms
will
be
completed
for
12,501
organic
chemicals
(
including
petroleum
process
streams)
and
1,966
inorganic
chemicals.
Full
forms
will
be
completed
for
9,759
organic
chemicals
and
2,571
inorganic
chemicals.
The
number
of
partial
and
full
forms
completed
for
organic,
partial
exemption,
and
inorganic
chemicals
varies
by
option.
Under
Options
2,
3,
4,
5,
7,
and
8,
the
total
number
of
reports
completed
is
the
same
as
under
the
selected
option,
but
Option
2
would
generate
more
full
forms
than
the
selected
option
while
Options
3
and
4
would
generate
fewer
full
forms
than
the
selected
option.
Under
Option
5,
there
would
be
fewer
full
reports
than
the
selected
option
for
the
first
year,
but
more
full
reports
in
subsequent
years.
There
would
be
fewer
partial
reports
and
total
reports
under
Option
6
because
inorganic
chemicals
are
fully
exempt
from
reporting
under
this
option.
Under
Option
7,
there
would
be
more
full
reports
completed
than
under
the
selected
option
and
these
reports
would
be
completed
twice
as
often.
Option
8
also
generates
more
full
reports
than
the
selected
option
in
the
single
reporting
year,
but
then
provides
no
additional
information
in
subsequent
years.
The
expected
number
of
sites
that
would
report
under
each
option
for
the
amendments
is
3,026
(
2,482
sites
reporting
organic
chemicals
and
544
reporting
inorganic
chemicals)
with
the
exception
of
Option
6,
where
only
the
2,482
organic
chemical
sites
are
expected
to
report
due
to
the
inorganic
chemical
reporting
exemption.
It
is
expected
that
information
will
be
received
on
a
total
of
8,865
discrete
chemicals
for
each
option
except
Option
6,
for
which
information
on
only
7,748
discrete
chemicals
is
expected.
Table
2­
5
presents
the
number
of
chemicals
for
which
full
and
partial
reports
are
expected
to
be
reported,
broken
down
by
chemical
type.
Although
information
on
the
number
of
chemicals
is
not
used
to
estimate
industry
costs,
the
table
provides
a
useful
comparison
of
the
expected
number
of
chemicals
for
each
option.
The
number
of
chemicals
that
information
is
provided
for
is
important
because
one
of
the
main
benefits
of
the
rule
is
that
EPA
gains
more
detailed
information
on
chemicals.
Other
things
being
equal,
there
are
larger
benefits
to
options
that
provide
information
on
a
larger
number
of
chemicals.
2­
20
2­
21
Table
2­
5.
Number
of
Chemicals
Expected
to
be
Reported
for
Each
Option
Option
Partial
Form
Full
Form
Threshold
Level
(
lbs)
Number
of
Discrete
Chemicals
Threshold
Level
(
lbs)
Number
of
Discrete
Chemicals
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)
Inorganic
Chemical
s
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)
Inorganic
Chemicals
First
Reporting
Year
Baseline
10,000
8,915
0
N/
A
0
0
1
(
Selected)
25,000
3,771
1,117
300,000
3,977
0
2
25,000
2,303
1,117
100,000
5,445
0
3
25,000
4,366
1,117
500,000
3,382
0
4
25,000
5,079
1,117
1,000,000
2,669
0
5a
25,000
4,366
1,117
500,000
3,382
0
6
25,000
2,303
0
100,000
5,445
0
7
25,000
2,303
1,117
100,000
5,445
0
8
25,000
2,303
1,117
100,000
5,445
0
Future
Reporting
Years
Baseline
10,000
8,915
0
N/
A
0
0
1
(
Selected)
25,000
3,771
484
300,000
3,977
633
2
25,000
2,303
272
100,000
5,445
845
3
25,000
4,366
570
500,000
3,382
547
4
25,000
5,079
673
1,000,000
2,669
444
5a
25,000
2,303
272
100,000
5,445
845
6
25,000
2,303
0
100,000
5,445
0
7
25,000
2,303
272
100,000
5,445
845
8
25,000
2,303
272
100,000
5,445
845
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.
2­
22
14These
real
resource
costs
are
distinguished
from
tax
transfers
to
or
from
the
government,
which
have
no
net
effect
on
social
costs.

3­
1
SECTION
3
SOCIAL
COSTS
OF
REGULATORY
OPTIONS
This
section
analyzes
the
social
costs
associated
with
the
IUR
amendments.
Social
cost
analysis
of
regulatory
actions
attempts
to
measure
the
economic
value
of
the
opportunities
foregone
to
comply
with
the
regulation.
Resources
committed
to
producing
and
reporting
information
on
the
presence
and
use
of
toxic
chemicals
(
e.
g.,
TSCA
Section
8
reporting
rules)
could
also
be
productive
elsewhere
in
the
economy.
Thus,
the
opportunity
cost
of
devoting
those
resources
to
these
prescribed
activities
equals
their
value
in
other
uses.
Some
of
the
social
cost
components
to
consider
in
an
economic
analysis
are
compliance
costs;
government
administration,
monitoring,
and
enforcement;
foregone
economic
surpluses;
transitional
costs;
and
indirect
(
long­
run)
efficiency
costs.
These
components
are
explained
in
more
detail
in
subsequent
paragraphs.
Compliance
costs,
in
general,
include
expenditures
associated
with
abatement
activities,
waste
recovery,
reporting
and
recordkeeping,
or
other
changes
in
the
production
process
required
to
comply
with
a
regulation.
These
costs
are
borne
directly
by
the
owners
of
the
regulated
entities,
but
they
may
be
partly
or
completely
passed
on
to
other
parties
in
society
through
market
interactions.
For
the
IUR
amendments,
the
incremental
compliance
costs
are
assumed
to
be
limited
to
labor
hours
required
to
comply
with
additional
reporting
requirements.
Government
administration,
monitoring,
and
enforcement
costs
are
borne
by
the
taxpayers
who
support
regulatory
government
agencies
(
such
as
EPA
and
state
environmental
agencies)
that
develop,
administer,
and
enforce
environmental
regulations.
Administrative
and
enforcement
activities
involve
real
resource
expenditures
that
could
be
spent
on
the
provision
of
alternative
goods
and
services,
and
these
activities
impose
social
opportunity
costs
that
must
be
accounted
for
in
the
economic
analysis.
14
Foregone
economic
surpluses
are
incurred
when
a
regulation
affects
the
production
or
use
of
goods
and
services
traded
in
markets.
The
opportunity
cost
of
these
actions
is
captured
in
measures
of
producer
and
consumer
surplus
from
the
markets
affected
by
the
regulation.
Producer
and
consumer
surplus
measures
account
for
changes
in
economic
behavior
brought
about
by
the
compliance
cost
requirements,
which
distinguishes
these
measures
from
compliance
cost
measures.
For
instance,
if
the
costs
of
compliance
cause
producers
to
raise
the
market
price,
consumers
will
presumably
respond
by
reducing
consumption
or
switching
to
a
substitute.
This
foregone
consumption
of
the
regulated
product
leads
to
a
reduction
in
consumer
welfare;
this
reduction
is
measured
as
the
change
in
consumer
surplus.
Similarly,
3­
2
unless
producers
can
collectively
raise
the
price
enough
to
offset
the
compliance
costs,
the
net
price
of
the
regulated
product
will
fall
for
producers.
In
this
case,
the
producers
will
presumably
respond
by
reducing
production
or
switching
to
a
substitute
output.
This
action
entails
reductions
in
producer
welfare
(
profits),
as
measured
by
the
change
in
producer
surplus.
Transitional
costs
are
costs
not
captured
in
compliance,
administration,
and
enforcement
cost
measures,
but
that
do
involve
resource
costs
resulting
from
the
economy's
transition
from
a
pre­
regulation
to
a
regulated
state.
An
example
may
be
costs
associated
with
unemployment
resulting
from
the
regulation
or
mandated
obsolescence
of
otherwise
useful
capital.
The
costs
of
these
impacts
are
often
difficult
to
quantify.
Indirect
(
long­
run)
efficiency
costs
can
potentially
result
from
diverting
resources
toward
environmental
compliance
activities.
As
resources
are
moved
towards
these
activities,
product
quality,
innovation,
and
productivity
may
be
affected.
Any
negative
effects
on
these
factors
add
to
the
social
cost
of
the
regulation;
positive
effects
reduce
social
costs.
General
equilibrium
models
are
sometimes
used
to
estimate
the
indirect
impact
of
regulations
on
these
elements
of
long­
run
economic
efficiency.
Although
a
consideration
of
market
responses
is
required
for
strict
consistency
with
economic
theory,
the
relatively
small
size
of
the
compliance
costs
associated
with
the
IUR
amendments,
and
their
lack
of
correspondence
with
output
(
i.
e.,
reporting
requirements
are
assumed
not
to
alter
firms'
production),
suggests
behavioral
responses
will
be
minimal.
Therefore,
the
focus
of
this
analysis
is
on
the
first
two
categories:
compliance
costs
and
government
administration
costs.
This
section
presents
an
analysis
of
the
increase
in
compliance
costs
borne
by
IUR
respondents
relative
to
the
original
IUR
(
referred
to
as
the
incremental
cost
of
the
IUR
amendments).
In
addition,
it
provides
an
analysis
of
EPA
costs
under
the
IUR
amendments.
Finally,
the
social
costs
incurred
as
a
result
of
the
IUR
amendments
are
summarized.

3.1
Compliance
Costs
for
IUR
Submitters
Figure
3­
1
provides
a
graphic
representation
of
the
allocation
of
IUR
reporting
costs
expected
under
the
IUR
amendments
in
relation
to
the
original
IUR.
The
relative
costs
borne
by
industry
for
reporting
site
and
manufacturing
information,
and
processing
and
use
information
are
presented
in
relation
to
the
expected
number
of
reports
at
the
10,000
pound,
25,000
pound,
and
300,000
pound
reporting
thresholds.
As
the
figure
indicates,
some
chemicals
that
are
reported
under
the
current
IUR
(
those
with
a
production
volume
between
10,000
pounds
and
25,000
pounds)
will
not
be
required
to
report
under
the
IUR
amendments.
In
addition,
chemicals
manufactured
above
a
25,000
pound
threshold
will
be
required
to
report
additional
site
and
manufacturing
information
and
those
above
a
300,000
pound
threshold
will
report
processing
and
use
information,
as
well
as
the
site
and
manufacturing
information.
The
Agency
used
a
four­
step
methodology
to
estimate
the
incremental
compliance
costs
of
the
IUR
amendments.
This
section
describes
that
methodology
and
the
data
used
for
the
compliance
cost
analysis.
This
section
also
explains
the
3­
3
compliance
cost
calculations
and
summarizes
the
compliance
costs.
Finally,
limitations
of
the
analysis
are
discussed.
3­
4
3­
5
Processing
and
Use
Information
Additional
Facility
and
Manufacturing
Information
Current
IUR
Information
Type
of
Information
10K­
25K
Production
Volume
Type
of
Reporting
Form
C
A
B
D
E
F
G
H
I
Partial
Form
25K­
300K
Production
Volume
(
and
partial
exemption
chemicals)
Full
Form
>
300K
Production
Volume
Increase
in
Costs
under
Amendments
Reduction
in
Costs
under
Amendments
Identification
of
Information
Reporting
Costs:

A,
B:
Processing
and
use
information
reporting
costs
and
the
additional
site
and
manufacturing
information
reporting
costs
required
under
the
amended
IUR
are
not
incurred
for
production
volumes
between
10,000
and
25,000
pounds
under
either
the
current
or
amended
IUR
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
300,000
pounds)
or
the
partial
exemptions.
E,
H:
Site
and
manufacturing
information
reporting
costs.
These
costs
are
incurred
for
both
full
and
partial
forms
under
the
amended
IUR
but
are
not
incurred
under
the
current
IUR
requirements.
F,
I:
Reporting
costs
that
are
incurred
for
all
companies
filing
reports
under
both
the
current
IUR
and
the
amended
IUR
requirements.
G:
Processing
and
use
information
reporting
costs
for
companies
completing
the
full
form.
These
costs
are
incurred
under
the
amendments
but
are
not
incurred
under
the
existing
IUR
information
requirements.

Incremental
Costs
of
Amendments:
E+
H+
G
B
C
Figure
3­
1.
Allocation
of
Incremental
IUR
Amendments
Reporting
Costs
15The
methodology
for
estimating
the
compliance
costs
of
the
IUR
amendments
requires
estimating
the
cost
of
complying
with
the
existing
IUR.
Only
the
incremental
costs
of
complying
with
the
amendments
are
presented
in
this
section.
The
costs
of
complying
with
the
current
IUR
are
presented
in
Appendix
D.

3­
6
3.1.1
Methodology
for
Compliance
Cost
Analysis
The
following
general
methodology
was
employed
for
estimating
the
incremental
compliance
costs
of
the
IUR
amendments:


Step
1:
Identify
the
tasks
that
sites
perform
to
comply
with
reporting
requirements
for
both
the
original
IUR
and
for
the
IUR
amendments.
15

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


Step
3:
Determine
the
expected
number
of
sites
and
reports
filed
under
the
original
IUR
and
the
number
expected
to
be
reported
under
the
IUR
amendments.


Step
4:
Multiply
the
cost
per
form
times
the
number
of
forms
to
determine
the
estimated
total
costs
of
compliance
for
both
the
current
IUR
and
the
amended
IUR,
then
subtract
the
cost
of
the
current
IUR
from
the
cost
of
the
amended
IUR
to
calculate
the
incremental
costs
of
the
amendments.
Each
of
these
steps
is
outlined
in
more
detail
in
the
following
four
subsections.

3.1.1.1
Identify
Tasks
Compliance
with
the
original
IUR
and
with
the
IUR
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
on
the
type
of
chemical,
company
size,
and
the
variety
of
uses
of
the
chemical.
The
procedure
for
compliance
with
the
original
IUR
and
the
IUR
amendments
is
as
follows:


Compliance
Determination:
For
chemicals
produced
at
or
imported
to
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
fall
into
one
of
the
categories
exempt
from
reporting,
(
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)?
This
task
is
considered
to
be
incurred
at
the
site
level
because
the
majority
of
the
time
required
for
this
task
involves
identifying
the
requirements.
The
next
step
is
to
determine
whether
any
chemicals
produced
at
the
site
meet
these
requirements.
This
portion
of
the
compliance
determination
cost
depends
on
the
number
of
chemicals.
For
most
chemicals,
however,
this
component
of
the
burden
would
be
extremely
small.
For
simplicity,
this
cost
is
considered
16The
incremental
burden
of
compliance
determination
for
chemicals
produced
in
quantities
less
than
25,000
pounds
is
assumed
to
be
zero.
It
is
assumed
that
companies
reporting
under
the
current
IUR
will
spend
the
same
amount
of
time
verifying
whether
the
chemicals
they
produce
in
volumes
between
10,000
and
25,000
pounds
need
to
report
as
they
did
before
the
rule
change
because
they
will
simply
continue
to
verify
whether
reporting
is
required
for
all
chemicals.

3­
7
to
be
a
per­
site
cost,
as
opposed
to
a
per­
report
cost
(
see
Section
3.1.1.3
for
more
detail
on
the
distinction
between
per­
site
and
per­
report
costs).
16

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
IUR
amendments
add
exposure­
related
information
to
the
original
reporting
requirements,
change
the
reporting
cycle,
and
amend
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
including
all
of
the
reports
from
that
site
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:
Submitters
must
keep
records
supporting
their
submissions.
Currently
submitters
are
required
to
keep
their
records
for
four
years.
Under
the
amended
IUR,
submitters
must
retain
records
for
five
years.
EPA
estimated
the
hours
required
for
each
of
these
tasks,
including
the
total
time
needed
to
report
and
the
incremental
labor
hours
necessary
to
comply
with
the
additional
requirements
under
the
IUR
amendments.
These
estimates
are
presented
below.

3.1.1.2
Determine
Unit
Costs
To
calculate
costs
of
compliance
associated
with
the
IUR
amendments,
it
is
necessary
to
estimate
both
the
costs
associated
with
the
original
requirements
and
costs
anticipated
when
the
IUR
amendments
go
into
effect.
Unit
costs
of
reporting
for
both
the
IUR
amendments
and
the
original
IUR
were
developed
based
on
estimates
of
the
wage
rates
and
labor
requirements,
by
labor
category,
for
various
activities.
Although
the
development
of
the
baseline
costs
of
the
current
IUR
is
not
shown
in
this
section,
the
baseline
costs
are
provided
in
Appendix
D
for
comparison
purposes.


Estimates
of
Wage
Rates:
Estimates
for
wage
rates
were
developed
for
clerical,
technical,
and
managerial
staff.
A
more
detailed
description
of
the
method
used
to
develop
these
estimates
is
presented
below.
17The
survey
and
its
results
are
presented
in
Appendix
E.

3­
8

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
presented
later
in
this
section.
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
(
EPA,
1997a).
Data
used
to
develop
basic
wage
rates
were
derived
from
1993
salary
information
published
by
BLS
for
all
goods­
producing,
private
industries
and
were
inflated
to
current
dollars
as
described
in
Section
3.1.2.1.
Four
BLS
occupation
categories
were
analyzed:
engineers,
accountants,
attorneys,
and
secretaries.
Estimates
of
costs
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
from
an
industry
survey17
in
cases
where
previous
analyses
did
not
accurately
reflect
the
specific
reporting
requirements
of
the
IUR
amendments.
The
procedures
used
to
develop
the
reporting
burden
estimates
are
as
follows:


review
comparable
reporting
requirements
for
other
rules;


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


develop
new
estimates
as
necessary;
and

present
the
hours
of
labor
required
(
by
staff
level)
for
each
task
associated
with
the
amended
and
original
reporting
requirements.
Note
that
the
analysis
of
burden
is
segmented
between
organic
chemicals
(
including
petroleum
process
stream
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.

3.1.1.3
Determine
Number
of
Forms
and
Reports
In
1998,
the
most
recent
reporting
year,
more
than
26,000
reports,
covering
over
8,900
chemicals,
were
received
during
the
IUR
reporting
cycle
(
CUS
Database,
2000).
The
reporting
instrument
for
the
IUR
is
the
Form
U.
Each
reporting
site
is
only
required
to
file
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;
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
to
the
site.
If
there
are
multiple
chemicals
produced
at
a
single
site,
multiple
reports
are
prepared,
and
the
reports
are
submitted
together
as
a
single
Form
U.
EPA
18The
amendments
include
a
partial
exemption
for
certain
chemicals
termed,
for
the
purposes
of
IUR
amendments,
"
petroleum
process
stream
chemicals,"
as
well
as
a
full
exemption
for
certain
forms
of
natural
gas.
Chemicals
with
a
partial
exemption
only
have
to
provide
site
and
manufacturing
information.
They
are
exempt
from
reporting
processing
and
use
information
regardless
of
production
volume.
Inorganic
chemicals
have
a
partial
exemption
from
reporting
in
the
first
reporting
year
only.
In
future
reporting
years,
they
are
subject
to
the
same
threshold
for
full
reports
as
organic
chemicals.

3­
9
therefore
estimated
some
costs
on
a
per­
report
basis
and
some
on
a
per­
site
basis.
Per­
report
costs
are
costs
incurred
through
completion
of
the
individual
reports
for
each
reportable
chemical.
Per­
site
costs
are
incurred
one
time
for
each
site
through
completion
of
the
Form
U.
Each
site
must
determine
whether
it
must
comply
with
the
IUR
and
then
must
familiarize
itself
with
rule
requirements.
The
costs
associated
with
these
tasks
are
calculated
per
site.
For
each
reportable
chemical,
a
report
must
be
prepared
and
submitted
and
a
record
of
it
must
be
kept;
therefore,
reporting
and
recordkeeping
costs
are
calculated
as
per­
report
costs.
However,
in
calculating
reporting
costs,
note
that
Part
I
of
Form
U
(
Facility
Identification
Information)
is
common
to
all
chemical
reports
and
must
be
completed
only
once
regardless
of
the
number
of
chemical
reports
submitted.
Therefore,
to
obtain
per­
report
burden
hours
for
Company
Information
and
Plant
Site
Identification,
the
burden
of
filling
out
this
information
was
divided
by
the
number
of
reports
submitted
per
Form
U.
Although
the
Form
U
only
needs
to
be
certified
once,
the
labor
hours
required
for
certification
were
not
scaled
by
the
number
of
reports
per
Form
U
based
on
the
assumption
that
verification
of
information
included
in
the
Form
U
must
be
done
for
each
report
before
the
certification
is
completed.
This
may
potentially
overstate
the
burden
of
certification
if
the
time
to
certify
the
accuracy
of
the
Form
U
is
not
directly
proportional
to
the
number
of
chemical
reports
submitted.
Estimates
of
the
total
number
of
reports
expected
under
the
IUR
amendments
are
determined
using
data
compiled
from
EPA's
Chemical
Update
System
(
CUS)
and
EPA's
Chemicals
in
Commerce
Information
System
(
CICIS).
The
CUS
database
contains
information
collected
under
the
IUR
for
the
1986,
1990,
1994,
and
1998
reporting
cycles,
and
is
used
to
generate
estimates
of
expected
reports
for
organic
chemicals.
The
CICIS
database
is
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
amendments.
The
total
number
of
reports
is
broken
down
into
those
that
must
file
full
reports
and
those
that
must
file
partial
reports
because
of
the
difference
in
cost
between
the
two
types
of
reports.
18
3­
10
3.1.1.4
Determine
Total
Costs
of
Compliance
The
total
industry
compliance
cost
of
reporting
under
both
the
current
IUR
and
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
amendments
consist
of
compliance
determination;
rule
familiarization;
preparation
and
submission
of
reports,
including
CBI
determination
and
substantiation;
and
recordkeeping.
To
calculate
the
incremental
costs
of
the
IUR
amendments,
the
incremental
costs
per
unit
(
either
per
site
or
per
report)
were
calculated
for
each
task
and
multiplied
by
the
number
of
units
for
that
task.
These
costs
were
then
added
together
to
get
the
total
incremental
cost.
It
is
important
to
note
that
all
cost
estimates
are
estimates
of
the
average
cost
and
may
not
represent
the
actual
costs
of
all
firms.

3.1.2
Data
for
Compliance
Cost
Analysis
The
compliance
cost
analysis
uses
estimates
of
wage
rates,
estimates
of
labor
hours,
and
estimates
of
the
number
of
sites
and
reports.

3.1.2.1
Estimates
of
Wage
Rates
As
presented
in
Table
3­
1,
the
managerial­
and
technical­
level
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
are
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
(
EPA,
1997a).
19The
three
labor
rates
were
each
adjusted
using
separate
ECI
categories.
The
clerical
rate
was
adjusted
using
the
Administrative
Support,
including
Clerical
Occupations
data,
the
technical
rate
was
adjusted
using
the
Professional
Specialty
and
Technical
Occupations
data,
and
the
managerial
rate
was
adjusted
using
the
Executive,
Administrative,
and
Managerial
Occupations
data.

3­
11
The
1993
composite
annual
salary
estimates
were
adjusted
to
first­
quarter
2000
dollars
using
the
Employment
Cost
Index
(
ECI)
for
white­
collar
occupations
in
private
industries.
19
The
2000
adjusted,
composite
salaries
for
the
managerial,
technical,
and
clerical
labor
categories
were
then
multiplied
by
benefits
and
overhead
factors
to
estimate
2000
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
Table
3­
1.
Loaded
Hourly
Wage
Rates
by
Labor
Category
Occupation
(
levels)
Average
Salary
($
1993)
Weighting
Factor
Comp.
Salarya
($
1993)
ECI
Ratio
3/
00:
6/
93b
Adjusted
Salary
($
2000)
2000
Benefits
(%
Salary)
2000
Overhead
(%
Salary)
Loaded
Annual
Salary
($
2000)
Loaded
Hourly
Rate
($
2000)

Managerial
Engineer
(
6­
8)
$
93,981
10/
17
$
55,283
Attorney
(
4­
6)
$
111,263
5/
17
$
32,724
Accountant
(
5­
6)
$
73,528
2/
17
$
8,650
Composite
17/
17
$
96,658
1.33
$
128,555
37.6%
17.0%
$
198,746
$
95.55
Technical
Engineer
(
3­
8)
$
74,802
5/
6
$
62,335
Accountant
(
3­
6)
$
59,436
1/
6
$
9,906
Composite
C
6/
6
$
72,241
1.23
$
88,856
37.4%
17.0%
$
137,194
$
65.96
Clerical
Secretary
(
1­
5)
$
28,850
1/
1
$
28,850
Composite
C
1/
1
$
28,850
1.26
$
36,351
39.6%
17.0%
$
56,926
$
27.37
a
1993
composite
salaries
were
determined
by
multiplying
average
salaries
by
the
weighting
factor
and
summing
across
occupations.
b
The
ECI
ratio
measures
the
change
in
wages
and
salaries
between
June
1993
and
March
2000.

Sources:
U.
S.
Environmental
Protection
Agency.
April
1997a.
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313.
Office
of
Pollution
Prevention
and
Toxics,
Regulatory
Impacts
Branch.

Bureau
of
Labor
Statistics
(
BLS).
2000.
Employment
Cost
Index.
<
www.
bls.
gov>.
As
obtained
April
28,
2000.
20The
contents,
administration,
and
results
of
the
survey
are
described
in
detail
in
Appendix
E.

21Please
note
that
the
draft
version
of
the
revised
Form
U
on
which
the
industry
survey
is
based
was
different
than
the
final
revised
Form
U
presented
in
Appendix
A.
Thus,
in
some
cases,
adjustments
were
necessary
to
use
the
survey
data
to
estimate
burden
to
comply
with
the
new
form.

3­
12
employee)
to
derive
the
loaded,
hourly
wage
rates
used
in
this
analysis
for
each
labor
category.

3.1.2.2
Estimates
of
Labor
Hours
The
baseline,
total,
and
incremental
costs
of
the
IUR
and
amendments
were
developed
through
an
analysis
and
comparison
of
the
time
required
to
report
the
type
of
information
required
for
compliance
with
both
the
original
and
amended
rule.
The
labor
hours
required
for
compliance
determination,
rule
familiarization,
and
recordkeeping
are
based
on
previous
EPA
studies
(
EPA,
1990;
EPA,
1997a).
However,
the
time
required
by
industry
to
prepare
and
submit
information
for
each
data
element
on
Form
U
is
unique
to
this
rule.
To
examine
this
issue,
the
Agency
developed
a
survey
to
assess
the
labor
hours
required
to
complete
each
section
of
the
amended
Form
U.
The
survey
was
administered
to
81
chemical
manufacturers
in
the
spring/
summer
of
1996.20
Table
3­
2
presents
the
estimates
of
reporting
burden
for
each
section
of
the
revised
Form
U
as
determined
from
the
survey
(
see
Appendix
E).
21
For
chemicals
produced
between
25,000
and
300,000
pounds
and
for
chemicals
meeting
the
partial
exemptions,
only
Sections
I,
II,
and
IV
of
the
revised
Form
U
must
be
completed.
Survey
respondents
provided
low
and
high
estimates
of
labor
hours
required
to
complete
each
task
for
each
of
the
three
staff
levels.
These
estimates
are
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
amendments.
The
estimates
in
Table
3­
2
are
the
foundation
of
the
estimates
of
baseline,
total,
and
incremental
costs
of
preparing
and
submitting
reports
under
the
proposal.
These
costs
are
presented
in
Section
3.1.3.
It
is
important
to
note
that,
although
the
IUR
amendments
only
require
that
industry
report
"
reasonably
ascertainable"
information
for
most
data
elements
and
"
readily
available"
information
for
downstream
processing
and
use
information,
the
survey
that
respondents
completed
did
not
mention
these
standards.
Thus,
survey
respondents
were
reporting
burden
estimates
assuming
a
much
higher
standard
of
information
than
EPA
will
require.
In
addition,
the
UEIP
program,
which
asked
respondents
to
report
chemical
information
very
similar
to
that
required
by
the
IUR,
also
asked
respondents
to
report
the
time
spent
preparing
the
UEIP
form
for
submission
(
EPA,
1997b).
Companies
reported
a
median
burden
of
8
hours
per
chemical
report,
with
a
mean
of
12
hours
per
chemical
report.
Both
of
these
factors
indicate
that
the
burden
estimates
derived
from
the
survey
may
overestimate
the
actual
burden.
3­
13
Table
3­
2.
Estimated
First­
Year
Industry
Reporting
Burden
for
Sections
of
Revised
Form
U
(
hours
per
section
for
each
report)

Task
Clerical
Hours
Technical
Hours
Managerial
Hours
Total
Part
I.
Site
Identification
Informationa
0.54
B
0.99
0.91
B
0.98
1.01
B
1.09
2.46
B
3.06
I.
Certification
0.46
B
0.89
0.81
B
0.89
0.97
B
1.05
2.25
B
2.82
II.
Company
Information
Company
Name,
Contact,
Address
0.03
B
0.04
0.04
B
0.04
0.02
B
0.02
0.09
B
0.10
D&
B
Number,
Mailing
Address
III.
Plant
Site
Identification
Plant
Name,
D&
B
Number,
Address
0.04
B
0.05
0.06
B
0.06
0.02
B
0.02
0.12
B
0.14
Mailing
Address
Part
II.
Manufacturing
Information
1.52
B
1.57
7.18
B
10.38
2.35
B
4.64
11.05
B
16.59
I.
Chemical
Identification
II.
(
Other)
Manufacturing
Information
Site
Limited
0.49
B
0.55
1.97
B
2.59
0.28
B
0.84
2.75
B
3.98
Activity
Production
Volume
(
lbs)
Chemical
Identification
Up­
front
CBI
Substantiation
0.26
B
0.26
1.08
B
1.82
0.48
B
1.05
1.82
B
3.13
Plant
Site
Up­
front
CBI
Substantiation
0.12
B
0.12
0.54
B
1.12
0.23
B
0.79
0.88
B
2.03
Total
Number
of
Workers
0.21
B
0.21
1.13
B
1.73
0.29
B
0.88
1.63
B
2.82
Maximum
Concentration
0.44
B
0.44
2.46
B
3.12
1.07
B
1.07
3.98
B
4.64
Physical
Form,
Percent
of
Production
Volumeb
C
C
C
C
Part
III.
Processing
and
Use
Information
8.70
B
9.98
51.21
B
55.3
9
18.99
B
20.25
78.91
B
85.62
I.
Industrial
Processing
and
Use
Exposure
Related
Data
7.99
B
9.27
46.32
B
49.9
6
17.53
B
18.66
71.84
B
77.89
Determination
of
Applicability
0.15
B
0.15
1.13
B
1.24
0.32
B
0.35
1.60
B
1.74
Industrial
Function
Category
2.17
B
2.80
5.02
B
5.36
2.43
B
2.43
9.63
B
10.59
Function
Code
0.22
B
0.22
1.04
B
1.16
0.46
B
0.47
1.71
B
1.85
Percent
Production
Volume
1.45
B
1.45
11.36
B
12.1
7
5.78
B
6.63
18.59
B
20.26
Total
Number
of
Processing
and
Use
Sites
1.56
B
2.14
10.17
B
11.3
4
4.11
B
4.18
15.84
B
17.66
Total
Number
of
Potentially
Exposed
Workers
2.44
B
2.51
17.61
B
18.6
9
4.41
B
4.60
24.46
B
25.79
II
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
0.71
B
0.71
4.89
B
5.43
1.47
B
1.59
7.07
B
7.73
Determination
of
Applicability
0.17
B
0.17
1.07
B
1.13
0.28
B
0.31
1.52
B
1.61
Identification
of
Product
Category/
Children's
Use
0.17
B
0.17
0.92
B
1.05
0.28
B
0.30
1.37
B
1.53
Percent
Production
Volume
0.24
B
0.24
1.40
B
1.56
0.51
B
0.55
2.15
B
2.35
Maximum
Concentration
by
Category
0.13
B
0.13
1.51
B
1.69
0.39
B
0.42
2.03
B
2.25
Part
IV.
Reassertion
of
Past
CBI
Claimsc
C
C
C
C
Total
Hours
for
Report
Preparation
and
Submission
Partial
Form
2.06
B
2.56
8.09
B
11.36
3.37
B
5.73
13.51
B
19.65
Full
Form
10.76
B
12.5
4
59.30
B
66.7
5
22.36
B
25.98
92.42
B
105.2
7
Notes:
1.
Shaded
area
represents
original
requirements;
the
unshaded
area
represents
the
additional
requirements
of
the
amended
IUR.
2.
The
sum
of
the
components
under
a
particular
information
category
may
not
equal
total
due
to
independent
rounding.
3­
14
a
The
burden
associated
with
determining
facility
identification
information
has
been
adjusted
to
account
for
the
additional
information
required
under
the
IUR
amendments.
The
baseline
burden
associated
with
providing
facility
identification
information
is
presented
in
Table
D­
3.
b
The
burden
associated
with
physical
form
reporting
is
subsumed
within
the
chemical
identification
reporting
estimate
above.
c
No
reassertion
is
required
in
the
first
reporting
year.
In
future
years,
labor
hours
will
be
required
for
CBI
reassertion
as
outlined
in
Section
3.1.3.

Sources:
U.
S.
Environmental
Protection
Agency.
April
14,
1994.
Regulatory
Impact
Analysis
of
Amendments
to
Regulations
for
TSCA
Section
5
Premanufacture
Notifications.
Office
of
Pollution
Prevention
and
Toxics,
Regulatory
Impacts
Branch.
Appendix
D.
3­
15
3.1.2.3
Estimates
of
the
Number
of
Sites
and
Reports
The
number
of
reports
expected
and
the
number
of
sites
filing
those
reports
under
both
the
baseline
and
the
amended
IUR
are
estimated
based
on
the
CUS
and
CICIS
databases.
Table
3­
3
displays
the
number
of
reports
and
sites
expected
under
baseline
conditions
and
under
the
amendments
to
the
IUR.
This
information
is
used
to
aggregate
the
unit
costs
to
reflect
the
population
of
affected
firms.

3.1.3
Compliance
Cost
Calculations
The
costs
of
compliance
under
the
IUR
amendments
are
estimated
in
this
section.
Incremental
unit
costs
are
presented
based
on
the
four
steps
for
compliance
(
see
Section
3.1.1.1):
compliance
determination,
rule
familiarization,
report
preparation
and
submission,
and
recordkeeping.
Costs
were
estimated
as
either
per­
site
or
perreport
depending
on
the
way
the
costs
are
incurred.
Compliance
determination
and
rule
familiarization
were
estimated
as
per­
site
costs,
while
report
preparation
and
submission
and
recordkeeping
were
estimated
as
per­
report
costs.
The
incremental
unit
costs
were
then
combined
with
the
numbers
of
reports
and
sites
to
estimate
the
cost
of
compliance
in
the
first
reporting
year
and
in
future
reporting
years.
From
these
Table
3­
3.
Estimated
Number
of
Sites,
Reports,
and
Discrete
Chemicals
by
Chemical
Typea
Number
of
Sites
Number
of
Reports
Number
of
Discrete
Chemicalsb
Type
of
Chemical
Partial
Full
Partial
Full
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)

Baseline
2,666
26,365
0
8,915
0
IUR
Amendments
2,482
12,501
9,759
3,359
4,389
Inorganic
Chemicals
Baseline
0
0
0
0
0
IUR
Amendments
First
Reporting
Year
544
4,537
0
1,117
0
Future
Reporting
Years
544
1,965
2,571
484
633
a
Petroleum
process
stream
chemicals
do
not
have
to
report
processing
and
use
information
regardless
of
production
volume.
Inorganic
chemicals
do
not
have
to
report
processing
and
use
information
in
the
first
year
of
reporting,
but
in
all
future
years
are
subject
to
the
same
300,000
pound
threshold
for
reporting
this
information
as
organic
chemicals.
b
These
columns
refer
to
the
number
of
discrete
chemicals
for
which
partial
reports
and
full
reports
are
submitted.
22This
is
because
the
entire
burden
of
rule
familiarization
is
incremental
for
those
sites
that
did
not
have
to
report
in
the
past.

3­
16
values,
the
net
present
value
of
the
costs
and
the
annualized
cost
over
a
20­
year
period
were
calculated.

3.1.3.1
Labor
Hours
Required
for
Compliance
Tasks
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
determination
attributable
to
the
amendments
is
zero
for
those
sites
already
reporting
under
the
original
IUR.
For
sites
not
reporting
under
the
original
IUR
(
such
as
inorganic
chemical
companies),
the
incremental
labor
requirement
is
estimated
to
be
1
to
4
hours
of
technical
labor
to
review
production
and
import
data
for
all
chemicals
and
determine
whether
compliance
is
necessary.
These
estimates
are
presented
as
a
range
to
reflect
variation
in
the
reporting
community.
Sites
that
produce
fewer
chemicals
may
only
need
1
hour
to
determine
compliance,
while
sites
that
produce
numerous
chemicals
may
require
up
to
4
hours
(
EPA,
1990).
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.
Table
3­
4
presents
the
incremental
hours
required
for
compliance
determination
by
chemical
type
for
the
first
reporting
year
and
future
reporting
years.
Once
a
site
determines
that
reporting
is
required
under
the
IUR,
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
additional
hours
of
technical
labor
and
6
to
8
additional
hours
of
managerial
labor
relative
to
the
baseline
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.
22
Table
3­
5
provides
the
incremental
labor
required
for
rule
familiarization.
These
estimates
are
based
on
EPA's
estimate
that
rule
familiarization
for
the
TRI
requirements
requires
an
average
of
22.5
hours
of
technical
review
and
12
hours
of
managerial
review
(
EPA,
1997a).
The
scope
of
the
reporting
requirements
under
the
TRI
program
is
similar
to
the
IUR
amendments.
However,
the
requirements
under
the
TRI
program
are
more
complicated;
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
to
4.5
hours
of
technical
time
and
2
to
4
hours
of
managerial
time
relative
to
the
estimates
developed
for
rule
familiarization
with
the
TRI
requirements.
3­
17
In
future
reporting
years,
the
burden
of
rule
familiarization
under
the
amendments
is
estimated
to
be
equal
to
the
burden
under
the
current
IUR.
For
sites
currently
reporting,
there
is
no
incremental
burden
associated
with
the
amendments
as
these
parties
would
have
been
required
to
refamiliarize
even
without
the
amendments.
For
sites
new
to
reporting,
the
refamiliarization
burden
is
estimated
to
be
2
hours
of
technical
labor
and
2
hours
of
managerial
labor.
EPA
has
assumed
that
the
burden
of
rule
familiarization
is
incurred
in
both
first­
and
future­
year
reporting
because
of
the
length
of
the
time
3­
18
Table
3­
4.
Incremental
Labor
Hours
for
Compliance
Determination
(
hours
per
site)

Clerical
Technical
Managerial
Total
Low
High
Low
High
Low
High
Low
High
First
Reporting
Year
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)

PV

25K
lbsa
0
0
0
0
0
0
0
0
PV
>
25K
lbsb
0
0
0
0
0
0
0
0
Inorganic
Chemicals
PV

25K
lbsa
0
0
0
0
0
0
0
0
PV
>
25K
lbsb
0
0
1
4
0
0
1
4
Future
Reporting
Years
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)

PV

25K
lbsa
0
0
0
0
0
0
0
0
PV
>
25K
lbsb
0
0
0
0
0
0
0
0
Inorganic
Chemicals
PV

25K
lbsa
0
0
0
0
0
0
0
0
PV
>
25K
lbsb
0
0
1
4
0
0
1
4
a
As
compliance
determination
is
a
per­
site
cost,
this
only
applies
if
all
chemicals
produced
at
a
site
that
previously
reported
under
the
IUR
are
manufactured
or
imported
in
quantities
of
less
than
25,000
pounds.
b
This
burden
applies
for
sites
with
at
least
one
reportable
chemical
manufactured
or
imported
in
a
volume
of
greater
than
25,000
pounds.

Sources:
U.
S.
Environmental
Protection
Agency.
February
1990.
Economic
Analysis
for
the
TSCA
Inventory
Update
Final
Rule.
Office
of
Toxic
Substances,
Office
of
Pollution
Prevention
and
Toxics.

U.
S.
Environmental
Protection
Agency.
April
1997a.
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313.
Office
of
Pollution
Prevention
and
Toxics,
Regulatory
Impacts
Branch.
3­
19
between
reporting
cycles.
EPA
recognizes,
however,
that
the
burden
of
familiarization
in
future
years
is
likely
to
be
significantly
less
than
the
initial
first­
year
burden.
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.
Burden
and
cost
estimates
are
associated
with
this
process.
A
more
detailed
description
of
the
survey
results
on
which
these
burden
estimates
are
based
is
provided
in
Appendix
E.
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
amendments
add
requirements
for
information
related
to
worker
exposure
and
chemical
use.
The
costs
3­
20
associated
with
these
additional
data
elements
comprise
the
costs
of
the
proposal.
Box
3­
1
presents
these
additional
data
requirements.
Section
1.2
provides
a
more
detailed
discussion.
Table
3­
5.
Incremental
Labor
Hours
Required
for
Rule
Familiarization
(
hours
per
site)

Clerical
Technical
Managerial
Total
Low
High
Low
High
Low
High
Low
High
First
Reporting
Year
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)

PV

25K
lbsa
0
0
B
2
B
2
B
2
B
2
B
4
B
4
PV
>
25K
lbsb
0
0
16
18
6
8
22
26
Inorganic
Chemicals
PV

25K
lbsa
0
0
0
0
0
0
0
0
PV
>
25K
lbsb
0
0
18
20
8
10
26
30
Future
Reporting
Years
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)

PV

25K
lbsa
0
0
B
2
B
2
B
2
B
2
B
4
B
4
PV
>
25K
lbsb
0
0
0
0
0
0
0
0
Inorganic
Chemicals
PV

25K
lbsa
0
0
0
0
0
0
0
0
PV
>
25K
lbsb
0
0
2
2
2
2
4
4
a
As
compliance
determination
is
a
per­
site
cost,
this
only
applies
if
all
chemicals
produced
at
a
site
that
previously
reported
under
the
IUR
are
manufactured
or
imported
in
quantities
of
less
than
25,000
pounds.
b
This
burden
applies
for
sites
with
at
least
one
reportable
chemical
manufactured
or
imported
in
a
volume
of
greater
than
25,000
pounds.

Sources:
U.
S.
Environmental
Protection
Agency.
February
1990.
Economic
Analysis
for
the
TSCA
Inventory
Update
Final
Rule.
Office
of
Toxic
Substances,
Office
of
Pollution
Prevention
and
Toxics.

U.
S.
Environmental
Protection
Agency.
April
1997a.
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313.
Office
of
Pollution
Prevention
and
Toxics,
Regulatory
Impacts
Branch.
3­
21
Box
3­
1.
Comparison
of
Data
Elements
for
Completion
of
the
Original
and
Amended
Form
U
Baseline
Data
Elements
Certification

signature

date

name
and
title
of
the
representative
responsible
for
the
accuracy
of
the
information
provided
Company
Information

company
name

technical
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
Additions
under
IUR
Amendments
Estimates
for
the
amount
of
time
required
to
complete
and
submit
the
amended
Form
U
are
developed
from
the
results
of
the
survey
described
in
Appendix
E.
Survey
results
were
weighted
based
on
company
size
to
reflect
the
universe
of
companies
expected
to
report
under
the
amendments.
As
described
previously
in
this
report,
under
the
amendments,
submitters
of
certain
categories
of
chemicals
complete
a
partial
reporting
form,
reporting
only
the
site
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
300,000
pounds,
petroleum
process
stream
chemicals,
and
inorganic
chemicals
in
the
first
reporting
year.
The
remaining
chemicals
subject
to
IUR
reporting,
with
annual
production
volumes
greater
than
300,000
pounds,
must
complete
the
full
form,
which
requires
reporting
of
additional
information
on
industrial
processing
and
use
and
consumer/
commercial
use.
The
burden
associated
with
CBI
claims
is
accounted
for
in
a
variety
of
ways.
Up­
front
substantiation
burdens
are
accounted
for
separately,
as
reported
in
Table
3­
2.
The
burden
of
complying
with
these
requirements
and
the
frequency
of
CBI
claims
is
discussed
further
in
Box
3­
2.
Reassertion
of
CBI
claims
appears
in
Section
IV
of
Form
U.
For
the
first
year
of
reporting
under
the
amendments,
reassertion
is
not
required.
Therefore,
for
each
of
the
chemical
types,
the
time
required
for
CBI
reassertion
is
zero
in
the
first
year
of
reporting.
In
future
years,
firms
must
reassert
CBI
claims
made
in
previous
reporting
periods
to
maintain
the
CBI
status
of
this
information.
It
is
assumed
23This
value
is
based
on
EPA's
professional
judgment
of
the
time
required
to
reassert
relative
to
the
time
required
to
complete
a
report
originally.
Because
of
data
limitations,
a
simplifying
assumption
that
submitters
reassert
the
same
types
of
forms
(
i.
e.,
breakdown
between
full
and
partial
reports)
for
prior
periods
as
they
are
submitting
in
the
current
period
was
made.
This
assumption
may
cause
costs
to
be
understated
in
the
second
reporting
period
because
of
the
increase
in
the
proportion
of
full
reports
from
the
first
reporting
period
to
the
second.

24In
a
previous
version
of
this
report
(
EPA,
1999),
the
burden
estimated
for
CBI
reassertion
was
3.5
to
7
hours
for
both
full
and
partial
reports.
Upon
review,
EPA
anticipates
that
the
burden
for
reassertion
is
much
more
likely
to
be
proportional
to
the
burden
of
preparing
the
report
(
i.
e.,
a
full
report
that
contains
many
more
data
elements
is
likely
to
take
more
time
to
reassert
than
a
partial
report).
Based
on
professional
judgment,
EPA
believes
10
percent
of
the
original
time
required
to
prepare
and
submit
a
report
is
a
reasonable
burden
estimate
for
reassertion.
This
change
increased
the
estimated
burden
for
full
reports
and
decreased
the
estimated
burden
for
partial
reports
such
that
full
reports
are
estimated
to
require
about
5
to
7
times
as
many
hours
for
reassertion
as
partial
reports.
This
seems
reasonable
given
the
difference
in
the
quantity
of
data
that
must
be
examined
for
reassertion.

25Analysis
is
entitled
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313
(
EPA,
1997a).

3­
22
that
the
labor
required
for
reassertion
in
future
years
is
10
percent
of
the
labor
required
to
prepare
and
submit
a
report.
23,
24
In
addition
to
a
change
in
the
cost
of
CBI
reassertion
in
future
reporting
years,
it
is
also
assumed
that
the
burden
of
reporting
other
information
on
Form
U
changes
in
future
years.
Unit
costs
for
report
preparation
and
submission
in
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.
The
efficiency
gained
from
repeated
reporting
varies
based
on
the
types
of
information
reported
and
whether
that
information
changes
significantly
from
year
to
year.
Based
on
these
assumptions
and
a
cost
analysis
for
a
similar
reporting
rule,
25
scaling
factors
are
developed
for
each
section
of
the
reporting
form
under
the
IUR
amendments.
These
scaling
factors,
presented
in
Table
3­
6,
are
applied
to
the
report
preparation
and
submission
burden
in
each
reporting
period
following
the
first.
The
second
reporting
year
would
include
CBI
reassertion
claims
for
the
first
time;
hence,
the
burden
of
reassertion
is
first
incurred
during
the
second
reporting
period.
Table
3­
7
provides
estimates
of
the
incremental
labor
required
for
report
preparation
and
submission.
The
current
IUR
requires
that
sites
maintain
records
of
reported
information
for
at
least
four
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
amendments
will
be
somewhat
greater
than
the
burden
under
the
original
IUR
because
it
is
likely
submitters
would
maintain
3­
23
Box
3­
2.
Burden
of
Complying
with
CBI
Substantiation
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
3­
2
presents
typical
burden
associated
with
compliance
for
various
CBI
substantiation
issues
attributable
to
the
IUR
amendments.
Using
the
wage
rates
presented
in
Table
3­
1,
the
costs
of
up­
front
CBI
substantiation
range
from
$
185
to
$
380,
as
compared
to
$
125
to
$
227
under
the
current
IUR
requirements
because
of
the
additional
requirement
to
provide
up­
front
substantiation
for
plant
site
information.
This
results
in
incremental
costs
of
between
$
60
and
$
153.
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,
and
plant
site
CBI
identification,
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
nonzero
entries,
the
cost
of
CBI
compliance
ranges
from
$
204
to
$
360
for
the
baseline
scenario
and
from
$
363
to
$
738
under
the
amendments.
Based
on
these
values,
the
incremental
cost
of
meeting
CBI­
related
requirements
is
estimated
to
be
between
$
159
and
$
378,
or
about
twice
as
much
as
above.

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
(
1998
data
on
CBI
claims
were
unavailable
for
analysis)
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
and
plant
site
identification,
was
3
percent
and
20
percent,
respectively.
Survey
respondents
indicated
that
chemical
identification
and
plant
site
identification
would
be
claimed
confidential
by
58
percent
and
36
percent
of
reporting
companies,
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.

additional
records,
and
the
records
must
be
maintained
for
five
years
C
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.
Table
3­
8
provides
the
labor
required
to
comply
with
this
portion
of
the
regulation.
3­
24
3.1.3.2
Incremental
Costs
of
Compliance
Tasks
under
IUR
Amendments
Table
3­
6.
Scaling
Factors
for
Unit
Cost
of
Preparation
and
Submission
of
Reports
in
Future
Reporting
Cycles
Under
the
IUR
Amendments
Part­
Section
of
Reporting
Form
Description
of
Information
Incurred
Percent
of
First­
Year
Cost
Comments
Two­
Year
Reporting
Cycle
Four­
Year
Reporting
Cycle
Facility
Identification
and
Manufacturing
Information
I­
I
Certification
100
100
No
reduction
expected.

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

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

II­
I
Chemical
Identification
20
20
Information
unlikely
to
change.

II­
II
Manufacturing
70
80
Information
may
change.

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

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

Reassertion
of
Past
CBI
Claims
IV
Reassertion
100
100
No
reduction
expected
in
future
reporting
periods.
However,
reassertion
costs
are
not
incurred
in
the
first
reporting
year.
26Chemicals
with
production
volumes
less
than
25,000
pounds
are
denoted
by
"
PV<
25K
lbs,"
chemicals
with
production
volumes
between
25,000
and
300,000
pounds
and
chemicals
meeting
the
partial
exemption
requirements
are
denoted
by
"
Partial
Form,"
and
chemicals
with
production
volumes
greater
than
300,000
pounds
that
do
not
qualify
for
an
exemption
are
denoted
by
"
Full
Form."

3­
25
The
incremental
costs
of
compliance
with
the
IUR
amendments
are
presented
for
two
categories
of
reporting
at
the
site
level
(
production
volume
greater
than
or
less
than
25,000
pounds)
and
for
three
categories
of
reporting
at
the
report
level
(
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).
26
Tables
3­
9
through
3­
12
provide
the
incremental
costs
per
unit
associated
with
the
four
tasks
required
under
the
IUR
amendments.
All
industry
compliance
costs
are
assumed
to
be
incurred
in
the
year
in
which
reporting
occurs.
3­
26
Table
3­
7.
Incremental
Labor
Hours
for
Report
Preparation
and
Submission
(
hours
per
report)

Clerical
($
27.37/
hr)
Technical
($
65.96/
hr)
Managerial
($
95.55/
hr)
Total
Low
High
Low
High
Low
High
Low
High
First
Reporting
Year
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)
Form
U
Part
I.
Facility
Information
0.17
0.30
0.01
0.01
0.00
0.00
0.18
0.31
II.
Manufacturing
Information
0.77
0.77
4.13
5.97
1.59
2.75
6.48
9.48
III.
Processing
and
Use
Information
8.70
9.98
51.21
55.39
18.99
20.25
78.91
85.62
IV.
CBI
Reassertiona
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Incremental
Hours
by
Labor
Category
PV

25K
lbs
B
1.13
B
1.51
B
3.95
B
5.39
B
1.78
B
2.98
B
6.86
B
9.87
Partial
Form
0.93
1.06
4.14
5.98
1.59
2.75
6.66
9.79
Full
Form
9.63
11.04
55.35
61.37
20.58
23.00
85.57
95.42
Inorganic
Chemicals
Form
U
Section
I.
Facility
Information
0.54
0.99
0.91
0.98
1.01
1.09
2.46
3.06
II.
Manufacturing
Information
1.52
1.57
7.18
10.38
2.35
4.64
11.05
16.59
III.
Processing
and
Use
Information
8.70
9.98
51.21
55.39
18.99
20.25
78.91
85.62
IV.
CBI
Reassertiona
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Incremental
Hours
by
Labor
Category
PV

25K
lbs
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Partial
Form
2.06
2.56
8.09
11.36
3.37
5.73
13.51
19.65
Full
Form
10.76
12.54
59.30
66.75
22.36
25.98
92.42
105.27
Future
Reporting
Years
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)
Form
U
Section
I.
Facility
Information
0.14
0.26
0.00
0.00
0.00
0.00
0.14
0.26
II.
Manufacturing
Information
0.61
0.61
3.30
4.77
1.27
2.20
5.19
7.59
III.
Processing
and
Use
Information
6.96
7.98
40.97
44.31
15.19
16.20
63.13
68.50
IV.
CBI
Reassertion
C
Partial
Formb
0.19
0.24
0.73
1.02
0.30
0.52
1.22
1.77
CBI
Reassertion
C
Full
Formc
0.88
1.04
4.82
5.45
1.82
2.14
7.53
8.62
Incremental
Hours
by
Labor
Category
PV

25K
lbs
B
1.13
B
1.51
B
3.95
B
5.39
B
1.78
B
2.98
B
6.86
B
9.87
Partial
Form
0.94
1.11
4.03
5.79
1.57
2.72
6.54
9.62
Full
Form
8.59
9.89
49.10
54.54
18.29
20.54
75.98
84.97
Inorganic
Chemicals
Form
U
Section
I.
Facility
Information
0.52
0.96
0.90
0.98
1.01
1.09
2.43
3.03
II.
Manufacturing
Information
1.37
1.42
6.35
9.18
2.04
4.09
9.76
14.70
III.
Processing
and
Use
Information
6.96
7.98
40.97
44.31
15.19
16.20
63.13
68.50
IV.
CBI
Reassertion
C
Partial
Formb
0.19
0.24
0.42
1.02
0.30
0.52
1.22
1.77
CBI
Reassertion
C
Full
Formc
0.88
1.04
4.52
5.45
1.82
2.14
7.53
8.62
Incremental
Hours
by
Labor
Category
PV

25K
lbs
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Partial
Form
2.07
2.62
4.62
11.18
3.35
5.69
13.41
19.49
Full
Form
9.73
11.40
49.69
59.92
20.06
23.52
82.80
94.84
a
No
reassertion
is
required
in
the
first
reporting
year.
In
future
years,
labor
hours
will
be
required
for
CBI
reassertion
as
outlined
in
Section
3.1.3.
b
Labor
hours
for
CBI
reassertion
in
future
years
is
assumed
to
equal
10
percent
of
the
time
required
to
complete
3­
27
Table
3­
8.
Incremental
Labor
Hours
for
Recordkeeping
(
hours
per
report)

Clerical
Technical
Managerial
Total
Low
High
Low
High
Low
High
Low
High
First
Reporting
Year
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)

PV

25K
lbs
B
0.5
B
1
B
1
B
2
B
0.5
B
1
B
2
B
4
Partial
Form
0.5
1
1
2
0.5
1
2
4
Full
Form
0.5
1
1
2
0.5
1
2
4
Inorganic
Chemicals
PV

25K
lbs
0
0
0
0
0
0
0
0
Partial
Form
1
2
2
4
1
2
4
8
Full
Form
1
2
2
4
1
2
4
8
Future
Reporting
Years
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)

PV

25K
lbs
B
0.5
B
1
B
1
B
2
B
0.5
B
1
B
2
B
4
Partial
Form
0.5
1
1
2
0.5
1
2
4
Full
Form
0.5
1
1
2
0.5
1
2
4
Inorganic
Chemicals
PV

25K
lbs
0
0
0
0
0
0
0
0
Partial
Form
1
2
2
4
1
2
4
8
Full
Form
1
2
2
4
1
2
4
8
3­
28
Table
3­
9.
Incremental
Costs
of
Compliance
Determination
(
2000$)

Type
of
Chemical
Per­
Site
Cost
First
Reporting
Year
Future
Reporting
Years
Low
High
Low
High
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)

PV

25K
lbsa
$
0
$
0
$
0
$
0
PV
>
25K
lbsb
$
0
$
0
$
0
$
0
Inorganic
Chemicals
PV

25K
lbsa
$
0
$
0
$
0
$
0
PV
>
25K
lbsb
$
66
$
264
$
66
$
264
a
As
compliance
determination
is
a
per­
site
cost,
this
only
applies
if
all
chemicals
produced
at
a
site
that
previously
reported
under
the
IUR
are
manufactured
or
imported
in
quantities
of
less
than
25,000
pounds.
b
This
burden
applies
for
sites
with
at
least
one
reportable
chemical
manufactured
or
imported
in
a
volume
of
greater
than
25,000
pounds.

Table
3­
10.
Incremental
Costs
of
Rule
Familiarization
Per
Site
(
2000$)

Type
of
Chemical
Per­
Site
Cost
First
Reporting
Year
Future
Reporting
Years
Low
High
Low
High
Organic
Chemicals
(
including
petroleum
Process
Stream
Chemicals)

PV

25K
lbsa
B$
323
B$
323
B$
323
B$
323
PV
>
25K
lbsb
$
1,629
$
1,952
$
0
$
0
Inorganic
Chemicals
PV

25K
lbsa
$
0
$
0
$
0
$
0
PV
>
25K
lbsb
$
1,952
$
2,275
$
323
$
323
a
As
compliance
determination
is
a
per­
site
cost,
this
only
applies
if
all
chemicals
produced
at
a
site
that
previously
reported
under
the
IUR
are
manufactured
or
imported
in
quantities
of
less
than
25,000
pounds.
b
This
burden
applies
for
sites
with
at
least
one
reportable
chemical
manufactured
or
imported
in
a
volume
of
greater
than
25,000
pounds.
3­
29
3.1.4
Summary
of
Compliance
Costs
The
total
costs
to
industry
of
the
IUR
amendments
are
estimated
for
the
first
year
of
reporting
and
for
future
reporting
years
in
constant
2000
dollars.
Total
costs
were
calculated
based
on
the
unitcosts
and
the
number
of
reports
and
sites
estimated
earlier
in
this
section.
These
costs
were
developed
based
on
costs
for
each
type
of
Table
3­
11.
Incremental
Costs
of
Report
Preparation
and
Submission
Per
Report
(
2000$)

Type
of
Chemical
First
Reporting
Year
Future
Reporting
Years
Low
High
Low
High
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)

PV

25K
lbs
$
0
$
0
$
0
$
0
Partial
Form
$
451
$
686
$
442
$
672
Full
Form
$
5,882
$
6,548
$
5,221
$
5,830
Inorganic
Chemicals
PV

25K
lbs
$
0
$
0
$
0
$
0
Partial
Form
$
912
$
1,367
$
903
$
1,353
Full
Form
$
6,343
$
7,221
$
5,683
$
6,512
Table
3­
12.
Incremental
Costs
of
Recordkeeping
per
Report
(
2000$)

Type
of
Chemical
First
Reporting
Year
Future
Reporting
Years
Low
High
Low
High
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)

PV

25K
lbs
B$
127
B$
255
B$
127
B$
255
Partial
Form
$
127
$
255
$
127
$
255
Full
Form
$
127
$
255
$
127
$
255
Inorganic
Chemicals
PV

25K
lbs
$
0
$
0
$
0
$
0
Partial
Form
$
255
$
510
$
255
$
510
Full
Form
$
255
$
510
$
255
$
510
27Table
3­
3
presents
the
estimated
number
of
reports
and
reporting
sites
under
the
amendments.
The
estimates
in
this
table
were
used
to
develop
the
incremental
costs
associated
with
each
compliance
task
in
Tables
3­
9
through
3­
12
and
industry­
wide
incremental
costs
of
the
IUR
amendments
in
Tables
3­
13
through
3­
15.

28Further
discussion
of
the
approach
used
to
develop
the
appropriate
discount
rate
is
presented
in
Appendix
E.

3­
30
chemical
(
i.
e.,
organic
chemicals,
or
inorganic
chemicals)
and
for
the
two
report
types
(
full
or
partial
form,
based
on
production
volume
and
exemption
status).

3.1.4.1
Compliance
Costs
under
Amendments
Incremental
costs
for
the
amendments
were
developed
by
combining
information
from
Tables
3­
3,
3­
9,
3­
10,
3­
11,
and
3­
12.27
These
costs
are
presented
for
organic
chemicals
and
inorganic
chemicals
in
Tables
3­
13
and
3­
14,
respectively.
Table
3­
15
provides
the
total
incremental
cost
associated
with
the
IUR
amendments
and
Table
3­
16
presents
the
total
incremental
burden
hours
associated
with
the
IUR
amendments.
Because
the
benefits
resulting
from
the
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.
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.
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
by
compliance
requirements.
The
issues
involving
the
appropriate
discount
rates
and
procedures
are
complex
and
are
not
likely
to
be
resolved
soon.
Much
of
the
recent
economics
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
environmentalrelated
health
effects
differs
from
financial
rates
of
return
and
cite
evidence
that
a
2
percent
rate
is
appropriate.
Lind
(
1990)
recommends
a
range
of
1
to
3
percent,
and
Freeman
(
1993)
recommends
2
to
3
percent.
Based
on
this
information,
this
analysis
uses
a
3
percent
discount
rate.
28
The
results
of
an
analysis
using
a
7
percent
discount
rate
are
presented
in
Appendix
F
for
comparison.
Table
3­
17
shows
the
flow
of
compliance
costs
over
a
20­
year
period.
3.1.4.2
Compliance
Costs
under
Regulatory
Options
The
costs
associated
with
the
alternative
reporting
options
for
the
IUR
amendments
are
presented
in
Table
3­
18.
Industry
costs
for
the
alternative
threshold
options
would
be
either
higher
or
lower
than
the
selected
option
depending
on
whether
the
upper
threshold
is
higher
or
lower
than
300,000
pounds.
For
thresholds
above
300,000
pounds,
the
total
costs
would
be
lower
than
the
selected
option,
and
for
thresholds
below
300,000
pounds,
the
total
costs
would
be
higher
than
for
the
selected
option.
The
costs
will
be
lower
under
Option
6
than
the
selected
option
because
inorganic
chemicals
would
not
have
to
report
any
information
under
this
option.
Option
7
increases
net
present
value
of
the
costs
because
the
information
is
collected
more
3­
31
frequently.
Option
8
would
have
a
much
lower
net
present
value
of
costs
than
any
other
option
because
information
is
collected
only
once
under
this
option.
3­
32
Table
3­
13.
Summary
of
Incremental
Costs
of
IUR
Amendments
for
Organic
Chemicals
(
2000$)

Unit
of
Analysis
Cost
per
Unit
Number
of
Units
Total
Cost
Low
High
Low
High
First
Reporting
Year
Baseline
Compliance
Determination
Site
65.96
263.84
2,666
175,848
703,392
Rule
Familiarization
Site
323.02
323.02
2,666
861,178
861,178
Report
Preparation
and
Submission
Report
461.51
681.09
26,365
12,167,554
17,956,675
Recordkeeping
Report
127.42
254.84
26,365
3,359,352
6,718,705
Total
Baseline
Cost
16,563,933
26,239,949
With
Amendments
Compliance
Determination
Site
65.96
263.84
2,482
163,710
654,839
Rule
Familiarization
Site
1,951.6
6
2,274.68
2,482
4,844,032
5,645,766
Report
Preparation
and
Submission
Partial
report
Report
912.02
1,367.43
12,501
11,401,110
17,094,300
Full
report
Report
6,343.0
5
7,229.28
9,759
61,901,784
70,550,510
Recordkeeping
Report
254.84
509.67
22,260
5,672,661
11,345,322
Total
Cost
with
Amendments
83,983,297
105,290,73
7
Incremental
Cost
67,419,364
79,050,787
Future
Reporting
Years
Baseline
Compliance
Determination
Site
65.96
263.84
2,666
175,846
703,385
Rule
Familiarization
Site
323.02
323.02
2,666
861,169
861,169
Report
Preparation
and
Submission
Report
461.51
681.09
26,365
12,167,663
17,956,836
Recordkeeping
Report
127.42
254.84
26,365
3,359,382
6,718,765
Total
Baseline
Cost
16,564,061
26,240,155
With
Amendments
Compliance
Determination
Site
65.96
263.84
2,482
163,710
654,839
Rule
Familiarization
Site
323.02
323.02
2,482
801,734
801,734
3­
33
Table
3­
14.
Summary
of
Incremental
Costs
of
IUR
Amendments
for
Inorganic
Chemicals
(
2000$)

Unit
of
Analysis
Cost
per
Unit
Number
of
Units
Total
Cost
Low
High
Low
High
First
Reporting
Year
Baseline
Compliance
Determination
Site
0.00
0.00
0
0
0
Rule
Familiarization
Site
0.00
0.00
0
0
0
Report
Preparation
and
Submission
Report
0.00
0.00
0
0
0
Recordkeeping
Report
0.00
0.00
0
0
0
Total
Baseline
Cost
0
0
With
Amendments
Compliance
Determination
Site
65.96
263.84
544
35,885
143,540
Rule
Familiarization
Site
1,951.6
6
2,274.68
544
1,061,810
1,237,550
Report
Preparation
and
Submission
Partial
report
Report
912.02
1,367.43
4,537
4,137,495
6,203,570
Full
report
Report
6,343.0
5
7,221.48
0
0
0
Recordkeeping
Report
254.84
509.67
4,537
1,156,104
2,312,207
Total
Cost
with
Amendments
6,391,294
9,896,868
Incremental
Cost
6,391,294
9,896,868
Future
Reporting
Years
Baseline
Compliance
Determination
Site
0.00
0.00
0
0
0
Rule
Familiarization
Site
0.00
0.00
0
0
0
Report
Preparation
and
Submission
Report
0.00
0.00
0
0
0
Recordkeeping
Report
0.00
0.00
0
0
0
Total
Baseline
Cost
0
0
With
Amendments
Compliance
Determination
Site
65.96
263.84
544
35,885
143,540
Rule
Familiarization
Site
323.02
323.02
544
175,740
175,740
3­
34
Table
3­
15.
Total
Incremental
Costs
of
IUR
Amendments
(
million
2000$)

First
Reporting
Year
Total
Cost
Future
Reporting
Years
Total
Cost
Low
High
Low
High
Baseline
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)
16.6
26.2
16.6
26.2
Inorganic
Chemicals
0.0
0.0
0.0
0.0
Total
Baseline
Cost
16.6
26.2
16.6
26.2
With
Amendments
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)
84.0
105.3
73.4
93.3
Inorganic
Chemicals
6.4
9.9
17.8
22.0
Total
with
Amendments
90.4
115.2
91.1
115.3
Total
Incremental
Cost
73.8
88.9
74.6
89.1
3­
35
Table
3­
16.
Total
Incremental
Burden
Hours
of
IUR
Amendments
(
thousands
of
hours)

First
Reporting
Year
Total
Burden
Hours
Future
Reporting
Years
Total
Burden
Hours
Low
High
Low
High
Baseline
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)
249.0
389.5
249.0
389.5
Inorganic
Chemicals
0.0
0.0
0.0
0.0
Total
Baseline
Burden
249.0
389.5
249.0
389.5
With
Amendments
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals)
1,228.0
1,536.9
1,078.2
1,368.1
Inorganic
Chemicals
94.2
144.0
260.2
322.4
Total
with
Amendments
1,322.2
1,680.9
1,338.4
1,691.0
Total
Incremental
Burden
1,073.2
1,291.4
1,089.4
1,301.5
29It
is
assumed
here
that
a
site
either
produces
organic
chemicals
(
including
petroleums
stream
chemicals)
or
inorganic
chemicals,
but
not
both.

3­
36
3.1.4.3
Average
Compliance
Costs
per
Site
The
average
incremental
compliance
costs
per
site
for
organic
chemicals
manufacturers
and
inorganic
chemical
manufacturers
are
presented
in
Tables
3­
19
and
3­
20,
respectively.
29
The
number
of
reports
per
site
is
based
on
the
CUS
database
for
organic
chemicals
and
on
the
relationship
between
organic
and
inorganic
chemicals
from
the
CICIS
database.
The
distribution
of
reports
between
partial
and
full
is
based
on
the
percentage
of
reports
expected
to
be
partial
and
full
under
the
IUR
amendments
calculated
from
Table
2­
4.
The
incremental
cost
for
an
average
organic
chemical
site
is
expected
to
be
$
27,609
to
$
32,563
in
the
first
reporting
year
and
to
decrease
in
future
reporting
years
to
$
23,343
to
$
27,719.
The
cost
for
an
average
inorganic
site
is
expected
to
be
around
$
11,749
to
$
18,194
in
the
first
reporting
year
and
then
to
increase
to
$
32,638
to
$
40,502
in
future
reporting
years
because
they
will
no
longer
have
a
partial
exemption
for
reporting
processing
and
use
information.

3.1.5
Limitations
of
the
Compliance
Cost
Analysis
A
number
of
uncertainties
result
from
the
approach
and
methodology
used
to
model
the
industry
costs
associated
with
the
IUR
amendments.
Some
of
these
uncertainties
may
lead
to
underestimates
or
overestimates
of
quantified
industry
costs.
The
following
points
discuss
some
uncertainties
that
could
significantly
affect
the
results
of
the
analysis:


Although
the
IUR
amendments
only
require
that
industry
report
"
reasonably
ascertainable"
information
for
most
data
elements
and
"
readily
available"
information
for
downstream
processing
and
use
information,
the
industry
survey
(
ICF,
1996)
that
respondents
completed
did
not
mention
these
Table
3­
17.
Flow
of
Compliance
Costs
Over
the
Next
20
Years
(
million
2000$)
Under
Amendments
Cost
Year
Low
High
1
73.8
88.9
2
0.0
0.0
3
0.0
0.0
4
0.0
0.0
5
74.6
89.1
6
0.0
0.0
7
0.0
0.0
8
0.0
0.0
9
74.6
89.1
10
0.0
0.0
11
0.0
0.0
12
0.0
0.0
13
74.6
89.1
14
0.0
0.0
15
0.0
0.0
16
0.0
0.0
17
74.6
89.1
18
0.0
0.0
19
0.0
0.0
20
0.0
0.0
30As
discussed
in
Appendix
E,
small
companies
were
identified
as
having
annual
sales
less
than
$
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.
Small
businesses
that
manufacture
less
than
100,000
pounds
of
a
reportable
chemical
in
a
reporting
year
are
exempt
from
all
reporting.

3­
37
standards.
Thus,
survey
respondents
were
reporting
burden
estimates
assuming
a
much
higher
standard
of
information
than
EPA
will
require.


The
analysis
may
overestimate
the
costs
of
compliance
for
smaller
companies.
According
to
the
survey
(
ICF,
1996)
(
see
Appendix
E),
the
average
cost
of
preparing
and
submitting
a
partial
report
for
a
large
company
is
$
1,100
to
$
1,855,
for
a
medium
company
is
$
784
to
$
833,
and
for
a
small
company
is
$
521
to
$
537.30
For
a
full
report,
the
average
cost
is
between
$
7,158
and
$
8,635
for
a
large
company,
between
$
9,744
and
$
10,092
for
a
medium
company,
and
between
$
3,110
and
$
3,192
for
a
small
company.
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
Table
3­
18.
Incremental
Net
Present
Values
and
Annualized
Industry
Costs
of
Amendment
Options
Discounted
at
3
Percent
(
million
2000$)

Option
First­
Year
Cost
Net
Present
Valuea
Annualized
Cost
Low
High
Low
High
Low
High
Threshold
Options
1
(
Selected)
$
73.8
$
88.9
$
289.1
$
346.0
$
19.4
$
23.3
2
$
91.1
$
103.1
$
362.3
$
410.3
$
24.4
$
27.6
3
$
67.2
$
77.3
$
260.7
$
300.6
$
17.5
$
20.2
4
$
59.1
$
68.6
$
226.4
$
263.6
$
15.2
$
17.7
5
$
67.2
$
77.3
$
339.0
$
385.2
$
22.8
$
25.9
Reporting
Exemption
Option
6
$
84.7
$
94.7
$
292.5
$
328.8
$
19.7
$
22.1
Reporting
Cycle
Options
7
$
91.1
$
103.1
$
706.3
$
800.0
$
47.5
$
53.8
8
$
91.1
$
103.1
$
88.5
$
100.1
$
5.9
$
6.7
a
NPV
determined
for
a
20­
year
period.
3­
38
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
likely
that
the
cost
of
supplying
the
processing
and
use
information
for
a
smaller­
volume
chemical
with
few
uses
is
lower
than
for
a
larger­
volume
and
widely­
used
chemical.
For
example,
if
compliance
costs
for
a
small­
use,
lowvolume
chemical
are
one­
third
of
the
compliance
costs
for
a
larger­
volume,
multiuse
chemical,
a
substantial
drop
in
the
total
expected
costs
is
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
unit
costs
of
compliance
presented
in
this
analysis
are
averages
and
not
intended
to
represent
these
two
quite
different
scenarios.


The
scaling
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.
3­
39
Table
3­
19.
Average
Incremental
Compliance
Costs
per
Site
for
Organic
Chemicals
(
2000$)

Unit
of
Analysi
s
Cost
per
Unit
Number
of
Units
Total
Cost
Low
High
Low
High
Baseline
Compliance
Determination
Site
$
65.96
$
263.84
1.0
$
66
$
264
Rule
Familiarization
Site
$
323.02
$
323.02
1.0
$
323
$
323
Report
Preparation
and
Submission
Report
$
461.51
$
681.09
9.9
$
4,564
$
6,736
Recordkeeping
Report
$
127.42
$
254.84
9.9
$
1,260
$
2,520
Total
Baseline
Cost
$
6,213
$
9,843
First
Reporting
Year
Compliance
Determination
Site
$
65.96
$
263.84
1.0
$
66
$
264
Rule
Familiarization
Site
$
1,951.66
$
2,274.68
1.0
$
1,952
$
2,275
Report
Preparation
and
Submission
Partial
report
Report
$
912.02
$
1,367.43
5.0
$
4,598
$
6,893
Full
report
Report
$
6,343.05
$
7,229.28
3.9
$
24,921
$
28,403
Recordkeeping
Report
$
254.84
$
509.67
9.0
$
2,286
$
4,572
Total
Cost
in
the
First
Reporting
Year
$
33,822
$
42,407
Incremental
Cost
in
First
Reporting
Year
$
27,609
$
32,563
Future
Reporting
Years
Compliance
Determination
Site
$
65.96
$
263.84
1.0
$
66
$
264
Rule
Familiarization
Site
$
323.02
$
323.02
1.0
$
323
$
323
Report
Preparation
and
Submission
Partial
report
Report
$
903.46
$
1,353.08
5.0
$
4,554
$
6,821
Full
report
Report
$
5,682.77
$
6,511.51
3.9
$
22,327
$
25,583
Recordkeeping
Report
$
254.84
$
509.67
9.0
$
2,286
$
4,572
Total
Cost
in
Future
Reporting
Years
$
29,556
$
37,563
Incremental
Cost
in
Future
Reporting
Years
$
23,343
$
27,719
3­
40

Insufficient
data
exist
to
determine
how
many
sites
currently
subject
to
reporting
will
be
affected
by
removing
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.
3­
41
Table
3­
20.
Average
Incremental
Compliance
Costs
per
Site
for
Inorganic
Chemicals
(
2000$)

Unit
of
Analysi
s
Cost
per
Unit
Number
of
Units
Total
Cost
Low
High
Low
High
Baseline
Compliance
Determination
Site
C
C
0.0
C
C
Rule
Familiarization
Site
C
C
0.0
C
C
Report
Preparation
and
Submission
Report
C
C
0.0
C
C
Recordkeeping
Report
C
C
0.0
C
C
Total
Baseline
Cost
C
C
First
Reporting
Year
Compliance
Determination
Site
$
65.96
$
263.84
1.0
$
66
$
264
Rule
Familiarization
Site
$
1,951.66
$
2,274.68
1.0
$
1,952
$
2,275
Report
Preparation
and
Submission
Partial
report
Report
$
912.02
$
1,367.43
8.3
$
7,606
$
11,404
Full
report
Report
C
C
0.0
C
C
Recordkeeping
Report
$
254.84
$
509.67
8.3
$
2,125
$
4,251
Total
Cost
in
the
First
Reporting
Year
$
11,749
$
18,194
Incremental
Cost
in
the
First
Reporting
Year
$
11,749
$
18,194
Future
Reporting
Years
Compliance
Determination
Site
$
65.96
$
263.84
1.0
$
66
$
264
Rule
Familiarization
Site
$
323.02
$
323.02
1.0
$
323
$
323
Report
Preparation
and
Submission
Partial
report
Report
$
903.46
$
1,353.08
3.6
$
3,265
$
4,890
Full
report
Report
$
5,682.77
$
6,511.51
4.7
$
26,858
$
30,775
Recordkeeping
Report
$
254.84
$
509.67
8.3
$
2,125
$
4,251
Total
Cost
in
Future
Reporting
Years
$
32,638
$
40,052
Incremental
Cost
in
Future
Reporting
Years
$
32,638
$
40,502
3­
42

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
submit
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.


3.2
Agency
Costs
This
section
provides
an
analysis
of
the
costs
associated
with
the
IUR
amendments
expected
to
be
incurred
by
taxpayers
to
support
EPA
efforts
in
establishing
and
maintaining
IUR
amendments
data.
The
activities
associated
with
the
IUR
amendments
and
the
attendant
costs
are
discussed
below.
This
section
presents
the
methodology
for
Agency
cost
analysis
and
a
description
of
Agency
tasks.
It
also
provides
the
calculations
used
to
develop
Agency
cost
estimates.
Agency
costs
are
summarized
as
well.

3.2.1
Overview
of
and
Methodology
for
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
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
the
IUR
amendments
was
used:


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


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


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


Step
4:
Subtract
the
estimated
cost
of
the
original
IUR
from
the
estimated
cost
of
the
amendments
to
find
the
incremental
change
in
Agency
costs.
Additionally,
in
developing
the
cost
estimates
for
determining
Agency
burden,
activities
associated
with
one­
time
events
are
distinguished
from
costs
incurred
annually.
This
distinction
is
considered
throughout
the
discussion
of
individual
tasks
and
is
handled
directly
in
the
presentation
of
Agency
costs.
The
Agency
tasks
required
for
processing
submissions
under
the
current
IUR
include
database
systems
development,
Form
U
processing,
document
development,
and
mailings
and
other
informational
activities:


Database
Systems
Development
and
Maintenance:
The
Agency
is
responsible
for
having
adequate
information
systems
in
place
to
support
the
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
3­
43
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
used
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
costs
of
these
improvements
are
not
included
in
this
analysis
because
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
activity
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.
Agency
personnel
and
contractors
perform
the
various
tasks
associated
with
document
processing.


Mailings
and
Other
Informational
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
Hotline
with
standardized
responses
for
frequently
asked
questions;
preparing
mailings,
mailing
lists,
and
labels;
and
developing
outgoing
informational
materials.
3­
44
3.2.2
Agency
Cost
Calculations
The
Agency
incurs
costs
associated
with
the
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
incremental
costs
of
these
three
components
under
the
amendments
to
the
IUR
are
presented.
The
costs
associated
with
developing
a
database
system
and
a
guidance
document
are
assumed
to
be
one­
time
costs.
3.2.2.1
Agency
Costs
Under
the
IUR
Amendments
Agency
tasks
that
must
be
performed
under
the
IUR
amendments
consist
largely
of
an
expanded
effort
for
tasks
already
undertaken
for
the
original
IUR.
Thus,
the
task
descriptions
presented
in
Section
3.2.1
generally
do
not
change.
However,
the
magnitude
of
any
specific
task
may
change.
One
change
worthy
of
explanation
involves
database
systems
development
and
maintenance.
In
addition
to
the
tasks
identified
for
this
category
under
Section
3.2.1,
the
IUR
amendments
will
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
expanding
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
modules
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
system's
design.
A
change
in
the
magnitude
of
each
task
described
in
Section
3.2.1
is
reflected
in
the
number
of
Agency
personnel
or
contractors
required
and/
or
in
the
incremental
cost.
The
cost
of
tasks
performed
by
Agency
personnel
is
estimated
using
the
number
of
FTEs
and
the
GS­
level
required
to
perform
each
task.
The
salary
rates
are
taken
from
the
2000
General
Schedule
Locality
Rates
of
Pay
for
Washington­
Baltimore,
DCMD
VA­
WV
from
the
U.
S.
Office
of
Personnel
Management
(
OPM,
2000).
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
$
54,618
to
perform
quality
control
of
data
entry
and
an
additional
FTE,
GS­
13
at
a
salary
of
$
64,949,
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
IUR
amendments
would
amount
to
incremental
salary
costs
of
$
119,567.
Once
fringe
benefits
and
overhead
are
added,
this
represents
incremental
annual
costs
of
$
197,250
(
IMD,
1996;
EPA,
1996b;
EPA,
1997a).
The
development
of
a
guidance
document
for
the
amended
IUR
would
require
0.5
FTE,
GS­
13
at
a
total
cost
of
$
53,573
with
benefits
and
overhead
included.
The
cost
of
developing
the
guidance
document
is
a
one­
time
cost.
3­
45
Extramural
tasks
would
also
require
more
labor.
For
the
IUR
amendments,
document
receipt
and
tracking
and
data
entry
would
increase
by
approximately
$
42,318;
the
backup
systems
operations
cost
would
double,
causing
an
incremental
cost
of
$
26,449.
Hence,
the
annual
incremental
cost
of
extramural
activities
for
the
IUR
amendments
is
estimated
to
be
about
$
68,767.
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
approximately
$
214,763.
This
incremental
cost
is
the
one­
time
cost
for
conducting
the
necessary
systems
and
hardware/
software
upgrades
to
handle
submissions
under
the
IUR
amendments
(
IMD,
1996;
EPA,
1996b).
Additional
tasks
associated
with
the
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
TSCA
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
IUR
amendments,
it
is
estimated
that
the
incremental
costs
of
providing
forms
and
materials
would
be
approximately
$
4,232.
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
$
31,738
in
the
first
year
of
reporting
under
the
amendments.
No
incremental
costs
are
expected
in
future
years
because
it
is
estimated
that
the
annual
Hotline
cost
associated
with
the
IUR
will
return
to
the
original
cost
of
this
activity
under
the
current
IUR.
The
cost
associated
with
preparing
mailings
under
the
IUR
amendments
is
estimated
to
increase
by
$
5,396
in
the
first
year,
based
on
approximately
3,400
more
mailings
than
the
original
IUR
at
$
1.59
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
IUR
amendments
is
estimated
to
be
zero
in
future
years.
Under
the
IUR
amendments,
the
one­
time
costs
of
the
amendments
are
all
assumed
to
be
incurred
in
the
first
reporting
year.
Recurring
costs
would
be
incurred
in
the
first
and
all
future
reporting
years.
Therefore,
the
incremental
costs
for
additional
tasks
under
the
IUR
amendments
is
approximately
$
270,249
in
future
reporting
years,
while
the
incremental
costs
estimated
for
the
first
reporting
year
are
calculated
by
summing
the
recurring
costs
and
the
one­
time
costs,
which
yields
$
575,719
(
EPA,
1996g;
EPA,
1998b).
These
incremental
costs
are
summarized
in
Tables
3­
21
and
3­
22.
The
flow
of
Agency
costs
over
a
20­
year
period
is
displayed
in
Table
3­
23
along
with
the
net
present
value
of
these
costs
and
the
annualized
cost
to
the
Agency
using
a
3
percent
discount
rate.
3­
46
3.3
Social
Cost
Summary
The
total
social
cost
associated
with
the
IUR
amendments
includes
both
the
compliance
costs
borne
by
the
affected
firms
and
the
government
administration,
monitoring,
and
enforcement
costs
borne
by
taxpayers.
The
IUR
amendments
involve
real
resource
expenditures
for
both
firms
and
the
government,
causing
social
opportunity
costs
in
both
cases.
Because
the
costs
to
the
government
are
assumed
not
to
vary
with
the
quantity
of
reports,
this
cost
is
constant
across
all
options.
Table
3­
24
summarizes
the
total
social
cost
associated
with
the
IUR
amendments
across
all
of
the
3­
47
regulatory
options.
Table
3­
21.
Estimated
Incremental
Agency
Costs
for
the
IUR
Amendments
(
recurring
every
four
years)

Task
IUR
Amendment
Costs
Tasks
Performed
by
Agency
Personnel
Quality
Control
of
Data
Entry
$
90,103
(
1
FTE,
GS­
12)

Data
Processing,
Systems
Development,
and
Contract
Oversight
&
Management
$
107,146
(
1
FTE,
GS­
13)

Subtotal
$
197,250
Extramural
Tasks
(
contractor)

Document
Receipt
&
Tracking
and
Data
Entry
$
42,318
Backup
Systems
Operations
$
26,449
Subtotal
$
68,767
Additional
Tasks
Publication
and
Printing
Forms
&
Materials
$
4,232
Subtotal
$
4,232
Total
Annual
Cost
$
270,249
Note:
All
costs
associated
with
FTEs
include
41
percent
fringe
benefits
and
17
percent
overhead.

Sources:
U.
S.
Environmental
Protection
Agency.
April
1997a.
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313.
Office
of
Pollution
Prevention
and
Toxics,
Regulatory
Impacts
Branch.

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

U.
S.
Environmental
Protection
Agency.
August
29,
1996d.
Transcribed
Telephone
Conversation
with
Ruth
Heikkinen
on
Hotline
and
Mailing
Costs,
Office
of
Pollution
Prevention
and
Toxics.

U.
S.
Environmental
Protection
Agency.
August
26,
1998b.
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.

Office
of
Personnel
Management
(
OPM).
2000.
"
2000
General
Schedule
Locality
Notes
of
Pay
for
Washington­
Baltimore,
DC­
MD­
VA­
WV."
<
http://
www.
opm.
gov/
oca/
2000tbls/
GSannual/
html/
GSDCB.
HTM>
As
obtained
on
May
30,
2000.
3­
48
Table
3­
22.
Estimated
Incremental
One­
Time
Agency
Costs
for
the
IUR
Amendments
Task
IUR
Amendment
Costs
Tasks
Performed
by
Agency
Personnel
Guidance
Document
Development
$
53,573
(
0.5
FTE,
GS­
13)

Subtotal
$
53,573
Extramural
Tasks
(
contractor)

Systems
Development
$
100,505
Hardware
&
Software
$
8,464
Guidance
Document
Development
$
105,794
Subtotal
$
214,763
Additional
Tasks
Hotlinea
$
31,738
Mailinga
$
5,396
Subtotal
$
37,134
Total
One
Time
Cost
$
305,470
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
IUR
amendments.
No
incremental
costs
are
expected
for
these
tasks
in
subsequent
years.

Sources:
U.
S.
Environmental
Protection
Agency.
April
1997a.
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313.
Office
of
Pollution
Prevention
and
Toxics,
Regulatory
Impacts
Branch.

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

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

Office
of
Personnel
Management
(
OPM).
2000.
"
2000
General
Schedule
Locality
Notes
of
Pay
for
Washington­
Baltimore,
DC­
MD­
VA­
WV."
<
http://
www.
opm.
gov/
oca/
2000tbls/
GSannual/
html/
GSDCB.
HTM>.
As
obtained
on
May
30,
2000.
3­
49
Table
3­
23.
Flow
of
Agency
Costs
Over
the
Next
20
Years
(
2000$)
under
Amendments
Year
Cost
Year
Cost
1
$
575,719
12
$
0
2
$
0
13
$
270,249
3
$
0
14
$
0
4
$
0
15
$
0
5
$
270,249
16
$
0
6
$
0
17
$
270,249
7
$
0
18
$
0
8
$
0
19
$
0
9
$
270,249
20
$
0
10
$
0
Net
Present
Value
$
1,346,774
11
$
0
Annualized
Cost
$
90,524
Table
3­
24.
Measures
of
Incremental
Social
Costs
(
both
Industry
and
Agency
Costs)
Associated
with
Amendment
Options
(
million
2000$)

Option
First­
Year
Cost
Net
Present
Valuea
Annualized
Cost
Low
High
Low
High
Low
High
Threshold
Options
1
(
Selected)
74.4
89.5
290.4
347.3
19.5
23.3
2
91.7
103.7
363.6
411.6
24.4
27.7
3
67.7
77.8
262.1
302.0
17.6
20.3
4
59.7
69.1
227.7
264.9
15.3
17.8
5
67.7
77.8
340.4
386.5
22.9
26.0
Reporting
Exemption
Option
6
85.3
95.2
293.9
330.1
19.8
22.2
Reporting
Cycle
Options
7
91.7
103.7
708.7
802.3
47.6
53.9
8
91.7
103.7
89.0
100.7
6.0
6.8
a
NPV
determined
for
a
20­
year
period
using
a
discount
rate
of
3
percent.
4­
1
SECTION
4
THE
BENEFITS
OF
THE
IUR
AMENDMENTS
As
discussed
in
Section
2,
neither
EPA
nor
the
public
has
access
to
the
information
that
is
needed
to
most
effectively
and
accurately
identify
chemical
risks
from
production
or
use
in
the
United
States.
Screening
chemicals
according
to
these
potential
risks
is
an
essential
first
step
in
developing
and
prioritizing
risk
management
activities.
Effective
risk
screening
depends
critically
on
the
ability
to
characterize
chemical
uses
and
to
predict
potential
exposures;
however,
current
screening
activities
are
greatly
hampered
by
their
reliance
on
production
volume
estimates
and
on
relatively
scarce
public
sources
of
information.
This
rule
will
benefit
society
by
filling
this
information
void
and
contributing
to
better
assessments
of
potential
risks
and
risk
management
decisions.
Currently,
the
IUR
is
one
of
EPA's
most
important
tools
for
meeting
its
mandate
(
under
TSCA)
to
manage
the
risks
resulting
from
chemical
production
and
use
in
the
United
States.
It
is
EPA's
most
comprehensive
source
of
data
on
the
chemical
industry,
and
it
is
used
in
almost
all
of
OPPT's
risk
screening
and
management
programs.
However,
the
IUR
data
in
their
current
form
are
limited,
and
this
in
turn
limits
EPA's
effectiveness
in
meeting
its
TSCA
mandate.
The
amendments
will
reduce
many
of
these
data
constraints
and,
as
a
result,
improve
the
effectiveness
of
EPA's
chemical
risk
management
programs.
Most
importantly,
the
new
IUR
rule
will
require
the
collection
and
compilation
of
additional
manufacturing,
processing,
use,
and
exposure­
related
information.
This
additional
information
will
allow
EPA
to
more
accurately
assess
human
and
ecosystem
exposures
to
specific
chemicals,
including
the
concentrations,
frequency,
and
durations
of
these
exposures.
With
this
additional
information,
EPA
will
be
able
to
better
screen
chemicals
to
identify
whether
additional
risk
assessment
and
management
steps
are
needed.
By
enhancing
the
data
supplied
to
EPA's
risk­
screening
programs,
EPA
expects
to
more
effectively
and
expeditiously
reduce
the
risks
posed
by
chemicals.
Ultimately,
enhancing
the
risk
screening
process
will
have
positive
consequences
for
human
and
ecosystem
health,
and
will
use
EPA's
and
society's
resources
more
efficiently.
Additional
benefits
will
accrue
from
changes
in
reporting
requirements
that
will
improve
consistency
and
compatibility
with
other
EPA
databases.
EPA
also
expects
more
publicly
available
non­
CBI
information
and
an
increased
ability
to
anticipate
industry
trends,
particularly
for
chemicals
about
which
EPA
has
concerns.
Finally,
in
an
effort
to
better
target
information­
gathering
efforts,
the
rule
removes
one
reporting
exemption
while
adding
reporting
exemptions
in
other
areas.
The
social
benefits
resulting
from
the
IUR
amendments
are
qualitatively
discussed
in
this
section.
Unfortunately,
quantitative
estimates
of
these
benefits
are
not
feasible
due
to
data
limitations.
This
section
first
defines
a
conceptual
framework
4­
2
for
evaluating
the
benefits
of
public
information­
based
programs
such
as
the
IUR
amendments.
The
section
then
applies
this
framework
to
identify
and
describe
the
types
of
benefits
that
will
accrue
from
the
different
components
of
the
rule.

4.1
Benefits
of
Information­
Based
Policies
In
assessing
the
benefits
of
information­
based
policies
such
as
this
rule,
it
is
important
to
identify
the
primary
ways
through
which
the
public
provision
of
information
yields
benefits
for
society.
In
general,
increasing
the
amount
and
quality
of
publicly
available
information
has
two
effects:


It
reduces
the
costs
of
making
decisions.


It
improves
the
expected
outcomes
of
these
decisions.
In
the
first
case,
policies
that
make
new
information
about
toxic
substances
available
to
the
public
(
including
EPA)
can
serve
to
replace
other
information­
gathering,
management,
and
dissemination
activities
related
to
toxic
substances.
In
so
doing,
they
allow
information
users
(
i.
e.,
decisionmakers)
to
avoid
some
of
the
time
and
resource
costs
devoted
to
these
activities.
In
effect,
they
increase
the
efficiency
of
the
decisionmaking
process.
In
the
second
case,
information­
based
policies
contribute
to
better
decisions,
by
redirecting
resources
towards
their
most
highly­
valued
uses.
With
incomplete
information
regarding
toxic
substances,
public
and
private
decisionmakers
are
not
able
to
adequately
assess
the
benefits
and
costs
of
actions
that
involve
these
substances.
For
example,
EPA
decisions
regarding
whether,
when,
and
how
to
impose
controls
on
a
substance
can
be
misdirected
if
the
risks
from
the
substance
are
not
fully
understood
and
are
therefore
underestimated
(
or
overestimated).
Improved
information
can
therefore
lead
to
socially
optimal
reductions
in
risks
to
humans
and
the
environment
(
and/
or
reductions
in
control
costs).
As
discussed
in
more
specific
terms
in
the
remainder
of
this
section,
the
rule
will
generate
both
kinds
of
benefits.
First,
it
will
reduce
EPA's
(
and
other
decisionmakers')
reliance
on
other
databases
and
information
sources
that
are
ill­
suited
and
inadequate
for
accurately
and
efficiently
characterizing
the
risks
associated
with
the
thousands
of
chemicals
in
commerce
that
need
to
be
evaluated.
As
discussed
in
previous
sections,
EPA
will
bear
additional
costs
for
collecting
and
managing
the
new
IUR
data;
however,
by
providing
more
reliable
and
complete
data
on
chemical
uses
and
exposures,
the
rule
will
also
allow
EPA
to
save
time
and
resources
in
screening
chemicals
and
in
developing
risk
management
priorities.
Furthermore,
by
improving
the
consistency
and
compatibility
of
IUR
data
relative
to
other
datasets
used
in
evaluating
chemical
risks,
the
rule
will
reduce
the
costs
of
using
the
IUR
data
themselves.
Second,
it
will
improve
decisionmaking
by
EPA
and
others,
by
providing
them
with
a
better
understanding
of
the
benefits
and
costs
associated
with
chemical
substances.
It
will
allow
EPA
to
better
prioritize
its
risk
management
activities
C
to
move
more
quickly
in
addressing
chemicals
that
pose
relatively
high
risks
(
and/
or
relatively
low
risk­
management
costs)
and
to
delay
or
avoid
actions
where
the
gains
to
society
would
be
relatively
small
or
negative.
31Appendix
B
describes
databases
and
literature
sources
commonly
reviewed
by
EPA.

4­
3
In
assessing
the
benefits
of
information­
based
policies,
it
is
also
important
to
distinguish
between
and
identify

who
uses
the
information,


how
the
information
is
used,
and

who
benefits
(
or
loses)
from
these
uses.
These
distinctions
emphasize
that
the
ultimate
beneficiaries
of
these
policies
will
extend
well
beyond
those
who
disseminate
the
information
or
who
use
it
in
their
own
decisionmaking.
In
the
case
of
this
rule,
EPA
will
be
the
primary
user
of
the
new
information,
although
other
public
and
private
organizations,
in
particular
those
with
interests
in
managing
chemical
risks,
will
also
use
the
data.
The
information
is
expected
to
be
applied
and
disseminated
by
these
users
in
a
number
of
ways;
however,
it
will
primarily
serve
to
reduce
the
costs
of
screening
and
managing
chemical
risks
and
to
improve
risk
management
decisions.
The
American
public
will
be
the
ultimate
beneficiaries
of
the
amended
IUR.
By
lowering
the
cost
of
decisionmaking
in
the
public
sector,
the
rule
will
free
up
resources
for
other
public
or
private
uses.
Similar
gains
will
also
result
from
cost
savings
in
private­
sector
decisionmaking.
By
improving
risk
management
decisions,
the
rule
will
also
help
to
better
target
risk
management
activities
to
the
areas
where
the
net
benefits
(
i.
e.,
risk
reductions
net
of
control
costs)
are
expected
to
be
the
largest.
It
will
ultimately
improve
the
health
of
humans
and
ecosystems
by
promoting
greater
and
more
timely
reductions
in
chemical
risks.
Therefore,
benefits
will
accrue
directly
to
the
public
through
cost
savings
and
through
reductions
in
human
morbidity
and
mortality,
and
the
public
should
also
benefit
from
more
healthy
and
productive
ecosystems,
to
the
extent
these
systems
are
also
threatened
by
chemical
exposures.

4.2
Benefits
from
Processing
and
Use
Data
The
processing
and
use
data
collected
through
these
amendments
will
fill
an
important
information
void.
Currently,
EPA
and
the
general
public,
including
other
public
and
private
organizations,
have
very
limited
access
to
this
type
of
data31.
Processing
and
use
data
will
most
importantly
allow
EPA
to
improve
its
chemical
screening
and
risk
management
activities.
The
Agency
will
be
able
to
more
quickly
and
efficiently
identify
the
chemicals
posing
the
greatest
potential
risks
and
to
more
effectively
prioritize,
design,
and
implement
chemical
management
programs.
EPA
will
also
be
able
to
disseminate
this
previously
unavailable
(
non­
CBI)
information
and
to
make
its
findings,
based
on
analyses
of
these
data,
available
to
other
agencies
and
the
public.
This
will
promote
better
risk
management
decisions
by
these
groups
as
well.
In
addition
to
supporting
the
specific
programs
mentioned
below,
it
must
be
emphasized
that
IUR
data
provide
the
informational
foundation
for
a
wide
variety
of
OPPT
analyses
and
decisions.
The
additional
data
collected
through
the
IUR
amendment
will
further
enhance
this
role.
The
IUR
is
EPA's
primary
window
into
the
chemical
industry,
the
industry
OPPT
is
charged
with
regulating
under
TSCA.
The
use
4­
4
Box
4­
1.
An
Example
of
How
the
Amended
IUR
Data
can
be
Useful
in
Supporting
EPA's
Dayto
Day
Operations
In
late
1999,
a
chemical
importer
received
a
shipment
of
zinc­
sulfate
from
China
that
was
contaminated
with
cadmuim.
The
zinc
sulfate
was
distributed
as
a
raw
material
for
the
production
of
fertilizer
and
animal
feed
in
Washington,
California,
and
Idaho.
Such
use
could
result
in
occupational
exposure
to
workers
producing
agricultural
products,
or
even
in
consumer
or
livestock
exposures
from
food
or
animal
feed.
Cadmium
exposure
can
cause
flulike
symptoms
and
has
been
linked
to
lung
cancer
and
kidney
disease.
If
EPA
had
had
the
type
of
processing
and
use
information
that
will
be
collected
under
the
amended
IUR,
the
Agency
would
have
been
able
to
identify
and
contact
potential
importers
and
downstream
users
of
the
chemical
sooner
and
thus
contain
the
potential
exposures
more
quickly.
As
it
was,
the
Agency
was
forced,
at
least
in
part,
to
rely
on
data
from
the
U.
S.
Customs
Service.
This
process
was
time­
consuming
because
the
Customs
Service
generally
does
not
divulge
this
type
of
information.

of
current
IUR
data
on
a
daily
basis
to
answer
a
myriad
of
questions
is
widespread
within
EPA
and
within
OPPT
specifically.
With
expanded
information
available
on
many
chemicals,
the
quality
of
various
EPA
actions
will
improve
accordingly.
A
recent
example
of
how
expanded
IUR
data
would
be
valuable
for
use
on
a
more
as­
needed
basis
is
presented
in
Box
4­
1.

As
shown
in
Table
4­
1,
EPA
has
considered
different
chemical
production
thresholds
above
which
facilities
would
be
required
to
submit
processing
and
use
information
under
the
IUR.
These
thresholds
vary
across
options
from
100,000
pounds
to
1
million
pounds
per
year;
however,
the
selected
option
would
require
reporting
for
chemicals
with
production
volumes
above
300,000
pounds.
Clearly,
the
amount
of
information
collected
would
be
greater
with
lower
thresholds
because
more
facilities
and
more
chemicals
would
exceed
the
threshold.
4­
5
As
discussed
below,
it
is
very
difficult
to
quantify
and
monetize
the
benefits
of
this
additional
information;
however,
historical
data
on
IUR
submissions
do
allow
rough
approximations
of
how
the
number
of
chemicals
reported
would
vary
under
alternative
thresholds.
EPA
estimates
that
the
number
of
chemicals
with
reported
processing
and
use
data
in
the
first
reporting
cycle
would
be
roughly
5,450
chemicals
under
a
100,000
pound
threshold.
The
number
would
decrease
by
about
27
percent
to
about
4,000
chemicals
under
the
selected
option
of
300,000
pounds,
and
to
about
2,700
chemicals
with
a
1
million
pound
threshold.
Eliminating
the
exemption
on
inorganic
chemicals
in
later
years
will
further
increase
the
number
of
chemicals
reporting
processing
and
use
data.
For
the
100,000,
300,000
and
1
million
pound
thresholds,
EPA
estimates
that
data
for
850,
630,
and
440
inorganics,
respectively,
would
report
processing
and
use
data.
In
choosing
the
300,000
pound
threshold,
EPA
has
concluded
that
this
will
provide
the
optimal
balance
between
achieving
its
information
needs
and
not
imposing
overly
burdensome
reporting
requirements
on
IUR
submitters.
Collection
of
this
level
of
data
will
provide
valuable
input
to
risk­
screening
activities,
streamlining
EPA's
efforts
to
Table
4­
1.
Options
Considered
for
the
IUR
Amendments
Option
#
Thresholds
Reporting
Cycles
Site
and
Manufacturing
Information
Processing
and
Use
Information
Site
and
Manufacturing
Information
Processing
and
Use
Information
Threshold
Options
1
(
Selected)
25,000
lbs
300,000
lbs
4
yrs.
4
yrs.

2
25,000
lbs
100,000
lbs
4
yrs.
4
yrs.

3
25,000
lbs
500,000
lbs
4
yrs.
4
yrs.

4
25,000
lbs
1,000,000
lbs
4
yrs.
4
yrs.

5
25,000
lbs
500,000
lbs/
100,000
lbs
4
yrs.
4
yrs.

Reporting
Exemption
Optiona
6
25,000
lbs
100,000
lbs
4
yrs.
4
yrs.

Reporting
Cycle
Options
7
25,000
lbs
100,000
lbs
2
yrs.
2
yrs.

8
25,000
lbs
100,000
lbs
one­
time
one­
time
a
Inorganic
chemicals
are
fully
exempt
from
reporting.
4­
6
correctly
identify
chemicals
needing
further
review
and
subsequently
improving
later
risk
management
efforts.
The
following
sections
review
EPA's
current
risk­
screening
programs
and
chemical
management
programs
conducted
through
OPPT.
They
describe
how
these
programs
will
use
the
enhanced
information
and
how
the
public
will
gain.
They
also
describe
how
other
programs
and
other
agencies
can
use
the
information
to
benefit
the
general
public.

4.2.1
Benefits
through
OPPT
Risk­
Screening
and
Management
Programs
OPPT
has
a
multifaceted
approach
to
managing
chemical
risks.
Chemicals
enter
OPPT's
system
primarily
through
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
Use
Cluster
Scoring
System
(
UCSS).
Depending
on
the
outcome
of
these
screening
processes,
the
next
step
may
include
entering
one
of
EPA's
risk
management
programs.
Each
of
these
phases
and
the
benefits
derived
from
the
new
processing
and
use
information
are
examined
below.
4.2.1.1
Risk­
Screening
Programs
Risk
screening
is
a
critical
first
step
in
prioritizing
chemicals
for
further
evaluation
and
for
risk
management.
By
design,
it
is
less
detailed
and
data­
intensive
than
risk
assessment,
but
nonetheless
it
requires
adequate
information
for
comparing
potential
risks
across
a
large
group
of
chemicals.
Ideally,
such
information
would
include
a
characterization
of
the
chemical's
toxicity
as
well
as
indicators
of
human
and
ecosystem
exposures
to
the
chemical,
including
the
level
of
exposure
and
the
size
of
the
exposed
population.
In
these
efforts,
OPPT
currently
relies
primarily
on
a
combination
of
chemical
hazard
(
to
the
extent
that
it
is
known)
and
production
volume
information
to
evaluate
potential
chemical
risks.
Unfortunately,
production
volume
estimates
are
at
best
a
very
rough
proxy
for
exposure.
A
more
useful
and
complete
characterization
of
exposure
would
include,
for
example,
information
on
the
number
of
potentially
exposed
workers
and
consumers,
types
of
products
and
uses,
the
number
of
use
sites,
and
ambient
and
production
stream
concentrations
of
the
chemical.
As
described
in
Box
4­
2,
the
IUR
amendments
will
make
additional
information
of
this
type
available,
thereby
enhancing
the
effectiveness
and
efficiency
of
EPA's
chemical
riskscreening
programs.
4­
7
Box
4­
2.
EPA
Tools
to
Evaluate
and
Manage
Chemical
Risk
Risk
Screening.
OPPT
screens
chemicals
on
the
TSCA
Inventory
to
identify
potential
risks
and
determine
whether
more
detailed
assessments
should
be
undertaken.
With
the
data
currently
available,
EPA
does
not
have
the
information
needed
to
effectively
and
systematically
screen
some
of
the
chemicals
on
the
inventory.
Data
collected
as
a
result
of
the
amended
IUR
would
improve
the
Agency's
ability
to
screen
chemicals
in
commerce,
allowing
the
Agency
to
focus
its
chemical
screening
programs
and
to
identify
potentially
risky
situations
earlier
than
otherwise
possible.
Then
EPA
could
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
potentially
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.
Processing
and
use
data
collected
through
the
IUR
amendments
would
contribute
to
this
risk
management
program
in
several
ways.
First,
improved
screening
prior
to
review
would
lead
to
a
quicker
identification
of
chemicals
of
concern
and
more
appropriate
entry
into
EPA's
chemical
management
programs.
Second,
the
IUR
amendments
would
provide
readily
obtainable
initial
processing
and
use
information
for
these
chemicals,
significantly
improving
the
efficiency
and
effectiveness
of
screening.
Finally,
by
effectively
weeding
out
the
lower­
risk
chemicals
sooner,
EPA
would
be
able
to
focus
efforts
on
higher­
risk
chemicals.

Use
Cluster
Scoring
System
(
UCSS).
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
IUR
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.
The
amended
IUR
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
manufacturers
or
processors.
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,
processing
and
use
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.
The
amended
IUR
data
would
enable
EPA
to
better
target
testing
needs
to
situations
in
which
potential
exposures
are
known
to
occur,
thereby
increasing
the
efficiency
of
efforts
in
these
4­
8
Box
4­
2.
EPA
Tools
to
Evaluate
and
Manage
Chemical
Risk
(
continued)

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
IUR
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).
EPA's
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
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.

EPA
screens
chemicals
for
potential
chemical
risks
by
completing
an
initial
review.
This
initial
review
is
designed
to
select
the
chemical
substances
that
raise
particular
concern
regarding
the
risks
they
present
to
human
health
and
the
environment.
OPPT's
initial
risk
screening
is
a
review
and
analysis
of
any
readily
available
chemical
hazard
data
and
exposure
information
to
evaluate
potential
risks
to
human
health
and
the
environment
from
these
chemicals.
These
evaluations
are
used
to
support
basic
risk
management
decisions,
which
can
lead
to
more
detailed
assessments
and,
ultimately,
to
voluntary
and/
or
regulatory
actions.
The
initial
reviews
are
often
more
qualitative
than
quantitative
and
are
typically
eclectic
rather
than
formulaic:
the
extent
and
the
actual
process
of
the
review
depends
on
available
information
as
well
as
available
time
and
resources.
Further,
the
initial
screening
typically
is
broad
in
scope
and
shallow
in
depth.
For
example,
one
initial
review
might
be
conducted
for
a
chemical
or
group
of
chemicals
with
substantial
hazard
information
covering
a
number
of
adverse
effect
endpoints
(
such
as
cancer,
reproductive
problems,
mutations,
or
mortality)
but
little
exposure
data,
while
another
might
involve
hazard
data
on
only
one
endpoint,
but
with
exposure
data
usually
associated
with
other
endpoints.
As
a
result,
considerable
scientific
judgment
must
be
used
to
assess
the
chemicals,
decide
which,
if
any,
require
more
detailed
review,
and
account
for
a
great
deal
of
uncertainty
in
the
analysis.
This
uncertainty
usually
is
due
to
a
lack
of
current
hazard
data
or,
more
frequently,
exposure
data,
as
well
as
questions
about
data
reliability.
At
the
close
of
the
initial
review,
three
possible
outcomes
may
occur:
a
testing
recommendation,
a
recommendation
for
further
evaluation,
or
closure.
"
Closure"
may
32Additional
details
on
the
usefulness
of
this
information
can
be
found
in
the
EPA
(
1996c)
report
entitled
Inventory
Update
Rule
(
IUR)
Amendment
Technical
Support
Document:
Exposure­
Related
Data
Useful
for
Chemical
Risk
Screening,
Volume
I.

4­
9
include
referrals
to
other
programs
or
agencies,
dissemination
of
initial
review
results,
or
a
decision
to
discontinue
further
review
based
on
the
chemical's
low
hazard
or
low
risk
potential,
or
because
it
will
be
considered
for
regulatory
control
as
part
of
a
broader
cluster
of
chemical
substances.
Effective
risk
screening
and
risk
management
depend
on
both
exposure
information
and
hazard
information.
The
exposure­
related
information
reported
under
the
IUR
amendments,
in
combination
with
hazard
information,
such
as
that
developed
under
TSCA
Section
4
test
rules
or
the
High
Production
Volume
Challenge
Program,
would
allow
the
Agency
to
effectively
screen
and
prioritize
chemicals
based
on
potential
risk.
EPA's
Existing
Chemicals
Program
is
currently
evaluating
risks
from
indoor
air
pollutants,
high­
release
chemical
substances
listed
on
the
TRI,
persistent
bioaccumulators,
and
high
production
volume
chemicals.
While
past
approaches
to
priority
setting
have
been
primarily
based
on
relative
chemical
hazards
and
production
volume
as
a
simple
surrogate
for
exposure,
EPA
has
increased
its
emphasis
on
the
exposure
component
of
risk
screening
and
assessment.
EPA
also
believes
it
is
appropriate
to
develop
a
more
systematic
and
comprehensive
approach
to
the
prioritization
process.
The
new
exposure­
related
information
that
will
be
reported
under
this
amended
rule
is
necessary
to
allow
more
efficient
and
effective
chemical
risk
screening.
The
additional
information
required
by
the
rule
would
specifically
include
the
following
features
and
uses:
32

Number
of
Potentially
Exposed
Workers:
Estimates
of
the
number
of
workers
potentially
exposed
to
specific
chemicals
would
be
used
to
clearly
understand
the
potential
magnitude
of
occupationally­
exposed
populations.
The
number
of
workers
is
combined
with
the
chemical
function,
the
chemical
form,
the
chemical
concentration,
and
other
information
to
develop
exposure
scenarios
and
estimates
of
occupational
exposures.


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
that
might
be
good
candidates
for
early
involvement
in
risk
assessment
and
risk
management
activities,
as
well
as
pollution
prevention.


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
magnitude,
frequency,
and
duration
of
exposure.
4­
10

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
less
informed
and
disciplined
regarding
exposure­
control
measures.


Maximum
Concentration:
Information
on
the
maximum
concentration
of
a
chemical
as
sent
off­
site
or
as
used
for
commercial
or
consumer
purposes
would
be
used
to
estimate
the
upper
limits
to
potential
levels
of
exposure.


Number
of
Sites:
Information
on
the
number
of
sites
where
a
chemical
is
manufactured
or
used
will
provide
information
on
the
number
of
communities
or
ecosystems
potentially
exposed.


4.2.1.2
Risk
Management
Programs
Better
risk
screening
ultimately
generates
opportunities
for
improved
risk
management
by
EPA
and
other
entities.
Most
importantly,
it
improves
the
setting
of
priorities
for
risk
management
activities
by
helping
to
distinguish
between
relatively
high
risk
and
low
risk
chemicals.
The
IUR
amendments
may
also
provide
EPA
and
other
risk
management
entities
with
information
that
will
allow
them
to
better
evaluate
alternative
risk
management
strategies
for
high
priority
chemicals.
Box
4­
2
also
presents
OPPT
risk
management
programs
that
might
benefit
from
the
greater
scope
and
depth
of
the
new
IUR
data,
including
the
Existing
Chemicals
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
IUR
amendments
also
would
be
useful
to
a
variety
of
other
OPPT
programs
or
initiatives,
especially
the
New
Chemicals
Program.

4.2.1.3
Benefits
from
Cost
Savings
Associated
with
Screening
Activities
The
amended
IUR
will
reduce
the
average
time
and
other
Agency
resources
spent
per
chemical
in
the
screening
processes.
Because
the
current
IUR
lacks
exposure­
related
data
beyond
estimates
of
production
volume,
OPPT
must
rely
on
a
variety
of
other
data
sources
to
develop
better
indicators
or
estimates
of
exposure.
As
described
in
more
detail
in
Section
2
and
Appendix
B,
these
alternative
sources,
such
as
PAIR,
TRI,
NOES,
are
ill­
suited
for
this
task,
primarily
because
their
coverage
of
chemicals
and/
or
manufacturers
is
limited
or
because
the
data
have
only
been
collected
on
a
one­
time
basis.
The
processing
and
use
information
required
by
the
IUR
amendments
will
address
these
limitations.
It
will
decrease
OPPT's
reliance
on
alternative
data
sources
that
are
less
complete,
reliable,
and
up­
to­
date
and
are
therefore
more
costly
to
use.
Although
EPA
will
bear
some
additional
costs
in
collecting
and
managing
the
new
IUR
exposure
and
use
data,
overall
the
rule
is
expected
to
greatly
reduce
the
time
and
effort
required
of
EPA
to
collect
and
process
data
or
to
develop
exposure
estimates
for
screening
purposes.
Resources
will
be
saved
by
streamlining
the
screening
process
and
more
quickly
eliminating
chemicals
from
further
consideration.
In
this
way
the
Agency
avoids
the
time
and
other
resource
costs
that
would
otherwise
be
needed
to
further
evaluate
them.
Some
of
these
savings
can
be
roughly
estimated
by
examining
the
TSCA
4­
11
Inventory
and
screening
needs.
The
Inventory
and
Inventory
Update
processes
provide
production
volume
information
for
chemicals
that
is
then
used
to
further
screen
chemicals
for
exposure
risks.
Based
on
these
data,
EPA
has
decided
that
further
information
is
not
a
priority
at
this
time
for
a
large
portion
of
the
75,000
chemicals
on
the
TSCA
Inventory.
However,
for
about
10
to
15
percent
of
those
chemicals,
additional
information
is
required
to
adequately
assess
the
potential
risks.
This
amendment
will
collect
manufacturing­
level
information
on
8,900
of
these
chemicals
and
ultimately
provide
detailed
processing
and
use
for
approximately
4,600
of
these
8,900
chemicals.
By
allowing
EPA
to
screen
these
chemicals
more
effectively,
the
IUR
amendments
will
save
resources
by
reducing
the
number
of
chemicals
requiring
moredetailed
evaluations.
Assuming,
as
per
Box
2­
2
(
see
Section
2),
that
these
activities
require
100
hours
per
chemical,
reducing
the
number
of
chemicals
that
proceed
through
the
screening
process
could
result
in
savings
of
many
FTEs
over
time.
For
example,
if,
as
a
result
of
this
new
information,
the
number
of
chemicals
entering
Existing
Chemicals
Review
is
reduced
from
6,000
to
3,000,
savings
of
300,000
hours
or
144
FTEs
would
result.
The
information
required
by
the
IUR
amendments
will
reduce
OPPT's
reliance
on
unsuitable
data
sources
and
allow
it
to
more
quickly
and
more
cost­
effectively
make
these
screening
determinations.
As
a
result,
a
larger
number
of
chemicals
per
year
can
be
reviewed,
and
ultimately
the
time
and
resources
spent
evaluating
all
chemicals
of
concern
can
be
reduced.
The
public
will
ultimately
benefit
from
this
more
efficient
use
of
EPA's
resources.
In
other
words,
IUR
data
will
help
free
up
resources
for
other
EPA
activities
(
including
additional
chemical
risk
screening
and
management).

4.2.1.4
Benefits
from
Improved
Risk
Screening
and
Risk
Management
Decisions
The
chemical
processing
and
use
information
required
by
the
rule
will
contribute
to
better
decisionmaking
and
priority
setting
in
OPPT's
risk­
screening
and
risk
management
programs.
Under
ideal
circumstances
(
i.
e.,
full
information),
OPPT
would
be
able
to
completely
sort
chemicals
and
prioritize
risk
management
activities
according
to
where
the
net
benefits
of
these
activities
are
the
highest.
That
is,
it
would
be
able
to
(
1)
identify
the
chemicals
that
pose
relatively
high
potential
risks
to
humans
and
ecosystems
(
and/
or
relatively
low
costs
of
control),
and
(
2)
target
these
chemicals
for
regulation
or
other
forms
of
control.
Although
the
rule
will
not
provide
full
information
regarding
all
chemical
risks,
it
will
significantly
improve
the
information
available
for
making
these
judgments.
Compared
to
the
current
situation,
the
new
rule
will
result
in
larger
net
benefits
to
society
from
OPPT's
risk­
screening
and
management
programs.
For
example,
between
1990
and
1994,
1,924
chemicals
were
identified
as
candidates
for
the
EPA's
RM1
screening
process.
Of
these,
561
chemicals
C
an
average
of
112
chemicals
per
year
C
proceeded
through
RM1
and
were
either
recommended
for
further
testing,
for
further
risk
management,
or
for
closure.
The
RM1
process
was
primarily
informed
by
hazard
(
test)
data
as
opposed
to
hazard
data
coupled
with
actual
exposure
scenarios.
This
critical
lack
slowed
the
RM1
screening
process
considerably.
RM1
screening
was
discontinued
in
1998
due
to
the
fact
that
the
4­
12
Agency
felt
its
resources
could
be
used
more
effectively
in
other
risk
management
programs.
Existing
chemicals
review
continues
under
other
TSCA
programs,
but
none
provide
the
wide
coverage
that
will
be
necessary
to
effectively
screen
the
large
numbers
of
chemicals
for
which
EPA
is
required
to
manage
risks.
With
data
from
the
amended
IUR,
such
screening
can
proceed,
and
EPA's
mandate
to
manage
chemical
risks
can
be
fulfilled
more
effectively.
The
amended
IUR
will
improve
the
Agency's
ability
to
identify
potentially
high
risk
chemicals
or
chemical
uses
and,
when
appropriate,
to
accelerate
risk
assessment
and
management
activities
in
these
areas.
Under
current
conditions,
inadequate
chemical­
specific
information
may
be
delaying
or
even
precluding
actions
on
potentially
high
risk
chemicals.
Similarly,
new
exposure
and
use
information
will
assist
the
Agency
in
identifying
relatively
low
risk
chemicals
or
chemical
uses.
As
a
result,
these
chemicals
will
receive
lower
priority,
allowing
the
Agency
to
delay
or
even
completely
avoid
projects
that
lead
to
relatively
small
risk
reductions
relative
to
their
costs.
Therefore,
the
amended
IUR
will
prioritize
risk
management
activities
to
favor
those
that
are
expected
to
provide
the
largest
net
benefits
for
society.
That
is,
it
will
help
EPA
to
distinguish
the
risk
management
projects
that
have
the
highest
returns
(
i.
e.,
the
largest
risk
reduction)
net
of
the
costs
they
impose
on
society.
As
a
result,
the
availability
of
new
exposure
and
use
information
should
lead
to
tangible
reductions
in
mortality,
morbidity,
and
ecosystem
damages.
Compared
to
a
baseline
situation
without
the
rule,
high­
risk
exposures
will
be
identified
and
controlled
earlier.
And,
although
controls
on
some
relatively
low­
risk
exposures
may
be
delayed,
the
net
impact
will
be
to
reduce
the
incidence
of
fatal
and
nonfatal
illnesses
and
to
reduce
damages
to
ecosystems.
The
IUR
amendments
can
also
help
in
other
ways
to
identify
the
risk
management
activities
with
the
highest
expected
net
benefits.
In
addition
to
helping
identify
which
chemicals
should
receive
higher
priority,
the
information
may
also
be
useful
in
selecting
the
most
appropriate
risk
management
strategies
for
high
priority
chemicals.
For
example,
a
better
understanding
of
the
extent
and
types
of
uses
for
a
chemical
can
help
to
determine
whether
an
information
disclosure
approach
is
adequate
or
whether
more
proactive
regulatory
actions
are
needed.
Also,
the
IUR
information
would
provide
information
that
would
help
in
assessing
the
costs
of
managing
chemical
risks.
For
instance,
information
on
downstream
uses
can
be
used
to
evaluate
the
market
demand
for
the
chemical
and
the
market
adjustments
that
would
occur
as
a
result
of
risk
management
activities.
In
other
words,
this
information
can
also
help
to
distinguish
between
more
and
less
costly
risk
management
actions.
Ideally,
assessing
the
present
value
of
the
net
benefits
of
the
rule
would
involve
the
following
steps.
The
first
step
would
be
to
determine
"
baseline"
conditions.
This
step
involves
projecting
when
specific
risk
management
activities
would
be
undertaken
in
the
absence
of
the
new
rule
and
estimating
the
annual
net
benefits
to
society
(
i.
e.,
the
value
of
risk
reductions
net
of
their
control
costs)
associated
with
each
of
these
activities.
The
present
value
of
net
benefits
under
baseline
conditions
can
then
be
calculated
by
discounting
all
future
net
benefits
of
baseline
activities
to
the
present
and
aggregating
across
all
activities
and
future
years.
The
second
step
would
be
to
4­
13
determine
conditions
with
the
new
rule.
This
step
involves
estimating
the
revised
timing
and
net
benefits
of
activities
that
would
occur
using
the
new
exposure
and
use
information
and
then
duplicating
the
present
value
net
benefit
calculation
for
these
activities.
The
third
step
would
be
to
calculate
the
incremental
present
value
of
the
rule.
This
value
is
simply
the
difference
between
the
present
value
calculations
of
the
first
two
steps
(
i.
e.,
with
and
without
the
rule).
The
incremental
benefits
of
the
rule
arise
because
the
activities
with
the
largest
annual
net
benefits
C
in
particular,
those
with
the
largest
risk
reductions
C
would
be
undertaken
sooner
and
would
therefore
generate
benefits
that
accrue
over
a
longer
period
than
under
the
baseline
scenario.
Data
limitations,
however,
make
this
ideal
approach
difficult
to
implement.
First,
even
for
baseline
conditions,
determining
how
risk
management
activities
will
be
prioritized
is
very
difficult.
Second,
estimating
the
net
benefits
of
management
activities
under
either
scenario
is
even
more
difficult,
precisely
because
detailed
information
on
exposures
and
risks
is
currently
lacking
for
many
chemicals.

4.2.2
Benefits
to
Non­
OPPT
Risk
Management
Programs
In
addition
to
OPPT,
other
public
and
private
organizations
are
actively
involved
in
managing
chemical
risks.
These
organizations
include
other
EPA
programs,
the
Occupational
Health
and
Safety
Administration
(
OSHA),
the
National
Institute
of
Occupational
Safety
and
Health
(
NIOSH),
the
Consumer
Product
Safety
Commission
(
CPSC),
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
related
information
to
effectively
and
efficiently
manage
chemical
risks.
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
IUR
amendments
could
be
used
to
further
benefit
society
(
in
addition
to
the
gains
from
OPPT
programs)
by
contributing
to
more
effective
and
efficient
management
of
chemical
risks.
4.2.2.1
Other
Federal
Risk
Management
Programs
Federal
efforts
other
than
OPPT's
would
also
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
4­
14
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.
NIOSH
could
use
amended
IUR
data
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
new
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
information
is
limited
to
injuries
and
illnesses
resulting
from
acute
exposures
only.
Information
identifying
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
B
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.

4.2.2.2
State
and
Local
Programs
The
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.

4.2.2.3
Nongovernmental
Organization
(
NGO)
Initiatives
and
Private­
Sector
Stewardship
Many
private­
sector
organizations
have
a
strong
interest
in
reducing
risks
and
providing
leadership
in
preventing
pollution
while
still
maintaining
productive
economic
enterprises.
These
organizations
can
better
meet
these
objectives
by
developing
a
better
understanding
of
how
chemicals
are
used
in
general.
This
will
allow
them
to
more
effectively
manage
risks
and
participate
in
community,
regional,
and
national
priority
setting
for
chemicals.
4­
15
The
publicly
available
(
non­
CBI)
information
provided
by
the
amended
IUR
would
support
activities
typically
undertaken
by
NGOs,
such
as
tracking
industry
trends,
organizing
grassroots
involvement
in
risk­
based
decisionmaking,
and
conducting
outreach
and
educational
programs.
These
organizations
could
use
the
new
data
to
identify
and
establish
priorities
for
risks;
to
evaluate
chemicals
and
chemical
use
patterns
to
determine
areas
of
concern;
to
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
CMA's
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,
some
companies
have
told
EPA
that
they
do
not
know
how
their
chemicals
are
used.
Non­
CBI
information
provided
by
multiple
companies
could
give
an
individual
company
a
better
understanding
of
the
downstream
uses
of
its
product,
therefore
enabling
more
effective
implementation
of
the
Responsible
Care
concepts.

4.3
Benefits
Due
to
Changes
in
CBI
Reporting
A
second
category
of
benefits
attributable
to
the
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.
The
increased
data
availability
will
ultimately
benefit
the
public
by
allowing
them
to
better
evaluate
(
and
if
necessary
react
to)
public­
sector
risk
management
decisions
and
to
make
more
informed
risk
management
decisions
of
their
own.
Three
basic
changes
will
occur.
First,
EPA
is
proposing
to
add
a
requirement
to
provide
upfront
substantiation
for
site
identification,
as
well
as
retaining
the
existing
requirement
for
upfront
substantiation
for
chemical
identity.
EPA
has
found
that,
in
the
past,
CBI
claims
have
been
made
for
site
identification
when
that
information
has
already
been
made
public
through
the
reporting
requirements
under
EPCRA
and
other
public
documents.
This
requirement
will
discourage
such
erroneous
claims.
Second,
under
the
rule,
submitters
can
claim
a
non­
CBI
status
for
production
volume
information
in
ranges
while
continuing
to
claim
specific
production
volume
as
CBI.
As
was
the
case
in
the
original
TSCA
Inventory,
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.
33Under
Option
6,
inorganic
chemicals
would
maintain
their
full
exemption
from
both
site
and
manufacturing
information
and
from
processing
and
use
information.
Consequently,
for
Option
6,
no
benefits
(
relative
to
the
baseline
situation)
would
be
associated
with
the
modifications
to
the
inorganic
chemical
exemption.

4­
16
Third,
beginning
with
the
second
collection
cycle
under
the
amended
IUR,
reassertion
of
CBI
claims
from
the
prior
IUR
submission
will
be
required.
EPA
believes
that
information
that
is
four
years
old
or
more
might
often
have
lost
its
proprietary
value
and
will
not
need
to
be
maintained
as
CBI
at
public
expense.
This
change
provides
a
mechanism
to
ensure
that
older
CBI
claims
will
be
reviewed
by
the
submitter;
companies
will
have
to
restate
a
claim
or
else
confidentiality
would
lapse.
While
the
Agency
will
be
collecting
a
greater
volume
of
data
through
the
amended
IUR,
much
of
which
will
be
CBI,
EPA
expects
these
changes
to
reduce
the
percentage
of
that
data
incorrectly
claimed
as
CBI,
and
to
decrease
the
percentage
of
information
that
would
have
to
remain
under
CBI
protection.
This
will
increase
the
amount
of
information
available
to
the
public,
which
has
several
benefits.
The
Agency
will
be
able
to
discuss
and
explain
its
actions
and
decisions
more
publicly.
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,
such
that
the
Agency
will
ultimately
be
in
an
improved
position
to
incorporate
the
public's
preferences
and
concerns
in
its
decisions.
Second,
the
Agency
will
be
able
to
provide
other
public
and
private
organizations
and
individuals
with
better
information
for
making
their
own
decisions.
These
informationbased
benefits
are
discussed
in
more
detail
in
earlier
parts
of
this
section
and
center
around
the
fact
that
increasing
the
amount
of
information
available
to
the
public
allows
for
improved
understanding
of
potential
exposure
and
risk
concerns,
and
thus
more
effective
and
efficient
risk
management.

4.4
Benefits
of
Changing
Reporting
Exemptions
A
third
category
of
expected
benefits
of
the
IUR
amendments
relates
to
changes
in
exemptions
for
certain
inorganic,
petroleum
process
stream,
and
natural
gas
chemicals.
One
major
change
is
that
inorganic
chemicals
will
no
longer
be
exempt
from
IUR
reporting
requirements.
Inorganic
chemicals
will
file
partial
reports
in
the
first
reporting
period
and
full
reports
thereafter.
The
inorganic
chemical
exemption
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
have
brought
EPA
to
the
conclusion
that
hazard
information
alone
is
not
enough
to
protect
human
health
and
the
environment
C
basic
information
for
inorganic
chemicals
is
also
needed.
The
partial
exemption
for
inorganic
chemicals
in
the
first
reporting
period
will
allow
firms
to
become
accustomed
to
IUR
reporting.
33
It
is
estimated
that
removing
the
production
volume
exemption
for
inorganic
chemicals
would
make
site
manufacturing
data
available
for
an
additional
1,100
chemicals
in
the
first
wave
of
amended
IUR
reporting,
and
it
would
make
processing
4­
17
and
use
data
available
for
630
of
these
chemicals
(
with
production
volumes
greater
than
300,000
pounds)
in
later
years.
This
information
would
allow
OPPT
to
avoid
some
of
the
current
costs
involved
in
conducting
risk
screening
and
developing
management
activities
for
those
chemicals.
It
would
also
improve
EPA's
ability
to
prioritize
and
make
risk
management
decisions
about
this
class
of
chemicals
that
heretofore
have
been
difficult
or,
in
some
cases,
not
possible.
As
is
the
case
with
the
other
extensions
of
IUR
reporting,
the
public
will
ultimately
benefit
from
this
exemption
through
lower
publicsector
costs
and
through
risk
management
activities
that
will
be
better
targeted
to
areas
where
the
risk
reductions
and
net
benefits
to
society
are
the
greatest.
A
second
type
of
exemption
that
is
being
instituted
by
EPA
is
a
partial
exemption
for
petroleum
process
stream
chemicals,
which
would
exclude
them
from
the
processing
and
use
reporting
requirements
for
other
chemicals.
Relative
to
baseline
conditions,
there
would
be
no
specific
benefits
or
costs
associated
with
this
exemption.
It
would,
in
effect,
maintain
the
status
quo
for
these
chemicals
since
they
(
and
all
other
chemicals)
are
currently
exempt
from
such
reporting.
The
partial
exemption
is
being
maintained
because
petroleum
streams
tend
to
be
complex
chemical
combinations
with
variable
constituents.
A
third
exemption
that
is
being
instituted
is
to
exclude
certain
forms
of
natural
gas
(
six
chemical
substances
in
total)
from
all
IUR
reporting,
including
both
production
volume
information
and
processing
and
use
data.
In
the
1998
reporting
period,
reports
on
these
chemicals
accounted
for
roughly
4
percent
of
all
IUR
reports
submitted.
Compared
to
baseline
conditions,
this
would
result
in
less
information
being
available
to
evaluate
these
chemicals.
Although
this
would
partially
reduce
the
informationbased
benefits
of
the
rule,
EPA
expects
this
effect
to
be
small
because
most
of
EPA's
and
other
IUR
users'
needs
with
regard
to
these
chemicals
can
be
met
with
previously
collected
IUR
information
or
other
publicly
available
information.

4.5
Benefits
of
Administrative
Changes
A
separate
source
of
benefits
from
the
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,
the
time
frame
changes
for
IUR
reporting
would
make
the
data
more
internally
consistent
and
more
compatible
with
other
EPA
reporting
requirements.
As
with
the
other
changes
to
IUR
reporting,
the
public
will
ultimately
benefit
through
lower
publicsector
costs
and
through
more
efficiently
targeted
risk
management
activities
that
will
increase
net
benefits
to
society.
The
major
administrative
change
will
shift
the
reporting
time
frame
from
fiscal
year
to
calendar
year
for
all
reporting
sites
will
help
to
standardize
the
information
collected
across
IUR
submitters
and
with
respect
to
other
reporting
initiatives.
For
instance,
a
calendar
year
reporting
cycle
will
correspond
with
the
TRI
reporting
period,
enhancing
the
Agency's
ability
to
develop
linkages
between
the
two
databases.
This
will
lower
analysis
costs
for
the
Agency
and
allow
for
more
accurate
assessments
of
chemical
releases,
exposures,
and
risks.
4­
18
4.6
Benefits
From
Changes
to
Reporting
Thresholds
There
are
two
reporting
thresholds
in
these
amendments
C
a
reporting
threshold
for
site
and
manufacturing
information
(
e.
g.,
site
location
and
information
associated
with
producing
the
chemical)
and
a
reporting
threshold
for
processing
and
use
data
(
e.
g.,
numbers
of
exposed
employees
at
use
sites,
number
of
use
sites,
percentage
of
production
volume).
The
reporting
threshold
options
considered
by
EPA
are
presented
in
Table
4­
1.
As
discussed
previously
in
this
section,
relative
to
conditions
without
the
IUR
amendments,
each
of
the
threshold
options
for
processing
and
use
data
C
100,000,
300,000,
and
1
million
pounds
C
would
increase
the
amount
of
information
available
for
evaluating
potential
chemical
risks.
This
would
be
particularly
true
after
the
first
year
of
revised
IUR
reporting
when
processing
and
use
data
on
inorganic
chemicals
would
also
be
reported.
Lower
thresholds
would
provide
relatively
more
information
and
thus
more
benefits.
These
benefits
are
discussed
qualitatively
in
Section
4.2.
In
contrast,
the
threshold
for
site
and
manufacturing
data
under
all
of
the
options
(
25,000
pound
production
volume
per
year)
is
higher
than
the
current
threshold
(
10,000
pounds).
This
will
decrease
the
amount
of
chemical
information
available.
With
this
change,
benefits
would
decrease
because
EPA
risk
managers
would
no
longer
have
access
to
current
data
on
lower­
volume
chemicals
(
i.
e.,
those
produced
between
10,000
and
25,000
pounds).
In
considering
the
threshold
levels,
EPA
balanced
information
needs
and
associated
benefits
with
the
cost
of
the
information.
EPA
has
determined
that
the
selected
threshold
levels
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.
Based
on
historical
IUR
data
regarding
the
number
of
report
submissions
and
taking
into
account
the
changes
in
exemptions
included
in
the
IUR
amendments
(
addition
of
inorganic
chemicals),
information
on
approximately
10,400
chemicals
would
be
reported
if
the
current
10,000
pound
threshold
were
maintained.
It
is
estimated
that,
by
increasing
the
reporting
threshold
to
25,000
pounds,
information
on
approximately
15
percent
fewer
chemicals
C
approximately
8,900
in
total
C
would
be
collected.
This
loss
of
data
will
potentially
affect
EPA's
ability
to
undertake
risk
screening
activities,
as
well
as
the
preparation
of
certain
important
analyses,
including
use,
substitutes,
and
use
cluster
analyses.
Although
increasing
this
threshold
will
exclude
lower
volume
chemicals
(
which
are
generally
assumed
to
be
less
of
a
risk
concern
than
those
produced
in
larger
volumes),
information
on
these
chemicals
can
often
provide
useful
data
for
evaluating
the
availability
of
substitutes
for
larger
production
chemicals.
In
addition,
acquiring
information
on
lower­
volume
chemicals
from
alternative
sources
(
if
any
exist)
can
be
particularly
costly,
because
information
on
these
chemicals
is
much
less
likely
to
be
publicly
available
than
for
high
volume
chemicals.
Consequently,
by
increasing
this
reporting
threshold,
information
that
would
help
to
reduce
exposures
and
risks
may
become
more
costly
to
attain
or
may
simply
no
longer
be
available
to
OPPT.
The
public
will
ultimately
lose,
either
through
higher
4­
19
public­
sector
costs
or
through
less
socially
optimal
outcomes
from
risk
management
decisions.
It
is
expected,
however,
that
reductions
in
societal
benefits
associated
with
a
change
from
10,000
pounds
to
25,000
pounds
for
site
and
manufacturing
data
would
not
be
significant
compared
to
the
gains
from
the
selected
thresholds
for
processing
and
use
data.
EPA
chose
this
threshold
level
to
lessen
the
increased
burden
on
submitters;
however,
in
doing
so
it
recognizes
that
information
on
the
lower­
volume
chemicals
can
be
particularly
useful
and
may
find
it
necessary
to
collect
this
information
in
the
future.

4.7
Benefits
From
Alternative
Reporting
Cycle
Options
The
baseline
reporting
cycle,
which
requires
IUR
submissions
every
four
years,
is
being
retained
under
the
selected
option.
Therefore,
relative
to
baseline
conditions,
no
specific
benefits
will
result
from
this
aspect
of
the
rule.
EPA
considered
two
alternatives
to
this
cycle.
The
first
alternative,
referred
to
as
Option
5
in
Table
4­
1,
would
require
all
information
to
be
reported
every
two
years.
Past
experience
with
data
reported
under
the
IUR
has
demonstrated
the
dynamic
nature
of
the
chemical
industry
(
about
30
percent
of
the
chemicals
reporting
in
1990
were
not
reported
in
1994).
This
provides
a
strong
indication
that
more
frequent
reporting
would
provide
EPA
and
others
with
more
accurate
and
more
up­
to­
date
information
to
support
risk­
screening
and
management
activities.
However,
EPA
has
concluded
that
the
four­
year
cycle
is
sufficient
for
its
current
needs,
and
that
the
twoyear
cycle
would
not
provide
enough
additional
benefit
to
justify
the
additional
reporting
expense
to
industry.
A
second
alternative,
considered
under
Option
8,
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
the
information
would
quickly
become
out­
of­
date.
5­
1
SECTION
5
BENEFIT­
COST
ANALYSIS,
COST­
EFFECTIVENESS
COMPARISONS,
AND
RATIONALE
FOR
THE
SELECTED
OPTION
EPA
performs
benefit­
cost
analyses
of
potential
regulatory
actions
to
select
the
option
that
offers
the
highest
benefit­
cost
tradeoff
and
to
ensure
that
the
social
benefits
of
the
selected
option
outweigh
its
social
costs.
For
the
IUR
amendments,
however,
the
benefits
of
the
proposed
rule
are
difficult
to
quantify
and
monetize.
As
a
result,
EPA
has
used
a
cost­
effectiveness
criterion
to
compare
regulatory
options.
Cost­
effectiveness
typically
describes
the
cost
per
discrete
unit
of
a
quantified,
but
not
monetized,
benefit.
It
measures
the
relative
efficiency
of
regulatory
options
in
achieving
different
levels
of
the
targeted
outcome.
The
cost­
effectiveness
measure
is
generally
calculated
by
dividing
the
costs
of
a
regulatory
option
by
the
estimated
number
of
targeted
outcomes
achieved.
For
environmental
regulations,
costeffectiveness
can
often
be
expressed
by
measures
such
as
the
cost
per
life
saved
or
the
cost
per
illness
avoided
by
the
option.
However,
as
described
in
Section
4,
the
targeted
outcome
of
information
rules
C
improvement
in
welfare
from
better
decisionmaking
C
is
not
easily
quantified.
Therefore,
for
this
analysis,
the
"
effectiveness"
of
each
option
is
characterized
by
the
quantity
of
different
types
of
IUR
data
collected
(
partial
forms,
full
forms).
Because
it
is
not
meaningful
to
sum
across
all
partial
and
full
forms
collected
across
different
chemicals
to
come
up
with
a
single
measure
of
effectiveness,
EPA
does
not
estimate
costs
on
a
per­
unit
basis
in
this
assessment.
Rather,
the
array
of
information
provided
and
the
costs
of
each
option
are
presented
and
compared.
The
remainder
of
this
section
presents,
first,
the
information
provided
by
and
costs
of
the
selected
option
for
amending
the
IUR.
The
selected
approach
provides
the
benchmark
against
which
all
nonselected
regulatory
options
can
be
compared.
Those
comparisons
are
discussed
in
the
subsection
that
follows
the
assessment
of
the
selected
option.
The
section
concludes
with
a
summary
justifying
the
selected
option
on
benefit­
cost
criteria.

5.1
Benefits
and
Costs
of
the
Selected
Option
As
discussed
in
Section
2,
the
regulatory
options
for
amending
the
IUR
vary
along
several
dimensions.
Of
particular
relevance
is
the
chemical
production
threshold,
which
determines
when
producers
must
report
only
site
and
manufacturing
data
(
partial
form)
and
when
they
must
report
processing
and
use
data
(
full
form).
Other
dimensions
of
the
regulation
include
the
length
of
the
reporting
cycle
and
the
allowance
of
reporting
exemptions
for
various
classes
of
chemicals.
5­
2
The
selected
approach
for
the
IUR
amendments,
Option
1,
requires
subject
chemicals
to
be
reported
if
they
are
produced
or
imported
in
quantities
of
25,000
pounds
per
year
or
more.
For
those
chemicals
produced
or
imported
at
a
volume
greater
than
or
equal
to
25,000
pounds
but
less
than
300,000
pounds,
only
the
partial
form
(
site
identification
and
manufacturing
information)
will
be
required.
For
chemicals
produced
at
a
production
volume
greater
than
or
equal
to
300,000
pounds,
with
the
exception
of
partially
exempt
chemicals,
the
submitter
will
be
required
to
submit
the
full
form,
providing
use
and
exposure
information
in
addition
to
the
site
identification
and
manufacturing
information.
Table
5­
1
summarizes
the
information
obtained
and
costs
of
the
selected
option
(
1).
It
is
estimated
that
approximately
26,800
forms
will
be
submitted
under
the
amended
IUR.
Of
that
first­
year
total,
about
9,800
(
36
percent)
will
be
full
forms
including
both
current
IUR
data
(
site
and
manufacturing)
and
IUR
amendment
(
use
and
exposure)
data.
As
described
in
Section
4,
the
information
provided
in
the
amended
IUR
forms
can
enhance
social
welfare
by
improving
the
foundation
for
public
and
private
decisionmaking
related
to
risk
management
and
by
reducing
the
cost
of
obtaining
information
to
support
these
decisions
from
other
sources.
The
roughly
17,000
remaining
forms
(
64
percent)
will
be
partial
forms
reporting
only
site
and
manufacturing
data.
The
proportion
of
full
forms
rises
in
future
reporting
years
as
inorganic
chemicals
become
fully
reportable
under
the
IUR
amdndments.

Table
5­
1.
Benefits
and
Costs
of
Selected
Option
Number
of
Reports
Filed
First
Reporting
Year
Future
Reporting
Years
Total
Partial
Full
Total
Partial
Full
26,797
17,038
9,759
26,797
14,467
12,330
Value
of
Information
in
Reports
Filed
Use
and
exposure
data
support
better
government
decisionmaking
in
prioritizing
risk
management
objectives
Consolidated
data
source
reduces
government
costs
for
risk
screening
Public
access
to
otherwise
unavailable
exposure
data
can
improve
household
risk
management
decisions
and
enable
nongovernmental
actions
Better
risk
screening
and
management
improves
welfare
by
reducing
human
and
ecosystem
exposures
to
harmful
chemicals
and/
or
averting
expenditures
Annualized
Costs
(
million
2000$)

Compliance
Agency
Total
Low
High
Low
High
19.4
23.3
0.1
19.5
23.3
5­
3
The
estimated
total
annualized
costs
of
the
IUR
amendments
range
from
$
19.5
to
$
23.3
million
per
year
over
the
first
20
years
of
the
rule.
Details
on
the
timing
of
these
costs
and
their
net
present
value
are
presented
in
Section
3.
Almost
all
of
this
total
is
in
the
form
of
costs
to
private
parties
for
complying
with
the
additional
informational
requirements
of
the
amended
IUR.
The
remainder
(
approximately
$
90,500
per
year,
annualized)
is
borne
by
taxpayers,
who
finance
the
expenditures
by
EPA
to
periodically
administer
the
data
collection.
Additional
social
costs,
in
the
form
of
labor
and
capital
dislocation,
are
not
quantified
here
but
are
expected
to
be
transitory
and
relatively
small.

5.2
Comparing
the
Benefits
and
Costs
of
Regulatory
Alternatives
to
the
Selected
Option
Several
other
regulatory
options
were
considered
in
developing
the
rule
for
the
amendments
to
the
IUR.
Table
5­
2
reports
the
differences
between
the
alternative
regulatory
options
and
the
selected
option
in
the
number
and
type
of
reports
submitted,
the
nature
of
information
provided,
and
the
annualized
cost
of
compliance
and
administration.
Several
of
the
options
proposed
a
lower
threshold
for
use
and
exposure
data
(
100,000
pounds)
than
the
selected
option
(
300,000
pounds).
In
the
case
of
Option
2,
that
was
the
only
difference
from
the
selected
option.
Lowering
the
threshold
would
expand
the
collection
of
use
and
exposure
data
by
increasing
the
number
of
full
reports
by
about
3,200
forms
in
the
first
year
and
just
over
4,000
forms
in
future
reporting
years,
but
it
would
increase
the
annualized
costs
of
the
effort
by
$
4.3
to
$
4.9
million
(
about
one­
quarter).
Option
6
is
similar
to
Option
2
in
lowering
the
threshold
to
100,000
pounds,
but
it
exempts
inorganic
chemicals
from
any
reporting
requirements.
This
reduces
the
incremental
costs
of
the
option,
relative
to
the
selected
option,
but
essentially
eliminates
all
information
on
inorganic
chemicals.
Option
7
lowers
the
use
and
exposure
data
threshold
and
requires
biennial
reporting.
This
option
raises
the
costs
of
the
rule
substantially,
more
than
doubling
the
cost
of
the
selected
option.
Alternatively,
Option
8
lowers
the
threshold
to
100,000
pounds,
but
information
will
be
reported
only
once.
This
lowers
annualized
costs
substantially
but
foregoes
all
future
updates
to
this
information,
thereby
greatly
constraining
future
risk
screening
and
management
actions.
A
couple
of
the
options
examine
thresholds
higher
than
300,000
pounds
for
use
and
exposure
data.
Option
3
raises
the
threshold
to
500,000
pounds,
which
lowers
costs
by
about
9
to
13
percent,
but
reduces
use
and
exposure
data
for
over
1,200
chemical
streams
of
between
300,000
and
500,000
pounds.
Option
4
considers
raising
the
threshold
further
to
1,000,000
pounds,
which
lowers
costs
further
(
22
to
24
percent
lower
than
the
selected
option)
but
loses
use
and
exposure
data
on
several
thousand
chemical
streams
in
the
300,000
to
1,000,000
pound
range.
Finally,
Option
5
considers
raising
the
threshold
from
300,000
pounds
to
500,000
pounds
in
the
first
reporting
year
but
lowering
the
threshold
to
100,000
pounds
in
all
future
years.
When
compared
with
the
selected
option,
the
higher
first­
year
threshold
gives
some
cost
relief
5­
4
initially,
but
the
overall
annualized
cost
of
that
option
is
about
11
to
17
percent
higher
than
the
selected
option.

5.3
Benefit­
Cost
Summary
5.3.1
Rationale
for
Selecting
Option
1
Option
1
is
among
the
most
cost­
effective
options
considered
at
the
preliminary
and
final
stages
of
the
rulemaking
process.
That
is,
it
has
low
incremental
costs
for
the
number
of
full
and
partial
forms
that
would
be
submitted.
First,
its
minimum
reporting
threshold
(
i.
e.,
the
level
at
which
a
partial
form
is
required)
is
25,000
pounds
and
not
10,000
pounds,
as
with
the
current
IUR.
EPA
recognizes
that
the
IUR
amendments
expand
industry
burden,
and
by
forgoing
data
on
these
lower­
volume
chemicals,
the
Agency
will
mitigate
the
increase.
Of
course,
this
comes
at
the
cost
of
potentially
valuable
data
on
lower­
volume
chemicals.
Second,
Option
1
collects
full
information
for
chemicals
in
excess
of
300,000
pounds
of
production.
Again,
while
EPA
would
prefer
to
have
full
reporting
data
on
all
chemicals,
the
Agency
also
recognizes
the
need
to
limit
industry
burden,
and
believes
that
a
300,000
pound
threshold
for
processing
5­
5
and
use
information
balances
the
Agency's
informational
needs
with
the
cost
to
industry.
Other
options
for
cutting
the
cost
of
the
rule,
such
as
raising
the
thresholds
higher
(
500,000
and
1,000,000
pounds
respectively)
and
requiring
only
one­
time
reporting,
were
judged
to
involve
the
loss
of
too
much
valuable
information
on
current
Table
5­
2.
Incremental
Benefits
and
Costs
of
Regulatory
Alternatives
(
Relative
to
Selected
Option
1)

Difference
in
Number
of
Reports
Filed
Option
First
Reporting
Year
Future
Reporting
Years
Total
Partial
Full
Total
Partial
Full
2
0
B
3,187
3,187
0
B
4,049
4,049
3
0
1,224
B
1,224
0
1,572
B
1,572
4
0
2,707
B
2,707
0
3,474
B
3,474
5
0
1,224
B
1,224
0
B
4,049
4,049
6
B
4,537
B
7,724
3,187
B
4,537
B
5,153
616
7
0
B
3,187
3,187
0
B
4,049
4,049
8
0
B
3,187
3,187
0
B
4,049
4,049
Option
Difference
in
Nature
of
Information
Collected
2
Gain
use
and
exposure
data
on
chemicals
with
volumes
of
100
B
300K
3
Lose
use
and
exposure
data
on
chemicals
with
volumes
of
300
B
500K
4
Lose
use
and
exposure
data
on
chemicals
with
volumes
of
300K
B
1MM
5
First
year:
Lose
use
and
exposure
data
on
chemicals
with
volumes
of
300
B
500K
Future
years:
Gain
use
and
exposure
data
on
chemicals
with
volumes
of
100
B
300K
6
Inorganic:
No
reporting
requirements
All
other:
Gain
use
and
exposure
data
on
chemicals
with
volumes
of
100
B
300K
7
Information
reported
more
frequently
(
every
two
years)

Gain
use
and
exposure
data
on
chemicals
with
volumes
of
100
B
300K
8
Information
reported
only
once
Gain
use
and
exposure
data
on
chemicals
with
volumes
of
100
B
300K
Difference
in
Total
Annualized
Cost
(
million
2000$)

Option
Low
High
2
+
4.9
+
4.3
3
B
1.9
B
3.0
4
B
4.2
B
5.5
5
+
3.4
+
2.6
6
+
0.2
B
1.2
7
+
28.1
+
30.6
8
B
13.5
B
16.6
5­
6
and
future
use
and
exposure
data
to
justify
the
cost
savings.
Thus,
although
strict
quantification
of
the
selected
option's
benefits
is
not
possible,
the
Agency
has
judged
Option
1
to
be
the
most
cost­
effective
option
considered
for
amending
the
IUR.

5.3.2
Economic
Rationale
for
the
IUR
Amendments:
Positive
Net
Benefits
of
the
Selected
Option
In
performing
economic
analysis
of
regulatory
actions,
EPA
considers
whether
the
benefits
of
the
action
are
likely
to
justify
its
costs.
As
indicated
throughout
this
report,
the
benefits
of
amending
the
IUR
are
difficult
to
quantify
and
monetize.
The
inability
to
monetize
benefits
impedes
direct
comparison
to
costs
and
calculation
of
net
benefits.
Nonetheless,
EPA
believes
that
the
benefits
of
the
additional
information
collected
in
the
amended
IUR
fully
justify
the
costs
of
the
collection
effort.
The
benefits
of
the
IUR
amendments
are
characterized
in
Section
4
and
briefly
restated
here.
EPA
will
use
the
information
collected
under
this
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
will
help
to
determine
potential
risks,
identify
opportunities
for
safer
substitutes,
target
specific
population
groups,
and
evaluate
the
need
for
risk
management.
The
data
will
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.
EPA
has
made
every
reasonable
effort
to
estimate
the
cost
burden
of
the
rule
for
the
regulated
community,
and
to
use
that
information
to
modify
the
rule's
requirements
to
avoid
situations
that
impose
higher
costs
for
lower
information
benefits.
For
instance,
the
selected
option's
reporting
threshold
for
use
and
exposure
data
(
300,000
pounds)
is
higher
than
other
options
considered.
Moreover,
the
minimal
reporting
threshold
has
also
been
raised
from
10,000
to
25,000
pounds.
The
selected
option
also
establishes
a
partial
exemption
for
inorganic
chemicals
in
the
first
reporting
period;
establishes
a
partial
exemption
for
petroleum
process
stream
chemicals
and
a
full
exemption
for
certain
forms
of
natural
gas;
requires
the
reporting
of
known
or
reasonably
ascertainable
site
and
manufacturing
information
and
readily
obtainable
processing
and
use
information;
and
allows
submitters
to
report
much
of
the
information
in
ranges.
These
changes
lower
the
costs
of
compliance,
without
greatly
diminishing
the
amount
and
quality
of
information
for
risk
screening,
prioritization,
and
management.
34Because
the
amendments
intend
to
collect
information
from
manufacturers
and
importers
only,
small
businesses
that
only
process
or
distribute
chemicals
or
products
but
do
not
manufacture
or
import
the
chemicals
would
not
be
affected.

6­
1
SECTION
6
SMALL
ENTITY
AND
ENVIRONMENTAL
JUSTICE
IMPACT
DETERMINATIONS
The
Regulatory
Flexibility
Act
of
1980
requires
federal
agencies
to
assess
the
effects
of
final
regulations
on
small
entities
(
P.
L.
96­
354).
The
Act
requires
agencies
to
evaluate
all
rulemakings
to
determine
if
Final
Regulatory
Flexibility
Analysis
(
FRFA)
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
affected
entities.
The
Regulatory
Flexibility
Act
was
amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA)
of
1996.
This
section
examines
the
effect
of
the
IUR
amendments
on
small
entities
and
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.
This
section
examines
the
effect
of
the
IUR
amendments
on
minority
and
low­
income
populations.

6.1
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
rule,
"
small
entity"
in
this
analysis
is
synonymous
with
small
business.
For
the
IUR
amendments,
small
businesses
are
limited
to
small
chemical
manufacturers
and
importers.
34
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
prepare
an
IRFA.
The
basis
for
determining
that
there
is
no
significant
economic
impact
is
explained
below.

6.1.1
Determination
of
the
Number
of
Small
Businesses
To
determine
the
number
of
small
businesses
affected
by
the
IUR
amendments,
the
Agency
needs
to
define
small
businesses
as
used
in
this
report
and
to
develop
the
methodology
for
determining
the
number
of
small
businesses
expected
to
report
under
the
IUR
amendments.
35It
is
important
to
note
that
the
$
40
million
level
is
for
parent
company
sales,
not
individual
site
sales.

6­
2
6.1.1.1
Definition
of
a
Small
Business
The
definition
of
small
businesses
under
TSCA
§
8(
a)
includes
firms
whose
annual
sales
are
less
than
$
40
million
and
that
produce
less
than
or
equal
to
100,000
pounds
of
a
regulated
substance
at
a
single
manufacturing
site.
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.
35
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).

6.1.1.2
Number
of
Small
Businesses
The
existing
IUR
exempts
small
businesses
from
reporting;
this
exemption,
as
defined
in
TSCA
§
8(
a),
is
maintained
in
the
IUR
amendments.
However,
there
are
three
primary
reasons
why
a
small
business
as
defined
in
this
analysis
(
sales
less
than
$
40
million)
would
report
under
the
IUR.
Either
the
business
produces
a
chemical
in
a
volume
of
greater
than
100,000
pounds,
the
chemical
it
produces
is
subject
to
an
action
under
TSCA
§
4,
5(
b)(
4),
5(
e),
or
6,
or
it
is
reporting
voluntarily.
The
expected
number
of
small
businesses
reporting
under
the
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.
Second,
the
expected
number
of
businesses
producing
inorganic
chemicals
that
would
be
required
to
report
was
estimated
based
on
the
number
of
businesses
producing
organic
chemicals.
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
chemicals
and
inorganic
chemicals
identified
in
the
CICIS
database
(
1986)
maintained
by
EPA.
Together,
these
two
estimates
represent
the
number
of
small
businesses
affected.
Organic
Chemicals
(
including
Petroleum
Process
Stream
Chemicals).
To
determine
the
number
of
small
businesses
producing
organic
chemicals
that
may
be
affected
by
the
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
&
Bradstreet
(
1996;
1992),
and
Ward's
Business
Directory
(
Gale
Research,
1996).
Annual
sales
data
were
unavailable
for
the
remaining
131
companies.
There
were
several
reasons
why
information
for
these
remaining
companies
was
unavailable.
First,
these
businesses
may
be
too
small
to
be
listed
in
the
directories
consulted.
Second,
the
IUR
database
may
be
out
of
date
because
it
is
based
on
TSCA
6­
3
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
removed
from,
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
was
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
6­
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
rule.
As
the
table
indicates,
a
range
of
between
21
percent
and
35
percent
of
the
regulated
community
may
be
considered
small
(
i.
e.,
annual
parent
company
sales
less
than
or
equal
to
$
40
million).
Inorganic
Chemicals.
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
Section
3.
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,
Number
of
Inorganic
Businesses
=
(
Number
of
Inorganic
Reports/
Number
of
Organic
Reports)
×
(
Number
of
Organic
Businesses)
Number
of
Inorganic
Businesses
=
(
4,502/
16,576)
×
758
Number
of
Inorganic
Businesses
=
206
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
6­
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
98
large
companies,
36
medium
companies,
and
72
small
companies.
Total
Number
of
Small
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
460
large,
169
medium,
and
335
small
businesses.
However,
964
may
be
an
overestimate
of
the
total
number
of
businesses
expected
to
6­
4
report
under
the
IUR
amendments
because
it
is
possible
that
some
businesses
would
submit
a
Form
U
for
both
organic
chemicals
and
inorganic
chemicals.
These
companies
would
be
double
counted,
once
as
an
inorganic
chemical
business
and
once
as
an
organic
chemical
business,
according
to
the
approach
presented
in
this
analysis.

6.1.2
Estimation
of
Impacts
According
to
the
1999
Revised
Interim
Guidance
for
EPA
Rulewriters:
Regulatory
Flexibility
Act
as
amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act,
prepared
by
the
Regulatory
Management
Division
of
EPA's
Office
of
Policy,
the
Regulatory
Flexibility
Act
does
not
define
"
significant
economic
impact
on
a
6­
5
substantial
number"
of
small
entities.
The
criterion
recommended
by
the
guidance
for
Table
6­
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
263
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:
Gale
Research
Inc.
1996.
Ward's
Business
Directory
of
U.
S.
Private
and
Public
Companies
1996.
New
York:
Gale
Research
Inc.

Dun
&
Bradstreet.
1996.
Dun's
Market
Identifiers
Database.
Parsippany,
NJ:
Dun
&
Bradstreet
Information
Services.

Dun
&
Bradstreet.
1992.
Million
Dollar
Directory:
America's
Leading
Public
and
Private
Companies,
Top
50,000
Companies.
Murray
Hill,
NJ:
Dun
&
Bradstreet
Information
Services.

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

CUS
Database.
1996.
Information
from
the
Chemical
Update
System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

CUS
Database.
1997.
Information
from
the
Chemical
Update
System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.
6­
6
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
of
annual
sales
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.
The
Regulatory
Flexibility
Act
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,
two
assumptions
were
used:


Each
site
producing
organic
chemicals
submits
an
average
of
9.0
reports,
and
each
site
producing
inorganic
chemicals
submits
an
average
of
8.3
reports
(
CUS
Database,
2000).


Each
small
business
has
one
site
(
see
Appendix
E).
This
section
also
presents
a
sensitivity
analysis
examining
the
impact
on
costs
if
more
than
one
site
per
small
business
is
assumed.

6.1.2.1
Cost­
to­
Sales
Ratios
for
Small
Businesses
Based
on
the
proportion
of
organic
chemical
reports
in
the
entire
IUR
population
that
are
expected
to
be
full
reports,
this
analysis
assumed
that
43.8
percent
of
the
reports
filed
by
small
organic
chemical
companies
will
be
full
reports
and
56.2
percent
will
be
partial
reports
in
both
the
first
reporting
year
and
all
future
reporting
years.
For
inorganic
chemicals,
there
is
a
difference
in
the
distribution
among
full
and
partial
reports
between
the
first
reporting
year
and
future
reporting
years.
In
the
first
reporting
year,
all
of
the
reports
filed
on
inorganic
chemicals
will
be
partial
reports
because
of
the
partial
exemption
that
inorganic
chemicals
have
been
granted
for
the
first
reporting
year.
In
future
years,
56.7
percent
of
inorganic
chemical
reports
are
expected
to
be
full
reports
and
43.3
percent
are
expected
to
be
partial
reports
based
on
the
percentage
of
all
inorganic
reports
that
are
estimated
to
be
full
reports.
Using
the
percentage
of
full
reports
in
the
overall
database
in
this
manner
is
likely
to
overstate
the
percentage
of
full
reports
filed
by
small
companies
to
some
extent
because
small
companies
are
presumably
more
likely
to
produce
below
the
300,000
pound
threshold
for
reporting
processing
and
use
information
than
an
average
company.
The
values
in
Tables
3­
19
and
3­
20
provide
the
average
incremental
costs
of
compliance
with
the
IUR
amendments
per
site.
For
organic
chemicals,
the
average
incremental
cost
of
compliance
with
the
amendments
is
estimated
to
be
$
27,609
to
$
32,563
in
the
first
reporting
year.
Dividing
this
cost
by
the
average
annual
sales
of
$
17.6
million,
the
average
cost­
to­
sales
ratio
is
0.16
to
0.19
percent
for
these
small
businesses
in
the
first
year
of
reporting.
Based
on
the
estimated
costs
in
future
years
of
$
23,343
to
$
27,719,
the
cost­
to­
sales
ratio
is
0.13
to
0.16
percent.
For
inorganic
chemicals,
the
average
incremental
cost
of
compliance
with
the
IUR
amendments
is
estimated
to
be
$
11,749
to
$
18,194
in
the
first
reporting
year
and
$
32,638
to
$
40,502
in
future
reporting
years
(
note
that
the
baseline
cost
for
inorganic
chemicals
is
zero).
Dividing
these
costs
by
the
average
annual
sales
of
$
17.6
million,
the
average
cost­
tosales
ratio
for
small
inorganic
chemical
businesses
reporting
under
the
IUR
amendments
is
approximately
0.07
to
0.10
percent
in
the
first
reporting
year
and
0.19
to
6­
7
0.23
percent
in
future
reporting
years.
Table
6­
2
summarizes
the
results
of
the
small
business
analysis
for
an
average
small
company.
This
analysis
provides
information
about
the
average
case
for
a
small
company,
but
there
may
be
some
significant
variation
in
annual
sales
among
small
companies.
However,
for
a
firm
to
have
a
cost­
to­
sales
ratio
larger
than
1
percent,
sales
would
have
to
be
less
than
$
4.05
million
even
for
the
highest
average
cost
per
site
presented
in
Tables
3­
19
and
3­
20.
As
mentioned
above,
firms
with
sales
of
$
4
million
or
less
are
considered
small
businesses
regardless
of
production
volume
(
40
CFR
704.3).
Therefore,
companies
small
enough
to
have
a
cost­
to­
sales
ratio
greater
than
1
percent
6­
8
would
generally
be
exempt
from
reporting
under
the
IUR
and
thus
would
not
be
significantly
affected
by
the
amendments.
This
analysis
assumed
that
there
is,
on
average,
one
site
per
company
for
small
businesses.
Table
E­
6
indicates
that
small
businesses
manufacture
a
given
chemical
at
a
mean
of
1.2
sites.
While
this
is
not
the
same
as
the
number
of
sites
per
company
because
it
is
possible
that
a
company
could
manufacture
different
chemicals
at
different
Table
6­
2.
Effect
of
IUR
Amendments
on
Small
Businesses
Organic
Chemical
Reporters
Inorganic
Chemical
Reporters
Number
Affected
Percentage
of
Sales
Number
Affected
Percentage
of
Sales
First
Reporting
Year
Allocated
by
Proportions
159
0.16
B
0.19
43
0.07
B
0.10
Allocated
as
Small
Businesses
263
0.16
B
0.19
72
0.07
B
0.10
Future
Reporting
Years
Allocated
by
Proportions
159
0.13
B
0.16
43
0.19
B
0.23
Allocated
as
Small
Businesses
263
0.13
B
0.16
72
0.19
B
0.23
Sources:
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,
DC.

CUS
Database.
1996.
Information
from
the
Chemical
Update
System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

CUS
Database.
1997.
Information
from
the
Chemical
Update
System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

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,
DC.

Gale
Research
Inc.
1996.
Ward's
Business
Directory
of
U.
S.
Private
and
Public
Companies
1996.
New
York:
Gale
Research
Inc.

Dun
&
Bradstreet.
1996.
Dun's
Market
Identifiers
Database.
Parsippany,
NJ:
Dun
&
Bradstreet
Information
Services.

Dun
&
Bradstreet.
1992.
Million
Dollar
Directory:
America's
Leading
Public
and
Private
Companies,
Top
50,000
Companies.
Murray
Hill,
NJ:
Dun
&
Bradstreet
Information
Services.

Thomas
Register.
1990.
1990
Thomas
Register
of
American
Manufacturers.
Vols.
15
and
16.
New
York:
Thomas
Publishing
Company.
6­
9
sites,
it
is
indicative
of
the
number
of
sites
that
a
company
is
likely
to
own.
Although
the
average
number
of
sites
per
chemical
is
1.2,
this
number
is
based
on
20
respondents
to
the
survey,
one
of
which
indicated
4
sites
while
the
remainder
indicated
1
site.
Therefore,
although
the
average
number
of
sites
per
company
is
indeed
1.2,
1.0
is
the
indicative
value
for
the
representative
company.
Even
though
the
assumption
of
1
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
4
and
14
sites
per
company
for
a
cost
greater
than
1
percent
of
annual
sales
to
be
incurred
for
the
typical
company.
In
addition,
even
if
the
assumption
of
1
site
per
small
business
slightly
underestimates
the
number
of
sites
per
company,
another
assumption
that
may
tend
to
overestimate
costs
offsets
this
assumption.
Specifically,
the
estimated
number
of
reports
(
9.0
for
organic
and
petroleum
stream
chemicals
and
8.3
for
inorganic
chemicals)
per
site
used
in
the
analysis
may
be
an
overestimate
of
the
expected
number
of
reports
per
site
for
small
businesses
because
small
businesses
tend
to
produce
fewer
chemicals
per
site
(
ICF,
1996).
However,
to
determine
the
impact
of
assuming
that
a
typical
small
business
has
the
same
number
of
sites
as
an
average
company,
the
analysis
was
repeated
using
an
assumption
of
2.3
sites
per
small
business.
This
is
the
average
number
of
sites
per
chemical
for
all
survey
respondents
(
ICF,
1996).
Table
6­
3
provides
the
cost
of
reporting
under
the
IUR
amendments
assuming
2.3
sites
per
small
business.
The
average
cost­
to­
sales
ratio
for
a
small
business
is
still
well
below
1
percent
of
the
annual
sales
for
an
average
small
business.
Therefore,
typical
small
businesses
will
not
experience
a
significant
economic
impact
from
the
changes
to
the
rule.
Because
the
amendments
will
not
significantly
affect
a
substantial
number
of
small
entities,
EPA
has
determined
that
an
IRFA
is
not
necessary
for
the
IUR
amendments.

6.2
Environmental
Equity/
Justice
Executive
Order
12898
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
IUR
amendments
are
an
information
collection
exercise,
no
negative
environmental
equity
issues
are
associated
with
them.
Instead,
the
information
that
would
become
available
through
the
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
to
be
gathered
under
the
IUR
amendments
would
help
EPA
make
decisions
that
will
benefit
potentially
at­
risk
communities,
some
of
which
may
be
disadvantaged.
To
illustrate
the
way
in
which
information
to
be
collected
under
the
IUR
amendments
would
benefit
minority
and
economically
disadvantaged
people
and
communities,
the
social
and
economic
characteristics
of
populations
potentially
affected
36A
"
large
number
of
reports"
is
defined
here
as
100
or
more
reports
from
an
IUR
submitting
site.

6­
10
by
the
amendments
were
compared
with
the
social
and
economic
characteristics
of
the
total
population
of
the
United
States.
Populations
potentially
affected
by
the
amendments
were
assumed
to
be
those
located
in
geographic
areas
with
a
large
number
of
reports
submitted
under
the
IUR.
36
A
significant
portion
of
low­
income
and
minority
communities
are
located
in
these
areas.
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
is
a
larger
proportion
of
minorities
than
in
the
United
States,
overall,
where
minorities
comprise
about
20
percent
of
the
population
(
approximately
49
million
minority
individuals
out
of
the
total
1990
U.
S.
population
of
248.7
million).
Roughly
24
million
(
20
percent)
of
the
people
6­
11
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
to
be
collected
through
the
IUR
amendments
will
allow
EPA
to
focus
risk­
screening
and
assessment
activities
on
chemicals
with
high
exposure
profiles
and
risks.
Additionally,
because
the
IUR
amendments
data
will
allow
EPA
and
others
to
view
chemical
exposures
and
uses
on
a
regional
or
local
level,
analyses
might
be
undertaken
that
will
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,
non­
CBI
IUR
data
will
be
publicly
available
to
groups
such
as
NGOs,
private­
sector
stewardship
programs,
other
federal
programs
such
as
Table
6­
3.
Effect
of
IUR
Amendments
on
Small
Businesses
Assuming
Two
Sites
Per
Small
Business
Organic
Chemical
Reporters
Inorganic
Chemical
Reporters
Number
Affected
Percentage
of
Sales
Number
Affected
Percentage
of
Sales
First
Reporting
Year
Allocated
by
Proportions
159
0.36
B
0.43
43
0.15
B
0.24
Allocated
as
Small
Businesses
264
0.36
B
0.43
72
0.15
B
0.24
Future
Reporting
Years
Allocated
by
Proportions
159
0.31
B
0.36
43
0.43
B
0.53
Allocated
as
Small
Businesses
264
0.31
B
0.36
72
0.43
B
0.53
Sources:
Gale
Research
Inc.
1996.
Ward's
Business
Directory
of
U.
S.
Private
and
Public
Companies
1996.
New
York:
Gale
Research
Inc.

Dun
&
Bradstreet.
1996.
Dun's
Market
Identifiers
Database.
Parsippany,
NJ:
Dun
&
Bradstreet
Information
Services.

Dun
&
Bradstreet.
1992.
Million
Dollar
Directory:
America's
Leading
Public
and
Private
Companies,
Top
50,000
Companies.
Murray
Hill,
NJ:
Dun
&
Bradstreet
Information
Services.

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

CUS
Database.
1996.
Information
from
the
Chemical
Update
System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

CUS
Database.
1997.
Information
from
the
Chemical
Update
System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.
6­
12
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
Section
4,
the
information
collected
under
the
IUR
amendments
will
aid
in
targeting
potential
health
and
ecosystem
risks.
Minority
and
economically
disadvantaged
groups
will
benefit
from
these
potential
risk
reductions
even
if
programs
specifically
targeting
disadvantaged
people
do
not
exist.
Because
the
production
volume
information
currently
available
to
EPA
is
not
always
sufficient
for
identifying
chemical
exposures
and
human
risks,
better
compilation
of
use
and
exposure
data
will
enable
EPA
to
predict
more
accurately
the
magnitude
and
nature
of
ecosystem
and
human
population
exposure.
This
better
information
on
uses
and
exposures
will
potentially
benefit
minority
and
economically
disadvantaged
groups
by
alerting
them
to
potential
chemical
exposures
in
their
workplaces
and
communities.
In
addition,
the
availability
of
better
information
will
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
will
be
used
to
develop
priorities
and
to
identify
chemicals
or
uses
that
require
a
more
detailed
risk
screening
or
assessment.
The
rapid
identification
of
potentially
high­
risk
situations
will
also
allow
for
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
may
not
be
targeted
to
a
specific
subset
of
workers,
disadvantaged
people
employed
at
these
sites
will
benefit
from
EPA's
and
others'
improved
ability
to
target
risks
and
thereby
more
efficiently
implement
the
programs
and
safety
measures
necessary
to
reduce
these
risks.
APPENDIX
A
DRAFT
REPORTING
FORM
FOR
THE
PROPOSED
IUR
AMENDMENTS
PAGE
1
of___
(
IMPORTANT:
Type
only,
read
instructions
before
completing
form)

U.
S.
Environmental
Protection
Agency
Washington,
DC
20460
Partial
Updating
of
TSCA
Inventory
Data
Base
Production
and
Site
Report
(
Section8(
a)
Toxic
Substances
Control
Act,
15
U.
S.
C
2607)

PART
I.
SITE
IDENTIFICATION
INFORMATION
SECTION
I.
CERTIFICATION
Certification
Statement:
I
hereby
certify
to
the
best
of
my
knowledge
and
belief
that
(
1)
all
information
entered
on
this
form
is
complete
and
accurate;
and
(
2)
the
confidentiality
statements
at
the
end
of
this
form
are
true
and
correct
as
to
that
information
for
which
I
have
asserted
a
confidentiality
claim.

1.1
Signature
1.2
Date
signed
1.3
Name
1.4
Official
Title
SECTION
II.
PARENT
COMPANY
AND
TECHNICAL
CONTACT
INFORMATION
2.1
Parent
Company
Name
2.2
Parent
Company
Dun
&
Bradstreet
Number
2.3
Technical
Contact
Name
2.4
Technical
Contact
Telephone
(
w/
Area
Code)
2.5
Technical
Contact
Email
Address
Technical
Contact
Mailing
Address
2.11
Technical
Contact
Address
(
Line
1)

2.12
Technical
Contact
Address
(
Line
2)

2.13
City
2.14
State
2.15
Zip
Code
SECTION
III.
PLANT
SITE
IDENTIFICATION
3.1
Plant
Site
Name
3.2
Plant
Site
Dun
&
Bradstreet
Number
EPA
Facility
Identification
Number
(
for
Agency
Use
Only)

3.3
Street
Address
(
Line
1)

3.4
Street
Address
(
Line
2)

3.5
City
3.6
County
/
Parish
3.7
State
3.8
Zip
Code
EPA
Form
Number
<
XXXX­
X>
(
Rev
2/
04/
2002)
­
Previous
editions
are
obsolete
Form
Approved
OMG
Number:
XX/
X­
XXXX
FORM
U
2006
Report
Number
Mark
"
X"
here
if
this
is
a
revision
to
the
previous
report
Previous
Report
Number
PAGE
___
of___

REPORT
NUMBER
PART
II.
MANUFACTURING
INFORMATION
SECTION
I.
CHEMICAL
IDENTIFICATION
CBI*

1.1
Chemical
Identifying
Number
1.2
ID
Code
1.3
Chemical
Name
SECTION
II.
MANUFACTURING
INFORMATION
CBI
CBI
CBI
CBI
CBI
2.1
Company
Information
2.2
Plant
Site
Identity
*
2.3
Site
limited
(
Y/
N)
2.4
Activity
(
M,
I
or
both)
2.5
Production
Volume
Range
CBI
CBI
CBI
2.6
Production
Volume
(
LB)
2.7
Number
of
Workers
(
code)
2.8
Maximum
Concentration
(
code)

a.
Physical
Form
b.
Percent
of
Production
Volume
in
each
Physical
Form
Check
All
CBI
Percent
CBI
That
Apply
2.9
Dry
Powder
2.10
Pellets
or
Large
Crystals
2.11
Water
or
Solvent
Wet
Solid
2.12
Other
Solid
2.13
Gas
or
Vapor
2.14
Liquid
PART
III.
PROCESSING
AND
USE
INFORMATION
Complete
Part
III,
section
I
and
II
only
if
the
production
volume
noted
in
Part
II,
Section
II
2.6
is
greater
than
or
equal
to
300,000
lb/
year
SECTION
I.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
b.
(
5­
digit)
NAICS
c.
Industrial
Function
d.
%
Production
e.
Number
of
f.
Number
of
use
Category
Volume
Sites
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
1.10
*
Substantiation
required
for
CBI
claims
on
chemical
identity
and
plant
site
identity.
PAGE
___
of___
REPORT
NUMBER
PART
IV.
REASSERTION
OF
PAST
CBI
CLAIM
Part
IV
does
not
need
to
be
completed
to
retain
CBI
claims
made
prior
to
reporting
year
2006.

1.1
If
an
IUR
report
was
submitted
to
EPA
for
the
last
reporting
cycle
for
the
chemical
identified
in
Part
II,
Section
I,
Last
IUR
Report
Number
item
1.1
from
the
plant
site
listed
in
Part
I,
Section
III,
enter
that
report
number
in
the
space
provided:

1.2
Do
you
wish
to
reassert
CBI
claims
made
or
reasserted
for
this
chemical
on
your
IUR
report?
SECTION
II.
COMMERCIAL
&
CONSUMER
END­
USE
EXPOSURE
RELATED
DATA
N/
A
a.
Commercial
and
Consumer
b.
Use
in
Children's
c.
Percent
Production
Volume
d.
Maximum
Concentration
Product
Category
Product
associated
with
each
category
associated
with
each
category
Code
CBI
Y/
N?
CBI
Percent
CBI
Code
CBI
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
2.10
NO
If
you
check
"
NO,"
all
the
information
you
have
previously
claimed
CBI
on
IUR's
for
this
chemical
will
be
DECLASSIFIED
AND
PUBLICLY
RELEASED
WITHOUT
FURTHER
NOTICE.
This
includes
any
reassertions
made
on
your
last
IUR
report.

YES,
all
*
SEE
BELOW
YES,
some
If
you
checked
"
YES,
some,"
include
with
this
report
an
amended
IUR
report
indicating
the
specific
changes
you
wish
to
make
in
you
prior
CBI
claims.
*
SEE
BELOW
*
If
you
checked
either
of
the
"
YES"
boxes
above,
any
data
which
you
continue
to
claim
CBI
must
qualify
for
this
protection
per
40
CFR
711.38
and
40
CFR
2.208.
If
any
of
your
answers
to
the
substantiation
questions
listed
in
40
CFR
711.38
and
submitted
with
your
original
CBI
claim
(
which
you
now
wish
to
re­
assert)
have
changed,
please
submit
amended
answers
together
with
this
Part
IV.
APPENDIX
B
CURRENT
DATA
COLLECTION
B­
1
A
number
of
chemical
data
sources
maintained
by
EPA
and
other
federal
and
state
agencies,
as
well
as
publicly
available
databases,
contain
limited
information
on
production,
processing,
emissions,
and
other
chemical
data.
However,
these
sources
generally
do
not
contain
the
type
of
chemical
processing
and
use
data
necessary
for
EPA
to
conduct
more
effective
chemical
risk
screening.
The
more
detailed
collection
of
chemical
processing
and
use
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
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
(
EPA,
1998a).
B.
1
Air
Programs
and
Datasets

The
Office
of
Air
Quality
Planning
and
Standards
(
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
(
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
ozonedepleting
substances
(
ODS).
The
information
is
collected
under
the
Significant
New
Alternatives
Policy
(
SNAP)
Program.
This
data
set
does
not
collect
the
more­
detailed
chemical
exposure
and
use
information
called
for
by
the
IUR
amendments.
B.
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
describe
the
aspects
of,
and
monitor
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
(
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
(
EPA,
1996a)
for
large
volume
industrial
chemicals
transported
in
bulk
B­
2
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
(
EPA,
1996a);
however,
the
dataset
does
not
collect
detailed
chemical
use
or
exposure
information
at
the
level
called
for
by
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.
B.
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
(
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;
EPA,
1996a).
B.
4
Pollution
Prevention
and
Toxic
Substances
Programs
and
Datasets

OPPT
administers
the
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
(
EPA,
1996a).


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.


OPPT
developed
a
joint
voluntary
program
in
cooperation
with
the
American
Chemistry
Council
(
formerly
the
Chemical
Manufacturers
Association,
or
B­
3
CMA),
Synthetic
Organic
Chemical
Manufacturers
Association
(
SOCMA),
Chemical
Specialities
Manufacturers
Association
(
CSMA),
and
American
Petroleum
Institute
(
API).
The
program,
entitled
the
Use
and
Exposure
Information
Voluntary
Project
(
UEIP),
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
to
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
serve
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
extrapolating
from
this
data
set
to
develop
a
nationwide
picture
of
use
and
exposure
would
be
difficult
and
inadvisable.


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
under
PAIR
change
from
year
to
year
based
primarily
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
chemicals
each
year
rather
than
a
periodically
updated
record
of
toxic
chemical
manufacture,
exposure,
and
use.
B.
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
known
hazard
data
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.
B.
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
B­
4
the
chemical
(
e.
g.,
NAICS
codes,
consumer
uses)
is
collected
under
TURA
(
MADEP,
1995).


New
Jersey
collects
production
volume
and
end­
use
information
under
the
New
Jersey
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
are
collected
under
this
program
(
Larmee,
1996).


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
snapshot
of
on­
site
use
of
toxic
chemicals
for
key
facilities
in
Oregon
(
Rozell
and
Brower,
1993;
OSPIRG,
1993).
B.
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
ten
EPA
Regions
(
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
that
occurred
due
to
the
release.
However,
there
are
several
limitations
to
these
data.
ERNS
data
are
focused
on
information
about
releases
and
not
B­
5
on
manufacturing
and
use
of
chemicals.
Secondly,
the
data
are
subject
to
a
certain
degree
of
uncertainty
because
ERNS
contains
primarily
initial
accounts
of
releases
made
when
exact
details
are
often
unknown.
Lastly,
these
data
are
usually
not
updated
unless
an
EPA
region
is
involved
in
the
response
action.


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.
These
data
focus
primarily
on
site­
specific/
problematic
worker
exposures.
The
data
do
not
contain
information
regarding
the
number
of
workers
across
an
industry
that
may
be
exposed
to
toxic
chemicals
in
the
workplace
and
do
not
track
chemical
use
information.
Further,
the
data
do
not
track
chemicals
in
every
workplace
where
they
may
be
used
and
only
focus
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.
CPSC
has
indicated
interest
in
the
information
on
consumer
use
and
potential
exposure
to
chemicals
that
EPA
will
collect
under
the
IUR
amendments.


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
cover
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.


The
U.
S.
Geological
Survey
(
USGS)
collects
information
on
over
90
minerals
and
materials
and
publishes
it
in
two
annual
publications,
the
Mineral
Commodity
Summaries
and
the
Mineral
Yearbook.
The
Mineral
Commodity
Summaries
provide
data
sheets
on
domestic
industry
structure,
government
programs,
tariffs,
and
five­
year
salient
statistics
for
each
mineral
and
material.
The
Minerals
Yearbook,
published
in
three
volumes,
also
includes
essential
statistical
data
on
minerals
and
materials
and
supplements
it
with
local
and
global
production
and
development
information
and
trends.
Data
collected
in
the
Minerals
Yearbook
include
production,
consumption,
technical
trends,
environmental
issues,
summary
outlooks,
and
their
B­
6
accompanying
narratives.
The
USGS
does
not
cover
those
chemical
compounds
that
are
not
geological
phenomena.
They
also
do
not
provide
information
on
minerals
and
materials
usage
in
various
production
stages
or
their
release
to
the
environment,
handling,
storage,
or
transfer.
The
type
and
level
of
environmental
information
that
would
be
required
to
be
collected
under
the
IUR
amendments
is
beyond
the
scope
of
USGS's
mission.


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,
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.
B.
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
CMA
and
the
American
Chemical
Society).
These
sources
can
sometimes
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
(
EPA,
1998a).
APPENDIX
C
DEVELOPMENT
OF
THE
ESTIMATED
NUMBERS
OF
EXPECTED
SUBMISSIONS
FOR
THE
ORIGINAL
IUR
AND
IUR
AMENDMENTS
REPORTING
37Data
maintained
by
EPA
in
the
CUS
database
system.

38The
CUS
databases
maintained
by
the
Agency
contain
information
collected
under
the
IUR
every
four
years.
Four
data
collection
cycles
have
been
completed
C
1986,
1990,
1994,
and
1998.
The
databases
contain
information
on
company
and
chemical
identification,
site
location,
and
annual
production
volume.

39The
CICIS
database
maintained
by
the
Agency
contains
information
collected
by
EPA
on
chemicals
in
commerce
in
the
United
States
in
1977.
The
data
include
company
and
chemical
identification,
site
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
This
appendix
describes
the
process
used
to
develop
estimates
of
the
number
of
reports
that
would
be
submitted
under
the
IUR
amendments.
The
total
number
of
reports
was
estimated
for
several
thresholds
based
on
data
submitted
in
1998
under
the
original
IUR
reporting
requirements.
37
This
appendix
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.
It
also
presents
the
estimated
number
of
reports
for
each
of
the
options
considered.

C.
1
Input
Data
and
Methodology
Data
compiled
from
EPA's
CUS38
and
EPA's
CICIS39
were
used
to
determine
the
estimated
number
of
reports
expected
under
the
IUR
amendments.
The
categories
of
input
data
refer
to
chemicals
reported
in
the
original
IUR
and
organic
and
inorganic
chemicals
reported
under
CICIS.
When
referring
to
the
CICIS
data,
organic
chemicals
refers
to
all
noninorganic
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
IUR
amendments.

C.
1.1
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
1998
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.
The
values
were
derived
for
each
of
the
various
production
volume
thresholds
to
facilitate
analysis
of
the
threshold
options
considered
for
the
IUR
amendments.
The
data
are
presented
in
Tables
C­
1
and
C­
2.

C.
1.2
Inorganic
Chemicals
C­
2
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
are
based
on
data
for
organic
and
inorganic
chemicals
and
are
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
amendment
options.
Therefore,
it
was
necessary
to
manipulate
the
data
to
reflect
the
thresholds
examined
by
the
IUR
amendment
reporting
options
(
e.
g.,
greater
than
10,000
pounds,
greater
than
25,000
pounds,
greater
than
300,000
pounds).
To
perform
this
manipulation,
the
ratio
of
inorganic
chemicals
to
organic
chemicals
in
the
Table
C­
1.
Organic
Chemicals
Reporting
Data
from
EPA's
CUS
Database
(
1998)

Threshold
(
lbs)
Reports
Discrete
Chemicals
Form
Us
Sites
Total
Reported
20,840
8,569
3,860
2,122
PV
>
25K
17,557
7,326
3,711
2,039
PV
>
100K
12,946
5,445
3,387
1,828
PV
>
300K
9,759
3,977
2,776
1,619
PV
>
500K
8,535
3,382
2,724
1,521
PV
>
1M
7,052
2,669
2,390
1,398
Source:
CUS
Database.
2000.
Information
from
the
Chemical
Update
System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

Table
C­
2.
Multiple
CAS
Number
Petroleum
Stream
Chemicals
Reporting
Data
from
EPA's
CUS
Database
(
1998)

Threshold
(
lbs)
Reports
Discrete
Chemicals
Form
Us
Sites
Total
Reported
4,830
426
478
464
PV
>
25K
4,703
422
456
443
PV
>
100K
4,535
417
414
404
PV
>
300K
4,416
412
381
372
PV
>
500K
4,364
412
368
360
PV
>
1M
4,296
409
356
248
Source:
CUS
Database.
2000.
Information
from
the
Chemical
Update
System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.
C­
3
CICIS
data
for
each
reported
threshold
was
applied
to
the
projected
numbers
of
chemicals
and
reports
developed
from
the
CUS
1998
data,
generating
the
numbers
of
reports
and
chemicals
for
inorganic
chemicals
corresponding
to
the
IUR
amendment
threshold
categories.
C.
2
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
1998.
Because
the
number
of
reports
has
remained
fairly
constant
over
time
and
1998
is
the
most
recent
reporting
period,
it
was
assumed
that
1998
is
a
representative
year.
The
number
of
reports
from
the
past
four
reporting
periods
is
presented
in
Table
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
B
10K
1,364
649
458
11,219
7,557
1,391
PV
10K
B
100K
1,614
651
660
11,586
7,352
1,709
PV
100
B
1M
2,103
621
985
8,568
4,933
2,073
PV
1M
B
10M
2,115
497
1,211
5,661
2,532
2,011
PV
10M
B
50M
1,539
283
987
3,624
1,069
1,477
PV
50M
B
100M
616
148
462
1,595
431
792
PV
100M
B
500M
1,292
150
758
3,421
436
1,008
PV
500M
B
1B
333
64
270
1,261
184
421
PV
>
1B
408
52
239
1,589
169
370
Source:
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,
DC.

Table
C­
4.
Number
of
Reports
Submitted
Under
the
Original
IUR
in
1986,
1990,
1994,
and
1998
Reporting
Year
Number
of
Reports
1986
26,250
1990
25,535
1994
25,058
1998
26,667
Average
25,878
Source:
CUS
Database.
2000.
Information
from
the
Chemical
Update
System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.
C­
4
The
CICIS
data
were
used
to
determine
a
ratio
of
the
historical
number
of
organic
chemicals
to
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
1998.
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
1998
(
see
Eq.
[
C.
1]).
This
estimate
(
i.
e.,
the
number
of
discrete
inorganic
chemicals
in
1998)
was
then
used
to
determine
the
number
of
reports
for
inorganic
chemicals
as
if
they
had
been
reported
in
1998,
based
on
the
ratio
of
inorganic
reports
to
inorganic
chemicals
in
the
1986
CICIS
data
(
see
Eq.
[
C.
2]).
Based
on
this
methodology,
estimated
numbers
of
discrete
chemicals
and
reports
for
inorganic
chemicals
were
developed,
as
presented
in
Table
C­
5.

Determination
of
the
Estimated
Number
of
Discrete
Inorganic
Chemicals
as
if
Reported
in
1998
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
1998
Inorganic
Discrete
Chemicals
(
Estimated
as
if
reported
in
1998)
Inorganic
Reports
(
Estimated
as
if
reported
in
1998)

PV
>
10K
8,915
1,284
5,216
PV
>
25K
7,754
1,117
4,537
PV
>
100K
5,868
845
3,433
PV
>
300K
4,395
633
2,571
PV
>
500K
3,800
547
2,223
PV
>
1M
3,084
444
1,804
aNumbers
may
not
calculate
exactly
because
of
rounding.

Sources:
CUS
Database.
2000.
Information
from
the
Chemical
Update
System
Database
maintained
by
the
Information
Management
Division,
Office
of
Pollution
Prevention
and
Toxics,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.

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,
DC.

U.
S.
EPA
estimates.
40Ratios
were
calculated
using
data
for
production
volumes
greater
than
10,000
pounds.

C­
5
IC
1
=
(
IC
2/
OC
2)
×
OC
1
(
C.
1)
Determination
of
the
Estimated
Number
of
Inorganic
Chemical
Reports
as
if
Reported
in
1998
RIC
1
=
(
RIC
2/
IC
2)
×
IC
1
(
C.
2)
IC
1
=
Estimated
number
of
discrete
inorganic
chemicals
as
if
reported
in
1998
IC
2
=
Discrete
inorganic
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)
OC
2
=
Discrete
organic
chemicals
reported
to
the
CICIS
database
RIC
1
=
Estimated
number
of
reports
for
inorganic
chemicals
as
if
reported
in
1998
RIC
2
=
Reports
for
inorganic
chemicals
reported
to
the
CICIS
database
Ratios40:
(
IC
2)/(
OC
2)
=
CICIS
inorganic
chemicals/
organic
chemicals
=
0.144
(
RIC
2)/(
IC
2)
=
CICIS
inorganic
reports/
inorganic
chemicals
=
4.063
C.
2.1
Calculation
of
Total
Expected
Numbers
of
Reports
Under
the
IUR
Amendments
The
IUR
amendments
would
require
reporting
for
both
organic
and
inorganic
chemicals
and
would
provide
a
partial
exemption
for
certain
chemicals
(
i.
e.,
multiple
CAS
number
petroleum
stream
chemicals)
from
reporting
requirements.
Eq.
(
C.
3)
was
used
to
calculate
the
total
number
of
reports
expected
under
the
IUR
amendments
for
all
types
of
subject
chemicals:
Determination
of
the
Total
Expected
Number
of
Reports
T
=
ROC
1
+
RIC
1
+
RPS
1
(
C.
3)
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
