ECONOMIC
ANALYSIS
For
the
Addition
of
47
Chemical
Abstract
Service
(
CAS)­
numbered
Chemicals
Requested
to
be
added
to
EPA's
Preliminary
Assessment
Information
Reporting
(
PAIR)
Rule
in
the
48th,
50th
,
and
51st
Reports
of
the
TSCA
Interagency
Testing
Committee
Economic
Policy
Analysis
Branch
Economics,
Exposure,
and
Technology
Division
Office
of
Pollution
Prevention
and
Toxics
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
N.
W.
Washington,
D.
C.
20460
April
18,
2003
OPPT­
2002­
0061­
0005
RECEIVED
OPPT
NCIC
2003
APR25
9:
28AM
1
1.0
OVERVIEW
On
June
22,
1982,
the
Environmental
Protection
Agency
(
EPA)
issued
the
Preliminary
Assessment
Information
Reporting
(
PAIR)
Rule
(
47
FR
26992)
under
Section
8(
a)
of
the
Toxic
Substances
Control
Act
(
TSCA).
Under
the
PAIR
rule,
which
is
codified
at
40
CFR
part
712,
manufacturers
(
defined
by
the
statute
to
include
importers)
of
specified
chemicals
are
required
to
submit
certain
production,
importation,
use,
and
exposure
data
for
these
chemicals
to
the
Agency.
The
reported
information
is
be
used
by
EPA
and
others
(
e.
g.,
the
TSCA
Interagency
Testing
Committee
(
ITC)
which
has
Members
and
Liaison
Members
from
16
Federal
agencies)
to
assess
health
and
environmental
risks
that
may
be
posed
by
exposure
to
the
subject
chemicals.
47
chemicals
were
requested
to
be
added
to
the
PAIR
rule
by
the
TSCA
ITC
in
its
48th
Report(
one
chemical),
50th
Report(
3
chemicals),
and
51st
Report
(
43
chemicals)
to
the
EPA
Administrator
(
see
66
FR
51276,
October
5
2001;
67
FR
49530,
July
30
2002;
and
68
FR
8976,
February
26
2003).
These
chemicals
and
their
specific
Chemical
Abstract
Service
(
CAS)
Registry
numbers,
which
were
provided
in
the
ITC
Reports,
are
presented
in
Table
1.

However
reports
on
only
7
of
the
47
chemicals
were
located
in
EPA's
1998
Chemical
Update
System
(
CUS)
utilizing
the
ITC­
supplied
CAS
numbers,
yielding
6
companies
producing
these
chemicals
at
7
sites.
Because
the
threshold
for
reporting
to
CUS
under
the
Inventory
Update
Rule
is
10,000
lbs.,
and
the
threshold
for
PAIR
reporting
is
500
kg
(
1,100
lbs.),
and
because
there
is
no
requirement
that
inorganic
chemicals
be
reported
to
CUS
(
the
majority
of
the
vanadium
compounds
are
inorganic),
EPA
assumed
that
one
manufacturer
exists
per
chemical
to
account
for
the
possibility
that
there
may
be
manufacturers
producing
PAIR­
reportable
amounts
that
weren't
captured
by
CUS.
But
EPA
has
no
way
of
ascertaining
this,
a
fact
which
highlights
the
need
for
PAIR
reporting
on
these
chemicals.

EPA
has
already
published
a
standardized
reporting
form
for
the
PAIR
rule
(
EPA
Form
No.
7710­
35).
The
submitted
forms
are
required
to
contain
the
following
information:

Section
I
­
Certification
This
section
requires
the
reporter
to
verify
that
all
information
provided
to
EPA
is
complete
and
accurate.
In
addition,
this
section
allows
the
reporter
to
claim
information
reported
to
be
TSCA
Confidential
Business
Information
(
CBI).
CBI
claims
require
certification.

Section
II
­
Chemical
Identification
Chemical
name,
CAS
number,
etc.

Section
III
­
Respondent
Identification
Site
name,
location,
address,
technical
contact's
name
and
telephone
number.
2
Section
IV
­
Preliminary
Assessment
Information
Part
A
­
Plant
Site
Activities
­
Quantities
imported
and/
or
manufactured,
quantities
in
waste
or
released
to
the
environment,
description
of
on­
site
activities,
quantities
in
products.
Part
B
­
Chemical
Substance
Processing
by
Customers
­
Customers'
uses
and
products,
market
names,
customers
process
categories.

Table
1:
Chemicals
and
CAS
Registry
Numbers
Provided
in
the
48th,
50th,
and
51st
ITC
Reports
CAS
NUMBER
CHEMICAL
NAME
EPA
CUS
reports
29091­
20­
1
benzenamine,
3_
chloro_
2,6_
dinitro_
N,
N_
dipropyl_
4_
(
trifluoromethyl)
X
68928­
76­
7
stannane,
dimethylbis[(
1_
oxoneodecyl)
oxy]
X
3278­
89­
5
benzene,
1,3,5­
tribromo­
2­(
2­
propenyloxy)
X
136­
35­
6
1­
triazene,
1,3­
diphenyl
X
]
X
11115­
67­
6
Ammonium
vanadium
oxide
11130­
21­
5
Vanadium
carbide
12007­
37­
3
Vanadium
boride
(
VB2)

12035­
98­
2
Vanadium
oxide
(
VO)

12036­
21­
4
Vanadium
oxide
(
VO2)

12070­
10­
9
Vanadium
carbide
(
VC)

12083­
48­
6
Vanadium,
dichlorobis
(.
eta.
5­
2,4­
cyclopentadien­
1­
yl)­

12166­
27­
7
Vanadium
sulfide
(
VS)

12439­
96­
2
Vanadium,
oxo[
sulfato(
2­)­
kappa.
O]­,
pentahydrate
[
Vanadyl
sulfate
(
VOSO4),
pentahydrate]

12604­
58­
9
Vanadium
alloy,
base,
V,
C,
Fe
(
Ferrovanadium)

13470­
26­
3
Vanadium
bromide
(
VBr3)

13476­
99­
8
Vanadium,
tris(
2,4­
pentanedionato­.
kappa.
O,.
kappa.
O')­,
(
OC­
6­
11)­
[
Vanadium
tris(
acetylacetonate)]
X
1
"
Burden
Hour
and
Cost
Estimates
for
PAIR
Section
8(
a)
Reporting
(
1994
Update),"
internal
U.
S.
EPA
memorandum
form
Carol
Rawie,
EETD,
to
Karen
Boswell,
CTIB,
May
16,
1994.
Economic
Impact
and
Small
Business
Definition
Analysis
for
TSCA
Section
8(
a)
Preliminary
Assessment
Information
Rule,
Office
of
Regulatory
Analysis,
OTS,
U.
S.
EPA,
February
1980.
Economic
Analysis
of
the
Final
Section
8(
a)
Preliminary
Assessment
Information
Rule,
R.
A.
Horner,
RIB,
OTS,
U.
S.
EPA,
November
12,
1981.

3
13497­
94­
4
Silver
vanadium
oxide
(
AgVO3)

13517­
26­
5
Sodium
vanadium
oxide
(
Na4V2O7)
[
Sodium
pyrovanadate]

13718­
26­
8
Vanadate
(
VO31­),
sodium
[
Sodium
metavanadate]

13721­
39­
6
Sodium
vanadium
oxide
(
Na3VO4)
[
Sodium
orthovanadate]

13769­
43­
2
Vanadate
(
VO31­),
potassium
[
Potassium
metavanadate]

13930­
88­
6
Vanadium,
oxo[
29H,
31H­
phthalocyaninato(
2­)­
.
kappa.
N29,.
kappa.
N30,.
kappa.
N31,.
kappa.
N32]­,
(
SP­
5­
12)­

14059­
33­
7
Bismuth
vanadium
oxide
(
BiVO4)

19120­
62­
8
Vanadium,
tris(
2­
methyl­
1­
propanolato)
oxo­,
(
T­
4)­
[
Isobutyl
orthovanadate]

24646­
85­
3
Vanadium
nitride
(
VN)

27774­
13­
6
Vanadium,
oxo[
sulfato(
2­)­.
kappa.
O]­
[
Vanadyl
sulfate]

30486­
37­
4
Vanadium
hydroxide
oxide
(
V(
OH)
2O)
X
39455­
80­
6
Ammonium
sodium
vanadium
oxide
53801­
77­
7
Bismuth
vanadium
oxide
65232­
89­
5
Vanadium
hydroxide
oxide
phosphate
68130­
18­
7
Vanadium
hydroxide
oxide
phosphate
(
V6(
OH)
3O3(
PO4)
7)

68815­
09­
8
Naphthenic
acids,
vanadium
salts
68990­
29­
4
Balsams,
copaiba,
sulfurized,
vanadium
salts
Both
industry
and
government
incur
costs
in
responding
to
(
industry)
and
in
implementing
(
government)
this
reporting
rule.
The
total
costs
and
burden
for
industry
and
government
are
as
follows:

INDUSTRY
GOVERNMENT
$
61,537.12
$
21,125.06
1330.3
hours
246.75
hours
The
methodology
and
the
burden
and
cost
details
are
discussed
in
the
following
sections.

2.0
METHODOLOGY
AND
DATA
SOURCES
2.1
Burden
Hour
Estimates
The
primary
source
of
burden
hour
and
direct
cost
estimates
in
this
report
are
previous
economic
analyses
performed
for
the
PAIR
rule1.
All
burden
hour
and
cost
estimations
in
this
analysis
are
directly
from
previous
PAIR
analyses
unless
otherwise
noted.
2
U.
S.
Environmental
Protection
Agency,
2002.
Wage
Rates
for
Economic
Analyses
of
the
Toxics
Release
Inventory
Program.
Cody
Rice,
Analytical
Support
Branch,
Office
of
Environmental
Information.
June
10,
2002.

4
2.2
Wage
Rates
and
Cost
Estimation
Wage
rates
including
fringe
benefits
and
overhead
for
three
broad
categories
of
labor
(
managerial,
technical,
and
clerical)
were
used
in
this
cost
analysis.
The
labor
categories
and
loaded
wage
rates
were
developed
during
previous
studies2.
The
basis
for
estimating
wage
rates
for
these
purposes
is
the
Bureau
of
Labor
Statistics
(
BLS)
wage
data
for
comparable
labor
categories.
The
BLS
now
reports
this
data
on
a
quarterly
basis,
allowing
near­
current
wages
to
be
used
in
this
analysis.

The
December
2002
loaded
hourly
wage
rates
used
in
the
analysis
are
presented
in
Table
2.
Unit
burden
estimates
are
converted
to
unit
cost
estimates
by
multiplying
the
unit
burden
hours
by
the
appropriate
wage
rates
in
Table
2.

Wage
data
used
in
developing
the
basic
wage
rates
for
this
analysis
were
derived
from
December
2002
wage
information
published
by
the
Bureau
of
Labor
Statistics
(
BLS)
for
all
goodsproducing
private
industries.
The
managerial
wage
rates
are
taken
from
the
BLS
data
for
the
executive,
administrative,
and
managerial
occupational
group.
The
technical
wage
rates
are
taken
from
BLS
data
for
the
professional
specialty
and
technical
occupational
group.
The
clerical
wage
rates
are
taken
from
the
BLS
data
for
the
administrative
support
(
including
clerical)
occupational
group.
Based
on
that
BLS
data,
the
average
hourly
wage
rates
are
$
33.09
for
managerial
personnel,
$
27.00
for
technical
personnel,
and
$
14.89
for
clerical
personnel,
all
in
December
2002
dollars.

The
benefits
and
overhead
loading
factors
are
calculated
from
the
BLS
data
on
the
cost
of
benefits,
with
17
percent
of
the
average
wage
added
for
overhead.
The
overhead
factor
of
17
percent
is
based
on
information
provided
by
the
chemical
industry
and
chemical
industry
trade
associations.
The
loaded
hourly
wage
rates
are
$
53.27
for
managerial
personnel,
$
43.34
for
technical
personnel,
and
$
23.96
for
clerical
personnel,
all
in
2002
dollars.

TABLE
2:
LOADED
HOURLY
WAGE
RATES
BY
LABOR
CATEGORY
Labor
Category
December
2002
Average
Wages
December
2002
Benefits
and
Overhead
Loading
Factor
December
2002
Loaded
Hourly
Rate
Managerial
$
33.09
1.610
$
53.27
Technical
$
27.00
1.605
$
43.34
Clerical
$
14.89
1.609
$
23.96
Sources:
U.
S.
Environmental
Protection
Agency,
2002.
Wage
Rates
for
Economic
Analyses
of
the
Toxics
Release
Inventory
Program.
Cody
Rice,
Analytical
Support
Branch,
Office
of
Environmental
Information.
June
10,
2002.
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics,
2003.
Employer
Costs
for
Employee
Compensation
Historical
Listing
(
Quarterly),
2002.
March
18,
2003.

3.0
INDUSTRY
BURDEN
AND
COST
ESTIMATES
5
Compliance
with
this
reporting
rule
will
require
the
following
activities:

­
Form
Familiarization;
­
Report
completion;
­
CBI
Substantiation;
­
Tradename
notification,
and;
­
Report
submission.

This
section
estimates
the
burden
and
cost
of
the
rule
to
industry.
The
unit
burden
and
unit
cost
of
each
major
activity
is
discussed
below.

3.1
Form
Familiarization
All
plant
sites
will
need
to
familiarize
themselves
with
EPA's
published
standard
reporting
form
and
reporting
requirements.
The
burden
and
costs
for
form
familiarization
are
assumed
to
be
incurred
on
a
unique
plant
site
since
many
of
the
same
site
staff
would
familiarize
themselves
with
the
reporting
form
regardless
of
the
number
of
site­
specific
chemicals
to
be
reported.

It
is
estimated
that
form
familiarization
will
require
about
3
hours
of
managerial
time
and
4
hours
of
technical
personnel
effort.
The
per
site
unit
burden
and
unit
cost
is
7
hours
and
$
597.92,
respectively.
There
are
no
other
direct
costs
(
ODCs).
The
specific
unit
burden
and
unit
costs
are
summarized
as
follows.

Site
Activity
Clerical
Technical
Managerial
ODCs
Total
Burden
0.00
4.00
3.00
­­
7.00
Cost
$
0.00
$
173.34
$
159.82
$
0.00
$
333.16
3.2
Report
Completion
Report
completion
requires
collecting,
analyzing,
transcribing,
and
reviewing
the
information
necessary
to
fully
respond
to
the
requirements
of
the
reporting
rule.
Report
completion
accounts
for
the
large
majority
of
the
burden
of
the
rule.

The
estimated
average
burden
for
the
completion
of
a
single
report
is
16
hours.
The
per
report
cost
is
estimated
to
be
$
723.81.
This
estimate
does
not
include
claims
of
CBI
(
Section
I),
or
tradename
notification
(
Section
IV,
Part
B,
item
10).

Report
Activity
Clerical
Technical
Managerial
ODCs
Total
Burden
1.25
9.25
5.5
­­
16.00
Cost
$
29.95
$
400.85
$
293.01
$
0.00
$
723.81
3
These
costs
include
$
3.85
in
postage
(
USPS
Priority
Mail,
up
to
one
pound),
and
$
0.20
in
photocopying
costs
(
4
pages
at
$
0.05
per
page.

6
3.3
CBI
Substantiation
In
Section
I
of
the
standard
PAIR
form,
the
reporting
firm
may
make
claims
of
confidentiality
for
any
data
element
contained
in
their
submission.
It
is
assumed
that
most
of
the
time
required
for
CBI
substantiation
involves
managerial
staff
discussion
of
whether
or
not
to
make
a
CBI
claim.
Four
hours
of
managerial
labor
and
one­
half
hour
of
clerical
labor
are
required
for
CBI
substantiation.
The
total
unit
costs
is,
therefore,
estimated
to
be
$
225.08
per
report.
It
is
assumed
that
75%
of
reports
contain
CBI
claims,
so
for
this
analysis
35
CBI
reports
are
estimated.

Report
Activity
Clerical
Technical
Managerial
ODCs
Total
Burden
0.50
0.00
4.00
­­
4.50
Cost
$
11.98
$
0.00
$
213.10
$
0.00
$
225.08
3.4
Tradename
Notification
In
Section
IV,
Part
B
of
the
PAIR
standard
form,
some
companies
may
report
their
customer's
uses
as
unknown
for
more
than
twenty
percent
of
their
total
volume.
These
companies
must
list
under
item
10
the
trade
names
under
which
they
distribute
the
chemical.
The
unit
costs
per
report
is
$
141.16.
It
is
assumed
that
thirty
percent
of
PAIR
reporting
sites
report
these
tradenames,
so
for
this
analysis
14
tradename
sites
are
estimated.

Report
Activity
Clerical
Technical
Managerial
ODCs
Total
Burden
1.00
0.00
2.20
­­
3.20
Cost
$
23.96
$
0.00
$
117.20
$
0.00
$
141.16
3.5
Report
Submission
These
costs
cover
the
expense
to
review,
copy,
and
mail
the
PAIR
form
to
EPA.
Report
submission
will
require
0.5
hours
of
clerical
time
and
0.5
hours
of
managerial
time
per
report.
The
clerical
burden
includes
the
time
required
to
photocopy
and
mail
the
report
package.
The
managerial
time
is
for
review
of
the
report
package
before
it
is
submitted
to
EPA.
These
burden
categories
are
estimated
to
cost
$
38.62
per
report;
but
do
not
include
other
direct
costs.
Other
direct
costs
(
photocopying
and
mailing
costs)
are
estimated
to
total
$
4.05
(
current
dollars)
per
report3.
Thus,
the
total
report
submission
costs
will
be
$
42.67
per
report
(
i.
e.,
$
38.62
+
$
4.05).
7
Report
Activity
Clerical
Technical
Managerial
ODCs
Total
Burden
0.50
0.00
0.50
0.00
1.00
Cost
$
11.98
$
0.00
$
26.64
$
4.05
$
42.67
3.6
Total
Industry
Burden
and
Cost
Summary
information
on
total
unit
burden
and
unit
cost
under
the
reporting
rule
is
presented
in
Tables
3
and
4.

The
total
industry
burden
and
costs
are
based
on
the
expected
level
reporting
activity
which,
in
turn,
is
related
to
the
number
of
reports
and
reporting
sites.
The
number
of
reports
and
reporting
sites
depends
upon
the
number
of
manufacturers
and
importers
and
their
number
of
sites
for
each
chemical
subjected
to
the
reporting
rule.
These
variables,
summarized
in
Table
5,
are
applied
to
the
unit
burden
and
cost
estimates
as
shown
in
Table
6
to
generate
an
estimate
of
total
industry
burden
and
costs.
The
total
industry
burden
and
costs
are,
respectively,
1330.3
hours
and
$
61,537.12.
The
unit
burden
per
site/
report
are
28.3
hours,
and
the
unit
costs
per
site/
report
are
$
1,309.30,
as
shown
in
Table
6.

Table
3:
Unit
Burden
(
hours)
of
PAIR
Reporting
Activity
Clerical
Technical
Managerial
Total
PER
SITE
Form
Familiarization
0.00
4.00
3.00
7.00
PER
REPORT
Report
Completion
CBI
Substantiation\
1
Tradename
Notification\
2
Report
submission
1.25
0.50
1.00
0.50
9.25
0.00
0.00
0.00
5.50
4.00
2.20
0.50
16.00
4.50
3.20
1.00
\
1
Assumes
site
claims
CBI.
Only
75%
of
sites
are
estimated
to
claim
CBI.
\
2
Assumes
site
reports
tradenames.
Only
30%
of
sites
are
estimated
to
report
tradenames.
8
Table
4:
Unit
Costs
(
Dec.
2002$)
of
PAIR
Reporting
Activity
Clerical
Technical
Managerial
ODC
Total
PER
SITE
Form
Familiarization
$
0.00
$
173.34
$
159.82
$
0.00
$
333.16
PER
REPORT
Report
Completion
CBI
Substantiation\
1
Tradename
Notification\
2
Report
submission
$
29.95
$
11.98
$
23.96
$
11.98
$
400.85
$
0.00
$
0.00
$
0.00
$
293.01
$
213.10
$
117.20
$
26.64
$
0.00
$
0.00
$
0.00
$
4.05
$
723.81
$
225.08
$
141.16
$
42.67
\
1
Assumes
site
claims
CBI.
Only
75%
of
sites
are
estimated
to
claim
CBI.
\
2
Assumes
site
reports
tradenames.
Only
30%
of
sites
are
estimated
to
report
tradenames.

Table
5:
Summary
of
Reporting
Requirements
Multipliers
UNIT
VARIABLE
QUANTITY
DESCRIPTION
/
COMMENTS
Number
of
Chemicals
47
EPA
Supplied.

Number
of
Manufacturers/
Importers
47
EPA
Assumption.

Number
of
Reporting
Sites
47
EPA
Assumption.

Number
of
Reports
47
Assumes
one
report
per
chemical
per
site.

Number
of
Reports
with
Tradenames
14
Assumes
30%
of
reports.

Number
of
Reports
with
CBI
Claims
35
Assumes
75%
of
reports.

Table
6:
Total
Industry
Burden
and
Costs
(
2002$)
of
the
Reporting
Rule
Activity
Unit
Burden
Unit
Costs
Units
Total
Burden
Total
Costs
PER
SITE
Form
Familiarization
7.00
hours
$
333.16
47
sites
329.0
hours
$
15,658.52
PER
REPORT
Report
Completion
CBI
Substantiation
Tradename
Notification
Report
submission
16.00
hours
4.50
3.20
1.00
$
723.81
$
225.08
$
141.16
$
42.67
47
reports
35
14
47
752.0
hours
157.5
44.8
47.0
$
34,019.07
$
7,877.80
$
1,976.24
$
2,005.49
TOTAL
$
1,465.88\
1
1330.3
hours
$
61,537.12
Unit
Burden
of
this
Rule
Per
Site/
Report
1330.3
total
hours
/
47
total
sites/
reports
=
28.3
hours
Unit
Cost
of
this
Rule
per
Site/
Report
$
61,537.12
total
cost
/
47
total
sites/
reports
=
$
1,309.30
\
1
This
figure
represents
the
maximum
potential
impact
for
any
one
firm.

4.0
GOVERNMENT
BURDEN
AND
COST
ESTIMATES
4
Data
processing
costs
for
the
1992
PAIR
ICR
update
was
estimated
to
be
approximately
$
177
per
report.
Adjusting
this
number
with
the
GNP
implicit
price
deflator
for
2002(
4)/
1991(
4)
(
from
Survey
of
Current
Business)
yields
an
adjusted
data
processing
cost
of
$
217.58
per
report
(
i.
e.,
$
177
*
(
111.21
/
90.47)
=
$
217.58).

5
It
has
been
derived
from
the
1989
PAIR
ICR
update
that
industry/
public
assistance
required
approximately
1.5
hours
per
report
(
or
0.00072
FTEs
per
report)
and
data
processing/
system
support
personnel
required
about
3.75
hours
per
report
(
or
0.0018
FTEs
per
report).
Other
government
activities
associated
with
PAIR
are
not
affected
(
Chemical
Nomination,
Review
and
Selection;
Rule
Development;
Rule
Evaluation;
Compliance
Monitoring).

6
The
annual
costs
per
FTE
are
derived
by
multiplying
the
annual
pay
rate
by
1.6
(
the
benefits
multiplication
factor).
The
multiplication
factor
used
is
recommended
in
EPA's
Office
of
Policy,
Planning,
and
Evaluation's
Instructions
for
Preparing
Information
Collection
Requests
(
ICRs)
(
June
1,
1992).
The
1.6
factor
includes
not
only
benefits
but
also
overhead.
An
annual
pay
rate
of
$
57,421
is
used
and
reflects
a
GS­
12
(
level
1)
salary
as
of
1/
1/
03.
This
GS­
12,
Step
1,
assumption
was
recommended
by
EPA.
(
Internal
EPA
phone
call
between
Carol
Rawie
(
OPPT/
EETD/
RIB)
and
Ron
Carlson
(
OPPT/
OPME)
on
April
25,
1994).
Thus,
the
annual,
fully­
loaded
cost
per
FTE
is
$
91,874
(
or
$
57,421
*
1.6).

9
The
estimated
cost
of
this
reporting
rule
to
the
Federal
government
is
provided
on
an
annual
basis.
The
2002
cost
of
a
full
time
equivalent
employee
(
FTE)
at
EPA
was
provided
by
the
Office
of
Personnel
Management.
One
FTE
is
equivalent
to
2,080
hours
per
year.

This
reporting
rule
estimates
that
a
total
of
47
reports
will
be
submitted.
The
base
cost
for
data
processing
was
adjusted
to
reflect
this
rule's
expected
number
of
report
submissions4.
Personnel
costs
associated
with
industry
assistance
and
data
processing
activities
have
been
similarly
adjusted5.
These
adjustments
were
carried
through
in
this
analysis.

Table
8
summarizes
the
Government's
activities
in
developing
and
administering
this
reporting
rule.
The
required
FTEs
per
activity
are
retained
from
previous
PAIR
ICRs
update
except
where
noted.
The
cost
for
data
processing
per
report
is
$
217.58.
Therefore,
it
is
estimated
that
the
annual
cost
to
the
Federal
Government
will
be
$
10,226.11
(
47
reports
*
$
217.58),
plus
0.0176
FTEs.
At
an
estimated
$
91,873.60
per
FTE6,
the
total
of
0.1186
FTEs
will
cost
EPA
$
10,898.95
in
salaries,
bringing
the
total
costs
to
the
Federal
government
to
$
21,125.06
(
i.
e.,
$
10,226.11
+
$
10,898.95).

Table
7:
Total
Government
Burden
and
Costs
(
December
2002$)

Activity
Unit
Burden
Total
Burden
Industry/
Public
Assistance
Data
Processing
/
System
Support
Personnel
TOTAL
ACTIVITY
BURDEN
1.5
hours/
report
3.75
hours/
report
0.0339
FTE
0.0847
FTE
0.1186
FTE
(
246.75
hours)

Loaded
Annual
Costs
per
FTE
$
91,873.60
TOTAL
ACTIVITY
COSTS
($
91,873.60
*
0.1186
FTE)
$
10,898.95
Data
Processing
costs
($
217.58
*
47
reports)
$
10,226.11
TOTAL
ANNUAL
GOVERNMENT
COSTS
$
21,125.06
5.0
REGULATORY
FLEXIBILITY
ACT
10
Under
the
Regulatory
Flexibility
Act
(
RFA)
and
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA),
EPA
is
required
to
consider
whether
a
regulatory
action
will
have
a
significant
adverse
impact
on
small
entities.
Both
the
RFA
and
SBREFA
require
EPA
to
determine
whether
a
rulemaking
may
result
in
"
significant
economic
impact
on
a
substantial
number
of
small
entities,"
and
if
so,
to
tailor
the
requirements
of
the
rule
to
mitigate
such
impacts,
while
still
maintaining
a
high
level
of
environmental
protection.

The
small
business
size
standards
promulgated
by
the
Small
Business
Administration
(
SBA)
(
61
FR
3280,
3289­
3291,
January
31,
1996)
for
chemical
manufacturers
are
based
solely
on
the
number
of
employees,
with
a
base
threshold
of
1,000
employees
for
the
ultimate
corporate
parent,
under
which
all
businesses
are
considered
small.
Of
the
47
businesses
assumed
to
be
affected
by
this
rule,
it
is
unknown
how
many
meet
this
definition
of
small
business.

To
estimate
the
impact
of
the
rule
on
a
business,
the
preferred
method
is
the
"
sales
test,"
wherein
costs
for
any
individual
firm
are
measured
as
a
percent
of
annual
sales.
At
a
maximum
cost
for
any
one
firm
of
$
1,465.88,
the
firm's
total
sales
would
have
to
be
less
than
$
150,000
for
this
rule
to
have
an
impact
of
even
1%
of
sales.
Of
the
6
companies
identified
in
CUS
as
manufacturers
of
affected
chemicals,
none
meets
the
SBA
definition
of
small.
Thus,
EPA
has
determined
that
this
rule
will
not
impose
a
significant
impact
on
a
substantial
number
of
small
entities.
