Economic
Analysis
of
the
IUR
Revisions
Final
Rule
Economic
and
Policy
Analysis
Branch
Economics,
Exposure
and
Technology
Division
Office
of
Pollution
Prevention
and
Toxics
U.
S.
Environmental
Protection
Agency
July
2005
iv
CONTENTS
Chapter
Page
Executive
Summary
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ES­
1
1.
Introduction
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1­
1
1.1
Regulatory
History
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1­
1
1.2
Current
IUR
Requirements
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1­
2
1.3
Overview
of
the
Regulated
Community
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1­
5
1.4.
Changes
in
Reporting
Requirements
under
the
IUR
Revisions
Rule
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1­
5
Change
Reporting
Frequency
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1­
5
Move
Submission
Period
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1­
5
Clarify
"
Low
Current
Interest"
Partial
Exemption
Petition
Process
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1­
6
Partially
Exempt
Additional
Petroleum
Process
Streams
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1­
6
Change
Consumer
and
Commercial
Product
Categories
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1­
7
Report
Manufactured
and
Imported
Volumes
Separately
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1­
8
Report
Processing
and
Use
Information
for
Domestic
Uses
Only
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1­
8
Update
Polymer
Exemption
Reference
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1­
8
Remove
Production
Volume
Range
CBI
Requirement
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1­
9
2.
Cost
Savings
due
to
the
IUR
Revisions
Rule
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2­
1
2.1
Unit
Time
and
Cost
Estimates
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2­
2
Estimates
of
Wage
Rates
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2­
2
Estimates
of
Labor
Hours
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2­
4
Estimates
of
the
Number
of
Sites
and
Reports
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2­
7
2.2
Current
IUR
Industry
Compliance
Costs
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2­
8
2.3
Changes
in
Industry
Costs
Due
to
the
IUR
Revisions
Rule
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2­
11
2.4
Industry
Savings
Due
to
the
IUR
Revisions
Rule
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2­
14
2.5
EPA
Savings
Due
to
the
IUR
Revisions
Rule
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2­
18
2.6
Total
Savings
Due
to
the
IUR
Revisions
Rule
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2­
19
3.
Impact
of
the
IUR
Revisions
Rule
on
the
Benefits
of
the
IUR
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3­
1
4.
Benefit­
Cost
Analysis
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4­
1
5.
Small
Entity
and
Environmental
Justice
Impact
Determinations
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5­
1
5.1
Small
Entity
Analysis
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5­
1
5.2
Environmental
Equity/
Justice
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5­
2
References
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R­
1
Appendix
A:
IUR
Form
U
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A­
1
v
LIST
OF
TABLES
Number
Page
2­
1
Loaded
Hourly
Wage
Rates
by
Labor
Category
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2­
3
2­
2
Average
Burden
Hours
for
2006
IUR
Submission
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2­
5
2­
3
Average
Burden
Hours
for
IUR
Submissions
after
2006
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2­
6
2­
4
Estimated
Number
of
Sites,
Reports,
and
Discrete
Chemicals
by
Chemical
Type
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2­
8
2­
5
Industry
Costs
of
the
Current
IUR
for
Organic
Chemicals
(
2000$)
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2­
9
2­
6
Industry
Costs
of
the
Current
IUR
for
Inorganic
Chemicals
(
2000$)
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2­
10
2­
7
Total
Industry
Costs
of
Current
IUR
(
million
2000$)
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2­
10
2­
8
Total
Industry
Burden
Hours
of
Current
IUR
(
thousands
of
hours)
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2­
11
2­
9
Change
in
Industry
Costs
Due
to
IUR
Revisions
Rule
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2­
13
2­
10
Industry
Costs
for
Organic
Chemicals
After
the
IUR
Revisions
Rule
(
2000$)
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2­
14
2­
11
Industry
Costs
for
Inorganic
Chemicals
After
the
IUR
Revisions
Rule
(
2000$)
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2­
15
2­
12
Total
Industry
Costs
After
the
IUR
Revisions
Rule
(
million
2000$)
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2­
15
2­
13
Total
Industry
Burden
Hours
After
the
IUR
Revisions
Rule
(
thousands
of
hours)
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2­
16
2­
14
Flow
of
Industry
Savings
Due
to
IUR
Revisions
Rule
Over
20
Years
(
million
2000$)
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2­
17
2­
15
Flow
of
EPA
Savings
Due
to
the
IUR
Revisions
Rule
Over
20
Years
(
2000$)
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2­
19
2­
16
Total
Savings
Due
to
the
IUR
Revisions
Rule
(
million
2000$)
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2­
20
2­
17
Burden
Savings
Due
to
the
IUR
Revisions
Rule
(
thousands
of
hours)
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2­
20
4­
1
Benefits
and
Costs
of
the
IUR
Revisions
Rule
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4­
2
LIST
OF
BOXES
Number
Page
1­
1
Industrial
Function
Categories
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1­
4
1­
2
Commercial
and
Consumer
Product
Categories
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1­
4
1
Several
categories
of
substances,
including
polymers,
microorganisms,
naturally
occurring
chemical
substances,
and
certain
natural
gas
substances,
are
generally
excluded
from
IUR
reporting.

ES­
1
EXECUTIVE
SUMMARY
The
U.
S.
Environmental
Protection
Agency
(
EPA)
requires
manufacturers
and
importers
of
certain
chemical
substances
to
periodically
report
information
to
the
Agency
under
reporting
requirements
known
as
the
Inventory
Update
Reporting
(
IUR)
rule.
This
information
is
collected
based
on
EPA's
authority
under
Section
8(
a)
of
the
Toxic
Substances
Control
Act
(
TSCA).
The
data
reported
under
the
IUR
rule
are
used
to
support
many
EPA
and
other
federal
agency
health,

safety,
and
environmental
protection
activities.
The
IUR
rule
was
extensively
amended
in
2003.

EPA
is
now
revising
some
of
the
IUR
rule
requirements.

The
IUR
rule
requires
companies
to
report
information
every
four
years
on
chemical
substances
listed
on
the
TSCA
Inventory.
1
For
reportable
substances
that
a
company
manufactures
or
imports
in
quantities
of
25,000
pounds
or
more
at
a
plant
site
during
the
reporting
year,
a
submitter
is
required
to
provide
plant
site,
production
volume,
and
manufacturing
information.
The
submitter
must
also
provide
processing
and
use
information
for
chemicals
that
exceed
a
300,000
pound
per
year
threshold.
Manufacturers
or
importers
of
specifically
listed
petroleum
process
streams,
and
listed
chemical
substances
of
low
current
interest
are
not
required
to
report
processing
and
use
information
for
those
listed
chemicals.

EPA
is
now
promulgating
the
IUR
Revisions
Rule
to
further
adjust
the
IUR
data
collection
and
reporting
process
in
several
ways:


Extend
the
data
reporting
cycle
from
four
years
to
five
years.


For
reporting
cycles
after
2006,
move
the
submission
period
for
reporting
from
the
end
of
the
calendar
year
(
August
through
December)
to
the
middle
of
the
year
(
June
through
September),
and
clarify
the
recordkeeping
requirements
by
identifying
that
the
5­
year
record
retention
period
begins
on
the
last
day
of
the
submission
period.


Clarify
that
the
partial
exemption
for
low
current
interest
chemicals
requires
language
requiring
a
written
rationale
to
be
included
in
petitions
to
change
the
list
of
these
chemicals.


Expand
the
list
of
petroleum
process
streams
receiving
a
partial
exemption,
and
clarifying
the
exemption.


Add
a
use
category
for
chemicals
of
300,000
pounds
or
more.
2
All
values
are
in
year
2000
dollars
to
facilitate
comparison
with
the
analysis
of
the
2003
Amendments
to
the
IUR.

ES­
2

Require
submitters
to
report
manufactured
and
imported
volumes
separately
(
as
they
did
prior
to
the
2003
Amendments).


Restrict
reporting
of
processing
and
use
information
to
domestic
uses.


Clarify
the
polymer
definition
in
the
regulations.


Eliminate
the
requirement
to
determine
confidentiality
of
production
volume
in
ranges.

These
revisions
will
reduce
IUR
rule
reporting
costs.
Over
the
first
20
years
of
the
rule,

the
net
present
value
of
the
savings
will
be
$
60
million
to
$
102
million,
depending
on
the
assumptions
and
the
discount
rate
used.
Annualized
savings
are
expected
to
be
$
6
million
to
$
7
million.
2
Although
the
data
will
be
obtained
less
frequently
after
implementing
the
revisions,
the
revised
reporting
schedule
will
still
provide
EPA
with
sufficient
information
to
target
activities
efficiently.
The
information
that
will
remain
available
will
enable
the
Agency
to
continue
to
target
educational,
regulatory,
or
enforcement
activities
toward
industries
or
chemicals
that
pose
the
greatest
potential
risks
and
to
target
programs
for
population
groups
that
are
at
the
highest
potential
risk.

No
negative
small
business
impacts
are
expected
to
result
from
the
IUR
Revisions
Rule.

In
fact,
the
revisions
generate
savings
for
small
businesses
and
other
businesses.
Nor
are
there
any
significant
negative
environmental
equity
issues
associated
with
the
rule.

Taking
together
the
factors
analyzed
in
this
report,
the
revisions
to
the
IUR
rule
will
generate
net
benefits
to
society
by
reducing
reporting
costs
for
submitters
while
supporting
EPA's
most
critical
data
needs.
3Chemicals
listed
on
the
TSCA
Inventory
are
referred
to
as
"
existing
chemicals,"
while
TSCA
chemicals
not
currently
listed
are
referred
to
as
"
new
chemicals."
Producers
intending
to
manufacture
or
import
a
new
chemical
must
submit
a
notice
to
the
Agency's
New
Chemicals
Program,
which
screens
new
chemicals
to
determine
if
and
under
what
conditions
they
can
be
made
or
brought
into
the
United
States.
Once
a
chemical
passes
through
the
program,
the
manufacturer
or
importer
must
file
a
Notice
of
Commencement
after
the
chemical
enters
commerce.

1­
1
CHAPTER
1
INTRODUCTION
This
report
assesses
the
benefits
and
costs
expected
to
result
from
revising
the
Inventory
Update
Reporting
(
IUR)
rule.
These
revisions
reduce
the
burden
on
submitters
while
enabling
EPA
to
meet
its
critical
need
for
information.
This
chapter
provides
information
on
EPA's
statutory
authority
for
collecting
information
through
the
IUR
rule,
a
discussion
of
the
regulatory
history
of
the
IUR
rule,
an
overview
of
the
regulated
community,
and
a
description
of
the
existing
rule
requirements
and
revisions.

1.1
Regulatory
History
When
Congress
passed
the
Toxic
Substances
Control
Act
(
TSCA),
it
granted
EPA
broad
authority
to
collect
information
on
chemical
substances
to
help
EPA
and
others
assess
the
magnitude
and
extent
of
human
and
environmental
exposure
to
chemicals
used
in
commerce.

Specifically,
under
§
8
of
TSCA
(
15
U.
S.
C.
2607),
EPA
is
authorized
to
promulgate
regulations
requiring
manufacturers
and
processors
of
chemicals
to
report
production
and
use
information
on
various
types
and
classes
of
chemicals.

In
1977,
EPA
used
its
authority
under
TSCA
§
8
to
create
the
TSCA
Chemical
Substances
Inventory,
also
known
as
the
TSCA
Inventory
(
42
FR
64572),
which
is
codified
at
40
CFR
Part
710
Subpart
A.
The
TSCA
Inventory
lists
all
TSCA
chemicals
that
have
been
in
commerce,

thereby
providing
a
snapshot
of
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
initial
TSCA
Inventory
listed
those
chemicals
in
commerce
in
1977.
Chemicals
are
added
to
the
Inventory
after
a
company
completes
EPA's
New
Chemicals
process
and
files
a
Notice
of
Commencement.
3
Currently,
the
Inventory
lists
over
82,000
chemicals.

In
1986,
EPA
used
its
authority
under
TSCA
§
8(
a)
to
promulgate
regulations
requiring
chemical
manufacturers
and
importers
to
submit
data
on
certain
chemical
substances
listed
in
the
TSCA
Inventory
(
51
FR
21447).
Commonly
called
the
TSCA
Inventory
Update
Reporting
rule,
4See
Appendix
A
for
a
copy
of
Form
U.

1­
2
or
IUR
rule,
these
regulations
are
codified
at
40
CFR
Part
710
Subpart
B.
Under
this
rule,
EPA
collected
data
every
four
years,
from
1986
to
2002,
for
organic
chemicals
produced
in
volumes
of
10,000
pounds
or
more
per
site.
(
Inorganic
chemicals,
polymers,
microorganisms,
and
naturally
occurring
chemical
substances
were
generally
excluded
from
reporting.)
From
1986
to
1998,
an
average
of
9,200
individual
chemicals
were
reported
per
cycle.
The
IUR
data
provided
a
more
up­
to­
date
picture
of
a
subset
of
the
TSCA
chemicals
in
commerce,
generating
data
that
were
used
to
support
TSCA
risk
management
activities,
as
well
as
providing
support
to
other
EPA
and
non­
EPA
program
activities.

In
January
2003
EPA
promulgated
amendments
to
the
IUR
rule.
Referred
to
in
this
report
as
the
"
2003
Amendments"
(
68
FR
848),
the
amended
IUR
applies
to
the
2006
reporting
cycle
and
beyond,
and
is
codified
at
40
CFR
Part
710
Subpart
C.
The
2003
Amendments
required
reporting
for
inorganic
chemical
substances,
added
new
site
and
manufacturing
data
elements,

required
companies
to
provide
basic
processing
and
use
information
related
to
potential
chemical
exposures,
changed
the
period
of
coverage
from
corporate
fiscal
year
to
calendar
year,
and
extended
the
recordkeeping
period
from
four
years
to
five
years.
The
2003
Amendments
limited
industry
burden
by
raising
the
reporting
threshold
to
25,000
pounds,
creating
a
partial
exemption
from
reporting
processing
and
use
information,
and
exempting
certain
forms
of
natural
gas
from
reporting.

As
part
of
the
interagency
review
of
the
2003
Amendments
(
under
Executive
Order
12866),
EPA
agreed
to
propose
a
subsequent
rulemaking
to
change
the
reporting
frequency
by
extending
the
reporting
cycle,
in
an
effort
to
further
reduce
industry
reporting
burden.
In
the
IUR
Revisions
Rule,
EPA,
in
addition
to
extending
the
reporting
cycle,
is
also
making
further
changes
to
the
IUR
rule
that
reduce
industry
burden
and
clarify
rule
requirements
while
maintaining
EPA's
ability
to
meet
its
critical
need
for
information.

1.2
Current
IUR
Rule
Requirements
The
current
IUR
rule
requires
that
members
of
the
regulated
community
submit
information
on
certain
TSCA
chemicals
once
every
four
years.
(
Polymers,
microorganisms,

naturally
occurring
chemical
substances,
and
certain
natural
gas
substances
are
generally
exempt
from
reporting.)
The
reporting
threshold
for
IUR
site
and
manufacturing
information
is
25,000
pounds,
and
there
is
a
second
reporting
threshold
of
300,000
pounds
for
processing
and
use
information.
This
means
that
sites
manufacturing
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).
4
Sites
producing
or
importing
TSCA
chemicals
at
annual
volumes
of
300,000
pounds
or
greater
are
required
to
report
processing
and
use
information
(
Part
III
of
Form
U)
as
well
as
site
and
manufacturing
data,
except
for
chemicals
1­
3
that
qualify
for
an
exemption
from
reporting
processing
and
use
information.
The
reporting
cycle
for
IUR
information
is
every
four
years
and
covers
the
previous
calendar
year.
Records
supporting
information
submitted
to
EPA
must
be
retained
for
five
years.

Reportable
chemicals
manufactured
in
quantities
less
than
300,000
pounds
are
referred
to
as
"
partially
exempt"
from
reporting
because
they
are
not
required
to
provide
processing
and
use
information
(
Part
III
of
Form
U),
but
continue
to
report
site
and
manufacturing
information
(
Parts
I
and
II
of
Form
U).
For
the
2006
reporting
cycle,
inorganic
chemicals
have
a
partial
exemption.

Starting
with
the
next
reporting
cycle
after
2006,
inorganic
chemicals
will
be
subject
to
the
same
full
reporting
requirements
as
organic
chemicals.
Partial
exemptions
are
also
granted
for
certain
listed
petroleum
process
stream
chemicals,
and
for
certain
other
chemicals
for
which
there
is
currently
low
interest
in
processing
and
use
data.

Form
U,
the
instrument
used
to
collect
the
IUR
information,
is
divided
into
three
parts:

Site
Identification
Information,
Manufacturing
Information,
and
Processing
and
Use
Information.

(
A
copy
of
Form
U
is
in
Appendix
A.)
An
overview
of
the
information
collected
under
the
IUR
rule
is
as
follows:


Certification
statement.
A
company
official
must
sign
the
form,
certifying
that
the
information
provided
is
complete
and
accurate.


Company
information.
Includes
the
company
name
and
Dun
&
Bradstreet
number.


Technical
contact
information.
Includes
the
name,
address,
telephone
number,
and
email
address
for
a
technical
contact.


Plant
site
information.
Includes
the
name,
address,
and
Dun
&
Bradstreet
number
for
the
plant
site
that
is
reporting.


Chemical
identification.
Includes
both
the
specific
chemical
name
and
the
Chemical
Abstracts
Service
(
CAS)
Registry
Number,
or
other
identifying
number,
of
the
chemical
substance.


Manufacturing
information.
Includes
an
indication
of
whether
the
chemical
substance
is
manufactured
or
imported;
whether
it
is
site
limited
(
whether
it
is
produced
and
used
at
the
same
site,
and
does
not
undergo
packaging
and
shipping);
and
the
production
volume.
Also
contains
the
number
of
workers
involved
in
manufacturing
that
are
reasonably
likely
to
be
exposed
to
the
chemical
substance,
the
physical
form(
s)
as
the
chemical
leaves
the
site
(
including
the
percent
of
the
production
volume
in
each
form),
and
the
maximum
concentration
of
the
chemical
as
it
leaves
the
site.
Codes
representing
ranges
are
used
to
report
these
data.


Industrial
processing
and
use
data.
Includes
the
types
of
process
or
use
for
the
chemical
substance,
the
related
North
American
Industrial
Classification
System
(
NAICS)
codes
and
industrial
function
codes,
as
well
as
the
percentage
of
production
volume
attributable
to
each
processing
or
use
activity
reported,
the
number
of
sites,
1­
4
Box
1­
1.
Industrial
Function
Categories
$
Adsorbents
and
absorbents
$
Adhesives
and
binding
agents
$
Aerosol
propellants
$
Agricultural
chemicals
(
non­
pesticidal)

$
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
2.
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
and
the
number
of
workers
for
downstream
processing
and
uses
of
the
chemical.
These
data
are
reported
for
up
to
ten
unique
combinations
of
use,
function,
and
NAICS
code
with
the
largest
production
volumes
(
by
weight)
for
the
chemical.
The
industrial
function
category
codes
are
listed
in
Box
1­
1.
Only
"
readily
obtainable"
data
are
required
to
be
reported.


Consumer
and
commercial
end­
use
data.
Includes
the
relevant
commercial
and
consumer
product
categories,
the
percentage
of
the
production
volume
in
each
product
category,
the
maximum
concentration
of
the
chemical
in
each
final
product,
and
an
indication
of
whether
the
chemical
is
intended
for
children's
use.
The
commercial
and
consumer
product
categories
are
listed
in
Box
1­
2.


Confidential
Business
Information
(
CBI)
status
can
be
claimed
for
each
data
element
reported.
Submitters
who
claim
the
chemical
identity
or
plant
site
identity
as
CBI
must
provide
up­
front
substantiation.
1­
5
1.3
Overview
of
the
Regulated
Community
The
regulated
community
for
the
IUR
rule
(
who
will
potentially
be
affected
by
the
IUR
Revisions
Rule)
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.
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
information
on
those
chemicals
under
the
IUR
rule.
(
Some
chemical
substances
might
have
both
TSCA
and
non­
TSCA
uses.
In
that
case,
the
production
associated
with
the
TSCA
use
is
reported.)
Companies
engaged
in
chemical
manufacturing
(
NAICS
Group
325)
or
petroleum
refining
(
NAICS
Group
3241)
are
the
most
likely
to
report
under
the
IUR
rule.
However,
companies
in
any
industry
are
subject
to
reporting
if
they
manufacture
or
import
covered
chemicals
above
the
reporting
threshold.
Companies
must
review
the
rule
to
determine
whether
they
must
report.

1.4.
Changes
in
Reporting
Requirements
under
the
IUR
Revisions
Rule
The
revisions
encompass
nine
specific
changes
to
the
IUR
rule.
Each
of
these
revisions
is
described
below.

Change
Reporting
Frequency
The
current
IUR
rule
requires
reporting
every
four
years.
The
first
submission
period
reflecting
the
changes
implemented
in
the
2003
Amendments
will
be
in
2006,
with
submitters
supplying
data
for
the
calendar
year
2005.
Under
the
IUR
Revisions
Rule,
the
reporting
frequency
would
be
changed
from
every
four
years
to
every
five
years
after
the
first
reporting
period.
In
other
words,
these
revisions
would
retain
the
current
reporting
year
of
2005
(
submitted
to
EPA
in
2006),
but
instead
of
occurring
in
2009
the
next
reporting
year
under
the
IUR
would
be
delayed
until
2010
(
i.
e.,
five
years
after
the
2005
reporting
year).
The
submission
period
would
continue
to
occur
during
the
year
after
the
reporting
year
(
e.
g.,
2011,
2016).
This
change
is
being
made
to
reduce
the
burden
of
the
IUR
rule.

Move
Submission
Period
Under
the
current
IUR
rule,
submitters
are
required
to
report
on
a
recurring
basis
during
a
120­
day
period
from
August
25
to
December
23
(
40
CFR
710.53).
EPA
proposed
changing
the
submission
period
to
occur
from
January
1
to
April
30,
but
reconsidered
this
action
after
receiving
comments.
EPA
is
keeping
the
submission
period
of
August
25
to
December
23
for
the
2006
reporting
cycle,
and
moving
the
reporting
cycle
to
June
1
to
September
30
in
subsequent
cycles.

This
change
is
related
to
the
change
in
reporting
year
from
company
fiscal
year
to
calendar
year
that
occurred
under
the
2003
Amendments.
The
August
to
December
submission
period
was
1­
6
originally
chosen
because
many
companies'
fiscal
years
end
in
July,
such
that
starting
the
IUR
submission
period
in
late
August
allowed
these
companies
to
report
their
most
current
information
in
the
most
timely
manner
possible.
However,
because
the
2003
Amendments
require
submitters
to
report
on
a
calendar­
year
basis,
an
earlier
submission
period
is
more
appropriate
because
it
will
allow
sites
to
submit
their
information
to
EPA
closer
to
the
period
during
which
it
was
generated.
This
will
then
allow
the
Agency
to
obtain
and
process
the
information
in
a
more
timely
manner.

Clarify
"
Low
Current
Interest"
Partial
Exemption
Petition
Process
Section
710.46(
b)(
2)
of
the
CFR
contains
the
requirements
for
the
partial
exemption
of
certain
chemicals
for
which
EPA
has
determined
the
IUR
processing
and
use
information
to
be
of
"
low
current
interest."
Manufacturers
and
importers
of
the
listed
chemicals
are
not
required
to
report
the
processing
and
use
information
in
Part
III
of
the
Form
U
for
those
listed
chemicals.

The
public
may
ask
EPA
to
change
the
partial
exemption
list
by
adding
or
removing
chemicals.

The
request
must
be
in
writing,
must
identify
the
chemical
in
question
(
including
a
chemical
identification
number),
and,
as
clarified
in
these
revisions,
must
provide
a
written
rationale
or
justification
for
the
request,
accompanied
by
relevant
documents
and
specific
cites
to
information
in
those
documents.
The
rationale
needs
to
provide
sufficient
information
on
which
the
Agency
can
assess
the
current
need
for
IUR
processing
and
use
information
and
can
make
a
decision
concerning
reporting
of
that
information
for
the
subject
chemical.

EPA
is
making
this
clarification
in
reaction
to
the
first
round
of
requests
for
consideration,

which
were
received
by
December
30,
2003.
It
was
always
EPA's
intent
that
the
requests
contain
supporting
rationale
associated
with
the
request,
and
that
the
rationale
specifically
address
at
least
the
considerations
outlined
in
40
CFR
710.46(
b)(
2)(
ii).
Instead,
EPA
received
a
number
of
petitions
that
only
cited
the
existence
of
another
document
(
i.
e.,
an
OECD
SIDS
Initial
Assessment
Report)
as
support,
without
any
discussion
of
the
document's
relevance
to
the
considerations
or
why
the
petitioner
believes
the
document
supports
a
finding
of
low
current
interest
in
the
IUR
processing
and
use
information.
EPA
is
clarifying
that
it
is
a
petitioner's
burden
to
present
an
argument
as
to
why
the
IUR
processing
and
use
information
for
a
given
chemical
substance
should
be
considered
of
low
current
interest.

Partially
Exempt
Additional
Petroleum
Process
Streams
There
are
currently
591
listed
petroleum
process
streams
that
are
exempt
from
reporting
downstream
processing
and
use
information
in
Part
III
of
the
Form
U.
This
list
of
partially
exempt
petroleum
process
streams
was
derived
from
a
1983
publication
of
the
American
Petroleum
Institute
(
API)
entitled
"
Petroleum
Process
Stream
Terms
Included
in
the
Chemical
Substance
Inventory
Under
the
Toxic
Substances
Control
Act
(
TSCA)"
(
API,
1983).
EPA
is
now
amending
its
list
to
add
certain
petroleum
process
streams
that
have
been
added
to
the
TSCA
Inventory
since
the
1983
API
publication
was
compiled.
EPA
is
adding
25
substances
that
were
1­
7
not
in
the
1983
API
publication,
plus
an
additional
two
other
substances
which
were
inadvertently
left
off
the
original
partial
exemption
listing.

Change
Consumer
and
Commercial
Product
Categories
Submitters
completing
Part
III
of
Form
U
must
designate
the
commercial
and
consumer
product
category
or
categories
that
best
describe
the
commercial
and
consumer
products
in
which
each
reportable
chemical
substance
is
used.
(
See
Box
1­
2
for
a
list
of
the
categories.)
The
Agency
is
adding
to
the
list
a
category
called
"
Agricultural
Products
(
non­
pesticidal)."
Many
chemicals
with
consumer
and
commercial
applications
are
used
in
agricultural
applications,
an
area
not
explicit
in
the
current
consumer
and
commercial
product
categories.
EPA
is
adding
this
category
to
ensure
that
the
volume
of
chemicals
associated
with
this
end
use
is
separated
out
and
not
combined
into
the
"
other"
category.

EPA
had
also
proposed
to
combine
the
categories
of
"
Soaps
and
Detergents"
and
"
Polishes
and
Sanitation
Goods"
to
form
a
new
category
called
"
Cleaning
Products
(

nonpesticidal
This
change
was
suggested
during
the
public
comment
period
for
the
2003
Amendments,
and
based
on
an
EPA
determination
that
manufacturers
might
have
difficulty
differentiating
between
these
similar
downstream
categories,
and
that
it
would
be
appropriate
for
them
to
report
under
a
single
category.
Upon
further
analysis,
these
two
categories
are
clearly
differentiated
in
the
six­
digit
North
American
Industry
Classification
System
(
NAICS)
codes,
and
the
use
scenarios
in
models
that
EPA
typically
uses
to
analyze
a
screening­
level
exposure
assessment
are
different
from
each
other
and
therefore
would
generate
different
potential
exposure
results.
Therefore
EPA
is
not
combining
these
two
categories.

EPA
had
additionally
proposed
removing
the
category
"
Photographic
Chemicals."
This
proposed
deletion
was
in
recognition
of
the
changing
photography
industry
(
i.
e.,
shift
from
traditional
film
photo
finishing
to
electronic
capture
and
production).
Further
investigation
reveals
that
despite
the
displacement
of
analog
photography
by
digital
imaging,
U.
S.
consumption
of
film
and
paper
chemicals
is
projected
to
remain
relatively
stable.
Included
in
this
category
are
many
substances
that
have
roles
in
digital
imaging
as
well
as
analog.
Thus,
EPA
is
maintaining
this
category.

Report
Manufactured
and
Imported
Volumes
Separately
Prior
to
the
2003
Amendments,
submitters
were
required
to
report
the
volume
manufactured
separately
from
the
volume
imported
for
each
reportable
chemical
substance.
As
a
result
of
the
2003
Amendments,
submitters
are
currently
required
to
report
the
total
production
volume
(
i.
e.,
the
sum
of
manufactured
and
imported
volumes)
for
each
reportable
chemical
substance.
EPA
often
needs
to
be
able
to
distinguish
between
the
quantities
of
a
chemical
that
are
manufactured
domestically
and
those
that
are
imported.
Thus,
EPA
is
returning
to
the
previous
method
of
reporting
manufactured
volume
separate
from
imported
volume.
1­
8
Report
Processing
and
Use
Information
for
Domestic
Uses
Only
Submitters
with
production
volumes
of
300,000
pounds
or
greater
for
a
reportable
chemical
substance
are
currently
required
to
report
processing
and
use
information
(
Part
III
of
Form
U)
for
domestic
and
overseas
uses,
to
the
extent
the
information
is
readily
available.
EPA
is
limiting
the
reporting
to
processing
and
use
occurring
domestically.
Submitters
would
no
longer
be
obligated
to
report
processing
or
use
information
for
activities
that
occur
once
the
chemical
substance
leaves
the
United
States.
This
change
is
intended
to
reduce
the
burden
associated
with
reporting
information
under
the
IUR
rule,
and
in
recognition
that
EPA's
primary
focus
is
on
domestic
exposures
to
chemicals.

Update
Polymer
Exemption
Reference
Chemical
substances
meeting
the
definition
for
polymers
are
currently
exempt
from
reporting
under
the
IUR
rule.
EPA
is
changing
the
regulatory
reference
of
the
polymer
definition
from
the
"
1985
edition
of
the
Inventory
or
the
Master
Inventory
File"
to
the
"
Master
Inventory
File".
EPA
is
removing
the
reference
to
the
1985
edition
of
the
Inventory
because
the
Master
Inventory
File
has
been
regularly
updated
since
the
1985
edition.
This
change
will
keep
the
reference
current
and
up­
to­
date.

Remove
Production
Volume
Range
CBI
Requirement
The
2003
Amendments
contained
a
requirement
that
submitters
determine
whether
production
volume
should
be
considered
CBI
if
presented
as
a
specified
range
instead
of
as
a
point
estimate.
This
amendment
was
included
in
the
2003
final
rule
as
part
of
an
effort
to
make
available
to
the
public
a
greater
amount
of
the
site­
and
chemical­
specific
production­
volume
range
information
from
the
IUR
rule.
EPA
is
now
repealing
this
reporting
requirement.

EPA's
decision
not
to
solicit
confidentiality
claims
for
the
standardized
production
volume
ranges
in
710.52(
c)(
3)(
v)
was
based
on
several
concerns,
most
importantly
issues
inherent
in
releasing
both
aggregated
data
and
site­
specific
production
volume
ranges.
The
Agency
has
determined
that
this
provision
regarding
the
confidentiality
of
production
volume
information
within
specified
ranges
is
not
likely
to
result
in
greater
availability
of
production
volume
information
to
the
public,
which
was
the
goal
of
this
data
element.
Therefore,
there
is
no
need
for
submitters
to
make
a
CBI
determination
for
production
volume
in
ranges.
It
is
important
to
note
that,
by
this
change,
EPA
is
not
presuming
consent
to
release
these
production
volume
ranges
for
site­
specific
production
volume
ranges
or
otherwise
lessening
any
CBI
protections.
2­
1
CHAPTER
2
COST
SAVINGS
DUE
TO
THE
IUR
REVISIONS
RULE
This
chapter
analyzes
the
changes
in
industry
compliance
costs
and
government
administration
costs
associated
with
the
IUR
Revisions
Rule.
The
incremental
social
costs
of
the
revisions
are
negative
(
i.
e.,
there
is
a
cost
savings),
primarily
due
to
less
frequent
information
collection.
This
chapter
calculates
the
incremental
cost
savings
of
the
revisions
by
comparing
the
costs
to
industry
and
the
government
under
the
current
IUR
rule
and
after
the
revisions.
The
methodology
for
estimating
the
change
in
industry
costs
can
be
summarized
as
follows:


Step
1:
Identify
the
tasks
that
sites
perform
to
comply
with
reporting
requirements
for
both
the
current
IUR
rule
and
the
IUR
Revisions
Rule.


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
each
of
the
rules.


Step
4:
Multiply
the
cost
per
form
by
the
number
of
forms
to
determine
the
estimated
total
costs
of
compliance
for
the
current
IUR
rule
and
the
IUR
Revisions
Rule.


Step
5:
Subtract
the
compliance
cost
after
the
IUR
Revisions
Rule
from
the
cost
under
the
current
IUR
rule
to
calculate
the
incremental
savings
due
to
the
revisions.

More
information
on
the
estimation
of
compliance
costs
under
the
current
IUR
rule
can
be
found
in
the
"
Economic
Analysis
for
the
Amended
Inventory
Update
Rule"
(
EPA,
2002).

The
steps
required
for
compliance
with
the
IUR
rule
can
be
characterized
as
compliance
determination,
rule
familiarization,
preparation
and
submission
of
reports,
and
recordkeeping.

The
actions
taken
under
these
steps
are
as
follows:


Compliance
Determination:
To
determine
if
it
must
submit
a
Form
U,
a
company
must
determine
whether
(
1)
it
manufactures
or
imports
any
chemicals
that
do
not
fall
into
one
of
the
categories
exempt
from
reporting,
(
2)
the
annual
production
or
import
volume
of
the
chemical
is
above
the
reporting
threshold,
and
(
3)
the
company
meets
the
small
business
criteria
set
forth
in
the
TSCA
§
8(
a)
Small
Manufacturer
Exemption
Rule
(
40
CFR
704.3).
For
simplicity,
the
cost
for
compliance
determination
is
considered
to
be
incurred
once
per
site,
and
does
not
vary
with
the
number
of
chemicals
at
the
site.
A
portion
of
the
compliance
determination
cost
depends
on
the
number
of
chemicals,
but
for
most
chemicals
this
component
of
the
burden
will
be
extremely
small.
The
majority
of
the
time
required
for
this
task
involves
identifying
2­
2
the
requirements
and
reviewing
information
to
determine
if
the
site
must
submit
a
Form
U.


Rule
Familiarization:
Once
a
company
has
determined
that
it
must
submit
a
Form
U
for
a
site,
staff
must
familiarize
themselves
with
the
remainder
of
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.


Preparation
and
Submission
of
Reports:
Once
a
site
has
determined
that
it
must
provide
information
on
a
chemical
and
has
become
familiar
with
the
rule,
the
required
information
must
be
collected
and
a
Form
U
covering
all
of
the
reportable
chemicals
at
that
site
must
be
completed,
reviewed,
and
submitted
to
EPA.


Recordkeeping:
Submitters
must
keep
records
supporting
their
submissions
for
five
years.

Only
a
few
of
the
provisions
of
the
IUR
Revisions
Rule
are
expected
to
have
a
measurable
impact
on
the
cost
of
IUR
reporting.
The
average
annual
cost
will
decline
under
the
IUR
Revisions
Rule
because
of
less
frequent
reporting.
The
exemption
of
exported
volume
from
processing
and
use
reporting
requirements
will
reduce
reporting
costs.
Also,
granting
partial
exemptions
for
additional
petroleum
process
streams
will
reduce
reporting
costs
for
these
substances.

2.1
Unit
Time
and
Cost
Estimates
The
reporting
costs
are
determined
based
on
estimates
of
wage
rates,
labor
hours,
and
the
number
of
sites
and
reports.
This
section
describes
the
specific
data
used
to
develop
these
estimates.

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

Four
BLS
occupation
categories
were
analyzed:
engineers,
accountants,
attorneys,
and
secretaries.

As
presented
in
Table
2­
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
5The
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.
Year
2000
dollars
are
used
for
consistency
with
the
Economic
Analysis
for
the
Amended
Inventory
Update
Rule
(
EPA,
2002).

2­
3
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).

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.
5
The
adjusted,
composite
salaries
for
the
managerial,
technical,
and
clerical
labor
categories
were
then
multiplied
by
benefits
and
overhead
factors
to
estimate
loaded,
annual
salaries
in
year
2000
dollars.
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
Table
2­
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
B
8)
$
93,981
10/
17
$
55,283
Attorney
(
4
B
6)
$
111,263
5/
17
$
32,724
Accountant
(
5
B
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
B
8)
$
74,802
5/
6
$
62,335
Accountant
(
3
B
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
B
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.
Washington,
DC:
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.
2­
4
labor.
The
overhead
factor
of
17
percent
is
based
on
information
provided
by
the
chemical
industry
and
chemical
industry
trade
associations.
The
loaded
annual
salary
was
then
divided
by
2,080
hours
(
i.
e.,
the
average
annual
number
of
hours
worked
per
year
by
a
full­
time
employee).

The
result
is
an
estimate
of
$
27.37
per
hour
for
clerical
labor,
$
65.96
per
hour
for
technical
labor,

and
$
95.55
per
hour
for
managerial
labor,
all
in
year
2000
dollars.

Estimates
of
Labor
Hours
As
mentioned
earlier,
the
reporting
instrument
for
the
IUR
rule
is
the
Form
U.
(
See
Appendix
A
for
a
copy
of
Form
U.)
Each
reporting
site
is
required
to
file
only
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
once.
Contained
within
the
Form
U
are
any
number
of
individual
chemical
reports.
EPA
estimated
some
costs
on
a
per­
site
basis
and
some
on
a
perreport
basis.
Each
site
must
determine
whether
it
must
comply
with
the
IUR
and
then
must
familiarize
itself
with
the
rule's
reporting
requirements.
The
costs
associated
with
these
tasks
are
calculated
per
site
(
i.
e.,
not
varying
with
the
number
of
chemicals
reported
at
the
site).
For
each
reportable
chemical,
a
report
must
be
prepared
and
submitted
and
a
record
of
it
must
be
kept.

Reporting
and
recordkeeping
costs
are
calculated
as
per­
report
costs
(
so
that
total
reporting
and
recordkeeping
costs
vary
with
the
number
of
chemicals
reported).

The
estimates
of
the
labor
hours
required
for
the
various
tasks
in
the
baseline
are
taken
from
the
economic
analysis
for
the
2003
Amendments
(
EPA,
2002).
Table
2­
2
summarizes
the
average
estimated
burden
per
unit
(
either
report
or
site)
for
each
of
these
tasks
for
the
2006
IUR
submission
period
(
when
inorganic
chemicals
have
a
partial
exemption).
Table
2­
3
presents
average
estimated
burden
under
baseline
conditions
for
submission
periods
after
2006,
when
inorganic
chemicals
become
subject
to
the
same
requirements
for
providing
processing
and
use
information
as
organic
chemicals.
In
addition,
burden
estimates
have
been
scaled
downward
in
some
categories
to
reflect
learning
from
the
2006
submission,
the
first
submission
that
includes
the
changes
due
to
the
2003
Amendments;
see
the
economic
analysis
for
the
2003
Amendments
(
EPA,
2002)
for
more
information.
For
chemicals
produced
at
volumes
of
25,000
to
300,000
pounds
and
for
chemicals
meeting
the
partial
exemptions,
only
Parts
I
and
II
of
Form
U
must
be
completed.
Thus,
burden
estimates
are
provided
separately
for
full
and
partial
reports.
The
amount
of
effort
(
and
therefore
costs)
required
may
vary
depending
on
factors
such
as
company
size,
type
of
chemical,
and
the
variety
of
uses
for
the
chemical.

The
IUR
Revisions
Rule
would
reduce
the
time
required
for
compliance
because
submitters
would
no
longer
be
required
to
report
processing
and
use
information
for
exports.
The
value
of
exports
for
the
chemical
industry
has
been
equal
to
about
15
percent
of
the
value
of
production
plus
imports
in
recent
years
(
ACC,
2003).
Thus,
it
was
assumed
that
the
average
burden
of
completing
Part
III
of
Form
U
would
be
reduced
by
15
percent
under
the
IUR
2­
5
Revisions
Rule
relative
to
the
current
burden
(
see
Tables
2­
2
and
2­
3).
This
reflects
the
reduction
in
time
required
to
determine
use
and
processing
information
for
exports.
To
the
extent
that
the
industrial
function
categories,
function
codes,
and
use
codes
are
the
same
for
domestic
and
exported
uses,
this
adjustment
will
tend
to
overstate
the
reduction
in
burden.

Table
2­
2.
Average
Burden
Hours
for
2006
IUR
Submission
Unit
Average
Burden
Hours
per
Reporting
Cycle
Totals
Clerical
$
27.37/
hr
Technical
$
65.96/
hr
Managerial
$
95.55/
hr
Average
Hours/
Unit
Low
High
Low
High
Low
High
Low
High
Organic
Chemicals
Compliance
Determination
Site
0
0
1
4
0
0
1
4
Rule
Familiarization
Site
0
0
18
20
8
10
26
30
Report
Preparation
and
Submission
Partial
Report
Report
2.1
2.6
8.1
11.4
3.4
5.7
13.5
19.7
Full
Report
(
Baseline)
Report
10.8
12.5
59.3
66.8
22.4
26.0
92.4
105.3
Full
Report
(
after
IUR
Revisions
Rule)
Report
9.5
11.0
51.6
58.4
19.5
22.9
80.6
92.4
Recordkeeping
Report
1
2
2
4
1
2
4
8
Inorganic
Chemicalsa
Compliance
Determination
Site
0
0
1
4
0
0
1
4
Rule
Familiarization
Site
0
0
18
20
8
10
26
30
Report
Preparation
and
Submission
Partial
Report
Report
2.1
2.6
8.1
11.4
3.4
5.7
13.5
19.7
Full
Report
(
Baseline
and
IUR
Revisions
Rule)
Report
0
0
0
0
0
0
0
0
Recordkeeping
Report
1
2
2
4
1
2
4
8
a
Inorganic
chemicals
have
a
partial
exemption
from
reporting
processing
and
use
information
for
the
2006
submission
period.

Source:
U.
S.
Environmental
Protection
Agency.
August
2002.
Economic
Analysis
for
the
Amended
Inventory
Update
Final
Rule,
Final
Report.
Washington,
DC:
Office
of
Pollution
Prevention
and
Toxics,
Economic
and
Policy
Analysis
Branch.

However,
it
is
likely
that
determining
information
on
processing
and
use
for
exports
is
generally
more
difficult
than
for
domestic
uses
and
would
have
required
a
disproportionate
share
of
the
burden.
Thus,
EPA
determined
that
comparing
exports
to
the
value
of
production
plus
imports
was
a
reasonable
estimate
of
the
proportionate
reduction
in
burden
resulting
from
this
rule.
2­
6
The
burden
reduction
from
not
reporting
processing
and
use
information
for
exported
volumes
can
be
determined
by
calculating
the
burden
of
Part
III
of
Form
U
by
subtracting
the
burden
for
a
partial
report
(
Parts
I
and
II
of
Form
U)
from
the
burden
of
a
full
report
under
the
baseline
conditions;
multiplying
the
result
by
85
percent
(
reflecting
the
15
percent
reduction
in
Table
2­
3.
Average
Burden
Hours
for
IUR
Submissions
after
2006
Unit
Average
Burden
Hours
per
Reporting
Cycle
Totals
Clerical
$
27.37/
hr
Technical
$
65.96/
hr
Managerial
$
95.55/
hr
Average
Hours/
Unit
Low
High
Low
High
Low
High
Low
High
Organic
Chemicals
Compliance
Determination
Site
0
0
1
4
0
0
1
4
Rule
Familiarization
Site
0
0
2
2
2
2
4
4
Report
Preparation
and
Submission
Partial
Report
Report
1.9
2.4
7.3
10.2
3.0
5.2
12.2
17.7
Full
Report
(
Baseline)
Report
8.8
10.4
48.2
54.5
18.2
21.4
75.3
86.2
Full
Report
(
after
IUR
Revisions
Rule)
Report
7.8
9.2
42.1
47.8
16.0
18.9
65.8
75.9
Recordkeeping
Report
1
2
2
4
1
2
4
8
Inorganic
Chemicalsa
Compliance
Determination
Site
0
0
1
4
0
0
1
4
Rule
Familiarization
Site
0
0
2
2
2
2
4
4
Report
Preparation
and
Submission
Partial
Report
Report
1.9
2.4
7.3
10.2
3.0
5.2
12.2
17.7
Full
Report
(
Baseline)
Report
8.8
10.4
48.2
54.5
18.2
21.4
75.3
86.2
Full
Report
(
after
IUR
Revisions
Rule)
Report
7.8
9.2
42.1
47.8
16.0
18.9
65.8
75.9
Recordkeeping
Report
1
2
2
4
1
2
4
8
a
Inorganic
chemicals
begin
reporting
processing
and
use
information
after
the
2006
submission
period.

Source:
U.
S.
Environmental
Protection
Agency.
August
2002.
Economic
Analysis
for
the
Amended
Inventory
Update
Final
Rule,
Final
Report.
Washington,
DC:
Office
of
Pollution
Prevention
and
Toxics,
Economic
and
Policy
Analysis
Branch.

burden
due
to
the
revision)
for
an
estimate
of
the
burden
for
the
revised
Part
III;
and
adding
back
in
the
burden
estimate
for
a
partial
report
(
Parts
I
and
II
of
Form
U),
yielding
an
estimate
of
the
burden
of
a
full
report
after
the
IUR
Revisions
Rule.
The
results
are
highlighted
in
Table
2­
2
and
2­
3.
6Both
the
current
and
revised
IUR
include
a
partial
exemption
for
petroleum
process
stream
chemicals
and
for
specific
chemicals
based
on
low
current
interest
in
processing
and
use
data
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
2006
submission
period
only.
In
future
reporting
cycles,
they
are
subject
to
the
same
threshold
for
full
reports
as
organic
chemicals.

7The
same
number
of
reports
are
expected
under
both
the
current
IUR
and
the
IUR
Revisions
Rule.
The
revisions
do
not
have
any
provisions
that
would
affect
the
total
number
of
reports
required.

2­
7
These
burden
estimates
may
overstate
the
actual
burden
associated
with
IUR
reporting.

The
estimates
were
based
in
part
on
information
collected
through
a
survey
of
IUR
respondents.

Although
the
IUR
rule
only
requires
that
industry
report
"
readily
available"
information
for
downstream
processing
and
use
information,
the
respondent
survey
that
was
used
to
estimate
reporting
burden
did
not
mention
this
standard.
Thus,
survey
respondents
were
likely
assuming
a
higher
standard
of
information
than
EPA
requires.
This
is
demonstrated
by
evidence
from
EPA's
Use
and
Exposure
Information
Project
(
UEIP).
Under
the
UEIP,
companies
were
asked
to
report
chemical
information
very
similar
to
that
required
by
the
IUR.
When
respondents
were
asked
about
the
time
spent
preparing
the
UEIP
form
for
submission
they
reported
a
median
burden
of
8
hours
per
chemical
report,
with
a
mean
of
12
hours
(
EPA,
1997b).
This
is
evidence
that
the
burden
estimates
derived
from
the
IUR
survey
may
overestimate
the
actual
reporting
burden.
It
is
not
clear
what
impact
this
has
on
the
estimates
of
savings
due
to
the
IUR
Revisions
Rule.

Estimates
of
the
Number
of
Sites
and
Reports
The
baseline
number
of
reports
expected
and
the
number
of
sites
filing
those
reports
were
estimated
in
the
economic
analysis
for
the
2003
Amendments
(
EPA,
2002).
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.
6
The
number
of
reports
expected
was
estimated
using
data
compiled
from
EPA's
Chemical
Update
System
(
CUS)
and
EPA's
Chemicals
in
Commerce
Information
System
(
CICIS).
7
The
CUS
database
contains
information
collected
under
the
IUR
rule
for
previous
submission
periods
and
was
used
to
generate
estimates
of
expected
reports
for
organic
chemicals.
The
CUS
database
could
not
be
used
to
estimate
the
number
of
reports
for
inorganic
chemicals
because
inorganic
chemicals
were
previously
exempt
from
the
IUR
rule
and
therefore
are
not
included
in
the
historical
CUS
data.

Instead,
the
CICIS
database
was
used
for
inorganic
chemicals.
CICIS
contains
information
collected
by
EPA
on
TSCA
chemicals
in
commerce
in
the
United
States
in
1977,
including
inorganic
chemicals.

Table
2­
4
displays
the
number
of
sites
and
reports
expected
under
baseline
conditions
and
under
the
IUR
Revisions
Rule.
The
only
difference
between
the
two
is
that
the
revisions
will
add
25
chemical
substances
to
the
list
of
petroleum
process
streams
with
partial
exemptions.
This
change
is
expected
to
switch
only
about
10
reports
from
full
to
partial
based
on
recent
CUS
2­
8
submissions,
because
reports
are
not
being
submitted
for
the
majority
of
these
chemicals
in
the
baseline.

Table
2­
4.
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
Baseline
2,482
12,765
9,495
3,848
3,900
IUR
Revisions
Rule
2,482
12,775
9,485
3,858
3,890
Change
0
+
10
­
10
+
10
­
10
Inorganic
Chemicals
2006
Submission
Baseline
544
4,537
0
1,117
0
IUR
Revisions
Rule
544
4,537
0
1,117
0
Change
0
0
0
0
0
Future
Submissions
Baseline
544
2,300
2,236
488
629
IUR
Revisions
Rule
544
2,300
2,236
488
629
Change
0
0
0
0
0
a
Petroleum
process
stream
chemicals
and
certain
specifically
listed
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
2006
IUR
submission,
but
in
all
future
cycles
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.

Source:
U.
S.
Environmental
Protection
Agency.
August
2002.
Economic
Analysis
for
the
Amended
Inventory
Update
Rule,

Final
Report.
Washington,
DC:
Office
of
Pollution
Prevention
and
Toxics,
Economic
and
Policy
Analysis
Branch.

2.2
Current
IUR
Rule
Industry
Compliance
Costs
The
estimated
wage
rates,
burden
hours,
and
number
of
sites
were
combined
to
estimate
the
total
compliance
costs
of
the
current
IUR
rule.
For
more
detail
on
underlying
calculations,

see
the
economic
analysis
of
the
2003
Amendments
(
EPA,
2002).
Costs
were
estimated
as
either
per
site
or
per
report,
depending
on
the
way
the
costs
are
incurred.
Compliance
determination
and
rule
familiarization
were
estimated
on
a
per­
site
basis,
while
report
preparation
and
submission
and
recordkeeping
were
estimated
on
a
per­
report
basis.
Separate
estimates
were
developed
for
organic
and
inorganic
chemicals
and
for
the
two
report
types
(
full
or
partial
form,

based
on
production
volume
and
exemption
status).
Tables
2­
5
and
2­
6
present
the
costs
of
the
current
IUR
for
organic
and
inorganic
chemicals,
respectively.

The
total
costs
to
industry
of
the
current
IUR
rule
in
the
2006
reporting
cycle
and
for
future
reporting
cycles
are
presented
in
Table
2­
7,
while
Table
2­
8
presents
estimates
of
the
total
2­
9
burden
hours
of
the
current
IUR
rule.
Total
industry
compliance
costs
of
the
current
IUR
are
estimated
at
$
88.9
million
to
$
113.6
million
for
the
2006
reporting
cycle
and
$
81
million
to
$
103.4
million
for
future
reporting
cycles.
Reporting
burden
is
estimated
to
be
1,300,000
to
1,658,000
hours
for
the
2006
reporting
cycle
and
1,189,000
to
1,516,000
hours
for
future
reporting
cycles.

Table
2­
5.
Industry
Costs
of
the
Current
IUR
Rule
for
Organic
Chemicals
(
2000$)

Unit
of
Analysis
Cost
per
Unit
Number
of
Units
Total
Cost
Low
High
Low
High
2006
Submission
Compliance
Determination
Site
$
65.96
$
263.84
2,482
$
163,710
$
654,839
Rule
Familiarization
Site
$
1,951.66
$
2,274.68
2,482
$
4,844,032
$
5,645,766
Report
Preparation
and
Submission
Report
Partial
Report
$
911.38
$
1,366.70
12,765
$
11,633,801
$
17,445,878
Full
Report
Report
$
6,342.41
$
7,228.54
9,495
$
60,221,208
$
68,634,970
Recordkeeping
Report
$
254.84
$
509.67
22,260
$
5,672,661
$
11,345,322
Total
Cost
of
Current
IUR
$
82,535,412
$
103,726,775
Future
Reporting
Cycles
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
Report
Preparation
and
Submission
Partial
Report
Report
$
821.20
$
1,229.93
12,765
$
10,482,671
$
15,700,042
Full
Report
Report
$
5,166.03
$
5,919.40
9,495
$
49,051,437
$
56,204,726
Recordkeeping
Report
$
254.84
$
509.67
22,260
$
5,672,661
$
11,345,322
Total
Cost
of
Current
IUR
$
66,172,212
$
84,706,662
Source:
U.
S.
Environmental
Protection
Agency.
August
2002.
Economic
Analysis
for
the
Amended
Inventory
Update
Rule,
Final
Report.
Washington,
DC:
Office
of
Pollution
Prevention
and
Toxics,
Economic
and
Policy
Analysis
Branch.
2­
10
Table
2­
6.
Industry
Costs
of
the
Current
IUR
Rule
for
Inorganic
Chemicals
(
2000$)

Unit
of
Analysis
Cost
per
Unit
Number
of
Units
Total
Cost
Low
High
Low
High
2006
Submission
Compliance
Determination
Site
$
65.96
$
263.84
544
$
35,885
$
143,540
Rule
Familiarization
Site
$
1,951.66
$
2,274.68
544
$
1,061,810
$
1,237,550
Report
Preparation
and
Submission
Partial
Report
Report
$
911.38
$
1,366.70
4,537
$
4,134,623
$
6,200,220
Full
Report
Report
$
6,342.41
$
7,228.54
0
0
0
Recordkeeping
Report
$
254.84
$
509.67
4,537
$
1,156,104
$
2,312,207
Total
Cost
of
Current
IUR
$
6,388,422
$
9,893,518
Future
Reporting
Cycles
Compliance
Determination
Site
$
65.96
$
263.84
544
$
35,885
$
143,540
Rule
Familiarization
Site
$
323.02
$
323.02
544
$
175,740
$
175,740
Report
Preparation
and
Submission
Partial
Report
Report
$
821.20
$
1,229.93
2,300
$
1,888,980
$
2,829,152
Full
Report
Report
$
5,166.03
$
5,919.40
2,236
$
11,553,261
$
13,238,101
Recordkeeping
Report
$
254.84
$
509.67
4,537
$
1,156,104
$
2,312,207
Total
Cost
of
Current
IUR
$
14,809,970
$
18,698,741
Source:
U.
S.
Environmental
Protection
Agency.
August
2002.
Economic
Analysis
for
the
Amended
Inventory
Update
Rule,
Final
Report.
Washington,
DC:
Office
of
Pollution
Prevention
and
Toxics,
Economic
and
Policy
Analysis
Branch.

Table
2­
7.
Total
Industry
Costs
of
Current
IUR
Rule
(
million
2000$)

2006
Reporting
Cycle
Total
Cost
Future
Reporting
Cycles
Total
Cost
Low
High
Low
High
Organic
Chemicals
$
82.5
$
103.7
$
66.2
$
84.7
Inorganic
Chemicals
$
6.4
$
9.9
$
14.8
$
18.7
Total
Cost
under
Current
IUR
$
88.9
$
113.6
$
81.0
$
103.4
Source:
U.
S.
Environmental
Protection
Agency.
August
2002.
Economic
Analysis
for
the
Amended
Inventory
Update
Rule,
Final
Report.
Washington,
DC:
Office
of
Pollution
Prevention
and
Toxics,
Economic
and
Policy
Analysis
Branch.
2­
11
Table
2­
8.
Total
Industry
Burden
Hours
of
Current
IUR
Rule
(
thousands
of
hours)

2006
Reporting
Cycle
Burden
Hours
(
thousands)
Future
Reporting
Cycles
Burden
Hours
(
thousands)

Low
High
Low
High
Organic
Chemicals
1,206
1,514
972
1,242
Inorganic
Chemicals
94
144
217
274
Total
Burden
of
Current
IUR
1,300
1,658
1,189
1,516
Source:
U.
S.
Environmental
Protection
Agency.
August
2002.
Economic
Analysis
for
the
Amended
Inventory
Update
Rule,
Final
Report.
Washington,
DC:
Office
of
Pollution
Prevention
and
Toxics,
Economic
and
Policy
Analysis
Branch.

2.3
Changes
in
Industry
Costs
Due
to
the
IUR
Revisions
Rule
The
expected
cost
impacts
of
each
of
the
revisions
to
the
IUR
rule
are
described
below.

See
Chapter
1.4
for
more
information
about
each
of
the
revisions
under
the
IUR
Revisions
Rule.

Change
Reporting
Frequency.
The
current
IUR
rule
requires
reporting
every
four
years.
The
next
reporting
year
will
be
2005,
with
the
submission
period
in
2006
(
i.
e.,
data
for
the
calendar
year
2005
are
due
to
be
submitted
to
EPA
in
2006).
Under
the
revisions,
the
reporting
frequency
will
be
changed
from
every
four
years
to
every
five
years
after
2005.
Instead
of
occurring
in
2009,
the
next
reporting
year
would
be
delayed
until
2010
(
i.
e.,
five
years
after
the
2005
reporting
year).
The
submission
period
would
continue
to
occur
during
the
year
following
the
reporting
year
(
e.
g.,
2011,
2016).
This
change
would
substantially
lower
the
present
value
of
reporting
costs
over
time.
Over
a
twenty
year
period,
extending
the
reporting
frequency
from
four
years
to
five
years
is
expected
to
reduce
the
present
value
of
industry
costs
by
$
59.3
million
to
$
75.7
million
using
a
3
percent
discount
rate
and
$
41.2
million
to
$
52.6
million
with
a
7
percent
discount
rate.
The
annualized
costs
decline
by
$
4.0
million
to
$
5.1
million
per
year
using
a
3
percent
discount
rate
and
$
3.9
million
to
$
5.0
million
per
year
using
a
7
percent
discount
rate.

Move
Submission
Period.
The
revisions
will
move
the
submission
period
for
reporting
from
the
end
of
the
calendar
year
(
August
through
December)
to
the
middle
(
June
through
September).
The
August
through
December
submission
period
was
originally
chosen
because
many
companies'
fiscal
years
end
in
July,
such
that
starting
the
IUR
submission
period
in
late
August
allowed
these
companies
to
report
their
most
current
information
in
the
most
timely
manner
possible.
However,
because
the
2003
Amendments
changed
the
basis
for
reporting
from
a
fiscal­
year
to
calendar­
year
basis,
an
earlier
submission
period
is
considered
more
appropriate
because
it
would
allow
sites
to
submit
their
information
closer
to
the
period
during
which
it
was
generated.
Because
the
data
are
required
approximately
the
same
amount
of
time
after
the
period
for
which
data
are
collected,
EPA
does
not
expect
this
change
to
result
in
incremental
costs
to
industry
submitters.
2­
12
Clarify
"
Low
Current
Interest"
Partial
Exemption
Process.
EPA
is
clarifying
that
a
request
for
listing
or
delisting
a
chemical
from
the
partial
exemption
must
contain
a
written
rationale
or
justification
for
the
request,
such
that
the
request
should
provide
sufficient
information
for
the
Agency
to
make
a
ruling
on
the
petition.
This
clarification
may
result
in
a
small
incremental
burden
for
some
companies
that
choose
to
file
a
petition,
but
EPA
expects
the
total
cost
to
be
minimal.
The
clarification
will
help
the
Agency
make
its
decision
in
a
more
expedient
manner.
By
making
a
petitioner's
intent
clearer,
it
may
also
increase
the
chance
of
the
petition
being
granted
by
EPA.
Companies
submitting
a
petition
presumably
expect
a
net
savings
from
their
action
(
because
they
will
no
longer
have
to
report
processing
and
use
information
for
the
chemical
if
the
petition
is
granted.)
Industry
savings
due
to
an
increased
likelihood
of
petitions
being
accepted
have
not
been
estimated
for
this
revision.

Partially
Exempt
Additional
Petroleum
Process
Streams.
The
revisions
will
add
27
petroleum
process
streams
to
the
list
of
partially
exempt
chemical
substances.
Based
on
recent
IUR
reporting
cycles,
there
have
been
an
average
of
only
about
10
reports
total
per
reporting
year
filed
across
all
27
of
these
chemical
substances.
The
difference
between
the
average
cost
of
submitting
a
full
report
and
a
partial
report
is
$
5,431
to
$
5,862
in
the
2006
submission
period
and
$
4,345
to
$
4,690
in
future
submission
periods.
Thus,
partial
exemptions
for
these
petroleum
process
streams
will
result
in
an
annual
savings
of
about
$
54,310
to
$
58,618
in
the
2006
submission
period
and
$
43,448
to
$
46,895
in
future
submission
periods.
Over
a
twenty
year
period,
the
present
value
of
the
savings
is
$
147,578
to
$
157,344
using
a
3
percent
discount
rate
and
$
115,067
to
$
122,327
using
a
7
percent
discount
rate.
The
annualized
savings
are
$
9,920
to
$
10,576
per
year
and
$
10,862
to
$
11,547
per
year
using
a
3
percent
and
a
7
percent
discount
rate,
respectively.

Consumer
and
Commercial
Product
Categories.
This
change
only
slightly
redefines
the
categories
that
submitters
can
use
to
identify
product
categories
for
the
chemical
substances
they
produce
or
import
and
is
not
expected
to
result
in
any
change
in
costs.

Report
Manufactured
and
Imported
Volumes
Separately.
The
revisions
will
require
separate
reporting
of
manufactured
and
imported
volumes.
This
is
expected
to
result
in
only
a
negligible
change
in
incremental
burden.
This
information
was
reported
separately
prior
to
the
2003
Amendments.
It
is
expected
that
these
values
are
readily
available.
If
this
change
were
not
made,
it
is
likely
that
submitters
would
continue
to
calculate
these
values
separately,
and
then
would
add
them
together
to
generate
an
estimate
of
total
production
volume.

Report
Processing
and
Use
Information
for
Domestic
Uses
Only.
This
revision
is
expected
to
substantially
reduce
the
burden
associated
with
submission
of
full
reports.

Approximately
15
percent
of
the
total
value
of
production
plus
imports
in
the
chemical
industry
is
exported
(
ACC,
2003).
Thus,
the
estimated
burden
for
reporting
IUR
processing
and
use
information
(
Section
III
of
Form
U)
for
an
average
report
was
reduced
by
15
percent
to
reflect
2­
13
the
savings
from
the
revision.
This
change
results
in
a
savings
of
$
7.8
million
to
$
8.4
million
for
the
2006
submission
period
and
$
7.7
million
to
$
8.3
million
in
future
submission
periods.
Over
a
twenty
year
period,
the
present
value
of
the
savings
is
$
24.4
million
to
$
26.3
million
using
a
3
percent
discount
rate
and
$
18.7
million
to
$
20.1
million
using
a
7
percent
discount
rate.
The
annualized
savings
are
$
1.6
million
to
$
1.8
million
per
year
using
a
3
percent
discount
rate
and
$
1.8
million
to
$
1.9
million
per
year
using
a
7
percent
discount
rate.

Update
Polymer
Exemption
Reference.
The
IUR
Revisions
Rule
will
adjust
the
polymer
definition
to
refer
to
the
current
Master
Inventory
File
rather
than
the
1985
version
of
the
Inventory.
This
change
is
not
expected
to
affect
the
costs
of
the
IUR.

Remove
CBI
Determination
for
Production
Volume
Ranges.
The
2003
Amendments
to
the
IUR
Revisions
Rule
required
submitters
to
determine
whether
production
volume
should
be
considered
CBI
if
presented
as
a
specified
range
instead
of
as
a
point
estimate.
EPA
is
now
repealing
this
requirement.
The
Agency
has
determined
that
this
provision
is
not
likely
to
result
in
greater
availability
of
production
volume
information
to
the
public,
which
was
the
goal.
It
is
important
to
note
that
EPA
is
not
lessening
any
CBI
protections
with
this
change.
This
change
will
result
in
a
negligible
decrease
in
burden
and
cost.

In
summary,
as
shown
in
Table
2­
9,
the
revisions
that
are
expected
to
have
a
significant
impact
on
costs
are
the
changes
to
the
reporting
frequency,
the
addition
of
25
petroleum
process
streams
to
the
list
of
partial
exemptions,
and
the
restriction
of
processing
and
use
reporting
requirements
to
domestic
uses
only.
All
three
of
these
changes
reduce
reporting
costs.

Table
2­
9.
Change
in
Industry
Costs
Due
to
IUR
Revisions
Rule
Revision
Change
in
Industry
Reporting
Costs
Change
Reporting
Frequency
$
4
to
$
5.1
million/
yr
in
savings
at
3%
discount
rate
$
3.9
to
$
5
million/
yr
in
savings
at
7%
discount
rate
Move
Submission
Period
Negligible
change
Clarify
"
Low
Current
Interest"
Partial
Exemption
Process
Negligible
change
Partially
Exempt
27
Petroleum
Process
Streams
$
0.01
million/
yr
in
savings
at
3%
and
7%
discount
rate
Change
Consumer
&
Commercial
Product
Categories
No
change
Report
Manufactured
&
Imported
Volumes
Separately
Negligible
change
Report
Process
and
Use
Information
for
Domestic
Uses
Only
$
1.6
to
$
1.8
million/
yr
in
savings
at
3%
discount
rate
$
1.8
to
$
1.9
million/
yr
in
savings
at
7%
discount
rate
Update
Polymer
Exemption
Reference
No
change
Remove
CBI
Determination
for
Production
Volume
Ranges
Negligible
change
2­
14
2.4
Industry
Savings
Due
to
the
IUR
Revisions
Rule
Based
on
the
information
provided
in
Tables
2­
2,
2­
3,
and
2­
4,
Tables
2­
10
and
2­
11
summarize
the
industry
costs
under
the
IUR
Revisions
Rule
for
organic
and
inorganic
chemicals,

respectively.
The
total
industry
costs
are
summarized
in
Table
2­
12,
while
Table
2­
13
presents
the
estimated
total
burden
hours.
The
total
industry
costs
after
the
IUR
Revisions
Rule
are
estimated
at
$
81.1
million
to
$
105.2
million
for
the
2006
reporting
cycle
and
$
73.3
million
to
$
95.1
million
for
future
reporting
cycles.
The
reporting
burden
is
estimated
at
1,187,000
to
1,535,000
hours
for
the
2006
reporting
cycle
and
1,077,000
to
1,395,000
hours
for
subsequent
reporting
cycles.

Table
2­
10.
Industry
Costs
for
Organic
Chemicals
After
the
IUR
Revisions
Rule
(
2000$)

Unit
of
Analysis
Cost
per
Unit
Number
of
Units
Total
Cost
Low
High
Low
High
2006
Submission
Compliance
Determination
Site
$
65.96
$
263.84
2,482
$
163,710
$
654,839
Rule
Familiarization
Site
$
1,951.66
$
2,274.68
2,482
$
4,844,032
$
5,645,766
Report
Preparation
and
Submission
Report
Partial
Report
$
911.38
$
1,366.70
12,775
$
11,642,915
$
17,459,545
Full
Report
Report
$
5,527.76
$
6,349.26
9,485
$
52,430,786
$
60,222,749
Recordkeeping
Report
$
254.84
$
509.67
22,260
$
5,672,661
$
11,345,322
Total
Cost
after
IUR
Revisions
$
74,754,104
$
95,328,221
Future
Reporting
Cycles
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
Report
Preparation
and
Submission
Partial
Report
Report
$
821.20
$
1,229.93
12,775
$
10,490,883
$
15,712,341
Full
Report
Report
$
4,514.30
$
5,215.98
9,485
$
42,818,178
$
49,473,583
Recordkeeping
Report
$
254.84
$
509.67
22,260
$
5,672,661
$
11,345,322
Total
Cost
after
IUR
Revisions
$
59,947,166
$
77,987,819
The
incremental
costs
of
the
IUR
Revisions
Rule
are
calculated
by
subtracting
the
current
IUR
costs
from
the
estimated
cost
of
the
revised
rule.
Many
of
the
revisions
are
expected
to
have
no
measurable
impact
on
the
costs
of
reporting,
but
provisions
to
extend
the
reporting
cycle
from
four
years
to
five
years
and
to
allow
submitters
to
exclude
exported
volumes
when
reporting
processing
and
use
information
will
result
in
a
considerable
industry
savings.
2­
15
Table
2­
11.
Industry
Costs
for
Inorganic
Chemicals
After
the
IUR
Revisions
Rule
(
2000$)

Unit
of
Analysis
Cost
per
Unit
Number
of
Units
Total
Cost
Low
High
Low
High
2006
Submission
Compliance
Determination
Site
$
65.96
$
263.84
544
$
35,885
$
143,540
Rule
Familiarization
Site
$
1,951.66
$
2,274.68
544
$
1,061,810
$
1,237,550
Report
Preparation
and
Submission
Partial
Report
Report
$
911.38
$
1,366.70
4,537
$
4,134,623
$
6,200,220
Full
Report
Report
$
5,527.76
$
6,349.26
0
0
0
Recordkeeping
Report
$
254.84
$
509.67
4,537
$
1,156,104
$
2,312,207
Total
Cost
after
IUR
Revisions
$
6,388,422
$
9,893,518
Future
Reporting
Cycles
Compliance
Determination
Site
$
65.96
$
263.84
544
$
35,885
$
143,540
Rule
Familiarization
Site
$
323.02
$
323.02
544
$
175,740
$
175,740
Report
Preparation
and
Submission
Partial
Report
Report
$
821.20
$
1,229.93
2,300
$
1,888,980
$
2,829,152
Full
Report
Report
$
4,514.30
$
5,215.98
2,236
$
10,095,752
$
11,664,976
Recordkeeping
Report
$
254.84
$
509.67
4,537
$
1,156,104
$
2,312,207
Total
Cost
after
IUR
Revisions
$
13,352,461
$
17,125,616
Table
2­
12.
Total
Industry
Costs
After
the
IUR
Revisions
Rule
(
million
2000$)

2006
Reporting
Cycle
Total
Cost
Future
Reporting
Cycles
Total
Cost
Low
High
Low
High
Organic
Chemicals
74.8
95.3
59.9
78.0
Inorganic
Chemicals
6.4
9.9
13.4
17.1
Total
Cost
after
IUR
Revisions
81.1
105.2
73.3
95.1
2­
16
Table
2­
13.
Total
Industry
Burden
Hours
After
the
IUR
Revisions
Rule
(
thousands
of
hours)

2006
Reporting
Cycle
Burden
Hours
(
thousands)
Future
Reporting
Cycles
Burden
Hours
(
thousands)

Low
High
Low
High
Organic
Chemicals
1,093,000
1,391,000
881,000
1,144,000
Inorganic
Chemicals
94,000
144,000
196,000
251,000
Total
Burden
after
IUR
Revisions
1,187,000
1,535,000
1,077,000
1,395,000
Source:
U.
S.
Environmental
Protection
Agency.
August
2002.
Economic
Analysis
for
the
Amended
Inventory
Update
Rule,
Final
Report.
Washington,
DC:
Office
of
Pollution
Prevention
and
Toxics,
Economic
and
Policy
Analysis
Branch.

Table
2­
14
calculates
the
savings
due
to
the
IUR
Revisions
Rule
over
a
twenty
year
period.
The
present
value
of
industry
savings
is
expected
to
be
$
83.6
million
to
$
101.9
million
using
a
3
percent
discount
rate
and
$
59.8
million
to
$
72.7
million
with
a
7
percent
discount
rate.

The
annualized
savings
are
$
5.6
million
to
$
6.9
million
per
year
and
$
5.6
million
to
$
6.8
million
per
year
using
3
percent
and
7
percent
discount
rates,
respectively.
2­
17
Table
2­
14.
Flow
of
Industry
Savings
Due
to
IUR
Revisions
Rule
Over
20
Years
(
million
2000$)

Year
Costs
Under
Current
IUR
Costs
After
IUR
Revisions
Rule
Savings
Due
to
IUR
Revisions
Rule
Low
High
Low
High
Low
High
1
$
88.9
$
113.6
$
81.1
$
105.2
$
7.8
$
8.4
2
0.0
0.0
0.0
0.0
0
0
3
0.0
0.0
0.0
0.0
0
0
4
0.0
0.0
0.0
0.0
0
0
5
$
81.0
$
103.4
0.0
0.0
$
81.0
$
103.4
6
0.0
0.0
$
73.3
$
95.1
 
$
73.3
 
$
95.1
7
0.0
0.0
0.0
0.0
0
0
8
0.0
0.0
0.0
0.0
0
0
9
$
81.0
$
103.4
0.0
0.0
$
81.0
$
103.4
10
0.0
0.0
0.0
0.0
0
0
11
0.0
0.0
$
73.3
$
95.1
 
$
73.3
 
$
95.1
12
0.0
0.0
0.0
0.0
0
0
13
$
81.0
$
103.4
0.0
0.0
$
81.0
$
103.4
14
0.0
0.0
0.0
0.0
0
0
15
0.0
0.0
0.0
0.0
0
0
16
0.0
0.0
$
73.3
$
95.1
 
$
73.3
 
$
95.1
17
$
81.0
$
103.4
0.0
0.0
$
81.0
$
103.4
18
0.0
0.0
0.0
0.0
0
0
19
0.0
0.0
0.0
0.0
0
0
20
0.0
0.0
0.0
0.0
0
0
3
Percent
Discount
Rate
Present
Value
$
322.4
$
411.7
$
238.8
$
309.8
$
83.6
$
101.9
Annualized
$
21.7
$
27.7
$
16.1
$
20.8
$
5.6
$
6.9
7
Percent
Discount
Rate
Present
Value
$
244.1
$
311.8
$
184.3
$
239.1
$
59.8
$
72.7
Annualized
$
23.0
$
29.4
$
17.4
$
22.6
$
5.6
$
6.8
2­
18
2.5
EPA
Savings
Due
to
the
IUR
Revisions
Rule
EPA
costs
for
the
IUR
rule
include
costs
attributable
to
systems
development,
document
processing,
contract
oversight
and
management,
and
publication
of
forms
and
materials.
The
Agency
costs
under
the
current
IUR
rule
are
estimated
to
be
$
310,980
in
annual
costs
incurred
in
every
calendar
year,
and
an
additional
$
270,249
in
recurring
costs
incurred
in
each
submission
year,
as
well
as
$
214,763
in
one­
time
costs
related
to
changes
in
the
2003
Amendments
(
assumed
to
be
incurred
for
the
2006
submission
year).
The
economic
analysis
of
the
2003
Amendments
(
EPA,
2002)
provides
more
detailed
information
on
the
estimated
Agency
costs
for
the
IUR
rule.

Extending
the
reporting
cycle
will
result
in
a
lower
present
value
of
Agency
costs
over
time.
Table
2­
15
shows
the
flow
of
Agency
compliance
costs
under
the
current
and
revised
IUR
rule.
For
a
20­
year
period,
the
present
value
of
Agency
costs
is
estimated
to
decline
by
$
197,801
using
a
3
percent
discount
rate
or
$
137,365
using
a
7
percent
discount
rate.
Annualized
Agency
costs
are
reduced
by
$
13,296
and
$
12,966
using
a
3
percent
and
7
percent
discount
rate,

respectively.
2­
19
Table
2­
15.
Flow
of
EPA
Savings
Due
to
the
IUR
Revisions
Rule
Over
20
Years
(
2000$)

Year
Costs
Under
Current
IUR
Costs
After
IUR
Revisions
Rule
Savings
Due
to
IUR
Revisions
Rule
1
$
795,992
$
795,992
0
2
$
310,890
$
310,890
0
3
$
310,890
$
310,890
0
4
$
310,890
$
310,890
0
5
$
581,229
$
310,890
$
270,339
6
$
310,890
$
581,229
­$
270,339
7
$
310,890
$
310,890
0
8
$
310,890
$
310,890
0
9
$
581,229
$
310,890
$
270,339
10
$
310,890
$
310,890
0
11
$
310,890
$
581,229
­$
270,339
12
$
310,890
$
310,890
0
13
$
581,229
$
310,890
$
270,339
14
$
310,890
$
310,890
0
15
$
310,890
$
310,890
0
16
$
310,890
$
581,229
­$
270,339
17
$
581,229
$
310,890
$
270,339
18
$
310,890
$
310,890
0
19
$
310,890
$
310,890
0
20
$
310,890
$
310,890
0
3
Percent
Discount
Rate
Present
Value
$
5,885,257
$
5,687,456
$
197,801
Annualized
$
395,582
$
382,286
$
13,296
7
Percent
Discount
Rate
Present
Value
$
4,285,188
$
4,147,823
$
137,365
Annualized
$
404,491
$
391,525
$
12,966
2.6
Total
Savings
Due
to
the
IUR
Revisions
Rule
As
shown
in
Table
2­
16,
combining
the
incremental
industry
and
EPA
savings
due
to
the
IUR
Revisions
rule
results
in
an
estimate
that
the
present
value
of
savings
over
the
next
20
years
will
be
between
$
83.8
million
and
$
102.1
million
using
a
3
percent
discount
rate.
For
a
7
percent
discount
rate,
the
estimated
savings
are
$
59.9
million
to
$
72.8
million.
Annualized
savings
are
$
5.7
million
to
$
6.9
million
per
year
with
a
3
percent
discount
rate
and
$
5.6
million
to
$
6.8
million
per
year
using
a
7
percent
discount
rate.
Reporting
burden,
summarized
in
Table
2­
17,
is
estimated
to
fall
by
113,000
to
123,000
hours
in
the
2006
reporting
cycle
and
112,000
to
121,000
hours
in
subsequent
reporting
cycles.
2­
20
Table
2­
16.
Total
Savings
Due
to
the
IUR
Revisions
Rule
(
million
2000$)

Industry
EPA
Total
Low
High
Low
High
3
Percent
Discount
Rate
Present
Valuea
$
83.6
$
101.9
$
0.2
$
83.8
$
102.1
Annualized
$
5.6
$
6.9
$
0.01
$
5.7
$
6.9
7
Percent
Discount
Rate
Present
Valuea
$
59.8
$
72.7
$
0.2
$
59.9
$
72.8
Annualized
$
5.6
$
6.8
$
0.01
$
5.6
$
6.8
a
NPV
determined
for
a
20­
year
period.

Numbers
do
not
add
due
to
rounding.

Table
2­
17.
Burden
Savings
Due
to
the
IUR
Revisions
Rule
(
thousands
of
hours)

2006
Reporting
Cycle
Burden
Hours
(
thousands)
Future
Reporting
Cycles
Burden
Hours
(
thousands)

Low
High
Low
High
Current
IUR
1,300
1,658
1,189
1,516
After
IUR
Revisions
Rule
1,187
1,535
1,077
1,395
Burden
Savings
Due
to
IUR
Revisions
Rule
113
123
112
121
3­
1
CHAPTER
3
IMPACT
OF
THE
IUR
REVISIONS
RULE
ON
THE
BENEFITS
OF
THE
IUR
RULE
The
IUR
rule
is
one
of
EPA's
most
important
tools
for
meeting
its
mandate
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.
The
IUR
rule
requires
the
collection
and
compilation
of
manufacturing,

processing
and
use
exposure­
related
information,
which
allows
EPA
to
more
accurately
assess
human
and
ecosystem
exposures
to
specific
chemicals,
including
the
concentrations,
frequency,

and
durations
of
these
exposures.
With
this
information,
EPA
is
better
able
to
screen
chemicals
to
identify
whether
additional
risk
assessment
and
management
steps
are
needed.
The
IUR
enhances
the
data
supplied
to
EPA's
risk­
screening
programs,
which
enables
EPA
to
more
effectively
and
expeditiously
reduce
the
risks
posed
by
chemicals.
Enhancing
the
risk­
screening
process
has
positive
consequences
for
human
and
ecosystem
health
and
promotes
more
efficient
use
of
EPA's
and
society's
resources.
Although
the
social
benefits
resulting
from
the
IUR
rule
can
extend
to
many
facets
of
society,
quantitative
estimates
of
these
benefits
are
not
feasible
because
of
data
limitations.

The
IUR
Revisions
Rule
will
decrease
the
benefits
associated
with
IUR
data
somewhat
by
reducing
the
frequency
of
data
collection
after
2006
and
providing
partial
exemptions
to
additional
petroleum
process
streams.
Extending
the
reporting
cycle
from
four
years
to
five
years
will
delay
the
availability
of
updated
data
on
IUR
chemicals,
thereby
reducing
the
present
value
of
the
benefits
of
the
IUR
rule
somewhat.
However,
EPA
has
determined
that
a
five­
year
reporting
cycle
will
provide
sufficient
data
to
meet
the
most
critical
information
needs.
The
impact
of
exempting
additional
petroleum
processes
is
expected
to
be
minimal
because
these
chemical
substances
have
accounted
for
an
extremely
small
number
of
IUR
submissions
in
the
last
few
reporting
cycles
(
an
average
of
10
reports
total
per
reporting
cycle).
Moving
the
submission
period
forward
will
have
a
small
positive
impact
in
that
EPA
will
have
more
timely
access
to
the
data.
None
of
the
other
changes
will
have
an
impact
on
the
benefits
of
the
data.
4­
1
CHAPTER
4
BENEFIT­
COST
ANALYSIS
Table
4­
1
summarizes
the
changes
in
information
obtained
and
costs
incurred
under
the
IUR
Revisions
Rule.
It
is
estimated
that
approximately
26,800
forms
will
be
submitted
in
each
reporting
cycle
under
both
the
current
and
revised
IUR
rule.
In
the
next
submission
period
(
scheduled
to
occur
in
2006
under
both
the
current
and
revised
IUR
rule),
about
9,500
(
35
percent)
will
be
full
forms
including
both
site
and
manufacturing
and
use
and
exposure
data.
The
information
provided
in
the
IUR
forms
can
enhance
social
welfare
by
improving
the
foundation
for
public
and
private
decision­
making
related
to
risk
management
and
by
reducing
the
cost
of
obtaining
information
to
support
these
decisions
from
other
sources
(
EPA,
2002).
The
roughly
17,300
remaining
forms
(
65
percent)
will
be
partial
forms
reporting
only
site
and
manufacturing
data.
The
proportion
of
full
forms
rises
in
future
reporting
cycles
as
inorganic
chemicals
become
fully
reportable.
Once
again,
the
number
of
reports
received
and
the
allocation
between
partial
and
full
reports
is
expected
to
be
very
similar
under
the
current
and
revised
IUR
rules.
In
future
cycles,
about
11,700
reports
(
44
percent)
are
expected
to
be
full
reports
and
approximately
15,100
(
56
percent)
will
be
partial
reports.
Based
on
data
from
recent
reporting
years,
the
addition
of
25
petroleum
process
streams
to
the
partial
exemption
list
under
the
IUR
Revisions
Rule
will
only
result
in
a
reduction
of
about
10
full
reports
per
submission
period.
In
addition,

submitters
would
no
longer
be
required
to
submit
processing
and
use
information
on
exported
chemicals,
but
that
was
not
a
priority
area
of
information
for
EPA.

A
key
difference
between
the
current
IUR
rule
and
the
IUR
Revisions
Rule
is
that
reports
will
be
received
less
frequently
(
after
the
2006
submission)
under
the
revisions.
To
the
extent
that
relevant
information
on
these
chemicals
is
changing
substantially
over
time,
this
delay
in
receiving
the
data
will
reduce
the
benefits
of
the
IUR
rule.
The
more
stable
the
data
are
over
time,
the
smaller
the
potential
reduction
in
benefits
from
extending
the
reporting
cycle.

The
annualized
savings
of
the
IUR
Revisions
Rule
are
estimated
to
be
from
$
5.7
million
to
$
6.9
million
per
year
over
the
first
20
years
of
the
rule
using
a
3
percent
discount
rate
and
$
5.6
million
to
$
6.8
million
based
on
a
7
percent
discount
rate.
Almost
all
of
the
savings
accrue
to
companies
submitting
reports
under
the
IUR
rule.
The
remainder
(
approximately
$
13,000
per
year,

annualized
using
a
3
percent
discount
rate)
is
a
reduction
in
EPA's
cost
to
periodically
administer
the
data
collection.
4­
2
As
indicated
throughout
this
report,
the
reductions
in
benefits
associated
with
the
revisions
to
the
IUR
rule
are
difficult
to
quantify
and
monetize.
The
inability
to
monetize
the
change
in
benefits
impedes
direct
comparison
to
costs
and
calculation
of
net
benefits.
Nonetheless,
EPA
believes
that
these
revisions
significantly
lower
the
costs
of
compliance
without
substantially
diminishing
the
amount
and
quality
of
information
for
risk
screening,
prioritization,
and
management.
Table
4­
1.
Benefits
and
Costs
of
the
IUR
Revisions
Rule
Number
of
Reports
Filed
2006
Reporting
Cycle
Future
Reporting
Cycles
Total
Partial
Full
Total
Partial
Full
Current
IUR
rule
26,797
17,302
9,495
26,797
15,065
11,731
IUR
Revisions
Rule
26,797
17,312
9,485
26,797
15,075
11,721
Reduction
in
Information
Available
Ten
fewer
full
reports
for
petroleum
process
streams
are
expected
because
of
new
chemical
substances
being
added
to
partial
exemption
list.
Processing
and
use
information
is
no
longer
reported
for
exported
chemical
substances.

In
future
reporting
cycles,
the
information
is
received
less
frequently.
To
the
extent
that
valuable
information
is
changing
substantially
between
reporting
years,
this
delay
in
receiving
information
will
tend
to
reduce
the
benefits
of
the
IUR.

Annualized
Savings
(
2000$)

Industry
EPA
Total
Low
High
Low
High
3
Percent
Discount
Rate
$
5.6
million
$
6.9
million
$
0.01
million
$
5.7
million
$
6.9
million
7
Percent
Discount
Rate
$
5.6
million
$
6.8
million
$
0.01
million
$
5.6
million
$
6.8
million
5­
1
CHAPTER
5
SMALL
ENTITY
AND
ENVIRONMENTAL
JUSTICE
IMPACT
DETERMINATIONS
The
Regulatory
Flexibility
Act
of
1980
requires
federal
agencies
to
assess
the
effects
of
regulations
on
small
entities
(
P.
L.
96­
354).
(
The
Act
was
later
amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
[
SBREFA]
of
1996.)
The
Act
requires
agencies
to
evaluate
rulemakings
to
determine
if
an
Initial
Regulatory
Flexibility
Analysis
(
IRFA)
or
Final
Regulatory
Flexibility
Analysis
(
FRFA)
is
necessary.
This
section
examines
whether
such
an
analysis
is
needed
for
this
rulemaking.

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
also
examines
the
effect
of
the
revisions
to
the
IUR
on
minority
and
low­
income
populations.

5.1
Small
Entity
Analysis
The
term
"
small
entities"
includes
small
businesses,
small
not­
for­
profit
organizations,
and
small
governmental
jurisdictions,
but
because
not­
for­
profit
organizations
and
governmental
jurisdictions
will
not
be
affected
by
this
rule,
"
small
entity"
in
this
analysis
is
synonymous
with
small
business.
Sections
603
and
604
of
the
Regulatory
Flexibility
Act
require
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
or
FRFA.
These
revisions
are
expected
to
reduce
the
present
value
and
annualized
cost
of
the
IUR
for
small
businesses.
Thus,
EPA
concludes
that
these
revisions
will
not
result
in
significant
adverse
effects
on
a
substantial
number
of
small
entities,
and
that
no
screening
analysis
or
IRFA
is
required.
The
basis
for
determining
that
there
is
no
significant
economic
impact
is
explained
below.

Only
rules
that
will
have
a
significant
adverse
economic
impact
on
small
entities
require
an
IRFA
and
FRFA,
because
the
primary
purpose
of
both
analyses
is
to
identify
and
address
regulatory
alternatives
"
which
minimize
any
significant
economic
impact
of
the
proposed
[
or
final]
rule
on
small
entities"
(
5
CFR
603
and
604).
Thus,
rules
that
relieve
regulatory
burden,
or
otherwise
have
a
positive
economic
effect
on
the
small
entities
subject
to
the
rule,
do
not
require
an
IRFA
or
a
FRFA.
Because
the
purpose
of
a
screening
analysis
is
to
determine
if
an
IRFA
or
FRFA
is
needed,
a
screening
analysis
is
also
not
required
for
burden
reduction
rules.
This
rulemaking
5­
2
reduces
regulatory
burden
and
has
a
positive
economic
effect
on
small
entities,
so
no
small
entity
analysis
is
needed
to
comply
with
the
Regulatory
Flexibility
Act.

5.2
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
rule
is
an
information
collection
exercise,
the
information
that
will
become
available
through
the
rule
will
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
rule
will
help
EPA
make
decisions
that
will
benefit
potentially
at­
risk
communities,
some
of
which
may
be
disadvantaged.
Extending
the
reporting
frequency
after
2006
will
reduce
the
availability
of
this
valuable
information
somewhat.
However,
EPA
expects
that
it
will
continue
to
meet
its
most
critical
data
needs
and
that
any
reductions
in
benefits
relative
to
the
current
IUR
rule
will
be
minimal.
R­
1
REFERENCES
American
Chemistry
Council
(
ACC).
2003.
"
Guide
to
the
Business
of
Chemistry
2003."

Arlington,
VA.

American
Petroleum
Institute
(
API).
1983.
"
Petroleum
Process
Stream
Terms
Included
in
the
Chemical
Substance
Inventory
Under
the
Toxic
Substances
Control
Act
(
TSCA)."

Washington,
DC.

Bureau
of
Labor
Statistics
(
BLS).
2000.
Employment
Cost
Index.
<
www.
bls.
gov>.
As
obtained
April
28,
2000.

Chemical
Update
System
(
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.

Federal
Register.
December
23,
1977.
42
FR
64572.

Federal
Register.
June
12,
1986.
51
FR
21447.

Federal
Register.
January
7,
2003.
68
FR
848.

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

U.
S.
Environmental
Protection
Agency.
1997b.
UEIP­
ICR
Database.
Summary
table.

U.
S.
Environmental
Protection
Agency.
August
2002.
Economic
Analysis
for
the
Amended
Inventory
Update
Rule,
Final
Report.
Washington,
DC:
Office
of
Pollution
Prevention
and
Toxics,
Economic
and
Policy
Analysis
Branch.
A­
1
FOR
EPA
USE
ONLY
Report
Number
Mark
"
X"
here
if
this
is
a
revision
to
the
previous
report
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
Site
Report
(
Section
8(
a)
Toxic
Substances
Control
Act,
15
U.
S.
C.
2607(
a))

CERTIFICATION
Certification
Statement:
I
hereby
certify
to
the
best
of
my
knowledge
and
belief
that
Parts
I
and
II
have
been
completed
in
compliance
with
the
requirements
of
40
CFR
710.52(
c)(
1),
(
2),
and
(
3);
Part
III
of
this
form
has
been
completed
in
compliance
with
the
requirements
of
40
CFR
710.52(
c)(
4);
and
the
confidentiality
statements
at
the
end
of
this
form
are
true
and
correct
as
to
that
information
for
which
a
confidentiality
claim
has
been
asserted.

Signature
Date
signed
Name
(
printed)
Official
Title
PART
I.
SITE
IDENTIFICATION
INFORMATION
SECTION
A.
COMPANY
INFORMATION*

1.
A.
1
Company
Name
1.
A.
2
Company
Dun
&
Bradstreet
Number
SECTION
B.
SITE
INFORMATION*

1.
B.
1
Site
Name
1.
B.
2
Site
Dun
&
Bradstreet
Number
EPA
Facility
Identification
Number
LEAVE
BLANK
1.
B.
3
Street
Address
(
Line
1)

1.
B.
4
Street
Address
(
Line
2)

1.
B.
5
City
1.
B.
6
County
/
Parish
1.
B.
7
State
1.
B.
8
Zip
Code
SECTION
C.
TECHNICAL
CONTACT
INFORMATION*

1.
C.
1
Name
1.
C.
2
Telephone
1.
C.
3
Email
Address
1.
C.
4
Mailing
Address
(
Line
1)

1.
C.
5
Mailing
Address
(
Line
2)

1.
C.
6
City
1.
C.
7
State
1.
C.
8
Zip
Code
*
Confidentiality
claims
for
information
in
Part
I,
Sections
A,
B,
and
C,
are
made
for
each
chemical
substance
on
subsequent
pages.
EPA
Form
Number
<
XXXX­
X>
(
Rev
03/
31/
05)
­
Previous
editions
are
obsolete
FORM
U
2006
A­
2
Form
Approved
OMG
Number
:
XX/
X­
XXXX
A­
3
Page
___
of
___

PART
II.
MANUFACTURING
INFORMATION
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI

2.
A.
1
Chemical
Identifying
Number
2.
A.
2
ID
Code
2.
A.
3
Chemical
Name
SECTION
B.
MANUFACTURING
INFORMATION
CBI
a.
Physical
Form
b.
Percent
of
Production
2.
B.
1
Company
Information
Volume
in
Each
Physical
Form
2.
B.
2
Site
Information

Check
All
2.
B.
3
Technical
Contact
Information
That
Apply
CBI
Percent
CBI
2.
B.
4
Site
Limited
(
Y/
N)
2.
B.
10
Dry
Powder
2.
B.
5
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
11
Pellets
or
Large
Crystals
2.
B.
6
Manufactured
Production
Volume
(
LB)
2.
B.
12
Water
or
Solvent
Wet
Solid
2.
B.
7
Imported
Production
Volume
(
LB)
2.
B.
13
Other
Solid
2.
B.
8
Number
of
Workers
(
code)
2.
B.
14
Gas
or
Vapor
2.
B.
9
Maximum
Concentration
(
code)
2.
B.
15
Liquid
PART
III.
PROCESSING
AND
USE
INFORMATION
Complete
Part
III,
Sections
A
and
B
if
the
sum
of
the
production
volumes
noted
in
Blocks
2.
B.
6
and
2.
B.
7
is
300,000
pounds
or
more.

SECTION
A.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
Code
c.
Industrial
Function
Category
d.
Percent
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Percent
CBI
Code
CBI
Code
CBI
3.
A.
1
3.
A.
2
3.
A.
3
3.
A.
4
3.
A.
5
3.
A.
6
3.
A.
7
3.
A.
8
3.
A.
9
3.
A.
10
SECTION
B.
COMMERCIAL
AND
CONSUMER
USE
DATA
N/
A
a.
Commercial
and
Consumer
Product
Category
b.
Used
in
Products
Intended
for
Children
c.
Percent
Production
Volume
associated
with
each
category
d.
Maximum
Concentration
associated
with
each
category
Code
CBI
Y/
N/
NRO
CBI
Percent
CBI
Code
CBI
3.
B.
1
3.
B.
2
3.
B.
3
3.
B.
4
3.
B.
5
3.
B.
6
3.
B.
7
3.
B.
8
3.
B.
9
3.
B.
10

Substantiation
required
for
CBI
claims
on
chemical
identity
and
site
information.
FOR
EPA
USE
ONLY
