1
TRI
Burden
Reduction
Analytic
Methods
and
Preliminary
Results
October
19,
2004
Paul
A.
Borst
202­
566­
2284
Borst.
Paul@
epa.
gov
2
2002
Baseline
Burden
°
Baseline
burden
refers
to
the
starting
point
you
are
using
to
compare
against
the
change
resulting
from
rulemaking.

°
2002
baseline
burden
for
Form
R
is
approximately
3.8
million
hours.

°
2002
baseline
burden
for
Form
A
is
approximately
260,000
hours
3
°
In
contrast
to
modifications
to
Form
R
itself,

the
Program
Related
burden
reduction
options
center
on
raising
reporting
thresholds,

expanding
eligibility
for
Form
A
or
a
simplified
form,
instead
of
filling
out
Form
R
itself.

°
The
trade
off
to
society
presented
by
this
type
of
burden
reduction
are
the
burden
hours
saved
by
not
filling
out
Form
R
balanced
against
any
lost
data
of
lbs.
toxic
chemicals
not
reported.

TRI
Program
Related
Options
4
TRI
Program
Related
Options
°
Part
of
evaluating
the
trade­
off
can
include
consideration
of
specific
groups
of
filers
and
chemicals
as
well
as
end
users
of
data.

 
Examples
for
filers
could
include,
small
businesses,

zero
releasers,
and
filers
who
only
recycle
 
Examples
of
chemicals
could
include
TRI
chemicals
in
nondispersible
form
(
e.
g.,
metal
alloys),
VOCs
that
are
oxidants
only.

 
Examples
of
specific
end
users
of
data
include
community
leaders,
environmental
groups,
and
state
governments.
5
Option
1,
Small
Businesses
°
Small
businesses
(<
50
employees
per
facility)

°
This
option
could
vary
according
to
small
business
definition
and
threshold
°
The
range
of
facility
size
could
be
between
10
and
100
employees
per
facility
6
Option
2,
Raising
thresholds
for
classes
of
chemicals/
facilities
°
Would
raise
thresholds
for
specific
categories
of
facilities
or
chemicals
°
One
variant
of
this
option
pertains
to
zero
releasers,
defined
as
facilities
that
do
not
release
TRI
chemicals
either
onsite
or
offsite.

°
Zero
releasers
manage
TRI
chemicals
through
recycling,
energy
recovery
or
treatment
for
destruction.

°
Simplified
reporting
form
for
those
who
only
recycle.
7
Zero
Releaser
Demographics
°
5300
facilities
°
8500
Form
Rs
°
Over
300
million
lbs
of
TRI
chemicals
recycled,

burned
for
energy
recovery
or
treated.

°
Among
recycling
zero
releasers,
metal
recovery
(
lead,
copper,
manganese,
chromium,
nickel)

was
dominant.

°
Among
treatment,
acid
neutralization
for
sulfuric,
nitric,
formic
acids
were
dominant.
8
Option
3,
Expanding
eligibility
for
Form
A
°
Modeling
assuming
a
500
lbs
limit
on
annual
reportable
amount
but
removed
recycling
&
energy
recovery
from
annual
reportable
amount
(
ARA).

°
A
variant
of
this
option
would
be
to
increase
the
threshold
on
the
ARA
or
both
remove
data
fields
from
the
ARA
and
increase
the
threshold.
9
Option
4,
No
Significant
Change
°
3
parameters
analyzed:

 
production
ratio
(
Section
8.9)

 
total
releases
(
Section
8.1)

 
total
production
related
wastes
(
Section
8.1­

8.8)

°
Range
of
0
to
15
percent
used
to
model.

°
Variant
using
range
codes
instead
of
3
parameters
is
currently
under
consideration.
10
Option
5,
Range
Reporting
in
Section
8
of
Form
R
°
No
preliminary
analysis
at
this
time
°
Future
analysis
to
focus
on
burden
savings,
if
any
and
an
Option
4
variant
11
Range
Reporter
Demographics
°
Between
1991
and
2002,
43
to
53
%
of
all
Form
R's
submitted
were
eligible
to
use
current
range
codes
in
sections
5
and
6,
respectively.

°
Despite
this
fact,
actual
range
reporting
averaged
only
between
21
and
37
%
over
the
same
period.

°
One
possible
reason
range
codes
are
not
used
more
widely
is
that
`
range'
codes
are
not
currently
allowed
in
Section
8,
possibly
forcing
the
Form
R
filer
to
estimate
`
precise'
weight.
This
may
deter
users
from
submitting
a
range
code
in
Section
5
and
6
since
the
weight
would
already
be
required
in
Section
8.
12
Ongoing
Analysis
°
Disaggregated
chemical
specific
data
loss
for
Options
1,
3
and
4.

°
Correlational
analysis
for
production
ratio,
total
releases,
and
total
production
related
waste
for
Option
4.

°
Option
5,
Range
reporting
variant
for
Option
4.
