3­
1
September
19,
2005
CHAPTER
THREE
TOTAL
BURDEN
AND
COST
SAVINGS
This
chapter
presents
the
total
burden
and
cost
savings
associated
with
the
proposed
Phase
2
burden
reduction
rule.
Following
the
methodology
presented
in
Chapter
Two,
unit
burden
and
cost
savings
as
well
the
number
of
affected
facilities
and
forms
were
derived.
The
unit
burden
and
cost
savings
information
is
then
combined
with
the
number
of
affected
facilities
and
forms
to
estimate
total
burden
and
cost
savings.

Table
3­
1
shows
the
national
burden
and
cost
saving
estimates
for
first
and
subsequent
year
reporters.
The
table
shows
an
estimated
total
potential
burden
savings
of
164,432
hours
and
total
cost
savings
of
$
7,381,022
as
a
result
of
the
proposed
rule.
National
burden
and
cost
saving
estimates
associated
with
alternate
Form
A
thresholds
of
500,
1,000,
and
2,000
pound
are
presented
in
Tables
B­
1
through
B­
3
in
Appendix
B.

Tables
3­
2
and
3­
3
shows
the
average
burden
savings
and
average
cost
savings
per
form
and
facility,
respectively.
Table
3­
2
shows
an
estimated
average
annual
burden
savings
per
form
of
approximately11
hours
and
an
average
cost
savings
per
form
of
approximately
$
500
annually.
Table
3­
3
shows
an
estimated
average
annual
burden
savings
per
facility
of
approximately
21
hours
and
an
estimated
average
cost
savings
per
facility
of
approximately
$
900
annually.
See
Appendix
B,
Tables
B­
4
through
B­
9
for
average
burden
savings
and
average
cost
savings
per
form
and
facility
for
the
500,
1,000,
and
2,000
pound
thresholds.

TABLE
3­
1
ANNUAL
BURDEN
AND
COST
SAVINGS
New
Eligibility
for
Form
A:
PBT
Chemicals
Option
Expanded
Eligibility
for
Form
A:
Non­
PBT
Chemicals
Optiona
Combined
Options
Number
of
Affected
Facilities
2,064
6,461
7,958
Number
of
Affected
Forms
2,703
12,201
14,904
Average
Annual
Burden
Savings
in
the
First
and
Subsequent
Years
of
the
Proposed
Rule
(
Hours)

Form
Completion
­
non­
PBT
chemicals
N/
A
92,728
92,728
Form
Completion
­
PBT
chemicals
41,897
N/
A
41,897
Recordkeeping/
Mailing
5,406
24,402
29,808
Total
47,303
117,130
164,432
Average
Annual
Cost
Savings
in
the
First
and
Subsequent
Years
of
the
Proposed
Rule
Form
Completion
­
non­
PBT
chemicals
N/
A
$
4,254,983
$
4,254,983
Form
Completion
­
PBT
chemicals
$
1,917,146
N/
A
$
1,917,146
Recordkeeping/
Mailing
$
219,246
$
989,648
$
1,208,893
Total
$
2,136,392
$
5,244,630
$
7,381,022
a
The
number
of
affected
facilities
and
forms
in
this
analysis
does
not
include
the
non­
PBT
Form
Rs
that
are
currently
likely
eligible
for
Form
A
based
on
an
ARA
of
less
than
or
equal
to
500
pounds.

The
number
of
facilities
cannot
be
summed
across
form
types
because
some
facilities
filed
both
PBT
and
non­
PBT
forms.

Source:
Frozen
RY2002
TRI
data
and
Wage
Rates
from
the
U.
S.
Department
of
Labor
(
see
Chapter
2).
3­
2
September
19,
2005
TABLE
3­
2
ANNUAL
BURDEN
AND
COST
SAVINGS
PER
FORM
Option
Number
of
Forms
Total
Burden
Savings
(
Hours)
Total
Burden
Savings
per
Form
(
Hours)
Total
Cost
Savings
Average
Cost
Savings
per
Form
New
Eligibility
for
Form
A:
PBT
Chemicals
Option
2,703
47,303
17.5
$
2,136,392
$
790
Expanded
Eligibility
for
Form
A:
Non­
PBT
Chemicals
Optiona
12,201
117,130
9.6
$
5,244,630
$
430
Combined
Options
14,904
164,432
11.0
$
7,381,022
$
495
a
The
number
of
affected
non­
PBT
forms
in
this
analysis
does
not
include
the
non­
PBT
Form
Rs
that
are
currently
likely
eligible
for
Form
A
based
on
an
ARA
of
less
than
or
equal
to
500
pounds.

Source:
Frozen
RY2002
TRI
data
and
Wage
Rates
from
the
U.
S.
Department
of
Labor
(
see
Chapter
2).

TABLE
3­
3
ANNUAL
BURDEN
AND
COST
SAVINGS
PER
FACILITY
Option
Number
of
Facilities
Total
Burden
Savings
(
Hours)
Total
Burden
Savings
per
Facility
(
Hours)
Total
Cost
Savings
Average
Cost
Savings
per
Facility
New
Eligibility
for
Form
A:
PBT
Chemicals
Option
2,064
47,303
22.9
$
2,136,392
$
1,035
Expanded
Eligibility
for
Form
A:
Non­
PBT
Chemicals
Optiona
6,461
117,130
18.1
$
5,244,630
$
812
Combined
Options
7,958
164,432
20.7
$
7,381,022
$
927
a
The
number
of
affected
facilities
in
this
analysis
does
not
include
the
non­
PBT
Form
Rs
that
are
currently
likely
eligible
for
Form
A
based
on
an
ARA
of
less
than
or
equal
to
500
pounds.

Source:
Frozen
RY2002
TRI
data
and
Wage
Rates
from
the
U.
S.
Department
of
Labor
(
see
Chapter
2).
