  SEQ CHAPTER \h \r 1 CHAPTER THREE

TOTAL BURDEN AND COST SAVINGS

	This chapter presents the total burden and cost savings associated with
the 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 123,404 hours and total cost savings of
$5,925,208 as a result of the rule.  

Tables 3-2 and 3-3 show 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 approximately 10
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 19 hours and an estimated average cost
savings per facility of approximately $890 annually. 

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	1,796	5,317	6,670

Number of Affected Forms	2,360	9,501	11,861

Average Annual Burden Savings in the First and Subsequent Years of the
Rule (Hours)

Form Completion - non-PBT chemicals	N/A	67,922	67,922

Form Completion - PBT chemicals	31,760	N/A	31,760

Recordkeeping/Mailing 	4,720	19,002	23,722

Total	36,480	86,924	123,404

Average Annual Cost Savings in the First and Subsequent Years of the
Rule

Form Completion - non-PBT chemicals	N/A	$3,335,628	$3,335,628

Form Completion - PBT chemicals	$1,560,140	N/A	$1,560,140

Recordkeeping/Mailing 	$204,829	$824,611	$1,029,440

Total	$1,764,969	$4,160,239	$5,925,208

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 RY2004 TRI data and Wage Rates from the U.S. Department
of Labor (see Chapter 2).



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	2,360	36,480	15.5
$1,764,969 	$748 

Expanded Eligibility for Form A: Non-PBT Chemicals Optiona	9,501	86,924
9.1	$4,160,239 	$438 

Combined Options	11,861	123,404	10.4	$5,925,208 	$500 

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 RY2004 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	1,796	36,480	20.3
$1,764,969 	$983 

Expanded Eligibility for Form A: Non-PBT Chemicals Optiona	5,317	86,924
16.3	$4,160,239 	$782 

Combined Options	6,670	123,404	18.5	$5,925,208 	$888 

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



***September 22, 2006***

