Economic Analysis of the Proposed Rule to add 1-

Bromopropane to the EPCRA Section 313

List of Toxic Chemicals

February 17, 2015

Prepared by Abt Associates for:

Analytical Support Branch

Environmental Analysis Division

Office of Information Analysis and Access

Office of Environmental Information

US Environmental Protection Agency
CONTENTS

Economic Analysis of the Proposed Addition of 1-Bromopropane ▌pg. i

ES. Executive Summary............................................................................................................... iii

ES.1 Introduction.................................................................................................................... iii

ES.2 Need for Rule ................................................................................................................. iii

ES.3 Addition of 1-Bromopropane......................................................................................... iii

ES.4 Estimated Reporting Activity......................................................................................... iii

ES.5 Costs of the Proposed Rule .............................................................................................iv

ES.5.1 Industry Costs ....................................................................................................iv

ES.5.2 EPA Costs...........................................................................................................v

ES.5.3 Total Costs..........................................................................................................v

ES.6 Small Entity Analysis.......................................................................................................v

ES.7 Benefits of the Proposed Rule....................................................................................... vii

1. Background and Overview of Analysis.............................................................................. 1-1

1.1 Overview of TRI.......................................................................................................... 1-1

1.1.1 Pollution Prevention Act................................................................................. 1-3

1.1.2 Changes to the List of Chemicals.................................................................... 1-3

1.1.3 Alternate Threshold......................................................................................... 1-3

1.1.4 Executive Order 12856 ................................................................................... 1-4

1.1.5 Changes to the List of Industries..................................................................... 1-4

1.1.6 Changes for Chemicals that are Persistent, Bioaccumulative, and Toxic ....... 1-4

1.1.7 Toxic Chemical Release Reporting Using North American Industry 

Classification System (NAICS) Rule.............................................................. 1-4

1.1.8 TRI Dioxin and Dioxin-like Compounds Toxic Equivalency (TEQ) 

Information Rule............................................................................................. 1-5

1.2 Addition of 1-Bromopropane to EPCRA Section 313 Reporting Requirements......... 1-5

1.3 Organization of This Report......................................................................................... 1-5

2. Estimates of the Number of Reports and Affected Facilities........................................... 2-1

2.1 Background .................................................................................................................. 2-1

2.2 Methodology ................................................................................................................ 2-2

2.2.1 Identifying Actual Facilities............................................................................ 2-3

2.2.2 Proxy Methods................................................................................................ 2-4

2.2.3 Form As......................................................................................................... 2-10

2.2.4 Existing Filers and First Time Filers............................................................. 2-10

2.3 Summary .................................................................................................................... 2-11

3. Cost Estimates...................................................................................................................... 3-1

3.1 Industry Burden and Cost Estimates............................................................................ 3-1

3.1.1 Estimation of Burden ...................................................................................... 3-1
CONTENTS

Economic Analysis of the Proposed Addition of 1-Bromopropane ▌pg. ii

3.1.2 Estimation of Cost........................................................................................... 3-3

3.1.3 Total Industry Burden Estimates..................................................................... 3-5

3.1.4 Total Industry Cost Estimates......................................................................... 3-7

3.1.5 Annualized Cost Estimates ............................................................................. 3-9

3.2 EPA Cost Estimates................................................................................................... 3-11

3.3 Total Costs ................................................................................................................. 3-12

4. Small Entity Analysis........................................................................................................... 4-1

4.1 Impact on Small Entities.............................................................................................. 4-1

4.2 Definitions of Small Entities........................................................................................ 4-1

4.3 Methodology Overview ............................................................................................... 4-2

4.3.1 Small Entity Impacts for Known Facilities..................................................... 4-4

4.3.2 Small Entity Impacts Analyzed using Census Data ........................................ 4-5

4.4 Summary of Impacts to Small Parent Entities ............................................................. 4-9

5. Benefits.................................................................................................................................. 5-1

6. References............................................................................................................................. 6-1
EXECUTIVE SUMMARY

Economic Analysis of the Proposed Addition of 1-Bromopropane ▌pg. iii

ES. Executive Summary

ES.1 Introduction

Under section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), and section 

6607 of the Pollution Prevention Act (PPA), certain facilities are required to file annual reports to the 

United States Environmental Protection Agency (EPA) and to states or Indian Country officials on their 

releases, transfers, and other waste management practices for certain toxic chemicals if they are 

manufactured, processed, or otherwise used above certain threshold amounts. This information is 

included in a publicly available database known as the Toxic Release Inventory (TRI).

Currently, there are 594 chemicals and 31 chemical categories on the list of chemicals subject to EPCRA 

section 313 requirements. EPCRA section 313(d) authorizes EPA to add chemicals to the list of 

reportable substances. Under the proposed rule, EPA adds 1-Bromopropane (1-BP) to the list of

individual chemicals subject to EPCRA section 313 reporting requirements.

ES.2 Need for Rule

EPA believes that 1-BP meets the EPCRA section 313(d)(2)(B) criteria for listing because it is considered

to be a human carcinogen. The classification is based on sufficient evidence of carcinogenicity in 

experimental animals and supporting data on mechanisms of carcinogenesis. Further, EPA believes that 

facilities currently manufacture, process, or otherwise use this chemical above TRI thresholds and 

therefore will file TRI reports based on the analysis presented in this document.

ES.3 Addition of 1-Bromopropane

1-BP is a short chain, brominated, alkyl molecule, which is a colorless liquid under standard conditions. 

Human exposure by inhalation or skin contact can lead to irritation and neurologic effects such as 

headaches, dizziness, slurred speech or loss of consciousness. In addition, studies with animal subjects 

have linked 1-BP to certain cancers, as well as toxicity in the liver, reproductive system, and nervous 

system (National Institute of Health and Safety, OSHA, 2014).

The halogenated alkane properties of 1-BP make it an ideal organic solvent. In industry, the main uses of 

1-BP are as an aerosol solvent in asphalt, aircraft, and synthetic fiber manufacturing, as a vapor and 

immersion degreaser in metals, metal products, plastics, optics, and electronics manufacturing, and as a 

cleaning solvent for dry cleaning. In addition, 1-BP can be used as an adhesive in laminates and foam 

products, and as a chemical intermediate in pharmaceuticals, pesticides, quaternary ammonium 

compounds, flavors, and fragrances.

ES.4 Estimated Reporting Activity

The number of additional TRI reports expected due to the proposed rule is summarized in Table ES-1: 

Total Estimated Forms and Facilities.

Table ES-1: Total Estimated Forms and Facilities

Facilities Form Rs Form As

140 126 14
EXECUTIVE SUMMARY

Economic Analysis of the Proposed Addition of 1-Bromopropane ▌pg. iv

ES.5 Costs of the Proposed Rule

The proposed rule will result in associated costs to both industry and EPA. Affected facilities will spend 

time reporting the required information to EPA on Form R or Form A. The Agency will spend time 

processing new forms.

ES.5.1 Industry Costs

For the proposed rule, the burden and cost potentially incurred by industry are estimated using the RatioBased Burden Methodology (RBBM) which is a simplified formulation of the previously employed 

burden methodology (U.S. EPA, 2011b). According to RBBM, reporting activities can be divided into 

two groups: 

 Form Activities, consisting of rule familiarization, reporter compliance determination, 

calculations and form completion, and recordkeeping and submission; and 

 Non-Form Activities, consisting of supplier notification and non-reporter compliance 

determination.

Form Activity burden is estimated using the Nominal Form R Unit Burden to represent average burden 

incurred by filers to file a Form R. The Nominal Form R Unit Burden is set at 35.70516 hours.1 Form A 

burden is closely linked to that of Form R, and is therefore quantified by the ratio A/R (set at 0.615), thus 

reflecting the burden of a Form A as 61.5 percent of the burden of a Form R. Form Activity Burden can 

be calculated using the Nominal Form R Unit Burden, the A/R ratio, and the number of Form R and Form 

A chemicals expected to be reported due to the proposed rule. RBBM combines Form Activity Burden 

with Non-Form Activity Burden (consisting of supplier notification and non-reporter compliance 

determination) in order to calculate Steady State Total Burden, which is the ongoing burden estimated to 

be incurred by filers due to the proposed rule. To represent the elevated level of effort incurred by both 

filers reporting to TRI for the first-time and those already reporting to TRI but considering the 

requirements of the proposed rule for the first time, a First-Time Filer Factor (FTFf) is computed at 2.1.

The costs potentially incurred by industry are estimated using the weighted average wage rate, WAWR,

representing the average loaded cost for a mix of Managerial, Technical and Clerical labor per hour of 

TRI reporter burden. The WAWR is calculated using data from Bureau of Labor Statistics’ Employer 

Costs for Employee Compensation, updated quarterly. As of December 10, 2014, the WAWR reflecting 

September 2014 wage rate data is calculated at 52.61.

 

1 The burden of 35.70516 includes the addition of 0.00516 hours of burden associated with the Dioxin Reporting 

Requirements promulgated in May 10, 2007, and accounted for in the 2011 ICR (Docket# EPA-HQ-OEI-2010-

0835).
EXECUTIVE SUMMARY

Economic Analysis of the Proposed Addition of 1-Bromopropane ▌pg. v

Table ES-2: Total First Year and Steady State Industry Burden under the Proposed Rule presents the total 

industry burden of the proposed rule in the first year of the rule and in the steady state. Table ES-3

presents annualized industry costs annualized at discount rates of 3% and 7%.
EXECUTIVE SUMMARY

Economic Analysis of the Proposed Addition of 1-Bromopropane ▌pg. vi

Table ES-2: Total First Year and Steady State Industry Burden under the Proposed Rule

First Year 

Form R 

Burden

(hrs)

First Year 

Form A 

Burden

(hrs)

First Year 

Total 

Burden

(hrs)

Steady State 

Form R 

Burden

(hrs)

Steady State 

Form A 

Burden

(hrs)

Steady State 

Total 

Burden

(hrs)

9,449 644 10,093 4,500 308 4,808

Table ES-3: Total Annualized Industry Cost under the Proposed Rule

Annualized 

Form R 

Cost (3%)

Annualized 

Form A 

Cost (3%)

Total 

Annualized 

Cost (3%)

Annualized 

Form R

Cost (7%)

Annualized 

Form A 

Cost (7%)

Total 

Annualized 

Cost (7%)

$266,321 $18,200 $284,521 $271,326 $18,539 $289,865

ES.5.2 EPA Costs

In general, EPA incurs burden and costs for five categories of activities related to the TRI program: data 

processing, outreach and training, information dissemination, policy and petitions, and compliance and 

enforcement. These activities involve both fixed (e.g., rent for the EPCRA reporting center) and variable 

costs (activities such as data processing that depend on the number of forms submitted). As a result of the 

proposed rule, the Agency is only expected to incur variable costs associated with data processing.

As of January 21, 2014, all non-trade secret forms must be submitted electronically. EPA estimates that 

the processing cost for TRI-MEweb submissions is $6.05 per form. Therefore, the total form processing 

burden for EPA associated with Form R and Form A chemical submissions under the proposed rule is 

estimated at $847.

ES.5.3 Total Costs

The total cost of the proposed rule to industry and EPA is estimated at approximately $300,000 under a 

3% or 7% discount rate. Table ES-4 summarizes the total annualized costs to industry and EPA as a result 

of the proposed rule.

Table ES-4: Summary of Total Costs of the Proposed Rule

Cost Category Total Cost (3% Discount Rate) Total Cost (7% Discount Rate)

Industry Costs $284,521 $289,865

EPA Processing Costs $847 $847

Total Costs $285,368 $290,712

ES.6 Small Entity Analysis

The Regulatory Flexibility Act (RFA) of 1980 (5 U.S.C. § 601 et. seq.) requires Federal agencies to 

assess the effects of regulations on small entities, and in some instances, to examine alternatives to the 

regulations that may reduce adverse economic effects on significantly impacted small entities. The RFA 

requires agencies to prepare an initial and final regulatory flexibility analysis for each rule unless the 
EXECUTIVE SUMMARY

Economic Analysis of the Proposed Addition of 1-Bromopropane ▌pg. vii

Agency certifies that the rule will not have a significant economic impact on a substantial number of 

small entities. 

This analysis uses annualized cost impact percentages to measure potential impacts on small entities. The 

cost impact percentage is defined as annualized compliance costs resulting from the proposed rule as a 

percentage of annual revenues or sales. For purposes of determining small entity impacts, comparing 

annualized compliance costs to annual revenues provides a reasonable indication of the magnitude of 

the regulatory burden relative to a commonly available and objective measure of a company's 

business volume. Where regulatory costs represent a small fraction of a typical firm's revenue, the 

impacts of the regulation are likely to be minimal.

Small entity impacts for the 140 facilities estimated to be affected by the proposed rule are estimated 

either using actual facility and parent entity data or using U.S. Census data.

For the sectors where the identity of each facility is known, (facilities manufacturing or importing 1-BP)

cost impact percentages are calculated using the actual compliance costs per facility, the number of 

facilities per parent company for small entities, and the annual revenues of the small entities. Company 

revenue data, facility-parent relationships, and the data necessary to determine if the parent entity is small 

were obtained from Hoover’s, Inc.’s business information database, which provides data including annual 

revenue, number of employees, line of business, parent company identity, and corporate linkages 

(Hoover's Inc, 2014).

Small entity impacts in sectors where the identify of each facility is not known (facilities processing or 

otherwise using 1-BP) were estimated using revenue, employment, and facility-parent relationship data

from the U.S. Census Bureau‘s Statistics of U.S. Businesses (SUSB) (U.S. Census Bureau, 2007). The 

SUSB provides annual data for U.S. business establishments by geography, industry, and enterprise size, 

including counts of establishments, firms, employees, and payroll. Data on total revenues are also 

provided by SUSB every five years. The data available from the SUSB can therefore be used to estimate 

annual revenues and calculate cost impact percentages for affected small parent entities.

A sensitivity analysis using industry-specific wage rates to construct the cost to employ ten workers as a 

revenue floor was also conducted to ensure that impacts to the smallest potentially-affected parent entities 

were considered.

2

Although the specific methodology used to estimate small entity impacts differs based on the data 

available for each sector, the general methodology employed consists of the following steps:

Step 1: Identify the universe of facilities expected to incur compliance costs due to the proposed rule.

Step 2: Characterize the relationships between these facilities and their global ultimate parent entities.

Step 3: Estimate annual revenues of parent entities.

Step 4: Identify small parent entities based on SBA or RFA definitions.

 

2

Industry-specific wage rates are published by the Bureau of Labor Statistics (BLS) (U.S. Bureau of Labor 

Statistics, 2014a).
EXECUTIVE SUMMARY

Economic Analysis of the Proposed Addition of 1-Bromopropane ▌pg. viii

Step 5: Develop annualized compliance cost estimates for small parent entities using the per-facility 

reporting cost and the number of facilities per parent entity that will report to TRI.

Step 6: Calculate the entity-level impact percentages, defined as annualized compliance costs as a 

percentage of annual revenues, to measure regulatory burden.

Step 7: Estimate the number and percentage of small parent entities with entity-level impact percentages 

in each of three categories: (1) less than one percent of annual revenues; (2) between one and three 

percent of annual revenues; and (3) greater than or equal to three percent of annual revenues.

The 140 facilities expected to report under the proposed rule were linked to 140 parent entities, 136 of 

which were categorized as small parent entities. All of the 136 small parent entities are estimated to incur 

annualized cost impacts of less than 1%. Therefore, the proposed rule is not expected to significantly 

impact a substantial number of small entities. Table ES-5 summarizes the results of the small entity 

analysis.

Table ES-5: Summary of Small Entity Analysis

Facilities Potential 

Parent Entities

Potential Small 

Parent Entities

Small Parent Entities Incurring Annualized 

(7%) Cost Impacts of...

<1% 1% to 3% >3%

140 140 136 136

(100%)

0

(0%)

0

(0%)

ES.7 Benefits of the Proposed Rule

The benefits of the proposed rule include improved understanding, awareness, and decision making

related to the provision and distribution of information on releases and waste management of 1-BP. The 

provision of information can lead to follow-on activities that create additional costs and benefits. In 

particular, this information can lead to voluntary initiatives by industry to review production processes, 

set goals for reductions in emissions, and institute “good neighbor” policies.

EPA has not attempted to monetize the benefits of the proposed rule due to the lack of quantitative 

information characterizing the range of users and non-users of TRI data and the substantial analytical 

challenges associated with conducting an analysis that accurately predicts behavioral responses to the 

provision of information. In addition, the potentially large numbers of beneficiaries who are not TRI data 

users, or who are otherwise unaware of the data (e.g., general public), further limits EPA’s ability to 

quantify potential benefits. However, the experience since the first forms were submitted to TRI in 1987 

suggests that reporting under EPCRA section 313 has produced real gains in understanding about 

communities’ exposure to toxic chemicals. In its report entitled The Toxics Release Inventory in Action: 

Media, Government, Business, Community and Academic Uses of TRI, EPA has documented numerous 

examples of how multiple stakeholders have used TRI data (U.S. EPA, 2013b). Moreover, a cursory 

search on GoogleScholarTM reveals thousands of academic articles referencing the Toxics Release 

Inventory. Listing 1-BP, and the subsequent use of the reported information, should provide similar gains 

in understanding of this particular chemical. EPA believes that 1-BP meets the statutory toxicity criteria 

of section 313, and is at least as toxic as some of the chemicals for which Congress initially believed there 

were net benefits due to reporting (i.e., the initial list of section 313 chemicals). 
BACKGROUND AND OVERVIEW OF ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 1-1

1. Background and Overview of Analysis

The Emergency Planning and Community Right-to-Know Act (EPCRA), also known as Title III of the 

Superfund Amendments and Reauthorization Act of 1986 (SARA), created a broad range of emergency 

response planning and reporting requirements for manufacturers, processors, and users of toxic chemicals 

in the United States. Under section 313 of EPCRA, certain facilities are required to submit annual reports 

to the United States Environmental Protection Agency (EPA) and to States and Indian Country officials

on their release(s), transfer(s), and waste management activities for certain toxic chemicals if they are 

manufactured, processed, or otherwise used above thresholds amounts. In addition, the Pollution 

Prevention Act (PPA) of 1990 requires these same facilities to report prevention, recycling, and other 

waste management information for these same chemicals. EPA maintains the data collected under 

EPCRA section 313 and the PPA in a database known as the Toxics Release Inventory (TRI).3

EPCRA section 313(f)(1) contains default reporting thresholds for facilities. These reporting thresholds 

are 25,000 pounds for toxic chemicals that are manufactured (including imported) or processed, and 

10,000 pounds for toxic chemicals that are otherwise used. For chemicals that are considered to be 

persistent, bioaccumulative, and toxic (PBT), reporting thresholds are set at 10 or 100 lbs, with the 

exception of dioxin, which is set at 0.1 grams. Facilities that meet these reporting thresholds, as well as 

other reporting criteria, are required to submit annual reports. Under this rule, reporting would be required 

for 1-Bromopropane (1-BP) which EPA considers to be a human carcinogen. The classification is based 

on sufficient evidence of carcinogenicity in experimental animals and supporting data on mechanisms of 

carcinogenesis. (U.S. Department of Health and Human Services, 2014)

This report analyzes the economic impacts of the proposed rule. To understand the effects of the proposed

rule, however, it is first necessary to understand how EPCRA section 313 and TRI currently operate. This 

chapter provides an overview of TRI followed by a description of the rule and organization of the report.

1.1 Overview of TRI

In 1986, Congress passed the Emergency Planning and Community Right-to-Know Act (EPCRA). The 

law was passed in response to the accidental release of methyl isocyanate gas in Bhopal, India, in 

December 1984, and to a number of chemical accidents in the United States, including one in Institute, 

West Virginia. These accidental releases highlighted the lack of information readily available to the 

public about toxic chemicals being manufactured, processed, used, and transported within their 

communities. EPCRA is based on the premise that the public has the right to know about the use of 

chemicals, as well as their routine and accidental releases. The broad purposes are to encourage planning 

for response to accidental chemical releases as well as daily management of routine releases, and to 

 

3 The term EPCRA section 313 properly refers to only the statutory requirements, while the term TRI properly refers 

to the database where the information collected under section 313 and under section 6607 of the PPA is stored. 

However, the terms have often been used interchangeably by the public to refer to the statute, the regulatory 

requirements, the reporting form, the database, and EPA's program to manage the data. In deference to common 

usage, the terms EPCRA section 313 and TRI are sometimes used interchangeably in this report where doing so will 

make the report simpler and easier to read.
BACKGROUND AND OVERVIEW OF ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 1-2

provide the public and government agencies with information about the presence, release, and 

management of toxic chemicals.

EPCRA contains four main provisions:

 Planning for chemical emergencies (sections 301-303),

 Emergency notification of chemical accidents and releases (section 304),

 Reporting of hazardous chemical inventories (sections 311-312), and

 Toxic chemical release reporting (section 313).

Because this rule falls under section 313 of EPCRA, the remainder of this overview only addresses the 

reporting provisions of section 313.

The first regulations implementing EPCRA section 313 were promulgated on February 16, 1988 (53 FR 

4500), and are codified at 40 CFR part 372. Under these original regulations, owners or operators of 

certain facilities must complete and submit one or more Toxic Chemical Release Inventory Reporting 

Form R reports. The information to be submitted on a Form R report includes, but is not limited to, 

information on releases to air, water, and land, as well as on-site waste treatment and transfers of the 

chemical to off-site locations.

A facility must report under section 313 if it meets all of the following three criteria: 

1. It is in an Industrial Classification code covered by the regulations;

2. It has ten or more full-time employees (or the hourly equivalent of 20,000 hours); and

3. It manufactures, processes, or otherwise uses any of the listed toxic chemicals or chemical 

categories above the applicable reporting threshold.

A completed Form R must be submitted for each listed toxic chemical manufactured, processed, or 

otherwise used above threshold levels at each regulated facility as described in 40 CFR part 372. For most 

chemicals, threshold levels are set at 25,000 lbs for manufacturing and processing and 10,000 lbs for 

otherwise use (40 CFR § 372.25). The EPCRA section 313 list currently contains over 600 toxic 

chemicals and chemical compound categories (hereinafter, “TRI chemicals”). Reports for each Calendar 

Year are due by July 1 of the following year.

TRI is unique among environmental databases because of the multimedia data it collects, and because it 

was designed for public access. The primary purpose of TRI data is to inform the public of releases and 

other waste management activities of toxic chemicals in their communities, and enable citizens to make 

informed decisions regarding the consequences of such activities to human health and the environment. 

TRI data are also used by the federal, state and local governments for prioritization purposes and to assess 

pollution prevention activities. Researchers, public interest groups, as well as others use TRI data for a 

variety of purposes. In general, TRI data have proven to be a powerful tool in environmental decisionmaking.
BACKGROUND AND OVERVIEW OF ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 1-3

1.1.1 Pollution Prevention Act

In 1990, Congress passed the Pollution Prevention Act (PPA), which adopted as national policy an 

environmental hierarchy that establishes pollution prevention as the first choice among waste 

management options (42 U.S.C. § 13101-13109). For waste that cannot be prevented at the source, 

recycling is considered the next best option, and treatment or disposal should be considered only when 

source reduction and recycling options cannot be implemented. Section 6607 of the PPA requires 

facilities to also provide information on their pollution prevention, recycling, and other waste 

management activities. This information complements the information reported under EPCRA section 

313 by providing information about the waste management activities related to the reported chemicals. 

The data elements required by the Pollution Prevention Act are included as Section 8 of Form R.

1.1.2 Changes to the List of Chemicals

When Congress passed EPCRA it provided an initial list of approximately 300 chemicals and chemical 

categories subject to TRI reporting. The statutory list was derived from chemical lists used in New Jersey 

and Maryland. Congress also included a provision in EPCRA that allows EPA to amend the list of 

chemicals subject to TRI reporting. Under section 313(d), EPA has the authority to add a chemical to the 

list if it determines that the chemical can cause or can be reasonably anticipated to cause:

 Adverse acute human health effects at concentration levels reasonably likely to exist beyond 

facility site boundaries as a result of continuous or frequently recurring releases;

 In humans, carcinogenic or teratogenic effects, serious or irreversible reproductive dysfunctions, 

neurological disorders, heritable genetic mutations, or other chronic health effects; or

 A significant adverse effect on the environment. See, 42 U.S.C.§ 11023(d).

EPA has added chemicals to the list through its authority under section 313(d). Most notably, EPA added 

286 chemicals and chemical categories to the EPCRA section 313 list of toxic chemicals on November 

30, 1994 (59 FR 61432).

EPA may remove a chemical from the list if it does not meet any of the above criteria found in 313(d). 

According to section 313(e) of EPCRA, any person may petition EPA to add or delete a chemical from 

the list on the basis of whether or not it meets the above criteria (see 42 U.S.C. § 11023(e)). All changes 

to the list are made through the rulemaking process under the Administrative Procedures Act (APA).

1.1.3 Alternate Threshold

On November 30, 1994, EPA finalized the “TRI Alternate Threshold for Facilities with Low Annual 

Reportable Amounts” (59 FR 61488). This rule was intended to reduce the compliance burden associated 

with EPCRA section 313. It established a streamlined reporting option for facilities that manufacture, 

process or otherwise use a TRI chemical in annual quantities of one million pounds or less and where the 

annual reportable amount of the chemical does not exceed 500 pounds.4 Under such circumstances the 

facility has the option of filing a two-page certification statement known as a “Form A” instead of the 

longer Form R (40 CFR 372.27). The Form A is a certification that once completed and signed certifies 

 

4 The annual reportable amount is equal to the combined total quantities recycled, combusted for energy recovery, 

treated, or released. It can be calculated as is the sum of data elements 8.1 through 8.7 on Form R.
BACKGROUND AND OVERVIEW OF ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 1-4

that the facility is not required to file a Form R for the chemical because the facility did not exceed 500 

pounds for the total annual reportable amount for that chemical, and that their amounts manufactured or 

processed or otherwise used did not exceed one million pounds. EPA has excluded certain chemicals 

designated as persistent, bioaccumulative, and toxic (see below) from Form A eligibility.

1.1.4 Executive Order 12856

On August 3, 1993, Executive Order 12856, “Federal Compliance with Right-to-Know Laws and 

Pollution Prevention Requirements” was signed by the President (58 FR 41981). The Executive Order 

requires federal facilities to comply with EPCRA requirements beginning with the 1994-reporting year. 

The Executive Order also asked all federal agencies to set a voluntary goal of 50% reduction from 

baseline quantities of their releases and transfers by 1999.

1.1.5 Changes to the List of Industries

On May 1, 1997, EPA added facilities in seven industry groups to the list of facilities subject to the 

reporting requirements of section 313 (62 FR 23833). The first reports from these facilities were required 

to be submitted by July 1, 1999 for the calendar year 1998. Prior to this action, reporting was limited to 

facilities in the manufacturing sector (SIC codes 20-39) and federal facilities. This action added facilities 

in the following sectors: 

 Metal mining, 

 Coal mining,

 Electric utilities,

 Commercial hazardous waste treatment, storage, and disposal facilities,

 Chemicals and allied products-wholesale,

 Petroleum bulk terminals and plants-wholesale, and

 Solvent recovery services.

1.1.6 Changes for Chemicals that are Persistent, Bioaccumulative, and Toxic 

On October 29, 1999, EPA published a final rule that lowered the reporting thresholds to 10 or 100 

pounds for certain TRI chemicals (persistent, bioaccumulative and toxic chemicals, or PBT chemicals) 

that are of special concern (64 FR 58666). In the same rule, EPA also added to the section 313 list of 

toxic chemicals certain PBT chemicals that were not already listed, including a dioxin category with a 

reporting threshold of 0.1 gram. Additionally, this rulemaking included other changes to PBT chemical 

reporting, such as disallowing the use of the de minimis exemption, range reporting, and Form A for PBT 

chemicals (40 CFR § 372.28(b)). On January 17, 2001, EPA published a final rule that designated lead 

and its compounds as PBTs, lowered the reporting threshold for these chemicals to 100 pounds, and 

applied the same limitations that are applied to other PBT chemicals (40 CFR § 372.28).

1.1.7 Toxic Chemical Release Reporting Using North American Industry Classification System 

(NAICS) Rule

On June 6, 2006, EPA published a final rule requiring facilities reporting to TRI to use North American 

Industry Classification System (NAICS) codes in place of the Standard Industry Classification (SIC) 
BACKGROUND AND OVERVIEW OF ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 1-5

codes previously used on TRI reporting forms. This rule required facilities that report to TRI to use 2002 

NAICS codes on reporting Form R and the Form A Certification Statement. The 2007 NAICS Revision 

Final Rule published on June 9, 2008, required facilities to use 2007 NAICS codes on TRI reporting 

forms. NAICS reporting requirements were revised again on July 18, 2013. Under the 2012 NAICS 

Revision Final Rule, facilities are required to use 2012 NAICS codes when submitting forms for reporting 

years 2013 and beyond.

1.1.8 TRI Dioxin and Dioxin-like Compounds Toxic Equivalency (TEQ) Information Rule

On May 10, 2007, the Toxics Release Inventory Program issued a final rule expanding reporting 

requirements for the dioxin and dioxin-like compounds category. There are seventeen distinct members of 

this chemical category that are included on the EPCRA section 313 list of toxic chemicals. The final rule 

requires that, in addition to the total grams released for the entire category, facilities must report the 

quantity for each individual member on a new Form R Schedule 1. EPA will then use the individual mass 

quantity data to calculate TEQ values that will be made available to the public along with the mass data. 

The final rule also removes the requirement to report the single distribution of compounds in the category.

1.2 Addition of 1-Bromopropane to EPCRA Section 313 Reporting 

Requirements

1-BP is a short chain, brominated, alkyl molecule, which is a colorless liquid under standard conditions. 

Human exposure by inhalation or skin contact can lead to irritation and neurologic effects such as 

headaches, dizziness, slurred speech or loss of consciousness. In addition, studies with animal subjects 

have linked 1-BP to certain cancers, as well as toxicity in the liver, reproductive system, and nervous 

system (National Institute of Health and Safety, OSHA, 2014).

The halogenated alkane properties of 1-BP make it an ideal organic solvent. In industry, the main uses of 

1-BP are as an aerosol solvent in asphalt, aircraft, and synthetic fiber manufacturing, as a vapor and 

immersion degreaser in metals, metal products, plastics, optics, and electronics manufacturing, and as a 

cleaning solvent for dry cleaning. In addition, 1-BP can be used as an adhesive in laminates and foam 

products, and as a chemical intermediate in pharmaceuticals, pesticides, quaternary ammonium 

compounds, flavors, and fragrances.

1.3 Organization of This Report

This report examines the potential impact to industry and the Agency of adding 1-BP to the list of 

EPCRA section 313 reportable chemicals. The remainder of this report is organized as follows:

 Chapter 2: Estimates of the Number of Reports and Affected Facilities summarizes the 

expected number of reports and facilities affected by the proposed rule.

 Chapter 3: Cost Estimates presents the methodology used to estimate costs, as well as the 

results of the analysis in terms of total incremental cost to industry and total incremental cost to 

EPA. 

 Chapter 4: Small Entity Analysis examines the impacts of the proposed rule, specifically those 

impacts on “small” entities as required by the Regulatory Flexibility Act of 1980. 

 Chapter 5: Benefits evaluates the benefits of the proposed rule.
BACKGROUND AND OVERVIEW OF ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 1-6

 Chapter 6: References provides references cited in this analysis.
ESTIMATES OF THE NUMBER OF REPORTS AND AFFECTED FACILITIES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 2-1

2. Estimates of the Number of Reports and Affected Facilities

This chapter presents the estimate of the number of additional forms and affected facilities that would 

result from the proposed addition of 1-Bromopropane (1-BP) to the TRI list of reportable chemicals.

Background information on 1-BP is provided in Section 2.1 of this chapter. The methods and associated 

assumptions used to estimate reporting for 1-BP are presented in Section 2.2. Section 2.3 provides a 

summary of expected reporting from the potentially affected universe of facilities.

2.1 Background

1-BP is a short chain, brominated, alkyl molecule, which is a colorless liquid under standard conditions. It 

is manufactured domestically and imported to the US. As shown in Table 2-1, domestic production of 1-

BP has increased significantly in the past 20 years. In 2007, 1-BP was approved for use under EPA's 

Significant New Alternatives Policy (SNAP) as a suitable replacement for ozone depleting chemicals, and 

has found significant new use as a substitute for chlorofluorocarbons and perchloroethylene.

Table 2-1: Historical 1-BP Production Volume

Year Production Volume (lb)

19861 10K - 500K

19901 10K - 500K

19941 500K - 1M

19981 1M - 10M

20021 1M - 10M

20061 1M - 10M

20122 15,348,727

1

Inventory Update Reporting: 

http://www.epa.gov/cdr/tools/previouslycollected.html

2 2012 Chemical Data Reporting: http://www.epa.gov/cdr/

The halogenated alkane properties of 1-BP make it an ideal organic solvent. While specific data regarding 

quantities of 1-BP used by application were not available, sources indicate that 1-BP is primarily 

otherwise used in application such as:

5

 an aerosol solvent in asphalt, aircraft, and synthetic fiber manufacturing; 

 a vapor and immersion degreaser in metals, metal products, plastics, optics, and electronics 

manufacturing; and 

 a cleaning solvent in dry cleaning. 

To a lesser extent, 1-BP also has processing applications such as: 

 

5 Abt Associates Memorandum: Percent 1-Bromopropane in Formulation by Usage, November 8, 2013.
ESTIMATES OF THE NUMBER OF REPORTS AND AFFECTED FACILITIES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 2-2

 adhesives in laminates and foam products; and

 limited use as a chemical intermediate in pharmaceuticals, pesticides, quaternary ammonium 

compounds, flavors, and fragrances. 

2.2 Methodology

Due to the widespread use of 1-BP, characterizing all potential reporters in all potentially affected

industries is not feasible. Therefore, this analysis focuses on the sectors that capture the majority of the 

manufacture, processing and otherwise use of 1-BP. Thus, this method assumes that most reports for 1-

BP would come from these sectors. Although reports could potentially be filed for 1-BP by facilities in 

additional sectors, reporting from the additional sectors is expected to be minimal. 

The estimates of reporting developed in this analysis rely on RY2012 CDR production data. Note that it is 

possible that the trend toward increasing 1-BP production in the US over the past decade will continue, 

however, this analysis does not account for potential further increased use of the chemical. 

The primary sectors manufacturing, processing, or otherwise using 1-BP were identified based on 

information available from:

 TSCA 2012 Chemical Data Reporting (CDR; U.S. EPA, 2013), 

 Directory of World Chemical Producers (DWCP; CIS, 2013), and

 SNAP –1-Bromopropane as a substitute for Ozone depleting substances (Federal Reg., 2007)

 Japanese PRTR Data (PRTR, Ministry of the Environment, Japan, 2014)

 TRI data for existing reporters (U.S. EPA, 2012).

The primary TRI-covered sectors manufacturing, processing or otherwise using 1-BP are listed in Table 

2-2. Note that not all six-digit NAICS codes within the three-digit NAICS code are expected to 

manufacture, process, or otherwise use 1-BP.

Table 2-2: NAICS codes Manufacturing, Processing or Otherwise using 1-Bromopropane

Sector NAICS Code NAICS Description

Chemical and 

Chemical Products 

Manufacturers

325 Chemical Manufacturing

325199 All Other Basic Organic Chemical Manufacturing

325220 Artificial and Synthetic Fibers and Filaments Manufacturing

325510 Paint and Coating Manufacturing

325520 Adhesive Manufacturing

Plastics and 

Rubber

3261 Plastics Product Manufacturing

326140 Polystyrene Foam Product Manufacturing

326150 Urethane and Other Foam Product (except Polystyrene) 

Manufacturing

3262 Rubber Product Manufacturing

331 Primary Metal Manufacturing. 

331110 Iron and Steel Mills and Ferroalloy Manufacturing
ESTIMATES OF THE NUMBER OF REPORTS AND AFFECTED FACILITIES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 2-3

Table 2-2: NAICS codes Manufacturing, Processing or Otherwise using 1-Bromopropane

Sector NAICS Code NAICS Description

Metals/ Metal 

Products

Manufacturing

3314 Nonferrous Metal (except Aluminum) Production and Processing

332 Fabricated Metal Product Manufacturing

332992 Small Arms Ammunition Manufacturing. 

332721 Precision Turned Product Manufacturing

333 Machinery Manufacturing

Electronics and 

Optics 

Manufacturing

333314 Optical Instrument and Lens Manufacturing

334 Computer and Electronic Product Manufacturing

33441 Semiconductor and Other Electronic Component Manufacturing

335 Equipment, Appliance, and Component Manufacturing. 

Aircraft 

Manufacturing

336 Transportation Equipment Manufacturing

336411 Aircraft Manufacturing

336412 Aircraft Engine and Engine Parts Manufacturing

336413 Other Aircraft Parts and Auxiliary Equipment Manufacturing

Wood Products 

Manufacturing

321 Wood Product Manufacturing

337 Furniture and Related Product Manufacturing. 

Other 

Manufacturing

323 Printing and Related Support Activities

324121 Asphalt Paving Mixture and Block Manufacturing

3271 Clay Product and Refractory Manufacturing

3279 Other Nonmetallic Mineral Product Manufacturing

339 Miscellaneous Manufacturing

Wholesalers and 

Waste Treatment

424690 Other Chemical and Allied Products Merchant Wholesalers

5622 Waste Treatment and Disposal

562211 Hazardous Waste Treatment and Disposal

For the purposes of the EA, the potential number of forms and facilities reporting 1-BP are estimated by 

NAICS code. Where possible, actual facilities expected to report to TRI if 1-BP is added are identified. 

However, due to the limited amount of available information for facilities processing or otherwise using 

1-BP, actual facilities processing or otherwise using 1-BP could not be identified. Potential reporting was 

estimated by using Japanese pollutant release and transfer registry (PRTR) data for 1-BP and—for the 

limited number of TRI-reportable US sectors not covered by the Japanese PRTR—TRI data for a proxy 

chemical to model 1-BP reporting under the proposed rule.

2.2.1 Identifying Actual Facilities

Companies or facilities manufacturing or importing 1-BP or chemicals manufactured from 1-BP can be 

identified in the open literature. Specifically, the number of facilities manufacturing or importing 1-BP is 

estimated based on actual companies or facilities identified in the 2012 Chemical Data Reporting (CDR; 
ESTIMATES OF THE NUMBER OF REPORTS AND AFFECTED FACILITIES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 2-4

U.S. EPA, 2013), 2013 Directory of World Chemical Producers (DWCP; CIS, 2014), and other available 

publications. Using these resources, eight facilities were identified that are expected to report 1-BP as a 

manufacturer or importer (Table 2-3).

Table 2-3: Count of US Facilities Estimated to Report 1-BP by US NAICS 

Codes

NAICS 

Code Industry Facility Count

325188 All Other Basic Inorganic Chemical Manufacturing 3

325199 All Other Basic Organic Chemical Manufacturing 5

Total 8

No significant derivatives of 1-BP have been identified to date, although some sources indicate 1-BP is 

used as a derivative in pharmaceuticals. As such, reports for actual facilities manufacturing derivatives of 

1-BP are not expected.

2.2.2 Proxy Methods

Information on quantities of 1-BP processed and otherwise used in the US is not currently available. 

Japanese domestic production and PRTR data were therefore used as a proxy (see Section 2.2.1). While 

the Japanese PRTR has generally good coverage of the sectors expected to report 1-BP to TRI, it does not 

include data for chemical wholesalers. Therefore, reporting in NAICS 424690: Other Chemical and 

Allied Products Merchant Wholesalers is estimated separately using a scaling method (described later in 

this section).

In both models, a proxy chemical is used to control for reporting differences between countries (Proxy 

Pollutant Release and Transfer Register (PRTR) Method) or a base line estimate of facilities reporting 

(Proxy Chemical Scaling Method). Chemicals that have relevant production volume and PRTR data 

available for both the US and Japan were identified, and share similar industrial use characteristics as 1-

BP including: 

 Significant otherwise use;

 Use as an industrial solvent;

 Production volume on the order of 15.5 million lb in 2012.

6

Based on this analysis, N,N-dimethylformamide is considered a suitable proxy chemical for 1-BP based 

on the following characteristics:

 Reported as otherwise used by 41% of RY2012 TRI Form Rs;

 Used as an industrial solvent; and

 Comparable production volume of 49.6 million lb in 2012.

7

 

6 2012 Chemical Data Reporting: http://www.epa.gov/cdr/

7 2012 Chemical Data Reporting: http://www.epa.gov/cdr/
ESTIMATES OF THE NUMBER OF REPORTS AND AFFECTED FACILITIES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 2-5

Proxy Pollutant Release and Transfer Register (PRTR) Method

Japanese PRTR data for 1-BP were obtained by sector for reporting year 2012, matching the most recent 

year of Japanese and US production data available for 1-BP.8 Specifically, the data obtained includes the 

number of reporting facilities, number of forms, and aggregated release and transfer quantities by sector. 

Facility-level data were not available in the public data set. Japanese industry codes were manually cross 

walked to corresponding US NAICS codes (Table 2-4). Comparing US sectors likely to process or 

otherwise use 1-BP to Japanese PRTR sectors, industries reporting 1-BP to the Japanese PRTR align well 

with expected uses in the US, supporting the assumption that Japanese production and use of 1-BP is 

similar to US production and use.

Table 2-4: 1-BP Reporting to Japanese PRTR (2012)

Count of 

Japanese 

Facilities

Japanese Industry Code NAICS Codes (US)

62

2800: Manufacture of fabricated metal 

products

332: Fabricated Metal Product 

Manufacturing

50

3000: Manufacture of electrical machinery, 

equipment and supplies

334: Computer and Electronic Product 

Manufacturing

30

3200: Manufacture of precision instruments 

and machinery

332721: Precision Turned Product 

Manufacturing

29

3100: Manufacture of transportation 

equipment

336: Transportation Equipment 

Manufacturing

20 2900: Manufacture of general machinery 333: Machinery Manufacturing

16

2000: Manufacture of chemical and allied 

products 325: Chemical Manufacturing

15

2200: Manufacture of plastic products, 

except otherwise classified 3261: Plastics Product Manufacturing

14

2700: Manufacture of non-ferrous metals and 

products

3314: Nonferrous Metal (except Aluminum) 

Production and Processing

9 2300: Manufacture of rubber products 3262: Rubber Product Manufacturing

7

3400: Miscellaneous manufacturing 

industries 339: Miscellaneous Manufacturing

7

2600: Manufacture of iron and steel 331110: Iron and Steel Mills and Ferroalloy 

Manufacturing

4

1900: Publishing, printing and allied 

industries

323: Printing and Related Support 

Activities

3 8722: Industrial waste disposal industry 5622: Waste Treatment and Disposal

2

2500: Manufacture of ceramic, stone and 

clay products

3271 and 3279: Clay Product and 

Refractory Manufacturing

 

8

Japan Ministry of the Environment, 2014. Available at: http://www.env.go.jp/en/chemi/prtr/prtr.html
ESTIMATES OF THE NUMBER OF REPORTS AND AFFECTED FACILITIES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 2-6

Table 2-4: 1-BP Reporting to Japanese PRTR (2012)

Count of 

Japanese 

Facilities

Japanese Industry Code NAICS Codes (US)

1

1600: Manufacture of lumber and wood 

products

321: Wood Product Manufacturing

337: Furniture and Related Product 

Manufacturing

1

7810: Machinery and equipment repair 

industry

8113: Commercial and Industrial 

Machinery and Equipment Repair and 

Maintenance

270 Total Count of Japanese Facilities Reporting 1-BP 

In order to estimate potential US reporting for processors and otherwise users of 1-BP from existing 

Japanese reporting, differences in total use of 1-BP and PRTR reporting requirements must be accounted 

for. 9 Specifically, the three key factors summarized in Table 2-5 are addressed in the proxy PRTR 

method. Controlling for these factors normalizes differences in reporting frequency due to higher 

production volume in the US and accounts for differing reporting thresholds between the US and 

Japanese PRTR. Specifically, a lower reporting rate is likely for the US due to the significantly higher US 

activity thresholds compared to Japanese activity thresholds. Note that the lower US reporting rate is 

somewhat counterbalanced by lower employment threshold in the US which may increase the reporting 

rate. 

Table 2-5: Key Factors Determining Reporting Differences for 1-BP

Key Factors US Japan

2012 Production Volume 

for 1-BP 

15.3 million lb1 4,000-5,000 metric tons 

(estimate 9.9 million lb using the 

range midpoint)2

PRTR Chemical Activity 

Threshold

10,000 lb for otherwise use; 25,000 

lb for manufacturing and processing

1 metric tons (2,205 lb)

PRTR Employment 

threshold

10 FTE 21 FTE

1 2012 CDR, available at: http://www.epa.gov/cdr/

2 J-CHECK, available at: http://www.safe.nite.go.jp/jcheck/top.action

The number of expected facilities reporting 1-BP for any country can be represented by the following 

function, which includes scaling functions for production volume, chemical activity threshold, and 

employment threshold: 

 

9 270 Japanese facilities reported 1-BP in 2012. Japan Ministry of the Environment, 2014. Available at: 

http://www.env.go.jp/en/chemi/prtr/prtr.html
ESTIMATES OF THE NUMBER OF REPORTS AND AFFECTED FACILITIES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 2-7

F1BP = C1BPf(PV)f(CT)f(ET) Equation 2-1

where: F1BP = the number of facilities reporting

C1BP = a universal reporting constant specific to 1-BP

PV = production volume

CT = chemical activity threshold

ET = employment threshold

Solving for the number of US facilities reporting includes the following steps:

1) Assume that for any country, reporting facility count is linearly related to production volume (scaling 

assumption).

F1BP = C1BPPV1BPf(CT)f(ET) Equation 2-2

2) Develop a ratio comparing US and Japan (JP) reporting and production using Equation 2-2 for each 

country. Note that the universal reporting constants cancel.

F1BP,US

F1BP,JP

=

PV1BP,US

PV1BP,JP

f(CT)USf(ET)US

f(CT)JPf(ET)JP

 Equation 2-3

3) Rearrange the equation to solve for US facility count. 

F1BP,US = F1BP,JP

PV1BP,US

PV1BP,JP

f(CT)USf(ET)US

f(CT)JPf(ET)JP

Equation 2-4

4) Substitute the known US and Japanese 2012 production volumes and the Japanese PRTR facility count 

yields:

F1BP,US = 270 facilities 15.3 million lb

9.9 million lb

f(CT)USf(ET)US

f(CT)JPf(ET)JP

Equation 2-5

F1BP,US = 418 facilities f(CT)USf(ET)US

f(CT)JPf(ET)JP

Equation 2-6

Assuming that there were no effects on reporting due to differences between US and Japanese PRTR 

reporting thresholds (i.e., the threshold scaling term f(CT)USf(ET)US

f(CT)JPf(ET)JP

is equal to 1), 418 facilities are 

expected to report 1-BP to TRI. However, as noted in Table 2-5, the thresholds are not identical, and it is 

important to estimate the effects of the higher TRI chemical activity threshold and lower employment 

threshold relative to the Japanese PRTR. Both linear and exponential relationships were considered for 

modeling the employment and chemical activity thresholds. However, rather than solving the models 

directly, the most effective approach is to solve for the threshold scaling term using data on the chemical 

proxy N,N-dimethylformamide. The scaling term for 1-BP would likely be close to that of the proxy 

chemical due to the similar industrial uses of 1-BP and N,N-dimethylformamide. 

5) To isolate the ratio of the threshold functions, Equation 2-3 is rearranged using the 1-BP proxy 

chemical (N,N-dimethylformamide). 
ESTIMATES OF THE NUMBER OF REPORTS AND AFFECTED FACILITIES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 2-8

f(CT)USf(ET)US

f(CT)JPf(ET)JP

=

F1BP Proxy,US

F1BP Proxy,JP

PV1BP Proxy,JP

PV1BP Proxy,US

Equation 2-7

6) Using 2012 US and Japanese production volume and PRTR data for N,N-dimethylformamide, solve 

for the threshold scaling term. 

f(CT)USf(ET)US

f(CT)JPf(ET)JP

=

465 facilities

145 facilities

49.6 million lb

50.0 million lb

Equation 2-8

f(CT)USf(ET)US

f(CT)JPf(ET)JP

= 0. 314 Equation 2-9

7) Combine the terms in Equations 2-6 and 2-9, and solve for total US facilities reporting for 1-BP. 

F1BP,US = 418 facilities × 0. 314 Equation 2-10

F1BP,US = 131 facilities Equation 2-11

Therefore, an estimated 131 US facilities would report to TRI for 1-BP. 

Assuming the number of TRI reports by sector is proportional to the number of facilities reporting to the 

Japanese PRTR for the corresponding sectors, the distribution of US reporters by NAICS code is shown 

in Table 2-6. As Japanese industry codes do not crosswalk perfectly to US 6-digit NAICS codes, facilities 

at the 3- or 4-digit NAICS are distributed to appropriate 6-digit NAICS codes when possible (see Table 

2-2). The distribution is proportional to the 2012 US Economic Census value of ‘sales, shipments, 

receipts, revenue, and business done’10 for each sector. For example, The Japanese PRTR reported 29 

facilities in 3100: Manufacture of Transportation Equipment. When adjusted for differences in production 

and reporting thresholds, 15 US facilities are expected to report in NAICS 336: Transportation Equipment 

Manufacturing. These facilities are then distributed among the three 6-digit NAICS codes listed in Table 

2-2 according to each sector’s percentage contribution to total value of the three sectors. Thus, in NAICS 

336, reporting of 1-BP in the following six-digit NAICS codes is expected: 

 336411: Aircraft Manufacturing;

 336412: Aircraft Engine and Engine Parts Manufacturing; and 

 336413 Other Aircraft Parts and Auxiliary Equipment Manufacturing.

Table 2-6: Count of US Facilities Estimated to Report 1-BP by US NAICS 

Codes

NAICS 

Code Industry Facility Count

321 Wood Product Manufacturing 0

323111 Commercial Printing (except Screen and Books) 2

325199 All Other Basic Organic Chemical Manufacturing 5

325220 Artificial and Synthetic Fibers and Filaments 

Manufacturing

1

 

10 http://www.census.gov/econ/census/
ESTIMATES OF THE NUMBER OF REPORTS AND AFFECTED FACILITIES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 2-9

Table 2-6: Count of US Facilities Estimated to Report 1-BP by US NAICS 

Codes

NAICS 

Code Industry Facility Count

325510 Paint and Coating Manufacturing 1

325520 Adhesive Manufacturing 1

326140 Polystyrene Foam Product Manufacturing 3

326150 Urethane and Other Foam Product (except Polystyrene) 

Manufacturing

4

3262 Rubber Product Manufacturing 4

327110 Pottery, Ceramics, and Plumbing Fixture Manufacturing 1

331110 Iron and Steel Mills and Ferroalloy Manufacturing 3

3314 Nonferrous Metal (except Aluminum) Production and 

Processing

7

332 Fabricated Metal Product Manufacturing 31

332721 Precision Turned Product Manufacturing 15

333 Machinery Manufacturing 10

334418 Printed Circuit Assembly (Electronic Assembly) 

Manufacturing

15

334419 Other Electronic Component Manufacturing 9

336411 Aircraft Manufacturing 9

336412 Aircraft Engine and Engine Parts Manufacturing 3

336413 Other Aircraft Parts and Auxiliary Equipment 

Manufacturing

3

339 Miscellaneous Manufacturing 3

562211 Hazardous Waste Treatment and Disposal 1

8113 Commercial and Industrial Machinery and Equipment 

Repair and Maintenance

0

Total 131

Proxy Chemical Scaling Method

Reporting from NAICS 424690: Other Chemical and Allied Products Merchant Wholesalers is estimated 

using TRI reporting from the proxy chemical and scaling to account for production volumes. Specifically, 

the 21 facilities reporting N,N-dimethylformamide for RY2012 in NAICS 424690 are scaled by the ratio 
ESTIMATES OF THE NUMBER OF REPORTS AND AFFECTED FACILITIES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 2-10

of the 2012 production volumes of 1-BP and N,N-dimethylformamide11 to estimate the number of 1-BP 

facilities expected to report under the proposed rule. 

F1BP = FProxy

PV1BP

PVProxy

Equation 2-12

F1BP = 21 facilities 15.3 million lb

49.6 million lb

Equation 2-13

F1BP = 6 facilities Equation 2-14

Therefore, an estimated 6 facilities from NAICS 424690: Other Chemical and Allied Products Merchant 

Wholesalers will report for 1-BP. 

2.2.3 Form As 

Some facilities manufacturing, processing or otherwise using 1-BP were expected to meet the Alternate 

Threshold and thus be eligible to file a Form A for 1-BP. For example, it is likely that some facilities 

process relatively low amounts of 1-BP in processes where releases and waste management are limited

(e.g., warehousing). Activity, release and waste management data necessary to evaluate Form A 

applicability could not be estimated due to limited available information. Therefore, other methods using 

proxy chemical data were used to estimate the number of Forms A.

To estimate the number of Forms A potentially expected from all facilities, the percentage of the proxy 

chemical (N,N-dimethylformamide)12 forms filed as Forms A in RY2012 was calculated (9.7%). This 

percentage was then multiplied by the number of 1-BP forms expected from all facilities to estimate the 

number of Forms A expected (i.e., 14 Forms A are expected from 140 facilities).

2.2.4 Existing Filers and First Time Filers

Facilities were classified as either existing filers or first time filers. Existing filers are defined as facilities 

that reported to TRI at least once during the period RY2008 – 2012. First time filers are defined as 

facilities that have never reported to TRI or have not reported to TRI since RY2007.

A facility was identified as an existing filer if a TRI Facility ID was identified and that facility reported to 

TRI at least once during the period RY2008 – 2012. None of the actual facilities are expected to be first 

time filers. 

In order to estimate existing versus first time filers for facilities modeled by the proxy PRTR or proxy 

chemical scaling methods, the average annual percentage of new filers for RY2008 to RY2012 across all 

chemicals (3.8%)13 was multiplied by the number of facilities expected to report 1-BP to calculate the 

expected number of first time filers.

 

11 2012 Chemical Data Reporting: http://www.epa.gov/cdr/

12 N,N-dimethylformamide, the proxy chemical identified for 1-BP, was applied since it was identified to best reflect 

the general use of 1-BP.

13 First time filers: RY2008 - 4.6%, RY2009 - 3.6%, RY2010 - 3.9%, RY2011 - 3.0%, RY2012 – 3.8%
ESTIMATES OF THE NUMBER OF REPORTS AND AFFECTED FACILITIES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 2-11

2.3 Summary

Total 1-BP reporting is estimated by summing across the three methods outlined above. It was necessary 

to adjust the total count to correct for double counting of 1-BP manufacturers or importers identified as 

actual facilities in the US and also estimated using the proxy PRTR method in NAICS 325199: All Other 

Basic Organic Chemical Manufacturing. As a result, five facilities are subtracted from the total (see Table 

2-7). From the potentially affected universe of facilities, a total of 126 Forms R and 14 Forms A from 140

facilities across 23 NAICS codes are expected. 
ESTIMATES OF THE NUMBER OF REPORTS AND AFFECTED FACILITIES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 2-12

Table 2-7: Count of US Facilities Estimated to Report 1-BP by US NAICS Codes

NAICS 

Code Industry Facility Count

Form R 

Count

Form A 

Count

323111 Commercial Printing (except Screen and Books) 2 2 0

325188 All Other Basic Inorganic Chemical Manufacturing 3 3 0

325199 All Other Basic Organic Chemical Manufacturing 5 4 1

325220 Artificial and Synthetic Fibers and Filaments 

Manufacturing 1 1 0

325510 Paint and Coating Manufacturing 1 1 0

325520 Adhesive Manufacturing 1 1 0

326140 Polystyrene Foam Product Manufacturing 3 3 0

326150 Urethane and Other Foam Product (except Polystyrene) 

Manufacturing 4 4 0

3262 Rubber Product Manufacturing 4 4 0

327110 Pottery, Ceramics, and Plumbing Fixture Manufacturing 1 1 0

331110 Iron and Steel Mills and Ferroalloy Manufacturing 3 3 0

3314 Nonferrous Metal (except Aluminum) Production and 

Processing 7 6 1

332 Fabricated Metal Product Manufacturing 31 27 4

332721 Precision Turned Product Manufacturing 15 13 2

333 Machinery Manufacturing 10 9 1

334418 Printed Circuit Assembly (Electronic Assembly) 

Manufacturing 15 13 2

334419 Other Electronic Component Manufacturing 9 8 1

336411 Aircraft Manufacturing 9 8 1

336412 Aircraft Engine and Engine Parts Manufacturing 3 3 0

336413 Other Aircraft Parts and Auxiliary Equipment 

Manufacturing 3 3 0

339 Miscellaneous Manufacturing 3 3 0

424690 Other Chemical and Allied Products Merchant 

Wholesalers 6 5 1

562211 Hazardous Waste Treatment and Disposal 1 1 0

Total 140 126 14
COST ESTIMATES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 3-1

3. Cost Estimates

This chapter presents the estimated industry and EPA costs associated with the proposed rule to add 1-

Bromopropane (1-BP) to the list of chemicals subject to TRI reporting. Section 3.1 describes the 

methodology used to estimate industry reporting burden and cost and presents the resulting estimates. 

Section 3.2 details the estimated cost to EPA. Section 3.3 summarizes the total cost of the proposed rule. 

3.1 Industry Burden and Cost Estimates

Industry burden and costs associated with the proposed rule are estimated using ratio-based burden 

methodology (RBBM). RBBM is a simplification of the previous methodology for estimating reporting 

burden and cost (U.S. EPA, 2011b). Section 3.1.1 describes the estimation of industry burden using 

RBBM. Section 3.1.2 describes the estimation of industry cost using RBBM. Sections 3.1.3 and 3.1.4

present the resulting industry burden and cost estimates. Section 3.1.5 presents annualized industry costs.

3.1.1 Estimation of Burden

Reporting activities can be divided into two distinct groups: Form Activities, consisting of rule 

familiarization, reporter compliance determination, calculations and form completion, and recordkeeping 

and submission; and Non-Form Activities, consisting of supplier notifications and non-reporter 

compliance determination. Specifically, the following activities may be undertaken under the proposed 

rule.

Form Activities

Rule Familiarization: Staff at a facility that is reporting under EPCRA §313 for the first time must 

read the reporting package and become familiar with the reporting requirements. This activity 

includes the time needed to review instructions as well as the time needed to train personnel to 

respond to an information collection request.

Reporter Compliance Determination: Staff at reporting facilities must make the determination that the 

facility meets the criteria for EPCRA §313 reporting. This activity includes the time required to 

become familiar with the definitions, exemptions, and threshold requirements under the TRI Program, 

to review the list of TRI chemicals, and to conduct preliminary threshold determinations to determine 

if the facility is required to report.

Calculations and Form Completion: Staff at reporting facilities must gather data and perform 

calculations to provide the information required on the form. This activity includes the time required 

to search data sources and to complete and review the information.

Recordkeeping and Submission: Staff at reporting facilities must maintain recordkeeping systems and 

submit the report to EPA and the state in which the facility is located. This activity includes the time 

required to transmit or otherwise disclose the information.
COST ESTIMATES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 3-2

Non-Form Activities14

Supplier Notification: Certain suppliers of mixtures or trade name products containing reportable 

substances must annually notify their customers of the product's composition if the customer is 

subject to EPCRA §313 reporting. This activity includes the required staff time at reporting facilities 

to inform customers either by letter or through the materials safety data sheet (MSDS) for the product. 

Under the proposed rule, EPA assumes that the number of facilities that might be required to provide 

supplier notifications would only be a small fraction of potential supplier notifications in connection 

with the TRI program overall. Therefore, no additional supplier notification burden is estimated in 

connection with the proposed rule. 

Non-Reporter Compliance Determination: In any given reporting year, a group of eligible facilities 

will complete compliance determination but will not file a Form R or Form A. The activity is the 

same as is presented above under Form Activities; however, given that compliance determination 

applies to all other facilities in NAICS code-eligible sectors (with ten or more employees)—including 

those that ultimately do not report to TRI—the latter category is accounted for in this separate 

activity. For this proposed rule, it is assumed that the addition of 1-BP constitutes a modest change 

when compared to the total number of chemicals subject to the program. Thus, it is assumed that the 

non-reporter compliance determination burden is already included in the existing compliance 

determination burden estimates.

The skills required to comply with the section 313 reporting requirements (including the requirements 

associated with Section 6607 of the Pollution Prevention Act) are expected to vary from facility to 

facility, depending upon factors such as: the complexity of the facility's processes and activities; the 

chemicals used at the facility; and the types of use and disposition of TRI chemicals at the facility. 

Individuals responsible for determining whether their facility is required to report and, if so, completing a 

Form R and Form A report (or multiple Form R and Form A reports) would often have an engineering, 

scientific, or technical background. These functions, however, do not require an engineering or other 

similar degree.

At a minimum, an understanding of the facility‘s chemical purchases and production processes are 

needed. Necessary skills may include the ability to evaluate and interpret records, understand material 

safety data sheets, and determine throughput or production volumes. Depending on the facility, estimates 

may be calculated using: (1) existing data collected under federal, state, or local regulations; (2) emissions 

factors; (3) design data supplied by the equipment manufacturer; (4) mass balance techniques; or (5) 

engineering calculations. Each technique requires varying skills and levels of sophistication to complete. 

EPA industry- and chemical-specific guidance documents would assist reporters in making the necessary 

calculations to comply with the section 313 reporting requirements. In addition to technical labor, 

requirements for managerial and clerical staff are also considered when estimating burden and costs.

Estimating reporting burden using RBBM produces a burden estimate that reflects overall “average” 

reporting conditions at reporting facilities. Burden calculations using RBBM involve the following key 

parameters:

 

14 Note that while petitions are considered in the overall burden/cost of the TRI program, they are not considered in 

this rulemaking as they are not related to the proposed addition of 1-BP to the list of TRI-reportable chemicals.
COST ESTIMATES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 3-3

Nominal Form R Unit Burden, which reflects the burden incurred by reporters to undertake all activities 

necessary to file a single Form R (including both facility- and form-level activities). Nominal Form R 

Unit Burden is set at 35.70516 hours.15

A/R is the ratio of Form A burden to Form R burden. A/R is calculated to be 0.615, reflecting the fact that 

filing a Form A results in a 38.5% (1.00 – 0.615 = 0.385, or 38.5%) reduction in burden per chemical 

compared to filing a Form R. Nominal Form R Unit Burden is multiplied by A/R to estimate burden 

associated with reporting a Form A chemical.

RBBM uses the estimated number of Form R and Form A chemicals, Nominal Form R Unit Burden, A/R, 

and Non-Form Burden to calculate Steady State Total Burden as shown in Equation 3-1. 

Equation 3-1: Steady State Total Burden Calculation

Steady State Total Burden = Form R Burden + Form A Burden + Non– Form Burden

Where:

Form R Burden = (Number of Form Rs)×(Nominal Form R Unit Burden) 

Form A Burden = (Number of Form As)×(A/R)×(Nominal Form R Unit Burden)

Non-Form Burden = Supplier Notifications + Non-Reporter Compliance Determination

Steady State Total Burden does not incorporate the greater burden incurred by facilities subject to TRI for 

the first time. RBBM accounts for the higher reporting burden in the first year through the use of the 

First-Time Filer Factor (FTFf). FTFf is calculated to be 2.1, indicating that burden in the first year of a 

rule is estimated to be roughly twice the ongoing burden. First Year Total Burden is calculated by 

multiplying the Steady State Burden by FTFf, as shown in Equation 3-2.

Equation 3-2: First Year Total Burden Calculation

First Year Total Burden = Steady State Total Burden × FTFf

3.1.2 Estimation of Cost

To estimate total reporting cost, RBBM uses the Weighted Average Wage Rate (WAWR), which is the 

average loaded cost for a combination of Managerial, Technical and Clerical labor per hour of TRI 

reporting burden. WAWR is based on the total cost to employ an individual and includes the cost of 

salaries, fringe benefits (e.g., paid leave), health insurance, retirement savings, legally required benefits, 

and other overhead costs, such as office space, furniture, equipment and computers, supplies and other 

business expenses.

According to feedback from existing TRI filers, the role of each labor category in the TRI reporting 

process at the facility level is as follows:

 Managerial staff are responsible for reviewing and certifying the accuracy of all TRI submissions 

and supporting documentation, including calculations, data sources, and assumptions. Managerial 

 

15 The burden of 35.70516 includes the addition of 0.00516 hours of burden associated with the Dioxin Reporting 

Requirements promulgated in May of 2007 and accounted for in the 2011 ICR ICR (Docket# EPA-HQ-OEI-2010-

0835).
COST ESTIMATES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 3-4

staff are briefed by technical staff once annually regarding TRI submissions and any changes to 

TRI reporting requirements. All sections of the Form are reviewed by managerial staff at this 

time.

 Technical staff possess the facility knowledge and familiarity with the TRI program required to 

understand which processes and activities at the facility should be considered in making threshold 

determinations for TRI chemicals. Technical staff gather the required data, make threshold 

determinations, calculate release and waste management quantities, and enter the required data on 

the TRI form, either by hand or electronically using TRI reporting software. Technical staff are 

also responsible for briefing managerial staff once annually regarding TRI submissions and any 

changes to TRI reporting requirements.

 Clerical staff are responsible for organizing, photocopying, and cataloging all TRI submissions 

and supporting documentation in accordance with TRI recordkeeping requirements. Note that as 

reporting facilities move toward filing TRI reports electronically, clerical time is minimized.

WAWR is calculated using data from the Bureau of Labor Statistics on “Wages and Salaries” and “Total 

Benefits” for three labor categories: Managerial (the “Management, Business, and Financial” 

occupational category), Technical (the “Professional and Related” occupational category), and Clerical 

(the “Office and Administrative Support” occupational category) (U.S. BLS, 2014c). Total Compensation 

is equal to the sum of Wages and Salaries and Total Benefits. Based on information provided by the 

chemical industry and chemical industry trade associations, a loading factor of 17 percent is applied to 

Wages and Salaries to calculate Overhead (Heiden Associates, 1989). The sum of Total Compensation 

and Overhead is equal to the Total Loaded Hourly Wage Rate. The Total Loaded Hourly Wage Rates for 

these labor categories are weighted by the relative contribution of each labor category to TRI reporting 

activities derived from Engineering Studies conducted by Abt Associates (Abt Associates, 2004). The 

calculation of WAWR is shown Equation 3-3.

Equation 3-3: Weighted Average Wage Rate Calculation

WAWR = (wManagerial × pManagerial) + (wTechnical × pTechnical) + (wClerical × pClerical)

Where:

wi = Total Loaded Hourly Wage Rate for labor category i, given by the formula:

 Total Loaded Hourly Wage Rate = Wages and Salaries + Total Benefits + (17% × Wages and Salaries)

pi = Proportion of overall reporting burden borne by labor category i

As shown in Table 3-1, WAWR is equal to $52.61 (in 2014 dollars).
COST ESTIMATES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 3-5

Table 3-1: Derivation of Weighted Average Wage Rate (2014 Dollars)

Wage Type Managerial Technical Clerical

Wages and Salaries $43.45 $33.96 $16.54

Total benefits $19.54 $14.57 $7.49

Overhead $7.39 $5.77 $2.81

Total Loaded Hourly Wage Rate $70.38 $54.30 $26.84

Labor Burden Weights1 0.03 0.89 0.08

Weighted Average Wage Rate (WAWR) $52.61

1 Labor burden weights have been rounded for ease of presentation.

Source: (U.S. BLS, 2014c). 

Steady State Total Cost and First Year Total Cost are calculated by multiplying the relevant total burden 

by WAWR, as shown in Equation 3-4 and Equation 3-5.

Equation 3-4: Steady State Cost Calculation

Steady State Total Cost = Steady State Total Burden × WAWR

Equation 3-5: First Year Cost Calculation

First Year Total Cost = First Year Total Burden × WAWR

3.1.3 Total Industry Burden Estimates

Table 3-2 presents the number of Form Rs estimated to be filed by facilities potentially affected by the 

proposed rule, the steady state total burden (calculated using Equation 3-1 and Equation 3-2), and the first 

year total burden (calculated using Equation 3-1). Non-form burden is assumed to be zero.16

Table 3-2: Estimated Number of Facilities Expected to Incur Reporting Burden, Total First 

Year Burden, and Total Steady State Burden under the Proposed Rule

NAICS Facilities Form 

Rs

Form 

As

First 

Year 

Form R 

Burden

First 

Year 

Form A 

Burden

First 

Year 

Total 

Burden

Steady 

State 

Form R 

Burden

Steady 

State 

Form A 

Burden

Steady 

State 

Total 

Burden

Commercial Printing 

(except Screen and 

Books) (NAICS 323111)

2 2 0 150 0 150 71 0 71

All Other Basic Inorganic 

Chemical Manufacturing 

(NAICS 325188)

3 3 0 225 0 225 107 0 107

 

16 Under the proposed rule, EPA assumes that the number of facilities that might be required to provide supplier 

notifications would only be a small fraction of potential supplier notifications in connection with the TRI program 

overall. Therefore, no additional supplier notification burden is estimated in connection with the proposed rule. 
COST ESTIMATES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 3-6

NAICS Facilities Form 

Rs

Form 

As

First 

Year 

Form R 

Burden

First 

Year 

Form A 

Burden

First 

Year 

Total 

Burden

Steady 

State 

Form R 

Burden

Steady 

State 

Form A 

Burden

Steady 

State 

Total 

Burden

All Other Basic Organic 

Chemical Manufacturing 

(NAICS 325199)

5 4 1 300 46 346 143 22 165

Artificial and Synthetic 

Fibers and Filaments 

Manufacturing (NAICS 

32522)

1 1 0 75 0 75 36 0 36

Paint and Coating 

Manufacturing (NAICS 

325510)

1 1 0 75 0 75 36 0 36

Adhesive Manufacturing 

(NAICS 325520) 1 1 0 75 0 75 36 0 36

Polystyrene Foam 

Product Manufacturing 

(NAICS 326140)

3 3 0 225 0 225 107 0 107

Urethane and Other 

Foam Product (except 

Polystyrene) 

Manufacturing (NAICS 

326150)

4 4 0 300 0 300 143 0 143

Rubber Product 

Manufacturing (NAICS 

3262)

4 4 0 300 0 300 143 0 143

Pottery, Ceramics, and 

Plumbing Fixture 

Manufacturing (NAICS 

32711)

1 1 0 75 0 75 36 0 36

Iron and Steel Mills and 

Ferroalloy Manufacturing 

(NAICS 33111)

3 3 0 225 0 225 107 0 107

Nonferrous Metal 

(except Aluminum) 

Production and 

Processing (NAICS 

3314)

7 6 1 450 46 496 214 22 236

Fabricated Metal 

Product Manufacturing 

(NAICS 332)

31 27 4 2,024 184 2,208 964 88 1,052

Precision Turned 

Product Manufacturing 

(NAICS 332721)

15 13 2 975 92 1,067 464 44 508

Machinery 

Manufacturing (NAICS 

333)

10 9 1 675 46 721 321 22 343

Printed Circuit Assembly 

(Electronic Assembly) 

Manufacturing (NAICS 

334418)

15 13 2 975 92 1,067 464 44 508

Other Electronic 

Component 

9 8 1 600 46 646 286 22 308
COST ESTIMATES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 3-7

NAICS Facilities Form 

Rs

Form 

As

First 

Year 

Form R 

Burden

First 

Year 

Form A 

Burden

First 

Year 

Total 

Burden

Steady 

State 

Form R 

Burden

Steady 

State 

Form A 

Burden

Steady 

State 

Total 

Burden

Manufacturing (NAICS 

334419)

Aircraft Manufacturing 

(NAICS 336411) 9 8 1 600 46 646 286 22 308

Aircraft Engine and 

Engine Parts 

Manufacturing (NAICS 

336412)

3 3 0 225 0 225 107 0 107

Other Aircraft Parts and 

Auxiliary Equipment 

Manufacturing (NAICS 

336413)

3 3 0 225 0 225 107 0 107

Miscellaneous 

Manufacturing (NAICS 

339)

3 3 0 225 0 225 107 0 107

Other Chemical and 

Allied Products Merchant 

Wholesalers (NAICS 

424690)

6 5 1 375 46 421 179 22 201

Hazardous Waste 

Treatment and Disposal 

(NAICS 562211)

1 1 0 75 0 75 36 0 36

Total 140 126 14 9,449 644 10,093 4,500 308 4,808

Under the proposed rule, industry is estimated to incur approximately 10,000 burden hours in the first year

and approximately 4,800 burden hours in the steady state.

3.1.4 Total Industry Cost Estimates

To estimate the cost of the proposed rule, total first year and total steady state industry reporting burden is 

multiplied by the Weighted Average Wage Rate (see Equation 3-4 and Equation 3-5); the first year and 

steady state costs are presented in Table 3-3.

Table 3-3: Total First Year and Steady State Industry Cost under the Proposed Rule

Industry Sector Facilities Form 

Rs

Form 

As

First 

Year 

Form R 

Cost

First 

Year 

Form A 

Cost

First 

Year 

Total 

Cost

Steady 

State 

Form R 

Cost

Steady 

State 

Form A 

Cost

Steady 

State 

Total 

Cost

Commercial Printing 

(except Screen and 

Books) (NAICS 

323111)

2 2 0 $7,889 $0 $7,889 $3,757 $0 $3,757

All Other Basic 

Inorganic Chemical 

Manufacturing (NAICS 

325188)

3 3 0 $11,834 $0 $11,834 $5,635 $0 $5,635

All Other Basic 

Organic Chemical 

5 4 1 $15,779 $2,426 $18,205 $7,514 $1,155 $8,669
COST ESTIMATES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 3-8

Industry Sector Facilities Form 

Rs

Form 

As

First 

Year 

Form R 

Cost

First 

Year 

Form A 

Cost

First 

Year 

Total 

Cost

Steady 

State 

Form R 

Cost

Steady 

State 

Form A 

Cost

Steady 

State 

Total 

Cost

Manufacturing (NAICS 

325199)

Artificial and Synthetic 

Fibers and Filaments 

Manufacturing (NAICS 

32522)

1 1 0 $3,945 $0 $3,945 $1,878 $0 $1,878

Paint and Coating 

Manufacturing (NAICS 

325510)

1 1 0 $3,945 $0 $3,945 $1,878 $0 $1,878

Adhesive 

Manufacturing (NAICS 

325520)

1 1 0 $3,945 $0 $3,945 $1,878 $0 $1,878

Polystyrene Foam 

Product 

Manufacturing (NAICS 

326140)

3 3 0 $11,834 $0 $11,834 $5,635 $0 $5,635

Urethane and Other 

Foam Product (except 

Polystyrene) 

Manufacturing (NAICS 

326150)

4 4 0 $15,779 $0 $15,779 $7,514 $0 $7,514

Rubber Product 

Manufacturing (NAICS 

3262)

4 4 0 $15,779 $0 $15,779 $7,514 $0 $7,514

Pottery, Ceramics, 

and Plumbing Fixture 

Manufacturing (NAICS 

32711)

1 1 0 $3,945 $0 $3,945 $1,878 $0 $1,878

Iron and Steel Mills 

and Ferroalloy 

Manufacturing (NAICS 

33111)

3 3 0 $11,834 $0 $11,834 $5,635 $0 $5,635

Nonferrous Metal 

(except Aluminum) 

Production and 

Processing (NAICS 

3314)

7 6 1 $23,668 $2,426 $26,094 $11,271 $1,155 $12,426

Fabricated Metal 

Product 

Manufacturing (NAICS 

332)

31 27 4 $106,508 $9,704 $116,212 $50,718 $4,621 $55,339

Precision Turned 

Product 

Manufacturing (NAICS 

332721)

15 13 2 $51,282 $4,852 $56,134 $24,420 $2,310 $26,730

Machinery 

Manufacturing (NAICS 

333)

10 9 1 $35,503 $2,426 $37,929 $16,906 $1,155 $18,061

Printed Circuit 

Assembly (Electronic 

Assembly) 

Manufacturing (NAICS 

334418)

15 13 2 $51,282 $4,852 $56,134 $24,420 $2,310 $26,730
COST ESTIMATES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 3-9

Industry Sector Facilities Form 

Rs

Form 

As

First 

Year 

Form R 

Cost

First 

Year 

Form A 

Cost

First 

Year 

Total 

Cost

Steady 

State 

Form R 

Cost

Steady 

State 

Form A 

Cost

Steady 

State 

Total 

Cost

Other Electronic 

Component 

Manufacturing (NAICS 

334419)

9 8 1 $31,558 $2,426 $33,984 $15,028 $1,155 $16,183

Aircraft Manufacturing 

(NAICS 336411) 9 8 1 $31,558 $2,426 $33,984 $15,028 $1,155 $16,183

Aircraft Engine and 

Engine Parts 

Manufacturing (NAICS 

336412)

3 3 0 $11,834 $0 $11,834 $5,635 $0 $5,635

Other Aircraft Parts 

and Auxiliary 

Equipment 

Manufacturing (NAICS 

336413)

3 3 0 $11,834 $0 $11,834 $5,635 $0 $5,635

Miscellaneous 

Manufacturing (NAICS 

339)

3 3 0 $11,834 $0 $11,834 $5,635 $0 $5,635

Other Chemical and 

Allied Products 

Merchant Wholesalers 

(NAICS 424690)

6 5 1 $19,724 $2,426 $22,150 $9,392 $1,155 $10,547

Hazardous Waste 

Treatment and 

Disposal (NAICS 

562211)

1 1 0 $3,945 $0 $3,945 $1,878 $0 $1,878

Total 140 126 14 $497,038 $33,964 $531,002 $236,682 $16,171 $252,853

Under the proposed rule, industry is estimated to incur approximately $531,000 in the first year and 

approximately $253,000 in the steady state.

3.1.5 Annualized Cost Estimates

The total cost to industry associated with the proposed rule is annualized over a ten-year period using 

Equation 3-6 below. 

Equation 3-6: Cost Annualization

Annualized Cost = Present Value of Costs ×

r × (1 + r)

10

(1 + r)

10 − 1

Where: 

Present Value of Costs = ∑ Costt ×

1

(1+r)

t

t=10

t=1

and r = 3% or 7%

Ten years is assumed to be a reasonable timeframe for annualization, as greater than forty percent of TRI 

facilities reported every year from reporting year 2004 to reporting year 2013. The annualized cost 

reflects both the first-year costs and steady-state costs presented in Section 3.1.4. Industry costs are 
COST ESTIMATES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 3-10

annualized both at a 3% discount rate and a 7% discount rate,17 resulting in total annualized per-Form R 

costs of $266,317 (3%) and $271,328 (7%), and total annualized per-Form A costs of $18,198 (3%) and 

$18,541 (7%). Total annualized industry costs are presented in Table 3-4.

18

Table 3-4: Total Annualized Industry Cost under the Proposed Rule

Industry Sector Facilities

Form 

Rs

Form 

As

Annualized 

Form R 

Cost 

(3%)

Annualized 

Form A 

Cost 

(3%)

Total 

Annualized 

Cost 

(3%)

Annualized 

Form R 

Cost 

(7%)

Annualized 

Form A 

Cost 

(7%)

Total 

Annualized 

Cost 

(7%)

Commercial Printing 

(except Screen and Books) 

(NAICS 323111)

2 2 0 $4,227 $0 $4,227 $4,307 $0 $4,307

All Other Basic Inorganic 

Chemical Manufacturing 

(NAICS 325188)

3 3 0 $6,341 $0 $6,341 $6,460 $0 $6,460

All Other Basic Organic 

Chemical Manufacturing 

(NAICS 325199)

5 4 1 $8,455 $1,300 $9,755 $8,614 $1,324 $9,938

Artificial and Synthetic 

Fibers and Filaments 

Manufacturing (NAICS 

32522)

1 1 0 $2,114 $0 $2,114 $2,153 $0 $2,153

Paint and Coating 

Manufacturing (NAICS 

325510)

1 1 0 $2,114 $0 $2,114 $2,153 $0 $2,153

Adhesive Manufacturing 

(NAICS 325520) 1 1 0 $2,114 $0 $2,114 $2,153 $0 $2,153

Polystyrene Foam Product 

Manufacturing (NAICS 

326140)

3 3 0 $6,341 $0 $6,341 $6,460 $0 $6,460

Urethane and Other Foam 

Product (except 

Polystyrene) Manufacturing 

(NAICS 326150)

4 4 0 $8,455 $0 $8,455 $8,614 $0 $8,614

Rubber Product 

Manufacturing (NAICS 

3262)

4 4 0 $8,455 $0 $8,455 $8,614 $0 $8,614

Pottery, Ceramics, and 

Plumbing Fixture 

Manufacturing (NAICS 

32711)

1 1 0 $2,114 $0 $2,114 $2,153 $0 $2,153

 

17 Pursuant to guidance issued by the Office of Management and Budget (OMB), federal agencies should take into 

account when costs and benefits will actually occur. Thus, costs and benefits that will accrue in the future must be 

discounted to present day dollars. Further, OMB’s guidance recommends federal agencies use discount rates of three 

and seven percent to estimate a range of average potential returns on investments. More information is available at 

http://www.whitehouse.gov/sites/default/files/omb/assets/omb/circulars/a004/a-4.pdf.

18 The annualization method used assumes that first-year costs are incurred at the end of the first year, and are thus 

discounted. No initial (undiscounted) costs are expected under the proposed rule.
COST ESTIMATES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 3-11

Industry Sector Facilities

Form 

Rs

Form 

As

Annualized 

Form R 

Cost 

(3%)

Annualized 

Form A 

Cost 

(3%)

Total 

Annualized 

Cost 

(3%)

Annualized 

Form R 

Cost 

(7%)

Annualized 

Form A 

Cost 

(7%)

Total 

Annualized 

Cost 

(7%)

Iron and Steel Mills and 

Ferroalloy Manufacturing 

(NAICS 33111)

3 3 0 $6,341 $0 $6,341 $6,460 $0 $6,460

Nonferrous Metal (except 

Aluminum) Production and 

Processing (NAICS 3314)

7 6 1 $12,682 $1,300 $13,982 $12,920 $1,324 $14,244

Fabricated Metal Product 

Manufacturing (NAICS 332) 31 27 4 $57,068 $5,200 $62,268 $58,142 $5,297 $63,439

Precision Turned Product 

Manufacturing (NAICS 

332721)

15 13 2 $27,477 $2,600 $30,077 $27,994 $2,649 $30,643

Machinery Manufacturing 

(NAICS 333) 10 9 1 $19,023 $1,300 $20,323 $19,381 $1,324 $20,705

Printed Circuit Assembly 

(Electronic Assembly) 

Manufacturing (NAICS 

334418)

15 13 2 $27,477 $2,600 $30,077 $27,994 $2,649 $30,643

Other Electronic 

Component Manufacturing 

(NAICS 334419)

9 8 1 $16,909 $1,300 $18,209 $17,227 $1,324 $18,551

Aircraft Manufacturing 

(NAICS 336411) 9 8 1 $16,909 $1,300 $18,209 $17,227 $1,324 $18,551

Aircraft Engine and Engine 

Parts Manufacturing 

(NAICS 336412)

3 3 0 $6,341 $0 $6,341 $6,460 $0 $6,460

Other Aircraft Parts and 

Auxiliary Equipment 

Manufacturing (NAICS 

336413)

3 3 0 $6,341 $0 $6,341 $6,460 $0 $6,460

Miscellaneous 

Manufacturing (NAICS 339) 3 3 0 $6,341 $0 $6,341 $6,460 $0 $6,460

Other Chemical and Allied 

Products Merchant 

Wholesalers (NAICS 

424690)

6 5 1 $10,568 $1,300 $11,868 $10,767 $1,324 $12,091

Hazardous Waste 

Treatment and Disposal 

(NAICS 562211)

1 1 0 $2,114 $0 $2,114 $2,153 $0 $2,153

Total 140 126 14 $266,321 $18,200 $284,521 $271,326 $18,539 $289,865

3.2 EPA Cost Estimates

For the TRI program in general, EPA incurs burden and cost to process TRI forms in five categories of 

activities: data processing, outreach and training, information dissemination, policy and petitions, and 

compliance and enforcement. The estimate of EPA burden and costs is separated into a fixed component 

and a variable component. Activities and expenses that are not greatly affected by marginal changes in 

report quantities are considered fixed costs. These activities and expenses include rent for the EPCRA 

Reporting Center, development costs for data access tools, compliance assistance measures, and other 
COST ESTIMATES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 3-12

activities and expenses listed above. There are no additional fixed costs to the Agency associated with the 

proposed rule. Activities and expenses that vary with marginal changes in the number of reports 

submitted are considered variable costs. The primary variable cost analyzed in this analysis is the cost of 

processing forms. 

As of January 21, 2014, all non-trade secret forms must be submitted electronically. EPA estimates that 

the processing cost for TRI-MEweb submissions is $6.05 per form.19 Therefore, the total form processing 

burden for EPA associated with Form R and Form A chemical submissions under the proposed rule is 

estimated at $847.

3.3 Total Costs

As shown in Table 3-5, the estimated total cost of the proposed rule—the sum of annualized industry 

costs and agency costs—is approximately $285,000 with a 3% discount rate and approximately $291,000 

with a 7% discount rate.

Table 3-5: Summary of Total Costs of the Proposed Rule

Cost Category

Total Cost

(3% Discount Rate, 

2013 Dollars)

Total Cost 

(7% Discount Rate, 

2013 Dollars)

Industry Costs $284,521 $289,865

EPA Processing Costs $847 $847

Total Costs $285,368 $290,712

1 The annual and annualized EPA processing costs are the same as they are assumed constant across the ten year time frame.

 

19 Source: E-mail communication with TRI Data Processing Center, January 10, 2014. 
SMALL ENTITY ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 4-1

4. Small Entity Analysis

This chapter addresses the potential impacts of the proposed rule on small entities. Section 4.1 discusses 

the regulatory requirement for this analysis. Section 4.2 provides the definitions of small entities for the 

industry groups affected by the proposed rule. Section 4.3 describes the methodology used to determine if 

the proposed rule results in a significant economic impact to a substantial number of small entities. 

Section 4.4 summarizes the results of the small entity analysis.

4.1 Impact on Small Entities

The Regulatory Flexibility Act (RFA) of 1980 (5 U.S.C. § 601 et. seq.) requires federal agencies to assess 

the effects of regulations on small entities, including businesses, nonprofit organizations, and 

governments, and, in some instances, to examine alternatives to the regulations that may reduce adverse 

economic effects on significantly impacted small entities. Section 604 of the RFA, as amended by the 

Small Business Regulatory Enforcement Fairness Act (SBREFA) of 1996, requires an agency to perform 

a regulatory flexibility analysis for a rule unless the agency certifies under section 605(b) that the 

regulatory action would not have a significant economic impact on a substantial number of small entities. 

The RFA does not specifically define “a significant economic impact on a substantial number” of small 

entities.

4.2 Definitions of Small Entities

The RFA uses the definition of “small business” found in the Small Business Act, which authorizes the 

Small Business Administration (SBA) to define “small business” by regulation. This analysis uses the 

SBA’s definition of a small business for each industry affected by the proposed rule (U.S. SBA, 2014). 

SBA's small business size definitions vary by industry. In establishing size standards, SBA considers a 

number of economic and market characteristics that may allow a business of concern to exercise 

dominance in an industry. Size standards are based on criteria—such as annual receipts or number of 

employees—that represent a measure of these characteristics. These standards represent the largest size 

that a for-profit enterprise (together with its affiliates) may be and still qualify as a small business.

The SBA small business size standards are expansive, classifying most businesses as “small” (U.S. SBA, 

2014). For example, the smallest SBA size standard for manufacturing industries (NAICS 31-33) is 500 

employees. According to the U.S. Census Bureau’s Statistics of U.S. Businesses, 252,737 of 256,363

manufacturing firms have fewer than 500 employees (U.S. Census Bureau, 2015). Therefore, at least 

98.6% of manufacturing firms are classified as small businesses according to the SBA definition. In fact, 

this percentage is actually higher, since for certain industrial classification codes within the broader 

manufacturing sector, the SBA size standards are greater (750, 1,000, or 1,500 employees). Table 4-1 lists 

the small business size standards for the industries affected by the proposed rule.
SMALL ENTITY ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 4-2

Table 4-1: Small Business Size Standards for Industry Sectors 

Affected by the Proposed Rule

Industry Sector Small Business 

Threshold

Commercial Printing (except Screen and Books) (NAICS323111) 500 Employees

All Other Basic Inorganic Chemical Manufacturing (NAICS325188) 500 Employees

All Other Basic Organic Chemical Manufacturing (NAICS325199) 1,000 Employees

Artificial and Synthetic Fibers and Filaments Manufacturing (NAICS32522) 1,000 Employees

Paint and Coating Manufacturing (NAICS325510) 500 Employees

Adhesive Manufacturing (NAICS325520) 500 Employees

Polystyrene Foam Product Manufacturing (NAICS326140) 500 Employees

Urethane and Other Foam Product (except Polystyrene) Manufacturing 

(NAICS326150) 500 Employees

Rubber Product Manufacturing (NAICS3262) 500 Employees

Pottery, Ceramics, and Plumbing Fixture Manufacturing (NAICS32711) 750 Employees

Iron and Steel Mills and Ferroalloy Manufacturing (NAICS33111) 750 Employees

Nonferrous Metal (except Aluminum) Production and Processing 

(NAICS3314) 750 Employees

Fabricated Metal Product Manufacturing (NAICS332) 500 Employees

Precision Turned Product Manufacturing (NAICS332721) 500 Employees

Machinery Manufacturing (NAICS333) 500 Employees

Printed Circuit Assembly (Electronic Assembly) Manufacturing 

(NAICS334418) 500 Employees

Other Electronic Component Manufacturing (NAICS334419) 500 Employees

Aircraft Manufacturing (NAICS336411) 1,500 Employees

Aircraft Engine and Engine Parts Manufacturing (NAICS336412) 1,000 Employees

Other Aircraft Parts and Auxiliary Equipment Manufacturing (NAICS336413) 1,000 Employees

Miscellaneous Manufacturing (NAICS339) 500 Employees

Other Chemical and Allied Products Merchant Wholesalers (NAICS424690) 100 Employees

Hazardous Waste Treatment and Disposal (NAICS562211) 35,500,000 Dollars

The RFA defines a “small governmental jurisdiction” as the governments of a city, county, town, school 

district, or special district with a population of less than 50,000 people. The RFA defines a “small 

organization” as any “not-for-profit enterprise which is independently owned and operated and is not 

dominant in its field.”

4.3 Methodology Overview

This analysis uses annualized cost impact percentages to measure potential impacts on small parent 

entities that own facilities affected by the proposed rule. The annualized cost impact percentage is defined 
SMALL ENTITY ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 4-3

as annualized compliance costs resulting from the proposed rule as a percentage of annual revenues or 

sales, a commonly available and objective measure of a company’s business volume.

Annualized compliance costs are estimated using ratio-based burden methodology (RBBM).

20 RBBM 

yields a per-form cost estimate that reflects average conditions at reporting facilities in the first year of a 

rule and in the steady state. Pursuant to guidance issued by the Office of Management and Budget 

(OMB), these costs are then annualized at a seven percent discount rate,21 resulting in an annualized perForm R cost of $2,153.40. (For more information on cost annualization, see Section 3.1.5.) Although 

EPA expects that both Forms R and Forms A will be submitted due to the proposed rule, it is not possible 

to determine the distribution of Forms R and Forms A across affected small entities. Therefore, as a 

conservative estimate, only Forms R are considered in the small entity analysis.

As small entity impacts are assessed at the parent entity level, annualized per-form costs are multiplied by 

the number of forms per facility and the number of facilities per parent entity to estimate total annualized 

parent entity compliance costs. Cost impact percentages are calculated for the incremental compliance 

costs incurred as a result of the proposed rule, as shown in Equation 4-1. Where regulatory costs represent 

a small fraction of a typical entity’s revenue, the impacts of the regulation are likely to be minimal.

Equation 4-1: Calculation of Cost Impact Percentages

Annualized Cost Impact Percentage =

Annualized Parent Entity Compliance Cost

Annual Parent Entity Revenue

Where Annualized Parent

Entity Compliance Cost =

Annualized Cost

Per Form ×

Number of Forms

Per Facility ×

Number of Facilities

Per Parent Entity

The general methodology used to estimate impacts on small entities consists of the following steps: 

Step 1: Identify the universe of facilities expected to incur compliance costs due to the proposed rule.

Step 2: Characterize the relationships between these facilities and their ultimate parent entities.22

 

20 See Chapter 3 and Revising TRI Burden to Ratio-Based Methodology (U.S. EPA, 2011b).

21 OMB’s guidance recommends federal agencies use discount rates of three and seven percent to estimate a range of 

average potential returns on investments (more information is available at 

http://www.whitehouse.gov/sites/default/files/omb/assets/omb/circulars/a004/a-4.pdf.). As using a 7% discount rate 

results in higher annualized costs and therefore a more conservative estimate of small entity impacts, only the 7% 

discount rate is used for the small entity analysis. If no impacts are experienced at the 7% level, the same is true for 

impacts at the 3% level.

22 The ultimate parent entity is the uppermost parent or headquarters that encompasses all directly related branches, 

subsidiaries, or parents of a specific business at a specific location. For the purposes of this analysis, “parent entity” 

is synonymous with “ultimate parent entity,” and denotes a ultimate parent company (including parent entities based 

in foreign countries) owning a facility expected to report under the proposed rule; “small parent entity” denotes a 

small ultimate parent entity (as defined by the Small Business Administration or RFA threshold) owning a facility 

expected to report under the proposed rule. 
SMALL ENTITY ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 4-4

Step 3: Estimate annual revenues of parent entities.23

Step 4: Identify small parent entities based on SBA or RFA definitions.

Step 5: Develop annualized compliance cost estimates for small parent entities using the per-facility 

reporting cost and the number of facilities per parent entity that will report to TRI.

Step 6: Calculate the entity-level impact percentages, defined as annualized compliance costs as a 

percentage of annual revenues, to measure regulatory burden.

Step 7: Estimate the number and percentage of small parent entities with entity-level impact 

percentages in each of three categories: (1) less than one percent of annual revenues; (2) between one 

and three percent of annual revenues; and (3) greater than or equal to three percent of annual 

revenues.

The specific methodology applied to facilities whose identities are known and facilities whose identities 

are not known differs slightly from the general methodology above depending on the data available (for 

more information, see Chapter 2). Eight of the facilities expected to report under the proposed rule are 

known, and there are sufficient data available to conduct the small entity analysis as described above 

using actual firm data. The remaining facilities are not known; Census data are therefore used to model 

small entity impacts using a slightly different methodology.

4.3.1 Small Entity Impacts for Known Facilities

Eight of the facilities expected to report under the proposed rule are known. For these facilities, cost 

impact percentages are calculated using estimated compliance costs per facility (based on the number of 

reports the facility is expected to submit), the number of affected facilities per parent entity, and the 

annual revenue of each parent entity. Parent entities are classified as large or small, and impacts to small 

parent entities are summarized.

Identification of Small Parent Entities and Generation of Revenue Data

Each facility’s ultimate parent company was identified using data obtained from Hoover’s, Inc.’s business 

information database (Hoover's Inc, 2014).

24 Hoover’s provides a range of business data including 

number of employees, annual revenue, NAICS code, and the identity of a facility’s parent entity. When 

Hoover’s data were incomplete or outdated, alternative resources such as company websites and annual 

reports were used to obtain missing data. With this information, it is possible to classify parent entities as 

small using the thresholds for the parent entity’s NAICS code.25

Of the eight known facilities, four are owned by small parent entities. No parent entity owns more than 

one known facility.

Compliance costs are calculated at the parent entity level by multiplying the per-Form R cost by the 

estimated number of Form Rs submitted by all facilities expected to report that are owned by that parent 

 

23 Revenues are converted to 2014 dollars using the GDP inflation index (U.S. BEA, 2014). 

24 This analysis assumes that a facility, as defined under TRI, is equivalent to a location as defined by Hoover’s.

25 The small entity determination is made using the NAICS code of the ultimate parent entity rather than the NAICS 

code of the facility subject to TRI. In some cases, the NAICS code of the parent entity is different from the facility’s 

NAICS code.
SMALL ENTITY ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 4-5

entity. As all four small parent entities own only one affected facility, the annualized parent entity 

compliance costs are $2,153.40 per parent entity at the 7% discount level.

Estimation of Cost Impact Percentages

Cost impact percentages for small parent entities are calculated by dividing annualized parent entity

compliance costs by the parent entity’s annual revenue. The estimated impacts on small parent entities are 

presented in Table 4-2 below. Of the small parent entities identified, all have annualized cost impacts of 

less than 1%.

Table 4-2: Small Entity Impacts for Known Facilities

Known 

Facilities

Parent 

Entities

Small Parent 

Entities

Small Parent Entities Incurring Annualized 

(7%) Cost Impacts of...

<1% 1% to 3% >3%

8 8 4 4 0 0

4.3.2 Small Entity Impacts Analyzed using Census Data

As only a small number of facilities are expected to report in many of the affected industry sectors, an 

analysis that distributes affected facilities across size categories in the Census data results in fractional 

facilities for many or all size categories, which makes analyzing impacts to affected facilities difficult. 

Evaluating the average revenue for all small parent entities in each sector may overlook impacts to the 

smallest affected facilities in a sector. This analysis therefore uses Census data to screen for small entity 

impacts under a “worst-case scenario” for facilities whose identity is not known.

Census’ Statistics of U.S. Businesses (SUSB) provides annual data for U.S. business enterprises, 

including counts of establishments, firms, employees, and payroll. Data on total receipts (revenues) are 

also provided by SUSB every five years. These data are available for each NAICS code and are tabulated 

by enterprise employment or enterprise revenue (U.S. Census Bureau, 2007). SUSB data tabulated by 

enterprise revenue are used to estimate the proportion of small parent entities incurring cost impacts 

greater than 1% or 3%.

SUSB defines an enterprise as “a business organization consisting of one or more domestic 

establishments that were specified under common ownership or control,” a firm as “a business 

organization consisting of one or more domestic establishments in the same industry that were specified 

under common ownership or control,” and an establishment as “a single physical location where business 

is conducted or where services or industrial operations are performed” (equivalent to TRI’s definition of a 

facility). For the purposes of this analysis, it is assumed that the SUSB concept of an enterprise is 

equivalent to the concept of ultimate parent company used in this small entity analyses.

As facilities are only required to report to TRI if the employment threshold of 10 full-time employees is 

met, the SUSB employment size category for 10 to 14 employees can be used to calculate average 

revenue for the smallest SUSB category of potentially affected parent entities.

If annualized cost impacts can be demonstrated to be less than 1% for an average parent entity with 10 to 

14 employees, it follows that larger firms will also not experience adverse economic impacts as a result of 

the proposed rule. 
SMALL ENTITY ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 4-6

This analysis consists of the following steps:

Step 1: Select industry sectors expected to incur compliance costs due to the proposed rule for 

analysis.

Step 2: Estimate annualized compliance cost.

Step 3: Calculate the revenue at which a small parent entity incurs an impact of 1% or 3% (“impact 

thresholds”) for each sector.

Step 4: Calculate average parent entity revenue for parent entities with 10 to 14 employees (the 

smallest employment size category subject to TRI reporting requirements).

Step 5: Determine if impacts 1% or greater and/or 3% or greater are incurred by the average parent 

entity.

Impact thresholds are calculated by dividing the annualized compliance cost by 1% and 3%; Table 4-3

displays the 1% and 3% impact thresholds. Note that due to the low annualized compliance costs 

associated with the proposed rule, a parent entity would need to have extremely small annual revenues to 

incur impacts of 1% or greater. Additionally, for all industry sectors, there is a maximum ratio of 1.08 

establishments to firms for parent entities with 10 to 14 employees. This ratio indicates that for the 

purposes of this analysis, the facility is equivalent to the parent entity; aggregating compliance costs is 

therefore unnecessary.

Table 4-3: Impact Thresholds

Impact Level Revenue Threshold

1% $215,340

3% $71,780

SUSB data are used to calculate average parent entity-level revenues for small parent entities in each 

sector. These average revenues represent the revenues of the “average parent entity” in the smallest size 

category subject to TRI reporting requirements (i.e., parent entities with 10 to 14 employees), and are 

compared to the impact thresholds to determine if small parent entities in the industry sector are expected 

to incur impacts of 1% or greater and/or 3% or greater. The results of this screening analysis are presented 

in Table 4-4.

Table 4-4: Small Entity Screening Analysis

Industry Sector

Average Revenue 

for Firms with 10-

14 Employees

10-14 

Employees: 

1% Impact

10-14 

Employees: 

3% Impact

Commercial Printing (except Screen and Books) (NAICS 

323111) $1,821,393 No No

All Other Basic Inorganic Chemical Manufacturing 

(NAICS 325188) $4,751,084 No No
SMALL ENTITY ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 4-7

Industry Sector

Average Revenue 

for Firms with 10-

14 Employees

10-14 

Employees: 

1% Impact

10-14 

Employees: 

3% Impact

All Other Basic Organic Chemical Manufacturing (NAICS 

325199) $6,898,515 No No

Artificial and Synthetic Fibers and Filaments 

Manufacturing (NAICS 32522) $4,826,422 No No

Paint and Coating Manufacturing (NAICS 325510) $3,380,561 No No

Adhesive Manufacturing (NAICS 325520) $4,340,082 No No

Polystyrene Foam Product Manufacturing (NAICS 

326140) $3,233,813 No No

Urethane and Other Foam Product (except Polystyrene) 

Manufacturing (NAICS 326150) $1,698,415 No No

Rubber Product Manufacturing (NAICS 3262) $1,939,871 No No

Pottery, Ceramics, and Plumbing Fixture Manufacturing 

(NAICS 32711) $1,327,550 No No

Iron and Steel Mills and Ferroalloy Manufacturing 

(NAICS 33111) $3,379,168 No No

Nonferrous Metal (except Aluminum) Production and 

Processing (NAICS 3314) $5,873,570 No No

Fabricated Metal Product Manufacturing (NAICS 332) $1,856,902 No No

Precision Turned Product Manufacturing (NAICS 

332721) $1,715,492 No No

Machinery Manufacturing (NAICS 333) $2,232,924 No No

Printed Circuit Assembly (Electronic Assembly) 

Manufacturing (NAICS 334418) $2,511,505 No No

Other Electronic Component Manufacturing (NAICS 

334419) $1,711,600 No No

Aircraft Manufacturing (NAICS 336411) $2,049,247 No No

Aircraft Engine and Engine Parts Manufacturing (NAICS 

336412) $2,404,672 No No

Other Aircraft Parts and Auxiliary Equipment 

Manufacturing (NAICS 336413) $2,241,999 No No

Miscellaneous Manufacturing (NAICS 339) $1,725,146 No No

Other Chemical and Allied Products Merchant 

Wholesalers (NAICS 424690) $8,634,977 No No

Hazardous Waste Treatment and Disposal (NAICS 

562211) $2,056,548 No No

The average revenue for parent entities with 10 to 14 employees is greater than the 1% or 3% impact 

threshold. For all industry sectors, there is a maximum ratio of 1.08 establishments to firms for parent 

entities with 10-14 employees. This ratio indicates that for the purposes of this analysis the facility is 
SMALL ENTITY ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 4-8

equivalent to the parent entity; aggregating compliance costs is therefore unnecessary. No small parent 

entities are expected to incur annualized cost impacts greater than 1%.

Sensitivity Analysis: Impacts to the Smallest Parent Entities

To model impacts to the smallest parent entities subject to TRI reporting requirements, an alternate small 

parent entity revenue for the smallest parent in each affected NAICS code is estimated by calculating the 

minimum cost of employing ten full-time employees (termed MCOE10). The assumption that parent 

entity revenues are equal to MCOE10 implies that the firm has no non-labor costs and earns zero business 

profits, instead only recouping the costs of labor. As such, this assumption is likely to underestimate 

revenues and overstate potential impacts. 

MCOE10 is calculated for each relevant 3- or 4-digit NAICS code26 associated with the industry sectors 

identified in Table 4-4 using the average hourly wage rate for all occupational categories in each industry

(U.S. Bureau of Labor Statistics, 2014a).

27 Note that this wage rate reflects wages for all workers in the 

industry, whereas WAWR reflects wages for the specific occupations involved in complying with TRI 

reporting requirements. The average hourly rate is loaded to include benefits (calculated as 43.15% of 

wages for all workers in private goods-producing and service-providing industries (U.S. Bureau of Labor 

Statistics, 2014c)) and overhead (assumed to be 17% of hourly wages, as in the calculation of WAWR).

As in the screening analysis, parent entities are assumed to be equivalent to facilities given the low 

establishment-to-firm ratio in the SUSB data (a maximum of 1.08 for parent entities with 10-14

employees in the affected NAICS codes). Each parent entity is therefore expected to submit only one 

Form R. As shown in Table 4-5, even the smallest possible parent entity in each potentially affected 

NAICS code is not expected to incur impacts above 1% of revenues. In order for a parent entity to incur 

impacts of 1% under these assumptions, the loaded hourly wage paid to employees would need to be 

$10.35; for a 3% impact, the loaded hourly wage would need to be only $3.45.28

Table 4-5: Small Entity Screening Analysis: Sensitivity Analysis

NAICS Code Loaded Hourly 

Wage MCOE10 MCOE10: 1% Impact

MCOE10: 3% 

Impact

3231 $33.08 $687,974 No No

3251 $49.63 $1,032,380 No No

3252 $45.87 $954,163 No No

3255 $40.63 $845,037 No No

3261 $31.47 $654,541 No No

3262 $32.69 $679,982 No No

3271 $31.43 $653,698 No No

3311 $39.37 $818,964 No No

 

26 BLS provides wage data for all 3- and 4-digit NAICS codes and selected 5- and 6-digit NAICS codes. None of the 

NAICS codes affected by the proposed rule have data at the 5- or 6-digit level, so the 3- or 4-digit NAICS code level 

is used.

27 Wages are converted to 2014 dollars using the GDP inflation index (U.S. BEA, 2014).

28 For a 1% impact: $215,340 ÷ (2,080×10) = $10.35. For a 3% impact: $71,780 ÷ (2,080×10) = $3.45.
SMALL ENTITY ANALYSIS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 4-9

3314 $37.87 $787,637 No No

332 $34.50 $717,619 No No

3327 $34.39 $715,305 No No

333 $39.79 $827,587 No No

3344 $51.76 $1,076,534 No No

3364 $56.46 $1,174,307 No No

339 $37.09 $771,446 No No

4246 $45.50 $946,383 No No

5622 $40.04 $832,842 No No

4.4 Summary of Impacts to Small Parent Entities

The 140 facilities expected to report were linked to a maximum of 136 small parent entities (four of the 

eight known facilities were determined to be large parent entities). All of the small parent entities affected 

by the proposed rule are estimated to incur annualized cost impacts of less than 1%. Table 4-6

summarizes the results of the small entity analysis.

Table 4-6: Summary of Small Entity Analysis

Facilities

Potential 

Parent 

Entities

Potential Small 

Parent Entities

Small Parent Entities Incurring Annualized 

(7%) Cost Impacts of...

<1% 1% to 3% >3%

140 140 136 136

(100%)

0

(0%)

0

(0%)

As all small entities are estimated to incur impacts of less than 1%, the proposed rule is not expected to 

significantly impact a substantial number of small entities.
BENEFITS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 5-1

5. Benefits

In enacting the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 and the 

Pollution Prevention Act (PPA) of 1990, Congress recognized the significant benefits of providing 

information on the presence, releases and waste management of toxic chemicals. The Toxics Release 

Inventory (TRI) has proven to be one of the most powerful forces in empowering the federal government, 

state and local governments, industry, environmental groups, and the general public to fully participate in 

an informed dialogue about the environmental impacts of toxic chemicals in the United States. The TRI 

database provides several types of information, including quantitative information on toxic chemical 

releases and other waste management practices. Starting in 1987, the collection of this information 

enhanced the ability for the public, government, and the regulated community to understand the breadth 

and magnitude of chemical releases in the United States, and to assess the need to reduce the releases and 

transfers of toxic chemicals. TRI data enable all interested parties to establish credible baselines, to set 

realistic goals for environmental progress, and to measure progress in meeting these goals over time. As 

such, the TRI Program has become a yardstick by which progress can be measured by all interested or 

affected stakeholders. 

The information reported to TRI increases community knowledge and awareness of quantities of toxic 

chemicals released to the environment, and potential pathways of exposure to those chemicals. This 

knowledge:

 Improves scientific understanding of the health and environmental risks of toxic chemicals; 

 Allows the public to make informed decisions on where to work and live; 

 Enhances the ability of corporate leaders and purchasers to more accurately gauge a facility’s 

potential environmental liabilities; 

 Provides reporting facilities with information that can be used to save money as well as reduce 

emissions; and,

 Assists federal, state, and local authorities in making better decisions on acceptable levels of toxic 

chemicals in the environment.

The benefits of the proposed rule include improved understanding, awareness, and decision making 

related to the provision and distribution of information on releases and waste management of 1-BP. This 

provision of information can lead to follow-on activities that create additional costs and benefits. In 

particular, voluntary initiatives by industry to review production processes, set goals for reductions in 

emissions, and institute “good neighbor” policies may result from information provision. If an individual 

facility owner or operator perceives that the additional information generated to comply with the section 

313 reporting requirements provides them with valuable information about their operations and how they 

might be modified, then changes may be implemented to reduce releases of TRI chemicals. 

Making TRI information available to the public may provide incentives for facilities to reduce TRI 

chemical releases. For example, the public availability of release information may induce facilities to 

reduce releases when such changes would not be in the facility’s interest if release information were not 

in the public domain. Potential social benefits derived from voluntary follow-on activities include 

decreased costs of waste treatment and disposal, lower probability of accidental releases and lower clean-
BENEFITS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 5-2

up costs in the event of such releases, reduced contamination of natural resources, improved air and water 

quality, and reduced risks to human health. Such social benefits are partially offset by the social costs to 

implement the changes, such as installing scrubbers and substituting materials that are less toxic but more 

expensive. The net social benefits of the information provided by the proposed rule and the possible 

follow-on activities equal the difference between the total benefits and the total costs of the activities 

leading to reduced releases.

The potential benefits of additional TRI reporting can be understood by examining the ways in which 

different groups of affected stakeholders—consumers, industry, governments and the general public—use 

TRI data. Consumers may use the data to make more informed decisions about the products they buy and 

to enter into constructive dialogue with firms in their communities that release 1-BP. Facilities may find 

opportunities for waste reduction and cost savings through the process of obtaining reporting data. Nonfederal governments may use the data in lieu of, or in support of, their own environmental protection 

activities. Non-users of the TRI data benefit from its public provision whenever others’ use of the data 

results in improvements in environmental quality.

Some examples of the ways in which various stakeholders have utilized TRI data include: 

 Use of the Data by Community and Public Interest Groups: Communities use TRI data to begin 

dialogues with local facilities and to encourage them to reduce their emissions, develop pollution 

prevention plans, and improve safety measures. Public interest groups use the data to educate the 

public about toxic chemical emissions and potential risk, and in environmental justice activities.

 Use of the Data by Education and Research Institutions: TRI data are being used in many 

environmental education programs, particularly at the high school and university levels. Students 

learn about toxic chemical releases, the potential health and environmental effects of those 

releases, pollution prevention activities and opportunities, and the social and political aspects of 

environmental protection. Some organizations also are conducting educational outreach programs 

using TRI data. 

 Use of the Data by the Financial and Business Communities: Investment analysts use TRI data to 

provide recommendations to clients seeking to make environmentally sound investments. 

Insurance companies look to TRI data as one indication of potential environmental liabilities. 

Consultants and others use the data to identify business opportunities, such as marketing pollution 

prevention and control technologies to TRI reporting facilities. Demand for environmental 

performance information by investors, insurance companies, and the public has led many 

companies to develop environmental annual reports similar to annual reports on financial 

performance traditionally prepared for investors.

 Industry Use of TRI Data: TRI data have been used by industry for activities such as developing 

waste reduction strategies and improving companies’ understanding of their own production 

processes. Industry also uses TRI submission information to show environmental progress and as 

a starting point for engaging with communities. 

 Government Use of TRI Data: Government organizations such as the media-specific and core 

offices at EPA, EPA Regional offices, and other national, state, and local government agencies 

routinely use TRI data. TRI data have been used to: develop inspection targeting and enforcement 

tools; analyze and prioritize long-term trends in waste minimization; identify candidates for the 
BENEFITS

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 5-3

National Primary Drinking Water Regulations; coordinate environmental data internationally 

through agreements and organizations such as the Commission for Environmental Cooperation; 

and set priorities and allocate increasingly scarce environmental protection resources to the most 

pressing problems.

EPA has not attempted to monetize the benefits of the proposed rule due to the lack of quantitative 

information characterizing the range of users and non-users of TRI data and the substantial analytical 

challenges associated with accurately predicting behavioral responses to the provision of information

(Palm, 1981; Moody et al., 1999). The analysis was not able to consider variations in quality or other 

attributes of TRI data access methods. The potentially large numbers of beneficiaries who are not users or 

who are otherwise unaware of the data (e.g., the general public) further limits EPA’s ability to quantify 

potential benefits.

The experience since the first forms were submitted to TRI in 1987 suggests that reporting under EPCRA 

section 313 has produced real gains in understanding communities’ exposure to toxic chemicals. In its 

report The Toxics Release Inventory in Action: Media, Government, Business, Community and Academic 

Uses of TRI, EPA has documented numerous examples of how multiple stakeholders have used TRI data

(U.S. EPA, 2013b). Moreover, a cursory search on GoogleScholarTM reveals thousands of academic 

articles referencing the Toxics Release Inventory. Listing 1-BP, and the subsequent use of the reported 

information, should provide similar gains in understanding of this particular chemical. EPA believes that

1-BP meets the statutory toxicity criteria of section 313, and is at least as toxic as some of the chemicals 

for which Congress initially believed there were net benefits due to reporting (i.e., the initial list of section 

313 chemicals).
REFERENCES

Economic Analysis of Proposed Addition of 1-Bromopropane ▌pg. 6-1

6. References

Abt Associates. (July 16, 2004). Abt Associates Engineering Study (TRI Reporting Burden Estimates).

Memo from Hilary Eustace, David Cooper, and Susan Day, Abt Associates to Paul Borst, EPA.

Abt Associates. (November 8, 2013). Memorandum: Percent 1-Bromopropane in Formulation by Uage.

Albatross USA. (2004). Material Safety Data Sheet VDS-3000- Stabilized N-Propyl Bromide. Retrieved 

November 6, 2013, from http://albatrossusa.com/pdf/elecchemmsds/AlbatrossVDS3000MSDS.pdf

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