Revising TRI Burden to Ratio-Based Methodology 

Information Collection Request Renewal (ICR) 2nd FR Notice 

April 28, 2011 

TRI Regulatory Development Branch 

TRI Program Division 

Office of Information Analysis and Access 

Office of Environmental Information 
ii

Authors 

EPA

Laura B. Nielsen, Ph.D. 

Kara Koehrn 

Andrew Prugar 

Zachary Scott 

Esmeralda Stuk 

Abt Associates Inc.

Susan Day 

Svetlana Semenova 

Rebecca Fink 
iii

Table of Contents 

Abstract iv

Acknowledgment v

Introduction 1

Overview 1

TRI Program Burden Estimate Requirements and Uses 4

Background Research: Relevant History and Methodology Comparisons 5

Ratio-Based Burden Methodology, Methods, and Models 9

Benefits 12

Appendix A. Methodology Overview and Guide to Methods Technical 

 Appendices (B-E) A-1 to A-18 

Appendix B. Steady State Total Burden Calculation B-1 to B-26 

Appendix C. Form Element Estimation C-1 to C-16 

Appendix D. First-Time Filer Estimation D-1 to D-4 

Appendix E. Cost Conversion E-1 to E-6 

Appendix F. Program Staff Tool F-1 to F-8 

Appendix G. Abt Associates Engineering Studies G-1 to G-64 

Appendix H. Peer Review Information H-1 to H-4 
iv

Abstract

The TRI Program Division is proposing to revise the TRI burden methodology to a Ratio-Based 

Burden Methodology (RBBM) to boost efficiency and sharpen transparency. Through 

simplifications, internal consistency, and better access, EPA staff and the general public will 

obtain faster, more reliable, and more understandable burden estimates for a variety of uses. The 

TRI Program Division envisions implementing this methodology in the 2012 ICR Renewal. 

Thereafter, the methodology will also be employed in economic analyses associated with TRI 

rulemakings. 

RBBM simplifies calculations and imposes internal consistency while maintaining the overall 

total Program burden estimate as a starting point. The revised structure consists of four ratio 

models plus one base number, the Nominal Form R unit burden. The ratio models characterize 

key relationships of TRI burden estimation. For example, the A/R model, a ratio of Form A 

(single-chemical) to Form R burden, ensures internal consistency between Form A and Form R 

burden estimates. The Nominal Form R unit burden provides a comprehensive unit burden of 

35.7 hours per Form R and consequently also supports focused discussions about burden 

estimate accuracy. 

TRI’s burden estimates comply with Paperwork Reduction Act (PRA) requirements for 

providing burden estimates, “to the extent practicable,” while reflecting a reasonable sense of 

average conditions and an appropriate level of specificity. The activities included in burden 

estimates are the same in RBBM as under the previous methodology. For activities associated 

with filing TRI Form R/Form A chemical reports, burden estimates include: rule familiarization, 

compliance determination, calculations and Form completion, and recordkeeping and 

submission. For activities unrelated to Form reporting, burden estimates include: supplier 

notification, non-reporter compliance determination, and petitions.

As a result of RBBM’s simplicity, internal consistency, and accessibility, the TRI Program 

Division anticipates that staff will need to spend less time and effort developing TRI information 

collection burden information. In addition, ease of re-creating estimates supports administrative 

consistency, while improved access to calculations affords greater transparency. 
v

Acknowledgment 

The authors thank the following colleagues who provided a fresh perspective in their informal 

reviews of portions, or of the entire draft, at various stages of document development. 

Rachel Alford 

Daniel Bushman, Ph.D. 

Louise Camalier 

Constance Downs 

Olga Faktorovich 

Thomas Forbes, Ph.D. 

Gregory Nielsen 

Barry Nussbaum, D.Sc. 

Cody Rice 

Denice Shaw, Ph.D. 

Daniel Teitelbaum 
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Introduction

The purpose of this document is to provide technical explanation and documentation for the 

Ratio-Based Burden Methodology (RBBM), as currently proposed for use in the Toxics Release 

Inventory (TRI) Program. In addition, EPA explains how RBBM will be able to provide 

improvements in efficiency, administrative consistency, and transparency. EPA begins with an 

overview of the methodology, followed by background information, and research comparing 

burden estimate methodologies. EPA then explains the RBBM approach, including quantitative 

details of its constituent methods, such as the Steady State Total Burden Calculation (page 10). 

Lastly, EPA presents the benefits of using RBBM. Appendices A-E supplement the main body 

of the report. More specifically, EPA provides an overview of the methodology in Appendix A, 

followed by technical appendices for each of the constituent methods: Steady State Total Burden 

Calculation, Form Element Estimation, First-Time Filer Estimation, and Cost Conversion 

(Appendices B-E, respectively). 

Additional appendices F-H are provided as reference material. Appendix F depicts the Program 

Staff Tool, a Microsoft Excel spreadsheet which is designed to provide a user-friendly interface 

for generating burden estimates. Appendix G provides the Abt Associates Engineering Studies, 

which provide previously developed detailed data element-specific burden estimates used as the 

building blocks for RBBM’s ratio models. Appendix H summarizes the May 2010 peer review of 

an earlier draft of this document. Also useful for reference are: 1) the Form R and Form A ICR 

Supporting Statements1

 from the 2008 TRI ICR, and 2) the Form R and Form A ICR Supporting 

Statement2

 for the ICR slated in 2012, which illustrate the existing and revised methodologies, 

respectively. The latter item is being published concurrently with this document (originally and 

with this revised version). 

Overview 

Ratio-Based Burden Methodology (RBBM) simplifies calculations, establishes internal 

consistency, and sharpens transparency while retaining the components of the existing 

methodology and maintaining the overall total Program burden estimate as a starting point. EPA 

initiated this methodology revision due to its experience with Information Collection Request 

(ICR) renewals and rulemaking economic analyses (EAs) that were particularly complex and/or 

performed under tight time constraints. In less formal settings, additional ideas for characterizing 

burden emerged from staff experiences while generating burden estimates. Consequently, EPA 

sought improvements on the current approach, as guided by two key questions: 1) What is the 

simplest and easiest way to calculate burden? and 2) How can EPA best provide clearly defined 

and consistent estimates? 

The current methodology for estimating burden hours and cost is based on a system of 96 factors 

organized into four categories as shown in Figure 1. There are 96 total factors because for each 

of the four categories—persistent bioaccumulative and toxic (PBT) first year, PBT subsequent 

1 Toxics Release Inventory (TRI) Form R Toxic Chemical Release Reporting Information Collection Request Supporting Statement. EPA ICR 

#1363.15. March 02, 2008. and Toxics Release Inventory (TRI) Alternate Threshold For Low Annual Reportable Amounts; TRI Form A Toxic 

Chemical Release Reporting Information Collection Request Supporting Statement. EPA ICR # 1704.09. March 2, 2008. Docket #EPA-HQ-TRI2007-0355. 

2 Toxics Release Inventory (TRI) Form R and Form A Toxic Chemical Release Reporting Information Collection Request Supporting Statement. 

EPA ICR#1363.21. OMB Control No. 2025-0009. Date Forthcoming. Docket # EPA-HQ-OEI-2010-0835; hereafter referred to as TRI 2012 ICR 

Supporting Statement. 
Revising TRI Burden to Ratio-Based Methodology 

year, nonPBT first year, nonPBT subsequent year—there are 12 factors (two for each facilitylevel and form-level, estimated across three labor categories—managerial, technical and 

clerical). Taking those 12 factors across four categories and two Forms (R and A) yields this 

total of 96 factors. For each category’s set of factors, such as Form R non-PBT subsequent year 

unit burdens, a relevant subpopulation TRI chemical count must be provided – for example, the 

number of subsequent year non-PBT Form R chemicals. The factors in Figure 1 are referred to as 

OMB-approved, as these unit burdens are officially approved by the Office of Management and 

Budget (OMB) for use in estimating TRI Program burden as of March 27, 2008. 

Figure 1 

Current Methodology Complexity: Numerous Burden Factors and Chemical Counts

In developing RBBM, EPA decided to restructure this system for several reasons: 1) calculations 

could be greatly simplified via algebraic reduction, 2) relationships between interrelated 

categories could be specified via ratio models to remove potential internal inconsistencies, 

3) multiple scales could be unified to prevent certain accounting errors caused by doublecounting (i.e., facility-level converted to form-level factors).3

Table 1 provides a structural comparison between the existing methodology and RBBM as 

applied to Form R burden.4

 Note that RBBM consolidates PBT factors and first-year factors 

within the base “Form R unit burden” to yield one unit burden instead of multiple unit burdens. 

Moreover, this single unit burden is comprehensive and thus incorporates all activities (e.g. rule 

familiarization, form completion, etc.) which contribute to the burden of Form R reporting. 

 

3

Under the existing methodology, the double-counting potential exists due to the facility-level unit burdens in two situations 1) via the structure 

by which Form A and Form R reporting is estimated separately with both estimates counting facility burden 2) the rulemaking context in which 

additional reports are added from facilities that already handle facility level burden regardless of the changes imposed by the rule. Both these 

sources of error are prevented in RBBM. 

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4

 The same comparison applies for Form A, but is omitted for ease of presentation. 
Revising TRI Burden to Ratio-Based Methodology 

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Therefore, in addition to requiring fewer unit burdens (with fewer subpopulations to track), 

RBBM’s comprehensive unit burden permits the estimation of total burden by simply 

multiplying just one unit burden by the total number of chemicals. In this case, total “Form R 

burden” can be estimated by “Form R unit burden” multiplied by the “number of Form R 

chemicals.” 

Table 1: Burden Methodology Calculation Factors and Unit Burdens – Form R 

Current Burden via Existing Methodology Steady State Burden via RBBM 

Estimate Description: Sum the numerous products of 

factors multiplied by chemical counts or facilities 

(depending on the scale of the factor). 

Estimate Description: multiply the 

comprehensive unit burden by total 

number of chemicals. 

Estimation Factors

Per (chemical) form-level: 

• hrs per PBT, subsequent year, 

• hrs per PBT, first year 

• hrs per non-PBT, subsequent year 

• hrs per non-PBT, first year 

per facility-level: 

• hrs for PBT and non-PBT, subsequent year 

• hrs for PBT and non-PBT, first year 

Estimation Factor

Per (chemical) form-level: 

• hrs per chemical* 

Reported Unit Burdens

(do not include related facility-level burden) 

Î 29.66 hrs per Form R non-PBT (subsequent year) 

Î 53.34 hrs per Form R PBT (subsequent year) 

Reported Unit Burden

Î 35.7 hrs per Form R 

* Incorporates all the same considerations as the existing methodology. Simplifications are detailed in the 

Ratio-Based Burden Methodology, Methods and Models Section (p.9). See also Appendix B. 

Focusing on RBBM information in Table 1 to present the total burden estimate, Figure 2 

provides the Steady State Total Burden Calculation, RBBM’s primary method. Steady State 

Total Burden is the estimate of the ongoing TRI Program burden, as updated by rulemakings’ 

permanent impacts, but absent any first-time filer impacts. Note that the only inputs required for 

this estimate are the total counts of Form R and Form A chemicals. Next, EPA describes the key 

factors within RBBM’s reformulated structure. 

The Nominal Form R unit burden is the unit burden for Form R. As a component of RBBM, it 

provides the base number for the entire methodology. For the transition to RBBM, its value is 

back-calculated in order to maintain the established baseline’s total burden. In practice, the 

Nominal Form R unit burden provides the primary focal point for assessing and maintaining 

RBBM’s accuracy. 

Form A unit burden is defined as Nominal Form R unit burden multiplied by A/R, a model of the 

ratio of Form A single-chemical burden5

 to Form R burden. The value for A/R is derived by 

assessing the Form R burden for activities similarly required to complete a Form A. A/R

 

5

 Although Form A permits multiple chemical reports on the same form (on average 2.31 chemicals per Form A), for purposes of methods 

development and modeling, EPA works with chemical counts, referring to “Form R chemicals” and “Form A chemicals.” Note that for Form R 

reporting, there is only one chemical per Form. 
Revising TRI Burden to Ratio-Based Methodology 

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specifies the relationship between Form A and Form R burden.6

 The examples in Table 1 and 

Figure 2 illustrate that RBBM incorporates the same components of the existing methodology, 

but offers a much simpler formulation. Furthermore, the use of ratio models such as A/R ensures 

internal consistency within the new structure. 

Figure 2 

Ratio-Based Burden Methodology 

Two Unit Burdens; Two Chemical Counts; One Wage Rate 

Steady State Total Burden Calculation

1) Steady State Total Burden = Form R Burden + Form A Burden + Non-Form Burden 

Where: 

Form R Burden = (# Form R Chemicals) * (Nominal Form R Unit Burden) 

Form A Burden = (# Form A Chemicals) * (A/R) * (Nominal Form R Unit Burden) 

Non-Form Burden 

 = (Supplier Notification) + (Non-Reporter Compliance Determination) + (Petitions) 

And: 

A/R, Ratio of Form A Burden to Form R Burden = 0.615 

Nominal Form R Unit Burden = 35.7 hours per Form R Chemical 

Form A Unit Burden (derived) = 22.0 hours per Form A Chemical 

2) Steady State Total Cost = Steady State Total Burden * (WAWR) 

And: 

WAWR, Weighted Average Wage Rate = $49.62/hour†

†

 Based on June 2010 wage data. Wage data: http://www.bls.gov/ncs/ect/#tables 

TRI Burden Estimate Requirements and Uses

Under the Emergency Planning and Community Right to Know Act (EPCRA), the TRI Program, 

as authorized under Section 313, requires reporting facilities to submit data annually on use and 

management of toxic chemicals. As part of EPA’s responsibilities to the public under the 

Paperwork Reduction Act (PRA), EPA must regularly satisfy requirements that permit 

information collection from members of the general public, including industry participants in the 

TRI reporting community. One of these requirements is to ensure that each information 

collection exercise “...informs the person receiving the collection of information of—...(III) an 

estimate, to the extent practicable, of the burden of the collection.”7

 Burden estimates encompass 

“...the total time, effort, or financial resources expended by persons to generate, maintain, retain, 

disclose, or provide information to or for a federal agency.” These estimates should consider 

time needed to: 8

 

6

 The bases for A/R include detailed burden estimates by task, making the A/R model verifiable and readily subject to validation. See Appendix B 

for development and Appendix G for detailed burden estimates by task. 7

 US National Archives and Records Administration, Paperwork Reduction Act of 1995, Accessed 23 Mar 2010 < 

http://www.archives.gov/federal-register/laws/paperwork-reduction/3506.html > 8

 See EPA. 1999. ICR Handbook: EPA’s Guide to Writing Information Collection Requests Under the Paperwork Reduction Act of 1995.

Accessed 2 Feb 2010 < http://www.epa.gov/wed/pages/opportunities/icrhndbk.pdf> 
Revising TRI Burden to Ratio-Based Methodology 

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• Review instructions; 

• Develop, acquire, install, utilize technology and systems, for the purpose of 

collecting, validating and verifying information, processing and maintaining 

information, and disclosing and providing information; 

• Adjust the existing ways to comply with any previously applicable instructions 

and requirements; 

• Train personnel to be able to respond to a collection of information; 

• Search data sources; 

• Complete and review the collection of information; and 

• Transmit or otherwise disclose the information. 

For the TRI Program, these considerations translate to factors that reflect industry efforts 

associated with form burden—rule familiarization, compliance determination, calculations and 

form completion, recordkeeping, and non-form burden—supplier notification, non-reporter 

compliance determination, and petitions. 

The TRI Program uses burden estimates in the context of three main types of Program activities: 

ICR renewal, rulemaking economic analyses, and informal informational gathering. At the time 

of the ICR renewal, which is performed every three years, EPA’s TRI Program must update the 

burden estimates that OMB has on record for the current burden associated with TRI reporting. 

The Supporting Statement for the ICR renewal provides estimates of the program’s ongoing 

burden—or steady state total burden—in labor hours, and cost in current dollars. These estimates 

are obtained based on actual conditions as measured in the most recent TRI reports.9

 

In the context of a rulemaking, the economic analysis provides burden estimates in order to 

predict the impact of the policy change(s) under consideration. Upon policy implementation, this 

estimated incremental change in burden is added or subtracted from the current burden estimate 

that OMB has on record. If the rulemaking increases the number of reporters or otherwise 

imposes reporter start-up burden, the economic analysis also provides estimates of first-time filer 

burden incurred during the first year of a policy change. Note that economic analysis estimates, 

both steady state and first-time filer, are based on models—not actual conditions. If there are 

differences between the economic analysis predictions and the actual conditions, these 

differences are implicitly reconciled at the next ICR renewal as the ICR is based on actual 

reporting of Form R and Form A chemicals.10

Background Research: Relevant History and Methodology Comparisons 

The information in this section provides background in preparation for presenting more detail 

about RBBM in the next section. The methodology history explains how the TRI Program 

9

 Estimates based on actual conditions contrast to estimates based on model projections. Note that in the event that the TRI program implements 

policy changes due to a rulemaking finalized in the course of the year of the ICR renewal project, the ICR renewal burden estimates are updated 

using more current information and/or models. 10 For example, when new policy permits decreases in reporting that are not fully utilized, the economic analysis may predict a reduction in 

reporting, while the ICR measures the actual reporting at levels higher than originally modeled/anticipated. 
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burden methodology has evolved. Methodology comparisons show that EPA’s existing and 

revised methodologies fit within the range of currently accepted practices.11 

Methodology History 

Under the existing methodology, EPA calculates total industry burden estimates using a 

methodology established at the TRI Program inception that has since been periodically reviewed 

and approved by OMB during ICR renewals. For example, as the program underwent changes in 

reporting—such as implementing the shorter Form A—the methodology underwent reviews and 

occasional revisions. Beyond minor adjustments to include additional form elements, the biggest 

revision occurred in the 2004 ICR Renewal when changes to the system of unit burden factors 

were adopted. 

As preparation prior to the 2004 ICR renewal, EPA staff questioned the magnitude of estimates 

and related unit burdens which had not been updated since the beginning of the TRI program, 

given the fact that the program had implemented technological advances designed to ease 

reporter burden.12 Based on numerous evidentiary sources, EPA proposed a systematic revision 

to the methodology. After the public comment period and OMB review, partial revisions were 

implemented which lowered total burden estimates by 49%,13 and also resulted in: 14

• Reducing the amount of Form R Non-PBT unit burden, while holding PBT unit burden 

constant, thereby unintentionally imposing a distinction in which PBT burden is 1.73 of 

non-PBT burden (i.e., 73% higher). This change occurred as an offshoot of the revision 

process, rather than as a deliberate specification. 

• Maintaining the ratio of Form A unit burden to Form R unit burden at .64 as previously 

determined.15

Subsequently, during the Phase I Burden Reduction Rule, EPA proposed to revise the 

methodology using a basis developed in Abt Associates Engineering Studies. The July 2004 

document and methodology was peer-reviewed with results posted in the public docket 

(Proposed Rule EPA HQ-TRI-2005-0073). The method was neither finalized nor formally 

adopted into TRI burden estimation practice. 

By the time of the 2008 ICR revision, TRI staff and management recognized sources of potential 

internal inconsistency that, at a minimum, led to confusion and/or inefficiency. For example, the 

ratio of .64 for Form A to Form R burden was not readily verifiable. Additionally, the effective 

ratio of 1.73 for PBT to non-PBT burden was not directly specified, and therefore could not be 

verified. Lastly, procedures for revising/adding form elements occasionally used a set of 

estimates which were not reconciled to the whole (form) unit burden, and therefore could not be 

11 Per analysis in Table 2. Sources: EPA -TRI Program Staff (June 2009); IRS – Office of Research, Taxpayer Analysis and Modeling Group 

(June 2009).

12 An electronic version of the Reporting Forms and Instructions was initially implemented in desk-top software (TRI-ME CD) and later upgraded 

to Web-based technology (TRI-MEweb). 13 Total TRI Program burden estimate was decreased from 6.03 million to 2.61 million hours based on Notices of OMB Action (called Paperwork 

Reduction Submissions) for Form R ICR and Form A ICR. Submitted October 27, 2003; Approved January 9, 2004. Per the 2004 ICR 

Supporting Statement, 85.95 % of the (57%) total reduction was associated with adjustment of “unit burden for Form R completion in subsequent 

years from 47.1 to 14.5 hours,” yielding a 49% decrease in total burden associated with the methodology change. See Appendix B for full 

breakdown of the 2004 ICR renewal 57% decrease. 

14 For context and details, see: Rice, Cody. 2004. Terms of Clearance for TRI ICR Renewal. Regulations.gov. Accessed 23 Dec 2010 

<http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OEI-2004-0006-0004> 15 See Appendix B for additional detail and references to supporting material. 
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applied consistently across Form R and Form A. As a result of these issues, EPA staff had 

limited ability to manage questions about the origin and validity of burden estimates. From these 

observations, EPA concluded that a revised methodology should require internally consistent and 

verifiable unit burdens. 

Methodology Comparisons 

In the process of seeking guidance for RBBM’s design, EPA staff reviewed a range of 

approaches to burden estimation in government information collections, all of which conform to 

PRA requirements. Table 2 depicts methodology features from several high volume collections, 

including TRI. In this discussion, the term “calibration” refers to a method by which estimates 

are compared to, and reconciled with, an actual measurement of the quantity that they are 

designed to estimate.16 The IRS 1120 (U.S. Corporation Income Tax Return) and IRS 1040 (U.S. 

Individual Income Tax Return) collections employ a lower and higher level of accuracy in their 

methodologies, respectively, when compared to TRI. EPA’s TRI burden methodologies (both the 

existing and the algebraically equivalent RBBM) fall in between, with high specificity but no 

calibration via representative sampling.17 Across the columns of Table 2, the differences in 

approaches address different applications and correspondingly require different types of 

maintenance.

With the IRS examples, additional specificity accompanies higher precision because the more 

complex 1040 burden estimation employs calibration using a representative sample. In contrast, 

TRI burden estimates are derived from best professional judgment without this type of 

calibration. Generally, the TRI-type of methodology develops calculations drawing from an 

appropriate amount of specificity and some sense of average values. Overall, calibrated estimates 

are more accurate than uncalibrated estimates; but highly specified estimates are not necessarily 

more precise (and hence not necessarily more accurate) than less specified estimates. In the 

context of TRI’s uncalibrated estimates, increasing specificity (i.e., adding variables) adds 

complexity without necessarily increasing precision. EPA concludes that neither TRI’s existing 

nor revised methodologies require additional specificity. EPA also considered enhancing the TRI 

methodology with calibration via a representative survey but did not wish to impose additional 

burden on the TRI reporting community. TRI’s approach is appropriate and complies with PRA 

requirements for providing burden estimates, “to the extent practicable” while reflecting a 

reasonable sense of average conditions and an appropriate level of specificity.18 

In summary, the internal consistencies identified during the 2008 ICR Renewal, and the insight 

above regarding appropriate complexity lay the groundwork for RBBM’s design. A simpler 

formulation is derived with ratio models ensuring internal consistency across Forms R and 

Forms A, as well as from form elements to whole forms. 

16 This definition contrasts with the one used in scientific circles that discuss measurement techniques, where accuracy has two components: nonbias and precision. In such contexts, calibration is assured using a high precision “standard.” Outside this context (as in RBBM), estimates 

achieve accuracy by approximating the average conditions and incorporating an appropriate level of specificity. 17 Note as a matter of context that the TRI Program’s methodology is the Agency’s most complex (per Rick Westlund, OEI Office of Information 

Collection 1/13/2010). 

18 RBBM allows for future enhancements. As the single base number, the Nominal Form R burden may be adjusted to reflect updates identified 

via calibration or other sources. 
Revising TRI Burden to Ratio-Based Methodology 

8

Table 2: Burden Estimation Methodology Features from Example Government Information Collections Sources: EPA—TRI Program Staff (June 2009); IRS— Office of Research (June 2009) 

IRS 1120 

Corporate (ADL)

Uncalibrated/ 

Low Specificity

TRI Current 

Form R and Form A 

Uncalibrated/High Specificity

TRI Proposed (RBBM) 

Form R and Form A 

Uncalibrated/Simplified 

Specificity 

(Equivalent to TRI Current) 

Description 

Burden depends on: • the number of lines on the form instructions • the number of fields • the number of attachments • the number of line items completed 

Burden depends on: • Unit burdens for Form A and Form R (PBT, non-PBT) set by informed decisions based on best professional judgment and input via Public Comment • Estimates of Incremental increases to form burden based on Abt Associates Engineering estimates and case-by-case evaluations 

Burden depends on: • Internally consistent and verifiable unit 

burdens for Form A and Form R. Unit burdens reflect the number of elements and related calculations. Nominal Form R unit burden set by informed decisions based on best professional judgment and input via Public Comment. • Estimates of incremental increases to form burden utilize internal consistent system of standardized form element estimates 

Methods 

Development 

Model burden based on readily observable variables 

Identify element-level processes; assign values for associated activities 

Restructure to simplify and to ensure internal consistency. Retain previously identified processes; utilize Abt Associates Engineering estimates of element-level burden on a relative basis (in ratio models). 

• Model relationships between population subsets as ratios 

• Maintain same baseline burden as a 

starting point. 

Assumptions Few, strong assumptions Several, unverifiable assumptions Few, measurable assumptions 

Updates/Survey 

Requirements 

Based on survey data for one population extended to other populations 

Not based on survey data Not based on survey data (capability exists 

for future upgrade) 

Updates as there are changes to forms 

Updates as there are changes to forms; otherwise, wholesale adjustments are nonsytematic 

Updates as there are changes to forms; otherwise wholesale adjustments streamlined and internally consistent 

Strengths 

Easy to update Satisfies PRA requirements • Easy to update 

• Increased understanding • Robust • Simple and transparent 
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Ratio-Based Burden Methodology, Methods, and Models 

The revised methodology simplifies a set of multiple, large matrices to four ratio models plus 

one base number for Form R unit burden. This simplification converts the system to a new 

structure, as depicted in the equation below. 

Burden Hours = fct [(Nominal Form R Unit Burden), (A/R), (PBT/non-PBT), (FTFf)] 

and 

Cost = (Burden Hours)*WAWR 

Where: 

fct Means “a function of” 

Nominal Form R Unit Burden= Single base number for the entire methodology; provides 

the focal point for assessing and maintaining estimate 

accuracy 

A/R = Ratio of burden for single-chemical Form A to Form R

 

PBT/non-PBT = Ratio of burden for PBT chemical to non-PBT chemical 

FTFf =

(First-Time Filer Factor) 

Ratio of burden for first-time (first year) filers to steady 

state (subsequent year) filers 

WAWR = 

(Weighted Average Wage Rate) 

Cost conversion factor in current $ per hour; incorporates 

fixed proportions of Managerial, Technical, and Clerical 

labor categories. 

Specifications Within a New Structure 

The summary equation above applies to the entire system of methods and relevant models. In 

this methodology’s final formulation, and as described below, RBBM accomplishes the 

following design objectives: 

• Internal consistency maintained via ratio models 

o Steady state burden—A/R, PBT/non-PBT

o First-time filer burden factor—FTF f

o Standardized Form Element Burdens, as comprehensive estimates that are 

consistent from element to Form, as well as across Form R and Form A 

• Algebraic and substantive simplifications, including: 1) neglect the effects of first-time 

filers in steady state burden estimates19 2) set the PBT/non-PBT model equal to one20

• Unified scales across activity-specific unit burdens – i.e., facility-level factors were rescaled to (per chemical) form-level factors for both Form A and Form R 

• One-step conversion from hours to current dollars, using WAWR

• Overall total Program burden estimate maintained as a starting point 

19 The incremental contribution for first-time filing burden produces a very slight increase to the Steady State Total Burden estimate, as reflected 

in the calculated effect of modeling error on the Steady State Total Burden estimate at -.04%. See Appendix B. 20 Specified as a ratio model, but set to the default value for the ratio equal to one, due to the lack of verifiable alternative. See Appendix B for 

qualitative evidence considered (public comments and engineering studies). 
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Table 3 presents the decision rules used to direct simplifications and ensure internal consistency. 

See Appendices A-E for further detail. Regarding the ratio models, EPA used estimates for form 

subtasks from the Abt Associates Engineering Studies as building blocks, particularly for A/R

and FTFf (See Appendix G for these studies). For example, the value for A/R is derived by 

assessing the Form R burden for activities similarly required to complete a Form A. 

Table 3: Methodology Development Decision Rules 

Rule Description Models 

1 Derive Form A numbers from Form R numbers using estimates of 

burden by activity 

A/R 

2 Use Form R basis where additional complexity for Form A basis is 

unmerited 

FTFf, WAWR 

3 Make simplifying assumptions where they are mathematically justified A/R Model regarding 

First-Time Filers, 

WAWR

4 Make simplifying assumptions where a distinction is not backed up by 

quantitative and/or statistical evidence (especially when the need for 

evidence is expressed by stakeholders) 

A/R Model regarding 

PBT/non-PBT

5 When scaling to Nominal Form R unit burden, scale up elements 

equally, in proportion to their contributions to the total 

Standardized Form 

Element Burdens 

6* Back-calculate the Form R unit burden in order to maintain the 

established baseline’s total burden 

Nominal Form R unit 

burden

* Preserving the existing methodology’s total burden estimate is important because TRI burden estimates are primarily used 

to track changes from year to year against an established baseline. EPA defines the methodology transition point as the time 

of the last ICR approval with conditions specified by 2008 ICR renewal projections. At that point in time, the Program 

burden totals calculated under existing and revised methodologies are identical. See Appendix B for detailed calculations of 

Nominal Form R unit burden. 

The RBBM Models and Equations 

Figure 4 depicts the entire system of equations for the RBBM. The values for key factors are: 

• Nominal Form R unit burden is 35.7 hrs per Form R 

• A/R is .615 hr/hr ; PBT/non-PBT is 1.0 hr/hr 

• FTFf is 2.1 hr/hr 

• WAWR (June 2010) is $49.62/hr. 

See also Appendix C for Standardized Form Element Burdens and related procedures for updates 

to the Nominal Form R unit burden, under RBBM. 

Figure 4 

RBBM System and Constituent Methods 

Steady State Total Burden Calculation

Steady State Total Burden 

 = Form R Burden + Form A Burden + Non-Form Burden 

 = Nominal Form R Unit Burden*# Form R Chemicals 

 + [Nominal Form R Unit Burden* (A/R)*(# Form A Chemicals )] + Non-Form Burden 
Revising TRI Burden to Ratio-Based Methodology 

 4/28/11

 11 

Form Element Estimation

Nominal Form R unit burdennew = Nominal Form R unit burdenold + Form change burden 

First-Time Filer Estimation

First-Time Filer Burden 

 = FTFf * (Relevant Steady State Burden) 

 = FTFf *[(Nominal Form R Unit Burden* # New Form R Chemicals)] 

 + [(A/R) * Nominal Form R Unit Burden * # New Form A Chemicals] 

Cost Conversion

Steady State Total Cost = (Steady State Total Burden)*WAWR 

Ratio Models: Stability and Internal Consistency 

Beyond imposing internal consistency and preventing related inconsistencies from developing in 

the future, ratio models are inherently more (roughly) stable and therefore more robust to 

changes than their component variables. For example, for A/R (the ratio of Form A burden to 

Form R burden) the value of the actual ratio (.615) remains stable over the course of typical 

Program changes. This ratio remains stable because the actual changes to Form R and Form A 

impose similarly small incremental burden changes to both the numerator and the denominator 

of the ratio, thus causing the ratio itself to remain roughly constant.21 In contrast, the Nominal 

Form R unit burden requires routine updating because typical changes to the Form R increase or 

decrease actual reporting burden per Form R. Last, the ratio models are useful standalone metrics 

because they quantify key relationships between two elements. For example, A/R is .615, 

reflecting the burden of a Form A as 61.5% of the burden of a Form R, and implying that filing a 

Form A instead of a Form R yields a 38.5% burden reduction per chemical. 

Nominal Form R Unit Burden: Comprehensive Focus and High Utility 

The Nominal Form R unit burden provides a number of functions. As already stated, it is the 

base number for the entire methodology, providing a single focal point for discussions about 

methodology accuracy. This contrasts with the existing methodology in which numerous factors 

and variables are maintained and the suggestion to add more variables (e.g., staff turnover) arises 

frequently. Instead, RBBM supports focused discussions about whether 35.7 hours per Form R is 

the correct base number. Second, revisions are straightforward. In rulemaking and ICR revision, 

Form R changes are estimated and applied to the Nominal Form R unit burden. Other changes in 

the system are automatically propagated via the ratio models (to Form A and for first-time filers). 

Similarly, when EPA receives information indicating that overall burden estimates are either too 

high or too low, the Nominal Form R unit burden is the single primary point of adjustment. 

As a clarification on RBBM’s design, note that Decision Rules 4 (PBT/non-PBT=1) and 6 (backcalculated Nominal Form R unit burden) both impact the definition for nominal Form burden, as 

well as the resultant overall structure of RBBM. In choosing to leave the value of the PBT/non-

 

21 Note that in the event that the Form R and/or Form A undergo extreme revisions that alter the relationship between A/R burden, then A/R would 

require updating. 
Revising TRI Burden to Ratio-Based Methodology 

 4/28/11

 12 

 

PBT ratio at the default value of one, the back-calculated base number (Nominal Form R unit 

burden) remains a single focal point for considering overall average conditions for Form R 

burden per chemical.22 This single focal point is afforded by the simplicity of the overall Steady 

State Total Burden Calculation that also does not required a PBT/non-PBT model and tracking of 

related separate subpopulations. Moreover, given that the back-calculated Nominal Form R unit 

burden preserves the existing totals as a starting point (Decision Rule 6), RBBM carries forward 

certain prior assumptions from the existing methodology without explicitly modeling them. In 

particular, note that the higher PBT reporting burden is incorporated into the Nominal Form R 

unit burden’s starting value of 35.7 hours/Form R, which is elevated above the value that would 

have been otherwise obtained—at about 30 hours/form—had only non-PBT burden been used to 

determine Nominal Form R unit burden.

23 

In opting for simplicity over specificity via the RBBM approach (even if PBT/non-PBT burden 

were quantified), EPA retains the sophistication of a single unit burden for Form R reporting 

with Form A reporting burden closely linked. The Nominal Form R unit burden reflects overall 

“average” conditions, without the need to add variables. In short, any effect that EPA needs to 

consider is incorporated into the average conditions of the Nominal Form R unit burden. 

In the event that the overall PBT/non-PBT relationship is determined, EPA could restructure to a 

more complex total burden calculation,24 or keep the simpler formulation by updating the 

Nominal Form R unit burden (single base number) on a prorated basis. Regardless, EPA would 

then be able to estimate burden differences associated with PBT chemical reporting, as needed. 

EPA supports this value of 35.7 hours per Form R as a reasonable approximation of the actual 

unit burden, based on years of review and scrutiny to which the current total burden estimate has 

been subjected. The unit burden of 35.7 hours, in the context of a new system of ratio models, is 

the culmination of prior accuracy assessments (see methodology history). Therefore, this basis is 

legitimized for ultimately setting the magnitude of the Program total burden at this time. 

Benefits 

With the simplified and internally consistent calculations plus a user-friendly interface via the 

Program Staff Tool (shown in Appendix F), EPA expects RBBM to streamline burden 

estimation. In addition to saving time, RBBM enhances administrative consistency with shorter, 

more straightforward procedures that are readily replicated and consistently communicated. Last, 

RBBM increases transparency because burden information is available in a more accessible, 

compact, and comprehensive format that is easier to use. As a result, EPA staff and the general 

public will obtain an increased understanding of the key drivers of burden estimation for a 

variety of purposes, including those encountered in the context of public policy changes. 

Therefore, EPA recommends the adoption of RBBM for the TRI Program, beginning with the 

2012 ICR renewal. 

22 Moreover, RBBM’s total burden calculation does not have the complexity of tracking separate subpopulations for Form R PBT and non-PBT 

chemical reports. 

23 For the transition, the previous methodology’s inclusion of a higher PBT unit burden for 20% of chemical reports is rolled up into the new 

back-calculated unit burden. Similar logic applies to first-time filer effects, though the impact is negligible. 24 Requires the inclusion of the PBT/non-PBT ratio and separate chemical counts for Form R PBT and non-PBT subpopulations. 
Appendix A 

 4/28/11 

A-1 

Methodology Overview and Guide to Methods Technical Appendices (B – E) 

This appendix presents an overview of the revised methodology, Ratio-Based Burden 

Methodology (RBBM) as a guide to the other more detailed Appendices B-E. As such, this 

appendix does not provide back-up evidence or justify assumptions; that information is covered 

in the relevant detailed appendices: 

• Appendix B – Steady State Total Burden Calculation 

• Appendix C – Form Element Estimation 

• Appendix D – First-Time Filer Estimation 

• Appendix E – Cost Conversion 

The methodology revision project that culminated as RBBM started in May 2009, with technical 

document writing initiated in March 2010. The draft technical document was submitted for peer 

review on May 1, 2010. The peer reviewers endorsed the methodology as credible and effective 

(See Appendix H for summary). As a result, EPA left all of RBBM’s design and major 

procedures in tact. EPA then revised the technical document, addressing specific 

questions/critiques of the methodology and implementing editorial suggestions from peer 

reviewers and other sources. Throughout the project, EPA employed interdisciplinary teams for 

methodology development, document development, and document revisions. 

RBBM development was guided by the methodology priorities of simplicity, internal 

consistency, and transitional baseline continuity and was more precisely specified by broadly 

applicable decision rules. These rules are presented on page 10 in the main report and discussed 

herein. The methodology revision entails restructuring a set of large matrices to a system of four 

ratio models plus one base number (Nominal Form R unit burden, derivation to follow). 

Additionally, Standardized Form Element Burdens replace case-by-case engineering estimates 

for use in updating unit burden to reflect Form changes, such as burden associated with adding a 

new element. 

There are two major classes of burden estimates in TRI applications: steady state burden and 

first-time filer burden. Steady State Total Burden is the estimate of the ongoing TRI Program 

burden, as updated by rulemakings’ permanent impacts, but absent any first-time filer impacts. 

These are the burden estimates that OMB has on record that are re-estimated in full at ICR 

renewal time. Similarly, when an economic analysis (EA) is conducted in association with a 

rulemaking, the ongoing incremental change in burden is added or subtracted from the Steady 

State Total Burden, constituting a sustained steady state change in burden. In a related 

application, the Form Element Estimate provides revisions to unit burden due to changes in Form 

R/Form A filing requirements which can occur either in the ICR renewal or in a rulemaking. 

In contrast to steady state, first-time filer burden (previously termed first-year year burden) 

accounts for the elevated level of effort that reporters incur during a start-up year. In RBBM, 

first-time filer burden is estimated using a ratio model that reflects the increased burden over and 

above relevant steady state burden. Given this structure, EPA first derives models supporting the 

Steady State Total Burden estimate, including the restructuring and related Form Element 

Estimation. Thereafter, First-Time Filer Estimation is presented. Last, Cost Conversion is 

presented, as this method is applicable to all burden estimates. 
Appendix A 

 4/28/11 

A-2 

Steady State Burden 

The Steady State Total Burden Calculation consists of Form burden and non-Form burden. In the 

next sections, EPA derives the portions of the restructured system pertaining to Form burden. 

This first set of derivations demonstrates that the proposed approach is a greatly simplified 

algebraic equivalent to the existing method. The next section provides the derivation for the A/R

model that is central to the new structure. After that, EPA presents a revised and slightly 

modified calculation for non-Form burden that addresses TRI burden not directly captured by 

filling out a Form R or A. EPA then provides the procedure for back-calculating the base 

number, Nominal Form R unit burden. Finally, EPA presents an overview of the related Form 

Element Estimation. 

 

Restructuring the System 

The existing method for estimating Form burden consists of an extensive system of matrices that 

can be collapsed and further simplified. The matrix notation for Form R burden hours is: 

Eqn. A-1: Form R Burden hours = [F]chem. category, activity, YR, labor category * [N]forms 

Eqn. A-2: Form R Cost = [F]chem. category, activity, YR, labor category * [N]forms * [$] labor category 

Where: 

chem category = PBT or Non-PBT 

activity = Rule familiarization, compliance determination, form completion, 

recordkeeping and submission 

YR= First year or subsequent year 

labor category = Management, technical, or clerical labor 

And where: 

[F]chem category, activity, 

YR, labor category 

18x3 matrix of reporting activity factors with subsets 

depending on whether the Form is for a PBT or non-PBT 

chemical, and a first year or subsequent year filing...with three 

columns for the three labor categories (managerial, technical, 

clerical) 

[N]forms 1x18 vector of TRI chemical counts according to the 

categories specified in matrix F 

[$] labor category 3x1 vector of current dollar wage rate ($/hr) for managerial, 

technical, and clerical labor 

Note that a parallel set of matrices exist for Form A burden estimation in the existing 

methodology. However, as the new methodology derives Form A-related burden exclusively 

from Form R, the derivation that follows need only pertain to Form R. 

The detailed list of OMB-approved unit burdens as of March 27, 2008 for reporting activities 

(hereafter known as factors) for Form R non-PBT and PBT chemicals are presented in Tables A-
Appendix A 

 4/28/11 

A-3 

1 and A-2, respectively. An alternative set of factors for non-PBT only, as developed in the Abt 

Associates Engineering Studies (for source reference, see Appendix G) and derived by EPA, are 

presented in Table A-3 for Form R and Form A. Table A-4 provides the slightly reformulated 

version of Table A-3’s factors, incorporating RBBM conversion of facility-level unit burdens to 

(per chemical) form-level. The totals in Table A-4 apply directly to building RBBM ratio models 

(used later in Eqns. A-4, A-9, and A-10). For the purposes of deriving the system simplification, 

however, Tables A-1 and A-2 may be combined to populate the comprehensive matrices below. 

Note that these tables’ factors are a mixture of facility-level and form-level constants. 

Table A-1: OMB-Approved Burden, Non-PBT 

Form R (non-PBT) 

 Managerial Technical Clerical Total first year 

Facility Rule Familiarization 12 22.5 0 34.5 

Compliance Determination 4 12 0 16 

 

Form R 

Calculations and Form 

Completion 20.5 44.4 2.8 67.66 

 Recordkeeping 0 4 1 5 

 

Managerial Technical Clerical Total 

subsequent 

Facility Rule Familiarization 0 0 0 0 

Compliance Determination 1 3 0 4 

 

Form R 

Calculations and Form 

Completion 7.55 16.08 1.03 24.66 

 Recordkeeping 0 4 1 5 

Table A-2: OMB-Approved Burden, PBT 

Form R (PBT) 

 Managerial Technical Clerical Total first year 

Facility Rule Familiarization 12 22.5 0 34.5 

Compliance Determination 4 12 0 16 

 

Form R 

Calculations and Form 

Completion 20.28 43.87 2.70 66.86 

 Recordkeeping 0 4 1 5 

 

Managerial Technical Clerical Total 

subsequent 

Facility Rule Familiarization 0 0 0 0 

Compliance Determination 1 3 0 4 

 

Form R 

Calculations and Form 

Completion 14.10 30.37 1.86 46.34 

 Recordkeeping 0 4 1 5 
Appendix A 

 4/28/11 

A-4 

Table A-3: Abt Associates Engineering Study Factors, Non-PBT with Derived Form A Form R (non-PBT) 

 Managerial Technical Clerical 

Total 

Derived 

Form A 

Total* 

first year 

Facility Rule Familiarization 1 22.5 0 23.5 23.5 

Compliance Determination 1 13.7 0 14.7 14.7 

Form R 

Calculations and Form 

Completion 0.37 10.49 0 10.86 3.39 

 Recordkeeping 0 4 1 5 5 

Managerial Technical Clerical Total 

Derived 

Form A 

Total* 

subsequent 

Facility Rule Familiarization 0 0 0 0 0 

Compliance Determination 0.25 1 0 1.25 1.25 

Form R 

Calculations and Form 

Completion 0.32 6.89 0.0 7.20 2.30 

 Recordkeeping 0 4 1 5 5 

* Form A burden estimates are derived from Form R by summing the burden associated with Form R data elements for which a 

reporter would make calculations to determine their Form R eligibility as well as the data elements they actually report on Form A. 

Table A-4: Ratio-Based Burden Methodology “Building Blocks” for Ratio Models 

Abt Associates 

Factors, 

Mixed Scales

Ratio-Based Burden Methodology Unit 

Burdens, 

Consistent per Chemical Scale

Form R 

Derived 

Form A* 

Ratio Model 

Bases Form R 

Derived 

Form A* 

Form R (non-PBT )

 first year 

Facility Rule Familiarization 23.5 23.5 R, A Chemical ** 6.07 6.90 

Compliance Determination 14.7 14.7 3.80 4.31 

 

Form R Calculations and Form Completion 10.86 4.27 R, A Chemical 10.86 4.27 

 Recordkeeping 5 5 5 5 

Form Burden Per Chemical Total N/A N/A 25.73 20.48 

subsequent 

Facility Rule Familiarization 0 0 R, A Chemical ** 0 0 

Compliance Determination 1.25 1.25 0.32 0.37 

 

Form R Calculations and Form Completion 7.2 2.34 R, A Chemical 7.2 2.34 

 Recordkeeping 5 5 5 5 

Form Burden Per Chemical Total N/A N/A 12.52 7.71 

*Form A burden estimates are derived from Form R by summing the burden associated with Form R data elements for which a reporter 

would make calculations to determine their Form R eligibility as well as the data elements they actually report on Form A. 

** Facility-level factors converted to form (per chemical) level factors via equivalent chemicals per facility for R (3.87) and A (3.41). See 

Appendix B Supplement for derivations In practice Form R reports contain one chemical per report and Form A allows multiple 

chemicals (2.3 on average).
Appendix A 

 4/28/11 

A-5 

Starting with the F * N matrix product (represented by Eqn. A-1), with F being an array of 

factors (burden per form or facility), and N a vector of variables (form or facility counts), EPA 

simplifies by collapsing the entire set of factors to one constant and reducing vector N to one 

variable—total Form R chemical counts. However, in order to make this simplification, EPA 

must convert the factors to the same unit of analysis (per chemical form-level) by dividing 

facility-level factors by the applicable average number of Form R chemicals per facility, Rcpfe.

1

 

Expanding the matrix notation and standardizing the factors’ units, F * N becomes F′ * N. 

Matrix System F′ * N

FNPBT,fYR,RF,m

Rcpfe

FNPBT,fYR,RF,t

Rcpfe

FNPBT,fYR,RF,c

Rcpfe

NNPBT,fYR 

FNPBT,fYR,CD,m

Rcpfe

FNPBT,fYR,CD,t

Rcpfe

FNPBT,fYR,CD,c

Rcpfe

NNPBT, fYR 

FNPBT,fYR,CFC,m FNPBT,fYR,CFC,t FNPBT,fYR,CFC,c NNPBT,fYR 

FNPBT,fYR,REC,m FNPBT,fYR,REC,t FNPBT,fYR,REC,c NNPBT,fYR 

FNPBT,sYR,RF,m

Rcpfe

FNPBT,sYR,RF,t

Rcpfe

FNPBT,sYR,RF,c

Rcpfe

NNPBT,sYR 

FNPBT,sYR,CD,m

Rcpfe

FNPBT,sYR,CD,t

Rcpfe

FNPBT,sYR,CD,c

Rcpfe

NNPBT, sYR 

FNPBT,sYR,CFC,m FNPBT,sYR,CFC,t FNPBT,sYR,CFC,c NNPBT,sYR 

FNPBT,sYR,REC,m FNPBT,sYR,REC,t FNPBT,sYR,REC,c NNPBT,sYR 

FPBT,fYR,RF,m

Rcpfe

FPBT,fYR,RF,t

Rcpfe

FPBT,fYR,RF,c

Rcpfe

* NNPBT,fYR 

FPBT,fYR,CD,m

Rcpfe

FPBT,fYR,CD,t

Rcpfe

FPBT,fYR,CD,c

Rcpfe

NPBT, fYR 

FPBT,fYR,CFC,m FPBT,fYR,CFC,t FPBT,fYR,CFC,c NPBT,fYR 

FPBT,fYR,REC,m FPBT,fYR,REC,t FPBT,fYR,REC,c NPBT,fYR 

FPBT,sYR,RF,m

Rcpfe

FPBT,sYR,RF,t

Rcpfe

FPBT,sYR,RF,c

Rcpfe

NPBT,sYR 

FPBT,sYR,CD,m

Rcpfe

FPBT,sYR,CD,t

Rcpfe

FPBT,sYR,CD,c

Rcpfe

NPBT, sYR 

FPBT,sYR,CFC,m FPBT,sYR,CFC,t FPBT,sYR,CFC,c NPBT,sYR 

FPBT,sYR,REC,m FPBT,sYR,REC,t FPBT,sYR,REC,c NPBT,sYR 

Figure A-1: Sample Definition of Matrix Term 

FPBT,fYR,RF,m 

Where: 

PBT = Chemical category is PBT form. (Other possibility is non-PBT) 

fYR= Year is first year of filing. (Other possibility is subsequent year of filing) 

RF = Activity is rule familiarization. (Other possibilities are compliance determination, 

calculations and form completion, and recordkeeping and submission) 

m= Labor category is managerial. (Other possibilities are technical and clerical) 

 

1

 Although this appears to be a straightforward conversion, in practice it was not. EPA derived “equivalent chemical 

per facility,” for Form R and Form A, based on distributions of Form R and Form A chemicals within and across 

facilities, on average. See Appendix B Supplement for details. 
Appendix A 

 4/28/11 

A-6 

To help clarify terms, Figure A-1 defines the terms for an example variable in the matrix. The 

value of each variable is contained in Tables A-1, A-2 (existing methodology), and A-3, A-4 

(revised methodology). 

Assuming that the first-time filer effect is negligible and asserting the model that PBT/non-PBT

burden=1 (i.e., on average no quantifiable difference between burden for filing a PBT chemical 

report versus a non-PBT), the matrix factors reduce to a simple sum. Correspondingly, the matrix 

product reduces to the unit burden (hours per Form R chemical) times the total number of Form 

R chemicals. 

F′′ * N′ (with matrix N reduced to the constant NR for total number of Forms) 

Matrix System F′′ * N′ FNPBT,sYR,RF,m

fpRe

FNPBT,sYR,RF,t

Rcpfe

FNPBT,sYR,RF,c

Rcpfe

NR 

FNPBT,sYR,CD,m

fpRe

FNPBT,sYR,CD,t

Rcpfe

FNPBT,sYR,CD,c

Rcpfe e

* NR 

FNPBT,sYR,CFC,m FNPBT,sYR,CFC,t FNPBT,sYR,CFC,c NR 

FNPBT,sYR,REC,m FNPBT,sYR,REC,t FNPBT,sYR,REC,c NR 

Form R Burden Hour N =s R﴾ 2 :3-A .nqE F′′ ∑∑ i,j ﴿ = NRCR 

==

4

1

4

1 ji

 

Where: 

CR= Sum of all factors in the matrix, reflecting the unit burden per Form R chemical

Intuitively, one would state this equation as follows: “the total Form R burden hours estimate is 

the product of the Form R unit burden times the number of chemicals filed by Form R where the 

unit burden consists of four contributing activities: rule familiarization, compliance 

determination, calculations and form completion, and recordkeeping and submission.” 

Ensuring Internal Consistency Using Ratio Models and Engineering Estimates 

If EPA were to make simplifications such as “Form R burden hours = NRCR” and go no further, 

EPA would greatly reduce the computational and reporting complexity for TRI program burden 

calculations. However, this alone would not address one of the key concerns that led it to 

develop a new method: internal consistency. Consistency across Forms R and A is desired, as 

well as consistency in computing estimates of the first-time filing burden that affect new entrants 

to the reporting community as a result of policy change. Ratio models of A/R and first year 

burden/subsequent year burden (newly termed “first-time filer factor (FTFf)”) characterize the 

relationships between these estimates, regardless of the magnitude of the values used in the 

composite Form unit burdens. As seen by comparing Table A-1 and A-3, the OMB-approved 

numbers are higher than the Abt Associates Engineering Studies numbers.3

 These differences in 

absolute magnitude are not relevant to RBBM development of ratio models for the purpose of 

2

 This equation uses standard matrix notation where i refers to the row of the matrix and j refers to the column. 3

 Differences are due to differences in origin: EPA OMB-approved estimates were defined at program inception 

(with periodic revisions), while Abt Associates’ Engineering Study estimates were generated more than a decade 

after program inception. 
Appendix A 

 4/28/11 

A-7 

providing internal consistency. Specifically, the Abt Associates Engineering estimates are used 

on a relative basis only, for building ratio models. Moreover, EPA concludes that the Abt 

Associates Engineering estimates are appropriate for RBBM’s ratio models because they most 

reliably quantify the relative burdens of various tasks making them useful for quantifying 

relationships between key variables. As an added benefit, EPA’s use of the Abt Associates 

Engineering estimates provides a means by which A/R and other models may be verified.4

 At 

another level, the Abt Associates Engineering estimates inform updates to the Nominal Form R 

unit burden which are internally consistent with the Form unit burden, based on Standardized 

Form Element Burdens (see more information later in this appendix and also in Appendix C). 

Several models were specified using the Abt Associates Engineering Studies Form R non-PBT 

estimates presented in Table A-4. For clarification purposes, Table A-5 presents unit burden 

components as a percent of total Form R unit burden. This format provides information about 

activity-based components of unit burden on a percentage basis, regardless of the value of Form 

R Nominal unit burden. 

Table A-5: Ratio-Based Burden Methodology Components, Standardized to Form R Basis

Ratio-Based Burden Methodology 

Unit Burdens, 

Consistent per Chemical Scale 

100%=Form R Unit Burden

Ratio Model Bases Form R 

% 

Derived 

Form A* 

% 

Nominal Form R(non-PBT )

Subsequent year 

(Steady State)

Facility Burden 

Apportioned to 

Form R 

Activity 

Rule Familiarization R, A Chemical 0 0 

Compliance Determination 2.58 2.93 

 

 

 

Form R Calculations and Form Completion R, A Chemical 57.49 18.64 

Recordkeeping 39.93 39.93 

Form Burden Per Chemical Total 

Percentage of Form R Unit Burden 100.00 61.50 

*Form A burden estimates are derived from Form R by summing the burden associated with Form R data elements for which a reporter 

would make calculations to determine their Form R eligibility as well as the data elements they actually report on Form A.

In the A/R ratio model, EPA ensures that Form A unit burden is related to Form R unit burden 

via the subset of tasks and data elements from Form R that are similarly required to complete 

Form A. Using the values in Table A-4, and the relevant elements of Matrix System F′′ * N′, the 

A/R ratio model is computed at .615 as follows: 

 

4 See also discussions in Appendix B regarding benefits of ratio models and strengths/weaknesses of Abt Associates 

Engineering Studies.
Appendix A 

 4/28/11 

A-8 

 

Eqn. A-4: A/R = (Sum of Form A Factors (as derived from Form R) / Sum of Form R Factors) 

 = ((FNPBT,sYR,RF,T +FNPBT,sYR,CD,T )/Acpfe )+FNPBT,sYR,CFC*,T +FNPBT,sYR,REC,T

 ---------------------------------------------------------------------------------------------------------------------------------- 

((FNPBT,sYR,RF,T +FNPBT,sYR,CD,T )/Rcpfe )+FNPBT,sYR,CFC,T +FNPBT,sYR,REC,T

Notes 

1 Facility level factors are converted to Form level factors using Acpfe and Rcpfe

2 T subscript refers to managerial plus technical plus clerical labor 

3 Acpfe refers to Equivalent Form A Chemicals per Facility (see Appendix B Supplement) 

4 Rcpfe refers to Equivalent Form R Chemicals per Facility (see Appendix B Supplement) 

5 CFC* refers to the Form A factor, as derived from Form R factor components; these burdens include 

Form A eligibility determination with half of Form R’s Section 5 and 6 work plus all the tasks associated 

with Form R elements that also occupy Form A 

The A/R value of .615 has the following interpretation: “the burden of a Form A as 61.5% of the 

burden of a Form R, implying that filing a Form A instead of a Form R yields a 38.5% burden 

reduction per chemical.” 

Transitioning to the New System 

The final system of models calculates total burden as follows: 

Eqn. A-5: Steady State Total Burden = Form R burden + Form A burden + Non-Form burden 

Where: 

• Form R Burden = (# Form R Chemicals) * (Nominal Form R Unit Burden) 

• Form A Burden = (# Form A Chemicals) * (A/R) * (Nominal Form R Unit Burden) 

• Non-Form Burden 

 = (Supplier Notification) + (Non-Reporter Compliance Determination) + Petitions 

And: 

A/R= Ratio model of single-chemical Form A unit burden to Form R unit 

burden5

Nominal Form 

R unit burden= Single base number for the entire methodology; provides the focal point 

for assessing and maintaining estimate accuracy 

To establish the starting point for RBBM that would provide a seamless transition to the new 

methodology, EPA estimated the nominal Form unit burden that would not produce a change in 

the Steady State Total Burden estimate. The back calculation yields a Nominal Form R unit 

burden of 35.7 hours/Form R:6

5

 For purposes modeling, EPA refers to “Form R chemicals” and “Form A chemicals” in order to provide a 

consistent metric across form types. In practice Form R reports contain one chemical per report and Form A allows 

multiple chemicals (2.3 on average). 

6

 EPA defines the methodology revision’s transition point as the time of the last ICR approval with conditions 

specified by 2008 ICR renewal projections. In the actual calculation EPA corrects for previous double-counting of 

facility level burden among facilities filing both As and Rs in the last ICR renewal, shifting the baseline downward 

slightly by 5460 hours (removes .13% overstatement). Non-Form Burden amounts are: Supplier Notification—
Appendix A 

 4/28/11 

A-9 

 

Eqn. A-6: Nominal Form R Unit Burden = 

(Total Burden – Non-Form burden)/[# Form R Chemicals + ((A/R)* # Form A Chemicals)] 

Form Element Estimation 

Form Element Estimation provides a standardized and reproducible method for estimating 

updates to unit burden associated with form changes, replacing the case-by-case engineering 

approach used in the existing method. The model consists of Standardized Form Element 

Burdens, organized by “type” of element. The generalized format for using this method is: 

Egn. A-7: Nominal Form R unit burdennew 

= Nominal Form R unit burdenold + Form change burden 

Where: 

Form change 

burden= estimate based on conditions of the form change, utilizing Standardized 

Form Element Burdens 

Form element estimation is applicable any time changes to the reporting Form R, and by 

association, corresponding elements of the Form A, are involved. Changes to the reporting form 

can occur at ICR renewal and during rulemakings. Such changes impact the Nominal Form R 

unit burden. This method differs from the rest of RBBM’s burden estimation methods because 

its specifications are tied to the magnitude of the Nominal Form R unit burden. 

Figure A-2 at the end of this Appendix depicts the Standardized Form Element Burdens, as 

mapped onto an RY 2009 Form R. See Appendix C for further details including a list of 

Standardized Form Element Burdens by type of element, as well as related procedures for 

updating the Nominal Form R unit burden. 

First-Time Filer Estimation 

First-time filer burden, referred to as first year burden in the existing methodology, historically 

has two applications. First-time filer burden is estimated as part of the total Program burden 

estimate in ICR renewals to account for the portion of the reporting community with new 

entrants. The estimate of first-time filers is made by determining the number of facilities newly 

reporting to TRI in the year the ICR is updated. The number of new TRI reporters serves as an 

approximation for the number of new filers expected in any reporting year during the period 

covered by the ICR renewal. In the revised RBBM formulation, the impact of additional firsttime reporter burden is neglected in the (newly termed) Steady State Total Burden Calculation. 

In rulemakings, first-time filer burden is estimated to account for the start-up effect of a policy or 

regulatory change to the TRI reporting requirements—for example, when a new sector is added 

to the reporting community. In this example, during the year that to policy change is first 

implemented, the new reporters incur start-up burden which then reduces to steady state burden 

89,616 hours; Non-Reporters Compliance Determination—734,976 hours; and Petitions—925 hours (see 

Appendix B for further explanation) 
Appendix A 

 4/28/11 

A-10 

in the next year. In the case of EAs, the first-time filer burden includes both the burden to 

facilities reporting to TRI for the first-time as well as the burden to existing filers in the first year 

of a policy or regulatory change. Under RBBM, EAs still typically report both steady state and 

first-time filer incremental burdens/costs associated with the new policy or regulation. For these 

estimates, only Form burden is relevant.7

 Given the overarching estimation method (Eqn. A-11), 

the first-time filer factor (FTFf) is derived below. 

Eqn. A-8 First-Time Filer Burden = FTFf * Relevant Steady State Total Burden

Similar to the A/R model, the FTF model provides a consistent basis to estimate the first year 

burden relative to steady state burden for both Form R and Form A. It is developed using the 

ratio of Form R factors for the first year to Form R factors for subsequent years. Using the 

values in Table A-4 and the relevant factors from Matrix System F′ * N, the first-time filer 

factor, FTFf , for RBBM is computed at 2.1 as follows: 

Eqn. A-9: FTFf = 

 ((FNPBT,fYR,RF,T +FNPBT,fYR,CD,T )/Rcpfe )+FNPBT,fYR,CFC,T +FNPBT,fYR,REC,T

 ------------------------------------------------------------------------------------------------------------------------------

((FNPBT,sYR,RF,T +FNPBT,sYR,CD,T )/Rcpfe )+FNPBT,sYR,CFC,T +FNPBT,sYR,REC,T 

Notes 

1 Facility level factors are converted to Form level factors. 

2 T subscript refers to managerial plus technical plus clerical labor. 

3 Rcpfe refers to Equivalent Form R Chemicals per Facility (see Appendix B Supplement). 

The FTFf of 2.1 has the following interpretation: “for any comparison of first-time filer to 

ongoing filer burden, the elevated startup effort is roughly twice the normal ongoing burden.” 

Cost Conversion 

The Cost Conversion method involves developing a universal WAWR that incorporates fixed 

proportions of Managerial, Technical and Clerical labor categories at values of .03, .89. and .08 

respectively and can be applied to Form R burden, Form A burden and Steady State Total 

Burdens. Similar to the burden estimate in Eqn A-3, for the cost estimate, the matrix calculation 

is reduced to the following weighted average unit cost per Form times the number of Forms:8

NR *(F′′ * $) 

Matrix System NR *(F′′ * $)

NR * FNPBT,sYR,RF,m

Rcpfe

FNPBT,sYR,RF,t

Rcpfe

FNPBT,sYR,RF,c

Rcpfe

* $/hr 

managerial

$/hr 

technical 

$/hr 

clerical 

FNPBT,sYR,CD,m

Rcpfe

FNPBT,sYR,CD,t

Rcpfe

FNPBT,sYR,CD,c

Rcpfe

FNPBT,sYR,CFC,m FNPBT,sYR,CFC,t FNPBT,sYR,CFC,c 

FNPBT,sYR,REC,m FNPBT,sYR,REC,t FNPBT,sYR,REC,c 

 

7

 EA’s report incremental burden associated with proposed changes; since non-Form burden components are 

constant, they do not vary with changes in forms, yielding a zero effect in this context. 

8

 The existing method has been modified for ease of presentation. In practice, no devisor is used but rather, facility 

burden is multiplied by the number of facilities and form burden is multiplied by the number of forms. Total facility 

and form burden are then summed to equal total burden reported by Form R. 
Appendix A 

 4/28/11 

A-11 

( ∑∑ ==

4

1

4

1 ji

 

-A .nqE 10 stsoC R mroF : = ((NR F′′i,j ﴿* $j )﴿ 

Rearranging this equation to a Weighted Average Wage Rate (WAWR in current $/hr) from which 

hours can be readily converted to cost (for Form R related burden) yields:

Eqn. A- 11: Form R Costs = Form R Burden * WAWR

Generalizing to the overall equation: 

Eqn. A-12: Steady State Total Cost = Steady State Total Burden * WAWR

Intuitively, one would state this equation as follows: “the total steady state cost estimate is the 

product of total burden times the weighted average $/hr labor rate.” The current WAWR (June 

2010)9 of $49.62/hour has the following interpretation: “for every hour of incremental burden 

increased or decreased, the associated cost, on average, is $49.69 per hour.” WAWR provides a 

universal conversion factor for all TRI key burden estimates, including Form R burden, Form A 

burden, and Steady State Total Burden. 

Methodology Decision Rules Summary 

This appendix presented the conceptual bases for the new RBBM, including the generalized 

steps by which the existing methodology’s system was restructured and simplified. In the 

process of restructuring and simplifying, certain key development decision rules (summarized in 

main report, p. 10) were established, including: 

• Rule 1: Derive Form A burden from Form R burden using estimates of burden by activity 

—This decision rule, used in the A/R model, ensures transparency and internal 

consistency by using the subset of tasks from Form R reporting that similarly apply to 

Form A reporting. 

• Rule 2: Use Form R basis where additional complexity for Form A basis is unmerited— 

This decision rule, used in the FTFf and WAWR models, provides universal models across 

Form A, Form R, and total burdens. 

• Rule 3: Make simplifying assumptions where they are mathematically justified—This 

decision rule is used in the A/R model in the context of the decision to exclude first-time 

filer effects from models from the Steady State Burden Calculation. The rule is also used 

in applying the WAWR universally across Form R, Form A, and total burden estimates. 

• Rule 4: Make simplifying assumptions where a distinction is not backed up by 

quantitative and/or statistical evidence (especially when the need for evidence is 

expressed by stakeholders)—This decision rule was used to set the value of the ratio 

model for PBT/non-PBT burden equal to one. 

• Rule 5: When scaling from form element estimates to Nominal Form R unit burden, scale 

elements equally, in proportion to their contributions to the total—This decision rule was 

used in developing Standardized Form Element Burdens. 

9

 Wage data source: http://www.bls.gov/ncs/ect/#tables 
Appendix A 

 4/28/11 

A-12 

• Rule 6: Back-calculate the Form R unit burden in order to maintain the established 

baseline’s total burden—This decision rule was used to set the starting value for Nominal 

Form unit burden. 

Appendices B-E present method development, including detailed analyses used to formulate and 

refine distinct pieces of the overall methodology. These appendices, organized by each of the 

constituent methods, comprehensively detail models and computational procedures of the 

methodology. Additionally, key analytical decisions are discussed with assumptions validated 

using empirical evidence where possible. 
Appendix A 

 4/28/11 

A-13 

Figure A-2: Standardized Data Element Time Estimates Scaled to 35.7 Hours 

Form Approved OMB Number: 2070-0093 

(IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 03/31/2011Page 1 of 5 

EPA

United States 

Environmental Protection Agency 

FORM R 

Section 313 of the Emergency Planning and 

Community Right-to-Know Act of 1986, also 

Known as Title III of the Superfund 

Amendments and Reauthorization Act 

TRI Facility ID Number 

Toxic Chemical, Category or Generic Name

WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing 

Center 

 P. O. Box 1513

2. APPROPRIATE STATE OFFICE 

 (See instruction in Appendix E) 

This section only applies if you are revising or 

withdrawing a previously submitted form, 

otherwise leave bank. 

Revision (enter up to two codes(s)) Withdrawal (enter up to two code(s)) 

 

IMPORTANT: See instructions to determine when “Not Applicable (NA)” boxes should be checked. 

PART 1. FACILITY IDENTIFICATION INFORMATION

SECTION 1. REPORTING YEAR 0.006 hours 

SECTION 2. TRADE SECRET INFORMATION 

2.1 

 Are you claiming the toxic chemical identified on page 2 trade secret? 

0.006 hours 

2.2

Is this copy  Sanitized 

Unsanitized 

Answer only if “YES” in 2.1 

0.006 hours 

 Yes (Answer question 2.2; 

Attach substantiation forms) 

 No (Do not answer 

question 2.2; 

Go to Section 3) 

SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.) 

I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted information is true and 

complete and that the amounts and values in this report are accurate based on reasonable estimates using data available to the preparers of this report.

Name and official title of owner/operator or senior management official: Signature: Date Signed: 

NA NA 

SECTION 4. FACILITY IDENTIFICATION 

4.1 TRI Facility ID Number 0.002 

hours

Facility or Establishment Name 

0.002 hours 

Facility or Establishment Name or Mailing Address (If different from street 

address) 0.002 hours

Street 0.002 hours Mailing Address 0.002 hours

City/County/State/Zip Code 0.002 hours City/County/State/Zip Code 0.002 hours Country (Non-US) 0.002 hours

4.2 This report contains information for: 0.006 hours

(Important: Check c or d if applicable) a.  an entire facility b.  Part of a facility c.  a Federal facility d.  GOCO 

4.3 

Technical Contact Name 0.002 hours Telephone Number (include area code) 

 0.002 hours Email Address 0.002 hours 

4.4

Public Contact Name 0.002 hours Telephone Number (include area code) 

 0.002 hours Email Address 0.002 hours

4.5 NAICS Code(s) 

Primary 

b. c. d. e. f. a.0.002 hours

4.6 Dun & Bradstreet 

Number (s) (9 digits) 

a. 0.002 hours

b. 

SECTION 5. PARENT COMPANY INFORMATION 

5.1 Name of Parent Company NA  0.002 hours 

5.2 Parent Company’s Dun & Bradstreet Number NA  0.002 hours 

EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete. 
Appendix A 

 4/28/11 

A-14 

Form Approved OMB Number: 2070-0093 

(IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 03/31/2011 Page 2 of 5 

FORM R 

PART II. TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM 

TRI Facility ID Number 

Toxic Chemical, Category or 

Generic Name 

SECTION 1. TOXIC CHEMICAL IDENTITY (Important: DO NOT complete this section if you completed Section 2 below.) 

1.1 CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical 

 0.002 hours 

1.2 Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.) 

 0.002 hours 

Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked “yes”. Generic Name must be structurally descriptive.)

1.3 0.002 hours 

SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.) 

Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces and punctuation.) 

2.1 0.002 hours 

SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY 

(Important: Check all that apply.) 

3.1 Manufacture the toxic chemical: 

0.002 hours 3.2 Process the toxic chemical: 0.002 hours 3.3 Otherwise use the toxic chemical:0.002 hours

a.  Produce b.  Import 

a.  As a reactant 

b.  As a formulation component 

c.  As an article component 

c.  Repackaging 

c.  As an impurity 

a.  As a chemical processing aid 

b.  As a 

manufacturing aid 

c.  Ancillary or other use

If produce or import 

c.  For on-site use/processing 

d.  For sale/distribution 

e.  As a byproduct 

f.  As an impurity

SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON SITEATANY TIME DURING THE CALENDAR YEAR 

4.1 0.944 hours (Enter two digit code from instruction package.) 

SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE 

A. Total Release (pounds/year*)

(Enter a range code** or estimate) 

B. Basis of Estimate 

(enter code) 

C. % From Stormwater 

5.1 Fugitive or non-point 

air emissions 

NA 

0.005 hours

3.264 hours 0.010 hours 

5.2 Stack or point 

air emissions 

NA 

0.005 hours

1.879 hours 0.010 hours 

5.3 Discharges to receiving streams or 

water bodies (enter one name per box) 

Stream or Water Body Name 

5.3.1 0.008 hours 1.881 hours 0.010 hours 0.416 hours 

5.3.2 

5.3.3 

If additional pages of Part II, Section 5.3 are attached, indicate the total number of pages in this box, 

and indicate the Part II, Section 5.3 page number in this box. (example: 1,2,3, etc.) 

EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete. *For Dioxin or Dioxin-like compounds, report in 

grams/year. 

** Range Codes: A= 1-10 pounds; B= 11-499 pounds; 

C= 500-999 pounds. 
Appendix A 

Form Approved OMB Number: 2070-0093 

(IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 03/31/2011 Page 3 of 5

FORM R 

PART II. CHEMICAL - SPECIFIC INFORMATION (CONTINUED)

TRI Facility ID Number 

Toxic Chemical, Category or Generic Name

SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ON SITE (continued) 

NA A. Total Release (pounds/year*) 

 (enter range code ** or estimate ) 

B. Basis of Estimate 

(enter code) 

5.4.1 Underground Injection onsite to Class I 

Wells  0.005 hours 1.881 hours 0.010 hours 

5.4.2 Underground Injection onsite 

to Class II-V Wells  0.005 hours 1.881 hours 0.010 hours 

5.5 Disposal to land onsite 

5.5.1A RCRA Subtitle C landfills  0.005 hours 1.810 hours 0.010 hours 

5.5.1B Other landfills  0.005 hours 1.810 hours 0.010 hours 

5.5.2 Land treatment/application 

farming  0.005 hours 1.881 hours 0.010 hours 

5.5.3A RCRA Subtitle C 

surface impoundments  0.005 hours 1.810 hours 0.010 hours 

5.5.3B Other surface impoundments  0.005 hours 1.810 hours 0.010 hours 

5.5.4 Other disposal  0.005 hours 1.810 hours 0.010 hours 

SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS 

6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs) 

6.1.A Total Quantity Transferred to POTWs and Basis of Estimate 

6.1.A.1Total Transfers (pounds/year*) 

(enter range code ** or estimate) 

6.1.A.2 Basis of Estimate 

(enter code) 

1.881 hours 0.010 hours 

POTW Name 

6.1.B______ 0.008 hours 

POTW Address 0.008 hours 

City 0.008 hours State0.008 hours County 0.008 hours Zip 0.008 hours 

POTW Name 

6.1.B______

POTW Address 

City State County Zip 

If additional pages of Part II, Section 6.1 are attached, indicate the total number of pages 

in this box and indicate the Part II, Section 6.1 page number in this box (example: 1,2,3, etc.) 

SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS 

6.2.______ Off-Site EPA Identification Number (RCRA ID No.) 0.008 hours 

Off-Site Location Name 0.008 hours 

Off-Site Address 0.008 hours 

City 0.008 hours State 0.008 hours County 0.008 hours Zip 0.008 hours Country 

(Non-US)

0.008 

hours 

Is location under control of reporting facility or parent company?  Yes  No 0.008 hours

EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete. * For Dioxin or Dioxin-like compounds, report in grams/year ** Range 

Codes: A=1-10 pounds: B=1-499 pounds; C=500 - 999 pounds. 

 4/28/11 

A-15 
Appendix A 

 4/28/11 

A-16 

Form Approved OMB Number: 2070-0093 

(IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 03/31/2011 Page 4 of 5 

FORM R 

PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)

TRI Facility ID Number 

Toxic Chemical, Category or 

Generic Name 

SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (CONTINUED) 

A. Total Transfers (pounds/year*) 

(enter range code**or estimate) 

B. Basis of Estimate 

(enter code) 

C. Type of Waste Treatment/Disposal/ 

Recycling/Energy Recovery (enter code)

1. 1.810 hours 1. 0.010 hours 1.M 0.010 hours

2. 2. 2 . M 

3. 3. 3 . M 

4. 4. 4 . M 

6.2______ Off-Site EPA Identification Number (RCRA ID No.) 

Off-Site Location Name 

Off-Site Address 

City State County Zip

Country 

(Non-US)

Is location under control of reporting facility or parent company? Yes  No 

A. Total Transfers (pounds/year*) 

(enter range code**or estimate) 

B. Basis of Estimate 

(enter code) 

C. Type of Waste Treatment/Disposal/ 

 Recycling/Energy Recovery (enter 

code)

1. 1. 1 . M 

2. 2. 2.M 

3. 3. 3.M 

4. 4. 4.M 

SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY 

 Not Applicable (NA)

0.005 hours

Check here if no on-site waste treatment is applied to any 

waste stream containing the toxic chemical or chemical category 

a. General 

Waste Stream 

[enter code] 

b. Waste Treatment Method(s) Sequence 

[enter 3- or 4- character code(s)] 

d. Waste Treatment Efficiency 

[enter 2 character code] 

7A.1a 7A.1 1 2 7A.1d

0.162 hours 

3 4 0.648 hours 5 

0.416 hours 

6 7 8 

7A.2a 7A.2 1 2 7A.2d

3 4 5 

6 7 8 

7A.3a 7A.3 1 2 7A.3d

3 4 5 

6 7 8 

7A.4a 7A.4 1 2 7A.4d

3 4 5 

6 7 8 

7A.5a 7A.5 1 2 7A.5d

3 4 5 

6 7 8 

If additional pages of Part II, Section 6.2/7A are attached, indicate the total number of pages in this box . 

and indicate the Part II, Section 6.2/7 page number in this box: (example: 1,2,3,etc.) 

EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete. *For Dioxin or Dioxin-like compounds, report 

in grams/year 

**Range Codes: A=1 - 10 pounds; B=11 - 499 pounds 

C= 500-999 pounds. 
Appendix A 

 4/28/11 

A-17 

Form Approved OMB Number: 2070-0093 

(IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 03/31/2011 Page 5 of 5 

FORM R 

PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)

TRI Facility ID Number 

Toxic Chemical, Category or Generic Name 

SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES 

 Not Applicable (NA) – 0.005 hours Check here if no on-site energy recovery is applied to any waste 

stream containing the toxic chemical or chemical category. 

Energy Recovery Methods [enter 3-character code(s)] 0.648 hours

1 2 3 

SECTION 7C. ON-SITE RECYCLING PROCESSES 

 Not Applicable (NA) – 0.005 hours Check here if no on-site energy recovery is applied to any waste 

stream containing the toxic chemical or chemical category. 

Recycling Methods [enter 3-character code(s)] 0.648 hours

1 2 3 

SECTION 8. SOURCE REDUCTION AND RECYLING ACT IVITIES 

Column A 

Prior Year 

(pounds/year*) 

Column B 

Current Reporting Year 

(pounds/year*) 

Column C 

Following Year 

(pounds/year*) 

Column D 

Second Following Year 

(pounds/year*) 

8.1 

8.1a 

Total on-site disposal to Class I 

Underground InjectionWells, RCRA 

Subtitle C landfills, and other landfills 

0.009 hours 0.146 hours 0.030 hours 0.030 hours 

8.1b Total other on-site disposal or other 

releases 0.009 hours 0.146 hours 0.030 hours 0.030 hours 

8.1c Total off-site disposal to Class I 

Underground Injection Wells, RCRA 

Subtitle C landfills, and other landfills 

0.009 hours 0.146 hours 0.030 hours 0.030 hours 

8.1d Total other off-site disposal or other 

releases 0.009 hours 0.146 hours 0.030 hours 0.030 hours 

8.2 Quantity used for energy recovery 

onsite 0.009 hours 0.856 hours 0.030 hours 0.030 hours 

8.3 Quantity used for energy recovery 

offsite 0.009 hours 0.146 hours 0.030 hours 0.030 hours 

8.4 Quantity recycled 

onsite 0.009 hours 0.856 hours 0.030 hours 0.030 hours 

8.5 Quantity recycled offsite 0.009 hours 0.146 hours 0.030 hours 0.030 hours 

8.6 Quantity treated onsite 0.009 hours 0.856 hours 0.030 hours 0.030 hours 

8.7 Quantity treated offsite 0.009 hours 0.146 hours 0.030 hours 0.030 hours 

8.8 Quantity released to the environment as a result of remedial actions, catastrophic events, 

or one-time events not associated with production processes (pounds/year)* 0.146 hours 

8.9 Production ratio or activity index 0.944 hours 

8.10 Did your facility engage in any source reduction activities for this chemical during the reporting 

year? If not, enter “NA” in Section 8.10.1 and answer Section 8.11. 

Source Reduction Activities 

[enter code(s)] Methods to Identify Activity (enter codes) 

8.10.1 0.648 hours a. 0.010 hours b. c. 

8.10.2 a. b. c. 

8.10.3 a. b. c. 

8.10.4 a. b. c. 

8.11 If you wish to submit additional optional information on source reduction, recycling, or pollution 

control activities, check “Yes.” 

Yes 

 0.000 hours

EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete. *For Dioxin or Dioxin-like compounds, report 

in grams/year 

*Range Codes: A=1 - 10 pounds; B=11 - 499 pounds C= 

500-999 pound 
Appendix A 

 4/28/11 

A-18 
Appendix B 

 4/28/11 

B-1 

 

Steady State Total Burden Calculation 

This appendix presents and justifies the primary method of Ratio-Based Burden Methodology 

(RBBM)—the Steady State Total Burden Calculation, including details of its development. 

As stated earlier, Steady State Total Burden is the estimate of the ongoing TRI Program burden, 

as updated by rulemakings’ permanent impacts, but absent any first-time filer impacts. Recall 

from (Eqn. A- 5) of Appendix A:1, 2, 3 

Steady State Total Burden = Form R burden + Form A burden + Non-Form burden 

Where: 

• Form R Burden = (# Form R chemicals) * (Nominal Form R unit burden) 

• Form A Burden = (# Form A chemicals) * (A/R) * (Nominal Form R unit burden) 

• Non-Form Burden 

 = (Supplier Notification) + (Non-Reporter Compliance Determination) + Petitions 

And: 

A/R= Ratio model of single-chemical Form A unit burden to Form R unit 

burden 

Nominal Form 

R Unit 

Burden= 

Single base number for the entire methodology; provides the focal point 

for assessing and maintaining estimate accuracy 

The components of this method include Form burden (A/R model and Nominal Form R unit 

burden) and non-Form burden (petitions, supplier notification, and non-reporter compliance 

determination). An important note about this method is the way its components support the 

overarching methodology priorities of simplicity, internal consistency, and transitional baseline 

continuity. The A/R model ensures internal consistency between Form R and Form A unit 

burdens, and ultimately between total burdens for Form R and Form A chemicals. The Nominal 

Form R unit burden is computed with two purposes in mind: to provide a seamless transition 

from old to new methodology and to serve as the one point for adjustments and updates. 

The first section of this appendix presents the existing system’s relevant characteristics and 

explains why the new structure was chosen. This section is followed by a series of discussions on 

method development for several models. These discussions include, as part of the relevant A/R

model specifications, the substantive simplifications including: 1) neglect the effects of first-time 

filers in steady state burden estimates, and 2) set the value of PBT/non-PBT model equal to one. 

 

1 This model also applies to estimates of incremental burden associated with a proposed policy or regulatory change. 

In that case, the number of forms in the equation would represent the incremental number of forms associated with 

the proposed change.

2

 Note that the method’s formulation incorporates simplifications: a) Neglect the effect of first-time filers in the 

steady state, and b) set the ratio model for PBT to non-PBT burden equal to one. 

3

 For purposes of modeling, EPA refers to “Form R Chemicals” and “Form A Chemicals” in order to provide a 

consistent metric across form types. In practice Form R reports contain one chemical per report and Form A allows 

multiple chemicals (2.3 on average). 
Appendix B 

 4/28/11 

B-2 

 

Additionally, the details for specifying non-Form burden and for back calculating Nominal Form 

R unit burden are provided. 

This appendix does not address burden estimation associated with new Form elements, or related 

procedures for updating Nominal Form R unit Burden, as these topics are covered as a separate 

method in Appendix C. Similarly, as first-time filers are not included in RBBM’s formulation of 

the Steady State Total Burden Calculation; that estimation, for calculating first-time effects in 

rulemakings, is covered as a separate method in Appendix D. 

Changes to an Existing System: Adding Simplicity and Internal Consistency 

Two aspects of the existing methodology focused RBBM’s design. It was overly complex and it 

lacked internal consistency (see discussion in this document’s main report). In order to provide 

internal consistency, EPA redesigned the Steady State Burden Calculation to incorporate ratio 

models (discussed in next section). In order to simplify, EPA developed the Steady State Burden 

Calculation which requires a minimum number of variables (discussed further here). 

The overarching simplification in RBBM is to algebraically reduce a complex matrix system, as 

described in Appendix A. As an essential step in that simplification, EPA re-scaled facility-level 

factors to (per chemical) form-level factors. EPA derived Equivalent Form R/A Chemicals per 

Facility based on the distributions of Form R and Form A chemicals within and across facilities 

(see Appendix B Supplement – Distribution Analysis for details). In addition to providing 

simplification, the re-scaled factors prevent double-counting facility-level burden. 

Under the existing methodology, double-counting potential occurs in two variants. First, when 

total Form A and Form R burdens are estimated, both estimates count the burden for those 

facilities filing both A and R chemicals. Second, when a new chemical is reported by a facility, 

the incremental burden associated with the new chemical report does not discount for the fact 

that the facility may already be filing other chemical forms. With RBBM, facility-level burden is 

apportioned across (per chemical) form-level unit burdens, so that facility-level burden is now 

accounted for on a “by chemicals” basis, with each chemical’s burden only counted once each. 

As a secondary benefit of uniformly scaled factors, the RBBM form-level estimates are “fully 

loaded” to incorporate all aspects of TRI reporting. For this reason, the resultant unit burdens 

(Form R and the related Form A single-chemical) are comprehensive, preventing the need to 

track multiple unit burdens for form and facility. Similarly, the Standardized Form Element 

Burdens contain incremental elemental estimates that similarly incorporate all associated burden 

(discussed in Appendix C). 

As another essential step in the overarching simplification of algebraic reduction, EPA imposed 

substantive simplifications to the Steady State Total Burden Calculation by: 1) neglecting the 

effects of first-time filers in steady state burden estimates, and 2) setting the PBT/non-PBT

model’s ratio value equal to one. The first simplification is justified mathematically, as treating 

the relevant 3% of TRI chemical reports as steady state filers instead of first-time filers decreases 
Appendix B 

 4/28/11 

B-3 

 

the total steady state burden by .04%.4

 The second simplification is justified due to the absence 

of an evidence-based verifiable alternative (see discussion section on the PBT/non-PBT model). 

These simplifications, as adjustments to the overall burden calculation, improve the methodology 

in two ways. First, they keep the equation simple. Had these simplifications not been made, the 

Calculation would have required tracking subpopulations of PBT chemical filers and first-time 

filers, making the method more complex. As it now stands, only two input variables are 

required—number of Form R chemicals and number of Form A chemicals. A second benefit 

from these simplifications is the sophistication of a single unit burden for Nominal Form R unit 

burden with Form A reporting burden closely linked (see further discussion in Justification: 

Back-Calculated Nominal Unit Burden).

Moving from Implicit to Explicit Ratios 

Table B-1 provides the unit burdens and effective ratios embedded in the existing system. As 

described in the main report, the A/R is .64 across PBT and non-PBT chemicals. Similarly, the 

ratio for PBT/non-PBT is 1.73 across Form R and Form A chemicals. 

Table B-1: Summary of Form-Based Unit Burdens from Existing Methodology

Subsequent Year Burden Hours per Single Chemical Form* 

A/R=.64; PBT/non-PBT=1.73 

Non-PBT PBT 

Form R 29.66 51.34 

Form A 

(single chemical)** 

20.52 35.89 (no longer valid as PBTs 

may not be reported on Form A) 

*excludes facility-level burden for compliance determination 

**single chemical Form A is used in unit burden comparisons, although multiple chemicals may be 

reported on Form A (about 2.3 on average) 

Source: Toxics Release Inventory TRI Form R Toxic Chemical Release Reporting Information Collection 

Request Supporting Statement OMB Control Number 2070-0093 EPA ICR #1363.15. December 10, 2007. 

In the case of A/R, the current ratio of .64 for Form A to R burden5 is very close to RBBM’s 

value of .615. However, with the Form A to Form R burden very different from the ratio of form 

pages of .25, the ratio value needed to be more readily verifiable. Upon inspection, EPA 

concluded that the reason for the apparently high ratio is due to labor-intensive calculations 

required to determine Form A eligibility that are made regardless of final decision on Form type. 

Using RBBM, the detailed estimates of the Abt Associates Engineering Studies substantiate this 

finding with A/R burden estimated at .615. RBBM estimates Form A burden based on detailed 

 

4

 Based on 2008 ICR (RY 2007) chemical counts and models, see Findings under A/R Model in this Appendix. 5

 For details and context for the A/R value of .64, see: Rice, Cody. 2004. Terms of Clearance for TRI ICR Renewal. 

Regulations.gov. Accessed 23 Dec 2010 <http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OEI-2004-

0006-0004>Additional references include: 1) the Regulatory Impact Analysis of the EPCRA Section 313 Alternate 

Threshold Final Rule, Regulatory Impacts Branch, Economics, Exposure and Technology Division, Office of 

Pollution Prevention and Toxics, US Environmental Protection Agency, November 18, 1994 and 2) memo from 

Cody Rice (USEPA/OEI) to Amy Newman (USEPA/OEI) re: Terms of Clearance for TRI ICR Renewal, January 

20, 2004. Sources used to derive the .64 figure included 1) the original TRI Regulatory Impact Analysis, 2) the 

Pollution Prevention Act EA for the proposed rule from 1991, and 3) the 1/20/2004 Terms of Clearance Memo. 
Appendix B 

 4/28/11 

B-4 

 

 

analysis of common tasks between Form A and Form R.6 The RBBM approach to the A/R model 

ensures internal consistency and provides verifiable unit burdens, thereby increasing 

transparency. 

Regarding the ratio of PBT/non-PBT burden, the existing system’s ratio unintentionally resulted 

from discussions aimed at lowering totals with the decision to make a downward adjustment to 

non-PBT unit burden, while holding PBT unit burden constant.7

 Under these circumstances, the 

resultant ratio of 1.73 occurred as an offshoot of the revision process, rather than as a deliberate 

specification. This value of 1.73 is very different than the “null” assumption of 1.0, leaving the 

basis vulnerable to questions such as: Given the rationale that PBT chemical reporters incur 

greater burden because they cannot use the de minimis exemption, how much greater should the 

ratio be? How should the ratio be determined? Is there sufficient evidence to support the 73% 

difference? Ideally, quantitative evidence obtained via representative sampling would provide 

information on overall average conditions for TRI reporters. Regarding RBBM’s PBT/non-PBT

ratio model, EPA sought to specify a ratio value in a manner that would produce internally 

consistent and verifiable unit burdens.8

 

Justification: Ratio Models with Engineered Building Blocks 

As the name implies, ratio models are central to RBBM’s design. As often as possible, EPA 

formulates ratio models in order to characterize key relationships around which it wants to 

ensure internal consistency. In this appendix, EPA uses A/R and PBT/non-PBT models; see also 

Standardized Form Element Burdens, FTF, and WAWR models. The ratio structure has a number 

of advantages: 

• Ratios, as a type of measure, possess an absolute zero requiring less maintenance than 

measures of the components separately. 

• Ratio models themselves have intrinsic value, providing useful standalone metrics as they 

quantify key relationships between two elements. 

• Ratio models are inherently more stable and therefore more robust to changes than their 

component variables. 

Moreover, RBBM’s ratio models provide assurances that unit burdens are internally consistent 

and verifiable because: 

• Ratio models specify internal relationships. 

• The bases for the ratio models (A/R, FTF, WAWR) are quantitatively derived. 

 

6

 Note that the burden required to determine eligibility to use Form A (as described here) is not the same as the 

burden required to determine whether or not the Section 313 reporting requirements apply to a facility in general. 

Form A eligibility is based on whether, on a per chemical basis, a facility has less than 500 lbs of total annual 

reportable amount and that amounts manufactured, processed or otherwise used do not exceed one million lbs. 7

 For details, Rice, Cody. 2004. Terms of Clearance for TRI ICR Renewal. Regulations.gov. Accessed 23 Dec 2010 

<http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OEI-2004-0006-0004>. 8

 Ultimately, in RBBM the PBT/non-Pbt value is specified as one. Note, however, that the higher PBT reporting 

burden from the existing methodology is incorporated into RBBM’s Nominal Form R unit burden’s starting value of 

35.7 hours/Form R. See discussion in Justification: Back-Calculated Nominal Unit Burden section. 
Appendix B 

 4/28/11 

B-5 

 

 

Regarding the robustness, RBBM’s ratio models are robust due to the inherent stability of 

relationships that they characterize, as well as stability of related assumptions. For example, in 

the technology advances by which reporting shifted from primarily paper to electronic 

submission, the relationship between Form A burden and Form R burden remained largely 

unchanged and of the same ratio, while the magnitude of total reporting burden was estimated to 

decrease. This ratio remains stable because the changes to Form R and Form A impose similarly 

small incremental burden changes to both the numerator and the denominator of the ratio, thus 

causing the ratio itself to remain roughly constant. Note, however, that in the event that the Form 

R and/or Form A undergo extreme revisions that alter the relationship between A/R burden, then 

the A/R model would require updating. 

EPA developed RBBM’s ratio models based on existing work and best available information. 

Detailed burden estimates from the Abt Associates Engineering Studies are employed as 

computational components of RBBM ratio models (see Appendix G for these studies). In these 

studies, Abt Associates provided expertise for each study using a team of three staff with nearly 

40 years of combined experience working with facilities on environmental issues. These staff 

members had worked with hundreds of facilities on TRI reporting and other environmental 

requirements. They had conducted inspections and provided technical assistance, served as TRI 

trainers, conducted technical review on hundreds of TRI data withdrawal requests, conducted 

hundreds of TRI data quality calls, worked for two of the Massachusetts Toxics Use Reduction 

Act agencies, and worked as environmental staff at large manufacturing facilities. In short, the 

authors have a thorough understanding of what is required in reporting, especially with regard to 

the relative burden associated with each task in relation to others. The authors’ knowledge base 

was tapped to evaluate burden consistently across reporting activities and develop a systematic 

set of burden estimates. 

The Abt Associates Engineering Studies themselves provide estimates of burden by activity, 

with the “calculation and Form completion” activity broken down to element-by-element 

estimates. This means that for each element of a Form R, the authors evaluated the 

calculations/tasks involved and estimated burden. Moreover, within the Form R, the authors 

assessed how frequently a response was provided for each element, and adjusted the element 

burden by incidence weights.9

Given the strengths of internal validity and internal consistency, the Abt Associates Engineering 

Estimates are used as building blocks for ratio models in RBBM. Additionally, since these 

estimates were derived after the TRI program underwent numerous technology advances, EPA 

concludes that, on a relative basis, these estimates reflect updated and more current conditions 

than those made at TRI program inception. EPA recognizes that the information from the Abt 

Associates Engineering Studies drew from a non-representative sample of TRI reporters10, and 

consequently uses the estimates to develop ratio models of relative relationships but not for 

absolute measures (e.g. Form R compliance determination). Additionally, use of the Abt 

Engineering estimates provides a means by which A/R and other models may be verified. For 

9

 The incidence rate was calculated using the frozen RY 2002 TRI data. All but one method of the RBBM use this 

version of unit burdens (in models A/R, FTF, WAWR). The exception is the set of Form Element Burden Estimates, 

for reasons described in Appendix C. 

10 Note that this weakness does not pose problems in the context of designing ratio models reflecting relative 

relationships; it is more problematic when revising absolute values for unit burdens. 
Appendix B 

 4/28/11 

B-6 

 

 

justifications of the values assigned to the specific ratios see detailed sections on the ratio models 

themselves in this and other appendices. 

Justification: Back-Calculated Nominal Unit Burden 

RBBM’s base unit burden, Nominal Form R unit burden is a base number for the entire 

methodology. Due to the simplifications described above, it provides a comprehensive single 

focal point for discussions about methodology accuracy. For routine adjustments, such as Form 

R revisions, estimates for increases or decreases in burden associated with the particular form 

changes are applied to the Nominal Form R unit burden, with related changes automatically 

propagated through the RBBM system via ratio models (e.g., to Form A, and for first-time 

filers). As an additional RBBM feature, with the ratio models addressing key internal 

relationships, Nominal Form R unit burden reflects overall average conditions for all remaining 

unspecified effects, removing the need to revise the methodology by adding variables.11 

EPA considered the question: How should the value of the base unit burden be set? From the Abt 

Associates Engineering Studies, one could ask, why not just sum up the Form R element-byelement estimates to set the value for the Form R unit burden of 7.06 hours? Instead, RBBM sets 

the base unit burden based on the back-calculated number—35.7 hours per Form R—that 

preserves the same total burden, assuming constant levels of Form R and Form A chemical 

counts. 

In managing the transition to RBBM, EPA placed priority on ensuring transitional baseline 

continuity. This requirement preserves the baseline of total burden at its existing level, with 

RBBM estimates starting at the point from which prior estimates left off. Note that EPA defines 

the methodology revision’s transition point as the time of the last ICR approval.12 Thereafter 

updates are to be made according to RBBM, either via wholesale changes to the Nominal Form 

R unit burden, or by making incremental changes to it using Standardized Form Element 

Burdens. Given the simplified Steady State Total Burden Calculation, with the A/R key 

relationship modeled and the total burden fixed, the only variable left unspecified is the base unit 

burden. The resultant back-calculated value is 35.7 hours, and the variable is termed Nominal 

Form R unit burden. 

EPA refers to the back-calculated number as the Nominal Form R unit burden because it is a 

base number without exact derivation from rigorous modeling. Mathematically, it represents the 

Form R, non-PBT, subsequent year unit burden. In practice it serves as a proxy for overall 

average conditions for all Form R’s (with Form A burden closely linked at 61.5% of that unit 

burden). As noted above in the previous discussions on overarching simplifications, this unit 

burden incorporates facility-level burdens, comprehensively reflecting all aspects of relevant TRI 

reporting.13

11 In this Appendix, the discussion has mainly focused on the PBT/non-PBT and first-time filer effects because they 

were part of the previous methodology. The broader argument stated here applies to other unmodeled effects, such 

as ongoing staff turnover. 

12 Based on 2007 projections, see TRI 2008 ICR Supporting Statement. 

13 Note also that Standardized Burden Element Burdens (See Appendix C), used to update the Nominal Form R unit

burden in the event of form changes, are also comprehensive (i.e.,“fully loaded”) and internally consistent with the 

base unit burden. 
Appendix B 

 4/28/11 

B-7 

 

As a reflection of overall average Form R unit burden, RBBM’s Nominal Form R unit burden

carries forward certain prior assumptions from the existing methodology without explicitly 

modeling them. In particular, note that the higher PBT reporting burden for 20% of Form Rs is 

incorporated into the Nominal Form R unit burden’s starting value of 35.7 hours/Form R, which 

is elevated above the value that would have been otherwise obtained—at about 30 hours/form—

had only non-PBT burden been used to determine Nominal Form R unit burden.

14

EPA supports this value of 35.7 hours per Form R as a reasonable approximation of the actual 

unit burden, based on years of review and scrutiny to which the current total burden estimate has 

been subjected. The unit burden of 35.7 hours, in the context of a new system of ratio models, is 

the culmination of prior accuracy assessments, including a 49% decrease to the baseline in the 

2004 ICR Renewal.15 Therefore, this basis is legitimized for ultimately setting the magnitude of 

the Program total burden at this time. 

Method Development 

In this section, EPA describes the development work and model-specific justifications for the 

key components for the Steady State Total Burden Calculation. The section covers models for 

Form Burden and constants for non-Form Burden. The back-calculated unit burden is presented 

last, because it is specified last. 

PBT/Non-PBT Model 

The PBT/non-PBT model specifies unit burden for PBT chemicals with respect to non-PBT 

chemicals. In this methodology, the value of this ratio is set equal to one: 

Ratio of Form R PBT Unit Burden to Form 

R non-PBT Unit Burden 

 [=] Hours per PBT Form R 

 Hours per non-PBT Form R 

Unlike most analytical decisions in the revised methodology, the decision to set the PBT/nonPBT equal to one is based on the lack of evidence. It is an assertion of a null hypothesis out of 

concern that the existing system’s specification of 1.73 is unverifiable and could produce internal 

inconsistencies. EPA concludes that in the event that a reasonable person asks: Why would a 

PBT chemical require 73% more burden, on average than a non-PBT chemical? EPA should 

 

14 Note from Table B-1 that form-level burden is 29.66 hours per Form R chemical. Adding facility level burdens 

totaling 4 hours per facility, and given that each reporting facility manages about 4 Form R chemicals, yields the 

rough estimate of 30 hours per non-PBT Form R chemical. 

15 As an overall 57% downward adjustment, the TRI Program burden estimate was decreased from 6.03 million to 

2.61 million hours according to Notices of OMB Action (called Paperwork Reduction Submissions) for Form R ICR 

and Form A ICR. Submitted October 27, 2003. Approved January 9, 2004. Based on the TRI 2004 ICR Supporting 

Statements, there were four sources (with relative contributions): 1) reducing non-PBT subsequent year burden from 

47.1 to 14.5 hours (85.95%), 2) correcting the previous ICR due to Lead Rule implementation (6.37%), 3) changes 

to actual reporting from previous ICR (.24%) and 3) a one-time adjustment for TRI-ME (7.44%). This yields a 49% 

decrease in total burden associated with the methodology change from the first source. 
Appendix B 

 4/28/11 

B-8 

 

have a concrete, evidence-based response. In the absence of such quantitative evidence, the 

fallback position was chosen. 

This question has been extensively debated. On one side, public comments from industry express 

concern about additional burden due to additional demands related to PBT reporting 

requirements. One the other side, Abt Associates Engineering Studies find no substantial bases 

for differences. Table B-3 provides the arguments on both sides. Regardless of credibility on 

either side, both of which are compelling, neither position offers strong evidence of the most 

likely average relationship representative of the TRI reporting population. EPA concludes that 

the ratio of PBT to non-PBT reporting burden cannot be determined analytically using the 

readily available information. 

As an important qualifier, even though the ratio value for the model for PBT/non-PBT is set 

equal to one, the overall Steady State Burden Calculation carries forward the elevated level of 

burden related to the prior assumptions of higher PBT unit burden from the existing 

methodology while not explicitly modeling the effect (see discussion earlier, under Justification: 

Back-Calculated Nominal Unit Burden).

Table B-3: PBT Chemical Reporting Burden relative to non-PBT Chemicals 

Industry Comments Abt Associates Engineering Studies 

SUMMARY 

Special conditions of PBT reporting, including 

no de minimis exception and no range 

reporting create higher burden for PBT 

reporting. 

SUMMARY 

Activities required for reporting PBT and nonPBT chemicals are similar enough that the 

same unit burden hour estimate should be used. 

PBT reporting requires additional research, 

inquiries of suppliers not required to provide 

notification of de minimis levels of PBT chemicals, 

additional calculations for compliance 

determinations, additional calculations for Form R 

completion and recordkeeping (extra burden 

associated with obtaining and managing the 

relevant data). 

1) It does not appear, however, that the lack of the 

de minimis exemption will increase the burden 

associated with making release estimates due to a 

need to assess additional waste streams. 

2) Also, not being able to use range reporting does 

not actually increase the reporting burden for PBT 

filers. Even though range reporting is allowed for 

non-PBT chemicals in Part II, Sections 5 and 6 of 

the Form R, it is not allowed for same data 

elements in Part II, Section 8. As a result, no fewer 

calculations are necessary to complete a Form R for 

non-PBTs versus PBTs due to range reporting. 

Requires facilities to report PBT chemicals to a 

precision level of .1 lbs for lead or .0001 grams for 

dioxins; large number of facilities reporting one 

pound or less; median lead release for all reporters 

is one pound.* 

*Lead and Lead Compounds Form R reports constitute about 55% of PBT chemical reports (and PBTs constitute 

about 20% of total TRI chemical reports)—measured by average percentages in period between 2004-2007 in 

Frozen TRI data for RY 2007 
Appendix B 

 4/28/11 

B-9 

 

Sources: 

1) Industry comments drawn from comment documents in docket #OEI-2003-0025 for EPA ICR No. 1363.12 and 

EPA ICR 1363.13;in docket # OEI-2004-0006 for EPA ICR 1363.14; and from docket # TRI-2007-0355, EPA 

ICR 1363.15 

Abt Associates Engineering Studies (provided in Appendix G) based on development of Realistic Burden Estimates 

for Total Form R Completion (also see description of these models in this Appendix’s “Justification: Ratio Models 

with Engineered Building Blocks”).This analysis was conducted separately for non-PBT and PBT chemicals 

In conclusion, EPA recommends the value for the PBT/non-PBT model of 1.0 hr/hr. 

A/R Model 

Given the decision to set PBT/non-PBT equal to one, the next question to address in developing 

the Steady State Total Burden Calculation is: how to set the A/R ratio value? The A/R model 

specifies the unit burden for Form A as a function of its components common to Form R, defined 

by: 

Ratio of Form A Unit Burden to Form R 

Unit Burden 

 [=] Hours per Single-Chemical Form A

 Hours per Form R 

Computed using the factor matrices for Form R and Form A (as derived from Form R)16

presented in Appendix A: 

A/R = ( [A factors from F′′i,j] / ( [F′′ ∑∑ i,j ]﴿ ==

3

1

4

1 ji

∑∑ ==

3

1

4

1 ji

In A/R model building, EPA ensures internal consistency between Form A and Form R. When 

specifying the set of Form R activities similarly applicable to Form A, the factor for calculations 

and form completion is based on the burden involved in Form A eligibility determination 

(including half of Form R’s Section 5 and 6 work) plus all the tasks associated with Form R 

elements that also occupy Form A. This level of detail was provided via the rigor of the Abt 

Associates Engineering Studies. See Appendix A’s Table A-4 for calculation results for A/R

components, according to Form R and Form A. Also see Table A-5 for a comparison of relative 

contributions from the various activities across Forms. 

The design of this model required the following steps:17

1. Rescale facility-level factors to form-level factors. 

2. Reduce the factor matrices to sums for each Form A and Form R. 

3. Compute the ratio of Form A to Form R burden. 

4. Verify simplifying assumptions. 

 

16 Where i denotes the row and j denotes the column from the Matrix F′′ in Appendix A. 17 See Appendix A for an overview of the derivations and page 10 of the main report for an overview of the decision 

rules. 
Appendix B 

 4/28/11 

B-10 

 

 

5. Assess model robustness to shifts in distributions of Form R and Form A chemicals 

within and across facilities. 

The key analytical decisions for developing this model include: 

1. Deriving Equivalent Form R/A Chemicals per Facility for use in rescaling facility-level 

factors to (per chemical) form-level factors (covered in Appendix B Supplement). 

2. Determining how to translate the burden estimates for Form elements in Form R to 

corresponding estimates for Form A. 

3. Where possible, confirming simplifying assumptions. 

Testing the A/R Model 

Table B-4 presents the results of the tests that support EPA’s analytical decisions to incorporate 

distributional effects in rescaling, to neglect the effect of first-time filers, and to employ the most 

rigorous version of Abt Associates’ estimates (incidence weighted engineering estimates). 

Column (1) shows the reference case, which is the most complex model without any 

simplifications. The reference case has the following attributes: 

• Incorporates first-time filer effects 

• Uses the most rigorous version of the Abt Associates Engineering Studies’ estimates 

(incidence-weighted “Realistic” estimates) 

• Rescales using Equivalent Form R/A Chemicals per Facility. 

Each model run as shown in Columns (2) through (4) removes complexities one at a time to 

support the recommended model in Column (5) which accepts only one simplification—to 

neglect first-time filers.18 Additionally, Column (6) provides a robustness test that shows how 

much modeling error would be incurred if circumstances changed to a dramatically different 

distribution of Form Rs/Form As within and across facilities.19

18 EPA expected negligible first-time filer effects on the steady state burden because first-time filers account for 

2.87% of the total chemicals filed and 6.16 % of facilities (average percentages in period between 2004-2007 per 

Frozen TRI data for RY 2007 based on RY 2005). 

19 EPA used distributions from TRI Phase II burden reduction conditions (see details in Appendix B Supplement). 
Appendix B 

 4/28/11 

B-11 

 

Table B-4: A/R Model Development Results and Analysis 

Test Run 

Description 

(1) 

REFERENCE 

no 

simplifications 

(2) 

Same as 

(1) but 

without 

first-time 

filer 

adjustment 

(3)

Same as (1) 

but without 

incidence 

rate 

adjustments 

(4)

Same as (1) 

but without 

distribution 

specificity* 

(5) 

RECOMMENDED 

 realistic 

estimates with 

incidence rate 

adjustments** 

(6)

Robustness 

Test - 

alternate 

distribution

*** 

 Model Form R 

unit Burden 

(hrs/Form R) 12.66 12.52 27.24 12.67 12.52 12.53 

 

Model Form A 

unit burden 

(hrs/single 

chem Form A) 7.76 7.67 13.16 7.95 7.71 7.67 

 

 

A/R 0.613 0.612 0.483 0.628 0.615 0.612 

A/R % difference from Reference 

(Model Error) -0.12 -21.22 2.41 0.39 0.50 

* Does not account for potential double-counting of facility level burden among facilities reporting both Rs and As. 

** Current A, R, A+R distributions, no first-time filer adjustments 

*** Phase 2 Burden Reduction Rule 

Findings 

The recommended formulation of the A/R model with a value of .615 hr/hr, is robust to changes 

in model assumptions as well as changes in actual conditions, as simulated, yielding differences 

between A/R conditions and the A/R model under 0.5 %. Moreover, similar results are shown for 

the Nominal Form R unit burden in Table B-5—with a corresponding difference of 1%. 

Regarding the practical need for distributional considerations, given the relatively small 

difference for A/R at 2.41%,20 EPA considered making the additional simplification. However, 

with the conversion factors (Equivalent Form R/A Chemicals per Facility—Rcpfe. Acpfe) 

fundamental to RBBM overall, and integral to the development of several models (A/R, FTFf, 

WAWR), EPA examined the robustness of the conversion factors themselves. Table B-5 presents 

the result that even in the face of dramatic shifts in distribution, Equivalent Form R/A Chemicals 

per Facility are reasonably robust, within about 10%. 

Taking a more comprehensive view, EPA calculates the effects of 1) neglecting first-time filers 

and 2) the alternate distribution on the Steady State Total Burden estimate. Regarding the 

assumption to neglect the effect of first-time filer in the steady state, EPA calculates the effect of 

modeling error on the Steady State Total Burden estimate at -.04% . Regarding the test for an 

alternate distribution, EPA calculates the associated error of encountering different conditions 

while using RBBM original models which results in an error of -.55% for Steady State Total 

Burden. 

 

20 The percent difference is calculated by taking the difference between the reference A/R model without 

distributional specificity and the reference A/R model divided by the reference A/R model [((0.628-0.613)/0.613) 

*100 =2.41% ]. Note that figures have been rounded. 
Appendix B 

 4/28/11 

B-12 

 

Table B-5: Nominal Form R Unit Burden and Equivalent Forms per Facility 

Test Run 

Description 

(1) 

REFERENCE 

no 

simplifications 

(2) 

Same as (1) 

but without 

first-time filer 

adjustment 

(3)

Same as (1) 

but without 

incidence 

rate 

adjustments 

(4)

Same as (1) 

but without 

distribution 

specificity* 

(5) 

RECOMMENDED 

realistic estimates 

with incidence 

rate adjustments** 

(6)

Robustness 

test - 

alternate 

distribution*** 

A/R 0.613 0.612 0.483 0.628 0.615 0.612 

A/R % difference from Reference 

(Model Error) -0.12 -21.22 2.41 0.39 0.50 

 

 

Back 

Calculated 

Nominal 

Form R Unit 

Burden 35.75 35.75 37.15 35.59 35.72 35.99 

Nominal Form R Unit Burden % 

difference from Reference (Model 

Error) 0.02 3.92 -0.43 -0.07 -0.77 

Equivalent 

Form R 

chemical/facility 3.869 3.869 3.869 3.733 3.869 3.817 

chemical/Form R % difference from 

Reference -3.53 0.00 -1.35 

Equivalent 

Form A 

chemical/facility 3.407 3.407 3.407 2.302 3.407 3.777 

chemical/Form A % difference from 

Reference -32.43 0.00 10.86 

* Does not account for potential double-counting of facility level burden among facilities reporting both Rs and As. 

**Current A, R, A+R distributions, no first-time filer adjustments 

*** Phase 2 Burden Reduction Rule

Non-Form Burden 

The non-Form burden portion of the Steady State Burden Calculation contains three components: 

petitions, supplier notification, and non-reporter compliance determination. Each component and 

the new method’s simplifying assumptions are presented below.21

Burden associated with supplier notification applies to suppliers with customers subject to 

EPCRA §313 reporting. These suppliers do not necessarily complete TRI reports/Forms 

themselves. On an annual basis, 3,734 facilities are assumed to spend 24 hours each for a total 

of 89,616 hours. This estimate is currently not regularly updated. It was reviewed in terms of 

providing an adequate level of burden for the task and viewed as sufficiently high. Moving 

forward with the same basis of numbers of facilities and hours per task—and supporting 

transitional baseline continuity—a constant value of 89,616 hours is estimated. 

 

21 For more detailed information regarding the existing method for non-form burden estimates, see TRI 2008 ICR 

Supporting Statement. 
Appendix B 

 4/28/11 

B-13 

 

 

Burden associated with non-reporter compliance determination comes from facilities outside of 

the TRI reporting community that have to determine whether they need to file a Form R or Form 

A. On an annual basis, 183,744 facilities22 are assumed to spend four hours each for a total of 

734,976 hours. In this method, all facilities in NAICS-code-eligible sectors (with ten or more 

employees) are assumed to incur compliance determination burden. When reviewing this 

assumption, EPA concluded that it produces a highly overstated estimate because only those 

facilities close to the cusp of TRI reporting thresholds for manufacture, process and otherwise 

use, need to check their reporting eligibility regularly. In sum, the burden estimate was reviewed 

in terms of providing an adequate level of burden for the task and viewed as sufficiently high. 

For the sake of simplicity in support of transitional baseline continuity, this basis of numbers of 

facilities and hours per task will be frozen and the new methodology estimates the current value 

as a constant—734,976 hours. 

Burden associated with petitions for the TRI program includes activities to research, prepare and 

file a petition with EPA. In the existing method, five petitions per year are assumed at 185 hours 

per petition, totaling 925 hours. This estimate is currently not regularly updated. It was reviewed 

in terms of providing an adequate level of burden for the task and viewed as sufficiently high. 

Moving forward with the same basis of numbers of petitions and hours per petition, as well as 

supporting transitional baseline continuity, a constant value of 925 hours is estimated. 

In comparison to the Form burden estimates, which vary with the number and types of Forms 

that are being filed, the non-Form burden estimates remain constant in the Steady State Total 

Burden Calculation. Moreover, as these estimates are sufficiently large, and in one case highly 

overstated, they do not require any regular maintenance or further updates. The sum of non-Form 

burden is constant at 825,517 hours. 

Nominal Form R Unit Burden 

Given overarching simplifications and RBBM’s objective of transitional baseline continuity, 

Nominal Form R is back-calculated via the following equation:23

Eqn. B-1: Nominal Form R Unit Burden 

 = (Total Burden – non-Form burden)/[(# Form R chemicals)+((A/R)*#Form A chemicals)] 

EPA defines the methodology revision’s transition point as the time of the last ICR approval 

with conditions specified by 2008 ICR renewal projections. This calculation produces a value of 

35.7 hours per Form R chemical for the Nominal Form R unit burden. As shown in Table B-5, 

22 The estimate for the number of facilities that are doing compliance determination but not reporting to TRI is 

determined by subtracting reporters from the total number of facilities with ten or more employees in TRI-subject 

NAICS codes. To compute the number of reporting facilities, EPA divides the current number of Form R reports 

from the latest ICR by the average number of Forms per facility—66,751/3.7. Although non-Form burden has 

historically been reported with the estimate for Form R burden in its ICR Supporting Statement, this is only done by 

convention, as it reflects total non-Form burden for the TRI program. 

23 In the actual calculation EPA corrects for double-counting of facility level burden among facilities filing both As 

and Rs in the last ICR renewal, shifting the baseline downward slightly (administrative correction due to calculation 

error). The double-count was caused by estimating facility-level burden twice for facilities that file both Forms R 

and A. In the revised methodology the conversion factors for equivalent chemicals per facility used to rescale 

facility unit burdens prevent double-counting. 
Appendix B 

 4/28/11 

B-14 

 

 

the Nominal Form R unit burden is robust to changes in model assumptions as well as changes in 

conditions, showing differences under 1%. 

In April 2010, EPA tested the effectiveness of the back-calculated Nominal Form R unit burden

in providing transitional baseline continuity. In a spot-check comparison between RBBM Steady 

State Total Burden and the TRI Program on-record burden numbers, results were within 2%.24

Summary: Steady State Total Burden Method

Computation 

Eqn. B-2: Steady State Total Burden = Form R burden + Form A burden + non-Form burden

= (Nominal Form R unit burden*# Form R chemicals) 

+(Form R unit burden*(A/R)*#Form A chemicals) + non-Form burden 

= 35.7*# Form R chemicals + [35.7 * .615 * # Form A chemicals] + 825,517

Where: 

A/R= Ratio model of single-chemical Form A unit burden to Form R unit 

burden 

Nominal 

Form R unit 

Burden= Single base number for the entire methodology; provides the focal point 

for assessing and maintaining estimate accuracy. 

Assumptions 

The following assumptions apply for the maintenance and update recommendations that follow: 

1) Simplifying substantive assumptions remain valid. First-time filers in the steady state 

have a negligible effect; PBT/non-PBT burden=1 due to lack of a verifiable alternative. 

2) The Nominal Form R unit burden of 35.7 hours remains a reasonable estimate of unit 

burden with Form R non-PBT remaining the most frequent type submission. 

3) Relationships between reporting activities in the Abt Associates Engineering Studies 

which are drawn from a subpopulation, as measured by best professional judgment of Abt 

Associates’ engineers, are reasonably reflective of the true relationships in the total 

reporting population overall. 

4) The distribution for Form As/Form Rs within and across facilities stays within the range 

of distributions in this study (see values for Equivalent R/A Chemicals per Facility in 

Appendix B Supplement). 

24 As of June 2010, the sum of burden hours “on record” was 3.87 million hours, based on Notices of OMB Action, 

Form R ICR and Form A ICR March 27, 2009. The corresponding RBBM estimate is 3.93 million hours which is 

within 2%. Note that this RBBM estimate does not include updates to the Form R unit burden to account for the 

slight additional burden associated with dioxin reporting (see estimate in the TRI 2012 ICR Renewal Supporting 

Statement). 
Appendix B 

 4/28/11 

B-15 

 

Maintenance and Update Recommendations 

EPA evaluated maintenance needs for A/R, Nominal Form R unit burden, and Equivalent Form 

R/A Chemicals per Facility. None of the models require updating on a routine basis. The A/R

model and the back-calculated Nominal Form R unit burden values are robust to extreme 

changes in (per chemical) Form/facility distributions and model assumptions, with differences of 

less than 1%. However, EPA notes that the A/R formulation is dependent on the conversion 

factors used to rescale facility-level unit burdens to (per chemical) form level. Regarding the 

conversion factors, EPA does not anticipate extreme changes in their values under status quo 

operations (and even so, results here are within a 10% modeling error). However, in the event 

that the program adds industry sector(s), the (per chemical) form/facility distribution could shift 

due to the addition of large chemical counts of different distributions than the distributions 

considered here. 

As a practical matter, given that the requirements for ICR renewal reporting provide periodic 

recalculation of the Equivalent Form R/A Chemicals per Facility, these numbers can be routinely 

checked to be sure that this basis for the A/R model (and others—FTFf and WAWR) remains 

valid. EPA recommends this routine check. 
Appendix B 

 4/28/11 

B-16 

 

 Supplement– Distributional Analysis 

Equivalent Form R Chemicals per Facility and 

Equivalent Form A Chemicals per Facility 

This supplement describes how and why the conversion factors, Equivalent Form R/A Chemicals 

per Facility ( / ) were developed. The factors are used to re-scale facility-level unit 

burdens to (per chemical) form level unit burdens. This supplement describes: 

Rcpf e Acpfe

• Why the scaling factors are needed; 

• Formulas used to calculate the factors; 

• Derivation of the formulas; 

• Distributions for Forms R and A reporting under two scenarios; and 

• Values for these factors under the two scenarios. 

The derivations below provide a divisor for each facility-level unit burden that apportions facility 

level burden to form level burden. Based on the distributions of Form As and Form Rs within 

and across facilities, facility-level burden associated with Form R chemicals is apportioned 

equally across Form R chemicals and facility-level burden associated with Form A chemicals is 

apportioned equally across Form A chemicals. As a result of the derivations herein, these values, 

as used for scaling facility-level factors to chemical level factors are (used in matrices of 

Appendix A and Table A-4) are: 

Equivalent Form R Chemicals per Facility, = 3.87 Rcpf e

Equivalent Form A Chemicals per Facility, = 3.42 Acpfe

Equivalent Form R Chemicals per Facility ( ) and Equivalent Form A Chemicals per 

Facility ( )

Rcpf e

Acpfe

Facilities reporting to TRI incur facility-level burden, such as compliance determination. This 

facility-level burden is incurred once per reporting cycle, regardless of how many forms a 

facility files. Facility-level burden must be converted to a per chemical measure unit burden to be 

incorporated into the chemical-level ratio model. The conversion entails breaking down and 

apportioning the facility-level burden by chemical and it depends on the number and form-type 

of chemicals filed at the average facility. Since EPA tracks burden differently for A and R 

reporting, the apportionment must be calculated separately for Form R and Form A reporting, 

with consideration of the combined Form distributions at facilities. 

At the form level, R and A chemicals are reported differently, with Form Rs containing one 

chemical per form and Form As containing one or multiple chemicals on the same form. In 

actual reporting, a given facility may report any combination of Form types (Rs only, As only, or 

Rs and As together). 

For purposes of methods development and modeling, EPA refers to Form R chemicals and Form 

A chemicals as the number of chemicals for which each form type is submitted. This metric puts 

both types of reporting on the same basis, avoiding the awkward conversion to put Form As on a 

per chemical basis, dividing by the average number of chemicals per form. In TRI program 
Appendix B 

 4/28/11 

B-17 

 

operations, the average number of chemicals per Form A is used to scale chemical counts to 

form counts, as required to report to OMB the number of responses. It is also intuitively helpful 

to know how many chemicals, on average, are reported via Form A. This conversion—based on 

raw counts of chemicals and facilities—is different than the conversion described herein for 

purposes of re-scaling facility-level unit burdens to per R/A chemical bases (here termed 

Equivalent Form R/A Chemicals per Facility). 

Since, Form Rs and Form As are considered separately in the model, two measures of facilitylevel burden per chemical are needed: 

Bprc Facility-level burden per Form R chemical, in hrs/Form R chemical 

Bpac Facility-level burden per Form A chemical, in hrs/Form A chemical 

Equivalent Form R/A Chemicals per Facility are used to allocate facility-level burden to 

chemical-level burden. For example, chemical-level unit burden (e.g., compliance determination 

per Form R chemical) for Form Rs can be calculated by dividing facility-level burden associated 

with Form R chemicals by Equivalent Form R Chemicals per Facility. Similarly, chemical-level 

burden for Form As can be calculated by dividing facility-level burden associated with Form A 

chemicals by Equivalent Form A Chemicals per Facility.

 Equivalent Form R Chemicals per Facility Rcpfe

 Equivalent Form A Chemicals per Facility Acpfe

These scaling factors are used instead of average forms per facility to adjust reporting burden in 

a manner that prevents the potential double-counting of facility-level burden for that can occur 

when a facilities that files both Form Rs and Form As. There are three types of facilities that 

report to TRI (see Figure B-1): 

• Facilities reporting only Form As (A Only), 

• Facilities reporting both Form As and Form Rs (R+A), and 

• Facilities reporting only Form Rs (R Only). 

Figure B-1: Facility Types 

If average forms per facility is used to allocate facility-level burden to chemical-level burden, 

R+A facilities are double-counted (Figure B-2). Using Equivalent Form R/A Chemicals per 
Appendix B 

 4/28/11 

B-18 

 

Facility to apportion facility-level burden across forms removes this double-counting; these 

measures account for the distribution of Form As and Rs within and across facilities. 

Figure B-2: Double-Counting using Average Forms per Facility 

Calculation of Bprc and Bpac using and Rcpfe Acpfe

EPA calculates and using a measure of nominal facility-level burden per facility 

and and . EPA calculates and from the distributions of Form R and 

Form A reporting among facility types. Specific measures used include counts of Form R 

chemicals and Form A chemicals reported and counts of facilities reporting Form Rs and As. 

Bprc

Apcfe

Bpac

Rpcfe Rpcfe Apcfe

 

The formulas Bprc and are as follows: Rcpfe

e

OVERALL

Rcpf

Bff Bprc = , where 

RONLY ARR

RTOT

f f

rc Rcpfe + +

= η

ARAR

AR

acrc

rc

R + +

+

+ η =

= Nominal facility-level burden per facility overall, for all TRI filers BffOVERALL

 = Number of R+A facilities ARf +

 = Number of R Only facilities RONLY f

 = Number of Form A chemicals reported to TRI by R+A facilities AR ac +

 = Number of Form R chemicals reported to TRI by R+A facilities AR rc +

 = Number of Form R chemicals reported to TRI (by R+A and R Only facilities) RTOT rc

The formulas Bpac and are as follows: Apcfe

e

OVERALL

Acpf

Bff Bpac = , where 

AONLY ARA

ATOT

f f

ac Acpfe + +

= η

ARAR

AR

acrc

ac

A ++

+ η = +

= Nominal facility-level burden per facility overall, for all TRI filers BffOVERALL

 = Number of R+A facilities ARf +

 = Number of A Only facilities AONLY f

 = Number of Form A chemicals reported to TRI by R+A facilities AR ac +

 = Number of Form R chemicals reported to TRI by R+A facilities AR rc +
Appendix B 

 4/28/11 

B-19 

 

 = Number of Form A chemicals reported to TRI (by R+A and A Only facilities) acATOT

Derivation of Formulas for Bprc , , Bpac , and Rcpfe Acpfe

Together, facility-level burden per Form R chemical ( ) and facility-level burden per Form 

A chemical ( ) must account for facility-level burden from all three facility types (Table B6). 

Bprc

Bpac

 Total facility-level burden associated with Form R chemicals from R Only 

facilities 

BfRONLY

 Total facility-level burden associated with Form A chemicals from A Only 

facilities 

Bf AONLY

 Total facility-level burden associated with Form A and R chemicals from R+A 

facilities 

Bf + AR

 Total facility-level burden associated with Form R chemicals and Form A 

chemicals from all facilities 

BfOVERALL

Table B-6: Facility-level Unit Burden 

Facility Type Form Type Facility-Level Burden 

A Only Form A Bf AONLY

A+R BfOVERALL

Form A 

Bf + AR

Form R 

R Only Form R BfRONLY

All facility-level burden from R Only facilities is apportioned to Form R chemicals. Similarly, all 

facility-level burden from A Only facilities is apportioned to Form A chemicals. To avoid 

double-counting, facility-level burden from R+A facilities is split between Form R chemicals 

and Form A chemicals (Table B-7). 

 Total facility-level burden associated with Form A chemicals from all facilities 

reporting Form As 

BfATOT

 Total facility-level burden associated with Form R chemicals from all facilities 

reporting Form Rs 

BfRTOT
Appendix B 

 4/28/11 

B-20 

 

Table B-7: Apportionment of Facility-level Unit Burden to Rs and As 

Facility Type Form Type Facility-Level Burden 

A Only Form A Bf AONLY BfATOT

A+R BfOVERALL

Form A 

Bf + AR

Form R BfRTOT

R Only Form R BfRONLY

The total facility-level burden for A+R facilities can be apportioned amongst form types using 

the fraction of forms reported by A+R facilities that are Form Rs and Form As (Figure B-3, 

Table B-8). This method assumes the magnitude of total facility-level burden for each form type 

is distributed evenly with the number of forms in each type reported by A+R facilities. 

η R Fraction of the A+R facility-level burden that is associated with Form R 

chemicals; used to apportion total facility-level burden from A+R facilities to 

total facility-level burden for Form R chemicals 

η A Fraction of the A+R facility-level burden that is associated with Form A 

chemicals; used to apportion total facility-level burden from A+R facilities to 

total facility-level burden for Form A chemicals 

 Number of Form R chemicals reported by A+R facilities AR rc +

 Number of Form A chemicals reported by A+R facilities AR ac +

 Eqn. 1 ARAR

AR

acrc

rc

R + +

+

+ η = 

 Eqn. 2 ARAR

AR

acrc

ac

A + +

+

+ η =

Note that =+ 1 η η RA . Combining Eqn. 1 and Eqn. 2: 

 Eqn. 3 =+ + = =1 + +

+ +

+ +

+

+ +

+

+

+

+ + ARAR

ARAR

ARAR

AR

ARAR

AR

acrc

acrc

acrc

ac

acrc

rc ηη RA

Figure B-3: Fraction of Forms Reported By R+A Facilities 

that are Form Rs And Form As 
Appendix B 

 4/28/11 

B-21 

 

Table B-8: Apportionment of Facility-level Unit Burden from R+A Facilities 

Facility Type Form Type Facility-Level Burden 

A Only Form A Bf AONLY BfATOT

A+R BfOVERALL

Form A 

Bf + AR

Bf + ARA η ⋅

Form R Bf + ARR η ⋅ BfRTOT

R Only Form R BfRONLY

Apportioning all facility-level burden from R Only facilities to Form R chemicals, all facilitylevel burden from A Only facilities to Form A chemicals, and splitting facility-level burden from 

R+A facilities between Form R chemicals and Form A chemicals involves the following: 

 Eqn. 4 BfRTOT η + ARR +⋅= BfBf RONLY

 Eqn. 5 Bf ATOT η + ARA +⋅= BfBf AONLY

The total facility-level burden for all TRI filers can be apportioned amongst facility types using 

the fraction of TRI reporters in each facility type (Figure B-4). This method assumes the fraction 

of total facility-level burden incurred by each facility type is equal to the fraction of facilities in 

each type. 

 Number of facilities reporting to TRI OVERALL f

 Number of R Only facilities RONLY f

 Number of A Only facilities AONLY f

 Number of R+A facilities ARf +

 Fraction of TRI reporters (facilities) reporting only Form Rs, RONLY x

 Fraction of TRI reporters (facilities) reporting only Form As AONLY x

 Fraction of TRI reporters (facilities) reporting Form Rs and As AR x +

 Eqn. 6 OVERALL

RONLY

OVERALL

RONLY

Bf

Bf

f

f

RONLY x ==

 Eqn. 7 OVERALL

AONLY

OVERALL

AONLY

Bf

Bf

f

f

AONLY x ==

 Eqn. 8 OVERALL

AR

OVERALL

AR

Bf

Bf

f

f

AR x + +

+ ==

Combining Eqn. 4, Eqn. 6, and Eqn. 8: 

 Eqn. 9 RTOT = RONLY BfxBf OVERALL +η +ARR Bfx OVERALL

Combining Eqn. 5, Eqn. 7, and Eqn. 8: 

 Eqn. 10 ATOT = AONLY BfxBf OVERALL +η +ARA Bfx OVERALL
Appendix B 

 4/28/11 

B-22 

 

Figure B-4: The Fraction of Total Facility-Level Burden 

Incurred by Each Facility Type 

The total facility-level burden for all TRI filers divided by the total number of TRI filers equals 

the facility-level burden per facility for all TRI filers. 

 Facility-level burden per facility overall, for all TRI filers BffOVERALL

 Eqn. 11 f OVERALL

Bf Bff OVERALL

OVERALL =

Combining Eqn. 9 and Eqn. 11: 

 Eqn. 12 RTOT RONLY OVERALL OVERALL ARR OVERALL OVERALL = ⋅ fBffxBf + ⋅ fBffx η +

Combining Eqn. 10 and Eqn. 11: 

 Eqn. 13 ATOT AONLY OVERALL OVERALL ARA OVERALL OVERALL = ⋅ fBffxBf + ⋅ fBffx η +

Total facility-level burden can be converted to facility-level burden per chemical by dividing by 

number of chemicals: 

 Eqn. 14 RTOT

RTOT

rc

Bf Bprc =

 Eqn. 15 ATOT

ATOT

ac

Bf Bpac =

Combining Eqn. 12 and Eqn. 14: 

 Eqn. 16 RTOT

RONLY OVERALL OVERALL ARR OVERALL OVERALL

rc

Bffx f Bffx f Bprc +⋅ ⋅ + = η

Simplifying Eqn. 16: 

 Eqn. 17 rc OVERALL

f f Bprc Bff RTOT

RONLY ARR = ⋅ +η +
Appendix B 

 4/28/11 

B-23 

 

In Eqn. 17, RONLY ARR ff +η + represents the equivalent number of facilities associated with Form 

R reporting. Equivalent Form R Chemicals per Facility equals the number of Form R chemicals 

reported divided by this number of facilities. 

Eqn. 18 RONLY ARR

RTOT

ff

rc Rcpfe + +

= η

Combining Eqn. 17 and Eqn. 18: 

Eqn. 19 e

OVERALL

Rcpf

Bff Bprc =

Combining Eqn. 13 and Eqn. 15: 

 Eqn. 20 ATOT

AONLY OVERALL OVERALL ARA OVERALL OVERALL

ac

Bffx f Bffx f Bpac +⋅ ⋅ + = η

Simplifying Eqn. 20: 

 Eqn. 21 ac OVERALL

f f Bpac Bff ATOT

AONLY + +ARA = η

In Eqn. 21, AONLY ARA ff +η + represents the equivalent number of facilities associated with Form 

A reporting. Equivalent Form A Chemicals per Facility equals the number of Form A chemicals 

reported divided by this number of facilities. 

Eqn. 22 AONLY ARA

ATOT

f f

ac Acpfe + +

= η

Combining Eqn. 23 and Eqn. 24: 

Eqn. 23 e

OVERALL

Acpf

Bff Bpac =

Calculation of Bprc , , Bpac , and Under Current Operations Rcpfe Acpfe

Bprc and can be calculated using the distribution of forms and facilities among facility 

types under current operations as projected in the 2008 ICR renewal. This distribution is 

presented in Table B-9. 

Bpac
Appendix B 

 4/28/11 

B-24 

 

Table B-9: Form and Facility Distributions Under Current Operations - No Burden 

Reduction 

Reporter 

Type 

Unique 

Facilities 

Count of Chemicals Average Number of 

Chemicals 

R A Total R A Total 

A Only 2,307 0 4,831 4,831 N/A 2.09 2.09

R Only 18,748 67,772 0 67,772 3.61 N/A 3.61

Both R and A 2,406 10,764 5,945 16,709 4.47 2.47 6.94

Total/Overall 23,461 78,536 10,776 89,312 3.73 2.30 3.81

Note: Raw form counts were used to match the 2008 ICR. Chemicals are not rolled up at 

the facility-chemical level. 

Source: TRI 2005 Public Data Release, RY 2005 

Under current TRI operations, 

• Nominal Facility-level burden=1.25 for non-PBT, subsequent year (compliance 

determination only) 

• Equivalent Form R Chemicals per Facility = 3.87 

• Equivalent Form A Chemicals per Facility = 3.41 

• Facility-level burden per Form R chemical = 0.32 

• Facility-level burden per Form A chemical = 0.37 (Table B-10 and Table B-11) 

Table B-10: Variables, Formulas, 

and Values Used to Calculate 

Facility-level Burden per Form R 

Chemical Under Current Operations 

Variable/Formula Value 

RTOT rc 78,536 

AR rc + 10,764 

AR ac + 5,945 

RONLY f 18,748 

ARf + 2,406 

BffOVERALL 1.25 

ARAR

AR

acrc

rc

R + +

+

+ η = 0.64 

RONLY ARR

RTOT

f f

rc Rcpfe + +

= η 3.87 

e

OVERALL

Rcpf

Bff Bprc = 0.32 

Table B-11: Variables, Formulas, 

and Values Used to Calculate 

Facility-level Burden per Form A 

Chemical Under Current Operations 

Variable/Formula Value 

acATOT 10,776 

AR rc + 10,764 

AR ac + 5,945 

AONLY f 2,307 

ARf + 2,406 

BffOVERALL 1.25 

ARAR

AR

acrc

ac

A ++

+ η = + 0.36 

AONLY ARA

ATOT

f f

ac Acpfe + +

= η 3.41 

e

OVERALL

Acpf

Bff Bpac = 0.37 
Appendix B 

 4/28/11 

B-25 

 

Calculation of Bprc , , Bpac , and Under Alternate Operations Rpcfe Apcfe

Bprc and were also calculated under an alternative scenario, using the distribution of Form 

R/ Form A within and across facilities during phase II burden reduction conditions. This 

alternative distribution is presented in Table B-12. 

Bpac

Table B-12: Form and Facility Distributions Under Alternate Conditions 

Reporter 

Type 

Unique 

Facilities 

Count of Chemicals Average Number of 

Chemicals 

R A Total R A Total 

A Only 4,020 0 8,096 8,096 N/A 2.01 2.01

R Only 13,226 35,196 0 35,196 2.66 N/A 2.66

Both R and 

A 6,215 31,555 14,465 46,020 5.08 2.33 7.40

Total/Overa

ll 23,461 66,751 22,561 89,312 3.80 2.21 3.81

Note: Raw form counts were used to match the 2008 ICR. Chemicals were not rolled up 

at the facility-chemical level. 

Source: TRI 2005 Public Data Release, RY 2005 

Under alternate conditions, 

• Nominal Facility-level burden=1.25 for non-PBT, subsequent year (compliance 

determination only) 

• Equivalent Form R Chemicals per Facility = 3.82 

• Equivalent Form A Chemicals per Facility = 3.78 

• Facility-level burden per Form R chemical = 0.33 

• Facility-level burden per Form A chemical = 0.33 (Table B-13 and Table B-14) 
Appendix B 

 4/28/11 

B-26 

 

Table B-13: Variables, Formulas, 

and Values Used to Calculate 

Facility-level Burden per Form R 

Chemical Under Alternate 

Conditions 

Variable/Formula Value 

Table B-14: Variables, Formulas, and 

Values Used to Calculate Facility-level 

Burden per Form A Chemical Under 

Alternate Conditions 

Variable/Formula Value 

acATOT 22,561

AR rc + 31,555

AR ac + 14,465

AONLY f 4,020

ARf + 6,215

BffOVERALL 1.25

ARAR

AR

acrc

ac

A ++

+ η = + 0.31

AONLY ARA

ATOT

f f

ac Acpfe + +

= η 3.78

e

OVERALL

Acpf

Bff Bpac = 0.33

RTOT rc 66,751 

AR rc + 31,555 

AR ac + 14,465 

RONLY f 13,226 

ARf + 6,215 

BffOVERALL 1.25 

ARAR

AR

acrc

rc

R + +

+

+ η = 0.69 

RONLY ARR

RTOT

f f

rc Rcpfe + +

= η 3.82 

e

OVERALL

Rcpf

Bff Bprc = 0.33 
Appendix C

 4/28/11 

 C-1 

Form Element Estimation 

This appendix presents the Form Element Estimation method of the Ratio-Based Burden 

Methodology (RBBM), including the models of Standardized Form Element Burdens. The 

method provides a standardized set of form element burdens for use when estimating changes to 

the Form R, as applied to the Nominal Form R unit burden.

1

 

This method is different from the other methods of RBBM in the way it implements the 

methodology priorities of simplicity, internal consistency, and estimate baseline continuity. 

Unlike the A/R, FTF and WAWR, this method’s models are closely tied to the methodology’s 

base number, Nominal Form R unit burden. If estimates obtained by this method are not 

considered in context of the unit burden used for reference, they may induce artificial baseline 

shifts, or at a minimum, produce internal inconsistencies, as burden estimates due to form 

changes do not adequately reflect their proportionate contribution to the total form unit burden. 

The means by which this method maintains internal consistency with Nominal Form R unit 

burden is by ensuring that the form elements of the Form R sum to the value (or close to the 

value of) the Nominal Form R unit burden. Therefore, in the event that the Nominal Form R unit 

burden undergoes a wholesale update or large change its value, the entire Form Element 

Estimation method must be revised so that Standardized Form Element Burdens proportionately 

add up to the value of the new Nominal Form R unit burden. 

For simplicity, this method standardizes the Abt Associates Engineering Studies estimates to 

develop Standardized Form Element Burdens. Standardization is achieved by organizing similar 

form elements into standard categories, and then using average burdens. For internal consistency 

between Standardized Form Element Burdens and the Nominal Form R unit burden, the elements 

are scaled so that the sum of all element estimates is equal to the Nominal Form R unit burden of 

35.7. Like the Nominal Form R unit burden, each form element estimate is fully loaded, 

incorporating facility-level burden. This approach is consistent with Decision Rule #5 on page 10 

in the main report.2 With respect to transitional and ongoing baseline continuity, the method 

ensures that the changes in unit burden are estimated in a manner that induces changes to the 

baseline commensurate with intended changes in the form. 

Form Element Estimation Method 

Method Development 

The method provides a way to quickly estimate an incremental burden associated with a form 

change. The equation below represents the method for estimating the total burden after 

accounting for the new data elements. 

Nominal Form R unit burdennew = Nominal Form R unit burdenold + Form change burden 

 

1

 Changes that affect Form R may or may not affect Form A. In this methodology, when changes to Form R affect 

Form A, they are theoretically captured when the Form R unit burden is multiplied by the A/R model. The A/R

model is not updated in conjunction with form changes, as it is sufficiently robust. 

2

 This scaling differs from scaling used in Abt Associates Engineering Studies (see references in Appendix G). In 

the Engineering Studies, when scaling from “realistic” to “scaled” estimates, elements were not scaled up 

proportionately. Some elements were considered “un-scalable.” This decision altered the relative proportions of each 

element, compromising internal consistency and considered inappropriate for RBBM. 
Appendix C

 4/28/11 

 C-2 

 

The form change burden could be a positive or negative number, depending on the nature of the 

form elements that are added to, or removed from, Form R. In order to implement this feature, 

EPA first developed a classification system of estimates related to the current form and then 

scaled the standardized elements so they sum to the Nominal Form R unit burden. Key analytical 

decisions included 1) defining the categories of the classification system that best represent the 

form elements, and 2) specifying the scaling system that works best for this method’s objectives 

as well as overall methodology objectives. The development steps are described below. Due to 

the very long nature of the tables, they are all presented at the end of this Appendix with the 

exception of Table C-5, which is brief and therefore included in the body of the Appendix. 

Identifying Standardized Categories 

As mentioned above, EPA developed a classification system of estimates related to the existing 

Form R and then grouped data elements into standardized burden categories. This section 

describes how the classification system was organized. Table C-1 provides the list of estimates 

from the TRI RY 2002 Form R from the Abt Associates Engineering Studies (see Appendix G).3

From this list, EPA defined categories and computed means and variance for each category. 

This method groups elements into corresponding categories to which new data elements may 

belong. Data elements were grouped into categories using the following criteria: 

1. The information collected by the data element: release value, facility location 

information, chemical identification information; and 

2. The type of work required to fill out the data element: locating and reviewing 

monitoring data, conducting a short information look-up, or typing a simple code. 

Initially, data elements were grouped into categories with other elements that required the 

collection of similar information. However, in some cases these initial categories had high 

variability in estimated engineering burden. EPA reduced this variability by refining the 

categories by type of work required. Data elements collecting estimates of source reduction and 

recycling activity in the current year, for example, were initially grouped together yet varied 

considerably in burden. This group was then split into two groups: one for quantities derived 

from relevant Section 5 and 6 data elements and the other for source reduction and recycling 

estimates with no relevant Section 5 and 6 data elements. The final list of data elements in their 

respective categories is included in Table C-2. 

The estimates are called raw estimates for the purpose of this study, as they did not contain 

incidence weights, which were based on response frequencies by data element. EPA discussed 

the merits and disadvantages of using the Abt Associates Engineering Studies fully engineered 

numbers, as were used in A/R, FTF and WAWR. However, for the needs of this method, they 

were not considered the most appropriate estimates. Given the setting in which EPA estimates 

form changes, often the incidence rate for a new element is unknown, providing no basis for an 

average or general assumption. Also, given the objective of Standardized Form Element 

Burdens, raw data element estimates provided consistent information for data elements that are 

3

 Although the information drew from a non-representative sample of reporters, the study’s design insured a high 

level of internal consistency due to its internal validity. See Appendix B for a complete discussion of the strengths 

and weaknesses of Abt Associates Engineering Studies as they apply to RBBM. 
Appendix C

 4/28/11 

 C-3 

 

theoretically the same without respect to reporter behavior. Similarly, knowing in advance that 

the method will require scaled estimates used to update the Nominal Form R unit burden, then it 

is desirable to have similar data elements possess the same standardized value. As a result of 

these considerations, EPA decided to use the raw estimates without incidence weighting for the 

pre-scaling basis of the method. This decision provides internal consistency from data elements 

to Form and across Form R and Form A. 

Scaling Options 

EPA considered whether or not it was necessary to scale the standardized categories to the 

Nominal Form R unit burden to ensure consistency between the Form Element Estimation 

Method and the Nominal Form R unit burden. The following four options were considered: 

• Option 1 – No scaling, use raw estimates (no incidence weighting) 

• Option 2 – No scaling, use incidence weighted raw estimates 

• Option 3 – Scale raw estimates (no incidence weighting) to Nominal Form R burden 

(35.7 hours). 

• Option 44

 – Scale raw estimates (no incidence weighting) to Calculation and Form 

Completion portion of Nominal Form R burden (20.4 hours) 

EPA then ranked the first three options based on internal consistency, parsimony, intuitive 

calculations, temporal consistency, ICR renewal implications and EA implications (see Table C4). With the highest rank, Option 3 was selected as the best approach. The main reasons for this 

decision are as follows: 

1. Scaling the raw estimate category so that the Form R totals 35.7 hours provides 

consistency because 35.7 hours is the value of the Nominal Form R unit burden. As 

with the Nominal Form R unit burden, the Standardized Form Element Burdens 

reflect “fully loaded” estimates of all activities associated with Form R completion 

(facility-level and per chemical form-level). 

2. At face value, this scaling produces relatively intuitive calculations given 

expectations that that the sum of category means should equal the total burden per 

Form R. 

Tables C-2 and C-3 present a general profile for each category of the Standardized Form 

Element Burdens, including the number of data elements corresponding to each category, the 

mean, and the standard deviation for each category with burden estimates raw and scaled to 35.7 

hours, respectively. 

Findings 

The Form Element Estimation method is designed to provide a structured and reproducible 

method for estimating burden associated with Form changes. When new form elements are 

added to Form R, EPA staff will be able to use Table C-3 or Figure A-2 standardized burdens to 

determine what change in burden (in hours) is associated with the form changes. 

Additionally, with experience, EPA has discovered that form changes do not always manifest 

themselves within the confines of this method’s framework for “add or subtract a form element.” 

4

 Note that Option 4 was considered at a later date and therefore, was not ranked. 
Appendix C

 4/28/11 

 C-4 

In fact, changes are often so minuscule that EPA estimates them to have a negligible impact on 

form-related burden. Table C-5 provides a list of changes of this nature. 

Table C-5: Form Changes for Which Additional Burden is not Estimated 

Form Change Circumstance of Inestimable Burden 

Code or Check Box (could include: 

indication of activity or reason, yes/no, 

NA, etc.) 

Where burden associated with data 

gathering and recording is negligible and 

frequency of reporting the data element is 

low. Or if response is already implied in 

existing data element (e.g. addition of NA 

box) 

Clarification of existing required data fields 

including reorganization 

Where clarification on reporting form is 

made but no new information is required 

Addition of optional open-ended question No burden by convention 

Method Summary 

Computation 

To illustrate how a revised Nominal Form R unit burden is calculated when new data elements 

are added to Form R, assume that EPA is adding a new data element to capture an additional 

EPA identification number such as the Facility Registry System (FRS) ID. If the analyst is 

familiar with the specific existing data element or group of existing data elements to which the 

new data element is similar, he/she can refer to the relevant categorical burden in the 

Standardized Form Element Burdens listed in Table C-3 and in the Program Staff Tool. 

Alternately, the analyst can look up a similar element’s standardized burden, as depicted in 

Figure A-2. Table C-3 shows the time estimate for Facility Identification Information Codes 

.0023 hours. The sample calculation of the new Nominal Form R unit burden is as follows: 

Eqn. C-1: Form R Unit Burden when New Form Elements are Added 

Nominal Form R unit burdennew = Nominal Form R unit burdenold + Form change burden 

Nominal Form R unit burdennew = 35.7 hours + .0023 hours =35.7023 hours 

Assumptions 

When a new form element is added to Form R and the incremental burden associated with the 

form element is selected from one of the categories, the following three assumptions are made: 

1) The corresponding category is representative of the new data element. For this 

assumption to hold true, reporter activity representing the new data element should be 

similar to the activities comprising that general category. 

2) The incidence weight for the new data element need not be considered in this method. 

3) The Nominal Form R unit burden—as the calculated sum of form element burdens—

remains close to the value used to scale the system of form elements (35.7 hours) because 

burden associated with form changes are small relative to the overall form burden. 
Appendix C

 4/28/11 

 C-5 

Maintenance and Update Recommendations 

This method does not require periodic updates. The decision on whether an update is necessary 

should be made according to the following recommendation: 

• For ICR renewals and EAs accompanying major rulemakings: review the form 

element categories to ensure proper form element classification. Compare the scaling 

basis of 35.7 to the current value assigned to Nominal Form R unit burden. 

• For minor EAs and other minor analyses: no update is required. 

In the event that the Nominal Form R unit burden undergoes a wholesale update or large change 

in its value, the entire Form Element Estimation method must be revised to assure that 

Standardized Form Element Burdens proportionately add up to the value of the new Nominal 

Form R unit burden. 

Table C-1: List of Categories and Corresponding Form Elements 

Category Form Part Sub Section Data Element 

Certification PART I. Facility Identification 

Information 3: Certification 

Name and official title 

Signature 

Date signed 

Chemical 

Identification 

Information 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

1.1: CAS Number Section 1.1: CAS number 

1.2: Toxic Chemical or Chemical 

Category Name 

Section 1.2: Toxic chemical 

or chemical category name 

1.3: Generic Chemical Name Section 1.3: Generic chemical 

name 

2.1: Generic Chemical Name 

Provided by Supplier 

Section 2.1: Generic chemical 

name provided by supplier 

Code or 

Checkbox for 

Readily 

Available Info 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

5.1: Fugitive or non-point air 

emissions B. Basis of estimate 

5.2: Stack or point air emissions B. Basis of estimate 

5.4.1: Underground injection 

onsite to Class I wells B. Basis of estimate 

5.4.2: Underground injection 

onsite to Class II-V wells B. Basis of estimate 

5.5.1A: RCRA Subtitle C landfills B. Basis of estimate 

5.5.1B: Other landfills B. Basis of estimate 

5.5.2: Land treatment/application 

farming B. Basis of estimate 

5.5.3A: RCRA Subtitle C surface 

impoundments B. Basis of estimate 
Appendix C

 4/28/11 

 C-6 

5.5.3B: Other surface 

impoundments B. Basis of estimate 

5.5.4: Other disposal B. Basis of estimate 

6.1.A: Total quantity transferred to 

POTWs and basis of estimate 6.1.A.2: Basis of estimate 

7A.1e: Based on operating data? 7A.1e: Based on operating 

data? 

5.3: Discharges to receiving 

streams or water bodies B. Basis of estimate 

6.2: Transfers to other off-site 

locations B: Basis of estimate 

6.2: Transfers to other off-site 

locations 

C: Type of waste treatment/ 

disposal/recycling/energy 

recovery 

8.10: Did your facility engage in 

any source reduction activities? Methods to identify activity 

Description of 

M/P/OU at 

Facility 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

3.1: Manufacture the toxic 

chemical 

Section 3.1: Manufacture the 

toxic chemical 

3.2: Process the toxic chemical Section 3.2: Process the toxic 

chemical 

3.3: Otherwise use the toxic 

chemical 

Section 3.3: Otherwise use 

the toxic chemical 

Description of 

Treatment or 

Pollution 

Prevention 

Activity 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

7B: On-site energy recovery 

processes Energy recovery methods 

7C: On-site recycling processes Recycling Methods 

7A: On-site waste treatment 

methods and efficiency 

7A.1b: Waste treatment 

method(s) sequence 

8.10: Did your facility engage in 

any source reduction activities? Source reduction activities 

Description of 

Waste Stream at 

Facility 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

7A: On-site waste treatment 

methods and efficiency 

7A.1a: General waste stream 

(enter code) 

Facility 

Identification 

Information - 

Codes 

PART 1. Facility Identification 

Information 

4.5 Section 4.5 NAICS Code(s) (6 

digits) 

4.6 

Section 4.6: Dunn and 

Bradstreet Number(s) (9 

digits) 

5.2: Parent company's Dun & 

Bradstreet number 

Section 5.2: Parent 

company's Dun & Bradstreet 

number 

4.8: EPA identification number 

(RCRA I.D. No.) 

Section 4.8: EPA 

identification number (RCRA 

I.D. No.) 

4.9: Facility NPDES permit 

number(s) 

Section 4.9: Facility NPDES 

permit number(s) 

4.10: Underground injection well 

code (UIC) I.D. number(s) 

Section 4.10: Underground 

injection well code (UIC) I.D. 

number(s) 

4.1 TRI facility ID number 
Appendix C

 4/28/11 

 C-7 

Facility 

Identification 

Information - 

Geographic 

PART 1. Facility Identification 

Information 4.6: Latitude 

Degrees 

Minutes 

Seconds 

Degrees 

Minutes 

Seconds 

Facility 

Identification 

Information - 

Name and 

Contact 

PART 1. Facility Identification 

Information 

4.1 

Facility or establishment name 

Street 

City/county/state/zip code 

Facility or establishment name 

or mailing address (if different 

from street address) 

Mailing address 

City/state/zip code 

Country (non-US) 

4.3 

Technical contact name 

Telephone number 

Email address 

4.4 

Public contact name 

Telephone number 

5.1: Name of parent company Section 5.1: Name of parent 

company 

Form Type PART 1. Facility Identification 

Information 

1: Reporting Year Section 1: Reporting Year 

2.1: Are you claiming the toxic 

chemical identified on page 2 

trade secret? 

Section 2.1: Are you claiming 

the toxic chemical identified 

on page 2 trade secret? 

2.2: Is this copy sanitized or 

unsanitized? 

Section 2.2: Is this copy 

sanitized or unsanitized? 

4.2: This report contains 

information for (check a or b; 

check c or d if applicable) 

Section 4.2: This report 

contains information for 

(check a or b; check c or d if 

applicable) 
Appendix C

 4/28/11 

 C-8 

Future Year 

Projection 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

8.1a: Total on-site disposal to 

Class I Underground Injection 

Wells, RCRA Subtitle C landfills, 

and other landfills 

Column C: Following year 

Column D: Second following 

year 

8.1b: Total other on-site disposal 

or other releases 

Column C: Following year 

Column D: Second following 

year 

8.1c: Total off-site disposal to 

Class I Underground Injection 

Wells, RCRA Subtitle C landfills, 

and other landfills 

Column C: Following year 

Column D: Second following 

year 

8.1d: Total other off-site disposal 

or other releases 

Column C: Following year 

Column D: Second following 

year 

8.2: Quantity used for energy 

recovery on-site 

Column C: Following year 

Column D: Second following 

year 

8.3: Quantity used for energy 

recovery off-site 

Column C: Following year 

Column D: Second following 

year 

8.4: Quantity recycled on-site 

Column C: Following year 

Column D: Second following 

year 

8.5 Quantity recycled offsite 

Column C: Following year 

Column D: Second following 

year 

8.7: Quantity treated off-site 

Column C: Following year 

Column D: Second following 

year 

8.6: Quantity treated on-site 

Column C: Following year 

Column D: Second following 

year 

Measure of 

Activity at 

Facility 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

8.9: Production ratio or activity 

index 

Section 8.9: Production ratio 

or activity index 

4.1 Section 4.1: Determine 

maximum quantity on-site 
Appendix C

 4/28/11 

 C-9 

Measure of 

Waste/Discharge 

Stream 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

7A.1c: Range of influent 

concentration 

7A.1c: Range of influent 

concentration 

5.3: Discharges to receiving 

streams or water bodies C. % from stormwater 

7A: On-site waste treatment 

methods and efficiency 

7A.1d: Waste treatment 

efficiency estimate 

NA 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

5.1: Fugitive or non-point air 

emissions NA 

5.2: Stack or point air emissions NA 

5.4.1: Underground injection 

onsite to Class I wells NA 

5.4.2: Underground injection 

onsite to Class II-V wells NA 

5.5.1A: RCRA Subtitle C landfills NA 

5.5.1B: Other landfills NA 

5.5.2: Land treatment/application 

farming NA 

5.5.3A: RCRA Subtitle C surface 

impoundments NA 

5.5.3B: Other surface 

impoundments NA 

5.5.4: Other disposal NA 

7A: On-site waste treatment 

methods and efficiency NA 

7B: On-site energy recovery 

processes 

NA 

7C: On-site recycling processes NA 

5.3: Discharges to receiving 

streams or water bodies NA 

Optional Data 

Element 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

8.11: If you wish to submit 

additional optional information on 

source reduction, recycling, or 

pollution control activities, check 

“Yes.” 

Section 8.11: If you wish to 

submit additional optional 

information on source 

reduction, recycling, or 

pollution control activities, 

check “Yes.” 

Quantity 

Derived from 

Relevant 

Section 5 and 6 

Data Elements 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

8.1a: Total on-site disposal to 

Class I Underground Injection 

Wells, RCRA Subtitle C landfills, 

and other landfills 

Column B: Current reporting 

year 

8.1b: Total other on-site disposal 

or other releases 

Column B: Current reporting 

year 

8.1c: Total off-site disposal to 

Class I Underground Injection 

Wells, RCRA Subtitle C landfills, 

and other landfills 

Column B: Current reporting 

year 

8.1d: Total other off-site disposal 

or other releases 

Column B: Current reporting 

year 
Appendix C

 4/28/11 

 C-10 

8.3: Quantity used for energy 

recovery off-site 

Column B: Current reporting 

year 

8.5 Quantity recycled offsite Column B: Current reporting 

year 

8.7: Quantity treated off-site Column B: Current reporting 

year 

8.8: Quantity released to the 

environment as a result of 

remedial actions, catastrophic 

events, or one-time events not 

associated with production 

processes 

Section 8.8: Quantity 

released to the environment 

as a result of remedial actions, 

catastrophic events, or onetime events not associated 

with production processes 

Receiving 

Facility/Site 

Identification 

Information 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

5.3: Discharges to receiving 

streams or water bodies 

5.3.1: Stream or water body 

name 

6.1.B: POTW 

POTW name 

POTW address 

City 

State 

County 

Zip 

6.2: Transfers to other off-site 

locations 

Off-site EPA identification 

number (RCRA ID No.) 

Off-site location name 

Off-site address 

City 

State 

County 

Zip 

Country (non-US) 

Is location under control of 

reporting facility or parent 

company? 

Release 

Quantity 

Estimated Using 

Emissions 

Factors 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

5.2: Stack or point air emissions A. Total release 

Release 

Quantity 

PART II. Toxic Chemical 

Release Inventory Reporting 5.5.1A: RCRA Subtitle C landfills A. Total release 
Appendix C

 4/28/11 

 C-11 

Estimated Using 

Facility Records 

Form 5.5.1B: Other landfills A. Total release 

5.5.3A: RCRA Subtitle C surface 

impoundments A. Total release 

5.5.3B: Other surface 

impoundments A. Total release 

5.5.4: Other disposal A. Total release 

6.2: Transfers to other off-site 

locations A: Total transfers 

5.4.1: Underground injection 

onsite to Class I wells A. Total release 

5.4.2: Underground injection 

onsite to Class II-V wells A. Total release 

5.5.2: Land treatment/application 

farming A. Total release 

6.1.A: Total quantity transferred to 

POTWs and basis of estimate 6.1.A.1: Total transfers 

5.3: Discharges to receiving 

streams or water bodies A. Total release 

Release 

Quantity 

Estimated Using 

Physical and 

Chemical 

Properties of 

Chemical and 

Process 

Operating 

Conditions 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

5.1: Fugitive or non-point air 

emissions A. Total release 

SRR with No 

Relevant 

Section 5 and 6 

Data Elements 

Current Year 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

8.2: Quantity used for energy 

recovery on-site 

Column B: Current reporting 

year 

8.4: Quantity recycled on-site Column B: Current reporting 

year 

8.6: Quantity treated on-site Column B: Current reporting 

year 

Value Reported 

in Prior Year 

PART II. Toxic Chemical 

Release Inventory Reporting 

Form 

8.1a: Total on-site disposal to 

Class I Underground Injection 

Wells, RCRA Subtitle C landfills, 

and other landfills 

Column A: Prior year 

8.1b: Total other on-site disposal 

or other releases Column A: Prior year 

8.1c: Total off-site disposal to 

Class I Underground Injection 

Wells, RCRA Subtitle C landfills, 

and other landfills 

Column A: Prior year 

8.1d: Total other off-site disposal 

or other releases Column A: Prior year 
Appendix C

 4/28/11 

 C-12 

8.2: Quantity used for energy 

recovery on-site Column A: Prior year 

8.3: Quantity used for energy 

recovery off-site Column A: Prior year 

8.4: Quantity recycled on-site Column A: Prior year 

8.5 Quantity recycled offsite Column A: Prior year 

8.6: Quantity treated on-site Column A: Prior year 

8.7: Quantity treated off-site Column A: Prior year 
Appendix C

 4/28/11 

 C-13 

Table C-2: Standardized Form Element Burden Categories (Raw Estimate Means and 

Standard Deviations) 

Category Number of Data 

Elements 

Time 

(Hours) 

Mean St Dev 

Certification 3 NA NA 

Chemical Identification Information 4 0.0014 0.0000

Code or Checkbox for Readily Available Info 15 0.0057 0.0005

Description of M/P/OU at Facility 3 0.0014 0.0000

Description of Treatment or Pollution Prevention 

Activity 4 0.3889 0.2102

Description of Waste Stream at Facility 1 0.0972 NV 

Facility Identification Information - Codes 4 0.0014 0.0000

Facility Identification Information - Name and 

Contact 14 0.0014 0.0000

Form Type 4 0.0035 0.0014

Future Year Projection 20 0.0181 0.0000

Measure of Activity at Facility 2 0.5667 0.0668

Measure of Waste/Discharge Stream 2 0.2494 0.2997

NA 13 0.0028 0.0000

Optional Data Element 1 0.0000 NV 

Quantity Derived from Relevant Section 5 and 6 Data 

Elements 8 0.0875 0.0000

Receiving Facility/Site Identification Information 16 0.0046 0.0027

Release Quantity Estimated Using Emissions 

Factors 1 1.1278 NV 

Release Quantity Estimated Using Facility Records 6 1.0861 0.2645

Release Quantity Estimated Using Monitored Values 5 1.1287 0.1644

Release Quantity Estimated Using Physical and 

Chemical Properties of Chemical and Process 

Operating Conditions 

1 1.9583 NV 

SRR with No Relevant Section 5 and 6 Data 

Elements Current Year 3 0.5139 0.0000

Value Reported in Prior Year 10 0.0056 0.0000

NV indicates a value could not be calculated because there is only one data element in the category or 

because total raw time is zero.
Appendix C

 4/28/11 

 C-14 

Table C-3: Standardized Form Element Burden Categories (Means and Standard 

Deviations Based on Raw Burden Estimates Scaled to 35.7 Hours) 

Category Number of Data 

Elements 

Time 

(Hours) 

Mean St Dev 

Certification 3 NA NA 

Chemical Identification Information 4 0.0023 0.0000

Code or Checkbox for Readily Available Info 15 0.0096 0.0008

Description of M/P/OU at Facility 3 0.0023 0.0000

Description of Treatment or Pollution Prevention 

Activity 4 0.6481 0.3502

Description of Waste Stream at Facility 1 0.1620 NV 

Facility Identification Information - Codes 4 0.0023 0.0000

Facility Identification Information - Name and 

Contact 14 0.0023 0.0000

Form Type 4 0.0058 0.0023

Future Year Projection 20 0.0301 0.0000

Measure of Activity at Facility 2 0.9444 0.1113

Measure of Waste/Discharge Stream 2 0.4157 0.4995

NA 13 0.0046 0.0000

Optional Data Element 1 0.0000 NV 

Quantity Derived from Relevant Section 5 and 6 Data 

Elements 8 0.1458 0.0000

Receiving Facility/Site Identification Information 16 0.0077 0.0044

Release Quantity Estimated Using Emissions 

Factors 1 1.8795 NV 

Release Quantity Estimated Using Facility Records 6 1.8100 0.4408

Release Quantity Estimated Using Monitored Values 5 1.8810 0.2740

Release Quantity Estimated Using Physical and 

Chemical Properties of Chemical and Process 

Operating Conditions 

1 3.2636 NV 

SRR with No Relevant Section 5 and 6 Data 

Elements Current Year 3 0.8564 0.0000

Value Reported in Prior Year 10 0.0093 0.0000

NV indicates a value could not be calculated because there is only one data element in the category or 

because total raw time is zero.
Appendix C

 4/28/11 

 C-15 

Table C-4: Example Evaluation of Options for Scaling, by Category 

Option 1: 

Raw Estimates/No 

Incidence Weighting 

(Sum of data elements= 

21.43 hours) 

Option 2: 

Incidence Weighting 

Included 

(Sum of data 

elements= 7.06 hours) 

Option 3: 

Scaled to Equal 

Nominal Form R for 

Raw or Incidence 

Weighted 

(Sum = 35.7 hours) 

Option 4: 

Scaled to Equal 

Nominal Form R 

Proportion of 

Calculations and 

Form Completion 

(Sum = 20.4 hours)

Rank 

(1-3) Comments Rank (1-3) Comments Rank (1-3) Comments Rank (1-3) Comments 

Internal 

Consistency 2 

More consistent 

with old method 

(compared to 

incidence 

weighted 

estimates.) 

3 1 

More 

consistent with 

the new 

method moving 

forward. 

NA 

Equally 

consistent as 

Option3, but 

more 

consistent 

with total 

form unit 

burden 

Parsimony 1 

Easiest to 

generate using 

existing 

engineering 

burden 

estimates. 

3 

Requires 

information on 

how often data 

elements are 

filled out in a 

given year. 

Will have year 

to year 

variation. 

2 Simply scaling 

from base. NA 

Simply 

scaling from 

base. 

Intuitive 

Calculations 2 

Based on real 

world experience 

with form. 

1 

Reflects the 

reality that not 

all facilities fill 

out all data 

elements. 

3 Modeled 

estimate. NA 

requires 

explanation, 

given 

expectation 

that elements 

should add to 

total Form 

burden 

Temporal 

Consistency 2 3 

Requires 

information on 

how often data 

elements are 

filled out in a 

given year. 

Will have year 

to year 

variation. 

1 

More 

consistent with 

the new 

method moving 

forward. 

NA 

More 

consistent 

with the new 

method 

moving 

forward. 

ICR Renewal 

Implications 3 

Would be adding raw 

engineering estimate 

to back calculated 

nominal. Different 

bases. 

2 1 

Consistent with 

reporting burden 

for entire form 

(nominal form 

burden.) 

NA 

Consistent with 

reporting burden 

for appropriate 

portion of entire 

form (nominal 

form burden.) 

EA 

Implications 1 

Need to show nonincidence weighted 

burden in EA. 

3 2 

Can scale both raw 

and incidence 

weighted. 

NA 

Can scale both 

raw and 

incidence 

weighted. 

Overall Rank 1.83 2.5 1.66 NA 
Appendix C

 4/28/11 

 C-16 
Appendix D 

 4/28/11 

D-1

First-Time Filer Estimation 

This appendix presents the First-Time Filer Estimation method of the Ratio-Based Burden 

Methodology (RBBM). As explained in Appendix A, first-time filer burden accounts for the 

elevated level of effort that reporters incur during a start-up year. The existing method estimates 

first-time filer burden in two instances. For ICR renewals, first-time filer burden is estimated as 

part of total Program burden to account for new entrants to the reporting community in any given 

reporting year. In RBBM terms, this estimate has a small effect on the Steady State Total Burden 

Calculation. Second, first-time filer burden is used in economic analyses (EAs) supporting 

rulemakings to evaluate the start-up effect of a policy or regulatory change to the TRI reporting 

requirements, for example, when a new sector is added to the reporting community. As noted in 

Appendix A, however, in the Ratio-Based Burden Methodology (RBBM), first-time filer burden 

now applies to calculating EA start-up burden only, as it was shown to be negligible in the 

overall Steady State Total Burden Calculation. First-Time Filer Estimation, as presented in 

Appendix A, is envisioned as working in conjunction with estimates of steady state burden as 

follows: 

First-Time Filer Burden = FTFf * Relevant Steady State Total Burden 

Model Development for ICR Renewal Burden 

As stated in Appendix B, neglecting the impact of first-time filing in the steady state estimate is 

justified mathematically because treating the relevant 3% of TRI chemical reports as steady state 

filers instead of first-time filers decreases the Steady State Total Burden estimate by .04%, based 

on 2008 ICR Renewal conditions. Therefore, with respect to ICR renewal burden estimates and 

the Steady State Burden Calculation, EPA has concluded that incorporating first-time filer 

burden has a negligible influence (see Appendix B). 

Model Development for Economic Analysis Burden 

In the context of EA work, EPA must estimate the incremental steady state and first-time impacts 

that a policy or regulatory change would have on TRI reporting. Depending on the proposed 

change, it may have significant first-time impacts when new reporters enter the TRI reporting 

universe or when existing reporters complying with a new aspect of TRI reporting are getting up 

to speed with the new policies or requirements. Therefore, when estimating the incremental 

impacts associated with a policy change or rulemaking, first-time filer burden must be estimated. 

It should be noted that first-time filer burden is a transient effect that will decrease to steady state 

burden levels in the second year. 

First-Time Filer Model 

Under the existing methodology, first-time burden is estimated using the same method as that 

used for steady state burden, i.e., using the two complex matrices and a separate count for firsttime filers. As described in Appendix A, the Steady State Total Burden Calculation simplifies 

these calculations using ratio models and unit burdens from Abt Associates Engineering Studies. 

Using the same development process, EPA provides internal consistency between estimates for 

first-time and steady state reporting, as defined by the First-Time Filer factor, FTFf): 
Appendix D 

 4/28/11 

D-2

Ratio of First-Time Burden to 

Steady State Burden 

 [=] _First-Time Hours__ 

 Steady State Hours 

Computed using the factor matrices for Form R presented in Appendix A: 1

FTFf = ( [first year factors from F′′i,j] / ( [subsequent year factors from F′′ ∑∑ i,j ]﴿ ==

3

1

4

1 ji

∑∑ ==

3

1

4

1 ji

The FTFf is developed using the ratio of the burden associated with first-time Form R reporting 

activities to the burden associated with steady state Form R reporting activities. See Appendix 

A’s Eqn A-9 and Table A-4 for the model’s specific calculation. 

 Findings 

The recommended value for the First-Time Filer Factor, FTFf , is 2.1 hr/hr, based on Form R 

factors. EPA estimated the FTFf separately for Form R and Form A using several model 

assumptions and distribution conditions similar to the design for A/R tests described in Appendix 

B. Following Decision Rule #2 on page 10 of the main report, the Form R basis is used to apply 

for all instances in which first-time filing is estimated, given that the additional complexity of 

incorporating the Form A basis is unmerited. Table D-1 supports this decision as the difference 

in estimates based on Form R (FTFR) versus those based on Form A (FTFA) do not differ 

substantially. 

 

1

 Where i denotes the row and j denotes the column from the Matrix F′′ in Appendix A. 
Appendix D 

 4/28/11 

D-3

Table D-1: Estimation of First-Time Filer Factor for Form R and Form A

Test Run 

Description 

(1) 

REFERENCE 

no 

simplifications 

(2) 

Same as (1), but 

without Firsttime filer 

adjustment 

(3)

Same as (1), 

but without 

incidence rate 

adjustments 

(4)

Same as (1), 

but without 

distribution 

specificity* 

(5) 

RECOMMENDED 

-realistic 

estimates with 

incidence rate 

adjustments** 

(6)

 Robustness 

Test - 

alternate 

distribution*** 

 

Model Form R unit burden (hrs/Form 

R) 

12.66 12.52 27.24 12.67 12.52 12.53 

Model Form A unit burden (hrs/single 

-chemical Form A) 

7.76 7.67 13.16 7.95 7.71 7.67 

 

FTFR 2.05 2.05 1.67 2.08 2.05 2.06

FTFR % difference from Reference 0.00 -18.66 1.31 0.00 0.49 

FTFA 2.66 2.51 2.14 3.28 2.66* 2.53 

A/R 0.613 0.612 0.483 0.628 0.615 0.612 

A/R % difference from Reference -0.12 -21.22 2.41 0.39 0.50 

* Does not account for potential double counting of facility level burden among facilities reporting both Form Rs and Form As. 

**Current A, R, A+R distributions, no first-time filer adjustments. Based on the same conditions as for column 5 in Tables B-3 and B-4. See Eqn 

A-12 for FTF derivation. 

***Phase 2 Burden Reduction Rule. 

Note: FTFA is only 23% higher than FTFR. According to Decision Rule # 2 in the main report Form R basis is used when complexity of Form A 

basis is unmerited. 

Method Summary 

Computation 

For first-time incremental burden: As noted above, first-time filer burden is only addressed in 

the context of calculating EA start-up burden. Specifically, in any EA supporting a regulatory or 

policy change, there will be costs incurred only in the first year of the change, in addition to the 

sustained steady state costs associated with the change. Take, for example, the recent TRI 

rulemaking adding 16 chemicals to the list of reportable chemicals. To estimate first-time filer 

burden, the analyst will combine information on the unit burden associated with the filing of 

forms for the new chemicals, the number of new chemicals and the FTFf . Note that in this 

rulemaking, reporters are not expected to file Form As for any of the new chemicals. The analyst 

would estimate first-time filer burden for the additional 186 Form Rs that are expected to be filed 

as follows: 

Eqn D-2: Total first-time filer burden associated with the rule adding 16 chemicals to TRI = 

= FTFf *(Form R Relevant Steady State Burden for New Chemicals + Form A Relevant 

Steady State Burden for New Chemicals) 
Appendix D 

 4/28/11 

D-4

= FTFf * (Nominal Form R unit burden* # New Form R chemicals + [(A/R) * Nominal 

Form R unit burden] * # New Form A chemicals) 

= 2.1*(35.7*186 + [.615*35.7]* 0) 

= 13,944 hours 

This first-time filer burden estimate will be reported in the EA along with steady state burden as 

an estimate of the total burden associated with TRI reporting created by the proposed regulatory 

or policy change. 

Assumptions 

Use of the FTF model for estimating first-time filer burden relies on the following assumptions: 

• First-time and steady state burden as currently identified in the Abt Associates 

Engineering Studies estimates for Form R is a reasonable reflection of the amount of time 

it takes to complete reporting activities for the first-time relative to the steady state for 

TRI reporting. 

• The relationship between first-time and steady state burden does not vary between the 

steady state and policy/regulatory change scenarios or across policy/regulatory change 

scenarios. 

• Relationships between reporting activities in the Abt Associates Engineering Studies that 

are drawn from a subpopulation are reasonably reflective of the true relationships in the 

total reporting population, as measured by the best professional judgment of Abt 

Associates’ engineers. 

Maintenance and Update Recommendations 

The FTF model/method requires no maintenance. However, EPA notes that the FTF formulation 

is dependent on the conversion factors used to rescale facility-level unit burdens to (per 

chemical) form level. As shown in Appendix B, even in the face of dramatic shifts in 

distribution, Equivalent Form R/A Chemicals per Facility are reasonably robust, within about 

10%. However, in the event that the program adds industry sector(s), the (per chemical) 

form/facility distribution could shift due to the addition of large chemical counts of substantially 

different distributions of (per chemical) form type and/or number of chemicals per facility. 

As a practical matter, given the requirements for ICR renewal reporting, periodic recalculations 

of the Equivalent Form R/A Chemicals per Facility will be regularly available and can be 

checked to be sure that this basis for the FTFf model (and others—A/R and WAWR) is still valid. 

EPA recommends this routine check. 
Appendix E 

 4/28/11 

E-1 

Cost Conversion 

This appendix presents the Cost Conversion method of Ratio-Based Burden Methodology 

(RBBM), including the weighted average wage rate (WAWR). WAWR provides and alternative to 

separately computing wages for the three labor categories, Managerial, Technical and Clerical, 

with each ICR renewal or rulemaking and instead specifies one up-front Cost Conversion 

incorporating all three labor categories. As presented in Appendix A, this method is envisioned 

as working primarily in conjunction with estimates of steady state burden as follows: 

Eqn. E-1: Steady State Total Cost = (Steady State Total Burden)*WAWR

It should be noted that this method is the only method in the Ratio-Based Burden Methodology 

(RBBM) that calibrates with updates to actual economic conditions, given the availability of 

quarterly current wage data from the Bureau of Labor Statistics (BLS). It should also be noted 

that this method uses information from the Abt Associates Engineering Studies to set the relative 

proportions of each labor category reflecting current technology conditions. As with other 

similarly developed models (A/R, FTE), updates may be required in the event that large changes 

in the distributions of form counts/types across facilities affect the conversion factors (Equivalent 

Form R/A Chemicals per Facility). Unlike these other models, which have no impact on 

transitional baseline continuity, the WAWR under RBBM induces a slight one-time decrease 

(5%) to the baseline for the total cost estimate, while not affecting the relevant burden hour 

estimate. 

Weighted Average Wage Rate (WAWR) Models 

The WAWR ratio model determines costs associated with burden hour estimates, as defined by: 

WAWR (Weighted Average Wage Rate): 

Average loaded cost for a mix of managerial, 

technical and clerical labor per hour of TRI 

reporter burden 

[=] Current $/Hour 

This model uses one wage rate that reflects an average estimate for all labor categories as 

opposed to three different wage rates. The weighted hourly wage rate is developed by 

combining the relative contribution of each labor category to total burden with current hourly 

wages. 

 Procedure 

As an example, to compute the steady state costs for Form R :1

 

1

 Form R burden only is used for initial illustrations, with verification of assumptions that the same bases apply to 

Form A and steady state total costs. See key analytical decisions in this Appendix. For additional details on Form 

R/A burden, and Steady State Total Burden calculations, see Appendix B. 
Appendix E 

 4/28/11 

E-2 

Eqn. E-2: Form R Cost = Form R Burden Hours* WAWR

The WAWR for year YR is calculated as follows: 

Eqn. E-3: WAWRYR = (pm * $/hr m,YR ) + (pt * $/hr t,YR ) + (pc * $/hr c,YR)

Where 

WAWRYR = WAWR in current dollars for year YR 

pm, pt, pc = proportions of the reporting burden for each labor 

category, managerial, technical and clerical. 

$/hr m,YR, $/hr t,YR, $/hrc,YR = The wage rates for managerial, technical and clerical 

labor for year YR, in current $/hour. 

For Form R, as in Form A, and the Total Cost calculation, the proportions are constant, providing 

fixed weights to the weighted average calculation: 

Eqn. E-4: WAWRYR = (.03 * $/hr m,YR ) + (.89 * $/hr t,YR ) + (.08 * $/hr c,YR)

In this method, the burden is calculated in total and then multiplied by WAWR. Note that each 

labor category wage rate must be obtained for the quarter and year of interest. 

 Method Development 

The key analytical decisions for developing this method include: 

1. Specifying the set of fixed weights that represent the proportion of the reporting burden 

for each labor category: two options were considered: 1) weights developed using the 

unit burden estimates from the existing methodology, or 1) weights developed using the 

Abt Associates Engineering Studies. The fixed weights for Managerial, Technical and 

Clerical labor categories are 0.03, 0.89 and 0.08, based on the Abt Associates 

Engineering Studies, and 0.25, 0.68 and 0.07, based on the existing methodology, 

respectively. Both sets of weights were derived using Form R burden as a basis (see 

Decision Rule #2 on page 10 of the main report). 

2. Determining if one WAWR can be used to convert From R, Form A, and total burdens to 

costs. This determination involved verifying the assumption that a Form A WAWR is not 

substantially different from a Form R WAWR in order to be able to use a standardized 

form WAWR for calculating required for Form R. It also involved verifying that the same 

WAWR could be applied to total burden to obtain total cost. 

3. Recommending an update frequency. 

Analyses to support these decisions are presented in order. The first set of analytical decisions 

specifies the basis for the proposed fixed weights for proportions of each labor category. Should 

EPA use existing methodology’s proportions or those implied by the Abt Associates engineering 

estimates? Although RBBM has fully justified using the Abt Associates Engineering Study unit 
Appendix E 

 4/28/11 

E-3 

burdens in ratio models (see Appendix B), in this particular method, the practice will induce a 

slight (5%) one-time baseline shift of $2.65/hour, from $52.27/hour (using the existing 

methodology) to $49.62/hour using RBBM. For many of the same reasons that the revised 

methodology uses the Abt Associates Engineering Studies unit burdens for A/R and FTF, they 

are preferred for WAWR as well. Advantages include internal consistency and the fact that these 

estimates were made in 2004, reflecting technology advances since program inception. EPA 

concludes that the slight one-time baseline shift for cost is acceptable, given the relative merits of 

using the same building blocks used throughout RBBM. 

Consequently, the WAWRs used for RBBM have a modified formulation from that of the existing 

method because the RBBM fixed weights are derived using Abt Engineering Studies.. Recall that 

the OMB-approved implied weights are 0.25, 0.68, and 0.07 and that RBBM weights are 0.03, 

0.89, and 0.08 (see Appendix A, Table A-4 for a breakdown by activity). The resultant RBBM 

weights as they apply to Form R reporting are presented in Table E-1 below. 

Table E-1 

Subsequent Year Reporting Burden – Per Form R Chemical 

Activity Management Technical Clerical 

Rule Familiarization 0 0 0

Compliance Determination 0.069* 0.275* 0*

Calculations and Form Completion 0.320 6.890 0.0

Recordkeeping 0.000 4.000 1

Total Form level burden 0.389 11.165 1

Weights 0.03 0.89 0.08

*Facility-level factors converted to form (per chemical)-level factors via Equivalent Form R Chemicals 

per Facility (3.87) See Eqn A-10 and Tables A-3 and A-4. 

Source: Table A-3, Abt Associates Engineering Studies (see Appendix B and references in Appendix G)

The second set of analytical decisions verifies that the derived Form R WAWR weights may be 

used for Form R burden, Form A burden, and total burden. 

An analysis similar to the one presented in Table E-1 was conducted based on Form A, as 

derived from Form R, for reporting activities resulting in management, technical, and clerical 

weights of 0.03, 0.84 and 0.13, compared to Form R proportions of 0.03, 0.89 and 0.08, 

respectively. EPA concluded that Form A weights are similar enough to Form R weights to allow 

use of the Form R weights when computing Form A costs. 

To assess WAWR’s applicability to total burden, EPA then analyzed the effect of using the Form 

R WAWR to calculate total TRI reporting costs. EPA found that using the Form R based WAWR

yields total cost estimates that are less than 0.2% higher than a total cost calculation that uses 

separate Form R and Form A WAWRs. Additionally, differences incurred by incorporating nonform burden are negligible.2

 

2

 This finding is based on an analysis of the per form comparable proportion of burden attributable to management, 

technical, and clerical under the following two scenarios: Total reporting burden (including non-form activities such 

as supplier notification and petitions) and form-related reporting burden only. In scenario one: total reporting 

burden, the weights are as follows: 24 management, .66 technical, and .09 clerical. In scenario two: form-related 
Appendix E 

 4/28/11 

E-4 

Given the findings from these two analyses, EPA concludes that the Form R WAWR is equally 

applicable to Form R, Form A, and Steady State Total Cost estimates, using the weights for 

Form R for each labor rate category. To compute WAWR, the cost of each activity by labor 

category is developed by combining the burden in hours with hourly wage rates for the 

appropriate labor category. An example calculation is presented in Table E-2. 

Table E-2 

Derivation of Weighted Average Wage Rate ($/hour), June 2010 

Managerial Technical Clerical 

Total Loaded Rate $62.29 $51.37 $25.24 

Weights 0.03 (3%) 0.89 (89%) 0.08 (8%) 

Average Wage (weighted) $49.62* 

Source: http://www.bls.gov/news.release/ecec.t11.htm

Note: For comparison, the Form A weighted average wage is $48.30. 

* Individual numbers may not result in the total due to rounding.

The weighted average loaded hourly wage rate across the three labor categories was $49.62 in 

June 2010. This weighted average rate is applied to the total number of hours needed to complete 

Form R and Form A (Nominal Form R and Form A unit burden where Form A unit burden is 

derived from Form R unit burden using the A/R model) to estimate the unit cost per form. The 

cost per form is then applied to the total TRI total burden to estimate the total TRI reporting cost. 

The third analytical decision involves recommending the frequency of updating the method. 

Since the information on wage rates is published quarterly by the Bureau of Labor Statistics 

(BLS), updates to the WAWR should be made accordingly. 

Findings 

The RBBM-consistent basis using Abt Associates engineering estimates are preferred for 

weighting labor categories within WAWR, for the same reason they are the basis for A/R and 

FTF. They provide benefits of internal consistency and reflect more current conditions with 

technology advances. 

Method Summary 

 

Computation 

To update the WAWR for an ICR renewal or a major rulemaking, the following steps are 

involved: 

 reporting burden only, the weights are as follows: 25 management, .68 technical, and .07 clerical. Both calculations 

use 2008 ICR renewal estimates. 
Appendix E 

 4/28/11 

E-5 

 

1. Obtain employer cost current wage rates for total and salary compensation3

 from BLS 

for three labor categories: Managerial, Technical and Clerical labor.4 Adjust each 

upward to account for non-wage compensation: 17% overhead, 43.4% benefits. 

2. Compute the weighted average wage rate, using the fixed weights reflecting burden 

hours (0.03, 0.89 and 0.08)5 to calculate the current WAWR2010 (e.g., $49.62/hour for 

June 2010). 

The following equation presents the estimation of total burden when updating the WAWR for an 

ICR renewal or a major rulemaking using current wages from BLS (see Eqn B-2 for reference 

regarding Steady State Total Burden). 

Eqn. E-5: 

Steady State Total Cost = Steady State Total Burden * WAWR2010

Steady State Total Cost = (Nominal Form R Unit Burden*# Form R Chemicals + 

[Nominal Form R Unit Burden*(A/R)*# Form A Chemicals] + Non-Form 

Burden)*WAWR2010

Total Cost 

= (35.7*# Form R Chemicals + [35.7*.615*# Form A Chemicals] + 825,517)* 

WAWR2010

Where WAWR2010 is calculated using Eqn. E-4 and the latest 2010 wage rates from BLS: 

WAWR2010 = (.03 * $/hr m,2010) + (.89 * $/hr t,2010) + (.08 * $/hr c,2010) 

Assumption

Wage rate proportions in WAWR of .03 for managerial labor, .89 for technical labor, and .08 for 

clerical labor are reasonable estimates of actual conditions, on average, for the overall reporting 

community. 

Maintenance and Update Recommendations

Update WAWR in every burden estimate for which new information from BLS is available 

(quarterly updates). The fixed weights of WAWR require no maintenance. However, EPA notes 

that the values of these weights are dependent on the conversion factors used to rescale facilitylevel unit burdens to (per chemical) form level. As shown in Appendix B, even in the face of 

dramatic shifts in distribution, Equivalent Form R/A Chemicals per Facility, within about 10%. 

However, in the event that the program adds industry sector(s), the (per chemical) form/facility 

3

 Note that benefits may be calculated as the difference between total and salary compensation on a quarterly basis 

(e.g., WAWR benefits are 43.4% of compensation for June 2010). 

4

 Corresponding BLS titles: Managerial = Management, business, and financial; Technical = Professional and 

related; Clerical = Office and administrative support. 

5

 See calculation components and results in Table E-1. 
Appendix E 

 4/28/11 

E-6 

distribution could shift due to the addition of large chemical counts of substantially different 

distributions of (per chemical) form type and/or number of chemicals per facility. 

As a practical matter, given the requirements for ICR renewal reporting, periodic recalculations 

of the Equivalent Form R/A Chemicals per Facility will be regularly available and can be 

checked to be sure that this basis for the fixed weights of the WAWR model (and others—A/R

and FTFf) are still valid. EPA recommends this routine check.
Appendix F 

Program Staff Tool 

 F-1 4/28/11 
Appendix F 

F-2 

DIRECTIONS:

The pink fields are user input cells. Your final estimates will be displayed in the dark green cells on this page. To see calculatio

interface, including models and accounting parameters, refer to the “Reference Information” tab. If you need to change or add finstructions and data under the “Form Element Estimates” tab. 

DEFINITIONS:Steady State Burden (SS) - estimate of ongoing Program burden, including permanent impacts from rulemakings, but absent fiFirst Time Filer Burden (FTF) - estimate to account for start-up burden incurred during the first year of a policy changeWeighted Average Wage Rate (WAWR) - consolidated wage rate that incorporates relevant proportions of managerial, technicaForm R and Form A unit burdens - comprehensive unit burdens that incorporate all aspects of per chemical form-related burdecompliance determination, calculations and form completion, and recordkeeping and submissionSection 1: UNIT BURDEN1. If you are adding form elements for this analysis, estimate the burden of these new elements using the procedure in the "Forenter the sum of these estimates into the "Additional Burden per Form" user input cell. Note that for added form elements that odo not discount based on incidence rate. 2. If you do not have additional form elements for this analysis, make sure the number in the "Additional Burden per Form" cell Note: The newly calculated Form R Unit Burden will be used to calculate both total Form R and total Form A burden.Section 2: CHEMICAL COUNTSComplete this section according to whether you are estimating the full model (ICR) or incremental model (EA).In the case of an ICR, enter the number of chemicals reported by Form A and Form R, or in the case of an EA, enter the changreported by Form A and Form R in the "Incremental Change" input cells in Section 2.Section 3: STEADY STATE BURDEN ESTIMATESThis section displays the final estimates in the dark green cells. For an ICR use the "Final Totals" and for an EA use the "Final Section 4: FIRST YEAR ADDITIONAL BURDEN DUE TO FIRST-TIME FILERS (FTF)For EAs that initiate policy change that in turn causes a startup burden for first-time filers (FTF), enter the number of additional 

in this section to determine this burden due to FTFs.
Appendix F 

F-3 

Key Models (see reference tab) User inputs Calculated numbers Final estimates Intermediate Calculations Helpful hints 

USER INPUTS AND MODELS E

Section 1: UNIT BURDEN Starting Point 

Additional 

Burden per 

Form New F

Form R unit burden (hours per form) 35.7 + 0 = Form A unit burden (hours per single-chemical form) 22.0 + 0 = Form A unit burden = (A/R) * Form R unit burden 

Section 2: CHEMICAL COUNTS 

Number of Chemicals Starting Point 

Incremental 

Change 

Number chemicals reported on Form R 81,382 + 0 = Number of chemicals reported on Form A 9,284 + 0 = Note: Form A is units of chemicals rather than responses 
Appendix F 

F-4 

Section 3: STEADY STATE BURDEN ESTIMATES Hours of Form Burden Starting Point 

Incremental 

Change 

Total Form R Burden (hrs) 2,905,337 + 0 = Total Form A Burden (hrs) 203,835 + 0 = Total Non-form Burden (hrs) 825,517 

Note: Incremental change numbesection 3 include new forms and achanges in form unit burden. 

Totals and Cost Conversion 

Final 

Incremental 

Change 

WAWR (current $/hr) 49.62 Total Burden (hrs) 0 Total Cost (dollars) 

(Total Burden in hrs) * (June 2010 $ WAWR) = $0 

Section 4: FIRST YEAR ADDITIONAL BURDEN DUE TO FIRST TIME FILERS (FTF) 

Incremental 

Change 

# of chemicals reported on Form R for FTFs 0# of chemicals reported on Form A for FTFs 0FTF Form R Burden (hrs) 

Form R Unit Burden * FTF # Form R Chemicals * FTF Factor = 0

FTF Form A Burden (hrs) 

Form A Unit Burden * FTF # Form A Chemicals * FTF Factor = 0

FTF Total Burden (hrs) 0FTF Total Cost (dollars) (FTF Burden in hrs) * (June 2010 $ WAWR)= $0
Appendix F 

F-5 

Reference Equations and Model Values Equations used in Estimator: Total Burden = Form R Burden + Form A Burden + NonForm Burden  Where:  Form R Burden = (# Form R chemicals) * (Nominal Form R Unit Burden)  Form A Burden = (# Form A chemicals) * (A/R) * (Nominal Form R Unit Burden)  NonForm Burden = (Petitions) + (Supplier Notification) + (Non-Reporters’ Burden) Total Cost = Total Burden * (WAWR)  Where:  WAWR is the weighted average wage rate in current dollars/hr First Time Filer Burden = (FTFf * relevant steady state burden) 

 Where:  FTFf = the first time filer factor 

 relevant steady state burden = [(# new Form R chemicals * Nominal Form R unit burden)] + [(# new Form A chemicals * 

burden * (A/R))] 
Appendix F 

F-6 

Table 1. Values used in Estimator 

Update Frequency Last Updated Name Value Units Desc

MODEL PARAMETERS 

According to Tolerances May 2010 A/R Model = 0.615 hrs/hrs 

A ratio of burdens for sto Form R. 

None by Schedule May 2010 Petitions = 925 hrs 

Non-form burden, ass185 hours per petition

None by Schedule May 2010 

Supplier Notification = 89,616 hrs 

Non-form burden, can basis is 24 hours per r2008 ICR. 

None by Schedule May 2010 

Non-Reporter Compliance Determination = 734,976 hrs 

Non-Form burden, asscompliance determinaover 10 employees as 

According to Tolerances May 2010 

First Time Filer Factor (FTFf) = 2.1 hrs/hrs 

A ratio of the first-time state burden. 

WAWR 

Quarterly June 2010 

Weighted Average Wage Rate (WAWR) = $49.62 $/hr 

Dollars per hour ratio tmanagerial, technical, Note: to update the Wguidance below. 

REFERENCE INFORMATION

As Form Changes are Implemented in Rulemakings and ICRs (note: verify Rulemaking estimates at ICR) Feb 2011 

Nominal Form R Unit Burden = 35.7 hrs 

Current Base number the form elements appaction (ICR or Rulema

At Every ICR 

Feb 2011 

Form R Chemicals per Facility = 3.68 chems/facility Based on number of c

At Every ICR Feb 2011 

Form A Chemicals per Form = 2.31 chems/Form A 

Based on number of cis assumed to be numfacility. 

Guidance to Update the WAWR:The WAWR is a dollar per hour ratio that is based on the managerial, technical, and clerical labor rates from the EmployeCost for Employee Compensation Economic update published quarterly by the BLS.To update the WAWR with the latest data from BLS, enter the most recently published values for Total Compensation anWages and Salaries in the table titled Employer Cost for Employee Compensation under the appropriate date. The Benefits column will automatically calculate the Benefit amount for each labor type. The table titled WAWR will then generate the new WAWR and present it under the appropriate date.To use the new WAWR in the Estimator tab, update the reference formulas for $/hr and date in cells F30 and C30 to link the new WAWR and date. (For example, when updating to a September 2010 WAWR, cell F30 would be linked to F60 and cell C30 would be linked to F56.) 
Appendix F 

F-7 

Table 2. WAWR Calculation WAWR 

Date December 2009 March 2010 June 2010 September 2010 

Managerial $61.42 $62.32 $62.29 Technical $50.51 $51.17 $51.37 Clerical $24.99 $25.22 $25.24 WAWR $48.81 $49.44 $49.62 EMPLOYER COST FOR EMPLOYEE COMPENSATION

Date December 2009 March 2010 Ju

Compensation 

Component 

Total 

Compensation 

Wages 

and 

Salaries 

Benefits Total Compensation Wages and Salaries Benefits Total Compensation 

Managerial $54.91 $38.30 $16.61 $55.73 $38.75 $16.98 $55.69 Technical $45.04 $32.16 $12.88 $45.63 $32.59 $13.04 $45.81 Clerical $22.33 $15.65 $6.68 $22.55 $15.73 $6.82 $22.56 Note: Corresponding BLS titles: Managerial = Management, business, and financial; Technical = Professional and related; Clerical = O

support. Total Compensation and Wages and Salaries data is taken directly from ECEC, while Benefits data is derived from the ECEC 

Source: Employer Cost for Employee Compensation, Table 9. BLS. <http://www.bls.gov/news.release/ecec.t11.htm> 

September 2010 

Total 

Compensation 

Wages 

and 

Salaries 

Benefits 

OVERHEAD 

17% 

LABOR BURDEN WEIGHTS Managerial 0.03Technical 0.89Clerical 0.08
Appendix F 

F-8 

FORM R 

 EPA 

FORM R 

TRI Facility ID Number 

United States

Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986, also Known 

as Title III of the Superfund Amendments and Reauthorization Act

Environmental Protection Agency Toxic Chemical, Category or GWHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center 2. APPROPRIATE ST

P. O. Box 1513 (See instruction in App

Lanham, MD 20703-151 

This section only applies if you are revising or withdrawing a previously submitted form, otherwise leave bank. 

Revision (enter up to two codes(s)) Withdrawal (enter up to two code

IMPORTANT: See instructions to determine when “Not Applicable (NA)” boxes should be checked. 

PART 1. FACILITY IDENTIFICATION INFORMATION 

NOTE: For further details of this form image see Appendix A, Figure A-2. 
Appendix G 

 4/28/11 G-1 

Abt Associates Engineering Studies 

1) TRI Reporting Burden Estimates, Memo from Hilary Eustace, David Cooper, Susan Day, Abt 

Associates to Paul Borst, EPA, July 16, 2004 

2) Modified TRI Reporting Burden Estimates for Rule Familiarization, Compliance 

Determination, and Form Completion from Susan Day, Abt Associates to Laura Nielsen, EPA, 

December 2, 2010 

NOTICE 

Abt Associates Engineering Estimates in Ratio-Based Burden Methodology (RBBM)

As explained in Methodology History, the Abt Associates engineering estimates were proposed 

in 2004, but neither finalized nor formally adopted into TRI burden estimation practice. In this 

methodology revision and in the formulation of RBBM, EPA uses the estimates for a different 

purpose than originally intended. Instead of using Abt Associates engineering estimates as a 

basis for absolute values (i.e., the Nominal Form R unit burden), RBBM uses the estimates to 

construct ratio models of key relationships (e.g., A/R), thereby only relying on the relative values 

of the estimates and not absolute values. 

 
Appendix G 

 4/28/11 G-2 

 

M E M O R A N D U M

TO: Paul Borst, U.S. EPA 

 

FROM: Hilary Eustace, David Cooper, Susan Day 

DATE: July 16, 2004 

RE: TRI Reporting Burden Estimates 

 

1. INTRODUCTION

EPA currently relies on previously developed OMB approved TRI reporting burden estimates 

that reflect the total time required by facilities to complete activities such as rule familiarization, 

compliance determination, form completion, record keeping/mailing, and supplier notification. 

While form completion reporting burden estimates have been prepared for completion of the full 

Form R, the total time is not broken down by the individual data elements that make up the form. 

Data element specific burden estimates would allow for informed assessments and comparisons 

of proposed TRI burden reduction methods as well as any future proposed Form R 

modifications. In this memo, burden estimates are derived for every data element on the Form R 

based on the activities TRI reporters undertake to complete each data element as well as the time 

estimates for technical, managerial, and clerical staff at a typical facility to conduct these 

activities. During the last TRI ICR renewal, EPA referenced industry data suggesting that TRI 

reporting burden is lower than previously estimated. While the newly negotiated burden 

estimates were revised downward for non-PBT chemicals, they were not lowered by as much as 

EPA proposed. Furthermore, PBT chemical reporting burden was not lowered at all. The OMB 

approved reporting estimates are presented in Table 1. The data element specific burden 

estimates presented in this memo are estimated first to reflect the time it actually takes the typical 

facility to fill out each data element. This burden is referred to as the “realistic burden.” Second, 

the data element specific realistic burden estimates are scaled up so that summing them yields 

the OMB approved burden estimate of form completion. Several sets of burden estimates were 

prepared, including times for both electronic and paper form preparation for every category 

outlined below: 
Appendix G 

 4/28/11 G-3 

• Realistic Burden Estimates for Every Form R Data Element: Realistic burden 

estimates were prepared for every data element on the Form R based on best engineering 

judgment for both management and technical time. Under the realistic scenario, no 

clerical time is spent on form completion. Separate realistic burden estimates were 

prepared for non-PBT and PBT chemicals. 

• Realistic Burden Estimates for Total Form R Completion: The realistic data element 

burden estimates were weighted by the incidence rate, which is the total percentage of 

forms containing information other than “NA” for the data element, in order to reflect the 

fact that not all data elements will be completed on all forms. The incidence rate was 

calculated using the frozen RY 2002 TRI data. This analysis was conducted separately 

for non-PBT and PBT chemicals. 

• Scaled Burden Estimates for Every Form R Data Element for non-PBT Chemicals: 

The realistic burden estimates generated for every data element for non-PBT chemicals 

were scaled up to meet the current OMB-approved time estimate for calculations and 

form completion for a Form R for a non-PBT chemical. 

• Scaled Burden Estimates for Every Form R Data Element for PBT Chemicals: The 

realistic burden estimates generated for every data element for PBT chemicals were 

scaled up to meet the current OMB-approved time estimate for calculations and form 

completion for a Form R for a PBT chemical. Since the current OMB-approved time 

estimate for calculations and form completion for a PBT chemical assumes that all data 

elements are completed, these scaled data element time estimates were not multiplied by 

the incidence rate for PBT chemicals. 
Appendix G 

 4/28/11 G-4 

TABLE 1 

 OMB-APPROVED TIME ESTIMATES FOR FORM R 

CALCULATIONS/FORM COMPLETION

Activity Management Technical Clerical Total Hours

First year

Calculations and report completion - 

non-PBT chemicals 11.3 24.1 1.6 37.0 

Calculations and report completion - 

PBT chemicals 20.9 45.2 2.9 69.0 

Subsequent years

Calculations and report completion - 

non-PBT chemicals 7.7 16.4 1.1 25.2 

Calculations and report completion - 

PBT chemicals 14.3 30.8 2.0 47.1 

Source: Rice, Cody Memo: Terms of Clearance for TRI ICR Renewal. Jan 20, 2004. 

An OMB-approved estimate for first time non-PBT filers does not exist; however, the RIA for 

the original Section 313 rulemaking estimated the time required to complete a report in the first 

year to be 147% of the time required in subsequent years. This factor was applied to the OMB 

approved subsequent year non-PBT report completion times to calculate the first year non-PBT 

completion times. (U.S. EPA Regulatory Impact Analysis in Support of Final Rulemaking 

under Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 

(1988). 

Realistic estimates, based on best engineering judgment, are presented in Section 2; Section 3 

presents the realistic estimate scaled to the OMB approved Form R completion times. Within 

each section, PBT and non-PBT reporting burden is examined separately due to differences in 

methodology. The PBT and non-PBT chemical sub-sections are further divided into electronic 

and paper methodology and results sub-sections. 

2. REALISTIC REPORTING BURDEN ESTIMATES

2.1.A. Methodology for Electronic Submission

 

The basis for all of the burden estimates presented in this memo start with a realistic burden 

estimate for a typical facility to prepare a Form R in the first year and all subsequent reporting 

years. To generate this realistic burden estimate, the method described below was utilized. First, 

the steps required for completion of each data element (field) on the Form R were identified. 

Best engineering judgment was used to estimate the time to complete each step based on a 
Appendix G 

 4/28/11 G-5 

reasonable and likely scenario for conducting the needed steps a typical facility. Best 

engineering judgment was provided by a team of three staff with nearly 40 years of combined 

experience working with facilities on environmental issues. These staff have worked with 

hundreds of facilities on TRI reporting and other environmental requirements by conducting 

inspections and providing technical assistance to hundreds of facilities, serving as TRI trainers, 

conducting technical review on hundreds of TRI data withdrawal requests, conducting hundreds 

of TRI data quality calls, working for two of the Massachusetts Toxics Use Reduction Act 

agencies, and working as environmental staff at large manufacturing facilities.) Next, the total 

time to complete each data element was estimated by summing together the labor hours required 

to complete the set of steps necessary for each data element. 

Best and worst-case scenarios of activities were considered when estimating the time required to 

complete each step. The time estimates presented here reflect the most typical/likely scenario. 

For example, scenarios to identify average discharge water flow rate range from transcribing 

dozens of hand-written entries from manual meter observation to simply pulling this piece of 

data from a fully-automated system. The likely scenario selected is that the typical facility will 

have at least partial automation on data capture from their flow meter, but technical staff will 

likely have to pull multiple pieces of information, interpret this information, and perform a few 

calculations. Several Form R data elements will require the same or similar activities. To ensure 

consistency, times were standardized for these activities. These standard times are presented in 

Table 2 (refer to Excel spreadsheet). 

 

For Form R data elements requiring a quantitative estimate of release or other waste management 

quantities, the steps a facility would take to fill in the data elements were derived based on the 

most common basis of estimate code reported for that field in the RY 2002 TRI data. The basis 

of estimate code analysis is presented in Table 3 (refer to Excel spreadsheet). For example, 

monitoring data was the most common basis of estimate code for off-site transfers to POTWs; 

therefore, the steps required to make engineering calculations based on monitoring data were 

used as the basis for the time estimate for this data element. In actuality, each facility would use 

their best available data for completing each field. As a final check, estimated times for data 

elements were compared with one another based on expected relative degree of difficulty. 

The total realistic form completion burden was calculated by combining the time required to 

complete each data element with the percent of times individual data elements are typically 

completed. As mentioned above, this adjustment was made by weighting the data element 

specific burden by the incidence rate for that element. For example, if a stack air release 

quantity (either “0" or an actual quantity) was reported on 50% of all non-PBT Form Rs, the time 

estimated to complete Part II, Section 5.2 of the Form R was multiplied by 50%. For data 

elements that are required, it was assumed that 100% of forms had the data element filled out. 

The final reporting burden is a realistic estimate of the total form completion time based on 

engineering judgment. A separate analysis was done for non-PBT and PBT chemicals. 
Appendix G 

 4/28/11 G-6 

As mentioned above, these burden estimates are based on the TRI reporting experiences of a 

typical facility. It was, therefore, necessary to make the following assumptions about a typical 

facility: 

• The facility is reasonably modern and well-organized. 

• The facility has internet access with reasonable connection speed. 

• Through rule familiarization, the technical staff are aware that written EPA TRI guidance 

is available through the website. 

• Unless otherwise noted, the set of activities listed for a release estimate need only be 

conducted once. 

• Unless otherwise noted, there is no difference in completing a data element for non-PBT 

versus PBT chemicals. (Additional discussion on PBTs versus non-PBTs is provided 

below). 

• Technical staff retain copies of the previous year’s reports in a readily available format. 

Therefore, static information available from the previous year’s reports, such as RCRA 

I.D., is assumed to require only typing time in subsequent years. 

• For subsequent year reports, technical staff will be able to locate, review, and interpret 

information needed to prepare release and other waste management estimates more 

quickly since they have already gone through the process. 

• For subsequent year reports, it is assumed that there are no significant changes to facility 

operations or waste management practices. 

• Technical staff preparing the report will concurrently type this information into TRI-ME 

and will not require clerical assistance in entering information into TRI-ME. 

• On the paper form estimates of reporting burden, clerical time consists entirely of typing 

hard copy Form Rs; no other activities are undertaken. For example, technical staff 

conduct all of the needed research for preparing the form. 

Since more than 80% of Form Rs were filed electronically in RY 2002, it is assumed for the 

realistic burden estimate that technical staff prepare the electronic form; therefore, no clerical 

burden is estimated. Also, in the realistic burden estimate, management review time is based on 

the maximum perceived level of management involvement at reporting facilities and is lower 

than previous OMB approved management burden estimates. In the following sections, data 

elements are presented as they appear on the Form R. Reporting burden estimates are presented 

after each step for first year/subsequent years in minutes. If a step will take less time or does not 
Appendix G 

 4/28/11 G-7 

need to be repeated in subsequent years, this will be reflected in the allotted time (i.e., a lower 

time or “0" will be given for subsequent years). 

As mentioned above, the calculations/form completion burden for non-PBT chemicals was 

recently revised from 47.1 hours to 25.2 hours for non-PBT chemicals (Memo from Cody Rice 

to Amy Newman: Terms of Clearance for TRI ICR Renewal. Jan 20, 2004). Reporting burden 

associated with PBT chemicals was not revised due to trade association comments suggesting 

that because range reporting and the de minimis exemption cannot be used for PBT chemicals, 

form completion takes longer for a PBT chemical than a non-PBT chemical. While there may be 

overall differences in TRI reporting burden between PBT and non-PBT forms, this difference is 

largely due to compliance determination activities, not form completion. 

Specifically, the de minimis exemption is not allowed for PBT chemicals. Therefore, compliance 

determination may take longer for PBT chemicals, as additional mixtures may need to be 

assessed for threshold quantity. It does not appear, however, that the lack of the de minimis 

exemption will increase the burden associated with making release estimates due to a need to 

assess additional waste streams. An analysis of the RY 2002 TRI data indicated that the average 

number of reported “M” codes for off-site transfers was slightly lower for PBTs than for nonPBTs (2.55 versus 2.64, respectively). Assuming that different waste streams are indicated by 

different waste management methods, as indicated by the “M” code, it appears that there were 

slightly fewer differing waste streams for PBT chemicals than for non-PBT chemicals. 

Also, not being able to use range reporting does not actually increase the reporting burden for 

PBT filers. Range reporting is allowed for non-PBT chemicals in Part II, Sections 5 and 6 of the 

Form R (on-site releases and off-site transfers of wastes), but is not allowed in Part II, Section 8 

of the Form R. All release and other waste management quantities from Sections 5 and 6 are 

also recorded in Section 8 of the Form R, therefore, actual estimates (versus range estimates) for 

Sections 5 and 6 must be made to complete Section 8. As a result, no fewer calculations are 

necessary to complete a Form R for non-PBTs versus PBTs due to range reporting. In addition, 

range reporting is only allowed for releases less than 1,000 pounds, and calculations are needed 

to determine which range is applicable. 

As shown below, using best engineering judgment, there does not appear to be a significant 

difference between calculations/form completion activities and burden for PBT versus non-PBT 

chemicals. In fact, it is estimated that the calculations/form completion time for PBT chemicals 

is slightly lower, primarily due to the fact that more EPA-published quantitative guidance is 

available for PBT chemicals, such as emission factors. Analysis of RY 2002 TRI data shows the 

following: 

• The most commonly reported basis of estimate codes were nearly identical for PBTs 

versus non-PBTs. 
Appendix G 

 4/28/11 G-8 

• The percent of data elements filled out by RY 2002 filers was nearly the same for PBT 

and non-PBT forms, with the difference being the percent was slightly lower for PBTs. 

• For data elements where multiple occurrences were reported (e.g., off-site transfer 

locations, number of “M” codes for off-site transfers, number of reported on-site 

treatment waste streams), the incidence rates were nearly identical for PBT and non-PBT 

forms. 

The derivation of the data element specific burden estimates is presented below. Only one 

complete set of steps reflecting expected activities for both PBT and non-PBT chemicals is 

provided for each data element (with a few minor exceptions) as there are no significant 

differences in form completion activities. Minor differences expected between non-PBT and 

PBT chemicals are noted in the individual data element discussions where they occur. 

Data Element Specific Reporting Burden 

Form R, Part I. Facility Identification Information

Section 1: Reporting Year 

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

Technical staff will have knowledge of this information and will report it in Part I, Section 1 of 

the Form R. (0.25 min/0.25 min) 

Reporting Burden Associated with Part I, Section 1

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 0.25 0.25 

Total 0.33 0.33 

Section 2: Trade Secret Information 

2.1 Are you claiming the toxic chemical identified on page 2 trade secret? 

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

Technical staff will have knowledge of this information and will check yes or no in Part I, 

Section 2.1 of the Form R. (0.08 min/0.08 min) 
Appendix G 

 4/28/11 G-9 

Reporting Burden Associated with Part I, Section 2.1

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 0.08 0.08 

Total 0.16 0.16 

2.2 Is this copy sanitized or unsanitized?

Facilities must meet rigorous standards as outlined in 40 CFR 350 in order to claim trade secret 

status; therefore, it is assumed a typical facility will check “no” in Part I, Section 2.1 of the Form 

R, and subsequently Part I, Section 2.2 of the Form R will be left blank. 

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

Technical staff will have knowledge of this information and will check yes or no in Part I, 

Section 2.2 of the Form R. (0.08 min/0.08 min) 

Reporting Burden Associated with Part I, Section 2.2

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 0.08 0.08 

Total 0.16 0.16 

Section 3: Certification

In RY 2002, more than 80% of Form R reports were filed via diskette or CDX submission. 

Electronic signature occurs as part of the CDX submission process and with diskette submission 

a separate signed letter is sent. Burden for this effort is allocated under “Record 

keeping/Mailing” and therefore is not included in the “Calculations/Form Completion” burden 

estimate outlined in this report. Thus, no management, technical, nor clerical burden associated 

with this element of the Form R will be allocated for this analysis. 

Section 4.1: Facility Identification (Name, Address) 

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.67 min/0.67 min) 

Technical staff will have knowledge of this information and will report it in Part I, Section 4.1 of 

the Form R. (2.0 min/0 min) 
Appendix G 

 4/28/11 G-10

Reporting Burden Associated with Part I, Section 4.1

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.67 0.67 

Technical 2.00 0.00 

Total 2.67 0.67 

Section 4.2: Reporting by Part

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

4.2a or 4.2b

Technical staff will have knowledge of this information, and will check off if this Form R is for 

an entire facility or part of a facility in Part I, Section 4.2a or 4.2b, respectively, of the Form R. 

(0.08 min/0.08 min) 

Reporting Burden Associated with Part I, Section 4.2a or 4.2b 

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 0.08 0.08 

Total 0.16 0.16 

4.2c or 4.2d

This section is only filled out if the Form R is from a federal facility or a government-owned, 

contractor-operated (GOCO) entity conducting work on behalf of the federal government. Since 

fewer than 5% of Form Rs are filled out by these facilities, this section will typically be left 

blank. 

Technical staff will have knowledge of this information, and will check off if this Form R is for a 

federal facility or a GOCO in Part I, Section 4.2c or 4.2d, respectively, of the Form R. No time 

is included for this step because it is filled out less than 5% of the time. 

Section 4.3: Technical Contact Information (Name, Address, E-mail, Telephone) 

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.25 min/0.25 min) 
Appendix G 

 4/28/11 G-11

Technical staff will have knowledge of this information and will report it in Part I, Section 4.3 of 

the Form R. (0.75 min/ 0 min) 

Reporting Burden Associated with Part I, Section 4.3

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.25 0.25 

Technical 0.75 0.00 

Total 1.00 0.25 

Section 4.4: Public Contact Information (Name, Telephone)

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.17 min/0.17 min) 

Technical staff will have knowledge of this information and will report it in Part I, Section 4.4 of 

the Form R. (0.50 min/0 min) 

Reporting Burden Associated with Part I, Section 4.4

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.17 0.17 

Technical 0.50 0.00 

Total 0.67 0.17 

Section 4.5: SIC Code(s)

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

 

As an integral part of compliance determination, a facility will have determined which SIC codes 

apply to the facility. Technical staff simply record this information in Part I, Section 4.5 of the 

Form R. (0.25 min/0 min) 

Reporting Burden Associated with Part I, Section 4.5

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 0.25 0.00 

Total 0.33 0.08 
Appendix G 

 4/28/11 G-12

Section 4.6: Latitude/Longitude

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.50 min/0.50 min) 

Technical staff will go to the TRI facility siting tool available on the EPA Web site and type in 

their facility address. The tool will then report back the latitude and longitude. The technical 

staff will record this information in Part I, Section 4.6 of the Form R. (4.5 min/0 min) 

Reporting Burden Associated with Part I, Section 4.6

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.50 0.50 

Technical 4.50 0.00 

Total 5.00 0.50 

Section 4.7: Dun & Bradstreet Number

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min)

Technical staff will obtain this information from elsewhere in the company by making a phone 

call, checking files, or making an in-person information request. Once obtained, technical staff 

will record this information in Part I, Section 4.7 of the Form R. (10.0 min/0 min) 

Reporting Burden Associated with Part I, Section 4.7

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 10.00 0.00 

Total 10.08 0.08 

Section 4.8: EPA Identification Number (RCRA ID)

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

Unless hazardous waste manifests are stored with the technical staff preparing the report, they 

will need to obtain this information from elsewhere in the company by making a phone call, 

checking files, or making an in-person information request. For the purposes of this estimate, it 

is assumed that technical staff will need to obtain this information from elsewhere. Once 
Appendix G 

 4/28/11 G-13

obtained, technical staff will record this information in Part I, Section 4.8 of the Form R. (10.0 

min/0 min) 

Reporting Burden Associated with Part I, Section 4.8

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 10.00 0.00 

Total 10.08 0.08 

Section 4.9: Facility NPDES Permit Number

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min)

Unless NPDES permit documents are stored with the technical staff preparing the report, they 

will need to obtain this information from elsewhere in the company by making a phone call, 

checking files, or making an in-person information request. For the purposes of this estimate, it 

is assumed that technical staff will need to obtain this information from elsewhere. Once 

obtained, technical staff will record this information in Part I, Section 4.9 of the Form R. (10.0 

min/0 min) 

Reporting Burden Associated with Part I, Section 4.9

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 10.00 0.00 

Total 10.08 0.08 

Section 4.10: Underground Injection Well Code (UIC I.D.) 

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min)

Unless UIC permit documents are stored with the technical staff preparing the report, they will 

need to obtain this information from elsewhere in the company by making a phone call, checking 

files, or making an in-person information request. For the purposes of this estimate, it is 

assumed that technical staff will need to obtain this information from elsewhere. Once obtained, 

technical staff will record this information in Part I, Section 4.10 of the Form R. (10.0 min/0 

min). 
Appendix G 

 4/28/11 G-14

Reporting Burden Associated with Part I, Section 4.10

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 10.00 0.00 

Total 10.08 0.08 

Section 5.1: Name of Parent Company

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

Technical staff will need to obtain this information from elsewhere in the company by making a 

phone call, checking files, or making an in-person information request. Once obtained, technical 

staff will record this information in Part I, Section 5.1 of the Form R. (10.0 min/0 min) 

Reporting Burden Associated with Part I, Section 5.1

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 10.00 0.00 

Total 10.08 0.08 

Section 5.2: Parent Company’s Dun & Bradstreet Number

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

Technical staff will need to obtain this information from elsewhere in the company by making a 

phone call, checking files, or making an in-person information request. Once obtained, technical 

staff will record this information in Part I, Section 5.2 of the Form R. (10.0 min/0 min) 

Reporting Burden Associated with Part I, Section 5.2

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 10.00 0.00 

Total 10.08 0.08 
Appendix G

 4/28/11 

G-15

Form R, Part II. Chemical-Specific Information

Section 1.1: CAS Number

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

Technical staff will have the CAS Number readily available from activities conducted during 

compliance determination, such as review of Material Safety Data Sheets (MSDSs) or review of 

the EPCRA Section 313 chemical list, and report it in Part II, Section 1.1 of the Form R. (0.25 

min/0 min) 

Reporting Burden Associated with Part II, Section 1.1

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 0.25 0.00 

Total 0.33 0.08 

Section 1.2: Toxic Chemical or Chemical Category Name

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

Technical staff will have the chemical name readily available from activities conducted during 

compliance determination, such as review of Material Safety Data Sheets (MSDSs) or review of 

the EPCRA Section 313 chemical list, and report it in Part II, Section 1.2 of the Form R. (0.25 

min/0 min) 

Reporting Burden Associated with Part II, Section 1.2

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 0.25 0.00 

Total 0.33 0.08 

Section 1.3: Generic Chemical Name

Facilities must meet rigorous standards as outlined in 40 CFR 350 in order to claim trade secret 

status; therefore, this section of the Form R is not typically used. If a facility meets the standard 

for trade secret status, this section of the Form R is completed instead of Part II, Sections 1.1 and 

1.2. If this section is used, management burden includes proofreading this section as part of an 

overall review of the Form R. (0.08 min/0.08 min) 
Appendix G

 4/28/11 

G-16

Technical staff would create a generic, structurally descriptive chemical name and report it in 

Part II, Section 1.3 of the Form R. (0.50 min/0 min) 

Reporting Burden Associated with Part II, Section 1.3

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 0.50 0.00 

Total 0.58 0.08 

Section 1.4: Distribution of Each Member of the Dioxin and Dioxin-Like Compounds 

Category 

This section of the Form R is left blank unless the chemical is dioxin and dioxin-like compounds. 

Therefore, for Form Rs for all other chemicals there is no management, technical, nor clerical 

burden associated with this element. If the Form R is for dioxin and dioxin-like compounds, 

management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

Technical staff would most likely obtain the distribution of each member of the dioxin and 

dioxin-like compounds category for the appropriate activity from EPA’s document “EPCRA 

Section 313 Guidance for Reporting Toxic Chemicals Within the Dioxin and Dioxin-like 

Compounds Category” and report it in Part II, Section 1.4 of the Form R. (5 min/2 min) 

Reporting Burden Associated with Part II, Section 1.4

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 5.00 2.00 

Total 5.08 2.08 

Section 2.1: Generic Chemical Name Provided by Supplier

This section of the Form R is only completed if the facility’s chemical supplier meets the 

standard for trade secret status and is therefore not typically used. If the material supplied meets 

the standard for trade secret status, this section of the Form R is completed instead of Part II, 

Sections 1.1 and 1.2. If this section is used, management burden includes proofreading this 

section as part of an overall review of the Form R. (0.08 min/ 0.08 min) 
Appendix G

 4/28/11 

G-17

Technical staff would have the generic chemical name provided by the supplier readily available 

from activities conducted during compliance determination, such as review of Material Safety 

Data Sheets (MSDSs), and report it in Part II, Section 2.1 of the Form R. (0.25 min/0 min) 

Reporting Burden Associated with Part II, Section 2.1

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 0.25 0.00 

Total 0.33 0.08 

Section 3.1: Manufacture the Toxic Chemical

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

As an integral part of compliance determination, the facility becomes familiar with the EPCRA 

Section 313 threshold activities that the chemical was involved in during the reporting year. 

Therefore, technical staff simply check off the relevant descriptions of manufacturing activities 

for the chemical presented in Part II, Section 3.1 of the Form R. (0.08 min/0 min) 

Reporting Burden Associated with Part II, Section 3.1

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 0.08 0.00 

Total 0.16 0.08 

Section 3.2: Process the Toxic Chemical

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

As an integral part of compliance determination, the facility becomes familiar with the EPCRA 

Section 313 threshold activities that the chemical was involved in during the reporting year. 

Therefore, technical staff simply check off the relevant descriptions of processing activities for 

the chemical presented in Part II, Section 3.2 of the Form R. (0.08 min/0 min) 
Appendix G

 4/28/11 

G-18

Reporting Burden Associated with Part II, Section 3.2

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 0.08 0.00 

Total 0.16 0.08 

Section 3.3: Otherwise Use the Toxic Chemical

Management burden includes proofreading this section as part of an overall review of the Form 

R. (0.08 min/0.08 min) 

As an integral part of compliance determination, the facility becomes familiar with the EPCRA 

Section 313 threshold activities that the chemical was involved in during the reporting year. 

Therefore, technical staff simply check off the relevant descriptions of otherwise use activities 

for the chemical presented in Part II, Section 3.3 of the Form R. (0.08 min/0 min) 

 

Reporting Burden Associated with Part II, Section 3.3

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.08 0.08 

Technical 0.08 0.00 

Total 0.16 0.08 

Section 4.1: Maximum Amount of the Toxic Chemical On-Site at any Time During the 

Calendar Year

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (1.08 min/ 0.91 min) 

The maximum amount of toxic chemical on-site at any point during the year is reported as a 

range code, with each range representing one order of magnitude. To determine the range 

estimate for the maximum amount of the toxic chemical in storage, in process, and in on-site 

wastes at any one point during the year, it is assumed the technical staff performs the steps 

outlined below. The estimate is needed to identify a quantity within a very broad range, not to 

identify a more exact quantity. For this reason, steps outlined here will take less time than when 

conducted for a data element requiring a more precise estimate. 

• Determine the maximum quantity of the toxic chemical in storage at any point during the 

calendar year by either reviewing inventory records or talking with operations staff. (9.00 

min/9.00 min) 
Appendix G

 4/28/11 

G-19

• Determine the maximum quantity of the toxic chemical in process at any point during the 

calendar year by either reviewing operations records or talking with operations staff. 

(9.00 min/9.00 min) 

• Determine the maximum quantity of the toxic chemical in on-site wastes at any point 

during the calendar year by either reviewing waste records, such as hazardous waste 

manifests, or talking with operations staff. (9.00 min/9.00 min) 

• Sum together the storage, process, and waste quantities to calculate the maximum amount 

of the toxic chemical on-site at any one point during the year. (3.00 min/3.00 min) 

• Locate the appropriate 2-digit code from the TRI Reporting Forms and Instructions and 

report it in Part II, Section 4.1 of the Form R. (0.25 min/0.25 min) 

Reporting Burden Associated with Part II, Section 4.1

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 1.08 0.91 

Technical 30.25 30.25 

Total 31.33 31.16 

Section 5.1: Fugitive or Non-Point Air Emissions

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (3.08 min/2.58 min) 

The most commonly reported basis of estimate code for fugitive air releases for both non-PBT 

and PBT chemicals is “O,” other approaches. It is assumed the most typical approach would 

involve an estimate based on use of physical and chemical properties and process operating 

conditions. To estimate fugitive or non-point air emissions, technical staff would perform the 

following steps: 

• Identify all fugitive release points for the chemical through review of air permits, 

discussions with operations staff, review of process flow diagrams, or a visual inspection 

of operations. (30.00 min/5.00 min) 

• Identify physical and chemical property data for the chemical, including volatility, 

boiling point, etc. (5.00 min/5.00 min) 

• Identify relevant process operating conditions, such as temperature, turbulence, etc., 

(45.00 min/30.00 min) 
Appendix G

 4/28/11 

G-20

• Determine material usage quantity through a review of inventory records, purchase 

records, operation records, or discussions with operations staff. (30.00 min/30.00 min) 

• Locate and review guidance from EPA, trade associations, or other sources, or air permit 

information that provides quantitative assistance for estimating fugitive loss (e.g., EPA’s 

Protocol for Equipment Leak Emission Estimates, air permit assumption of 1% loss of 

volatiles due to transfers in an otherwise closed system). (60.00 min/30.00 min) 

• Make the best estimate of fugitive or non-point air emissions based upon the physical and 

chemical properties and process operating conditions and report the value in Part II, 

Section 5.1 of the Form R. (25.00 min/15.00 min) 

• Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 5.1.B of the Form R. (0.25 min/0.25 min) 

Reporting Burden Associated with Part II, Section 5.1

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 3.08 2.58 

Technical 195.25 115.08 

Total 198.33 117.66 

Section 5.2: Stack or Point Air Emissions

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (3.08 min/1.75 min) 

The most commonly reported basis of estimate code for stack air releases for non-PBT chemicals 

is “O,” other approaches. It is assumed the most typical approach uses non-published emission 

factors. The most commonly reported basis of estimate code for stack air releases for PBT 

chemicals is “E,” published emission factors. Using these emission factors, technical staff would 

perform the following steps: 

• Identify all of the stack release points for the chemical. The process for identifying these 

releases requires technical staff to perform any or all of the following steps: review air 

permits or process flow diagrams, consult with operational/environmental staff, or 

conduct a visual inspection of the facility. (30.00 min/5.00 min) 

• For each stack air release, locate the most applicable emission factor. For PBT 

chemicals, EPA-published emission factors are obtained from numerous EPA sources, 

including a chemical or industry specific guidance, AP-42, or the technology transfer 
Appendix G

 4/28/11 

G-21

network (for TANKS program). (10/9 minutes) For non-PBT chemicals, emission 

factors are obtained from sources such as trade associations and university research. 

(30.00 min/15.00 min) 

• Determine the annual quantity of input material by reviewing purchase records, inventory 

records, and/or operational records. (30.00 min/30.00 min) 

• Multiply this material usage quantity by the emission factor to determine the amount of 

material released from each point during the year. If needed, convert the amount of 

material released to pounds (or grams for dioxins) by applying the appropriate conversion 

factor. (6.00 min/6.00 min) 

It is assumed that there will be an average of two unique types of stack releases for each 

chemical at a typical facility (i.e., two different emission factors would be applied). There are 

economies of scale in quantifying the second release type due to concurrent activities, such as 

searching the same sources to locate emission and conversion factors (4.00 min/4.00 min) and 

reviewing the same sources to determine the annual quantity of input material. Technical staff 

would perform the following steps: 

• Multiply this material usage quantity by the emission factor to determine the amount of 

material released from each point during the year. If needed, convert the amount of 

material released to pounds (or grams for dioxins) by applying the appropriate conversion 

factor. (5.00 min/5.00 min) 

• Sum all of the quantified stack air releases for the given chemical to quantify the total 

stack or point air emissions (lb/yr) and report the value in Part II, Section 5.2 of the Form 

R. (1.00 min/1.00 min) 

• Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 5.2.B of the Form R. (0.25 min/0.25 min) 

Reporting Burden Associated with Part II, Section 5.2

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 3.08 1.75 

Technical 106.25 66.25 

Total 109.33 68.00 
Appendix G

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G-22

Section 5.3: Discharges to Receiving Streams or Water Bodies

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (3.33 min/2.83 min) 

The most commonly reported basis of estimate code for discharges to receiving streams or water 

bodies is “M,” use of monitoring data, for both non-PBTs and PBTs. To estimate discharges to 

receiving streams or water bodies, technical staff would perform the following steps: 

 

Release Quantity from Process Water 

1. Locate and review the facility’s monitoring results for process water outfall(s) to 

determine the chemical concentration for each monitoring point. (35.00 min/25.00 min) 

2. Obtain flow rate data from the NPDES permit or a flow meter. If neither is available, 

estimate the volume of wastewater generated by reviewing water usage data. The 

estimated flow is calculated by dividing the volume of wastewater by the usage time 

(e.g., days). (15.00 min/10.00 min) 

3. Identify the number of discharge days by talking with operations staff. (15.00 min/15.00 

min) 

4. Multiply the identified chemical concentration (for one monitoring data point) by the 

daily water flow rate to calculate the daily release for this point. Repeat this step for all 

monitoring points, averaging the results together to calculate the average daily release. 

Multiply the average daily release by the number of release days to calculate the total 

annual release quantity. Apply any needed conversion factors to get the result in pounds. 

(10.00 min/10.00 min) 

Release Quantity from Storm Water

5. Locate and review the facility’s monitoring results from storm water outfall(s) to 

determine the chemical concentration for each monitoring point, and average them 

together. Apply needed conversion factors to obtain the total annual release from storm 

water in pounds. (45.00 min/35.00 min) 

6. Locate the annual rainfall for the facility’s area, assuming 12 inches of snow is equivalent 

to 1 inch of rain. (4.00 min/3.00 min) 

7. Estimate the percent of land at the facility covered by asphalt, concrete, and unimproved 

vegetation/soil. Technical staff generate a weighted-average runoff coefficient by 

multiplying the percent of land area by the runoff coefficient for that land type. (30.00 

min/5.00 min) 
Appendix G

 4/28/11 

G-23

8. Multiply the total annual rainfall by the weighted-average runoff coefficient, the total 

area of the facility, and the conversion factor for gallons per cubic foot to calculate the 

total annual storm water runoff in gallons. (5.00 min/5.00 min) 

9. Multiply the total volume (gallons) of storm water by the chemical concentration to 

calculate the total mass (pounds) of the chemical contained in the annual storm water 

runoff. If needed, apply a conversion factor. (4.00 min/4.00 min) 

 

Total Release Quantity

10. Sum together the annual release quantity from process water with the annual release 

quantity from storm water to obtain the total annual release quantity to water. Report the 

total release (lb/yr) in Part II, Section 5.3.1.A of the Form R as the total releases to a 

water body for a specific chemical. (2.00 min/2.00 min) 

Basis of Estimate

11. Report whether the release estimate was based on monitoring data, mass balance, a 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 5.3.1.B of the Form R. (0.25 min/0.25 min) 

Percent from Stormwater

12. Divide the quantity of the chemical contained in the storm water by the total quantity of 

the chemical released to water in order to calculate the percent of the chemical released 

from storm water. Report this percentage in Part II, Section 5.3.1.C of the Form R. (2.00 

min/2.00 min) 

Note: Many facilities will not need to assess storm water in order to calculate release to water as 

many TRI chemicals will not typically be found in storm water run-off, but will instead only be 

found in process water. In order to reasonably estimate how much time should be allocated to a 

typical facility for assessing storm water, a data analysis was conducted on the RY 2002 TRI 

data. First, all form Rs for which 5.3A had a value of greater than or equal to zero were 

identified. Second, within that set, the percentage of these forms that had a value of greater than 

zero in 5.3C were identified. This analysis was conducted separately for non-PBTs and for 

PBTs, with identified values of 39.3% and 44.4%, respectively. The total estimated burden for 

identifying annual release quantity from storm water (steps 5 through 9 above) was then 

multiplied by 39.3% for non-PBTs and by 44.4% for PBTs. This calculation is shown below: 

Total percent from storm water burden multiplied by incidence rate for a value greater than zero 

in 5.3.C when there was a value of greater than or equal to zero in 5.3.A: 

non-PBTs: (88.00 min/52.00 min) x 39.3% incidence = (34.58/20.44) 

PBTs: (88.00 min/52.00 min) x 44.4% incidence = (39.07/23.09) 
Appendix G

 4/28/11 

G-24

 

This incidence-weighted value was added with the total estimated burden for identifying the 

annual release quantity from process water to obtain the total calculation time estimate for 5.3.A. 

The table below reflects the incidence-weighted value for storm water assessment. 

Reporting Burden Associated with Part II, Section 5.3

Personnel Type

First Year Burden (minutes) Subsequent Year Burden (minutes)

Non-PBT PBT Non-PBT PBT

Management 3.33 3.33 2.83 2.83 

Technical 113.83 118.32 84.69 87.34 

Total 117.16 121.65 87.52 90.17 

Section 5.4.1: Underground Injection On-Site to Class I Wells 

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (2.08 min/1.75 min) 

The most commonly reported basis of estimate code for releases to underground injection Class I 

wells is “M,” use of monitoring data for both non-PBT and PBT chemicals. To estimate 

quantities injected underground or on-site to Class I wells, the technical staff would perform the 

following steps: 

1. Locate and review monitoring data for the facility, and then, for each monitoring event, 

identify the concentration of the specific chemical in the waste stream. The chemical 

concentrations from all monitoring events are then averaged. (35.00 min/25.00 min) 

2. Either talk to operations staff, review production records and estimate waste generation, 

review well operations records, or review well permit data/required injection well reports 

to determine the total quantity of waste disposed via Class I wells for the reporting year. 

(30.00 min/30.00 min) 

3. Multiply the total quantity of waste disposed via Class I wells by the average 

concentration of the specific chemical in the waste stream to calculate the total pounds of 

the chemical released to Class I wells during the reporting year. If needed, apply a 

conversion factor. Report the value (lb/yr) in Part II, Section 5.4.1.A of the Form R. 

(8.00 min/8.00 min) 

4. Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 5.4.1.B of the Form R. (0.25 min/0.25 min) 
Appendix G

 4/28/11 

G-25

Reporting Burden Associated with Part II, Section 5.4.1

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 2.08 1.75 

Technical 73.25 63.25 

Total 75.33 65.00 

Section 5.4.2: Underground Injection On-Site to Class II-V Wells 

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (2.08 min/1.75 min) 

The most commonly reported basis of estimate code for releases to underground injection Class 

II-V wells is “M,” use of monitoring data for both non-PBT and PBT chemicals. To estimate 

quantities injected underground or on-site to Class II-V wells, the technical staff would perform 

the following steps: 

1. Locate and review monitoring data for the facility. Then, for each monitoring point, 

identify the concentration of the specific chemical in the waste stream. The chemical 

concentrations from all monitoring data points (events) are then averaged. (35.00 

min/25.00 min) 

2. Either talk to the operations staff, review production records and estimate waste 

generation, review well operations records, or review well permit data/required injection 

well reports to determine the total quantity of waste disposed via Class II-V wells for the 

reporting year. (30.00 min/30.00 min) 

3. Multiply the total quantity of waste disposed via Class II-V wells by the average 

concentration of the specific chemical in the waste stream to calculate the total pounds of 

the chemical released to Class II-V wells during the reporting year,. If needed, apply a 

conversion factor. Report the value (lb/yr) in Part II, Section 5.4.2.A of the Form R. 

(8.00 min/8.00 min) 

4. Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 5.4.2.B of the Form R. (0.25 min/0.25 min) 
Appendix G

 4/28/11 

G-26

Reporting Burden Associated with Part II, Section 5.4.2

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 2.08 1.75 

Technical 73.25 63.25 

Total 75.33 65.00 

Section 5.5.1A: On-site Land Disposal via RCRA Subtitle C Landfills

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (3.08 min/1.75 min) 

The most commonly reported basis of estimate code for releases to RCRA landfills is “O,” other 

approaches, for both non-PBT and PBT chemicals. It is assumed technical staff would track the 

generation and on-site disposal of these wastes as follows: 

1. Identify all waste streams containing the chemical of interest disposed of in RCRA 

landfills. (30.00 min/5.00 min) 

2. Review RCRA records (manifests and biennial reports) to determine the total quantity of 

waste disposed of in RCRA landfills for the reporting year; or talk to operations staff, 

review production records and estimate waste generation, or review on-site disposal 

tracking records. (30.00 min/30.00 min) 

3. Review RCRA waste characterization data, talk to operations staff, review any nonRCRA waste characterization information, or review production/activity Standard 

Operating Procedures (SOPs) and process flow diagrams to determine the concentration 

of a specific chemical disposed of in a RCRA landfill. (30.00 min/25.00 min) 

4. Multiply the total quantity of waste disposed of in RCRA landfills by the average 

concentration of the specific chemical in the waste stream to calculate the total pounds of 

the chemical disposed of in RCRA landfills during the reporting year,. If needed, apply a 

conversion factor. Report the value (lb/yr) in Part II, Section 5.5.1A.A of the Form R. 

(6.00 min/6.00 min) 

5. Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 5.5.1A.B of the Form R. (0.25 min/0.25 min) 
Appendix G

 4/28/11 

G-27

Reporting Burden Associated with Part II, Section 5.5.1A

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 3.08 1.75 

Technical 96.25 66.25 

Total 99.33 68.00 

Section 5.5.1B: On-site Land Disposal via Other Landfills

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (3.08 min/1.75 min) 

The most commonly reported basis of estimate code for releases to on-site non-RCRA landfills is 

“O,” other approaches, for both non-PBT and PBT chemicals. It is assumed the technical staff 

would track the generation and on-site disposal of these wastes as follows: 

1. Identify all waste streams containing the chemical of interest disposed of in on-site nonRCRA landfills. (30.00 min/5.00 min) 

2. Talk to operations staff, review production records and estimate waste generation, or 

review on-site disposal tracking records to determine the total quantity of waste disposed 

of in non-RCRA landfills for the reporting year. (30.00 min/30.00 min) 

3. Talk to operations staff, review any waste characterization information, or review 

production/activity SOPs and process flow diagrams to determine the concentration of a 

specific chemical disposed of in non-RCRA landfills. (30.00 min/25.00 min) 

4. Multiply the total quantity of waste disposed via non-RCRA landfills by the average 

concentration of the specific chemical in the waste stream to calculate the total pounds of 

the chemical disposed of in non-RCRA landfills during the reporting year. If needed, 

apply a conversion factor. Report the value (lb/yr) in Part II, Section 5.5.1B.A of the 

Form R. (6.00 min/6.00 min) 

5. Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 5.5.1B.B of the Form R. (0.25 min/0.25 min) 

 
Appendix G

 4/28/11 

G-28

Reporting Burden Associated with Part II, Section 5.5.1B

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 3.08 1.75 

Technical 96.25 66.25 

Total 99.33 68.00 

Section 5.5.2: On-Site Land Disposal via Land Treatment/Application Farming

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (2.08 min/1.75 min for non-PBT filers; 3.08 min/1.75 min for PBT filers) 

The most commonly reported basis of estimate code for releases via land treatment is “M,” use 

of monitoring data, for non-PBT chemicals. To estimate the quantity going to on-site land 

disposal via land treatment/application farming for non-PBT chemicals, the technical staff would 

perform the following steps: 

1. Locate monitoring data and determine the chemical concentration in the waste stream for 

each monitoring point. Then calculate an average chemical concentrations across all 

monitoring data points (events). (35.00 min/ 25.00 min) 

2. Talk to operations staff, review production records, and estimate waste generation, or 

review on-site disposal tracking records (i.e., the number of land applications multiplied 

by the average load size) to determine the total quantity of waste disposed via land 

treatment/application farming for the reporting year. (30.00 min/30.00 min) 

3. Multiply the total quantity of waste disposed via land treatment by the average 

concentration of the specific chemical in the waste stream to calculate the total pounds of 

the chemical disposed of on-site for land treatment/application farming during the 

reporting year. If needed, apply a conversion factor. Report the value (lb/yr) in Part II, 

Section 5.5.2.A of the Form R. (8 min/8 min) 

 

4. Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 5.5.2.B of the Form R. (0.25 min/0.25 min) 

The most commonly reported basis of estimate code for releases via land treatment is “O,” other 

approaches, for PBT chemicals. To estimate the quantity going to on-site land disposal via land 

treatment/application farming for PBT chemicals, the technical staff would perform the 

following steps: 
Appendix G

 4/28/11 

G-29

• Identify all waste streams disposed of via land treatment that contain the chemical of 

interest. (30.00 min/5.00 min) 

• Determining the total quantity of waste disposed of via land treatment for the reporting 

year requires the technical staff to either talk to operations staff, review production 

records and estimate waste generation, or review on-site disposal tracking records. (30.00 

min/30.00 min) 

• Talk to operations staff, review any waste characterization information, or review 

production/activity SOPs and process flow diagrams to generate chemical concentration 

estimates of a specific chemical disposed of via land treatment. (30.00 min/25.00 min) 

• Multiply the total quantity of waste disposed via land treatment by the average 

concentration of the specific chemical in the waste stream to calculate the total pounds of 

the chemical disposed of via land treatment during the reporting year. If needed, apply a 

conversion factor. Report the value (lb/yr) in Part II, Section 5.5.2.A of the Form R. 

(6.00 min/6.00 min) 

• Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 5.5.2.B of the Form R. (0.25 min/0.25 min) 

Reporting Burden Associated with Part II, Section 5.5.2

Personnel Type

First Year Burden (minutes) Subsequent Year Burden (minutes)

Non-PBT PBT Non-PBT PBT

Management 2.08 3.08 1.75 1.75 

Technical 73.25 96.25 63.25 66.25 

Total 75.33 99.33 65.00 68.00 

Section 5.5.3A: RCRA Subtitle C Surface Impoundments 

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (3.08 min/1.75 min) 

The most commonly reported basis of estimate code for releases via RCRA surface 

impoundments is “C,” mass balance, for both non-PBT and PBT chemicals. To estimate TRI 

chemical quantities sent to RCRA landfills, technical staff would track the loss of this chemical 

using a mass balance approach as follows: 

• Identify all waste streams disposed of via RCRA Subtitle C surface impoundments that 

contain the chemical of interest. (30.00 min/5.00 min) 
Appendix G

 4/28/11 

G-30

• Determine the total annual chemical usage quantity through a review of production 

records, a review of inventory records, or conversations with operations staff. (30.00 

min/30.00 min) 

• Estimate the quantity of the chemical that goes out with the product through a review of 

product QA/QC data or product specifications, or conversations with operations staff. 

(30.00 min/25.00 min) 

• Subtract the quantity of the chemical in the product from the total chemical usage 

quantity to determine the total waste quantity via mass balance. If the total waste quantity 

is not disposed of via RCRA surface impoundment, the total waste quantity is multiplied 

by the percentage of waste going to RCRA surface impoundments. If needed, apply a 

conversion factor. Report the value (lb/yr) in Part II, Section 5.5.3A.A of the Form R. 

(6.00 min/6.00 min) 

• Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 5.5.3A.B of the Form R. (0.25 min/0.25 min) 

Reporting Burden Associated with Part II, Section 5.5.3A

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 3.08 1.75 

Technical 96.25 66.25 

Total 99.33 68.00 

Section 5.5.3B: Other Surface Impoundments 

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (3.08 min/1.75 min) 

The most commonly reported basis of estimate code for releases via other surface impoundments 

is “C,” mass balance, for both non-PBT and PBT chemicals. To estimate TRI chemical 

quantities sent to other surface impoundments, technical staff would track the loss of this 

chemical using a mass balance approach as follows: 

• Identify all waste streams disposed of via other surface impoundments that contain the 

chemical of interest through a review of process flow diagrams, conversations with 

operations staff, or a visual inspection of the process area. (30.00 min/5.00 min) 
Appendix G

 4/28/11 

G-31

• Determine the total annual chemical usage quantity through a review of production 

records, a review of inventory records, or conversations with operations staff. (30.00 

min/30.00 min) 

• Estimate the quantity of chemical that goes out with the product through a review of 

product QA/QC data or product specifications, or conversations with operations staff. 

(30.00 min/25.00 min) 

• Subtract the quantity of the chemical in the product from the total chemical usage 

quantity to determine the total waste quantity via mass balance. If the total waste quantity 

is not disposed of via non-RCRA surface impoundment, the total waste quantity is 

multiplied by the percentage of waste going to non-RCRA surface impoundments. If 

needed, apply a conversion factor. Report the value (lb/yr) in Part II, Section 5.5.3B.A of 

the Form R. (6.00 min/6.00 min) 

• Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 5.5.3B.B of the Form R. (0.25 min/0.25 min) 

Reporting Burden Associated with Part II, Section 5.5.3B

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 3.08 1.75 

Technical 96.25 66.25 

Total 99.33 68.00 

Section 5.5.4: Other On-Site Land Disposal

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (1.08 min/0.91 min) 

 

Other on-site land disposal can include intentional storage of wastes on land (other than in 

landfills, surface impounds or via land treatment/application farming), or unplanned releases to 

land from spills and accidents. Best engineering judgement indicates that reporting in this 

category is primarily due to unplanned releases from spills and accidents. While time estimates 

are provided for both scenarios, the time allotted to this data element for the overall Form R 

realistic burden estimate is from the unplanned release scenario only. 

The most commonly reported basis of estimate code for other on-site land disposal is “O,” other 

approaches, for both non-PBT and PBT chemicals. It is assumed that the approach used by 

technical staff would be to track the generation and on-site disposal of these wastes as follows: 
Appendix G

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G-32

For planned other on-site disposal to land: 

• Identify all waste streams disposed of via other land disposal that contain the chemical of 

interest. (30.00 min/5.00 min) 

• Talk to operations staff, review production records and estimate waste generation, or 

review on-site disposal tracking records to determine the total quantity of waste disposed 

of via other land disposal for the reporting year. (30.00 min/30.00 min) 

• Talk to operations staff, review any waste characterization information, or review 

production/activity SOPs and process flow diagrams to generate chemical concentration 

estimates of a specific chemical disposed of via other land disposal. (30.00 min/25.00 

min) 

• For planned releases, multiply the total quantity of waste disposed via surface 

impoundment by the average concentration of the specific chemical in the waste stream 

to calculate the total release pounds of the chemical disposed of via other land disposal 

during the reporting year. If needed, apply a conversion factor. (6.00 min/6.00 min) 

For unplanned other on-site disposal to land: 

• For unplanned releases, determine the total quantity of the chemical released to land 

during unplanned events, such as spills and accidents, by either reviewing spill reports, 

contacting spill responders, or conducting a mass balance estimate based upon the 

quantity of materials in storage tanks before and after the event. Report the value (lb/yr) 

in Part II, Section 5.5.4.A of the Form R. (35.00 min/35.00 min) 

• Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 5.5.4.B of the Form R. (0.25 min/0.25 min) 

Best engineering judgment indicates that most reporting in this section will come from 

unplanned (accidental) releases. As such, the following table only provides time estimates 

relevant to the reporting of these releases. 

Reporting Burden Associated with Part II, Section 5.5.4

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 1.08 0.91 

Technical 35.25 35.25 

Total 36.33 36.16 
Appendix G

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Section 6.1: Discharges to Publicly Owned Treatment Works

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (3.58 min/2.25 min) 

The most commonly reported basis of estimate code for discharges to POTWs is “M,” use of 

monitoring data, for both non-PBTs and PBTs. To estimate the total quantity of a TRI chemical 

discharged to a POTW, technical staff would perform the following steps: 

• Locate and review monitoring data in order to identify the necessary chemical 

concentration information. The monitoring data could be obtained by either reviewing 

internal files or speaking directly with the pre-treatment coordinator at the POTW. (35.00 

min/25.00 min) 

• Review flow meter data to locate flow rate data. If flow meter data are not available, 

technical staff estimate the quantity of wastewater generated by reviewing water usage 

data. This quantity is then divided by usage time (e.g., days) in order to calculate the 

estimated flow. Alternatively, technical staff might request flow rate data directly from 

the POTW. (15.00 min/10.00 min) 

• Talk with operations staff or contact the POTW to determine the number of days 

wastewater was sent to the POTW. (15.00 min/15.00 min) 

• Multiply the identified chemical concentration (for one monitoring data point) by the 

daily water flow rate to calculate the total mass of the chemical transferred to the POTW 

on a daily basis. If needed, locate a conversion factor in order to report the final result in 

units of pounds per day. Repeat the above steps for every monitoring result, then average 

together all of the results. Multiply the pound per day release value by the total number 

of discharge days per year to calculate the total annual transfers to POTWs in pounds. 

Report the value (lb/yr) in Part II, Section 6.1.A.1 of the Form R. (8.00 min/8.00 min) 

• Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Part II, Section 6.1.A.2 of the Form R. (0.25 min/0.25 min) 

An analysis of the RY 2002 showed that an average of one POTW per Form R was listed for 

both non-PBT and PBT chemicals. For subsequent year reporting, it is assumed the facility will 

be using the same POTW. 

• Technical staff will have the POTW name and location information readily available 

from document review conducted for the release estimate. Technical staff will report this 

information in Part II, Section 6.1.B.1 of the Form R. (1.50 min/0 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 6.1

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 3.58 2.25 

Technical 74.75 58.25 

Total 78.33 60.50 

Section 6.2: Transfers to Other Off-Site Locations

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (4.83 min/3.42 min) 

The most commonly reported basis of estimate code for transfers to other off-site locations is 

“O,” other approaches, for both non-PBT and PBT chemicals. It is assumed that the approach 

used by technical staff would be to track the off-site transfer of these wastes primarily using 

waste characterization and waste transfer documentation as outlined below: 

• Identify all off-site transfers of unique waste streams containing the chemical of interest. 

(30.00 min/ 5.00 min) 

• For the first unique waste stream, determine the concentration of the chemical in the 

stream by either reviewing waste characterization profiles, contacting the facility’s 

hazardous waste shipper to obtain their waste characterization information, or conducting 

a mass balance evaluation. (30.00 min/30.00 min) 

• Determine the total quantity of the first unique waste stream that the facility ships offsite during the reporting year by reviewing hazardous waste manifests, invoices from 

waste vendors, or talking to operations staff. (30.00 min/30.00 min) 

• For the first waste stream, multiply the chemical concentration by the total quantity of 

waste shipped off-site to calculate the total quantity of the chemical shipped off-site for 

the year. If needed, multiply by a conversion factor to obtain a final result in pounds. 

(6.00 min/6.00 min) 

An analysis of RY 2002 TRI data indicates that there was an average of approximately two offsite transfer locations and an average of approximately two reported “M” codes. Therefore, it is 

assumed that on average, two unique waste streams are being transferred off-site. There are 

economies of scale in estimating the quantity of the TRI chemical in the second waste stream due 

to the concurrent activities of reviewing the same sources to determine the chemical 

concentration in the waste and to estimate the annual quantity of waste transferred off-site. To 

estimate the additional time needed to quantify the off-site transfer of the second waste stream 

technical staff would perform the following: 
Appendix G

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G-35

• For the second waste stream, determine the concentration of the chemical in the stream 

by either reviewing waste characterization profiles, contacting the facility’s hazardous 

waste shipper to obtain their waste characterization information, or conducting a mass 

balance evaluation. Determine the total quantity of each unique waste stream that the 

facility ships off-site during the reporting year. (5.00 min/5.00 min) 

• For the second waste stream, multiply the chemical concentration by the total quantity of 

waste shipped off-site to calculate the total quantity of the chemical shipped off-site for 

the year. If needed, multiply by a conversion factor to obtain a final result in pounds. 

Calculate the total quantity of the chemical shipped off-site for all waste streams by 

summing together the annual quantity of the chemical shipped off-site in each waste 

stream. Report this result (lb/yr) in Part II, Section 6.2.A of the Form R. (6.00 min/6.00 

min) 

For both waste streams, technical staff would perform the following steps: 

 

• Report whether the release estimate was based on monitoring data, mass balance, 

published emission factor, or other engineering calculations by recording the code M, C, 

E, or O, respectively, in Section 6.2.B of the Form R. (0.25 min/0.25 min) 

• Report the type of waste treatment/disposal/recycling/energy recovery code by recording 

the appropriate M-code in Section 6.2.C of the Form R. (0.25 min/0.25 min) 

As indicated above, an analysis of RY 2002 TRI data showed that for off-site transfers, there was 

an average of approximately two off-site transfer locations. For subsequent year reporting, it is 

assumed the facility will not necessarily use the same off-site transfer locations. Due to the 

competitive nature of the hazardous waste removal industry, market fluctuations, the search for 

better pricing, and the fact that facilities can readily change vendors (unlike piping changes 

needed to use a different POTW, for example), it is possible that facilities may be using different 

off-site transfer locations from year-to-year. For this reason, it is not assumed that only one offsite transfer facility name and location will be pre-populated from loading last year’s forms, and 

typing time is allotted to enter the second off-site transfer name and location information. 

• Technical staff will have the off-site transfer name and location information readily 

available from document review conducted for the release estimate and will report this 

information in Part II, Section 6.2.1 and 6.2.2 of the Form R. (4.17 min/2.08 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 6.2

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 4.83 3.42 

Technical 112.17 84.58 

Total 117.00 88.00 

Section 7A: On-Site Waste Treatment Methods and Efficiency 

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (5.17 min/3.50min) 

To complete Section 7A, technical staff perform the following steps: 

• Review process diagrams, review air or NPDES permits, or talk to the operations staff to 

identify any on-site waste treatment activities. For the first waste stream, technical staff 

perform the following steps: 

• Identify the type of waste stream (gaseous, wastewater, liquid waste, or solid 

waste) and report the appropriate code in Part II, Section 7A.1a. (10.00 min/5.00 

min) 

• Identify all of the treatment steps this waste stream passes through and the order 

of occurrence. Locate the appropriate treatment codes representing the treatment 

activity in the TRI Reporting Forms and Instructions and report them in the actual 

order of occurrence in Part II, Section 7A.1b of the Form R. (20.00 min/5.00 min) 

• Locate and review monitoring data, or talk with operations staff to determine the range of 

influent concentration. Report the appropriate range code for this concentration in Part 

II, Section 7A.1.c of the Form R. (30.00 min/15.00 min) 

• Technical staff apply one of the approaches listed below to quantify the treatment 

efficiency: 

• Review equipment manuals for manufacturer reported efficiencies. 

• Use pre- and post-treatment analytical data to calculate treatment efficiency by 

subtracting the post-treatment chemical concentration from the pre-treatment 

chemical concentration and then divide the result by the pre-treatment chemical 

concentration. 

• Technical staff can also obtain the information by talking to operations staff. 
Appendix G

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G-37

• Report the treatment efficiency in Part II, Section 7A.1.d of the Form R (15.00 

min/5.00 min). 

• Report whether the efficiency was calculated using monitoring data by checking yes or 

no in Part II, Section 7A.1e of the Form R. (0.08 min/0.08 min) 

An analysis of RY 2002 TRI data indicates that there was an average of approximately two waste 

streams listed under on-site treatment in Section 7A. The additional steps technical staff would 

take in identifying and reporting on-site treatment activities are outlined below. There are some 

economies of scale in identifying on-site treatment activities for the second waste stream as a full 

facility operations review was conducted as part of identifying if there are any waste streams 

undergoing on-site treatment. 

• No additional time would be needed to identify types of waste streams undergoing on-site 

treatment as the necessary review was already conducted to identify the first waste 

stream. Therefore, no additional time is needed in Part II, Section 7A.2a for the second 

waste stream (0.00min/0.00min). 

• Only incremental additional time would be needed to identify waste treatment activity 

steps for the second waste stream as document review and discussions with operations 

staff were already conducted to identify steps for the first waste stream. Therefore, the 

following additional time is needed in Part II, Section 7A.2b for the second waste stream 

(5.00min/2.00min). 

• Determining the range of the influent concentration for the second waste stream would 

require the same time effort as for the first waste stream because technical staff would be 

reviewing a different set of information, such as different laboratory reports. Therefore, 

the following additional time is needed in Part II, Section 7A.2c for the second waste 

stream (30.00min/15.00min). 

• Determining the treatment efficiency for the second waste stream would require the same 

time effort as for the first waste stream because technical staff would be reviewing a 

different set of information, such as different equipment manuals. Therefore, the 

following additional time is needed in Part II, Section 7A.2d for the second waste stream 

(15.00min/5.00min). 

• Report whether the efficiency for the second waste stream was calculated using 

monitoring data by checking yes or no in Part II, Section 7A.2e of the Form R,. (0.08 

min/0.08 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 7A

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 5.17 3.50 

Technical 125.16 52.16 

Total 130.33 55.66 

Section 7B: On-Site Energy Recovery Processes 

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (1.0 min/0.83 min) 

It is assumed that technical staff either review process flow diagrams or talk to operations staff in 

order to identify any on-site energy recovery activities. For each waste stream that is undergoing 

treatment for on-site energy recovery, technical staff locate the appropriate code for the activity 

in the TRI Reporting Forms and Instructions. The codes are reported in descending order by 

quantity of energy recycled in Part II, Section 7B of the Form R. (32.00 min/24.00 min) 

Reporting Burden Associated with Part II, Section 7B

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 1.00 0.83 

Technical 32.00 24.00 

Total 33.00 24.83 

Section 7C: On-Site Recycling Processes 

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (1.0 min/0.83 min) 

It is assumed that technical staff either review process flow diagrams or talk to operations staff in 

order to identify any on-site recycling activities. For each waste stream that is undergoing 

treatment for on-site recycling, technical staff locate the appropriate code for the activity in the 

TRI Reporting Forms and Instructions. The codes are reported in descending order by quantity 

of waste recycled in Part II, Section 7C of the Form R. (38.00 min/27.00 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 7C

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 1.00 0.83 

Technical 38.00 27.00 

Total 39.00 27.83 

Section 8.1a: Total On-Site Disposal to Class I Underground Injection Wells, RCRA 

Subtitle C Landfills, and Other Landfills

Management burden includes an assessment of whether quantities previously calculated for 

Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as 

proofreading this section as part of an overall review of the Form R. (0.50 min/0.50 min) 

Four columns must be completed in this section, requiring technical staff to perform the 

following steps: 

• Column A: Record "NA" in Part II, Section 8.1a, Column A of the Form R if the facility 

is a first time filer. For subsequent reporting years, locate the release estimate from the 

"Column B, Current Reporting Year" column from the previous year’s form and record 

this quantity in Part II, Section 8.1a, Column A of the Form R. (0.25 min/0.25 min) 

• Column B: Sum together the quantities calculated in Part II, Sections 5.4.1, 5.5.1A, and 

5.5.1B and then subtract any on-site release or disposal quantities due to catastrophic 

events. Report the total quantity disposed of on-site via Class I Underground Injection 

Wells, RCRA Subtitle C landfills, and other landfills in Part II, Section 8.1a, Column B 

of the Form R. (5.00 min/5.00 min) 

• Column C: Make the best projection for the following year's release quantity and record 

it in Part II, Section 8.1a, Column C of the Form R. If no source reduction activities are 

planned, multiply the current year release estimate by the expected percentage change in 

production for the following year. If source reduction activities are planned, make the 

best estimate for how much this will reduce the release quantity for the following year. 

(1.00 min/1.00 min) 

• Column D: Make the best projection for the second following year's release quantity and 

record it in Part II, Section 8.1a, Column D of the Form R. If no source reduction 

activities are planned, multiply the current year release estimate by the expected 

percentage change in production for the second following year. If source reduction 

activities are planned, make the best estimate of how much this will reduce the release 

quantity for the second following year. (1.00 min/1.00 min) 

Reporting Burden Associated with Part II, Section 8.1a
Appendix G

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G-40

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.50 0.50 

Technical 7.25 7.25 

Total 7.75 7.75 

Section 8.1b: Total Other On-Site Disposal or Other Releases

Management burden includes an assessment of whether quantities previously calculated for 

Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as 

proofreading this section as part of an overall review of the Form R. (0.50 min/0.50 min) 

Four columns must be completed in this section, requiring technical staff to perform the 

following steps: 

• Column A: Record "NA" in Part II, Section 8.1b, Column A of the Form R if the facility 

is a first time filer. For subsequent reporting years, locate the release estimate from the 

"Column B, Current Reporting Year" column from the previous year’s form and record 

this quantity in Part II, Section 8.1b, Column A of the Form R. (0.25 min/0.25 min) 

• Column B: Sum together the quantities calculated in Part II, Sections 5.1, 5.2, 5.3, 5.4.2, 

5.5.2, 5.5.3A, 5.5.3B, and 5.5.4 and then subtract any on-site release or disposal 

quantities due to catastrophic events. Report the total quantity disposed of on-site via 

other disposal or other releases in Part II, Section 8.1b, Column B of the Form R. (5.00 

min/5.00 min) 

• Column C: Make the best projection for the following year's release quantity and record 

it in Part II, Section 8.1b, Column C of the Form R. If no source reduction activities are 

planned, multiply the current year release estimate by the expected percentage change in 

production for the following year. If source reduction activities are planned, make the 

best estimate for how much this will reduce the release quantity for the following year. 

(1.00 min/1.00 min) 

• Column D: Make the best projection for the second following year's release quantity and 

record it in Part II, Section 8.1b, Column D of the Form R. If no source reduction 

activities are planned, multiply the current year release estimate by the expected 

percentage change in production for the second following year. If source reduction 

activities are planned, make the best estimate of how much this will reduce the release 

quantity for the second following year. (1.00 min/1.00 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 8.1b

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.5 0.50 

Technical 7.25 7.25 

Total 7.75 7.75 

Section 8.1c: Total Off-Site Disposal to Class I Underground Injection Wells, RCRA 

Subtitle C Landfills, and Other Landfills

Management burden includes an assessment of whether quantities previously calculated for 

Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as 

proofreading this section as part of an overall review of the Form R. (0.50 min/0.50 min) 

Four columns must be completed in this section, requiring technical staff to perform the 

following steps: 

• Column A: Record "NA" in Part II, Section 8.1c, Column A of the Form R if the facility 

is a first time filer. For subsequent reporting years, locate the release estimate from the 

"Column B, Current Reporting Year" column from the previous year’s form and record 

this quantity in Part II, Section 8.1c, Column A of the Form R. (0.25 min/0.25 min) 

• Column B: Sum together the quantities calculated in Part II, Sections 6.1 (portion of 

transfer that is untreated and ultimately disposed of in UIC Class I Wells, RCRA Subtitle 

C landfills and other landfills) and 6.2 (quantities associated with M codes M64, M65, 

and M81) and then subtract any off-site disposal quantities due to catastrophic events. 

Report the total quantity disposed of off-site via Class I Underground Injection Wells, 

RCRA Subtitle C landfills, and other landfills in Part II, Section 8.1c, Column B of the 

Form R. (5.00 min/5.00 min) 

• Column C: Make the best projection for the following year's release quantity and record 

it in Part II, Section 8.1c, Column C of the Form R. If no source reduction activities are 

planned, multiply the current year release estimate by the expected percentage change in 

production for the following year. If source reduction activities are planned, make the 

best estimate for how much this will reduce the release quantity for the following year. 

(1.00 min/1.00 min) 

• Column D: Make the best projection for the second following year's release quantity and 

record it in Part II, Section 8.1c, Column D of the Form R. If no source reduction 

activities are planned, multiply the current year release estimate by the expected 

percentage change in production for the second following year. If source reduction 

activities are planned, make the best estimate of how much this will reduce the release 

quantity for the second following year. (1.00 min/1.00 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 8.1c

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.5 0.50 

Technical 7.25 7.25 

Total 7.75 7.75 

Section 8.1d: Total Other Off-Site Disposal or Other Releases

Management burden includes an assessment of whether quantities previously calculated for 

Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as 

proofreading this section as part of an overall review of the Form R. (0.50 min/0.50 min) 

Four columns must be completed in this section, requiring technical staff to perform the 

following steps: 

• Column A: Record "NA" in Part II, Section 8.1d, Column A of the Form R if the facility 

is a first time filer. For subsequent reporting years, locate the release estimate from the 

"Column B, Current Reporting Year" column from the previous year’s form and record 

this quantity in Part II, Section 8.1d, Column A of the Form R. (0.25 min/0.25 min) 

• Column B: Sum together the quantities calculated in Part II, Sections 6.1 (portion of 

transfer that is untreated and ultimately disposed of in UIC Class II-V Wells, and land 

disposal other than to landfills) and 6.2 (quantities associated with M codes M10, M41, 

M62, M66, M67, M73, M79, M82, M90, M94, and M99) and then subtract any off-site 

disposal quantities due to catastrophic events. Report the total quantity disposed of offsite via other disposal or other releases in Part II, Section 8.1d, Column B of the Form R. 

(5.00 min/5.00 min) 

• Column C: Make the best projection for the following year's release quantity and record 

it in Part II, Section 8.1d, Column C of the Form R. If no source reduction activities are 

planned, multiply the current year release estimate by the expected percentage change in 

production for the following year. If source reduction activities are planned, make the 

best estimate for how much this will reduce the release quantity for the following year. 

(1.00 min/1.00 min) 

• Column D: Make the best projection for the second following year's release quantity and 

record it in Part II, Section 8.1d, Column D of the Form R. If no source reduction 

activities are planned, multiply the current year release estimate by the expected 

percentage change in production for the second following year. If source reduction 

activities are planned, make the best estimate of how much this will reduce the release 

quantity for the second following year. (1.00 min/1.00 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 8.1d

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.50 0.50 

Technical 7.25 7.25 

Total 7.75 7.75 

Section 8.2: Quantity Used for Energy Recovery On-Site

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (1.25 min/1.08 min) 

Four columns must be completed in this section, requiring technical staff to perform the 

following steps: 

• Column A: Record "NA" in Part II, Section 8.2, Column A of the Form R if the facility 

is a first time filer. For subsequent reporting years, locate the release estimate from the 

"Column B, Current Reporting Year" column from the previous year’s form and record 

this quantity in Part II, Section 8.2, Column A of the Form R. (0.25 min/0.25 min) 

• Column B: To estimate the quantity of the chemical used annually for actual energy 

recovery on-site, refer to the recovery processes reported in Section 7B and either review 

operations records or speak with operations staff. Report the total quantity used for 

energy recovery on-site in Part II, Section 8.2, Column B of the Form R. (30.00 

min/30.00 min) 

• Column C: Make the best projection for the following year's release quantity and record 

it in Part II, Section 8.2, Column C of the Form R. If no source reduction activities are 

planned, multiply the current year release estimate by the expected percentage change in 

production for the following year. If source reduction activities are planned, make the 

best estimate for how much this will reduce the release quantity for the following year. 

(1.00 min/1.00 min) 

• Column D: Make the best projection for the second following year's release quantity and 

record it in Part II, Section 8.2, Column D of the Form R. If no source reduction 

activities are planned, multiply the current year release estimate by the expected 

percentage change in production for the second following year. If source reduction 

activities are planned, make the best estimate of how much this will reduce the release 

quantity for the second following year. (1.00 min/1.00 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 8.2

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 1.25 1.08 

Technical 32.25 32.25 

Total 33.50 33.33 

Section 8.3: Quantity Used for Energy Recovery Off-Site

Management burden includes an assessment of whether quantities previously calculated for 

Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as 

proofreading of this section as part of an overall review of the Form R. (0.50 min/0.50 min) 

Four columns must be completed in this section, requiring technical staff to perform the 

following steps: 

• Column A: Record "NA" in Part II, Section 8.3, Column A of the Form R if the facility is 

a first time filer. For subsequent reporting years, locate the release estimate from the 

"Column B, Current Reporting Year" column from the previous year’s form and record 

this quantity in Part II, Section 8.3, Column A of the Form R. (0.25 min/0.25 min) 

• Column B: To estimate the quantity of the chemical used annually for energy recovery 

off-site, subtract Section 8.8 (off-site energy recovery due to catastrophic events) from 

Section 6.2 (quantities associated with energy recovery) and report the value in Part II, 

Section 8.3, Column B of the Form R. (5.00 min/5.00 min) 

• Column C: Make the best projection for the following year's release quantity and record 

it in Part II, Section 8.3, Column C of the Form R. If no source reduction activities are 

planned, multiply the current year release estimate by the expected percentage change in 

production for the following year. If source reduction activities are planned, make the 

best estimate for how much this will reduce the release quantity for the following year. 

(1.00 min/1.00 min) 

• Column D: Make the best projection for the second following year's release quantity and 

record it in Part II, Section 8.3, Column D of the Form R. If no source reduction 

activities are planned, multiply the current year release estimate by the expected 

percentage change in production for the second following year. If source reduction 

activities are planned, make the best estimate of how much this will reduce the release 

quantity for the second following year. (1.00 min/1.00 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 8.3

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.5 0.50 

Technical 7.25 7.25 

Total 7.75 7.75 

Section 8.4: Quantity Recycled On-Site

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (1.25 min/1.08 min) 

Four columns must be completed in this section, requiring technical staff to perform the 

following steps: 

• Column A: Record "NA" in Part II, Section 8.4, Column A of the Form R if the facility 

is a first time filer. For subsequent reporting years, locate the release estimate from the 

"Column B, Current Reporting Year" column from the previous year’s form and record 

this quantity in Part II, Section 8.4, Column A of the Form R. (0.25 min/0.25 min) 

• Column B: Estimate the quantity of the chemical actually recycled on-site annually by 

reviewing the information identified for Section 7C and either review operations records 

or speak with operations staff. Report the total quantity recycled on-site in Part II, 

Section 8.4, Column B of the Form R. (30.00 min/30.00 min) 

• Column C: Make the best projection for the following year's release quantity and record 

it in Part II, Section 8.4, Column C of the Form R. If no source reduction activities are 

planned, multiply the current year release estimate by the expected percentage change in 

production for the following year. If source reduction activities are planned, make the 

best estimate for how much this will reduce the release quantity for the following year. 

(1.00 min/1.00 min) 

• Column D: Make the best projection for the second following year's release quantity and 

record it in Part II, Section 8.4, Column D of the Form R. If no source reduction 

activities are planned, multiply the current year release estimate by the expected 

percentage change in production for the second following year. If source reduction 

activities are planned, make the best estimate of how much this will reduce the release 

quantity for the second following year. (1.00 min/1.00 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 8.4

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 1.25 1.08 

Technical 32.25 32.25 

Total 33.50 33.33 

Section 8.5: Quantity Recycled Off-Site

Management burden includes an assessment of whether quantities previously calculated for 

Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as 

proofreading this section as part of an overall review of the Form R. (0.50 min/0.50 min) 

Four columns must be completed in this section, requiring technical staff to perform the 

following steps: 

• Column A: Record "NA" in Part II, Section 8.5, Column A of the Form R if the facility 

is a first time filer. For subsequent reporting years, locate the release estimate from the 

"Column B, Current Reporting Year" column from the previous year’s form and record 

this quantity in Part II, Section 8.5, Column A of the Form R. (0.25 min/0.25 min) 

• Column B: To estimate the quantity of the chemical recycled annually off-site, subtract 

Section 8.8 (off-site recycling due to catastrophic events) from Section 6.2 (quantities 

associated with recycling) and report the value in Part II, Section 8.5, Column B of the 

Form R. (5.00 min/5.00 min) 

• Column C: Make the best projection for the following year's release quantity and record 

it in Part II, Section 8.5, Column C of the Form R. If no source reduction activities are 

planned, multiply the current year release estimate by the expected percentage change in 

production for the following year. If source reduction activities are planned, make the 

best estimate for how much this will reduce the release quantity for the following year. 

(1.00 min/1.00 min) 

• Column D: Make the best projection for the second following year's release quantity and 

record it in Part II, Section 8.5, Column D of the Form R. If no source reduction 

activities are planned, multiply the current year release estimate by the expected 

percentage change in production for the second following year. If source reduction 

activities are planned, make the best estimate of how much this will reduce the release 

quantity for the second following year. (1.00 min/1.00 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 8.5

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.5 0.50 

Technical 7.25 7.25 

Total 7.75 7.75 

Section 8.6: Quantity Treated On-Site

Management burden includes review of data, methods, and assumptions used to develop the 

estimate. In some cases it also includes data quality activities such as comparing the values with 

previous years. (1.25 min/1.08 min) 

Four columns must be completed in this section, requiring technical staff to perform the 

following steps: 

• Column A: Record "NA" in Part II, Section 8.6, Column A of the Form R if the facility 

is a first time filer. For subsequent reporting years, locate the release estimate from the 

"Column B, Current Reporting Year" column from the previous year’s form and record 

this quantity in Part II, Section 8.6, Column A of the Form R. (0.25 min/0.25 min) 

• Column B: Estimate the quantity of the chemical actually treated on-site annually by 

reviewing the information identified for Section 7A and either review operations records 

or speak with operations staff. The total quantity treated on-site is reported in Part II, 

Section 8.6, Column B of the Form R. (30.00 min/30.00 min) 

• Column C: Make the best projection for the following year's release quantity and record 

it in Part II, Section 8.6, Column C of the Form R. If no source reduction activities are 

planned, multiply the current year release estimate by the expected percentage change in 

production for the following year. If source reduction activities are planned, make the 

best estimate for how much this will reduce the release quantity for the following year. 

(1.00 min/1.00 min) 

• Column D: Make the best projection for the second following year's release quantity and 

record it in Part II, Section 8.6, Column D of the Form R. If no source reduction 

activities are planned, multiply the current year release estimate by the expected 

percentage change in production for the second following year. If source reduction 

activities are planned, make the best estimate of how much this will reduce the release 

quantity for the second following year. (1.00 min/1.00 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 8.6

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 1.25 1.08 

Technical 32.25 32.25 

Total 33.50 33.33 

Section 8.7: Quantity Treated Off-Site

Management burden includes an assessment of whether quantities previously calculated for 

Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as 

proofreading this section as part of an overall review of the Form R. (0.50 min/0.50 min) 

Four columns must be completed in this section, requiring technical staff to perform the 

following steps: 

• Column A: Record "NA" in Part II, Section 8.7, Column A of the Form R if the facility is 

a first time filer. For subsequent reporting years, locate the release estimate from the 

"Column B, Current Reporting Year" column from the previous year’s form and record 

this quantity in Part II, Section 8.7, Column A of the Form R. (0.25 min/0.25 min) 

• Column B: To estimate the quantity of the chemical treated off-site, sum together the 

quantities from Section 6.1 (excluding most metal/metal category compounds) and 

Section 6.2 (the quantities associated with treatment) and then subtract any portion of 

Section 8.8 associated with off-site treatment due to catastrophic events. Report the total 

quantity treated off-site in Part II, Section 8.7, Column B of the Form R. (5.00 min/5.00 

min) 

• Column C: Make the best projection for the following year's release quantity and record 

it in Part II, Section 8.7, Column C of the Form R. If no source reduction activities are 

planned, multiply the current year release estimate by the expected percentage change in 

production for the following year. If source reduction activities are planned, make the 

best estimate for how much this will reduce the release quantity for the following year. 

(1.00 min/1.00 min) 

• Column D: Make the best projection for the second following year's release quantity and 

record it in Part II, Section 8.7, Column D of the Form R. If no source reduction 

activities are planned, multiply the current year release estimate by the expected 

percentage change in production for the second following year. If source reduction 

activities are planned, make the best estimate of how much this will reduce the release 

quantity for the second following year. (1.00 min/1.00 min) 
Appendix G

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Reporting Burden Associated with Part II, Section 8.7

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.50 0.50 

Technical 7.25 7.25 

Total 7.75 7.75 

Section 8.8: Quantity released to the Environment as a Result of Remedial Actions, 

Catastrophic Events, or One-Time Events not Associated with Production Processes

Management burden includes an assessment of whether quantities previously calculated for 

Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as 

proofreading this section as part of an overall review of the Form R. (0.25 min/0.25 min) 

Technical staff sum together the relevant quantities already estimated and record them in Part II, 

Section 8.8, Column B of the Form R. (5.00 min/5.00 min) 

Reporting Burden Associated with Part II, Section 8.8

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.25 0.25 

Technical 5.00 5.00 

Total 5.25 5.25 

Section 8.9: Production Ratio or Activity Index

Management burden includes review of data, methods, and assumptions used to develop the 

production ratio; and in some cases, data quality activities such as comparing the values with 

previous years. (0.83 min/0.83 min) 

Technical staff would perform the following steps to calculate the production ratio or activity 

index: 

• Determine the annual production or activity level for the reporting year by either 

reviewing production records or maintenance logs, or talking with the operations staff. 

(30.00 min/30.00 min) 

• Determine the annual production or activity level for the previous year by reviewing 

maintenance records or talking with operations staff. (5.00 min/5.00 min) 

• Divide the current year’s production or activity level by the prior year’s production or 

activity level. Alternatively, review the waste minimization section of the RCRA report. 
Appendix G

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G-50

Report the production ratio or activity index in Part II, Section 8.9 of the Form R. (1.00 

min/1.00 min) 

For facilities reporting for the first year, a production ratio is required if the facility 

manufactured, processed or otherwise used the TRI chemical in the previous year, even if no 

thresholds were exceeded. While some first year reports will be for completely new operations, 

others will be for facilities that have exceeded threshold for the first time. For this reason, it was 

assumed that calculation of the production ratio would be required for first year reports. 

Reporting Burden Associated with Part II, Section 8.9

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0.83 0.83 

Technical 36.00 36.00 

Total 36.83 36.83 

Section 8.10: Did Your Facility Engage in any Source Reduction Activities?

Management burden includes review of data and methods used to identify source reduction 

activities. (1.08 min/0.92 min) 

To identify whether or not any source reduction activities were implemented, technical staff 

either review SOPs; review any process, equipment, or material input changes; review the waste 

minimization section of the RCRA report; or talk with operations staff. If source reduction 

activities were implemented, technical staff locate the source reduction codes in the Reporting 

Forms and Instructions and enter the codes in Section 8.10.1 of the Form R. Technical staff 

enter the appropriate codes for Methods to Identify Activity in Section 8.10.1.a. (35.25 

min/35.25 min) 

Reporting Burden Associated with Part II, Section 8.10

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 1.08 0.92 

Technical 35.25 35.25 

Total 36.33 36.17 
Appendix G

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Section 8.11: Is Additional Information on Source Reduction, Recycling or Pollution 

Control Activities Included with this Report?

Provision of additional information on source reduction, recycling, or pollution control activities 

is optional; therefore, there is no management, technical, nor clerical burden associated with this 

element of the Form R. 

Reporting Burden Associated with Part II, Section 8.11

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Management 0 0.00 

Technical 0 0.00 

Total 0.00 0.00 

2.1.B. Results for Electronic Submission

Table 4 summarizes the total reporting burden associated with electronic submissions of PBT 

and non-PBT forms. Tables 5 and 6 (refer to Excel spreadsheet) present the realistic and 

incidence weighted reporting burden for every data element on the Form R for first year 

electronic submissions of PBT and non-PBT reports. Tables 7 and 8 (refer to Excel spreadsheet) 

present the realistic and incidence weighted reporting burden for every data element on the Form 

R for subsequent year electronic submissions of PBT and non-PBT reports. 

 

TABLE 4 

TOTAL REPORTING BURDEN FOR ELECTRONIC SUBMISSIONS 

Estimated realistic time per form (hr) Incidence weighted time per form (hr)

Management Technical Total Management Technical Total 

First year

PBT 0.99 29.51 30.50 0.34 9.20 9.54 

Non-PBT 0.98 29.38 30.36 0.37 10.49 10.86 

Subsequent years

PBT 0.77 20.98 21.75 0.29 6.17 6.46 

Non-PBT 0.77 20.97 21.74 0.32 6.89 7.21 

 

2.1.C. Methodology for Paper Submission

The only difference between electronic and paper submissions for first year and subsequent year 

Form R reporting burden is clerical time. To generate a paper copy, clerical staff would take the 

information prepared by the technical staff and type it onto a paper copy of the Form R. 

Therefore, for both PBT and non-PBT chemicals, clerical times were estimated by dividing the 
Appendix G

 4/28/11 

G-52

currently approved OMB clerical times (Table 1) by the total number of fields on the Form R. 

While it may not take the exact same amount of time to line up each data element for typing, 

there is no reasonable way to estimate this, so giving equal time to each element was determined 

to be the best method. The clerical time allotted to each element was then added to the estimate 

for the electronic form (including management and technical time) for that element to generate 

time estimates for every data element for PBT and non-PBT first and subsequent year reporting 

via a paper Form R. 

2.1.D. Results for Paper Submission

Table 9 summarizes the total reporting burden for paper submission of PBT and non-PBT forms. 

Tables 10 and 11 (refer to Excel spreadsheet) present the realistic and incidence weighted 

reporting burden for every data element on the Form R for first year paper submissions of PBT 

and non-PBT reports. Tables 12 and 13 (refer to Excel spreadsheet) present the realistic and 

incidence weighted reporting burden for every data element on the Form R for subsequent year 

paper submissions of PBT and non-PBT reports. 

TABLE 9 

TOTAL REPORTING BURDEN FOR PAPER SUBMISSIONS 

Estimated realistic time per form (hr) Incidence weighted time per form (hr)

Management Technical Clerical Total Management Technical Clerical Total

First year

PBT 1.01 29.51 2.90 33.42 0.35 9.20 1.59 11.14

NonPBT 0.99 29.38 1.62 31.99 0.38 10.49 0.93 11.80

Subsequent years

PBT 0.78 21.17 2.00 23.95 0.30 6.33 1.10 7.73 

NonPBT 0.78 21.17 1.10 23.05 0.33 7.05 0.63 8.01 

 

3. SCALED REPORTING BURDEN ESTIMATES

 

3.1 Scaled Estimate for PBT Chemicals 

In this section, the realistic technical reporting burden estimates developed for PBT chemicals 

are used in combination with the currently-approved OMB form completion reporting burden 

estimates to generate burden estimates for each data element consistent with the OMB total. 

Four individual reporting burden scenarios are scaled up: first year electronic, subsequent year 

electronic, first year paper, and subsequent year paper. The incidence weighted values are not 
Appendix G

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G-53

used for PBT chemicals because the OMB burden estimate assumes all Form R fields are filled 

out by all reporters. 

3.1.A. Methodology for Scaled PBT Chemical Electronic Submissions

The OMB-approved form completion burden estimates for PBT first and subsequent year 

technical burden are 45.2 and 30.8 hours, respectively. The following procedure was used to 

scale the realistic electronic PBT data element burden estimates to these OMB-approved burden 

estimates. Reporting burden is estimated for both first and subsequent years. 

• Technical reporting burden for data elements requiring only typing or typing plus a quick 

information look-up (such as locating the facility’s D&B number) was estimated (86.25 

min, 13.42 min). The times for these steps were assumed static and, therefore, were not 

scaled up. 

• Total static time was subtracted from both the OMB approved technical burden (2712.0 

min, 1848.0 min) and the total realistic technical burden (1770.32 min, 1258.51 min) to 

estimate the total OMB (2625.75 min, 1834.58 min) and realistic (1684.07 min, 1245.09 

min) times for those Form R data elements that require more complex information 

gathering and calculations. 

• The OMB approved technical burden for nonstatic data elements was divided by the PBT 

realistic burden for nonstatic data elements (i.e., 2625.75/1770.32; 1834.58/1258.71) to 

calculate a scaling factor (1.56, 1.47). (Note that the PBT realistic estimates used here 

were not incidence-weighted, as the OMB assumption for the current estimate for PBT 

chemicals is that all data elements are completed). 

• The scaling factor was applied to all of the nonstatic realistic data element burden 

estimates. 

• Realistic management burden estimates were generated by multiplying the scaled up 

realistic technical burdens by the 20.9/45.2 or 14.3/30.8 hr ratio of management to 

technical burden in the current OMB-approved burden estimate for first and subsequent 

year reporting for PBT chemicals, respectively. 

• Scaled up management and technical times were added together for each data element to 

estimate a total time for that data element. 
Appendix G

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G-54

3.1.B. Results for PBT Chemical Electronic Submissions 

Table 14 (refer to Excel spreadsheet) presents scaled management and technical burden estimates 

for completing each data element of the Form R for first and subsequent year electronic 

submissions of PBT reports. 

3.1.C. Methodology for PBT Chemical Paper Submissions

The only difference between electronic and paper submission for Form R reporting burden is the 

clerical time needed for typing. To generate a paper copy, clerical staff would take the 

information prepared by the technical staff and type it onto a paper copy of the Form R. The 

time required to type information into one data element on the Form R was considered to be 

static and unrelated to the relative degree of difficulty in determining the information to be 

entered into the field. For this reason, clerical time was not determined by scaling from the 

realistic estimates generated for technical time. Instead, clerical times were estimated by 

dividing the currently approved OMB clerical burden (Table 1) for PBT chemical submission by 

the total number of data elements on the Form R. 

While it may not take the exact same amount of time to line up each data element for typing, 

there is no reasonable way to estimate this, so giving equal time to each element was determined 

to be the best method. The clerical time allotted to each element was then added to the estimate 

for the electronic form (including management and technical time) for that element to generate 

scaled time estimates for every data element for PBT first and subsequent year reporting via a 

paper Form R. 

3.1.D. Results for PBT Chemical Paper Submission

Table 15 (refer to Excel spreadsheet) presents scaled management, technical, and clerical burden 

estimates for completing each data element of the Form R for first and subsequent year 

submissions of paper PBT chemical reports. 

3.2 Scaled Estimate for non-PBT Chemicals 

In this section, the realistic technical reporting burden estimates developed for non-PBT 

chemicals are used in combination with the currently-approved OMB form completion reporting 

burden estimates to generate burden estimates for each data element consistent with the OMB 

total. Four individual reporting burden scenarios are scaled up: first year electronic, subsequent 

year electronic, first year paper, and subsequent year paper. The incidence weighted values are 

used for non-PBT chemicals because the OMB burden estimates for non-PBT chemicals are 

based on actual reporting burden data from facilities. 
Appendix G

 4/28/11 

G-55

nt years. 

 

3.2.A. Methodology for non-PBT Chemical Electronic Submissions

 The OMB-approved form completion burden estimate for non-PBT subsequent year technical 

burden is 16.4 hours. A first-year estimate for non-PBT technical burden of 24.1 hours was 

estimated by multiplying the subsequent year estimate by 147 percent.1

 The following 

procedure was used to scale the realistic electronic non-PBT burden estimates to these OMBapproved burden estimates. Reporting burden is estimated for both first and subseque

• Technical reporting burden for data elements requiring only typing or typing plus a quick 

information look-up (such as locating the facility’s D&B number) was estimated (59.0 

min, 6.4min). The times for these steps were assumed static and, therefore, were not 

scaled up. 

• Total static time was subtracted from both the OMB approved technical burden (1446.48 

min, 984.0 min) and the total incidence-weighted realistic technical burden (629.49 min, 

413.18 min) to estimate the total OMB (1387.48 min, 977.60 min) and realistic (570.49 

min, 406.79 min) times for those Form R data elements that require more complex 

information gathering and calculations. 

• The OMB approved technical burden for nonstatic data elements was divided by the nonPBT realistic burden for nonstatic data elements (i.e., 1387.48/570.49; 977.60/406.79) to 

calculate a scaling factor (2.43, 2.40). 

• The scaling factor was applied to all of the nonstatic realistic data element burden 

estimates. 

• Realistic management burdens were generated by multiplying the scaled up realistic 

technical burdens by the 11.3/24.1 or 7.7/16.4 hr ratio of management to technical burden 

in the current OMB-approved burden estimate for first and subsequent non-PBT 

chemicals, respectively. 

• Scaled up management and technical times were added together for each data element to 

estimate a total time for that data element. 

1

An OMB-approved estimate for first time non-PBT filers does not exist; however, the RIA for 

the original Section 313 rulemaking estimated the time required to complete a report in the first year to be 

147% of the time required in subsequent years. This factor was applied to the OMB approved subsequent 

year non-PBT report completion times to calculate the first year non-PBT completion times. (U.S. EPA 

Regulatory Impact Analysis in Support of Final Rulemaking under Section 313 of Title III of the 

Superfund Amendments and Reauthorization Act of 1986 (1988). 
Appendix G

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G-56

3.2.B. Results for non-PBT Chemical Electronic Submissions 

Table 16 (refer to Excel spreadsheet) presents scaled management and technical burden estimates 

for completing each field of the Form R for first and subsequent year electronic submissions of 

non-PBT reports. 

3.2.C. Methodology for non-PBT Chemical Paper Submissions 

The only difference between electronic and paper submission for Form R reporting burden is the 

clerical time needed for typing. To generate a paper copy, clerical staff would take the 

information prepared by the technical staff and type it onto a paper copy of the Form R. The 

time required to type information into one data element on the Form R was considered to be 

static and unrelated to the relative degree of difficulty in determining the information to be 

entered into the field. For this reason, clerical time was not determined by scaling from the 

realistic estimates generated for technical time. Instead, clerical times were estimated by 

dividing the currently approved OMB clerical burden (Table 1) for non-PBT chemicals by the 

total number of fields on the Form R. 

While it may not take the exact same amount of time to line up each data element for typing, 

there is no reasonable way to estimate this, so giving equal time to each element was determined 

to be the best method. The clerical time allotted to each element was then added to the estimate 

for the electronic form (including management and technical time) for that element to generate 

time estimates for every data element for non-PBT first and subsequent year reporting via a 

paper Form R. 

3.2.D. Results for non-PBT Chemical Paper Submissions

Table 17 (refer to Excel spreadsheet) presents realistic management, technical, and clerical 

burden estimates for completing each data element of the Form R for first and subsequent year 

paper submissions of non-PBT reports. 
Appendix G

 4/28/11 

G-57

 

 

 

memorandum 

To: Laura Nielsen, U.S. EPA 

 

From: Susan Day 

Date: December 2, 2010 

 

Subject: Modified TRI Reporting Burden Estimates for Rule Familiarization and 

Compliance Determination 

________________________________________________________________________ 

1. INTRODUCTION 

EPA currently relies on previously developed OMB approved TRI reporting burden estimates 

that reflect the total time required by facilities to complete activities such as rule familiarization, 

compliance determination, form completion, record keeping/mailing, and supplier notification. 

In an earlier analysis (2004), Abt Associates Inc. developed new burden estimates for form 

completion, broken down by the individual data elements that make up the Form R.1 In that 

assessment, a list of activities a facility typically conducts to complete each data element was 

developed. Next, best professional judgment was used to estimate the time needed to complete 

each activity. Finally, these times were summed together. The total form completion time 

developed through that assessment was referred to as the “realistic burden.” This memo 

summarizes the application of the same methodology to rule familiarization and compliance 

determination in an analysis completed in 2005. “Realistic burden” estimates for each are 

presented below. 

In order to develop standardized estimates that are meaningful across the range of facility types, 

sizes, and sectors reporting to TRI, the realistic burden is set to reflect activities at a typical TRIreporting facility. Assumptions about the typical facility are outlined below. 

1

 TRI Reporting Burden Estimates, Memo from Hilary Eustace, David Cooper, Susan Day, Abt Associates to Paul 

Borst, EPA, July 16, 2004. Docket # EPA-HQ-TRI-2005-0073-0012. 
Appendix G

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G-58

The typical facility: 

• is mid-sized (somewhere between a small, single activity shop and a very large, very 

complex operation). 

• is representative of all sectors covered under TRI. 

• is reasonably modern and well-organized. 

• has internet access with reasonable connection speed. 

• has technical staff with sufficient expertise to readily understand the chemical and industrial 

concepts necessary for TRI program comprehension. 

• will not be right at threshold for employees or chemicals, but will be well above or well 

below threshold. Therefore, once these determinations are made, they will not need to be reassessed every year. 

• conducts quantitative threshold assessments for 6 chemicals, and files TRI reports for 3 of 

these. Each chemical is typically involved in only one threshold activity. 

2. COMPLIANCE DETERMINATION 

2.1 Realistic Burden – First Year 

To make a compliance determination the typical facility will need to conduct facility level 

activities such as NAICS code and employee assessment and a chemical list determination. In 

addition, chemical-specific threshold quantity determinations must be made. The activities a 

typical facility would conduct in making their compliance determination and associated burden 

estimates are presented in this section. 

2.1.1 Facility Level Activities 

NAICS Code Assessment 

To conduct the NAICS code assessment, (i.e., is the facility in an EPCRA section 313-covered 

NAICS code?) technical staff will call accounting or other corporate department for this 

information (10.00 min/0.17 hour). 

Employee Threshold Assessment

To conduct the employee threshold assessment, (i.e., does the facility exceed the EPCRA section 

313 20,000 hour employee threshold?) technical staff will determine the whole set of full- and 

part-time employees, temps, contractors (excepting drivers and janitorial contractors), and offsite corporate support by checking with payroll and other management, supervisory, or 

accounting staff as necessary (30.00 min/0.5 hour). 

Next, technical staff will calculate the total hours worked by this group during the full calendar 

year or up until a clear determination is made that the facility is above or below the 20,000 hour 

threshold by summing together quantities on timesheets or accounting system totals (30.00 min/ 

0.5 hour). 
Appendix G

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G-59

Chemical List Determination

To determine which TRI chemicals are present, technical staff will: 

• Compare all materials (including mixtures, alloys, and fuels) used/manufactured at the 

facility to the EPCRA section 313 (TRI) list. This task will involve: 

o Gathering all MSDSs, or other batch info, product specs, certificates of analysis, 

labeling information, etc (60.00 mins/1.0 hour). 

o Reviewing the “Regulatory Information” section of the MSDS. Where an MSDS 

is not available, technical staff will compare available supplier data on chemical 

constituents with the TRI chemical list (90.00 min/1.5 hours). 

o For PBT chemicals, technical staff will assess if there are likely PBT chemicals 

present at below de minimis in mixtures used by the facility. This step is needed 

since the de minimis exemption is allowed for supplier notification, but is not 

allowed for PBT chemicals for threshold determination or release reporting (60.00 

min/1.0 hour). 

Table 1: Facility-Level Compliance Determination Burden 

NAICS Code Assessment 0.17 technical hours 

Employee Threshold Assessment 1.0 technical hours 

Chemical List Determination 3.5 technical hours 

Total 4.67 technical hours 

2.1.2 Chemical-Specific Activities 

As mentioned above, the typical facility will conduct quantitative threshold assessments for six 

chemicals. For each TRI chemical, technical staff will review all manufacture/uses of the 

chemical at the facility to determine if they fall under the definition of manufacture, process, or 

otherwise use. This task will involve talking with operations staff, facility chemists, reviewing 

process flow diagrams, conducting facility walkthrough and reviewing standard operating 

procedures (30.00 min/0.5 hours). 

For each TRI chemical manufactured, processed, or otherwise used, technical staff will 

determine the total annual quantity of the chemical for each threshold activity. This activity will 

include determining the percentage of the TRI chemical in a mixture, alloy, or fuel. The method 

to calculate threshold quantity for process OR otherwise use is: 

• Determine the material usage quantity within each applicable threshold activity through a 

review of inventory records, purchase records, operation records, or discussions with 

operations staff (30.00 mins/0.5 hours). This task may require a determination of the total 

material usage quantity through inventory or purchase records, followed by dividing this total 

into the different threshold activities through operations records or discussions with 

operations staff. For the purposes of this analysis, however, it is assumed that each chemical 

typically falls within only one threshold activity. 

• If the material used is a mixture, determine the chemical concentration in the mixture through 
Appendix G

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G-60

a review of the MSDS, batch analysis, or other supplier information (30.00 min/0.5 hours). 

• Multiply total material usage quantity by chemical concentration to determine total annual 

chemical usage quantity (2.00 min/0.03 hours). 

The total time required to calculate a threshold quantity for process or otherwise use is 62.00 

min/1.0 hour. 

For intentional manufacture, technical staff will determine the annual quantity manufactured 

through production records (30.00 min/0.5 hours). 

The method used to calculate the threshold quantity for coincidental manufacture is to determine 

the annual quantity for combustion products and reaction by-products or impurities as follows: 

• Combustion products: Technical staff will determine the annual quantity manufactured 

through use of emission factors by: 

o Locating the most applicable emission factor. Numerous EPA sources are 

available such as AP-42 TRI chemical specific and industry specific guidance. 

Non-EPA sources include university research and trade associations (30.00 

min/0.5 hours). 

o Determining the annual quantity of input material by reviewing purchase records, 

inventory records, and/or operational records (30.00 min/0.5 hours). 

o Multiplying this material usage quantity by the emission factor to determine the 

amount of material released from each point during the year and, if necessary, 

converting the amount of material released to pounds (or grams for dioxins) by 

applying the appropriate conversion factor (6.00 min/0.1 hours). 

o Finding the average pollution control efficiency for the emission factor from the 

AP-42 listing or emission factor source, or identifying if the emission factor was 

generated from uncontrolled sources. Using this pollution control efficiency, 

technical staff will extrapolate the total quantity generated from the quantity 

emitted (10.00 min/0.17 hours). 

o The total time required to calculate a threshold quantity in coincidental 

manufacture is 76.00 min/1.27 hours. 

• Reaction by-products or impurities: Technical staff will identify the quantity of chemical 

coincidentally manufactured through discussions with facility chemists, production records, 

operations staff, chemistry literature, or EPA TRI guidance documents (45.00 min/0.75 

hours). 

 

Once annual threshold quantities have been calculated, technical staff will compare the annual 

threshold quantities for each chemical with the TRI regulatory threshold limits by entering the 

threshold quantity in TRI-MEweb for each chemical. TRI-MEweb will indicate for which 

chemicals TRI regulatory thresholds have been exceeded (0.25 min/0.0 hours). 
Appendix G

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G-61

Average Realistic Chemical-Specific Threshold Assessment

It is assumed in this analysis that a chemical is typically only involved in one threshold activity 

at a facility. However, this activity may be a processing, an otherwise use, or a manufacturing 

activity. As outlined above, the total time to calculate the threshold quantity for a chemical 

involved in a processing activity or an otherwise use is 62.00 minutes or 1.0 hour. There are 

three different scenarios for calculating the threshold quantity for a chemical involved in a 

manufacturing activity depending on whether the chemical is intentionally manufactured, a 

product of combustion, or a reaction by-product or impurity (0.5 hours, 1.27 hours, or 0.75 

hours, respectively). The average burden of these three methods is 0.8 hours. Since estimates 

for intentional manufacture and coincidental manufacture of combustion products or reaction byproducts and impurities may not occur with equal frequency, this average has been rounded up to 

1.0 hour. In addition, manufacturing, processing, or otherwise use activities may not occur at the 

same frequency. Therefore, a more accurate estimate is made if estimates for all three activities 

are rounded up to the most burdensome. The resulting burden estimates are summarized in 

Table 2. 

Table 2: Average Chemical-Specific Threshold Assessment Burden

Otherwise Use chemical specific threshold quantitative assessment 1.0 technical hour 

Processing chemical specific threshold quantitative assessment 1.0 technical hour 

Manufacturing chemical specific threshold quantitative assessment 1.0 technical hour 

Average burden for quantitative assessment of different threshold 

activities 1.0 technical hour 

Total Realistic Chemical-Specific Threshold Assessment Burden

To make a compliance determination, a facility must 1) determine the appropriate threshold 

activity for each chemical; 2) determine the quantity of chemical used in the threshold activity, 

and 3) compare the quantity of chemical being used in a threshold activity to TRI regulatory 

reporting thresholds. As outlined above, it will take a facility 30.0 minutes or 0.5 hours to 

determine in which threshold activity the chemical is used. On average, 1.0 hour will be 

required to determine the quantity of chemical being used in a threshold activity. Finally, it will 

take a facility 0.25 minutes or 0.0 hours to enter this quantity into TRI-MEweb for comparison 

with TRI regulatory reporting thresholds. A summation of burden estimates associated with 

these three activities is presented in Table 3. 

Table 3: Total Realistic Chemical-Specific Threshold Assessment Burden

Determine which threshold activity is occurring 0.5 technical hours 

Average quantitative assessment burden 1.0 technical hour 

Enter threshold quantity in TRI-MEweb 0.0 technical hours 

Total Per Chemical Burden 1.5 technical hours 
Appendix G

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G-62

2.1.3 Total Realistic First Year Compliance Determination Burden

Total realistic first year compliance determination burden is estimated by summing the facility 

level compliance determination burdens and the chemical-specific compliance determination 

burden across the six chemicals for which a typical facility will need to conduct threshold 

assessments. The estimated total realistic first year compliance determination burden is 

presented in Table 4. 

Table 4: Total Realistic First-Year Compliance Determination Burden

Facility level burden 4.67 technical hours 

6 chemicals x 1.5 hour / chemical 9.0 technical hours 

Total 13.67 technical hours 

2.2 Realistic Burden – Subsequent Year 

In subsequent years it is assumed that NAICS code and employee threshold determinations will 

typically not need to be reassessed, thus no burden will be incurred. It is also assumed that no 

new activities are required relative to quantitative threshold assessments. Some time is, however, 

required to review facility activities and ensure that no significant changes have occurred. 

2.2.1 Facility Level Activities 

At the facility level, technical staff will assess facility activities and products/mixtures used to 

determine if there are significant process and/or chemical use changes at the facility requiring 

modified or new quantitative threshold assessments. As part of this assessment, they will talk to 

production staff, review operations records, and review MSDSs (60.00 min/1.0 hour). 

Subsequent year burden estimates for compliance determination activities are summarized in 

Table 5. 

Table 5: Total Realistic Subsequent Year Compliance Determination 

Burden With No Staff or Process Changes

NAICS Assessment 0.0 technical hours 

Employee Threshold 0.0 technical hours 

Facility level review of operations to determine that there 

were no significant chemical use and/or process changes 1.0 technical hour 

Total 1.0 technical hour 
Appendix G

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G-63

2.3 Summary of Compliance Determination Burden Estimates

Table 6 summarizes the realistic burden estimates developed in this analysis. Realistic 

management burden estimates are based on best professional judgment of what is actually 

occurring at a typical TRI-reporting facility. No clerical burden is provided as it is assumed that 

a typical facility will be using TRI-MEweb, and that technical staff will conduct the data entry 

into TRI-MEweb as part of their efforts. 

Table 6: Compliance Determination Unit Burden Hour Estimates

Management Technical Clerical Total Hours

Realistic Estimate – 1st year 1 13.67 0 14.67 

Realistic Estimate – subs year 0.25 1 0 1.25 

Current OMB Estimate – 1st year 4 12 0 16 

Current OMB Estimate – subs year 1 3 0 4 

3. RULE FAMILIARIZATION

3.1 Realistic Burden Estimate - First Year

To familiarize themselves with the TRI reporting requirements, the typical facility will need to 

review TRI program content both generally and as applicable to their facility by: 

• Reading the Reporting Forms and Instructions booklet (600 min/10 hours). 

• Reviewing all or selected portions of relevant EPA TRI guidance documents including: 

o Q & A document (120 min/2 hours) 

o Industry-specific guidance (if it exists) or most closely applicable (90 min /1.5 

hour) 

o Electricity Generating Facilities Guidance (for fuels use) (30 min/0.5 hours) 

o Chemical Specific Guidance(s) (120min/2 hours) 

• Attending a training session (360 min/6-hour live session or both halves of a web-based 

training). 

• Contacting the EPCRA hotline or other information resource for clarifications/facilityspecific determinations (30 min/0.5 hours). 

Summing across these activities, the total realistic first year rule familiarization burden is 

estimated at 1,350 min/22.5 hours. 

3.2 Realistic Burden - Subsequent Year

It is assumed that no rule familiarization will occur in subsequent years. Even with a process 

change, technical staff will use existing knowledge of the TRI program to determine how TRI 
Appendix G

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G-64

applies to this process change. Table 7 summarizes rule familiarization burden estimates for the 

first and subsequent years. 

Table 7: Rule Familiarization Unit Burden Hour Estimates

Management Technical Clerical Total Hours

Realistic Estimate – 1st year 1 22.5 0 23.5 

Realistic Estimate – subs year 0 0 0 0 

Current OMB Estimate – 1st year 12 22.5 0 34.5 

Current OMB Estimate – subs year 0 0 0 0 
Appendix H 

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 H -1

Peer Review Summary Statement with EPA Responses 

This technical document underwent peer review to assess the integrity and value of the revised 

methodology, Ratio-Based Burden Methodology (RBBM). The reviewers represented academia, 

industry, and non-profit sectors with expertise in industrial engineering, social science/public 

policy, and mathematical methodology (see Table H-1 below). Overall the reviewers were 

positive, concluding that the methodology changes: 

• Are reasonable, appropriate, and well-supported 

• Achieve efficiency, administrative constancy, and transparency 

Table H-1: Peer Reviewers Represent a Range of Disciplines and Perspectives 

Reviewer Name Organization Sector Representing 

Jeffrey Burke, BA Executive Director, National 

Pollution Prevention 

Roundtable (in addition to 

twenty-plus years experience 

as Senior Environmental 

Scientist with US EPA Region 

3) 

Non-profit/Government 

Mark Cohen, PhD Economics Vice President for Research, 

Resources for the Future

Social Science/Public Policy 

Mark Stephan, PhD, Politics, 

Associate Professor 

Associate Professor, 

Washington State University

Social Science/Public Policy, 

Mathematical Methodology 

Michael Walls, MBA, JD VP, Regulatory and Technical 

Affairs, American Chemistry 

Council

Social Science/Public Policy 

Joelie Zak, BS, BA Executive VP of Scientific 

Control Laboratories

Engineering/Science 

Reviewers were asked for overall impressions and assessments of 1) goal attainment, 2) validity 

and consistent application of methodology decision rules/assumptions, and 3) model 

maintenance requirements. Beyond these assessments, EPA requested comments on the merits 

and methods of survey calibration. 

On goal attainment, reviewers generally agreed that the stated goals of simplification, improved 

internal consistency, and improved transparency are met (with only one disagreeing about 

transparency). Additional perceived benefits included: 1) increased access to burden estimates 

and 2) better understanding of uncertainties associated with TRI burden estimates. 

Regarding decision rules and assumptions, reviewers consistently agreed with the internal logic 

and conclusions of the Ratio-Based Burden Methodology. However, two noteworthy exceptions 

in which one or more reviewers raised concerns: 1) setting the value of for PBT/non-PBT burden 

equal to one, and 2) holding non-Form burden constant. 
Appendix H 

 4/28/11 

 H -2

In response to EPA’s solicitation for input on survey calibration as a future enhancement, three 

out of five reviewers recommended this type of enhancement (including one non-industry 

reviewer). More information is provided in EPA’s response below. 

Based on the peer review endorsement, EPA concluded that the methodology is sound without 

need of design changes or major procedural adjustments. Regarding document quality, the body 

of the report is considered well-written with Appendices receiving mixed reviews (although 

considered very thorough). EPA has revised the document, addressing specific 

questions/critiques of the methodology and implementing editorial suggestions from peer 

reviewers and other sources. 

SELECTED REVIEWER COMMENTS AND EPA RESPONSES

While reviewer comments were generally positive, EPA believes that responses and additional 

explanations on several issues are justified to ensure that EPA’s position is clear and to avoid 

potential misunderstandings. 

1. Accuracy Questions Remain on Burden Hours

Review Comments: Although it is beneficial to simplify calculations, there is still a need to 

validate the burden estimates to be sure they are representative of reporter experiences. For 

example, one reviewer stated, “The measure of the new methodology’s estimate should not be a 

simple comparison to the estimates generated under the prior methodology—the new 

methodology should return significant improvements in the (absolute) estimation of TRI 

burden.” 

EPA Response: EPA acknowledges that some reviewers (here and in public comment venues) 

question the credibility of the system of factors used to characterize reporting activities, as well 

as values assigned to those factors. EPA believes these bases, as implemented in both the 

existing and revised methodologies, comply with PRA requirements that burden estimates be 

provided, “to the extent practicable.” TRI burden estimates reflect a reasonable sense of the 

average conditions and an appropriate level of specificity. Further, EPA emphasizes that the 

purpose of TRI burden estimates—and its burden accounting system in general—is to track 

changes from year to year against an established baseline. 

2. PBT Burden—Modeling versus Accounting

Review Comments: Some reviewers are concerned by the methodology’s simplification that 

sets PBT/non-PBT burden equal to one, due to lack of evidence to quantify an average value 

representative of the overall reporter population. One reviewer asserts, “ ...in real life reporting, 

there is currently extra burden placed on specific PBT chemical TRI filings that does not seem to 

be accounted for in the existing or new model.” Another states, “ACC does not agree with the 

conclusion that reporting for PBT and non-PBT substances are similar enough to allow the same 

unit-burden-hour estimate. PBT reporting as a whole takes more time than non PBTs, largely due 

to the de minimis exception not applicable to non-PBT substances.”
Appendix H 

 4/28/11 

 H -3

EPA Response: There are two parts to this response. First and foremost, EPA recognizes the 

need to distinguish between PBT and non-PBT burden by including a specific ratio model for 

that purpose. At this time, however, EPA is unable to specify the value of the ratio in the context 

of RBBM which requires verifiable and internally consistent unit burdens. Without 

substantiating evidence for this type of model assertion (see Decision Rules in main report) EPA 

has decided to implement a default ratio equal to one, while providing a placeholder for later 

revision in the event that additional information becomes available. Second, though the value of 

the ratio is left unspecified, this methodology revision carries forward certain prior assumptions 

so that the net effect of PBT reporting is incorporated in overall totals. Specifically, the previous 

calculation’s effects of a higher PBT unit burden for 20% of chemicals are rolled up into the new 

unit burden (Nominal Form R unit burden). In back-calculating this base number of 35.7 hours 

per Form R, the unit burden reflects overall average conditions, and is elevated above the value 

that would have been otherwise obtained—at about 30 hours/form—had only non-PBT burden 

been used to determine Nominal Form R unit burden. An important note on RBBM and its 

benefits: the simplified comprehensive Nominal Form R unit burden plus the A/R model (which 

links to Form A unit burden) provides a focal point for burden-estimate discussions, reducing 

confusion associated with keeping up with additional unit burdens and chemical counts from 

multiple subpopulations. 

3. Survey Calibration Enhancement 

Review Comments: Three out of five reviewers recommend enhancement via some form of 

survey calibration. Of these three, the two industry reviewers make their recommendations based 

on 1) concerns that the burden estimates are generally too low and 2) the need to measure a 

distinction between PBT and non-PBT reporting burden. The third supporter does not see the 

need, but admits that pressure from any party would merit survey calibration. One of the nonsupporters does not recommend survey calibration for this application, but stresses that EPA is 

not correctly focused on the purpose of survey calibration. This reviewer states that the purpose 

of survey calibrated burden estimates is to determine if data elements should be dropped or 

altered (i.e., consider cost of the information compared to its value). 

EPA Response: EPA appreciates the thoughtfulness and thoroughness of the reviewers’ 

comments on survey calibration. At this time, and as stated above, EPA believes the current 

bases comply with PRA requirements for reasonable estimates. In addition to increased Agency 

effort, EPA is concerned about imposing additional burden on the reporting community to 

participate in a survey designed for the purposes of calibrating burden estimates. 

4. DIOXIN (and Form R Schedule 1) Burden Not Included

Review Comment: The revised methodology does not address Dioxin reporting (implemented 

in 2007) and the burden contributions from Form R Schedule 1. 

EPA Response: At the time of the calculations for the revised methodology, conditions are 

those of the 2008 ICR. As such, the Form R Schedule 1 requirement was not in place. 

Subsequently, the addition of Form R Schedule 1 reporting is estimated in the Supporting 

Statement of the 2012 ICR Renewal, using the techniques of RBBM’s Form Element Estimation 
Appendix H 

 4/28/11 

 H -4

(in Appendix C). Note, however, that the impact of Schedule 1 burden on total Form R burden is 

very small (.00516 hours overall per Form R).

5. Weighted Average Wage Rate (WAWR) of $51 Seems Low

Review Comment: According to one reviewer “In general the weighted average wage rate of 

$51 seems low given the engineering and managerial expertise required. We are aware that in 

similar (and admittedly less complicated) analyses conducted in other areas, the 90th percentile 

would be used and adjusted upward by 40 percent to get to a more accurate representation of 

non-wage compensation. In addition, with electronic data entry and submittal, there may well not 

be any appreciable clerical involvement with TRI reporting. The use of the clerical wage level 

also results in an average wage rate that is too low.” 

EPA Response: The WAWR is based on statistics generated by the US Department of Labor 

Bureau of Labor Statistics (BLS) and includes non-wage compensation. As shown in the table 

below, EPA uses the average wage rate and adjusts upward by 60.40% (in this June 2010 

example) to incorporate non-wage compensation. EPA’s WAWR method weights each category 

of management, technical, and clerical labor according to the proportional contribution (.03, .89, 

and .08 respectively) as defined in Appendix E based on the Abt Associates Engineering Studies. 

The value of $51 reflects these analytical decisions for September 2009 conditions using a 

method whereby wage rates are updated to current dollars using the employment cost index (no 

longer used in RBBM). Applying the current version of RBBM and June 2010 conditions, the 

result of $49.62/hr is obtained. Further detail is provided in the table below. 

Table H-2: Derivation of the Weighted Average Wage Rate (WAWR) 

(June 2010) 

Wage Type 

(Burden Proportion) 

Managerial 

(.03) 

Technical 

(.89) 

Clerical 

(.08) 

WAWR 

Composite 

Occupational Type 

Management, 

business, 

and financial 

Professional and 

related 

Office and 

administrative 

support 

WAWR $/hr 

Wages and Salaries $38.84 $32.73 $15.75 

Total benefits $16.85 $13.08 $6.81 

Overhead $6.60 $5.56 $2.68 

Total Loaded Rate $62.29 $51.37 $25.24 

WAWR Contribution 1.87 45.72 2.02 49.62 

Based on June 2010 wage data. http://www.bls.gov/ncs/ect/#tables.