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TIME AND COST ESTIMATES FOR REPORTING

UNDER EPCRA SECTION 313

Regulatory Impacts Branch

Economics, Exposure and Technology Division

Office of Pollution Prevention and Toxics

U.S . Environmental Protection Agency

August 1, 1996

63980000354
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EPA has estimated the time and cost for five activities that occur as a result of EPCRA section 313

requirements . These are compliance determination, rule familiarization, report completion ,

mailing/recordkeeping and supplier notification, which are defined as follows :

CoLnpliance Det.ermination : Facilities must determine whether they meet the criteria for Section 313

reporting (i.e., whether they are within a covered industry group ; have the equivalent of 10 or more full-time

employees; and manufacture, process or otherwise use any of the listed chemicals above the threshold

quantities). This takes longer *in the first year than in subsequent years, since after the first year the facility

has a baseline knowledge of which TRI chemicals are on-site above threshold quantities.

Rule Familiarization: Facilities that are reporting under Section 313 for the first time must read the reporting

package and become familiar with its requirements . The cost associated with rule familiarization occurs only

in the first year that a facility submits reports . In subsequent years, the staff will be familiar with the

requirements that apply to their facility, and would no longer bear this cost . Thus, facilities currently

reporting under Section 313 would not require time for rule familiarization .

Calculations and Report CoMpletion: Facilities must gather data and make calculations to provide the

information required on the form . This takes more time in the first year than *in subsequent years . In many

instances the process in subsequent years will consist of updating data and modify mig the information

reported the previous year, rather than originating or retrieving data for the first time . Because the

calculations required for the Alternate Threshold Certification Statement are a subset of those required for the

Form R, the cost to complete a Certification Statement is correspondingly lower.

Mailinp,/Recordkegping : Facilities must maintain recordkeeping systems, and mail the reports to EPA.

Recordkeeping and mailing costs are estimated to be the same in both first and subsequent years . Because a

Certification Statement requires less information and fewer calculations than a Form R, the time required for

recordkeeping is also lower.

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

must notify their customers of the composition of their product.

The estimates for these five components are shown in Tables I and 2 . Table I shows the costs for

the first year of reporting, while Table 2 lists the costs in subsequent years . The results are presented in

terms of hours and dollars, with the latter in 1995 dollars . The costs are calculated at two different levels .

Rule familiarization, compliance determination and supplier notification are calculated at the facility level,

independently of the number of reports submitted . Thus, the average cost of rule familiarization is estimated

at $2,243 per facility, irrespective of the number of reports submitted . Report completion and recordkeeping

are estimated at the report level . A facility's costs for these components is calculated by multiplying the umit

cost by the number of reports submitted. So, for example, a facility that submits one Form R in subsequent

years is estimated to have a report completion cost of $2,946, while a facility submittig two Form Rs is

estimated to have a cost of $5,892 ($2,946 x 2).

These estimates are averages, and the time required by any individual facility may vary sigmificantly

from the average. As with any average, some facilities will be above the average and others will be below it.

For instance, large multi-divisional, multi-departmental facilities may require more than the average time to

comply . However, there are many other facilities subject to the rule that are not large, multi-divisional or

multi-departmental . These facilities will typically have a simpler compliance process . EPA believes that its

time estimates represent reasonable averages .
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Table 1 : First Year of Reporting

AVG. AVG.COST

ACTIVITY TIME (in1995 dollars)

(Hours )

Rule familiarization 34.5 $2,243 per facility

Compliance determination 16 $ 1,0 10 per facility

Calculations and report completion

- Form R 69 $4,330 per report

- Certification Statement 46 $2,947 per report

Recordkeeping

- Form R 5 $257 per report

- Certification Statement 3 $154 per report

Supplier notification 24 $ 8 1Q_~acili

Table 2 : Subsequent Years of Reporting

AVG. AVG.COST

ACTIVITY TIME (in1995 dollars)

(Hours )

Compliance determination 4 $252 per facility

Calculations and report completion

-Form R 47.1 $2,946 per report

- Certification Statement 31 .6 1 $2,006 per report

Recordkeepin g

- Form R 5 $257 per report

- Certification Statement 3 $154 per report

Supplier notification 24 $ 8 10 per facility