# Economic Analysis of the IUR Revisions Final Rule

Economic and Policy Analysis Branch Economics, Exposure and Technology Division Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency

July 2005iv CONTENTS Chapter Page Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-1
1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1.1 Regulatory History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1.2 Current IUR Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2 1.3 Overview of the Regulated Community . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5 1.4. Changes in Reporting Requirements under the IUR Revisions Rule . . . . . . . . . 1-5 Change Reporting Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5 Move Submission Period . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5 Clarify “Low Current Interest” Partial Exemption Petition Process . . . . . . . . . 1-6 Partially Exempt Additional Petroleum Process Streams . . . . . . . . . . . . . . . . . 1-6 Change Consumer and Commercial Product Categories . . . . . . . . . . . . . . . . . 1-7 Report Manufactured and Imported Volumes Separately . . . . . . . . . . . . . . . . 1-8 Report Processing and Use Information for Domestic Uses Only . . . . . . . . . . 1-8 Update Polymer Exemption Reference . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-8 Remove Production Volume Range CBI Requirement . . . . . . . . . . . . . . . . . . 1-9 2. Cost Savings due to the IUR Revisions Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.1 Unit Time and Cost Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 Estimates of Wage Rates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 Estimates of Labor Hours . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4 Estimates of the Number of Sites and Reports . . . . . . . . . . . . . . . . . . . . . . . . 2-7 2.2 Current IUR Industry Compliance Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8 2.3 Changes in Industry Costs Due to the IUR Revisions Rule . . . . . . . . . . . . . . 2-11 2.4 Industry Savings Due to the IUR Revisions Rule . . . . . . . . . . . . . . . . . . . . . 2-14 2.5 EPA Savings Due to the IUR Revisions Rule . . . . . . . . . . . . . . . . . . . . . . . . 2-18 2.6 Total Savings Due to the IUR Revisions Rule . . . . . . . . . . . . . . . . . . . . . . . . 2-19 3. Impact of the IUR Revisions Rule on the Benefits of the IUR . . . . . . . . . . . . . . . . . . . 3-1 4. Benefit-Cost Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 5. Small Entity and Environmental Justice Impact Determinations . . . . . . . . . . . . . . . . . 5-1 5.1 Small Entity Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5.2 Environmental Equity/Justice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . R-1 Appendix A: IUR Form U . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1v LIST OF TABLES
Number Page 2-1 Loaded Hourly Wage Rates by Labor Category . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3 2-2 Average Burden Hours for 2006 IUR Submission . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5 2-3 Average Burden Hours for IUR Submissions after 2006 . . . . . . . . . . . . . . . . . . . . . . . 2-6 2-4 Estimated Number of Sites, Reports, and Discrete Chemicals by Chemical Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8 2-5 Industry Costs of the Current IUR for Organic Chemicals (2000$) . . . . . . . . . . . . . . . 2-9 2-6 Industry Costs of the Current IUR for Inorganic Chemicals (2000$) . . . . . . . . . . . . . 2-10 2-7 Total Industry Costs of Current IUR (million 2000$) . . . . . . . . . . . . . . . . . . . . . . . . 2-10 2-8 Total Industry Burden Hours of Current IUR (thousands of hours) . . . . . . . . . . . . . 2-11 2-9 Change in Industry Costs Due to IUR Revisions Rule . . . . . . . . . . . . . . . . . . . . . . . 2-13 2-10 Industry Costs for Organic Chemicals After the IUR Revisions Rule (2000$) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-14 2-11 Industry Costs for Inorganic Chemicals After the IUR Revisions Rule (2000$) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-15 2-12 Total Industry Costs After the IUR Revisions Rule (million 2000$) . . . . . . . . . . . . . 2-15 2-13 Total Industry Burden Hours After the IUR Revisions Rule (thousands of hours) . . . 2-16 2-14 Flow of Industry Savings Due to IUR Revisions Rule Over 20 Years (million 2000$) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-17 2-15 Flow of EPA Savings Due to the IUR Revisions Rule Over 20 Years (2000$) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-19 2-16 Total Savings Due to the IUR Revisions Rule (million 2000$) . . . . . . . . . . . . . . . . . 2-20 2-17 Burden Savings Due to the IUR Revisions Rule (thousands of hours) . . . . . . . . . . . . 2-20
4-1 Benefits and Costs of the IUR Revisions Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2

LIST OF BOXES
Number Page 1-1 Industrial Function Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4 1-2 Commercial and Consumer Product Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-41 Several categories of substances, including polymers, microorganisms, naturally occurring chemical substances, and certain natural gas substances, are generally excluded from IUR reporting.
ES-1 EXECUTIVE SUMMARY

The U.S. Environmental Protection Agency (EPA) requires manufacturers and importers of certain chemical substances to periodically report information to the Agency under reporting requirements known as the Inventory Update Reporting (IUR) rule. This information is collected based on EPA’s authority under Section 8(a) of the Toxic Substances Control Act (TSCA). The data reported under the IUR rule are used to support many EPA and other federal agency health, safety, and environmental protection activities. The IUR rule was extensively amended in 2003. EPA is now revising some of the IUR rule requirements. The IUR rule requires companies to report information every four years on chemical substances listed on the TSCA Inventory. 1 For reportable substances that a company manufactures or imports in quantities of 25,000 pounds or more at a plant site during the reporting year, a submitter is required to provide plant site, production volume, and manufacturing information. The submitter must also provide processing and use information for chemicals that exceed a 300,000 pound per year threshold. Manufacturers or importers of specifically listed petroleum process streams, and listed chemical substances of low current interest are not required to report processing and use information for those listed chemicals. EPA is now promulgating the IUR Revisions Rule to further adjust the IUR data collection and reporting process in several ways: Extend the data reporting cycle from four years to five years. For reporting cycles after 2006, move the submission period for reporting from the end of the calendar year (August through December) to the middle of the year (June through September), and clarify the recordkeeping requirements by identifying that the 5-year record retention period begins on the last day of the submission period. Clarify that the partial exemption for low current interest chemicals requires language requiring a written rationale to be included in petitions to change the list of these chemicals. Expand the list of petroleum process streams receiving a partial exemption, and clarifying the exemption. Add a use category for chemicals of 300,000 pounds or more.2All values are in year 2000 dollars to facilitate comparison with the analysisof the 2003 Amendments to the IUR.
ES-2 Require submitters to report manufactured and imported volumes separately (as they did prior to the 2003 Amendments). Restrict reporting of processing and use information to domestic uses. Clarify the polymer definition in the regulations. Eliminate the requirement to determine confidentiality of production volume in ranges. These revisions will reduce IUR rule reporting costs. Over the first 20 years of the rule, the net present value of the savings will be $60 million to $102 million, depending on the assumptions and the discount rate used. Annualized savings are expected to be $6 million to $7 million. 2Although the data will be obtained less frequently after implementing the revisions, the revised reporting schedule will still provide EPA with sufficient information to target activities efficiently. The information that will remain available will enable the Agency to continue to target educational, regulatory, or enforcement activities toward industries or chemicals that pose the greatest potential risks and to target programs for population groups that are at the highest potential risk. No negative small business impacts are expectedto result from the IUR Revisions Rule. In fact, the revisions generate savings for small businesses and other businesses. Nor are there any significant negative environmental equity issues associated with the rule. Taking together the factors analyzed in this report, the revisions to the IUR rule will generate net benefits to society by reducing reporting costs for submitters while supporting EPA’s most critical data needs.3 Chemicals listed on the TSCA Inventory are referred to as "existing chemicals," while TSCA chemicals not currently listed are referred to as "new chemicals." Producers intending to manufacture or import a new chemical must submit a notice to the Agency’s New Chemicals Program, which screens new chemicals to determine if and under what conditions they can be made or brought into the United States. Once a chemical passes through the program, the manufacturer or importer must file a Notice of Commencement after the chemical enters commerce.
1-1 CHAPTER 1 INTRODUCTION

This report assesses the benefits and costs expected to result from revising the Inventory Update Reporting (IUR) rule. These revisions reduce the burden on submitters while enabling EPA to meet its critical need for information. This chapter provides information on EPA’s statutory authority for collecting information through the IUR rule, a discussion of the regulatory history of the IUR rule, an overview of the regulated community, and a description of the existing rule requirements and revisions. 1.1 Regulatory History When Congress passed the Toxic Substances Control Act (TSCA), it granted EPA broad authority to collect information on chemical substances to help EPA and others assess the magnitude and extent of human and environmental exposure to chemicals used in commerce. Specifically, under §8 of TSCA (15 U.S.C. 2607), EPA is authorized to promulgate regulations requiring manufacturers and processors of chemicals to report production and use information on various types and classes of chemicals. In 1977, EPA used its authority under TSCA §8 to create the TSCA Chemical Substances Inventory, also known as the TSCA Inventory (42 FR 64572), which is codified at 40 CFR Part 710 Subpart A. The TSCA Inventory lists all TSCA chemicals that have been in commerce, thereby providing a snapshot of chemicals manufactured or processed in the United States. All chemicals are included, with the exception of pesticides, tobacco, nuclear material, firearms and ammunition, food and food additives, drugs, and cosmetics. The initial TSCA Inventory listed those chemicals in commerce in 1977. Chemicals are added to the Inventory after a company completes EPA’s New Chemicals process and files a Notice of Commencement. 3 Currently, the Inventory lists over 82,000 chemicals. In 1986, EPA used its authority under TSCA §8(a) to promulgate regulations requiring chemical manufacturers and importers to submit data on certain chemical substances listed in the TSCA Inventory (51 FR 21447). Commonly called the TSCA Inventory Update Reporting rule,4 See Appendix A for a copy of Form U.
1-2 or IUR rule, these regulations are codified at 40 CFR Part 710 Subpart B. Under this rule, EPA collected data every four years, from 1986 to 2002, for organic chemicals produced in volumes of 10,000 pounds or more per site. (Inorganic chemicals, polymers, microorganisms, and naturally occurring chemical substances were generally excluded from reporting.) From 1986 to 1998, an average of 9,200 individual chemicals were reported per cycle. The IUR data provided a more up-to-date picture of a subset of the TSCA chemicals in commerce, generating data that were used to support TSCA risk management activities, as well as providing support to other EPA and non-EPA program activities. In January 2003 EPA promulgated amendments to the IUR rule. Referred to in this report as the “2003 Amendments” (68 FR 848), the amended IUR applies to the 2006 reporting cycle and beyond, and is codified at 40 CFR Part 710 Subpart C. The 2003 Amendments required reporting for inorganic chemical substances, added new site and manufacturing data elements, required companies to provide basic processing and use information related to potential chemical exposures, changed the period of coverage from corporate fiscal year to calendar year, and extended the recordkeeping period from four years to five years. The 2003 Amendments limited industry burden by raising the reporting threshold to 25,000 pounds, creating a partial exemption from reporting processing and use information, and exempting certain forms of natural gas from reporting. As part of the interagency review of the 2003 Amendments (under Executive Order 12866), EPA agreed to propose a subsequent rulemaking to change the reporting frequency by extending the reporting cycle, in an effort to further reduce industry reporting burden. In the IUR Revisions Rule, EPA, in addition to extending the reporting cycle, is also making further changes to the IUR rule that reduce industry burden and clarify rule requirements while maintaining EPA’s ability to meet its critical need for information. 1.2 Current IUR Rule Requirements The current IUR rule requires that members of the regulated community submit information on certain TSCA chemicals once every four years. (Polymers, microorganisms, naturally occurring chemical substances, and certain natural gas substances are generally exempt from reporting.) The reporting threshold for IUR site and manufacturing information is 25,000 pounds, and there is a second reporting threshold of 300,000 pounds for processing and use information. This means that sites manufacturing or importing TSCA chemicals at annual volumes of 25,000 pounds up to 300,000 pounds are required to report only site and manufacturing information (Parts I and II of Form U). 4Sites producing or importing TSCA chemicals at annual volumes of 300,000 pounds or greater are required to report processing and use information (Part III of Form U) as well as site and manufacturing data, except for chemicals1-3 that qualify for an exemption from reporting processing and use information. The reporting cycle for IUR information is every four years and covers the previous calendar year. Records supporting information submitted to EPA must be retained for five years. Reportable chemicals manufactured in quantities less than 300,000 pounds are referred to as “partially exempt” from reporting because they are not required to provide processing and use information (Part III of Form U), but continue to report site and manufacturing information (Parts I and II of Form U). For the 2006 reporting cycle, inorganic chemicals have a partial exemption. Starting with the next reporting cycle after 2006, inorganic chemicals w ill be subject to the same full reporting requirements as organic chemicals. Partial exemptions are also granted for certain listed petroleum process stream chemicals, and for certain other chemicals for which there is currently low interest in processing and use data. Form U, the instrument used to collect the IUR information, is divided into three parts: Site Identification Information, Manufacturing Information, and Processing and Use Information. (A copy of Form U is in Appendix A.) An overview of the information collected under the IUR rule is as follows: Certification statement . A company official must sign the form, certifying that the information provided is complete and accurate. Company information . Includes the company name and Dun & Bradstreet number. Technical contact information . Includes the name, address, telephone number, and email address for a technical contact. Plant site information . Includes the name, address, and Dun & Bradstreet number for the plant site that is reporting. Chemical identification . Includes both the specific chemical name and the Chemical Abstracts Service (CAS) Registry Number, or other identifying number, of the chemical substance. Manufacturing information . Includes an indication of whether the chemical substance is manufactured or imported; whether it is site limited (whether it is produced and used at the same site, and does not undergo packaging and shipping); and the production volume. Also contains the number of workers involved in manufacturing that are reasonably likely to be exposed to the chemical substance, the physical form(s) as the chemical leaves the site (including the percent of the production volume in each form), and the maximum concentration of the chemical as it leaves the site. Codes representing ranges are used to report these data. Industrial processing and use data . Includes the types of process or use for the chemical substance, the related North American Industrial Classification System (NAICS) codes and industrial function codes, as well as the percentage of production volume attributable to each processing or use activity reported, the number of sites,1-4 Box 1-1. Industrial Function Categories

$ Adsorbents and absorbents

$ Adhesives and binding agents

$ Aerosol propellants

$ Agricultural chemicals (non-pesticidal)

$ Antiadhesive agents

$ Bleaching agents

$ Coloring agents, dyes

$ Coloring agents, pigments

$ Corrosion inhibitors and antiscaling agents

$ Fillers

$ Fixing agents

$ Flame retardants

$ Flotation agents

$ Fuels

$ Functional fluids

$ Intermediates

$ Lubricants

$ Odor agents

$ Oxidizing agents $ pH-regulating agents

$ Photosensitive chemicals

$ Plating agents and metal surface treating agents

$ Processing aid, not otherwise listed

$ Process regulators, used in vulcanization or polymerization processes

$ Process regulators, other than polymerization or vulcanization processes

$ Reducing agents

$ Solvents (for cleaning or degreasing)

$ Solvents (which become part of product formulation or mixture)

$ Solvents (for chemical manufacture and processing and are not part of the end product at greater than 1 percent by weight)

$ Stabilizers

$ Surface active agents

$ Viscosity adjustors

$ Other

Box 1-2. Commercial and Consumer Product Categories • Artists’ supplies • Adhesives and sealants • Automotive care products • Electrical electronic products • Glass and ceramic products • Fabrics, textiles, and apparel • Lawn and garden products (nonpesticidal) • Leather products • Lubricants, greases and fuel additives • Metal products • Paper products • Paints and coatings • Photographic chemicals • Polishes and sanitation goods • Rubber and plastic products • Soaps and detergents • Transportation products • Wood and wood furniture • Other and the number of workers for downstream processing and uses of the chemical. These data are reported for up to ten unique combinations of use, function, and NAICS code with the largest production volumes (by weight) for the chemical. The industrial function category codes are listed in Box 1-1. Only “readily obtainable” data are required to be reported. Consumer and commercial end-use data. Includes the relevant commercial and consumer product categories, the percentage of the production volume in each product category, the maximum concentration of the chemical in each final product, and an indication of whether the chemical is intended for children’s use. The commercial and consumer product categories are listed in Box 1-2. Confidential Business Information (CBI) status can be claimed for each data element reported. Submitters who claim the chemical identity or plant site identity as CBI must provide up-front substantiation.1-5 1.3 Overview of the Regulated Community The regulated community for the IUR rule (who will potentially be affected by the IUR Revisions Rule) consists of companies manufacturing or importing chemicals in amounts of 25,000 pounds or more annually that are listed on the TSCA Inventory and regulated under TSCA §8. Manufacturers and importers of non-TSCA chemical substances (such as pesticides, tobacco, nuclear material, firearms and ammunition, food and food additives, drugs, and cosmetics) are not required to report information on those chemicals under the IUR rule. (Some chemical substances might have both TSCA and non-TSCA uses. In that case, the production associated with the TSCA use is reported.) Companies engaged in chemical manufacturing (NAICS Group 325) or petroleum refining (NAICS Group 3241) are the most likely to report under the IUR rule. However, companies in any industry are subject to reporting if they manufacture or import covered chemicals above the reporting threshold. Companies must review the rule to determine whether they must report. 1.4. Changes in Reporting Requiremen ts under the IUR Revisions Rule The revisions encompass nine specific changes to the IUR rule. Each of these revisions is described below. Change Reporting Frequency The current IUR rule requires reporting every four years. The first submission period reflecting the changes implemented in the 2003 Amendments w ill be in 2006, with submitters supplying data for the calendar year 2005. Under the IUR Revisions Rule, the reporting frequency would be changed from every four years to every five years after the first reporting period. In other words, these revisions would retain the current reporting year of 2005 (submitted to EPA in 2006), but instead of occurring in 2009 the next reporting year under the IUR would be delayed until 2010 (i.e., five years after the 2005 reporting year). The submission period would continue to occur during the year after the reporting year (e.g., 2011, 2016). This change is being made to reduce the burden of the IUR rule. Move Submission Period Under the current IUR rule, submitters are required to report on a recurring basis during a 120-day period from August 25 to December 23 (40 CFR 710.53). EPA proposed changing the submission period to occur from January 1 to April 30, but reconsidered this action after receiving comments. EPA is keeping the submission period of August 25 to December 23 for the 2006 reporting cycle, and moving the reporting cycle to June 1 to September 30 in subsequent cycles. This change is related to the change in reporting year from company fiscal year to calendar year that occurred under the 2003 Amendments. The August to December submission period was1-6 originally chosen because many companies’ fiscal years end in July, such that starting the IUR submission period in late August allowed these companies to report their most current information in the most timely manner possible. However, because the 2003 Amendments require submitters to report on a calendar-year basis, an earlier submission period is more appropriate because it w ill allow sites to submit their information to EPA closer to the period during which it was generated. This will then allow the Agency to obtain and process the information in a more timely manner. Clarify “Low Current Interest” Partial Exemption Petition Process Section 710.46(b)(2) of the CFR contains the requirements for the partial exemption of certain chemicals for which EPA has determined the IUR processing and use information to be of “low current interest.” Manufacturers and importers of the listed chemicals are not required to report the processing and use information in Part III of the Form U for those listed chemicals. The public may ask EPA to change the partial exemption list by adding or removing chemicals. The request must be in writing, must identify the chemical in question (including a chemical identification number), and, as clarified in these revisions, must provide a written rationale or justification for the request, accompanied by relevant documents and specific cites to information in those documents. The rationale needs to provide sufficient information on which the Agency can assess the current need for IUR processing and use information and can make a decision concerning reporting of that information for the subject chemical. EPA is making this clarification in reaction to the first round of requests for consideration, which were received by December 30, 2003. It was always EPA’s intent that the requests contain supporting rationale associated with the request, and that the rationale specifically address at least the considerations outlined in 40 CFR 710.46(b)(2)(ii). Instead, EPA received a number of petitions that only cited the existence of another document (i.e., an OECD SIDS Initial Assessment Report) as support, without any discussion of the document’s relevance to the considerations or why the petitioner believes the document supports a finding of low current interest in the IUR processing and use information. EPA is clarifying that it is a petitioner’s burden to present an argument as to why the IUR processing and use information for a given chemical substance should be considered of low current interest. Partially Exempt Additional Petroleum Process Streams There are currently 591 listed petroleum process streams that are exempt from reporting downstream processing and use information in Part III of the Form U. This list of partially exempt petroleum process streams was derived from a 1983 publication of the American Petroleum Institute (API) entitled “Petroleum Process Stream Terms Included in the Chemical Substance Inventory Under the Toxic Substances Control Act (TSCA)” (API, 1983). EPA is now amending its list to add certain petroleum process streams that have been added to the TSCA Inventory since the 1983 API publication was compiled. EPA is adding 25 substances that were1-7 not in the 1983 API publication, plus an additional two other substances which were inadvertently left off the original partial exemption listing. Change Consumer and Commercial Product Categories Submitters completing Part III of Form U must designate the commercial and consumer product category or categories that best describe the commercial and consumer products in which each reportable chemical substance is used. (See Box 1-2 for a list of the categories.) The Agency is adding to the list a category called “Agricultural Products (non-pesticidal).” Many chemicals with consumer and commercial applications are used in agricultural applications, an area not explicit in the current consumer and commercial product categories. EPA is adding this category to ensure that the volume of chemicals associated with this end use is separated out and not combined into the “other” category. EPA had also proposed to combine the categories of “Soaps and Detergents” and“Polishes and Sanitation Goods” to form a new category called “Cleaning Products (nonpesticidal).” This change was suggested during the public comment period for the 2003 Amendments, and based on an EPA determination that manufacturers might have difficulty differentiating between these similar downstream categories, and that it would be appropriate for them to report under a single category. Upon further analysis, these two categories are clearly differentiated in the six-digit North American Industry Classification System (NAICS) codes, and the use scenarios in models that EPA typically uses to analyze a screening-level exposure assessment are different from each other and therefore would generate different potential exposure results. Therefore EPA is not combining these two categories. EPA had additionally proposed removing the category “Photographic Chemicals.” This proposed deletion was in recognition of the changing photography industry (i.e., shift from traditional film photo finishing to electronic capture and production). Further investigation reveals that despite the displacement of analog photography by digital imaging, U.S. consumption of film and paper chemicals is projected to remain relatively stable. Included in this category are many substances that have roles in digital imaging as well as analog. Thus, EPA is maintaining this category. Report Manufactured and Imported Volumes Separately Prior to the 2003 Amendments, submitters were required to report the volume manufactured separately from the volume imported for each reportable chemical substance. As a result of the 2003 Amendments, submitters are currently required to report the total production volume (i.e., the sum of manufactured and imported volumes) for each reportable chemical substance. EPA often needs to be able to distinguish between the quantities of a chemical that are manufactured domestically and those that are imported. Thus, EPA is returning to the previous method of reporting manufactured volume separate from imported volume.1-8 Report Processing and Use Information for Domestic Uses Only Submitters with production volumes of 300,000 pounds or greater for a reportable chemical substance are currently required to report processing and use information (Part III of Form U) for domestic and overseas uses, to the extent the information is readily available. EPA is limiting the reporting to processing and use occurring domestically. Submitters would no longer be obligated to report processing or use information for activities that occur once the chemical substance leaves the United States. This change is intended to reduce the burden associated with reporting information under the IUR rule, and in recognition that EPA’s primary focus is on domestic exposures to chemicals. Update Polymer Exemption Reference Chemical substances meeting the definition for polymers are currently exempt from reporting under the IUR rule. EPA is changing the regulatory reference of the polymer definition from the “1985 edition of the Inventory or the Master Inventory File” to the “Master Inventory File”. EPA is removing the reference to the 1985 edition of the Inventory because the Master Inventory File has been regularly updated since the 1985 edition. This change w ill keep the reference current and up-to-date. Remove Production Volume Range CBI Requirement The 2003 Amendments contained a requirement that submitters determine whether production volume should be considered CBI if presented as a specified range instead of as a point estimate. This amendment was included in the 2003 final rule as part of an effort to make available to the public a greater amount of the site- and chemical-specific production-volume range information from the IUR rule. EPA is now repealing this reporting requirement. EPA’s decision not to solicit confidentiality claims for the standardized production volume ranges in 710.52(c)(3)(v) was based on several concerns, most importantly issues inherent in releasing both aggregated data and site-specific production volume ranges. The Agency has determined that this provision regarding the confidentiality of production volume information within specified ranges is not likely to result in greater availability of production volume information to the public, which was the goal of this data element. Therefore, there is no need for submitters to make a CBI determination for production volume in ranges. It is important to note that, by this change, EPA is not presuming consent to release these production volume ranges for site-specific production volume ranges or otherwise lessening any CBI protections.2-1 CHAPTER 2 COST SAVINGS DUE TO THE IUR REVISIONS RULE

This chapter analyzes the changes in industry compliance costs and government administration costs associated with the IUR Revisions Rule. The incremental social costs of the revisions are negative (i.e., there is a cost savings), primarily due to less frequent information collection. This chapter calculates the incremental cost savings of the revisions by comparing the costs to industry and the government under the current IUR rule and after the revisions. The methodology for estimating the change in industry costs can be summarized as follows: Step 1 : Identify the tasks that sites perform to comply with reporting requirements for both the current IUR rule and the IUR Revisions Rule. Step 2 : Determine the unit costs for all activities identified in Step 1, based on labor requirements for managerial, technical, and clerical staff. Step 3 : Determine the expected number of sites and reports filed under each of the rules. Step 4 : Multiply the cost per form by the number of forms to determine the estimated total costs of compliance for the current IUR rule and the IUR Revisions Rule. Step 5 : Subtract the compliance cost after the IUR Revisions Rule from the cost under the current IUR rule to calculate the incremental savings due to the revisions. More information on the estimation of compliance costs under the current IUR rule can be found in the “Economic Analysis for the Amended Inventory Update Rule” (EPA, 2002). The steps required for compliance with the IUR rule can be characterized as compliance determination, rule familiarization, preparation and submission of reports, and recordkeeping. The actions taken under these steps are as follows: Compliance Determination : To determine if it must submit a Form U, a company must determine whether (1) it manufactures or imports any chemicals that do not fall into one of the categories exempt from reporting, (2) the annual production or import volume of the chemical is above the reporting threshold, and (3) the company meets the small business criteria set forth in the TSCA §8(a) Small Manufacturer Exemption Rule (40 CFR 704.3). For simplicity, the cost for compliance determination is considered to be incurred once per site, and does not vary with the number of chemicals at the site. A portion of the compliance determination cost depends on the number of chemicals, but for most chemicals this component of the burden will be extremely small. The majority of the time required for this task involves identifying2-2 the requirements and reviewing information to determine if the site must submit a Form U. Rule Familiarization : Once a company has determined that it must submit a Form U for a site, staff must familiarize themselves with the remainder of the rule. Sites that previously reported must become familiar with new requirements, and sites new to reporting must become familiar with all requirements. This entails reading the rule, understanding the various reporting and administrative requirements, and determining the manner in which the reporting requirements will be met. Preparation and Submission of Reports : Once a site has determined that it must provide information on a chemical and has become familiar with the rule, the required information must be collected and a Form U covering all of the reportable chemicals at that site must be completed, reviewed, and submitted to EPA. Recordkeeping : Submitters must keep records supporting their submissions for five years. Only a few of the provisions of the IUR Revisions Rule are expected to have a measurable impact on the cost of IUR reporting. The average annual cost will decline under the IUR Revisions Rule because of less frequent reporting. The exemption of exported volume from processing and use reporting requirements will reduce reporting costs. Also, granting partial exemptions for additional petroleum process streams will reduce reporting costs for these substances. 2.1 Unit Time and Cost Estimates The reporting costs are determined based on estimates of wage rates, labor hours, and the number of sites and reports. This section describes the specific data used to develop these estimates. Estimates of Wage Rates Standard wage rates for managerial, technical, and clerical levels were developed from information published by the Bureau of Labor Statistics (BLS) and an analysis adopted from the Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313 (EPA, 1997a). Data used to develop basic wage rates were derived from 1993 salary information published by BLS for all private, goods-producing industries and were inflated to current dollars. Four BLS occupation categories were analyzed: engineers, accountants, attorneys, and secretaries. As presented in Table 2-1, the managerial- and technical-level salaries used for the analysis are composites of the BLS average salaries for several occupation categories and levels. Weighting factors were applied to the average salaries for each of the occupation categories within the managerial and technical labor categories to develop the composite salary. The5 The three labor rates were each adjusted using separate ECI categories. The clerical rate was adjusted using the Administrative Support, including Clerical Occupations data, the technical rate was adjusted using the Professional Specialty and Technical Occupations data, and the managerial rate was adjusted using the Executive, Administrative, and Managerial Occupations data. Year 2000 dollars are used for consistency with the Economic Analysis for the Amended Inventory Update Rule (EPA, 2002).
2-3 weighting factors are based on information provided by the chemical industry and chemical industry trade associations for the typical fraction of total reporting effort that is accounted for by each specific BLS occupation category (EPA, 1997a). The 1993 composite annual salary estimates were adjusted to first-quarter 2000 dollars using the Employment Cost Index (ECI) for white-collar occupations in private industries. 5The adjusted, composite salaries for the managerial, technical, and clerical labor categories were then multiplied by benefits and overhead factors to estimate loaded, annual salaries in year 2000 dollars. Detailed benefits data for white-collar occupations in private, goods-producing industries were used to account for the additional cost of benefits for managerial, technical, and clerical Table 2-1. Loaded Hourly Wage Rates by Labor Category

Occupation

(Levels) Average Salary ($1993) Weighting Factor Comp. Salarya ($1993) ECI Ratio 3/00:6/93 b Adjusted Salary ($2000) 2000 Benefits (% Salary) 2000 Overhead (% Salary) Loaded Annual Salary ($2000) Loaded Hourly

Rate ($2000) Managerial Engineer (6

B 8) $93,981 10/17 $55,283 Attorney (4

B 6) $111,263 5/17 $32,724 Accountant (5

B 6) $73,528 2/17 $8,650
Composite 17/17 $96,658 1.33 $128,555 37.6% 17.0% $198,746 $95.55 Technical Engineer (3

B 8) $74,802 5/6 $62,335 Accountant (3

B 6) $59,436 1/6 $9,906
Composite

C 6/6 $72,241 1.23 $88,856 37.4% 17.0% $137,194 $65.96 Clerical Secretary (1

B 5) $28,850 1/1 $28,850
Composite

C 1/1 $28,850 1.26 $36,351 39.6% 17.0% $56,926 $27.37

a 1993 composite salaries were determined by multiplying average salaries by the weighting factor and summing across

occupations. b The ECI ratio measures the change in wages and salaries between June 1993 and March 2000. Sources: U.S. Environmental Protection Agency. April 1997a. Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313 . Washington, DC: Office of Pollution Prevention and Toxics, Regulatory Impacts Branch. Bureau of Labor Statistics (BLS). 2000. Employment Cost Index. < www.bls. gov>. As obtained April 28, 2000.2-4 labor. The overhead factor of 17 percent is based on information provided by the chemical industry and chemical industry trade associations. The loaded annual salary was then divided by 2,080 hours (i.e., the average annual number of hours worked per year by a full-time employee). The result is an estimate of $27.37 per hour for clerical labor, $65.96 per hour for technical labor, and $95.55 per hour for managerial labor, all in year 2000 dollars. Estimates of Labor Hours As mentioned earlier, the reporting instrument for the IUR rule is the Form U. (See Appendix A for a copy of Form U.) Each reporting site is required to file only one Form U, regardless of the number of reportable chemicals it manufactures or imports. Information such as site and company identification are common to all chemicals produced at a single site; therefore, this information need only be reported once. Contained within the Form U are any number ofindividual chemical reports. EPA estimated some costs on a per-site basis and some on a perreport basis. Each site must determine whether it must comply with the IUR and then must familiarize itself with the rule’s reporting requirements. The costs associated with these tasks are calculated per site (i.e., not varying with the number of chemicals reported at the site). For each reportable chemical, a report must be prepared and submitted and a record of it must be kept. Reporting and recordkeeping costs are calculated as per-report costs (so that total reporting and recordkeeping costs vary with the number of chemicals reported). The estimates of the labor hours required for the various tasks in the baseline are taken from the economic analysis for the 2003 Amendments (EPA, 2002). Table 2-2 summarizes the average estimated burden per unit (either report or site) for each of these tasks for the 2006 IUR submission period (when inorganic chemicals have a partial exemption). Table 2-3 presents average estimated burden under baseline conditions for submission periods after 2006, when inorganic chemicals become subject to the same requirements for providing processing and use information as organic chemicals. In addition, burden estimates have been scaled downward in some categories to reflect learning from the 2006 submission, the first submission that includes the changes due to the 2003 Amendments; see the economic analysis for the 2003 Amendments (EPA, 2002) for more information. For chemicals produced at volumes of 25,000 to 300,000 pounds and for chemicals meeting the partial exemptions, only Parts I and II of Form U must be completed. Thus, burden estimates are provided separately for full and partial reports. The amount of effort (and therefore costs) required may vary depending on factors such as company size, type of chemical, and the variety of uses for the chemical. The IUR Revisions Rule would reduce the time required for compliance because submitters would no longer be required to report processing and use information for exports. The value of exports for the chemical industry has been equal to about 15 percent of the value of production plus imports in recent years (ACC, 2003). Thus, it was assumed that the average burden of completing Part III of Form U would be reduced by 15 percent under the IUR2-5 Revisions Rule relative to the current burden (see Tables 2-2 and 2-3). This reflects the reduction in time required to determine use and processing information for exports. To the extent that the industrial function categories, function codes, and use codes are the same for domestic and exported uses, this adjustment will tend to overstate the reduction in burden. Table 2-2. Average Burden Hours for 2006 IUR Submission

Unit Average Burden Hours per Reporting Cycle Totals Clerical $27.37/hr Technical $65.96/hr Managerial $95.55/hr Average Hours/Unit Low High Low High Low High Low High Organic Chemicals Compliance Determination Site 0 0 1 4 0 0 1 4 Rule Familiarization Site 0 0 18 20 8 10 26 30 Report Preparation and Submission Partial Report Report 2.1 2.6 8.1 11.4 3.4 5.7 13.5 19.7 Full Report (Baseline) Report 10.8 12.5 59.3 66.8 22.4 26.0 92.4 105.3 Full Report (after IUR Revisions Rule) Report 9.5 11.0 51.6 58.4 19.5 22.9 80.6 92.4
Recordkeeping Report 1 2 2 4 1 2 4 8 Inorganic Chemicals a Compliance Determination Site 0 0 1 4 0 0 1 4 Rule Familiarization Site 0 0 18 20 8 10 26 30 Report Preparation and Submission Partial Report Report 2.1 2.6 8.1 11.4 3.4 5.7 13.5 19.7 Full Report (Baseline and IUR Revisions Rule) Report 0 0 0 0 0 0 0 0
Recordkeeping Report 1 2 2 4 1 2 4 8

a Inorganic chemicals have a partial exemption from reporting processing and use information for the 2006 submission period. Source: U.S. Environmental Protection Agency. August 2002. Economic Analysis for the Amended Inventory Update Final Rule, Final Report . Washington, DC: Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch.
However, it is likely that determining information on processing and use for exports is generally more difficult than for domestic uses and would have required a disproportionate share of the burden. Thus, EPA determined that comparing exports to the value of production plus imports was a reasonable estimate of the proportionate reduction in burden resulting from this rule.2-6 The burden reduction from not reporting processing and use information for exported volumes can be determined by calculating the burden of Part III of Form U by subtracting the burden for a partial report (Parts I and II of Form U) from the burden of a full report under the baseline conditions; multiplying the result by 85 percent (reflecting the 15 percent reduction in Table 2-3. Average Burden Hours for IUR Submissions after 2006

Unit Average Burden Hours per Reporting Cycle Totals Clerical $27.37/hr Technical $65.96/hr Managerial $95.55/hr Average Hours/Unit Low High Low High Low High Low High Organic Chemicals Compliance Determination Site 0 0 1 4 0 0 1 4 Rule Familiarization Site 0 0222244 Report Preparation and Submission

Partial Report Report 1.9 2.4 7.3 10.2 3.0 5.2 12.2 17.7 Full Report (Baseline) Report 8.8 10.4 48.2 54.5 18.2 21.4 75.3 86.2 Full Report (after IUR Revisions Rule) Report 7.8 9.2 42.1 47.8 16.0 18.9 65.8 75.9
Recordkeeping Report 1 2 2 4 1 2 4 8 Inorganic Chemicals a Compliance Determination Site 0 0 1 4 0 0 1 4 Rule Familiarization Site 0 0222244 Report Preparation and Submission

Partial Report Report 1.9 2.4 7.3 10.2 3.0 5.2 12.2 17.7 Full Report (Baseline) Report 8.8 10.4 48.2 54.5 18.2 21.4 75.3 86.2 Full Report (after IUR Revisions Rule) Report 7.8 9.2 42.1 47.8 16.0 18.9 65.8 75.9
Recordkeeping Report 1 2 2 4 1 2 4 8

a Inorganic chemicals begin reporting processing and use information after the 2006 submission period. Source: U.S. Environmental Protection Agency. August 2002. Economic Analysis for the Amended Inventory Update Final Rule, Final Report . Washington, DC: Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch.
burden due to the revision) for an estimate of the burden for the revised Part III; and adding back in the burden estimate for a partial report (Parts I and II of Form U), yielding an estimate of the burden of a full report after the IUR Revisions Rule. The results are highlighted in Table 2-2 and 2-3.6Both the current and revised IUR include a partial exemption for petroleum process stream chemicals and for specific chemicals based on low current interest in processing and use data as well as a full exemption for certain forms of natural gas. Chemicals with a partial exemption only have to provide site and manufacturing information. They are exempt from reporting processing and use information regardless of production volume. Inorganic chemicals have a partial exemption from reporting in the 2006 submission period only. In future reporting cycles, they are subject to the same threshold for full reports as organic chemicals.

7The same number of reports are expected under both the current IUR and the IUR Revisions Rule. The revisions do not have any provisions that would affect the total number of reports required.
2-7 These burden estimates may overstate the actual burden associated with IUR reporting. The estimates were based in part on information collected through a survey of IUR respondents. Although the IUR rule only requires that industry report “readily available” information for downstream processing and use information, the respondent survey that was used to estimate reporting burden did not mention this standard. Thus, survey respondents were likely assuming a higher standard of information than EPA requires. This is demonstrated by evidence from EPA’s Use and Exposure Information Project (UEIP). Under the UEIP, companies were asked to report chemical information very similar to that required by the IUR. When respondents were asked about the time spent preparing the UEIP form for submission they reported a median burden of 8 hours per chemical report, with a mean of 12 hours (EPA, 1997b). This is evidence that the burden estimates derived from the IUR survey may overestimate the actual reporting burden. It is not clear what impact this has on the estimates of savings due to the IUR Revisions Rule. Estimates of the Number of Sites and Reports The baseline number of reports expected and the number of sites filing those reports were estimated in the economic analysis for the 2003 Amendments (EPA, 2002). The total number of reports is broken down into those that must file full reports and those that must file partial reports because of the difference in cost between the two types of reports. 6The number of reports expected was estimated using data compiled from EPA’s Chemical Update System (CUS) and EPA’s Chemicals in Commerce Information System (CICIS). 7The CUS database contains information collected under the IUR rule for previous submission periods and was used to generate estimates of expected reports for organic chemicals. The CUS database could not be used to estimate the number of reports for inorganic chemicals because inorganic chemicals were previously exempt from the IUR rule and therefore are not included in the historical CUS data. Instead, the CICIS database was used for inorganic chemicals. CICIS contains information collected by EPA on TSCA chemicals in commerce in the United States in 1977, including inorganic chemicals. Table 2-4 displays the number of sites and reports expected under baseline conditions and under the IUR Revisions Rule. The only difference between the two is that the revisions will add 25 chemical substances to the list of petroleum process streams with partial exemptions. This change is expected to switch only about 10 reports from full to partial based on recent CUS2-8 submissions, because reports are not being submitted for the majority of these chemicals in the baseline. Table 2-4. Estimated Number of Sites, Reports, and Discrete Chemicals by Chemical Type a

Number of Sites Number of Reports Number of Discrete Chemicals b Type of Chemical Partial Full Partial Full Organic Chemicals Baseline 2,482 12,765 9,495 3,848 3,900 IUR Revisions Rule 2,482 12,775 9,485 3,858 3,890 Change 0 +10 -10 +10 -10 Inorganic Chemicals 2006 Submission Baseline 544 4,537 0 1,117 0 IUR Revisions Rule 544 4,537 0 1,117 0 Change 0 0 0 0 0 Future Submissions Baseline 544 2,300 2,236 488 629 IUR Revisions Rule 544 2,300 2,236 488 629 Change 0 0 0 0 0

a Petroleum process stream chemicals and certain specifically listed chemicals do not have to report processing and use

information regardless of production volume. Inorganic chemicals do not have to report processing and use information in the 2006 IUR submission, but in all future cycles are subject to the same 300,000-pound threshold for reporting this information as organic chemicals.
b These columns refer to the number of discrete chemicals for which partial reports and full reports are submitted.
Source: U.S. Environmental Protection Agency. August 2002. Economic Analysis for the Amended Inventory Update Rule, Final Report. Washington, DC: Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch.

2.2 Current IUR Rule Industry Compliance Costs The estimated wage rates, burden hours, and number of sites were combined to estimate the total compliance costs of the current IUR rule. For more detail on underlying calculations, see the economic analysis of the 2003 Amendments (EPA, 2002). Costs were estimated as either per site or per report, depending on the way the costs are incurred. Compliance determination and rule familiarization were estimated on a per-site basis, while report preparation and submission and recordkeeping were estimated on a per-report basis. Separate estimates were developed for organic and inorganic chemicals and for the two report types (full or partial form, based on production volume and exemption status). Tables 2-5 and 2-6 present the costs of the current IUR for organic and inorganic chemicals, respectively. The total costs to industry of the current IUR rule in the 2006 reporting cycle and for future reporting cycles are presented in Table 2-7, while Table 2-8 presents estimates of the total2-9 burden hours of the current IUR rule. Total industry compliance costs of the current IUR are estimated at $88.9 million to $113.6 million for the 2006 reporting cycle and $81 million to $103.4 million for future reporting cycles. Reporting burden is estimated to be 1, 300,000 to 1,658,000 hours for the 2006 reporting cycle and 1,189,000 to 1,516,000 hours for future reporting cycles.

Table 2-5. Industry Costs of the Current IUR Rule for Organic Chem icals (2000$)

Unit of Analysis Cost per Unit Number of Units Total Cost Low High Low High 2006 Submission Compliance Determination Site $65.96 $263.84 2,482 $163,710 $654,839 Rule Familiarization Site $1,951.66 $2,274.68 2,482 $4,844,032 $5,645,766 Report Preparation and Submission Report Partial Report $911.38 $1,366.70 12,765 $11,633,801 $17,445,878 Full Report Report $6,342.41 $7,228.54 9,495 $60,221,208 $68,634,970 Recordkeeping Report $254.84 $509.67 22,260 $5,672,661 $11,345,322 Total Cost of Current IUR $82,535,412 $103,726,775
Future Reporting Cycles Compliance Determination Site $65.96 $263.84 2,482 $163,710 $654,839 Rule Familiarization Site $323.02 $323.02 2,482 $801,734 $801,734 Report Preparation and Submission Partial Report Report $821.20 $1,229.93 12,765 $10,482,671 $15,700,042 Full Report Report $5,166.03 $5,919.40 9,495 $49,051,437 $56,204,726 Recordkeeping Report $254.84 $509.67 22,260 $5,672,661 $11,345,322 Total Cost of Current IUR $66,172,212 $84,706,662 Source: U.S. Environmental Protection Agency. August 2002. Economic Analysis for the Amended Inventory Update Rule, Final Report. Washington, DC: Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch.2-10 Table 2-6. Industry Costs of the Current IUR Rule for Inorganic Chem icals (2000$)

Unit of Analysis Cost per Unit Number of Units Total Cost Low High Low High 2006 Submission Compliance Determination Site $65.96 $263.84 544 $35,885 $143,540 Rule Familiarization Site $1,951.66 $2,274.68 544 $1,061,810 $1,237,550 Report Preparation and Submission Partial Report Report $911.38 $1,366.70 4,537 $4,134,623 $6,200,220 Full Report Report $6,342.41 $7,228.54 0 0 0 Recordkeeping Report $254.84 $509.67 4,537 $1,156,104 $2,312,207 Total Cost of Current IUR $6,388,422 $9,893,518
Future Reporting Cycles Compliance Determination Site $65.96 $263.84 544 $35,885 $143,540 Rule Familiarization Site $323.02 $323.02 544 $175,740 $175,740 Report Preparation and Submission Partial Report Report $821.20 $1,229.93 2,300 $1,888,980 $2,829,152 Full Report Report $5,166.03 $5,919.40 2,236 $11,553,261 $13,238,101 Recordkeeping Report $254.84 $509.67 4,537 $1,156,104 $2,312,207 Total Cost of Current IUR $14,809,970 $18,698,741 Source: U.S. Environmental Protection Agency. August 2002. Economic Analysis for the Amended Inventory Update Rule, Final Report. Washington, DC: Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch.

Table 2-7. Total Industry Costs of Current IUR Rule (million 2000$)
2006 Reporting Cycle Total Cost Future Reporting Cycles Total Cost Low High Low High Organic Chemicals $82.5 $103.7 $66.2 $84.7 Inorganic Chemicals $6.4 $9.9 $14.8 $18.7 Total Cost under Current IUR $88.9 $113.6 $81.0 $103.4 Source: U.S. Environmental Protection Agency. August 2002. Economic Analysis for the Amended Inventory Update Rule, Final Report. Washington, DC: Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch.2-11 Table 2-8. Total Industry Burden Hours of Current IUR Rule (thousands of hours)
2006 Reporting Cycle Burden Hours (thousands) Future Reporting Cycles Burden Hours (thousands) Low High Low High Organic Chemicals 1,206 1,514 972 1,242 Inorganic Chemicals 94 144 217 274 Total Burden of Current IUR 1,300 1,658 1,189 1,516 Source: U.S. Environmental Protection Agency. August 2002. Economic Analysis for the Amended Inventory Update Rule, Final Report. Washington, DC: Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch.
2.3 Changes in Industry Costs Due to the IUR Revisions Rule The expected cost impacts of each of the revisions to the IUR rule are described below. See Chapter 1.4 for more information about each of the revisions under the IUR Revisions Rule. Change Reporting Frequency . The current IUR rule requires reporting every four years. The next reporting year will be 2005, with the submission period in 2006 (i.e., data for the calendar year 2005 are due to be submitted to EPA in 2006). Under the revisions, the reporting frequency will be changed from every four years to every five years after 2005. Instead of occurring in 2009, the next reporting year would be delayed until 2010 (i.e., five years after the 2005 reporting year). The submission period would continue to occur during the year following the reporting year (e.g., 2011, 2016). This change would substantially lower the present value of reporting costs over time. Over a twenty year period, extending the reporting frequency from four years to five years is expected to reduce the present value of industry costs by $59.3 million to $75.7 million using a 3 percent discount rate and $41.2 million to $52.6 million with a 7 percent discount rate. The annualized costs decline by $4.0 million to $5.1 million per year using a 3 percent discount rate and $3.9 million to $5.0 million per year using a 7 percent discount rate.
Move Submission Period. The revisions will move the submission period for reporting from the end of the calendar year (August through December) to the middle (June through September). The August through December submission period was originally chosen because many companies’ fiscal years end in July, such that starting the IUR submission period in late August allowed these companies to report their most current information in the most timely manner possible. However, because the 2003 Amendments changed the basis for reporting from a fiscal-year to calendar-year basis, an earlier submission period is considered more appropriate because it would allow sites to submit their information closer to the period during which it was generated. Because the data are required approximately the same amount of time after the period for which data are collected, EPA does not expect this change to result in incremental costs to industry submitters.2-12 Clarify “Low Current Interest” Partial Exemption Process . EPA is clarifying that a request for listing or delisting a chemical from the partial exemption must contain a written rationale or justification for the request, such that the request should provide sufficient information for the Agency to make a ruling on the petition. This clarification may result in a small incremental burden for some companies that choose to file a petition, but EPA expects the total cost to be minimal. The clarification will help the Agency make its decision in a more expedient manner. By making a petitioner’s intent clearer, it may also increase the chance of the petition being granted by EPA. Companies submitting a petition presumably expect a net savings from their action (because they will no longer have to report processing and use information for the chemical if the petition is granted.) Industry savings due to an increased likelihood of petitions being accepted have not been estimated for this revision. Partially Exempt Additional Petroleum Process Streams . The revisions will add 27 petroleum process streams to the list of partially exempt chemical substances. Based on recent IUR reporting cycles, there have been an average of only about 10 reports total per reporting year filed across all 27 of these chemical substances. The difference between the average cost of submitting a full report and a partial report is $5,431 to $5,862 in the 2006 submission period and $4,345 to $4,690 in future submission periods. Thus, partial exemptions for these petroleum process streams will result in an annual savings of about $54,310 to $58,618 in the 2006 submission period and $43,448 to $46,895 in future submission periods. Over a twenty year period, the present value of the savings is $147,578 to $157,344 using a 3 percent discount rate and $115,067 to $122,327 using a 7 percent discount rate. The annualized savings are $9,920 to $10,576 per year and $10,862 to $11,547 per year using a 3 percent and a 7 percent discount rate, respectively. Consumer and Commercial Product Categories. This change only slightly redefines the categories that submitters can use to identify product categories for the chemical substances they produce or import and is not expected to result in any change in costs. Report Manufactured and Imported Volumes Separately. The revisions will require separate reporting of manufactured and imported volumes. This is expected to result in only a negligible change in incremental burden. This information was reported separately prior to the 2003 Amendments. It is expected that these values are readily available. If this change were not made, it is likely that submitters would continue to calculate these values separately, and then would add them together to generate an estimate of total production volume. Report Processing and Use Information for Domestic Uses Only. This revision is expected to substantially reduce the burden a ssociated with submission of full reports. Approximately 15 percent of the total value of production plus imports in the chemical industry is exported (ACC, 2003). Thus, the estimated burden for reporting IUR processing and use information (Section III of Form U) for an average report was reduced by 15 percent to reflect2-13 the savings from the revision. This change results in a savings of $7.8 million to $8.4 million for the 2006 submission period and $7.7 million to $8.3 million in future submission periods. Over a twenty year period, the present value of the savings is $24.4 million to $26.3 million using a 3 percent discount rate and $18.7 million to $20.1 million using a 7 percent discount rate. The annualized savings are $1.6 million to $1.8 million per year using a 3 percent discount rate and $1.8 million to $1.9 million per year using a 7 percent discount rate. Update Polymer Exemption Reference. The IUR Revisions Rule will adjust the polymer definition to refer to the current Master Inventory File rather than the 1985 version of the Inventory. This change is not expected to affect the costs of the IUR. Remove CBI Determination for Production Volume Ranges. The 2003 Amendments to the IUR Revisions Rule required submitters to determine whether production volume should be considered CBI if presented as a specified range instead of as a point estimate. EPA is now repealing this requirement. The Agency has determined that this provision is not likely to result in greater availability of production volume information to the public, which was the goal. It is important to note that EPA is not lessening any CBI protections with this change. This change will result in a negligible decrease in burden and cost. In summary, as shown in Table 2-9, the revisions that are expected to have a significant impact on costs are the changes to the reporting frequency, the addition of 25 petroleum process streams to the list of partial exemptions, and the restriction of processing and use reporting requirements to domestic uses only. All three of these changes reduce reporting costs. Table 2-9. Change in Industry Costs Due to IUR Revisions Rule
Revision Change in Industry Reporting Costs Change Reporting Frequency $4 to $5.1 million/yr in savings at 3% discount rate $3.9 to $5 million/yr in savings at 7% discount rate Move Submission Period Negligible change Clarify “Low Current Interest” Partial Exemption Process Negligible change
Partially Exempt 27 Petroleum Process Streams $0.01 million/yr in savings at 3% and 7% discount rate Change Consumer & Commercial Product Categories No change Report Manufactured & Imported Volumes Separately Negligible change Report Process and Use Information for Domestic Uses Only $1.6 to $1.8 million/yr in savings at 3% discount rate $1.8 to $1.9 million/yr in savings at 7% discount rate Update Polymer Exemption Reference No change Remove CBI Determination for Production Volume Ranges Negligible change2-14 2.4 Industry Savings Due to the IUR Revisions Rule Based on the information provided in Tables 2-2, 2-3, and 2-4, Tables 2-10 and 2-11 summarize the industry costs under the IUR Revisions Rule for organic and inorganic chemicals, respectively. The total industry costs are summarized in Table 2-12, while Table 2-13 presents the estimated total burden hours. The total industry costs after the IUR Revisions Rule are estimated at $81.1 million to $105.2 million for the 2006 reporting cycle and $73.3 million to $95.1 million for future reporting cycles. The reporting burden is estimated at 1, 187,000 to 1,535,000 hours for the 2006 reporting cycle and 1,077,000 to 1,395,000 hours for subsequent reporting cycles. Table 2-10. Industry Costs for Organic Chemicals After the IUR Revisions Rule (2000$)

Unit of Analysis Cost per Unit Number of Units Total Cost Low High Low High 2006 Submission Compliance Determination Site $65.96 $263.84 2,482 $163,710 $654,839 Rule Familiarization Site $1,951.66 $2,274.68 2,482 $4,844,032 $5,645,766 Report Preparation and Submission Report Partial Report $911.38 $1,366.70 12,775 $11,642,915 $17,459,545 Full Report Report $5,527.76 $6,349.26 9,485 $52,430,786 $60,222,749 Recordkeeping Report $254.84 $509.67 22,260 $5,672,661 $11,345,322 Total Cost after IUR Revisions $74,754,104 $95,328,221
Future Reporting Cycles Compliance Determination Site $65.96 $263.84 2,482 $163,710 $654,839 Rule Familiarization Site $323.02 $323.02 2,482 $801,734 $801,734 Report Preparation and Submission Partial Report Report $821.20 $1,229.93 12,775 $10,490,883 $15,712,341 Full Report Report $4,514.30 $5,215.98 9,485 $42,818,178 $49,473,583 Recordkeeping Report $254.84 $509.67 22,260 $5,672,661 $11,345,322 Total Cost after IUR Revisions $59,947,166 $77,987,819
The incremental costs of the IUR Revisions Rule are calculated by subtracting the current IUR costs from the estimated cost of the revised rule. Many of the revisions are expected to have no measurable impact on the costs of reporting, but provisions to extend the reporting cycle from four years to five years and to allow submitters to exclude exported volumes when reporting processing and use information will result in a considerable industry savings.2-15 Table 2-11. Industry Costs for Inorganic Chemicals After the IUR Revisions Rule (2000$)

Unit of Analysis Cost per Unit Number of Units Total Cost Low High Low High 2006 Submission Compliance Determination Site $65.96 $263.84 544 $35,885 $143,540 Rule Familiarization Site $1,951.66 $2,274.68 544 $1,061,810 $1,237,550 Report Preparation and Submission Partial Report Report $911.38 $1,366.70 4,537 $4,134,623 $6,200,220 Full Report Report $5,527.76 $6,349.26 0 0 0 Recordkeeping Report $254.84 $509.67 4,537 $1,156,104 $2,312,207 Total Cost after IUR Revisions $6,388,422 $9,893,518
Future Reporting Cycles Compliance Determination Site $65.96 $263.84 544 $35,885 $143,540 Rule Familiarization Site $323.02 $323.02 544 $175,740 $175,740 Report Preparation and Submission Partial Report Report $821.20 $1,229.93 2,300 $1,888,980 $2,829,152 Full Report Report $4,514.30 $5,215.98 2,236 $10,095,752 $11,664,976 Recordkeeping Report $254.84 $509.67 4,537 $1,156,104 $2,312,207 Total Cost after IUR Revisions $13,352,461 $17,125,616

Table 2-12. Total Industry Costs After the IUR Revisions Rule (million 2000$)
2006 Reporting Cycle Total Cost Future Reporting Cycles Total Cost Low High Low High Organic Chemicals 74.8 95.3 59.9 78.0 Inorganic Chemicals 6.4 9.9 13.4 17.1 Total Cost after IUR Revisions 81.1 105.2 73.3 95.12-16 Table 2-13. Total Industry Burden Hours After the IUR Revisions Rule (thousands of hours) 2006 Reporting Cycle Burden Hours (thousands) Future Reporting Cycles Burden Hours (thousands) Low High Low High Organic Chemicals 1,093,000 1,391,000 881,000 1,144,000 Inorganic Chemicals 94,000 144,000 196,000 251,000 Total Burden after IUR Revisions 1,187,000 1,535,000 1,077,000 1,395,000 Source: U.S. Environmental Protection Agency. August 2002. Economic Analysis for the Amended Inventory Update Rule, Final Report. Washington, DC: Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch.

Table 2-14 calculates the savings due to the IUR Revisions Rule over a twenty year period. The present value of industry savings is expected to be $83.6 million to $101.9 million using a 3 percent discount rate and $59.8 million to $72.7 million with a 7 percent discount rate. The annualized savings are $5.6 million to $6.9 million per year and $5.6 million to $6.8 million per year using 3 percent and 7 percent discount rates, respectively.2-17 Table 2-14. Flow of Industry Savings Due to IUR Revisions Rule Over 20 Years (million 2000$)

Year Costs Under Current IUR Costs After IUR Revisions Rule Savings Due to IUR Revisions Rule Low High Low High Low High 1 $88.9 $113.6 $81.1 $105.2 $7.8 $8.4 2 0.0 0.0 0.0 0.0 0 0 3 0.0 0.0 0.0 0.0 0 0 4 0.0 0.0 0.0 0.0 0 0 5 $81.0 $103.4 0.0 0.0 $81.0 $103.4 6 0.0 0.0 $73.3 $95.1 –$73.3 –$95.1 7 0.0 0.0 0.0 0.0 0 0 8 0.0 0.0 0.0 0.0 0 0 9 $81.0 $103.4 0.0 0.0 $81.0 $103.4 10 0.0 0.0 0.0 0.0 0 0 11 0.0 0.0 $73.3 $95.1 –$73.3 –$95.1 12 0.0 0.0 0.0 0.0 0 0 13 $81.0 $103.4 0.0 0.0 $81.0 $103.4 14 0.0 0.0 0.0 0.0 0 0 15 0.0 0.0 0.0 0.0 0 0 16 0.0 0.0 $73.3 $95.1 –$73.3 –$95.1 17 $81.0 $103.4 0.0 0.0 $81.0 $103.4 18 0.0 0.0 0.0 0.0 0 0 19 0.0 0.0 0.0 0.0 0 0 20 0.0 0.0 0.0 0.0 0 0 3 Percent Discount Rate

Present Value $322.4 $411.7 $238.8 $309.8 $83.6 $101.9

Annualized $21.7 $27.7 $16.1 $20.8 $5.6 $6.9 7 Percent Discount Rate

Present Value $244.1 $311.8 $184.3 $239.1 $59.8 $72.7

Annualized $23.0 $29.4 $17.4 $22.6 $5.6 $6.82-18 2.5 EPA Savings Due to the IUR Revisions Rule EPA costs for the IUR rule include costs attributable to systems development, document processing, contract oversight and management, and publication of forms and materials. The Agency costs under the current IUR rule are estimated to be $310,980 in annual costs incurred in every calendar year, and an additional $270,249 in recurring costs incurred in each submission year, as well as $214,763 in one-time costs related to changes in the 2003 Amendments (assumed to be incurred for the 2006 submission year). The economic analysis of the 2003 Amendments (EPA, 2002) provides more detailed information on the estimated Agency costs for the IUR rule. Extending the reporting cycle will result in a lower present value of Agency costs over time. Table 2-15 shows the flow of Agency compliance costs under the current and revised IUR rule. For a 20-year period, the present value of Agency costs is estimated to decline by $197,801 using a 3 percent discount rate or $137,365 using a 7 percent discount rate. Annualized Agency costs are reduced by $13,296 and $12,966 using a 3 percent and 7 percent discount rate, respectively.2-19 Table 2-15. Flow of EPA Savings Due to the IUR Revisions Rule Over 20 Years (2000$)

Year Costs Under Current IUR Costs After IUR Revisions Rule Savings Due to IUR Revisions Rule 1 $795,992 $795,992 0 2 $310,890 $310,890 0 3 $310,890 $310,890 0 4 $310,890 $310,890 0 5 $581,229 $310,890 $270,339 6 $310,890 $581,229 -$270,339 7 $310,890 $310,890 0 8 $310,890 $310,890 0 9 $581,229 $310,890 $270,339 10 $310,890 $310,890 0 11 $310,890 $581,229 -$270,339 12 $310,890 $310,890 0 13 $581,229 $310,890 $270,339 14 $310,890 $310,890 0 15 $310,890 $310,890 0 16 $310,890 $581,229 -$270,339 17 $581,229 $310,890 $270,339 18 $310,890 $310,890 0 19 $310,890 $310,890 0 20 $310,890 $310,890 0 3 Percent Discount Rate Present Value $5,885,257 $5,687,456 $197,801

Annualized $395,582 $382,286 $13,296 7 Percent Discount Rate Present Value $4,285,188 $4,147,823 $137,365

Annualized $404,491 $391,525 $12,966
2.6 Total Savings Due tothe IUR Revisions Rule As shown in Table 2-16, combining the incremental industry and EPA savings due to the IUR Revisions rule results in an estimate that the present value of savings over the next 20 years will be between $83.8 million and $102.1 million using a 3 percent discount rate. For a 7 percent discount rate, the estimated savings are $59.9 million to $72.8 million. Annualized savings are $5.7 million to $6.9 million per year with a 3 percent discount rate and $5.6 million to $6.8 million per year using a 7 percent discount rate. Reporting burden, summarized in Table 2-17, is estimated to fall by 113,000 to 123,000 hours in the 2006 reporting cycle and 112,000 to 121,000 hours in subsequent reporting cycles.2-20 Table 2-16. Total Savings Due to the IUR Revisions Rule (million 2000$)
Industry EPA Total Low High Low High 3 Percent Discount Rate Present Value a $83.6 $101.9 $0.2 $83.8 $102.1 Annualized $5.6 $6.9 $0.01 $5.7 $6.9 7 Percent Discount Rate Present Value a $59.8 $72.7 $0.2 $59.9 $72.8 Annualized $5.6 $6.8 $0.01 $5.6 $6.8

a NPV determined for a 20-year period. Numbers do not add due to rounding.

Table 2-17. Burden Savings Due to the IUR Revisions Rule (thousands of hours)
2006 Reporting Cycle Burden Hours (thousands) Future Reporting Cycles Burden Hours (thousands) Low High Low High Current IUR 1,300 1,658 1,189 1,516 After IUR Revisions Rule 1,187 1,535 1,077 1,395 Burden Savings Due to IUR Revisions Rule 113 123 112 1213-1 CHAPTER 3 IMPACT OF THE IUR REVISIONS RULE ON THE BENEFITS OF THE IUR RULE

The IUR rule is one of EPA’s most important tools for meeting its mandate to manage the risks resulting from chemical production and use in the United States. It is EPA’s most comprehensive source of data on the chemical industry, and it is used in almost all of OPPT’s risk-screening and management programs. The IUR rule requires the collection and compilation of manufacturing, processing and use exposure-related information, which allows EPA to more accurately assess human and ecosystem exposures to specific chemicals, including the concentrations, frequency, and durations of these exposures. With this information, EPA is better able to screen chemicals to identify whether additional risk assessment and management steps are needed. The IUR enhances the data supplied to EPA’s risk-screening programs, which enables EPA to more effectively and expeditiously reduce the risks posed by chemicals. Enhancing the risk-screening process has positive consequences for human and ecosystem health and promotes more efficient use of EPA’s and society’s resources. Although the social benefits resulting from the IUR rule can extend to many facets of society, quantitative estimates of these benefits are not feasible because of data limitations.

The IUR Revisions Rule will decrease the benefits associated with IUR data somewhat by reducing the frequency of data collection after 2006 and providing partial exemptions to additional petroleum process streams. Extending the reporting cycle from four years to five years will delay the availability of updated data on IUR chemicals, thereby reducing the present value of the benefits of the IUR rule somewhat. However, EPA has determined that a five-year reporting cycle will provide sufficient data to meet the most critical information needs. The impact of exempting additional petroleum processes is expected to be minimal because these chemical substances have accounted for an extremely small number of IUR submissions in the last few reporting cycles (an average of 10 reports total per reporting cycle). Moving the submission period forward will have a small positive impact in that EPA will have more timely access to the data. None of the other changes will have an impact on the benefits of the data.4-1 CHAPTER 4 BENEFIT-COST ANALYSIS

Table 4-1 summarizes the changes in information obtained and costs incurred under the IUR Revisions Rule. It is estimated that approximately 26,800 forms w ill be submitted in each reporting cycle under both the current and revised IUR rule. In the next submission period (scheduled to occur in 2006 under both the current and revised IUR rule), about 9,500 (35 percent) will be full forms including both site and manufacturing and use and exposure data. The information provided in the IUR forms can enhance social welfare by improving the foundation for public and private decision-making related to risk management and by reducing the cost of obtaining information to support these decisions from other sources (EPA, 2002). The roughly 17,300 remaining forms (65 percent) w ill be partial forms reporting only site and manufacturing data. The proportion of full forms rises in future reporting cycles as inorganic chemicals become fully reportable. Once again, the number of reports received and the allocation between partial and full reports is expected to be very similar under the current and revised IUR rules. In future cycles, about 11,700 reports (44 percent) are expected to be full reports and approximately 15,100 (56 percent) w ill be partial reports. Based on data from recent reporting years, the addition of 25 petroleum process streams to the partial exemption list under the IUR Revisions Rule will only result in a reduction of about 10 full reports per submission period. In addition, submitters would no longer be required to submit processing and use information on exported chemicals, but that was not a priority area of information for EPA.

A key difference between the current IUR rule and the IUR Revisions Rule is that reports will be received less frequently (after the 2006 submission) under the revisions. To the extent that relevant information on these chemicals is changing substantially over time, this delay in receiving the data will reduce the benefits of the IUR rule. The more stable the data are over time, the smaller the potential reduction in benefits from extending the reporting cycle.

The annualized savings of the IUR Revisions Rule are estimated to be from $5.7 million to $6.9 million per year over the first 20 years of the rule using a 3 percent discount rate and $5.6 million to $6.8 million based on a 7 percent discount rate. Almost all of the savings accrue to companies submitting reports under the IUR rule. The remainder (approximately $13,000 per year, annualized using a 3 percent discount rate) is a reduction in EPA’s cost to periodically administer the data collection.4-2 As indicated throughout this report, the reductions in benefits associated with the revisions to the IUR rule are difficult to quantify and monetize. The inability to monetize the change in benefits impedes direct comparison to costs and calculation of net benefits. Nonetheless, EPA believes that these revisions significantly lower the costs of compliance without substantially diminishing the amount and quality of information for risk screening, prioritization, and management. Table 4-1. Benefits and Costs of the IUR Revisions Rule

Number of Reports Filed 2006 Reporting Cycle Future Reporting Cycles Total Partial Full Total Partial Full Current IUR rule 26,797 17,302 9,495 26,797 15,065 11,731 IUR Revisions Rule 26,797 17,312 9,485 26,797 15,075 11,721 Reduction in Information Available Ten fewer full reports for petroleum process streams are expected because of new chemical substances being added to partial exemption list. Processing and use information is no longer reported for exported chemical substances. In future reporting cycles, the information is received less frequently. To the extent that valuable information is changing substantially between reporting years, this delay in receiving information will tend to reduce the benefits of the IUR. Annualized Savings (2000$) Industry EPA Total Low High Low High 3 Percent Discount Rate $5.6 million $6.9 million $0.01 million $5.7 million $6.9 million 7 Percent Discount Rate $5.6 million $6.8 million $0.01 million $5.6 million $6.8 million5-1 CHAPTER 5 SMALL ENTITY AND ENVIRONMENTAL JUSTICE IMPACT DETERMINATIONS

The Regulatory Flexibility Act of 1980 requires federal agencies to assess the effects of regulations on small entities (P.L. 96-354). (The Act was later amended by the Small Business Regulatory Enforcement Fairness Act [SBREFA] of 1996.) The Act requires agencies to evaluate rulemakings to determine if an Initial Regulatory Flexibility Analysis (IRFA) or Final Regulatory Flexibility Analysis (FRFA) is necessary. This section examines whether such an analysis is needed for this rulemaking.

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, requires that each federal agency examine the effect of its regulations on minority and low-income populations and address disproportionately high and adverse human health or environmental effects. This section also examines the effect of the revisions to the IUR on minority and low-income populations. 5.1 Small Entity Analysis

The term “small entities” includes small businesses, small not-for-profit organizations, and small governmental jurisdictions, but because not-for-profit organizations and governmental jurisdictions will not be affected by this rule, “small entity” in this analysis is synonymous with small business. Sections 603 and 604 of the Regulatory Flexibility Act require the Agency to either certify that the regulatory action will not have a significant economic impact on a substantial number of small entities or prepare an IRFA or FRFA. These revisions are expected to reduce the present value and annualized cost of the IUR for small businesses. Thus, EPA concludes that these revisions will not result in significant adverse effects on a substantial number of small entities, and that no screening analysis or IRFA is required. The basis for determining that there is no significant economic impact is explained below.

Only rules that will have a significant adverse economic impact on small entities require an IRFA and FRFA, because the primary purpose of both analyses is to identify and address regulatory alternatives “which minimize any significant economic impact of the proposed [or final] rule on small entities” (5 CFR 603 and 604). Thus, rules that relieve regulatory burden, or otherwise have a positive economic effect on the small entities subject to the rule, do not require an IRFA or a FRFA. Because the purpose of a screening analysis is to determine if an IRFA or FRFA is needed, a screening analysis is also not required for burden reduction rules. This rulemaking5-2 reduces regulatory burden and has a positive economic effect on small entities, so no small entity analysis is needed to comply with the Regulatory Flexibility Act. 5.2 Environmental Equity/Justice

Executive Order 12898 requires that all federal agencies address the issue of environmental justice by identifying and revising programs, policies, and activities that may disproportionately and adversely affect the health of minority or low-income populations or their environments.

Because the IUR rule is an information collection exercise, the information that will become available through the rule will enable the Agency to target educational, regulatory, or enforcement activities towards industries or chemicals that pose the greatest risks and/or to target programs for geographic areas that are at the highest risk. Thus, the information to be gathered under the rule will help EPA make decisions that will benefit potentially at-risk communities, some of which may be disadvantaged. Extending the reporting frequency after 2006 w ill reduce the availability of this valuable information somewhat. However, EPA expects that it will continue to meet its most critical data needs and that any reductions in benefits relative to the current IUR rule will be minimal.R-1 REFERENCES

American Chemistry Council (ACC). 2003. “Guide to the Business of Chemistry 2003.” Arlington, VA. American Petroleum Institute (API). 1983. “Petroleum Process Stream Terms Included in the Chemical Substance Inventory Under the Toxic Substances Control Act (TSCA).” Washington, DC. Bureau of Labor Statistics (BLS). 2000. Employment Cost Index. <www.bls.gov>. As obtained April 28, 2000. Chemical Update System (CUS) Database. 2000. Information from the Chemical Update System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U.S. Environmental Protection Agency, Washington, DC. Federal Register. December 23, 1977. 42 FR 64572. Federal Register. June 12, 1986. 51 FR 21447. Federal Register. January 7, 2003. 68 FR 848. U.S. Environmental Protection Agency. April 1997a. Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313 . Washington, DC: Office of Pollution Prevention and Toxics, Regulatory Impacts Branch. U.S. Environmental Protection Agency. 1997b. UEIP-ICR Database. Summary table. U.S. Environmental Protection Agency. August 2002. Economic Analysis for the Amended Inventory Update Rule, Final Report. Washington, DC: Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch.A-1 FOR EPA USE ONLY Report Number

Mark "X" here if this is a revision to the previous report PAGE 1 of ____ (IMPORTANT: Type only, read instructions before completing form) U.S. Environmental Protection Agency Washington, DC 20460 Partial Updating of TSCA Inventory Data Base Site Report (Section 8(a) Toxic Substances Control Act, 15 U.S.C. 2607(a)) CERTIFICATION

Certification Statement: I hereby certify to the best of my knowledge and belief that Parts I and II have been completed in compliance with the requirements of 40 CFR 710.52(c)(1), (2), and (3); Part III of this form has been completed in compliance with the requirements of 40 CFR 710.52(c)(4); and the confidentiality statements at the end of this form are true and correct as to that information for which a confidentiality claim has been asserted.
Signature Date signed

Name (printed) Official Title
PART I. SITE IDENTIFICATION INFORMATION SECTION A. COMPANY INFORMATION*
1.A.1 Company Name
1.A.2 Company Dun & Bradstreet Number

SECTION B. SITE INFORMATION*

1.B.1 Site Name

1.B.2 Site Dun & Bradstreet Number EPA Facility Identification Number LEAVE BLANK

1.B.3 Street Address (Line 1)
1.B.4 Street Address (Line 2)
1.B.5 City 1.B.6 County / Parish
1.B.7 State 1.B.8 Zip Code

SECTION C. TECHNICAL CONTACT INFORMATION*

1.C.1 Name 1.C.2 Telephone

1.C.3 Email Address
1.C.4 Mailing Address (Line 1)
1.C.5 Mailing Address (Line 2)
1.C.6 City 1.C.7 State 1.C.8 Zip Code
* Confidentiality claims for information in Part I, Sections A, B, and C, are made for each chemical substance on subsequent p ages. EPA Form Number <XXXX-X> (Rev 03/31/05) - Previous editions are obsolete FORM U 

### 2006A-2 Form Approved OMG Number :XX/X-XXXXA-3 Page ___ of ___
PART II. MANUFACTURING INFORMATION SECTION A. CHEMICAL IDENTIFICATION CBI 2.A.1 Chemical Identifying Number 2.A.2 ID Code

2.A.3 Chemical Name

SECTION B. MANUFACTURING INFORMATION CBI a. Physical Form b. Percent of Production 2.B.1 Company Information Volume in Each Physical Form
2.B.2 Site Information Check All 2.B.3 Technical Contact Information That Apply CBI Percent CBI 2.B.4 Site Limited (Y/N) 2.B.10 Dry Powder 2.B.5 Activity (Check all that apply) G Manufacture G Import 2.B.11 Pellets or Large Crystals 2.B.6 Manufactured Production Volume (LB) 2.B.12 Water or Solvent Wet Solid 2.B.7 Imported Production Volume (LB) 2.B.13 Other Solid
2.B.8 Number of Workers (code) 2.B.14 Gas or Vapor 2.B.9 Maximum Concentration (code) 2.B.15 Liquid

PART III. PROC ESSING AND USE INFORMATION Complete Part III, Sections A and B if the sum of the production volumes noted in Blocks 2.B.6 and 2.B.7 is 300,000 pounds or m ore. SECTION A. INDUSTRIAL PROCESSING AND USE DATA N/A a. Type of Process or Use b. (5-digit) NAICS Code c. Industrial Function Category d. Percent Production

Volume e. Number of Sites f. Number of Workers
Code CBI Code CBI Code CBI Percent CBI Code CBI Code CBI 3.A.1 3.A.2 3.A.3 3.A.4 3.A.5 3.A.6 3.A.7 3.A.8 3.A.9 3.A.10
SECTION B. COMMERCIAL AND CONSUMER USE DATA N/A a. Commercial and Consumer Product Category b. Used in Products Intended for Children c. Percent Production Volume associated with each category d. Maximum Concentration associated with each category Code CBI Y/N/NRO CBI Percent CBI Code CBI 3.B.1 3.B.2 3.B.3 3.B.4 3.B.5 3.B.6 3.B.7 3.B.8 3.B.9 3.B.10 Substantiation required for CBI claims on chemical identity and site information. FOR EPA USE ONLY