Systems Development $ 100,505 Hardware & Software $ 8,464 Guidance Document Development $ 105,794 Subtotal $ 214,763 Additional Tasks Hotlinea $ 31,738 Mailinga $ 5,396 Subtotal $ 37,134 Total One Time Cost $ 305,470 Note: All costs associated with FTEs include 41 percent fringe benefits and 17 percent overhead.

a These costs are the costs that will be incurred in the first reporting cycle under the IURA. No incremental costs are expected for these tasks in subsequent cycles.

Sources: U. S. Environmental Protection Agency. April 1997a. Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313. Office of Pollution Prevention and Toxics, Regulatory Impacts Branch.

Information Management Division ( IMD). 1996. Questions for Branches within OPPT with Responsibility for IUR Data Collection, Processing, and Storage. Information Management Division, U. S. Environmental Protection Agency, Washington, DC.

U. S. Environmental Protection Agency. July 30, 1996b. IUR Amendments   Agency Costs Question. Memorandum from Ward Penberthy to Susan Krueger, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency.

Office of Personnel Management ( OPM). 2000. " 2000 General Schedule Locality Notes of Pay for Washington Baltimore, DC MD VA WV." < http:// www. opm. gov/ oca/ 2000tbls/ GSannual/ html/ GSDCB. HTM>. As obtained on May 30, 2000. 3 37 Table 3 23. Flow of Agency Costs Over the Next 20 Years ( 2000$) under Amendments Year Cost Year Cost 1 $ 575,719 14 $ 0 2 $ 0 15 $ 0 3 $ 0 16 $ 0 4 $ 0 17 $ 270,249 5 $ 270,249 18 $ 0 6 $ 0 19 $ 0 7 $ 0 20 $ 0 8 $ 0 3 Percent Discount Rate 9 $ 270,249 Present Value $ 1,346,774 10 $ 0 Annualized Cost $ 90,524 11 $ 0 7 Percent Discount Rate 12 $ 0 Present Value $ 1,075,434 13 $ 270,249 Annualized Cost $ 101,513 3 38 Table 3 24. Measures of Incremental Social Costs ( both Industry and Agency Costs) Associated with Amendment Options ( million 2000$)

Option First Year Cost Net Present Valuea Annualized Cost Low High Low High Low High 3 Percent Discount Rate Threshold Options 1a  Draft Finalb 74.4 89.5 290.4 347.3 19.5 23.3 1b  Selected Finalb 72.9 88.0 259.4 311.1 17.4 20.9 2 91.7 103.7 363.6 411.6 24.4 27.7 3 67.7 77.8 262.1 302.0 17.6 20.3 4 59.7 69.1 227.7 264.9 15.3 17.8 5 67.7 77.8 340.4 386.5 22.9 26.0 Reporting Exemption Option 6 85.3 95.2 293.9 330.1 19.8 22.2 Reporting Cycle Options 7 91.7 103.7 708.7 802.3 47.6 53.9 8 91.7 103.7 89.0 100.7 6.0 6.8 7 Percent Discount Rate Threshold Options 1a  Draft Finalb 74.4 89.5 218.3 261.2 20.6 24.7 1b  Selected Finalb 72.9 88.0 196.8 236.2 18.6 22.3 2 91.7 103.7 273.0 309.0 25.8 29.2 3 67.7 77.8 197.2 227.2 18.6 21.4 4 59.7 69.1 171.6 200.0 16.2 18.. 8 5 67.7 77.8 250.6 284.8 23.6 26.9 Reporting Exemption Option 6 85.3 95.2 223.7 251.1 21.1 23.7 Reporting Cycle Options 7 91.7 103.7 513.5 581.3 48.5 54.9 8 91.7 103.7 85.7 96.9 8.1 9.1 a NPV determined for a 20 year period. b Option 1a represents the draft final option included in the initial submission for interagency review. Option 1b is the final option that was promulgated. EPA removed a CBI reassertion requirement and added a partial exemption for specific chemicals based on low current interest in processing and use data for those chemicals. All options other than 1b include CBI reassertion and do not include the partial exemption for specific chemicals. 4 1 SECTION 4 THE BENEFITS OF THE IURA As discussed in Section 2, neither EPA nor the public has access to the information that is needed to most effectively and accurately identify chemical risks from production or use in the United States. Screening chemicals according to these potential risks is an essential first step in developing and prioritizing risk management activities. Effective risk screening depends critically on the ability to characterize chemical uses and to predict potential exposures; however, current screening activities are greatly hampered by their reliance on production volume estimates and on relatively scarce public sources of information. This rule will benefit society by filling this information void and contributing to better assessments of potential risks and risk management decisions.

Currently, the IUR is one of EPA's most important tools for meeting its mandate ( under TSCA)

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. However, the IUR data in their current form are limited, and this in turn limits EPA's effectiveness in meeting its TSCA mandate. The amendments will reduce many of these data constraints and, as a result, improve the effectiveness of EPA's chemical risk management programs.

Most importantly, the new IUR rule will require the collection and compilation of additional manufacturing, processing, use, and exposure related information. This additional information will allow EPA to more accurately assess human and ecosystem exposures to specific chemicals, including the concentrations, frequency, and durations of these exposures. With this additional information, EPA will be able to better screen chemicals to identify whether additional risk assessment and management steps are needed. By enhancing the data supplied to EPA's risk screening programs, EPA expects to more effectively and expeditiously reduce the risks posed by chemicals. Ultimately, enhancing the risk screening process will have positive consequences for human and ecosystem health, and will use EPA's and society's resources more efficiently.

Additional benefits will accrue from changes in reporting requirements that will improve consistency and compatibility with other EPA databases. EPA also expects more publicly available non CBI information and an increased ability to anticipate industry trends, particularly for chemicals about which EPA has concerns. Finally, in an effort to better target information gathering efforts, the rule removes one reporting exemption while adding reporting exemptions in other areas.

The social benefits resulting from the IURA are qualitatively discussed in this section. Unfortunately, quantitative estimates of these benefits are not feasible due to data limitations. This section first defines a conceptual framework for evaluating the benefits of public information based programs such as the IURA. The section then applies this framework to identify and describe the types of benefits that will accrue from the different components of the rule. 4 2 4.1 Benefits of Information Based Policies In assessing the benefits of information based policies such as this rule, it is important to identify the primary ways through which the public provision of information yields benefits for society. In general, increasing the amount and quality of publicly available information has two effects:

 It reduces the costs of making decisions.

 It improves the expected outcomes of these decisions.

In the first case, policies that make new information about toxic substances available to the public ( including EPA) can serve to replace other information gathering, management, and dissemination activities related to toxic substances. In so doing, they allow information users ( i. e., decisionmakers) to avoid some of the time and resource costs devoted to these activities. In effect, they increase the efficiency of the decisionmaking process.

In the second case, information based policies contribute to better decisions, by redirecting resources towards their most highly valued uses. With incomplete information regarding toxic substances, public and private decisionmakers are not able to adequately assess the benefits and costs of actions that involve these substances. For example, EPA decisions regarding whether, when, and how to target chemicals for further risk assessment can be misdirected if basic risk screening information is not available or adequate. Improved information can therefore help lead to more socially optimal reductions in risks to humans and the environment because EPA can better direct its limited resources toward higherpriority risks.

As discussed in more specific terms in the remainder of this section, the rule will generate both kinds of benefits. First, it will reduce EPA's ( and other decisionmakers') reliance on other databases and information sources that are ill suited and inadequate for accurately and efficiently characterizing the risks associated with the thousands of chemicals in commerce that need to be evaluated. As discussed in previous sections, EPA will bear additional costs for collecting and managing the new IUR data;

however, by providing more reliable and complete data on chemical uses and exposures, the rule will also allow EPA to save time and resources in screening chemicals and in developing risk management priorities. Furthermore, by improving the consistency and compatibility of IUR data relative to other datasets used in evaluating chemical risks, the rule will reduce the costs of using the IUR data themselves.

Second, it will allow EPA to better prioritize its risk management activities   to move more quickly in addressing chemicals that pose relatively high risks ( and/ or relatively low risk management costs).

In assessing the benefits of information based policies, it is also important to distinguish between and identify  who uses the information,

 how the information is used, and  who benefits ( or loses) from these uses.

These distinctions emphasize that the ultimate beneficiaries of these policies will extend well beyond those who disseminate the information or who use it in their own decisionmaking. In the case of this rule, 1Appendix B describes databases and literature sources commonly reviewed by EPA.

4 3 EPA will be the primary user of the new information, although other public and private organizations, in particular those with interests in managing chemical risks, will also use the data. The information is expected to be applied and disseminated by these users in a number of ways; however, it will primarily serve to reduce the costs of screening and managing chemical risks and to improve risk management decisions.

The American public will be the ultimate beneficiaries of the amended IUR. By lowering the cost of decisionmaking in the public sector, the rule will free up resources for other public or private uses. Similar gains will also result from cost savings in private sector decisionmaking. By improving risk management decisions, the rule will also help to better target risk management activities to the areas where the net benefits ( i. e., risk reductions net of control costs) are expected to be the largest.

4.2 Benefits from Processing and Use Data The processing and use data collected through these amendments will fill an important information void. Currently, EPA and the general public, including other public and private organizations, have very limited access to this type of data1. Processing and use data will most importantly allow EPA to improve its chemical screening and risk management activities. The Agency will be able to more quickly and efficiently identify the chemicals posing the greatest potential risks and to more effectively prioritize, design, and implement chemical management programs. EPA will also be able to disseminate this previously unavailable ( non CBI) information and to make its findings, based on analyses of these data, available to other agencies and the public. This will promote better risk management decisions by these groups as well.

In addition to supporting the specific programs mentioned below, it must be emphasized that IUR data provide the informational foundation for a wide variety of OPPT analyses and decisions. The additional data collected through the IURA will further enhance this role. The IUR is EPA's primary window into the chemical industry, the industry OPPT is charged with regulating under TSCA. The use of current IUR data on a daily basis to answer a myriad of questions is widespread within EPA and within OPPT specifically. With expanded information available on many chemicals, the quality of various EPA actions will improve accordingly. A recent example of how expanded IUR data would be valuable for use on a more as needed basis is presented in Box 4 1.

As shown in Table 4 1, EPA has considered different chemical production thresholds above which facilities will be required to submit processing and use information under the IUR. These thresholds vary across options from 100,000 pounds to 1 million pounds per year; however, the selected option will require reporting for chemicals with production volumes above 300,000 pounds. Clearly, the amount of information collected would be greater with lower thresholds because more facilities and more chemicals would exceed the threshold. 4 4 Box 4 1. An Example of How the Amended IUR Data can be Useful in Supporting EPA's Dayto Day Operations In late 1999, a chemical importer received a shipment of zinc sulfate from China that was contaminated with cadmium. The zinc sulfate was distributed as a raw material for the production of fertilizer and animal feed in Washington, California, and Idaho. Such use could result in occupational exposure to workers producing agricultural products, or even in consumer or livestock exposures from food or animal feed. Cadmium exposure can cause flulike symptoms and has been linked to lung cancer and kidney disease. If EPA had the type of processing and use information that will be collected under the IURA, the Agency would have been able to identify and contact potential importers and downstream users of the chemical sooner and thus contain the potential exposures more quickly. As it was, the Agency was forced, at least in part, to rely on data from the U. S. Customs Service. This process was time consuming because the Customs Service generally does not divulge this type of information.

Table 4 1. Options Considered for the IURA Option # Thresholds Reporting Cycles Site and Manufacturing Information Processing and Use Information Site and Manufacturing Information Processing and Use Information Threshold Options 1a  Draft Finala 25,000 lbs 300,000 lbs 4 yrs. 4 yrs.

1b  Selected Finala 25,000 lbs 300,000 lbs 4 yrs. 4 yrs.

2 25,000 lbs 100,000 lbs 4 yrs. 4 yrs.

3 25,000 lbs 500,000 lbs 4 yrs. 4 yrs.

4 25,000 lbs 1,000,000 lbs 4 yrs. 4 yrs.

5 25,000 lbs 500,000 lbs/ 100,000 lbs 4 yrs. 4 yrs.

Reporting Exemption Optionb 6 25,000 lbs 100,000 lbs 4 yrs. 4 yrs.

Reporting Cycle Options 7 25,000 lbs 100,000 lbs 2 yrs. 2 yrs.

8 25,000 lbs 100,000 lbs one time one time a Option 1a represents the draft final option included in the initial submission for interagency review. Option 1b is the final option that was promulgated. EPA removed a CBI reassertion requirement and added a partial exemption for specific chemicals based on low current interest in processing and use data for those chemicals. All options other than 1b include CBI reassertion and do not include the partial exemption for specific chemicals. b Inorganic chemicals are fully exempt from reporting. 4 5 As discussed below, it is very difficult to quantify and monetize the benefits of this additional information; however, historical data on IUR submissions do allow rough approximations of how the number of chemicals reported would vary under alternative thresholds. EPA estimates that the number of chemicals with reported processing and use data in the first reporting cycle will be roughly 5,450 chemicals under a 100,000 pound threshold. The number will decrease by about 28 percent to about 3,900 chemicals under the selected option of 300,000 pounds, and to about 2,700 chemicals with a 1 million pound threshold. Eliminating the exemption on inorganic chemicals in future reporting cycles will further increase the number of chemicals reporting processing and use data. For the 100,000,

300,000 and 1 million pound thresholds, EPA estimates that processing and use data would be reported for 850, 630, and 440 inorganic chemicals, respectively. In choosing the 300,000 pound threshold, EPA has concluded that this will provide the optimal balance between achieving its information needs and not imposing overly burdensome reporting requirements on IUR submitters. Collection of this level of data will provide valuable input to risk screening activities, streamlining EPA's efforts to correctly identify chemicals needing further review and subsequently improving later risk management efforts.

The following sections review EPA's current risk screening programs and chemical management programs conducted through OPPT. They describe how these programs will use the enhanced information and how the public will gain. They also describe how other programs and other agencies can use the information to benefit the general public.

4.2.1 Benefits through OPPT Risk Screening and Management Programs OPPT has a multifaceted approach to managing chemical risks. Chemicals enter OPPT's system primarily through a request by the Interagency Testing Committee or a request by the public. The chemicals then go through one of several more detailed screening programs, such as the Use Cluster Scoring System ( UCSS). Depending on the outcome of these screening processes, the next step may include entering one of EPA's risk management programs. Each of these phases and the benefits derived from the new processing and use information are examined below.

<IP_ADDRESS> Risk Screening Programs Risk screening is a critical first step in prioritizing chemicals for further evaluation and for risk management. By design, it is less detailed and data intensive than risk assessment, but nonetheless it requires adequate information for comparing potential risks across a large group of chemicals. Ideally, such information would include a characterization of the chemical's toxicity as well as indicators of human and ecosystem exposures to the chemical, including the level of exposure and the size of the exposed population. In these efforts, OPPT currently relies primarily on a combination of chemical hazard ( to the extent that it is known) and production volume information to evaluate potential chemical risks. Unfortunately, production volume estimates are at best a very rough proxy for exposure. A more useful and complete characterization of exposure would include, for example, information on the number of potentially exposed workers and consumers, types of products and uses, the number of use sites, and ambient and production stream concentrations of the chemical. As described in Box 4 2, the IURA will make additional information of this type available, thereby enhancing the effectiveness and efficiency of EPA's chemical risk screening programs. 4 6 Box 4 2. EPA Tools to Evaluate and Manage Chemical Risk Risk Screening. OPPT screens chemicals on the TSCA Inventory to identify potential risks and determine whether more detailed assessments should be undertaken. With the data currently available, EPA does not have the information needed to effectively and systematically screen some of the chemicals on the inventory. Data collected as a result of the IURA will improve the Agency's ability to screen chemicals in commerce, allowing the Agency to focus its chemical screening programs and to identify potentially risky situations earlier than otherwise possible. Then EPA could expend resources more efficiently and reduce the number of occasions where resources are allocated for assessment of chemicals that ultimately pose low risk.

Existing Chemicals Review Program. The Existing Chemicals review program conducts detailed analyses of potentially high risk chemicals and develops strategies to reduce or eliminate the exposure risks. Chemicals are first screened to identify those that ( 1) require additional testing, ( 2) present potentially significant riskmanagement concerns, or ( 3) do not currently require further review. Processing and use data collected through the IURA will contribute to this risk management program in several ways. First, improved screening prior to review will lead to a quicker identification of chemicals of concern and more appropriate entry into EPA's chemical management programs. Second, the IURA will provide readily obtainable initial processing and use information for these chemicals, significantly improving the efficiency and effectiveness of screening. Finally, by effectively weeding out the lower risk chemicals sooner, EPA will be able to focus efforts on higher risk chemicals.

Use Cluster Scoring System ( UCSS). UCSS identifies potential risks of chemical substances used in similar applications, or " use clusters." This system enables the Agency to view the risks of a given chemical substance in the context of the risks presented by related products on the market and allows the Agency to establish regulatory review priorities for those use clusters. However, some of the UCSS data sources are outdated and estimating methodologies are speculative. The IURA will create a database providing additional information that will allow the Agency to provide more accurate screening level estimates for use clusters, targeting Agency programs to areas currently needing attention. The IURA will also enable the Agency to more easily conduct broader chemical screening analyses across several industries.

Existing Chemicals Testing. TSCA § 4 empowers EPA to require manufacturers and processors of chemicals to test the chemicals they manufacture and process to obtain hazard data necessary to assess the chemical's risks. EPA must make findings under either § 4( a)( 1)( A) (" A" finding) or § 4( a)( 1)( B) (" B" finding) before testing may be required of manufacturers or processors. The A finding permits EPA to require testing on a " may present" risk basis; the B finding can be made on an exposure basis. For the B finding, processing and use data will be a critical input when no hazard data are available to indicate a chemical's toxicity. In addition, OPPT uses the Master Testing List ( MTL) of chemicals identified by the Agency as having inadequate data for health and/ or environmental risk assessments. OPPT uses the MTL to establish priorities for chemical testing, keep the public informed, and solicit input from industries on specific chemical exposure and risk assessment needs and encourage them to perform testing. The IURA data will enable EPA to better target testing needs to situations in which potential exposures are known to occur, thereby increasing the efficiency of efforts in these programs and facilitating earlier completion of critical testing needs.

High Production Volume ( HPV) Chemical Challenge Program. This is a voluntary program designed to encourage manufacturers and importers of high production volume chemicals   those manufactured in or imported into the United States in amounts equal to greater than 1 million pounds per year   to provide basic toxicity information to the public. HPV chemicals are identified through information collected under the IUR and are publicly listed. The current HPV Challenge Program Chemical List consists of all the HPV chemicals reported during the 1990 IUR submission period, but information from subsequent submission periods may be used to expand this list. The expansion of the IUR reporting requirements, particularly the inclusion of inorganic chemicals, will therefore support the HPV program goals and help to increase the amount of information available to the public on these chemicals. The IURA exposure related data can put HPV Challenge data in context, generating a better notion of potential risks associated with HPVs.

( continued) 4 7 Box 4 2. EPA Tools to Evaluate and Manage Chemical Risk ( continued)

Screening Information Data Set ( SIDS). SIDS is a voluntary program, conducted under the auspices of the OECD, which allows member countries to share the burden of testing internationally traded large production volume chemicals. The U. S. is responsible for testing of 25 percent of the chemicals identified for the program. The information needed is collected by industry sponsors; however, the data elements collected may not be consistent across sponsors, and some companies may not participate in developing information. The IURA will provide many key needs for exposure data and will provide a consistent database of information from manufacturers and importers. This information will increase the program's efficiency by helping to identify chemicals requiring additional testing or assessment while excluding those with low domestic exposure. A better exposure database will also improve evaluation of potential risk in the assessment reports prepared at the end of the SIDS process.

Design for the Environment ( DfE). EPA's Design for the Environment ( DfE) program incorporates principles and strategies from both the Existing Chemicals review program and the UCSS, by focusing on specific chemical uses and establishing partnerships with industry to develop voluntary long range plans for risk management. The exposure related data collected through the IURA will help to identify use cluster candidates for this program. It will also provide the initial assessment of exposures and help identify potential substitutes and could be used to assist in ranking activities, identifying high risk areas, and developing realistic approaches for reducing risk.

EPA screens chemicals for potential chemical risks by completing an initial review. This initial review is designed to select the chemical substances that raise particular concern regarding the risks they present to human health and the environment. OPPT's initial risk screening is a review and analysis of any readily available chemical hazard data and exposure information to evaluate potential risks to human health and the environment from these chemicals. These evaluations are used to support basic risk management decisions, which can lead to more detailed assessments and, ultimately, to voluntary and/ or regulatory actions. The initial reviews are often more qualitative than quantitative and are typically eclectic rather than formulaic: the extent and the actual process of the review depends on available information as well as available time and resources. Further, the initial screening typically is broad in scope and shallow in depth. For example, one initial review might be conducted for a chemical or group of chemicals with substantial hazard information covering a number of adverse effect endpoints ( such as cancer, reproductive problems, mutations, or mortality) but little exposure data, while another might involve hazard data on only one endpoint, but with exposure data usually associated with other endpoints. As a result, considerable scientific judgment must be used to assess the chemicals, decide which, if any,

require more detailed review, and account for a great deal of uncertainty in the analysis. This uncertainty usually is due to a lack of current hazard data or, more frequently, exposure data, as well as questions about data reliability.

At the close of the initial review, three possible outcomes may occur: a testing recommendation,

a recommendation for further evaluation, or closure. " Closure" may include referrals to other programs or agencies, dissemination of initial review results, or a decision to discontinue further review based on the chemical's low hazard or low risk potential, or because it will be considered for regulatory control as part of a broader cluster of chemical substances.

Effective risk screening and risk management depend on both exposure information and hazard information. The exposure related information reported under the IURA, in combination with hazard 2Additional details on the usefulness of this information can be found in the EPA ( 1996c) report entitled Inventory Update Rule ( IUR) Amendment Technical Support Document: Exposure Related Data Useful for Chemical Risk Screening, Volume I.

4 8 information, such as that developed under TSCA Section 4 test rules or the High Production Volume Challenge Program, will allow the Agency to effectively screen and prioritize chemicals based on potential risk.

EPA's Existing Chemicals Program is currently evaluating risks from indoor air pollutants,

highrelease chemical substances listed on the TRI, persistent bioaccumulators, and high production volume chemicals. While past approaches to priority setting have been primarily based on relative chemical hazards and production volume as a simple surrogate for exposure, EPA has increased its emphasis on the exposure component of risk screening and assessment. EPA also believes it is appropriate to develop a more systematic and comprehensive approach to the prioritization process. The new exposure related information that will be reported under this amended rule is necessary to allow more efficient and effective chemical risk screening.

The additional information required by the rule will specifically include the following features and uses: 2  Number of Potentially Exposed Workers: Estimates of the number of workers potentially exposed to specific chemicals will be used to clearly understand the potential magnitude of occupationally exposed populations. The number of workers is combined with the chemical function, the chemical form, the chemical concentration, and other information to develop exposure scenarios and estimates of occupational exposures.

 NAICS Code: The NAICS code enables EPA to sort and screen information by industry sector. Specific industry sectors often have particular ways in which they handle, use, or manage chemicals; these ways affect the potential for exposures. As part of the riskscreening process, EPA can also identify those industries that might be good candidates for early involvement in risk assessment and risk management activities, as well as pollution prevention.

 Function Code: The industrial function of a chemical substance can be an important indicator of potential chemical exposures to the workers, the environment, and the general population. It will also be useful for estimating the potential magnitude, frequency, and duration of exposure.

 Commercial or Consumer End Uses: Information on the use of chemicals in commercial and consumer end use categories will be used to estimate the potential exposure. Generally, these populations are regarded as large and less informed and disciplined regarding exposurecontrol measures.

 Maximum Concentration: Information on the maximum concentration of a chemical as sent off site or as used for commercial or consumer purposes will be used to estimate the upper limits to potential levels of exposure.

 Number of Sites: Information on the number of sites where a chemical is manufactured or used will provide information on the number of communities or ecosystems potentially exposed. 4 9 <IP_ADDRESS> Risk Management Programs Better risk screening ultimately generates opportunities for improved risk management by EPA and other entities. Most importantly, it improves the setting of priorities for risk management activities by helping to distinguish between relatively high risk and low risk chemicals. The IURA may also provide EPA and other risk management entities with information that will allow them to better evaluate alternative risk management strategies for high priority chemicals. Box 4 2 also presents OPPT risk management programs that might benefit from the greater scope and depth of the new IURA data, including the Existing Chemicals review process and various pollution prevention, risk reduction, and chemical testing programs, such as the Design for the Environment ( DfE), and the Chemical Testing Program. EPA expects that the exposure data collected through the IURA also will be useful to a variety of other OPPT programs or initiatives, especially the New Chemicals Program.

<IP_ADDRESS> Benefits from Cost Savings Associated with Screening Activities The IURA will reduce the average time and other Agency resources spent per chemical in the screening processes. Because the current IUR lacks exposure related data beyond estimates of production volume, OPPT must rely on a variety of other data sources to develop better indicators or estimates of exposure. As described in more detail in Section 2 and Appendix B, these alternative sources, such as PAIR, TRI, and NOES, are ill suited for this task, primarily because their coverage of chemicals and/ or manufacturers is limited or because the data have only been collected on a one time basis. The processing and use information required by the IURA will address these limitations. It will decrease OPPT's reliance on alternative data sources that are less complete, reliable, and up to date and are therefore more costly to use. Although EPA will bear some additional costs in collecting and managing the IURA exposure and use data, overall the rule is expected to greatly reduce the time and effort required of EPA to collect and process data or to develop exposure estimates for screening purposes.

Resources will be saved by streamlining the screening process and more quickly eliminating chemicals from further consideration. In this way the Agency avoids the time and other resource costs that would otherwise be needed to further evaluate them. Some of these savings can be roughly estimated by examining the TSCA Inventory and screening needs. The Inventory and Inventory Update processes provide production volume information for chemicals that is then used to further screen chemicals for exposure risks. Based on these data, EPA has decided that further information is not a priority at this time for a large portion of the 76,000 chemicals on the TSCA Inventory. However, for about 10 to 15 percent of those chemicals, additional information is required to adequately assess the potential risks. This amendment will collect manufacturing level information on 8,900 of these chemicals and ultimately provide detailed processing and use for approximately 4,500 of these 8,900 chemicals. By allowing EPA to screen these chemicals more effectively, the IURA will save resources by reducing the number of chemicals requiring more detailed evaluations. Assuming, as per Box 2 2 ( see Section 2), that these activities require 100 hours per chemical, reducing the number of chemicals that proceed through the screening process could result in savings of many FTEs over time. For example, if, as a result of this new information, the number of chemicals entering Existing Chemicals Review is reduced from 6,000 to 3,000, savings of 300,000 hours or 144 FTEs would result.

The information required by the IURA will reduce OPPT's reliance on unsuitable data sources and allow it to more quickly and more cost effectively make these screening determinations. As a result, 4 10 a larger number of chemicals per year can be reviewed, and ultimately the time and resources spent evaluating all chemicals of concern can be reduced. The public will ultimately benefit from this more efficient use of EPA's resources. In other words, IURA data will help free up resources for other EPA activities ( including additional chemical risk screening and management).

<IP_ADDRESS> Benefits from Improved Risk Screening and Risk Management Decisions The chemical processing and use information required by the rule will contribute to better decisionmaking and priority setting in OPPT's risk screening and risk management programs. Under ideal circumstances ( i. e., full information), OPPT would be able to completely sort chemicals and prioritize risk management activities according to where the net benefits of these activities are the highest. That is, it would be able to ( 1) identify the chemicals that pose relatively high potential risks to humans and ecosystems ( and/ or relatively low costs of control), and ( 2) target these chemicals for regulation or other forms of control. Although the rule will not provide full information regarding all chemical risks, it will significantly improve the information available for making these judgments. Compared to the current situation, the new rule will result in larger net benefits to society from OPPT's risk screening and management programs.

For example, between 1990 and 1994, 1,924 chemicals were identified as candidates for the EPA's RM1 screening process. Of these, 561 chemicals   an average of 112 chemicals per year   proceeded through RM1 and were either recommended for further testing, for further risk management, or for closure. The RM1 process was primarily informed by hazard ( test) data as opposed to hazard data coupled with actual exposure scenarios. This critical lack slowed the RM1 screening process considerably. RM1 screening was discontinued in 1998 due to the fact that the Agency felt its resources could be used more effectively in other risk management programs. Existing chemicals review continues under other TSCA programs, but none provide the wide coverage that will be necessary to effectively screen the large numbers of chemicals for which EPA is required to manage risks. With data from the IURA, such screening can proceed, and EPA's mandate to manage chemical risks can be fulfilled more effectively.

The IURA will improve the Agency's ability to identify potentially high risk chemicals or chemical uses and, when appropriate, to accelerate risk assessment and management activities in these areas. Under current conditions, inadequate chemical specific information may be delaying or even precluding actions on potentially high risk chemicals. Similarly, new exposure and use information will assist the Agency in identifying relatively low risk chemicals or chemical uses. As a result, these chemicals will receive lower priority, allowing the Agency to delay or even completely avoid projects that lead to relatively small risk reductions relative to their costs.

Therefore, the IURA will prioritize risk management activities to favor those that are expected to provide the largest net benefits for society. That is, it will help EPA to distinguish the risk management projects that have the highest returns ( i. e., the largest risk reduction) net of the costs they impose on society. As a result, the availability of new exposure and use information should lead to tangible reductions in mortality, morbidity, and ecosystem damages. Compared to a baseline situation without the rule, high risk exposures will be identified and controlled earlier. And, although controls on some relatively low risk exposures may be delayed, the net impact will be to reduce the incidence of fatal and nonfatal illnesses and to reduce damages to ecosystems. 4 11 The IURA can also help in other ways to identify the risk management activities with the highest expected net benefits. In addition to helping identify which chemicals should receive higher priority, the information may also be useful in selecting the most appropriate risk management strategies for high priority chemicals. For example, a better understanding of the extent and types of uses for a chemical can help to determine whether an information disclosure approach is adequate or whether more proactive regulatory actions are needed. Also, the IURA data will provide information that will help in assessing the costs of managing chemical risks. For instance, information on downstream uses can be used to evaluate the market demand for the chemical and the market adjustments that will occur as a result of risk management activities. In other words, this information can also help to distinguish between more and less costly risk management actions.

Ideally, assessing the present value of the net benefits of the rule would involve the following steps. The first step would be to determine " baseline" conditions. This step involves projecting when specific risk management activities would be undertaken in the absence of the new rule and estimating the annual net benefits to society ( i. e., the value of risk reductions net of their control costs) associated with each of these activities. The present value of net benefits under baseline conditions can then be calculated by discounting all future net benefits of baseline activities to the present and aggregating across all activities and future years. The second step would be to determine conditions with the new rule. This step involves estimating the revised timing and net benefits of activities that would occur using the new exposure and use information and then duplicating the present value net benefit calculation for these activities. The third step would be to calculate the incremental present value of the rule. This value is simply the difference between the present value calculations of the first two steps ( i. e., with and without the rule). The incremental benefits of the rule arise because the activities with the largest annual net benefits   in particular, those with the largest risk reductions   would be undertaken sooner and would therefore generate benefits that accrue over a longer period than under the baseline scenario.

Data limitations, however, make this ideal approach difficult to implement. First, even for baseline conditions, determining how risk management activities will be prioritized is very difficult.

Second, estimating the net benefits of management activities under either scenario is even more difficult, precisely because detailed information on exposures and risks is currently lacking for many chemicals.

4.2.2 Benefits to Non OPPT Risk Management Programs In addition to OPPT, other public and private organizations are actively involved in managing chemical risks. These organizations include other EPA programs, the Occupational Health and Safety Administration ( OSHA), the National Institute of Occupational Safety and Health ( NIOSH), the Consumer Product Safety Commission ( CPSC), Department of Defense ( DoD), state and local governments, and the private sector. Given the large number of chemicals and potential exposure scenarios at the industrial, occupational, and consumer level, these organizations also require more complete use and exposure related information to effectively and efficiently manage chemical risks. In addition, EPA will provide analyses of the IURA information and anticipates that other organizations will use the results. Through efforts made by these various stakeholders, the data to be collected under the IURA could be used to further benefit society ( in addition to the gains from OPPT programs) by contributing to more effective and efficient management of chemical risks. 4 12 <IP_ADDRESS> Other Federal Risk Management Programs Federal efforts other than OPPT's will also benefit from new exposure information for IURA chemicals. For example, OSHA currently manages occupational exposure to chemicals by setting a variety of chemical and personal protection standards, by requiring preparation of emergency response and process safety management plans and by requiring provision of health and safety data to workers for chemicals used in the workplace. OSHA will be able to use the IURA data to identify chemicals with large numbers of potentially exposed workers or with uses that suggest greater exposure potential. The IURA information could increase OSHA's ability to manage chemical hazards, exposures, and risks in occupational settings.

NIOSH will also benefit from the updated exposure related information collected under the IURA. Currently, the exposure information that NIOSH uses to determine occupational safety and health in businesses nationwide is primarily based on outdated information collected under the National Occupational Exposure Survey ( NOES). Completed in 1983, NOES collected information such as plant site location, plant site SIC, information on the plant site's occupational safety and health programs,

occupational titles of workers potentially exposed, the number of employees per occupational title, information on process steps, and trade names of products. NIOSH could use IURA data in place of the NOES data to identify chemicals with large numbers of potentially exposed workers or with uses that suggest greater exposure potential.

CPSC also could directly use the new data in conducting its exposure and risk assessment activities ( screening consumer products for chemical hazards). The primary risk information used by CPSC to screen chemical hazards is information obtained from a network of hospital emergency rooms, and this information is limited to injuries and illnesses resulting from acute exposures only. Information identifying the chemicals used in consumer products is not readily available to CPSC at this time. The IURA will provide a source of reliable information on the chemicals used in consumer products, enabling CPSC to identify the chemicals used in consumer products and, with consideration of hazard data, to identify chemical   consumer use situations presenting greater potential risk. The information could improve CPSC's ability to meet its program objective of protecting the public from chemical hazards in consumer products.

<IP_ADDRESS> State and Local Programs The IURA data will also help state and local authorities with rulemaking, information collection,

and voluntary program activities. Because state and local governments must address chemicals, use patterns, and exposure scenarios that may be unique or isolated, state and local agency access to the enhanced data will assist in identifying situations that pose potentially high risks for individual states or locations within those states. The information added to the IUR includes county data, which will enable states to identify which counties are likely to have specific issues or which counties may have multiple chemical problems. The additional data also could be used to assist with setting goals, targeting actions,

and developing or expanding pollution prevention activities. Several state environmental protection agencies, including those in Illinois, Georgia, California, and New Jersey, have expressed interest in having access to data collected by OPPT, and to results of risk screening conducted by OPPT. 4 13 <IP_ADDRESS> Nongovernmental Organization ( NGO) Initiatives and Private Sector Stewardship Many private sector organizations have a strong interest in reducing risks and providing leadership in preventing pollution while still maintaining productive economic enterprises. These organizations can better meet these objectives by developing a better understanding of how chemicals are used in general. This will allow them to more effectively manage risks and participate in community, regional, and national priority setting for chemicals.

The publicly available ( non CBI) information provided by the IURA will support activities typically undertaken by NGOs, such as tracking industry trends, organizing grassroots involvement in risk based decisionmaking, and conducting outreach and educational programs. These organizations could use the new data to identify and establish priorities for risks; to evaluate chemicals and chemical use patterns to determine areas of concern; to identify and promote pollution prevention opportunities; and to focus pollution prevention, public outreach, and education initiatives and activities.

Industry can use the amended IUR information to improve corporate product stewardship programs through access to use information reported by multiple companies. The ACC's Responsible Care Program is one example of a corporate product stewardship program that could use this information. Currently, the ACC cites " emission reductions as measured by TRI" and a growth in the number of Community Advisory Panels as strengths in its Responsible Care Program. Use information supplied through IURA could be used to further strengthen this program. The Responsible Care Program requires companies to take responsibility for their products from cradle to grave, which requires an understanding of how their product is being used not only by their customers, but further down the chain. Despite this private effort, some companies have told EPA that they do not know how their chemicals are used. Non CBI information provided by multiple companies could give an individual company a better understanding of the downstream uses of its product, therefore enabling more effective implementation of the Responsible Care concepts.

4.3 Benefits Due to Changes in CBI Reporting A second category of benefits attributable to the IURA stems from changes in the requirements for claiming information as CBI; these changes are expected to enhance the utility of the data and the public's access to that data. The increased data availability will ultimately benefit the public by allowing them to better evaluate ( and if necessary react to) public sector risk management decisions and to make more informed risk management decisions of their own. Two basic changes will occur.

First, EPA is proposing to add a requirement to provide upfront substantiation for site identification, as well as retaining the existing requirement for upfront substantiation for chemical identity. EPA has found that, in the past, CBI claims have been made for site identification when that information has already been made public through the reporting requirements under EPCRA and other public documents. This requirement will discourage such erroneous claims.

Second, under the rule, submitters can claim a non CBI status for production volume information in ranges while continuing to claim specific production volume as CBI. As was the case in the original TSCA Inventory, this change is expected to reduce claims because, although some submitters may continue to claim production volume information in ranges as CBI, it is expected that other submitters will not feel the need to claim this information as confidential. 3Under Option 6, inorganic chemicals would maintain their full exemption from both site and manufacturing information and from processing and use information. Consequently, for Option 6, no benefits ( relative to the baseline situation) would be associated with the modifications to the inorganic chemical exemption.

4 14 While the Agency will be collecting a greater volume of data through the IURA, much of which will be CBI, EPA expects these changes to reduce the percentage of that data incorrectly claimed as CBI.

This will increase the amount of information available to the public, which has several benefits. The Agency will be able to discuss and explain its actions and decisions more publicly. Currently, support for Agency decisions is often CBI, and cannot therefore be included in any publicly available support document. The public will be better informed and better able to provide comment on Agency actions,

such that the Agency will ultimately be in an improved position to incorporate the public's preferences and concerns in its decisions. Second, the Agency will be able to provide other public and private organizations and individuals with better information for making their own decisions. These informationbased benefits are discussed in more detail in earlier parts of this section and center around the fact that increasing the amount of information available to the public allows for improved understanding of potential exposure and risk concerns, and thus more effective and efficient risk management.

4.4 Benefits of Changing Reporting Exemptions A third category of expected benefits of the IURA relates to changes in exemptions for certain inorganic, petroleum process stream, and natural gas chemicals as well as certain chemicals for which EPA has determined there is little current interest in processing and use data.

One major change is that inorganic chemicals will no longer be exempt from IUR reporting requirements. Inorganic chemicals will file partial reports in the first reporting period and full reports thereafter. The inorganic chemical exemption was originally developed based on EPA's belief that the hazard potential of many inorganic chemicals was relatively well established and therefore production information was not needed. Recent findings have brought EPA to the conclusion that hazard information alone is not enough to protect human health and the environment   basic information for inorganic chemicals is also needed. The partial exemption for inorganic chemicals in the first reporting period will allow firms to become accustomed to IURA reporting. 3 It is estimated that removing the production volume exemption for inorganic chemicals will make site manufacturing data available for an additional 1,100 chemicals in the first IURA reporting cycle, and it will make processing and use data available for 629 of these chemicals ( with production volumes greater than 300,000 pounds) in future cycles. This information will allow OPPT to avoid some of the current costs involved in conducting risk screening and developing management activities for those chemicals. It will also improve EPA's ability to prioritize and make risk management decisions about this class of chemicals that heretofore have been difficult or, in some cases, not possible. As is the case with the other extensions of IUR reporting, the public will ultimately benefit from this exemption through lower public sector costs and through risk management activities that will be better targeted to areas where the risk reductions and net benefits to society are the greatest.

A second type of exemption that is being instituted by EPA is a partial exemption for petroleum process stream chemicals and specific chemicals for which there is little current interest in processing and use information. The partial exemption exempts these chemicals from the processing and use reporting requirements that apply to other chemicals. Relative to baseline conditions, there will be no specific 4The list of chemicals that fall under the low current interest exemption is subject to revision as information needs change over time.

4 15 benefits or costs associated with this exemption. It will, in effect, maintain the status quo for these chemicals since they ( and all other chemicals) are currently exempt from such reporting. The partial exemption is being maintained for petroleum process streams because they tend to be complex chemical combinations with variable constituents and for those chemicals for which there is relatively little current interest in processing and use information. 4 A third exemption that is being instituted is to exclude certain forms of natural gas ( six chemical substances in total) from all IURA reporting, including both production volume information and processing and use data. In the 1998 reporting period, reports on these chemicals accounted for roughly 4 percent of all IUR reports submitted. Compared to baseline conditions, this will result in less information being available to evaluate these chemicals. Although this will partially reduce the information based benefits of the rule, EPA expects this effect to be small because most of EPA's and other IURA users' needs with regard to these chemicals can be met with previously collected IUR information or other publicly available information.

4.5 Benefits of Administrative Changes A separate source of benefits from the IURA stems from changes to several administrative requirements, each of which will facilitate data exchange and increase data comprehensiveness. Overall,

the administrative changes will enhance the utility of the data by allowing linkages between various Agency databases. In addition, the time frame changes for IURA reporting will make the data more internally consistent and more compatible with other EPA reporting requirements. As with the other changes to IUR reporting, the public will ultimately benefit through lower public sector costs and through more efficiently targeted risk management activities that will increase net benefits to society.

The major administrative change which will shift the reporting year from fiscal year to calendar year for all reporting sites will help to standardize the information collected across IURA submitters and with respect to other reporting initiatives. For instance, a calendar year reporting year will correspond with the TRI reporting period, enhancing the Agency's ability to develop linkages between the two databases. This will lower analysis costs for the Agency and allow for more accurate assessments of chemical releases, exposures, and risks.

4.6 Benefits From Changes to Reporting Thresholds There are two reporting thresholds in these amendments   a reporting threshold for site and manufacturing information ( e. g., site location and information associated with producing the chemical)

and a reporting threshold for processing and use data ( e. g., numbers of exposed employees at use sites, number of use sites, percentage of production volume). The reporting threshold options considered by EPA are presented in Table 4 1.

As discussed previously in this section, relative to conditions without the IURA, each of the threshold options for processing and use data   100,000, 300,000, and 1 million pounds   would increase the amount of information available for evaluating potential chemical risks. This would be particularly true after the first submission period for IURA reporting when processing and use data on inorganic 4 16 chemicals would also be reported. Lower thresholds would provide relatively more information and thus more benefits. These benefits are discussed qualitatively in Section 4.2.

In contrast, the threshold for site and manufacturing data under all of the options ( 25,000 pound production volume per year) is higher than the current threshold ( 10,000 pounds). This will decrease the amount of chemical information available. With this change, benefits will decrease because EPA risk managers will no longer have access to current data on lower volume chemicals ( i. e., those produced between 10,000 and 25,000 pounds).

In considering the threshold levels, EPA balanced information needs and associated benefits with the cost of the information. EPA has determined that the selected threshold levels provide the level of data necessary to provide EPA with the information necessary to screen the thousands of larger volume chemicals, develop risk management initiatives, and track changes in the marketplace ( and therefore in exposure scenarios) while not unduly burdening industry.

Based on historical IUR data regarding the number of report submissions and taking into account the changes in exemptions included in the IURA ( addition of inorganic chemicals), information on approximately 10,400 chemicals will be reported if the current 10,000 pound threshold were maintained. It is estimated that, by increasing the reporting threshold to 25,000 pounds, information on approximately 15 percent fewer chemicals   approximately 8,900 in total   will be collected. This loss of data will potentially affect EPA's ability to undertake risk screening activities, as well as the preparation of certain important analyses, including use, substitutes, and use cluster analyses. Although increasing this threshold will exclude lower volume chemicals ( which are generally assumed to be less of a risk concern than those produced in larger volumes), information on these chemicals can often provide useful data for evaluating the availability of substitutes for larger production chemicals. In addition, acquiring information on lower volume chemicals from alternative sources ( if any exist) can be particularly costly, because information on these chemicals is much less likely to be publicly available than for high volume chemicals.

Consequently, by increasing this reporting threshold, information that would help to reduce exposures and risks may become more costly to attain or may simply no longer be available to OPPT. The public will ultimately lose, either through higher public sector costs or through less socially optimal outcomes from risk management decisions. It is expected, however, that reductions in societal benefits associated with a change from 10,000 pounds to 25,000 pounds for site and manufacturing data will not be significant compared to the gains from the selected thresholds for processing and use data. EPA chose this threshold level to lessen the increased burden on submitters; however, in doing so it recognizes that information on the lower volume chemicals can be particularly useful and may find it necessary to collect this information in the future.

4.7 Benefits From Alternative Reporting Cycle Options The baseline reporting cycle, which requires IUR submissions every four years, is being retained under the selected option. Therefore, relative to baseline conditions, no specific benefits will result from this aspect of the rule.

EPA considered two alternatives to this cycle. The first alternative, referred to as Option 7 in Table 4 1, would require all information to be reported every two years. Past experience with data 4 17 reported under the IUR has demonstrated the dynamic nature of the chemical industry ( there was a change of about 30 percent of the chemicals reporting in 1990 when compared to 1994). This provides a strong indication that more frequent reporting would provide EPA and others with more accurate and more upto date information to support risk screening and management activities. However, EPA has concluded that the four year cycle is sufficient for its current needs, and that the two year cycle would not provide enough additional benefit to justify the additional reporting expense to industry. A second alternative,

considered under Option 8, would require one time reporting. While this option reduces costs significantly, it does not allow EPA to develop a stream of information over time to assess risks on an ongoing basis, and the information would quickly become out of date. 1Option 1a represents the draft final option included in the initial submission for interagency review. Option 1b is the final option that was promulgated. EPA removed a a CBI reassertion requirement and added a partial exemption for specific chemicals based on low current interest in processing and use data for those chemicals.

5 1 SECTION 5 BENEFIT COST ANALYSIS, COST EFFECTIVENESS COMPARISONS, AND RATIONALE FOR THE SELECTED OPTION EPA performs benefit cost analyses of potential regulatory actions to select the option that offers the highest benefit cost tradeoff and to ensure that the social benefits of the selected option outweigh its social costs. For the IURA, however, the benefits of the rule are difficult to quantify and monetize. As a result, EPA has used a cost effectiveness criterion to compare regulatory options.

Cost effectiveness typically describes the cost per discrete unit of a quantified, but not monetized, benefit. It measures the relative efficiency of regulatory options in achieving different levels of the targeted outcome. The cost effectiveness measure is generally calculated by dividing the costs of a regulatory option by the estimated number of targeted outcomes achieved. For environmental regulations, cost effectiveness can often be expressed by measures such as the cost per life saved or the cost per illness avoided by the option. However, as described in Section 4, the targeted outcome of information rules   improvement in welfare from better decisionmaking   is not easily quantified. Therefore, for this analysis, the " effectiveness" of each option is characterized by the quantity of different types of IURA data collected ( partial forms, full forms). Because it is not meaningful to sum across all partial and full forms collected across different chemicals to come up with a single measure of effectiveness, EPA does not estimate costs on a per unit basis in this assessment. Rather, the array of information provided and the costs of each option are presented and compared.

The remainder of this section presents, first, the information provided by and costs of the selected final option for amending the IUR. The selected approach provides the benchmark against which all nonselected regulatory options can be compared. Those comparisons are discussed in the subsection that follows the assessment of the selected option. The section concludes with a summary justifying the selected option on benefit cost criteria.

5.1 Benefits and Costs of the Selected Option As discussed in Section 2, the regulatory options for amending the IUR vary along several dimensions. Of particular relevance is the chemical production threshold, which determines when producers must report only site and manufacturing data ( partial form) and when they must report processing and use data ( full form). Other dimensions of the regulation include the length of the reporting cycle and the allowance of reporting exemptions for various classes of chemicals.

The selected approach for the IURA, Option 1b1, requires subject chemicals to be reported if they are produced or imported in quantities of 25,000 pounds per year or more. For those chemicals produced or imported at a volume greater than or equal to 25,000 pounds but less than 300,000 pounds, only the 5 2 partial form ( site identification and manufacturing information) will be required. For chemicals produced at a production volume greater than or equal to 300,000 pounds, with the exception of partially exempt chemicals, the submitter will be required to submit the full form, providing use and exposure information in addition to the site identification and manufacturing information.

Table 5 1 summarizes the information obtained and costs of the selected option ( 1b). It is estimated that approximately 26,800 forms will be submitted under the IURA. In the first submission period, about 9,500 ( 35 percent) will be full forms including both current IUR data ( site and manufacturing) and IURA ( use and exposure) data. As described in Section 4, the information provided in the IURA forms can enhance social welfare by improving the foundation for public and private decisionmaking related to risk management and by reducing the cost of obtaining information to support these decisions from other sources. The roughly 17,300 remaining forms ( 65 percent) will 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 under the IURA. In future cycles, about 11,700 reports ( 44 percent) are expected to be full reports and approximately 15,100 ( 56 percent) will be partial reports.

The estimated total annualized social costs of the IURA range from $ 17.4 to $ 20.9 million per year over the first 20 years of the rule using a 3 percent discount rate and $ 18.6 to $ 22.3 million based on a 7 percent discount rate. Details on the timing of these costs and their net present value are presented in Section 3. Almost all of this total is in the form of costs to private parties for complying with the Table 5 1. Benefits and Costs of the Selected Option ( Option 1b)

Number of Reports Filed First Submission Period Future Reporting Cycles Total Partial Full Total Partial Full 26,797 17,302 9,495 26,797 15,065 11,731 Value of Information in Reports Filed Use and exposure data support better government decisionmaking in prioritizing risk management objectives Consolidated data source reduces government costs for risk screening Public access to otherwise unavailable exposure data can improve household risk management decisions and enable nongovernmental actions Better risk screening and management improves welfare by reducing human and ecosystem exposures to harmful chemicals and/ or averting expenditures Annualized Costs ( million 2000$)

Compliance Agency Total Low High Low High 3 Percent Discount Rate 17.3 20.8 0.1 17.4 20.9 7 Percent Discount Rate 18.5 22.2 0.1 18.6 22.3 5 3 additional informational requirements of the IURA. The remainder ( approximately $ 90,500 per year, annualized using a 3 percent discount rate) is borne by taxpayers, who finance the expenditures by EPA to periodically administer the data collection. Additional social costs, in the form of labor and capital dislocation, are not quantified here but are expected to be transitory and relatively small.

5.2 Comparing the Benefits and Costs of Regulatory Alternatives to the Selected Option Several other regulatory options were considered in developing the IURA. Table 5 2 reports the differences between the alternative regulatory options and the selected final option in the number and type of reports submitted, the nature of information provided, and the annualized cost of compliance and administration.

Several of the options proposed a lower threshold for use and exposure data ( 100,000 pounds)

than the selected option ( 300,000 pounds). Lowering the threshold would expand the collection of use and exposure data by increasing the number of full reports by about 3,200 forms in the first submission period and just over 4,000 forms in future reporting cycles, but it would increase the annualized costs of the effort by $ 4.3 to $ 4.9 million ( about one quarter). Option 6 is similar to Option 2 in lowering the threshold to 100,000 pounds, but it exempts inorganic chemicals from any reporting requirements. This reduces incremental costs relative to the selected option ( 1b), but essentially eliminates all information on inorganic chemicals. Option 7 lowers the use and exposure data threshold and requires biennial reporting. This option raises the costs of the rule substantially, more than doubling the cost of the selected final option. Alternatively, Option 8 lowers the threshold to 100,000 pounds, but information will be reported only once. This lowers annualized costs substantially but foregoes all future updates to this information,

thereby greatly constraining future risk screening and management actions.

A couple of the options examine thresholds higher than 300,000 pounds for use and exposure data. Option 3 raises the threshold to 500,000 pounds, which lowers costs by about 9 to 13 percent relative to the selected option, but reduces use and exposure data for over 1,200 chemical streams of between 300,000 and 500,000 pounds. Option 4 considers raising the threshold further to 1,000,000 pounds, which lowers costs further ( 22 to 24 percent lower than the selected option) but loses use and exposure data on several thousand chemical streams in the 300,000 to 1,000,000 pound range. Finally, Option 5 considers raising the threshold from 300,000 pounds to 500,000 pounds in the first reporting cycle but lowering the threshold to 100,000 pounds in all future cycles. When compared with the selected final option, the higher first year threshold gives some cost relief initially, but the overall annualized cost of that option is about 11 to 17 percent higher than the selected option.

5.3 Benefit Cost Summary 5.3.1 Rationale for Selecting Option 1b Option 1b is among the most cost effective options considered at the preliminary and final stages of the rulemaking process. That is, it has low incremental costs for the number of full and partial forms that will be submitted. First, its minimum reporting threshold ( i. e., the level at which a partial form is required) is 25,000 pounds and not 10,000 pounds, as with the current IUR. EPA recognizes that the IURA expands industry burden, and by forgoing data on these lower volume chemicals, the Agency will mitigate the increase. Of course, this comes at the cost of potentially valuable data on lower volume chemicals. Second, Option 1b collects full information for chemicals in excess of 300,000 pounds of 5 4 Table 5 2. Incremental Benefits and Costs of Regulatory Alternatives ( Relative to Selected Final Option 1b)

Difference in Number of Reports Filed Option First Reporting Cycle Future Reporting Cycles Total Partial Full Total Partial Full 1aa 0   264 264 0   599 599 2 0   3,480 3,480 0   4,628 4,628 3 0 931   931 0 993   993 4 0 2,414   2,414 0 2,895   2,895 5 0 931   931 0   4,628 4,628 6   4,537   8,017 3,480   4,537   5,732 1,196 7 0   3,480 3,480 0   4,628 4,628 8 0   3,480 3,480 0   4,628 4,628 Option Difference in Nature of Information Collected 1a Gain processing and use data on selected chemicals for which there is a low current interest in such data.

2 Gain processing and use data on chemicals with volumes of 100   300K 3 Lose processing and use data on chemicals with volumes of 300   500K 4 Lose processing and use data on chemicals with volumes of 300K   1MM 5 First cycle: Lose processing and use data on chemicals with volumes of 300   500K Future cycles: Gain processing and use data on chemicals with volumes of 100   300K 6 Inorganic: No reporting requirements All other: Gain processing and use data on chemicals with volumes of 100   300K 7 Information reported more frequently ( every two years)

Gain processing and use data on chemicals with volumes of 100   300K 8 Information reported only once Gain processing and use data on chemicals with volumes of 100   300K Difference in Total Annualized Cost ( million 2000$)

Option Low High 1a + 2.1 + 2.5 2 + 7.1 + 6.9 3 + 0.3  0.5 4  2.0  3.0 5 + 5.6 + 5.2 6 + 2.5 + 1.4 7 + 30.3 + 33.1 8  11.3  14.0 a Option 1a represents the draft final option included in the initial submission for interagency review. Option 1b is the final option that was promulgated. EPA removed a CBI reassertion requirement and added a partial exemption for specific chemicals based on low current interest in processing and use data for those chemicals. All options other than 1b do include CBI reassertion and do not include the partial exemption for specific chemicals. 2The list of chemicals exempt from reporting processing and use information due to low current interest in that data may change over time as the Agency's interest in that information changes.

5 5 production. Again, while EPA would prefer to have full reporting data on all chemicals, the Agency also recognizes the need to limit industry burden, and believes that a 300,000 pound threshold for processing and use information balances the Agency's informational needs with the cost to industry. Other options for cutting the cost of the rule, such as raising the thresholds higher ( 500,000 and 1,000,000 pounds respectively) and requiring only one time reporting, were judged to involve the loss of too much valuable information on current and future use and exposure data to justify the cost savings. Option 1a has the same reporting thresholds as the selected option, but would not exempt chemicals in which there is little current interest in processing and use data from providing that data as is done under Option 1b. In addition, Option 1a would require CBI reassertion ( as would each of the options other than 1b). Although Option 1a would provide additional processing and use information relative to the selected option, the additional data would concern chemicals for which there is relatively little current interest in this information. Therefore, it was determined that the cost to industry for reporting processing and use information for these specific chemicals would likely exceed the benefits. 2 In addition, although a requirement for CBI reassertion would help to make information collected under the IURA more available to the public, this requirement was judged to impose an excessive burden on industry. Thus, although strict quantification of the selected option's benefits is not possible, the Agency has judged Option 1b to be the most cost effective option considered for amending the IUR.

5.3.2 Economic Rationale for the IURA: Positive Net Benefits of the Selected Option In performing economic analysis of regulatory actions, EPA considers whether the benefits of the action are likely to justify its costs. As indicated throughout this report, the benefits of amending the IUR are difficult to quantify and monetize. The inability to monetize benefits impedes direct comparison to costs and calculation of net benefits. Nonetheless, EPA believes that the benefits of the additional information collected in the IURA fully justify the costs of the collection effort.

The benefits of the IURA are characterized in Section 4 and briefly restated here. EPA will use the information collected under this rule to screen chemicals based on relative risk, set risk assessment priorities among chemical substances of potential concern, and support EPA's pollution prevention and environmental protection activities. The data collected through these amendments will help to determine potential risks, identify opportunities for safer substitutes, target specific population groups, and evaluate the need for risk management. The data will allow EPA to better focus its programs and use resources more efficiently. Currently, the lack of nationwide information related to chemical production and use prevents the Agency from screening large numbers of chemicals in a timely manner. The IURA data are critical if EPA is to meet its obligations under TSCA.

EPA has made every reasonable effort to estimate the cost burden of the rule for the regulated community, and to use that information to modify the rule's requirements to avoid situations that impose higher costs for lower information benefits. For instance, the selected option's reporting threshold for use and exposure data ( 300,000 pounds) is higher than other options considered. Moreover, the minimal reporting threshold has also been raised from 10,000 to 25,000 pounds. The selected option also establishes a partial exemption for inorganic chemicals in the first reporting cycle; establishes partial exemptions for petroleum process stream chemicals and for specific chemicals for which there is a low 5 6 current interest in processing and use data; establishes a full exemption for certain forms of natural gas; requires only the reporting of known or reasonably ascertainable site and manufacturing information and readily obtainable processing and use information; removes the proposed CBI reassertion requirement; and allows submitters to report much of the information in ranges. These changes lower the costs of compliance, without greatly diminishing the amount and quality of information for risk screening, prioritization, and management. 1Because the amendments intend to collect information from manufacturers and importers only, small businesses that only process or distribute chemicals or products but do not manufacture or import the chemicals will not be affected.

6 1 SECTION 6 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 requires agencies to evaluate final rulemakings to determine if a Final Regulatory Flexibility Analysis ( FRFA) is necessary. If the regulation will result in significant impacts on a substantial number of small entities, the Agency must examine alternatives that may reduce adverse economic effects on significantly affected entities. The Regulatory Flexibility Act was amended by the Small Business Regulatory Enforcement Fairness Act ( SBREFA) of 1996. This section examines the effect of the IURA on small entities.

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 examines the effect of the IURA on minority and low income populations.

6.1 Small Entity Analysis The term " small entities" includes small businesses, small not for profit organizations, and small governmental jurisdictions, but since not for profit organizations and governmental jurisdictions will not be affected by this rule, " small entity" in this analysis is synonymous with small business. For the IURA, small businesses are limited to small chemical manufacturers and importers. 1 Section 604 of the Regulatory Flexibility Act requires 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 a FRFA. The basis for determining that there is no significant economic impact is explained below.

6.1.1 Determination of the Number of Small Businesses To determine the number of small businesses affected by the IURA, the Agency needs to define small businesses as used in this report and to develop the methodology for determining the number of small businesses expected to report under the IURA.

<IP_ADDRESS> Definition of a Small Business The definition of small businesses under TSCA § 8( a) includes firms whose annual sales are less than $ 40 million and that produce less than or equal to 100,000 pounds of a regulated substance at a single manufacturing site. Firms that generate $ 4 million or less in annual sales are considered small businesses regardless of production volume ( 40 CFR 704.3). For purposes of this analysis, it is assumed 2It is important to note that the $ 40 million level is for parent company sales, not individual site sales.

6 2 that any firm with sales less than or equal to $ 40 million is small, regardless of production volume. 2 This assumption may tend to overestimate the number of small businesses affected because it includes entities that may not meet all small business requirements under TSCA § 8( a).

<IP_ADDRESS> Number of Small Businesses The existing IUR exempts small businesses from reporting; this exemption, as defined in TSCA § 8( a), is maintained in the IURA. However, there are three primary reasons why a small business as defined in this analysis ( sales less than $ 40 million) would report under the IURA. Either the business produces a chemical in a volume of greater than 100,000 pounds, the chemical it produces is subject to an action under TSCA § 4, 5( b)( 4), 5( e), or 6, or it is reporting voluntarily. The expected number of small businesses reporting under the IURA was estimated according to the following methodology. First, the expected number of businesses producing organic chemicals that will be required to report was estimated based on information in the CUS database. Second, the expected number of businesses producing inorganic chemicals that will be required to report was estimated based on the number of businesses producing organic chemicals. Because the CUS contains no data for inorganic chemicals, the number of businesses producing inorganic chemicals that are expected to report was estimated based on the relationship between the number of organic chemicals and inorganic chemicals identified in the CICIS database ( 1986) maintained by EPA. Together, these two estimates represent the number of small businesses affected.

Organic Chemicals ( including Petroleum Process Stream Chemicals). To determine the number of small businesses producing organic chemicals that may be affected by the rule, annual sales information was sought for the 758 companies that submitted production volume and company identification information for the IUR in 1994 ( CUS Database, 1996; CUS Database, 1997). Of these companies, information on parent company annual sales was obtained for 627 companies from the Thomas Register ( 1990), Dun & Bradstreet ( 1996; 1992), and Ward's Business Directory ( Gale Research,

1996). Annual sales data were unavailable for the remaining 131 companies.

There were several reasons why information for these remaining companies was unavailable.

First, these businesses may be too small to be listed in the directories consulted. Second, the IUR database may be out of date because it is based on TSCA reporting for 1994 ( e. g., some companies may have gone out of business or changed hands since the information was reported). Finally, certain companies may have requested to be removed from, or may have declined to provide information to, the various directories.

Because the missing company information could not be obtained, these companies have been allocated to the small, medium, and large size categories according to two methodologies. In the first approach, each of the remaining 131 companies was distributed according to the relative distribution established for the 627 companies for which data were available. The second approach placed all 131 companies in the small business category based on the assumption that these companies were too small to be listed. Table 6 1 presents company size information for the estimated 758 parent companies that submitted IUR information in 1994. The table identifies the proportion of small, medium, and large companies, as defined by annual sales, that are likely to be affected by the rule. As the table indicates, a 6 3 range of between 21 percent and 35 percent of the regulated community may be considered small ( i. e., annual parent company sales less than or equal to $ 40 million).

Inorganic Chemicals. EPA next accounted for businesses that will submit inorganic chemical reports under the IURA. The number of these businesses was estimated indirectly based on the projected number of reports for organic chemicals and inorganic chemicals under the IURA, as reported in Section 3. EPA assumed that the ratio of the number of businesses reporting for inorganic chemicals to the number of businesses reporting for organic chemicals, based on the CUS database, was the same as the Table 6 1. Size of Manufacturing Companies Producing Organic Chemicals Based on Annual Sales Information Company Size Based on Annual Salesa Basisb Method 1: Allocated by Proportionsc Method 2: Allocated as Small Businessesd Companies Companies Companies Number Percent Number Percent Number Percent Small ( annual sales less than or equal to $ 40 million) 132 21 159 21 263 35 Medium ( annual sales greater than $ 40 million and less than or equal to $ 200 million) 133 21 159 21 133 18 Large ( annual sales greater than $ 200 million) 362 58 440 58 362 48 Total 627 100 758 100 758 100 a Annual sales are for the parent company, when applicable. b The actual breakdown by size of the 627 companies that reported for the IUR in 1994 for which company sales data were available. c The estimated breakdown by size of all 758 companies that reported for the IUR in 1994 if the sizes of the 131 companies for which sales data were unavailable are assumed to be in the same proportion as the sizes of the companies for which sales data were available. d The estimated breakdown by size of all 758 companies that reported for the IUR in 1994 if all of the 131 companies for which sales data were unavailable are assumed to be small businesses.

Sources: Gale Research Inc. 1996. Ward's Business Directory of U. S. Private and Public Companies 1996. New York: Gale Research Inc.

Dun & Bradstreet. 1996. Dun's Market Identifiers Database. Parsippany, NJ: Dun & Bradstreet Information Services.

Dun & Bradstreet. 1992. Million Dollar Directory: America's Leading Public and Private Companies, Top 50,000 Companies. Murray Hill, NJ: Dun & Bradstreet Information Services.

Thomas Register. 1990. 1990 Thomas Register of American Manufacturers. Vols. 15 and 16. New York: Thomas Publishing Company.

CUS Database. 1996. 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.

CUS Database. 1997. 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. 6 4 ratio of the number of reports for inorganic chemicals ( based on the CICIS database) to the number of reports for organic chemicals. In other words,

Number of Inorganic Businesses = ( Number of Inorganic Reports/ Number of Organic Reports) × ( Number of Organic Businesses)

Number of Inorganic Businesses = ( 4,502/ 16,576) × 758 Number of Inorganic Businesses = 206 Based on the analysis of sales information for small businesses producing organic chemicals, the number of inorganic businesses can be broken down into small, medium, and large companies. Using the percentages derived through the proportional allocation method and presented in Table 6 1, the breakdown of inorganic businesses is calculated as 120 large companies, 43 medium companies, and 43 small companies. Using the percentages derived through the second method, placing all companies for which information was unavailable into the small business category, the breakdown of inorganic businesses is calculated as 98 large companies, 36 medium companies, and 72 small companies.

Total Number of Small Businesses. The total number of businesses submitting reports for organic and inorganic chemicals combined is estimated to be 964 businesses. Under the proportional allocation method, there are estimated to be 560 large, 202 medium, and 202 small businesses. Under the small business allocation method, there are estimated to be 460 large, 169 medium, and 335 small businesses. However, 964 may be an overestimate of the total number of businesses expected to report under the IURA because it is possible that some businesses will submit a Form U for both organic chemicals and inorganic chemicals. These companies would be double counted, once as an inorganic chemical business and once as an organic chemical business, according to the approach presented in this analysis.

6.1.2 Estimation of Impacts The Regulatory Flexibility Act does not explicitly define " significant economic impact on a substantial number" of small entities. The criterion used in this analysis to determine the impact on small businesses is the annualized compliance cost of the rule as a percentage of sales.

The Regulatory Flexibility Act requires that EPA consider only the effects of the IURA ( i. e., the amendment to the existing rule). Throughout the development of the estimates, two assumptions were used:

 Each site producing organic chemicals submits an average of 9.0 reports, and each site producing inorganic chemicals submits an average of 8.3 reports ( CUS Database, 2000).

 Each small business has one site ( see Appendix E).

This section also presents a sensitivity analysis examining the impact on costs if more than one site per small business is assumed.

<IP_ADDRESS> Cost to Sales Ratios for Small Businesses Based on the proportion of organic chemical reports in the entire IURA population that are expected to be full reports, this analysis assumed that 42.7 percent of the reports filed by small organic chemical companies will be full reports and 57.3 percent will be partial reports in both the first reporting 6 5 cycle and all future reporting cycles. For inorganic chemicals, there is a difference in the distribution among full and partial reports between the first reporting cycle and future reporting cycles. In the first reporting cycle, all of the reports filed on inorganic chemicals will be partial reports because of the partial exemption that inorganic chemicals have been granted for the first reporting cycle. In future cycles, 49.3 percent of inorganic chemical reports are expected to be full reports and 50.7 percent are expected to be partial reports based on the percentage of all inorganic reports that are estimated to be full reports. Using the percentage of full reports in the overall database in this manner is likely to overstate the percentage of full reports filed by small companies to some extent because small companies are presumably more likely to produce below the 300,000 pound threshold for reporting processing and use information than an average company.

The values in Tables 3 19 and 3 20 provide the average incremental costs of compliance with the IURA per site. For organic chemicals, the average incremental cost of compliance with the amendments is estimated to be $ 27,034 to $ 31,939 in the first reporting cycle. Dividing this cost by the average annual sales of $ 17.6 million, the average cost to sales ratio is 0.15 to 0.18 percent for these small businesses in the first submission period. Based on the estimated costs in future submission periods of $ 20,441 to $ 24,276, the cost to sales ratio is 0.12 to 0.14 percent. For inorganic chemicals, the average incremental cost of compliance with the IURA is estimated to be $ 11,742 to $ 18,185 in the first reporting cycle and $ 27,222 to $ 34,369 in future reporting cycles ( note that the baseline cost for inorganic chemicals is zero).

Dividing these costs by the average annual sales of $ 17.6 million, the average cost to sales ratio for small inorganic chemical businesses reporting under the IURA is approximately 0.07 to 0.10 percent in the first reporting cycle and 0.15 to 0.20 percent in future reporting cycles. Table 6 2 summarizes the results of the small business analysis for an average small company.

This analysis provides information about the average case for a small company, but there may be some significant variation in annual sales among small companies. However, for a firm to have a cost

tosales ratio larger than 1 percent, sales would have to be less than $ 3.5 million even for the highest average cost per site presented in Tables 3 19 and 3 20. As mentioned above, firms with sales of $ 4 million or less are considered small businesses regardless of production volume ( 40 CFR 704.3). Therefore, companies small enough to have a cost to sales ratio greater than 1 percent will generally be exempt from reporting under the IUR and thus will not be significantly affected by the amendments.

This analysis assumed that there is, on average, one site per company for small businesses. Table E 6 indicates that small businesses manufacture a given chemical at a mean of 1.2 sites. While this is not the same as the number of sites per company because it is possible that a company could manufacture different chemicals at different sites, it is indicative of the number of sites that a company is likely to own. Although the average number of sites per chemical is 1.2, this number is based on 20 respondents to the survey, one of which indicated 4 sites while the remainder indicated 1 site. Therefore, although the average number of sites per company is indeed 1.2, 1.0 is the indicative value for the representative company. Even though the assumption of 1 site per small business may tend to marginally underestimate the number of sites per company, it is important to note that small businesses would have to average between 4 and 14 sites per company for a cost greater than 1 percent of annual sales to be incurred for the typical company. 6 6 In addition, even if the assumption of 1 site per small business slightly underestimates the number of sites per company, another assumption used in the analysis may tend to overestimate costs, which limits the potential for underestimation of impacts. Specifically, the estimated number of reports ( 9.0 for organic and petroleum stream chemicals and 8.3 for inorganic chemicals) per site used in the analysis may be an overestimate of the expected number of reports per site for small businesses because small businesses tend to produce fewer chemicals per site ( ICF, 1996). However, to determine the impact of assuming that a typical small business has the same number of sites as an average company, the analysis was repeated using an assumption of 2.3 sites per small business. This is the average number of sites per chemical for all survey respondents ( ICF, 1996). Table 6 2. Effect of IURA on Small Businesses Organic Chemical Reporters Inorganic Chemical Reporters Number Affected Percentage of Sales Number Affected Percentage of Sales First Reporting Cycle Allocated by Proportions 159 0.15   0.18 43 0.07   0.10 Allocated as Small Businesses 263 0.15   0.18 72 0.07   0.10 Future Reporting Cycles Allocated by Proportions 159 0.12   0.14 43 0.15   0.20 Allocated as Small Businesses 263 0.12   0.14 72 0.15   0.20 Sources: CICIS Database. 1986. Information from the Chemical in Commerce Information System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC.

CUS Database. 1996. 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.

CUS Database. 1997. 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.

ICF. 1996. Survey for Estimating the Industry Burden Associated With Collecting Additional Chemical Use Data Under TSCA Section 8 ( IUR Amendments). OMB Control No. 2070 0034. Conducted for EPA by ICF Incorporated, Washington, DC.

Gale Research Inc. 1996. Ward's Business Directory of U. S. Private and Public Companies 1996. New York: Gale Research Inc.

Dun & Bradstreet. 1996. Dun's Market Identifiers Database. Parsippany, NJ: Dun & Bradstreet Information Services.

Dun & Bradstreet. 1992. Million Dollar Directory: America's Leading Public and Private Companies, Top 50,000 Companies. Murray Hill, NJ: Dun & Bradstreet Information Services.

Thomas Register. 1990. 1990 Thomas Register of American Manufacturers. Vols. 15 and 16. New York: Thomas Publishing Company. 6 7 Table 6 3 provides the cost of reporting under the IURA, assuming 2.3 sites per small business. The average cost to sales ratio for a small business is still well below 1 percent of the annual sales for an average small business. Therefore, typical small businesses will not experience a significant economic impact from the changes to the rule.

6.2 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 IURA is an information collection exercise, there are no associated negative environmental equity issues. Instead, 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 IURA will help EPA make decisions that will benefit potentially at risk communities, some of which may be disadvantaged. Table 6 3. Effect of IURA on Small Businesses Assuming Two Sites Per Small Business Organic Chemical Reporters Inorganic Chemical Reporters Number Affected Percentage of Sales Number Affected Percentage of Sales First Reporting Cycle Allocated by Proportions 159 0.35   0.42 43 0.15   0.24 Allocated as Small Businesses 264 0.35   0.42 72 0.15   0.24 Future Reporting Cycles Allocated by Proportions 159 0.27   0.32 43 0.36   0.45 Allocated as Small Businesses 264 0.27   0.32 72 0.36   0.45 Sources: Gale Research Inc. 1996. Ward's Business Directory of U. S. Private and Public Companies 1996. New York: Gale Research Inc.

Dun & Bradstreet. 1996. Dun's Market Identifiers Database. Parsippany, NJ: Dun & Bradstreet Information Services.

Dun & Bradstreet. 1992. Million Dollar Directory: America's Leading Public and Private Companies, Top 50,000 Companies. Murray Hill, NJ: Dun & Bradstreet Information Services.

Thomas Register. 1990. 1990 Thomas Register of American Manufacturers. Vols. 15 and 16. New York: Thomas Publishing Company.

CUS Database. 1996. 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.

CUS Database. 1997. 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. 3A " large number of reports" is defined here as 100 or more reports from an IUR submitting site.

6 8 To illustrate the way in which information to be collected under the IURA will benefit minority and economically disadvantaged people and communities, the social and economic characteristics of populations potentially affected by the amendments were compared with the social and economic characteristics of the total population of the United States. Populations potentially affected by the amendments were assumed to be those located in geographic areas with a large number of reports submitted under the IUR. 3 A significant portion of low income and minority communities are located in these areas. Specifically, of the 121.2 million people who lived within 10 miles of an IUR site ( 49 percent of the 1990 U. S. population), almost 38 million ( 30 percent) were minorities. This is a larger proportion of minorities than in the United States, overall, where minorities comprise about 20 percent of the population ( approximately 49 million minority individuals out of the total 1990 U. S. population of 248.7 million). Roughly 24 million ( 20 percent) of the people living within 12 miles of an IUR site were at or below 150 percent of the poverty level. This is consistent with the census figure of 52.5 million ( 21 percent) individuals at or below 150 percent of the poverty level nationwide ( U. S. Census, 1990).

The information to be collected through the IURA will allow EPA to focus risk screening and assessment activities on chemicals with high exposure profiles and risks. Additionally, because the IURA data will allow EPA and others to view chemical exposures and uses on a regional or local level, analyses might be undertaken that will benefit disadvantaged groups. Specific activities to benefit these groups could include information dissemination, community awareness, exposure mitigation, pollution prevention, outreach and educational programs, and consumer protection programs. In addition, non CBI IURA data will be publicly available to groups such as NGOs, private sector stewardship programs, other federal programs such as OSHA and CPSC, and other federal and state government agencies, resulting in worker or consumer oriented programs or local, state, and regional programs targeting disadvantaged groups.

Additionally, as discussed in Section 4, the information collected under the IURA will aid in targeting potential health and ecosystem risks. Minority and economically disadvantaged groups will benefit from these potential risk reductions even if programs specifically targeting disadvantaged people do not exist. Because the production volume information currently available to EPA is not always sufficient for identifying chemical exposures and human risks, better compilation of use and exposure data will enable EPA to predict more accurately the magnitude and nature of ecosystem and human population exposure. This better information on uses and exposures will potentially benefit minority and economically disadvantaged groups by alerting them to potential chemical exposures in their workplaces and communities.

In addition, the availability of better information will also enable EPA to conserve resources and focus efforts on chemicals that pose higher risks, and thereby potentially more effectively and expeditiously reduce the risks posed by these chemicals. For example, worker exposure information will be used to develop priorities and to identify chemicals or uses that require a more detailed risk screening or assessment. The rapid identification of potentially high risk situations will also allow for more timely and efficient identification and development of safer substitutes and alternative chemicals, processes, and technologies, thereby benefitting all potentially exposed employees ( including disadvantaged ones) that work at chemical manufacturing, importing, and processing sites. Although programs and safety 6 9 measures may not be targeted to a specific subset of workers, disadvantaged people employed at these sites will benefit from EPA's and others' improved ability to target risks and thereby more efficiently implement the programs and safety measures necessary to reduce these risks. R 1 REFERENCES Bureau of Labor Statistics ( BLS). April 5, 1997. Transcribed telephone conversation with Wayne Shelley, Office of Compensation Levels and Trends, Bureau of Labor and Statistics, Washington, DC.

Bureau of Labor Statistics ( BLS). 2000. Employment Cost Index. < www. bls. gov>. As obtained April 28, 2000.

Browning, Adam. TRI Coordinator, U. S. Environmental Protection Agency, Region 9. March 8, 1996. Transcribed telephone conversation with Ellie Stewart, ICF Incorporated, Washington, DC.

CICIS Database. 1986. Information from the Chemical in Commerce Information System Database maintained by the Information Management Division, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency, Washington, DC.

Codina, Thelma, Pesticides and Toxics Branch, U. S. Environmental Protection Agency, Region 5. March 7, 1996. Transcribed telephone conversation with Ellie Stewart, ICF Incorporated, Washington, DC.

CUS Database. 1996. 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.

CUS Database. 1997. 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.

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.

Dun & Bradstreet. 1992. Million Dollar Directory: America's Leading Public and Private Companies, Top 50,000 Companies. Murray Hill, NJ: Dun & Bradstreet Information Services.

Dun & Bradstreet. 1996. Dun's Market Identifiers Database. Parsippany, NJ: Dun & Bradstreet Information Services.

Executive Office of the President ( EOP). 1997. North American Industry Classification System: United States, 1997. Washington, DC: Executive Office of the President, Office of Management and Budget.

Federal Register. December 23, 1977. 42 FR 64572.

Federal Register. June 12, 1986a. 51 FR 21438.

Federal Register. June 12, 1986b. 51 FR 21447.

Freeman, A. Myrick III. 1993. The Measurement of Environmental and Resource Values: Theory and Methods. Washington, DC: Resources for the Future.

Fried, Fred. March 7, 1996. Toxics Release Inventory Program, U. S. Environmental Protection Agency, Region 8. Transcribed telephone conversation with Ellie Stewart, ICF Incorporated, Washington, DC. R 2 Gale Research Inc. 1996. Ward's Business Directory of U. S. Private and Public Companies 1996. New York: Gale Research Inc.

General Accounting Office ( GAO). September 26, 1994. Toxic Substances Control Act: Legislative Changes Could Make the Act More Effective. General Accounting Office, RCED 94 103. < www. gao. gov>.

Glynn, John, Department of Energy, Washington DC. June 26 and July 16, 1996. Transcribed telephone conversations with Ellie Stewart, ICF Incorporated, Washington, DC.

Hope, Walter, Department of Environmental Protection. March 7, 1996. Transcribed telephone conversation with Ellie Stewart, ICF Incorporated, Washington, DC.

ICF. 1996. Survey for Estimating the Industry Burden Associated With Collecting Additional Chemical Use Data Under TSCA Section 8 ( IUR Amendments). OMB Control No. 2070 0034. Conducted for EPA by ICF Incorporated, Washington, DC.

Information Management Division ( IMD). 1996. Questions for Branches within OPPT with Responsibility for IUR Data Collection, Processing, and Storage. Information Management Division, U. S. Environmental Protection Agency, Washington, DC.

Kolb, Jeffrey A., and Joel D. Scheraga. 1990. " Discounting the Benefits and Costs of Environmental Regulations." Journal of Policy Analysis and Management 9( 3): 381 390.

Larmee, Stan, Chemical Release Information Division, New Jersey Department of Environmental Protection. March 8 and March 11, 1996. Transcribed telephone conversation with Ellie Stewart, ICF Incorporated, Washington, DC.

Layne, Warren, Toxics Section, U. S. Environmental Protection Agency, Region 6. March 7, 1996. Transcribed telephone conversation with Ellie Stewart, ICF Incorporated, Washington, DC.

Lind, Robert C. 1990. " Reassessing the Government's Discount Rate Policy in Light of New Theory and Data in a World Economy with a High Degree of Capital Mobility." Journal of Environmental Economics and Management 18: S 8 S 28.

Massachusetts Department of Environmental Protection ( MADEP). 1995. Toxics Use Reduction: 1994 Reporting Package. Boston: Massachusetts Department of Environmental Protection, Bureau of Waste Prevention.

McBride, Allan, Office of Solid Waste and Emergency Response ( OSWER), U. S. Environmental Protection Agency. April 1, 1996. Transcribed telephone conversation with Julie Bedford, ICF Incorporated, Washington, DC.

Moore, Michael J., and W. Kip Viscusi. 1990. " Discounting Environmental Health Risks: New Evidence and Policy Implications." Journal of Environmental Economics and Management 18: S 51 S 62.

National Academy of Public Administration. April 1995. Setting Priorities, Getting Results: A New Direction for EPA. Washington, DC: National Academy of Public Administration.

Office of Personnel Management ( OPM). 2000. " 2000 General Schedule Locality Notes of Pay for Washington Baltimore, DC MD VA WV." < http:// www. opm. gov/ oca/ 2000tbls/ GSannual/ html/ GSDCB. HTM> As obtained on May 30, 2000.

Oregon State Public Interest Research Group ( OSPIRG). November 1993. Breaking the Chemical Dependency: The First Data on Oregon's Industrial Toxics Use. Prepared by the Oregon State Public Interest Research Group, Portland, Oregon.

Rozell, David K, and Roy W. Brower. 1993. " Pollution Prevention Facility Planning: The Oregon Experience." Pollution Prevention Review 3( 3): 277 283. R 3 Rubin, Steve. Office of Wastewater Enforcement and Compliance, Office of Water, U. S. Environmental Protection Agency. March 20, 1996. Transcribed telephone conversation with Julie Bedford, ICF Incorporated, Washington, DC.

Science Advisory Board. September 1990. Reducing Risk: Setting Priorities and Strategies for Environmental Protection. U. S. Environmental Protection Agency.

Strasler, Eric, Office of Water, Office of Science and Technology, Engineering and Analysis Division, U. S. Environmental Protection Agency. March 23, 1996. Transcribed telephone conversation with Julie Bedford, ICF Incorporated, Washington, DC.

Thomas Register. 1990. 1990 Thomas Register of American Manufacturers. Vols. 15 and 16. New York: Thomas Publishing Company.

U. S. Census. 1990. 1990 Census of Population and Housing. U. S. Department of Commerce, Economics and Statistics Administration Bureau of the Census, < http:// venus. census. gov/ cdrom/ lookup/ 885912463>. Washington, DC.

U. S. Environmental Protection Agency. February 1990. Economic Analysis for the TSCA Inventory Update Final Rule. Office of Toxic Substances, Office of Pollution Prevention and Toxics.

U. S. Environmental Protection Agency. 1992. " Guidelines for Exposure Assessment." Notice. Federal Register 57( 104): 22888 22938.

U. S. Environmental Protection Agency. April 14, 1994. Regulatory Impact Analysis of Amendments to Regulations for TSCA Section 5 Premanufacture Notifications. Office of Pollution Prevention and Toxics, Regulatory Impacts Branch.

U. S. Environmental Protection Agency. 1996a. Access EPA. Office of Information Research Management, U. S. Environmental Protection Agency, Chapter 5.

U. S. Environmental Protection Agency. July 30, 1996b. IUR Amendments   Agency Costs Question. Memorandum from Ward Penberthy to Susan Krueger, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency.

U. S. Environmental Protection Agency. July 19, 1996c. Inventory Update Rule ( IUR) Amendment Technical Support Document: Exposure Related Data Useful for Chemical Risk Screening, Volume I. Prepared for Office of Pollution Prevention and Toxics.

U. S. Environmental Protection Agency. August 29, 1996d. Transcribed Telephone Conversation with Ruth Heikkinen on Hotline and Mailing Costs, Office of Pollution Prevention and Toxics.

U. S. Environmental Protection Agency. April 1997a. Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313. 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. 1998a. A Review of Existing Exposure Related Data Sources and Approaches to Screening Chemicals: A Response to CMA. Economic and Policy Analysis Branch, Economics, Exposure, and Technology Division.

U. S. Environmental Protection Agency. August 26, 1998b. 1994 IUR. Memorandum from Rob Esworthy, U. S. Environmental Protection Agency, to Susan Krueger, Office of Pollution Prevention and Toxics, U. S. Environmental Protection Agency.

U. S. Environmental Protection Agency. March 1, 1999a. Economic Analysis of Proposed Amendments to the TSCA Section 8 Inventory Update Rule. Washington, DC: U. S. Environmental Protection Agency. R 4 U. S. Environmental Protection Agency. July 29, 1999b. Economic Analysis of Proposed Amendments to the TSCA Section 8 Inventory Update Rule, March 1, 1999. Addendum, Executive Summary, and Summary. Washington, DC. APPENDIX A DRAFT REPORTING FORM FOR THE IURA 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 Production and Site Report ( Section8( a) Toxic Substances Control Act, 15 U. S. C 2607)

PART I. SITE IDENTIFICATION INFORMATION SECTION I. CERTIFICATION Certification Statement: I hereby certify to the best of my knowledge and belief that ( 1) all information entered on this form is complete and accurate; and ( 2) the confidentiality statements at the end of this form are true and correct as to that information for which I have asserted a confidentiality claim.

1.1 Signature 1.2 Date signed 1.3 Name 1.4 Official Title SECTION II. PARENT COMPANY AND TECHNICAL CONTACT INFORMATION 2.1 Parent Company Name 2.2 Parent Company Dun & Bradstreet Number 2.3 Technical Contact Name 2.4 Technical Contact Telephone ( w/ Area Code) 2.5 Technical Contact Email Address Technical Contact Mailing Address 2.11 Technical Contact Address ( Line 1)

2.12 Technical Contact Address ( Line 2)

2.13 City 2.14 State 2.15 Zip Code SECTION III. PLANT SITE IDENTIFICATION 3.1 Plant Site Name 3.2 Plant Site Dun & Bradstreet Number EPA Facility Identification Number ( for Agency Use Only)

3.3 Street Address ( Line 1)

3.4 Street Address ( Line 2)

3.5 City 3.6 County / Parish 3.7 State 3.8 Zip Code EPA Form Number < XXXX X> ( Rev 7/ 11/ 02)  Previous editions are obsolete Form Approved OMB Number: XX/ X XXXX PAGE ___ of___ FORM U 2006 Report Number Mark " X" here if this is a revision to the previous report Previous Report Number REPORT NUMBER PART II. MANUFACTURING INFORMATION SECTION I. CHEMICAL IDENTIFICATION CBI* 1.1 Chemical Identifying Number 1.2 ID Code 1.3 Chemical Name SECTION II. MANUFACTURING INFORMATION CBI CBI CBI CBI CBI 2.1 Company Information 2.2 Plant Site Identity * 2.3 Site limited ( Y/ N) 2.4 Activity ( M, I or both) 2.5 Production Volume Range CBI CBI CBI 2.6 Production Volume ( LB) 2.7 Number of Workers ( code) 2.8 Maximum Concentration ( code) a. Physical Form b. Percent of Production Volume in each Physical Form Check All CBI Percent CBI That Apply 2.9 Dry Powder 2.10 Pellets or Large Crystals 2.11 Water or Solvent Wet Solid 2.12 Other Solid 2.13 Gas or Vapor 2.14 Liquid PART III. PROCESSING AND USE INFORMATION Complete Part III, section I and II only if the production volume noted in Part II, Section II 2.6 is greater than or equal to 300,000 lb/ year * Substantiation required for CBI claims on chemical identity and plant site identity. SECTION I. INDUSTRIAL PROCESSING AND USE DATA N/ A a. Type of Process b. ( 5 digit) NAICS c. Industrial Function d. % Production e. Number of f. Number or use Category Volume Sites of Workers Code CBI Code CBI Code CBI Code CBI Code CBI Code CBI 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 1.10 SECTION II. COMMERCIAL & CONSUMER END USE EXPOSURE RELATED DATA N/ A a. Commercial and Consumer b. Use in Children's c. Percent Production Volume d. Maximum Concentration Product Category Product associated with each category associated with each category Code CBI Y/ N/? CBI Percent CBI Code CBI 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 2.9 2.10 APPENDIX B CURRENT DATA COLLECTION B 1 A number of chemical data sources maintained by EPA and other federal and state agencies, as well as publicly available databases, contain limited information on production, processing, emissions,

and other chemical data. However, these sources generally do not contain the type of chemical processing and use data necessary for EPA to conduct more effective chemical risk screening. The more detailed collection of chemical processing and use information under the IURA will provide EPA with the means to better determine those chemicals with the greatest potential for risk and thereby conduct more effective risk management activities. This appendix describes the information available in each of the currently available sources as compared to the data to be collected under the IURA. Additional information can be found in A Review of Existing Exposure Related Data Sources and Approaches to Screening Chemicals: A Response to CMA ( EPA, 1998a).

B. 1 Air Programs and Datasets  The Office of Air Quality Planning and Standards ( OAQPS) maintains the Aerometric Information Retrieval System ( AIRS), a national repository for information on seven types of airborne pollution in the United States. The AIRS Facility Subsystem ( AFS), one of the four AIRS components, is used to track point source emissions and compliance data from industries. Information collected includes plant compliance summaries, emissions by SIC code, and the extent and distribution of emissions ( EPA, 1996a). This collection focuses on air emissions and does not contain information on specific chemical production volume, uses, or worker exposure scenarios.

 The Office of Air and Radiation ( OAR) tracks chemical use, hazard, and risk information for approximately 150 chemicals that are replacements for ozone depleting substances ( ODS). The information is collected under the Significant New Alternatives Policy ( SNAP) Program. This data set does not collect the more detailed chemical exposure and use information called for by the IURA.

B. 2 Solid and Hazardous Waste Programs and Datasets  The Office of Solid Waste and Emergency Response ( OSWER) manages the Biennial Reporting System ( BRS). The BRS data describe the aspects of, and monitor the trends in, hazardous waste generation, management, and minimization for RCRA large quantity generators and for treatment, storage, and disposal facilities subject to RCRA permitting requirements. Although the data set contains information on the chemical constituents in hazardous waste from the paint, petroleum, and pesticides industries ( EPA, 1996a; McBride, 1996), it does not contain information on specific chemical use, worker exposure scenarios, production volumes, or production locations.

 The Office of Emergency and Remedial Response ( OERR) is responsible for compiling the Oil and Hazardous Material Technical Assistance Data System ( OHMTADS), which contains information on hazardous substances including chemical name, physical/ chemical properties, lists of regulations covering production and use data, safety and toxicity data, and response information ( EPA, 1996a) for large volume industrial chemicals transported in bulk quantities. This data set does not contain the data to be collected under the IURA.

 The Office of Solid Waste ( OSW) maintains the Resource Conservation and Recovery Information System ( RCRIS), a national system supporting the Resource Conservation and Recovery Act ( RCRA) program. This system tracks events and activities related to facilities that generate, transport, treat, store, or dispose of hazardous waste ( EPA, 1996a); however, the dataset does not collect detailed chemical use or exposure information at the level called B 2 for by the IURA. Additionally, RCRA reporting does not account for chemicals used within a facility that are not disposed of or treated as hazardous waste.

B. 3 Water Programs and Datasets  The Office of Ground Water and Drinking Water ( OGWDW) maintains the Federal Reporting Data System ( FRDS), a repository of information about Public Water Supplies ( PWS) and their compliance with requirements of the Safe Drinking Water Act ( SDWA) of 1986 ( EPA, 1996a). This database does not include chemical exposure, end use, manufacturer, or production information as would be required under the IURA.

 The Office of Water ( OW) compiles the Permit Compliance System ( PCS), a computerized management information system containing data on National Pollutant Discharge Elimination System ( NPDES) permit holding facilities. Each permit record contains information that identifies permits, pollutant discharge limits, pollutants discharged in wastewater, and facility compliance schedules and violations. This database only contains industry specific information about the amount and type of chemicals discharged from various manufacturing and service industries, not information on site specific chemical production, worker exposure, or chemical end use ( Rubin, 1996; Strasler, 1996; EPA, 1996a).

B. 4 Environmental Information Programs and Datasets  The Office of Environmental Information ( OEI) administers the TRI ( this database was formerly administered by OPPT), which contains site specific information on the amounts of approximately 540 individually listed toxic chemicals and 22 categories of chemical compounds released directly to air, water, or land or transferred off site. Because the database only collects information on chemical releases, it does not contain site specific information on chemical production, use, or worker exposure ( EPA, 1996a).

B. 5 Pollution Prevention and Toxics Programs and Datasets  OPPT maintains the Premanufacture Notification ( PMN) database under the TSCA § 5 New Chemicals Program. The database contains physical/ chemical properties, use and predicted production information, worker exposure information, and process related information for " new" chemicals submitted for approval to begin commercialization. This data set provides information only on new chemicals and, therefore, has a negligible overlap with the data to be collected under the IURA.

 OPPT developed a joint voluntary program in cooperation with the American Chemistry Council ( formerly the Chemical Manufacturers Association, or CMA), Synthetic Organic Chemical Manufacturers Association ( SOCMA), Chemical Specialities Manufacturers Association ( CSMA), and American Petroleum Institute ( API). The program, entitled the Use and Exposure Information Voluntary Project ( UEIP), allows EPA to collect chemical use, exposure, and release information for certain chemicals targeted under EPA's Risk Management ( RM) program. Information has been collected in three groups ( two in 1994 and one in 1996) for 15 to 20 chemicals per group from a total of approximately 100 facilities. Because of the voluntary nature of the program and the limited number of chemicals examined, the data are not collected for most manufactured chemicals. Therefore, data generated from this project would have limited usefulness for initial risk screening activities. Rather, the data serve to inform the second step of risk characterization, after an initial risk screening. In other words, UEIP provides detailed information on a small number of chemicals for a select number of facilities, but extrapolating from this data set to develop a nationwide picture of use and exposure would be difficult and inadvisable. B 3  OPPT requires that chemical manufacturers and importers report facility identification, manufacturing, use, and exposure information as part of the Primary Assessment Information Rule ( PAIR). The type of information collected under the PAIR is similar to the type of information to be collected under the IUR amendments. However, the PAIR information is collected for only a very small, select set of chemicals during each reporting period, and the chemicals that are targeted under PAIR change from year to year based primarily on the priorities of the Interagency Testing Committee. Therefore, the information collected under the PAIR provides only a snapshot of the use and exposure of a small set of chemicals each year rather than a periodically updated record of toxic chemical manufacture, exposure, and use.

B. 6 Research and Development Programs and Datasets  The Office of Health and Environmental Assessment ( OHEA) maintains the Integrated Risk Information System ( IRIS), a database that contains summaries of known hazard data and EPA regulatory information on more than 500 specific chemicals. The database is not linked to chemical use and does not provide site specific characterizations of workplace exposure scenarios or production volumes.

B. 7 State Agency Data Collection Efforts  Massachusetts maintains a database of emission and process information ( i. e., quantity produced, process and end product description, and certain chemical identification and property information) from manufacturers, users, and processors within Massachusetts only. This database is part of an effort to reduce toxic wastes in the state ( Hope, 1996). The information is collected under the Toxic Use Reduction Act ( TURA); however, no exposure information regarding the number of potentially exposed workers or uses of the chemical ( e. g., NAICS codes, consumer uses) is collected under TURA ( MADEP, 1995).