vyEPA
United States
Environmental Protection
Agency
Office of Pesticides and
Toxic Substances
Washington, DC 20460
EPA 560/4-81-001
December 1980
Toxic Substances
Support Document
Commercial and
Industrial Uses of
Asbestos
Economic Analysis of
Reporting Forms
Proposed Rule - Section 8(a)
Toxic Substances Control Act
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EPA-560/4-81-001
December, 1980
ECONOMIC ANALYSIS OF REPORTING
FORMS, PROPOSED RULE SECTION 8(a)
OF TSCA FOR COMMERCIAL AND
INDUSTRIAL USES OF ASBESTOS
by
Susan Wright
Katherine Douglass
Philip Mathias
Contract No. 68-01-3930
Project Officers:
James w. Hughes/Richard A. Horner
Economics & Technology Division
Office of Toxic Substances
Washington, D.C. 20460
U.S. Environmental Protection Agency
Office of Pesticides and Toxic Substances
Washington, D.C. 20460
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PREFACE
The attached document is a contractor's study performed with the
supervision and review of the Office of Pesticides and Toxic Substances
of the U.S. Environmental Protection Agency. The purpose of the study
is to analyze the cost and economic impacts of the proposed rule
entitled "Reporting Commercial and Industrial Uses of Asbestos." This
proposed rule was prepared by the EPA Office of Pesticides and Toxic
Substances to partially implement section 8(a) of the Toxic Substances
Control Act.
This report was submitted in fulfillment of Research Request
Number 3 of Contract Number 68-01-3930, by Arthur Young & Company.
Work was completed as of October, 1980.
This report is being released and circulated at approximately the
same time as publication in the Federal Register of the proposed rule
on reporting Commercial and Industrial Uses of Asbestos under section
8(a) of TSCA. The study is not an official EPA publication. It will
be considered along with any comments received by EPA before or during
the proposed rulemaking proceedings in establishing final regulations.
Prior to final promulgation of this information gathering rule, the
accompanying study shall have standing in any EPA proceeding or court
proceeding only to the extent that it represents the views of the
contractor who performed the study. It cannot be cited, referenced,
or represented in any such proceedings as a statement of EPA's views
regarding the subject industry or the economic impact of the
regulation.
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TABLE OF CONTENTS
TITLE PAGE
i
PREFACE
iii
LIST OF TABLES
vi i
I.
INTRODUCTION
1
4
EXECUTIVE SUMMARY
1.
BACKGROUND
4
2.
OBJECTIVE AND SCOPE OF THIS STUDY
4
I I.
STUDY APPROACH
6
1.
DATA SOURCES
6
2.
TECHNICAL METHODOLOGY
8
III. STUDY RESULTS AND CONCLUSIONS
15
1.
THE AFFECTED INDUSTRY
15
2.
ESTIMATED REPORTING COSTS AND ECONOMIC IMPACTS
16
IV.
LIMITATIONS OF ANALYSIS
28
APPENDIX
A.
STATISTICS FOR COMPANIES WITH 10 OR FEWER
EMPLOYEES
31
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LIST OF TABLES
1.
18
MEDIAN TIME ESTIMATES FOR EPA FORM 7710-36
2.
MEDIAN TIME AND COST ESTIMATES FOR FORM 7710-36
FOR PRIMARY PROCESSORS
19
3.
MEDIAN TIME AND COST ESTIMATES FOR FORM 7710-36
FOR MINERS AND MILLERS
20
4.
MEDIAN TIME AND COST ESTIMATES FOR FORMS 7710-36
AND 7710-37 FOR SECONDARY PROCESSORS
21
5.
MEDIAN TIME AND COST ESTIMATES FOR FORMS 7710-36
AND 7710-37 FOR BULK ASBESTOS IMPORTERS
23
6.
MEDIAN TIME AND COST ESTIMATES FOR FORMS 7710-36
AND 7710-37 FOR IMPORTERS OF ABESTOS MIXTURES
OR ARTICLES CONTAINING ASBESTOS
24
7.
26
TOTAL ESTIMATED INDUSTRY IMPACT
8.
ESTIMATION OF THE ECONOMIC IMPACT FOR REPORTING
THE USE OF ASBESTOS AND ASBESTOS MATERIALS -
PRIMARY PROCESSORS
27
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EXECUTIVE SUMMARY
This report presents estimates of the cost and economic impact
of EPA's proposed implementation of the section 8(a) reporting rule
on the commercial and industrial uses of asbestos~ This regulation
is proposed to be implemented in two phases. In the first phase,
miners/millers, primary processors and importers of bulk asbestos will
report on EPA Form 7710-36. Secondary processors and importers of
asbestos mixtures and articles containing asbestos components will
also report in this phase but on the much less detailed Form 7710-37.
In the second phase, approximately 20% of the respondents in the
industry categories that were required to complete Form 7710-37 in
the first phase will also report on Form 7710-36. The actual number
that will respond to Form 7710-36 in the second phase will be determined
after examining the composition of respondents submitting Form 7710-
37.
This report also presents a discussion of the major data sources
used in developing estimates for this project. Through the utilization
of several key data sources (such as the GCA Corporation Master List,
listings of primary processors provided by the Research Triangle
Institute, the U.S. Bureau of Mines and the Mine Safety and Health
Administration, U.S. Customs Service, and the Weston Reportl/) as
complete a list as possible of affected firms and establishments was
developed and grouped according to industrial category.
Total cost estimates were based on reporting time estimates
obtained in a pre-test of EPA Form 7710-36 and standard industrial
labor costs. The labor costs were estimated using standard industrial
rates which have been utilized in similar analyses. In order to obtain
estimates of the time required to complete Form 7710-36, the
availability of the requested information and feedback on the clarity
of the form, the Institute for Survey Research (ISR) of Temple
University conducted a pre-test of the form. Members of the Asbestos
Information Association (AIA) participated in the pre-test. The
results of this test, presented in Section II of this report, were used
by EPA as the basis to estimate the median costs to complete each
section of the form. These EPA estimates were used by Arthur Young
in determining the cost and economic impacts derived in this report.
A description of the methodology and rationale behind these estimates
can be found in Section II of this report under "Estimation of Reporting
Costs".
~nTechnological Feasibility and Economic Impact of OSHA's Proposed
Revision to the Asbestos Standard," Roy F. Weston, Inc., March 1976.
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The total cost of this proposed regulation to the asbestos
industry was estimated to be about $2 million when small bu~in:sse~
(firms with ten or fewer employees) are exempted, and $3.3 m1ll1on 1f
small businesses are not exempted. Considering only the first phase
of the regulation, secondary processors bear the highest total cost
as a group ($0.65 million), followed by importers of bulk asbestos
($0.18 million), primary processors ($0.13 million), importers of
asbestos mixtures and articles containing asbestos components
($43,800), and miners/millers ($3,600). When the second phase is
considered, additional estimated costs of $1.1 million for secondary
processors and $45,990 for importers of asbestos mixtures and articles
containing asbestos components are incurred.
The economic impact of the implementation of the proposed
regulation in terms of cost as a percent of profits could only be
determined for the primary processors. Lack of data in the other three
industry categories (miners/millers, secondary processors, and
importers) did not allow a similar estimation. For primary processors
the regulation appears to have a relatively low impact (in terms of
cost as a percent of profits) ranging from 0.1% to less than 0.01%.
Since this study relied heavily on inputs from other studies, its
results are closely tied to those inputs. The major data sources for
this study (the GCA Master List and the ISR Survey) had certain
limitations which affected the completeness of this study's results.
The wide range of unit reporting time estimates for EPA Form
7710-36 were based on the variations in responses to the ISR industry
survey. This wide range is due, in the opinion of the authors, to
uncertainty on the part of the industry as to the specific requirements
of certain sections of the form.
During the course of the project, the EPA staff revised the
structure and content of several portions of EPA Form 7710-36.
Consequently, some of the data obtained by ISR were no longer
applicable. The revised sections (Sections G and H of Form 7710-36)
had reporting time estimates determined by the EPA staff, based on
their general experience with similar forms. In addition, reporting
time data for Parts D, E, and F of this form were inadequate because
the firms selected by AlA to participate in the pre-test included only
one secondary processor and one importer of asbestos mixtures and
articles containing asbestos components. Therefore, estimates for
Parts D, E, and F were derived by EPA staff based on the estimates for
Part c.
It is possible that there was over- or under-identification of
the number of firms in the asbestos industry, particularly with respect
to secondary processors. The main data source for this study, the GCA
Master List, did not attempt to list secondary processors because of
the ge~eral unav~i~abi~ity of information with which to identify these
companles. Identlflcatlon of secondary processors is one of the primary
purposes for the development of the section 8(a) rule. The use of
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several data sources facilitated the identification of primary
processors and importers. An adjustment, based on the methodology
utilized in the Weston report, was the only alternative for the
estimation of the number of secondary processors.
Despite the above limitations, this study produced meaningful
results. The cost estimates, though subject to a number of
qualifications, provide a reasonable basis for judging the overall
cost of the proposed action.
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I.
INTRODUCTION
This chapter discusses the background, scope and objectives of
the study. The first section summarizes the requirements of the
proposed EPA rule. The second section discusses the objectives of the
study and outlines the specific tasks that were performed to fulfill
these objectives.
1.
BACKGROUND
On October 17, 1979, the Envi ronmental Protection Agency publ ished
an Advance Notice of Proposed Rulemaking (ANPR) which would require,
under the authority of section Sea) of the Toxic Substances Control
Act (TSCA), the reporting of detailed technical data to EPA by asbestos
miners and millers, processors, and importers.
This regulation is intended to be implemented in two phases. In
the first phase, miners/millers, primary processors and importers of
bulk asbestos will report on EPA Form 7710-36. Secondary processors
and importers of asbestos mixtures and articles containing asbestos
components will also report in this phase but on the much less detailed
EPA Form 7710-37. In the second phase, approximately 20% of the
establishments that completed EPA Form 7710-37 in the first phase will
also report on EPA Form 7710-36. The types of establishment~ that
will be required to respond on EPA Form 7710-36 in the second phase
will be determined after receipt of the data in the first phase. Data
on EPA Form 7710-36 (much of which are considered confidential business
information and thus not otherwise available) include total amounts
and uses of asbestos and asbestos containing materials and articles,
employee exposure and monitoring data, and waste disposal and pollution
control information. EPA Form 7710-37 requires basic respondent and
product identification information.
2.
OBJECTIVE AND SCOPE OF THIS STUDY
The overall objective of this study is to analyze and present
estimates of the cost and economic impact of the implementation of
EPA's anticipated section Sea) rule requiring reporting of production,
exposure and other such information related to asbestos and materials
and products with absestos components.
Meeting this objective involved the following:
.
Use of the reporting time estimates provided by industry to
the Institute for Survey Research (ISR), and use of the
Master List of potential respondents to this rule compiled
by GCA Corporation (GCA). In addi tion, other sources of data
were reviewed and utilized to provide additional
information.
:)
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.
Industry segmentation by employment size was attempted for
all categories, but the nature of the employment data
permitted this segmentation only for primary processors.
For these industries, the following ranges of firm size were
chosen: firms with less than 10 employees, firms with
between 11 and 30 employees, firms with between 31 and 50
employees, firms with between 51 and 100 employees, firms
with between 101 and 500 employees, firms with between 501
and 1000 employees, firms with between 1001 and 2500
employees, and firms with more than 2500 employees. The
industrial categories identified were primary and secondary
processors of asbestos, miners and millers, importers of bulk
asbestos, and importers of asbestos mixtures and articles
containing asbestos components.
Tabulation of median reporting time estimates provided by
ISR and EPA staff. The cost estimates were tabulated for
each industry category and, for primary processors, for each
employment size category.
Estimation of economic impact (the total cost of the
reporting rule expressed as a percentage of gross profit).
Although attempts were made to develop this estimate for
all industrial categories, available data only supported
estimates for primary processors. For the other categories,
estimates of the cost of compliance were developed.
An essential intermediate step in meeting the objective of the study
was the development of detailed listings of affected firms and
establishments. These listings are by industry category and include
any available sales and employment data.
.
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II.
STUDY APPROACH
This chapter presents a discussion of the procedures and
assumptions used to estimate the cost and economic impact of the
proposed reporting regulation. The first section contains a review
of the data sources. The specific approaches used in this analysis
are presented in the second section with discussions on the
categorization and counts of the affected firms, and estimation of
unit reporting costs.
1.
DATA SOURCES
The final count of United States miners, millers, importer~, and
processors of bulk asbestos and asbestos products was compiled from
the following data sources:
GCA Corporation's Master List of firms and establishments
in the asbestos industry
Research Triangle Institute's list of primary processor
firms and their establishments
U.S. Customs Service data on importers of bulk asbestos and
asbestos mixtures and articles containing asbestos
components
A March 1976 report by R. Weston, Inc. for AIA on the economic
impact of OSHA asbestos regulations
U.S. Bureau of Mines 1979 Annual Asbestos Edit Listing of
primary processors.
Mine Safety and Health Administration (personal
communication).
A description of these sources and the type of data obtained is
presented below. Some of these documents (such as the GCA Master List,
the Weston Report and the RTI Report) are part of the section 8(a)
rulemaking public record and are available for inspection and review.
(1)
GCA Master List
GCA Corporation compiled a Master List (the purpose of which
was to identify the kinds of asbestos processors potentially
subject to the rule so that copies of the final rule and form
could be mailed to potential respondents) of 2,928 miners,
millers, importers, and processors of bulk asbestos and materials
containing asbestos from a variety of sources. This list was
available on computer tape. Of the total, approximately 2,146
firms were identified from Dun and Bradstreet computerized'
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listings of establishments for SIC codes 2891 (adhesives and
coatings), 2952 (asphalt felts and coatings) 3292 (asbestos
products) and 3293 (gaskets, packings, and sealing products).
The remainder of the list, over 700 names, was based on seven
other identified sources of information. These sources consisted
of the GCA Technology Division "Life Cycle" documents, a Journal
of Commerce list of asbestos importers and the following EPA-
supplied lists: Asbestos Information Association list, NESHAP
(National Emission Standards for Hazardous Air Pollutants)
listing from EPA Compliance Data System, NIOSH printout of
aSbestos-containing products, Bureau of Mines mailing list, AIC
Pipe Producers Association members, Friction Materials Standards
Institute members.
(2)
Research Triangle Institute
(RTI)
RTI, as part of the development of an asbestos industry
profile, identified 122 establishments (73 firms) as primary
processors by type of product line. These firms were identified
as being contained in one or more four-digit SIC code areas,
(3292, 3293, 3996 and 2661), with the majority being in SIC 3292.
SIC codes 3292 and 3293 were previously defined. Of the remaining,
SIC 3996 contains linoleum, asphalt-felt base, and other hard
surface floor coverings. SIC 2661 contains building paper and
building board mills.
(3)
U. S. Customs Service
A list of importers of asbestos products was obtained from
the U.S. Customs Service. Asbestos imports are declared within
ten product categories of the tariff schedule of the U.S.,
Annotated (518.1100-518.5400). The Customs Service list for
approximately 575 firms is not exhaustive as only those articles
that are clearly marked as containing asbestos are included.
These imported products are coded to distinguish between bulk
asbestos, and asbestos mixtures and articles containing asbestos
components.
(4)
Weston Report
This report, entitled Technological Feasibility and Economic
Impact of OSHA's Proposed Revision to the Asbestos Standard,
prepared by Roy F. Weston Environmental Consultants - Designers
(Weston Report) for AIA in March 1976, was utilized to obtain
industry-wide estimates of the number of secondary processors.
It provided detailed listings of the type of asbestos products
but only an aggregate estimate of the number of establishments.
The purpose of the report was to provide estimates of the impact
of a 1975 OSHA proposal to lower the asbestos workplace standard.
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(5)
Mine Safety and Health Administration
The Mine Safety and Health Administration identified five
firms operating four asbestos mills and four mines in the U.S.
(6)
U.S. Bureau of Mines
The U.S. Bureau of Mines, 1979 Annual Asbestos Edit Listing,
identified the names and locations of 128 primary processors of
asbestos (6 more than RTI and 89 more than GCA).
This project also required data to be obtained on SIC codes and
firm level sales and employment data for facilities identified as
processing and importing asbestos mixtures and articles containing
asbestos components. The following sources were used in this effort:
Dun & Bradstreet's Million Dollar and Middle Market
Directories. The 2000 and 3000 series for SIC codes 2891,
2962, 3292, 3293 were available on tape from EPA.
Standard and Poor's Directory.
Small Business Administration's Share of Market Data.
This effort was partially successful as sales and employment data
for the majority of secondary processors were unavailable (because
they could not De identified), and were not adequate for importers.
Only employment data were available for miners/millers, sales data
were not.
The analysis required development of average gross profit
percentage (on sales) by SIC code, by employment segment for primary
processors (the only industry category for which data were available).
In addition to sales, total wages and materials, and value of shipment
data were required for the calculation. These data were obtained from
the 1972 Census of Manufactures. To confirm no appreciable change in
the gross profit percentage figures over time, the results were spot
checked against the 1977 Census of Manufactures.
The major input to the development of unit reporting costs was
an industry survey of eight respondents performed by the Institute
for Survey Research (ISR). These data consisted of estimates of time
and the type of personnel required to complete each section of EPA
Form 7710-36. EPA, after review of these data, provided median
estimates of the hours required to complete the forms (see discussion
under "Estimation of Unit Reporting Costs").
2.
TECHNICAL METHODOLOGY
Discussion of our approach to the cost and economic impact
estimation tasks of this project is in four parts: definition of the
affected industries, identification of affected firms that are small
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businesses, estimation of unit reporting cost for the various affected
industrial categories, and estimation of the economic impacts of the
proposed regulation.
(1 )
Definition of the Affected Industries
The characterization of the affected industries was
performed in three steps. First, the establishments of each firm
processing, mining, mill ing or importing asbestos were identif ied.
Second, these firms were identified, wherever possible, according
to the size of the firm (total number of employees), into the
previously specified segments (less than 10, 11-30, 31-50, 51-100,
101-500, 501-1000, 1001-2500, 2501 and over employees). Third,
the firms were grouped into the industrial categories of primary
processors, secondary processors, miners/millers, and importers.
An EASYTRIEVE program was used to generate many of the lists
needed for this task.
Identification of Number of Plant Sites
(Facilities)
The identification of the number of plant sites in each
industry category was necessary in order to determine the
number of reports which would be required for each category
The data sources listed in Section I above were used in this
effort. Care was taken to avoid double counting of firms
and establishments which may be listed on more than one
source. Importers were considered at the firm level only
(one firm completing one report), so the plant sites were
not identified.
To determine the number of plant sites a list of branch
sites was generated and manually matched with a listing of
firm headquarters to determine the actual number of firms.
The financial sources described in the first section were
searched to locate headquarters of any unmatched branch
sites.
To estimate the number of potential reports the number of
firms and plant sites were tabulated. The total number of
firms consisted of all firms (independent and headquarters)
identified in the category. The total number of plant sites
reflects the sum of all branches, independent and headquarter
locations. To determine total reports the number of plant
sites was adjusted to remove sites at which the relevant
industry activity (primary, secondary processing,
milling/mining or importing) did not occur.
Identification of Firms By Size
A grouping of affected firms was performed using total
employment as the measure of size. The initial grouping of
firms by total number of employees was generated by sorting
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the firms listed on the computer tape of firms from Dun &
Bradstreet that was originally created for GCA's asbestos
industry study.
The list of firms not identifiable from the Dun & Bradstreet
computerized list was checked against Dun & Bradstreet's
Million Dollar and Middle Market Directories, Standard and
Poor's Directory, and the Small Business Administration Share
of Market lists to obtain employment data (total employment,
or employment for the entire firm, was used as opposed to
site employment). When total employment for the firm was
determined using the aforementioned financial sources, the
firm was included in its proper employment size segment. In
cases where total employment data were not available, the
firms were placed in an unclassified segment.
Identification By Industrial Category
Since the proposed regulation requires that different
asbestos industries provide different information, thus
influencing the cost of reporting for each industry, it was
necessary to determine the number of firms within these
categories: importers, miners/millers, primary processors,
and secondary processors. The Master List of asbestos firms
provided by GCA was used as the first source of data on
these categories, with supplemental information obtained
through various other sources: for miners and millers
through personal communication with the Mine Safety and
Health Administration; u.S. Customs helped identify
importers; RTI and the Bureau of Mines assisted in
identifying primary processors.
As the number of secondary processors was not adequately
identified from any known source, the number of secondary
processor establishments was calculated using the
methodology of the Weston Report. An average plant site
employment was calculated for all secondary processors by
sampling from the employment data from firms on the GCA list
which were assumed to be secondary processors. That is, they
were not positively identified as being primary processors,
importers or miner/millers. That average employment was
then divided into the total secondary processor category
employment (300,000) identified in the Weston Report for the
Asbestos Information Association of North America. This
resul ted in an estimate of the total number of establ ishments
in the secondary processor category.
In summary, the results of efforts to define the affected
industry were mixed. Data on primary processors and
miners/millers appeared adequate to support employment
segmentation. However, data on importers which included a large
portion of unclassified firms, and secondary processors were quite
inadequate.
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(2)
Identification of Small Businesses
A definition of small business for this proposed rule which
was developed by EPA and is used in this study characterizes
firms with 10 or less employees as small. Since small businesses
are proposed to be exempt from the proposed regulation, they need
to be excluded from the count of affected firms.
The small businesses in the primary processor and mine/mill
segments were identified directly from their employment
segmentation since relatively complete data were obtained.
In the secondary processor segment, an estimate was made
that 40% of the unclassified firms are small firms. The estimate
of 40%, which was developed by EPA staff, is based on an analysis
by GCA of the types of industries which may process asbestos.
GCA identified 54 four-digit SIC codes. EPA used Dun and
Bradstreet data to determine the percentages of sales, employees,
and establishments in those SIC codes of businesses with ten or
fewer employees. These figures were then averaged for all SIC
codes. The EPA analysis estimates that while approximately 43%
of these firms employ ten or fewer employees, these firms account
for less than 3% of the sales and employees in these ~ategories.
A detailed report of the analysis can be found in a memo in the
public record entitled "Statistics for Companies with Ten or
Fewer Employees". (Copy attached as Appendix A)
Due to a number of considerations, an estimate of small
businesses was not developed for either importer category. Th~
presence of a large unclassified segment precluded the direct
approach used for primary processors and miners/millers. The
analysis described above for secondary processors does not apply
either since the SIC codes involved cover a much larger range
including the 5000 and above series (service and other non-
manufacturing industries). There thus does not seem to be a
reasonable basis for estimating the number of small businesses
for importers.
(3)
Estimation of Unit Reporting Costs
We discuss below our approach to estimating unit reporting
costs. Separate discussions are provided for each type of
reporting form.
EPA Form 7710-36
EPA Form 7710-36 was pre-tested by eight members of the
Asbestos Information Association (AlA). The test was
coordinated for EPA by Institute for Survey Research (ISR)
of Temple University. The purposes of the pre-test were to
obtain feedback on the clarity of the form, the availability
of the requested information, and the time required to
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complete the form. AlA was asked to select firms from each
of the industry segments to be affected by the rule (miners,
millers, primary and secondary processors, and importers).
A complete description of the methodology and results of
the pre-test may be found in the lSR report "Design and
Testing of Asbestos Use Reporting Form", which is part of
the EPA public record. The results of the pre-test can be
examined in Tables 1 and 3.
Since the range of reporting time estimates was very wide
in most cases, EPA decided to develop a single median
estimate for each section of the form. The median estimate
was used for two reasons. First, EPA wanted to incorporate
all of the pre-test results since there were few data points
in the first place. Second, other measures of central
tendency, such as a geometric mean, could be artificially
high because of high outlier estimates by a single
respondent.
To develop the median estimate for each section of the form,
EPA examined the results of the ISR report and tried to find
a middle value. Where there was no apparent middle value,
EPA estimated the median value. In certain sections where
there were few or no estimates from the respondents, EPA
estimated the value by comparing the data requirements in
the unknown section to the time estimates for similar data
in other sections. Thus, the median estimates foe Part D,
Secondary Processor Production, was derived from the
estimates to complete Part C, primary Processor Production.
Parts G and H were substantially revised as a result of the
pre-test. After the revisions, EPA developed median
estimates of the time required by those sections that are
based on estimates in the rest of the form and experience
with the costs associated with similar reporting
requirements.
Although it is assumed that several personnel categories
will be involved in completing EPA 'Form 7710-36, data from
ISR did not provide a detailed labor rate breakdown for
different categories (See Table 1). An average labor rate
of $30 per hour was derived by EPA staff by assuming costs
for middle management (technical) personnel at $30/hour, and
by assuming that respondents would expend amounts of
technical time, clerical time (less than $30/hour) and legal
time (more than $30/hour) so as to average to $30/hour for
all labor.
For miners/millers, time estimates were calculated based on
the completion time data provided by miners/millers from
the ISR pre-test results. This was considered representative
since there are only five miners/millers in the United
States, and two (40%) of them had served as respondents on
the ISR pre-test.
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Primary processors, and miners/millers were assumed to be
required to report on Sections G-K, with primary processors
required to report on Sections A-C, and miners and millers
reporting on Sections A and B. Importers of bulk asbestos
were assumed to be required to report on Sections A, B, G, H
and I.
primary processors that also import would complete Sections
E or F, as would importers who import all types of asbestos
products. Further, primary processors who also engage in
secondary processing would complete Section D. However,
since these proportions are-unknown, they have not been
factored into the unit costs.
During the second phase of the proposed regulation EPA
estimates that a sample of approximately 20% of secondary
processors will be required to complete Form 7710-36,
Sections A, D, and G-K. EPA further estimates that 20% of
importers of asbestos mixtures and articles containing
asbestos components will also be required to complete Form
7710-36 during the second phase, reporting on Sections A, E
or F (depending on the type of material imported), and G-I.
The unit cost for Form 7710-36 was calculated for each
industrial category of the asbestos industry. This was
accomplished by adding the costs associated with each
section that the particular industry will be required to
complete. No information was available to correlate the
amount of data required to be provided by firms of various
sizes with the amount of time needed to complete the form.
This item is discussed in Chapter IV. The resulting unit
costs are listed in Tables 2 through 6.
EPA Form 7710-37
The unit cost for completing Form 7710-37 was estimated to
be $120. This estimate is based on the revised version of
Form 7710-37, for which no industry time estimates were
available. It was assumed that Part 1 of Form 7710-37 would
take as much time to complete as the median time estimate
for Section A of Form 7710-36, and that the rest of Form
7710-37 would require as much time -as the median time
estimate for Section B of Form 7710-36. The same $30/hour
average rate for all personnel was utilized.
(4)
Economic Impact Analysis
The reporting cost of the proposed 8(a} rule was calculated
for each industry category. It was estimated as the product of
the total number of reports (forms) to be completed by each
respondent and the appropriate unit reporting cost. For primary
processors the reporting costs were also expressed as a percentage
14
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of gross profit. The unavailability of adequate sales and
employment data (section 1 above) precluded analysis of economic
impacts in the other industry categories.
Total firm gross profit (see Table 8) was calculated as the
product of gross profit percentage and average firm sales times
the number of firms in the employment size segment. The gross
profit percentage estimation is the ratio of value of shipments
minus total wages and materials to value of shipments.
The data were obtained from the Census of Manufactures by
4-digit SIC code. The specific 4-digit SIC codes on which the
gross profit percentage data were based were the SIC codes that
appeared most prevalent in the industrial category. For primary
processors, these were the four SIC codes identified by GCA (SIC
codes 3292, 3293, 2891, and 2952).
Within each employment size segment the gross profit
percentage was calculated for each of the SIC codes chosen and
averaged for the employment size segment. Average annual sales
data were calculated by simple averaging of sales data of the
affected firms in each employment size segment.
15
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III.
STUDY RESULTS AND CONCLUSIONS
This chapter presents and discusses the results of this study of
the costs and economic impacts of the implementation of the proposed
8(a) rule on asbestos. The affected industry is described in Section
1. Section 2 presents the estimated reporting costs and economic
impacts of primary processors.
1.
THE AFFECTED INDUSTRY
This item is discussed separately for the four affected
industrial categories (miners/millers, importers, primary
processors, and secondary processors).
Miners/Millers
Five asbestos miners/millers currently operate four mines
and four mills in the United States. It appears that there
is one very large firm, the rest being much smaller
(including one firm that has less than 10 employees). At
least one of these establishments is operated on an
intermittent basis.
Primary Processors
There are an estimated 80 primary processor firms (128
establishments) including, at a minimum, 5 firms (7
establishments) that have ten or fewer employees. The number
of affected firms and plant sites increases substantially
from the 51-100 employees segment (4 firms) to the 101-500
employees segment (17 firms). There is a similarly large
increase from the 501-1000 employees segment (2 firms) to
the 1001-2500 employees segment (15 firms). The 1001-2500
employees segment also appears to contain the largest number
of affected plant sites per firm. The unclassified segment
was relatively small for the primary processors, since more
detailed information was available for those firms from an
ongoing study (RTI) and from the U.S. Bureau of Mines. The
unclassified segment may be due, as in the case of importers,
to the fact that the establishments are small, relatively
new, and branches or subsidiaries of other unidentifiable
firms. It is not possible from the available data to infer
what their approximate employment size distribution might
be.
.
Importers of Bulk and Asbestos Mixtures and Articles
Containing Asbestos Components
17
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There are an estimated 361 firms that import bulk asbestos
and an estimated 365 firms that import asbestos mixtures or
articles containing asbestos components. Although the
importing firms were all identified by name, available data
could not support an employment size breakdown of firms. A
large portion of each category was unclassified. As these
unclassified firms were not listed in any of the standard
sources for financial and employment data, they may be small
solely owned companies or agents. These firms may also be
newly formed firms (not included in the 1979 D&B or S&P
lists) or firms related to other corporations, but having
different names.
The number of firms importing asbestos mixtures and articles
containing asbestos components may be underestimated, as
there is no way to identify many of the articles now
imported. The reporting costs of this segment may,
therefore, be greater than the total cost reported in Table
6.
Secondary Processors
There are an estimated 8,974 secondary processor
establishments, the majority of which are not currently
identifiable. Of these establishments, 3,589 are estimated
to have less than 10 employees.
2.
ESTIMATED REPORTING COSTS AND ECONOMIC IMPACTS
(1)
Estimated Reporting Cost
Tables 2 through 6 present the median estimated costs for
the different industrial segments affected by the section 8(a)
reporting rule. A miner/miller should expect a median cost of
$720 and a primary processor a median cost of $1,080. The median
estimated cost for secondary processors to complete EPA Form
7710-37 is $120, and the secondary processors selected to complete
Form 7710-36 during the second phase should expect an additional
median cost of $990. Importers selected for the second phase
reporting of EPA Form 7710-36 should expect a median cost of $630,
in addition to the initial cost of $120 to complete EPA Form
7710-37.
The estimated total median cost for the asbestos industry
to comply with the proposed regulation is $2,120,610, excluding
small businesses with ten or fewer employees. This can be broken
down by industry as follows (See also Tables 2 through 7):
Primary Processors (EPA Form 7710-36):
$130,680
Miners/Millers (EPA Form 7710-36):
$3,600
18
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Importers of Bulk Asbestos (EPA Form 7710-36):
$184,110
Importers of Asbestos Mixtures and Articles Containing
Asbestos Components, First Phase (EPA Form 7710-37):
$43,800; Second Phase (EPA Form 7710-36): $45,990
Secondary Processors, First Phase (EPA Form 7710-37):
$646,200; Second Phase (EPA Form 7710-36): $1,066,230
If small businesses are included, the total estimated median cost
to industry is $3,270,000.
(2)
Economic Impact on Primary Processors
The economic impact of the implementation of the proposed
regulation in terms of cost as a percentage of profits was
determined for primary processors. The regulation appears to
have a low impact on the over 2,500 employees segment (under
0.01%). The three lowest size categories (11-30, 31-50, and 51-
100 employees) appear to be affected to similar extents (0.1%,
0.09%, and 0.08% of gross profits, respectively). The impact
decreases considerably from the 51-100 employees segment to the
101-500 employees segment (0.08% to 0.01%) and remains low (.02%
or less) for the remaining segments (501-1,000, 1,001-2,500, and
over 2,500 employees) (see Table 8).
Since there are insufficient data to characterize the other
industry segments which are subject to the rule, gross profit
analysis for these segments is not incorporated in this report.
Even though the above analysis was conducted using limited
information and information of varying reliability, meaningful results
and data were obtained. The primary processor industrial category has
been reasonably established in terms of numb9rs of firms in the
category, identification of these firms by name and site, employment
size and sales. Also, the cost of reporting and the economic impact
of this cost developed for primary processors will aid in the
assessment of the potential burden on industry to comply with the
proposed rule.
19
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MEDIAN TIME ESTIMATES FOR EPA FORM 7710-36
(All industrial segments except miners/millers)
Respondents (Hours)..!.! Median time 1
Section of Form A A B C F G H Estimates (hours)-/
A (Identification) 0.17 0.33 0.75 0.5 0.5 1.5 0.5
B (Bulk Asbestos) 0.5 0.42 12.0 3.0 3.0 20.0 3.0
C (Primary Processors) 0.67 14.0 90.0 4.0 1.5 10.0 7.0
D (Seconda ry processors)1.1 7.0
E (Impo rte r of Mixtures)l.! 7.0
F (Importer of Articles)l/ 12.0 7.0
G (Employees ).!I 2.0
H (EXposures).!/ -, 6.0
tV
01 (Emissions) 0.5 0.08 8.0 0.5 1.0 0.5
J (Waste and Disposal) 0.17 0.25 24.0 6.0 1.0 8.0 2.0
K (Pollution Control Equip.) 16.0 1.5 60.0 6.0 40.0 8.0 10.0
1/ The time estimates provided by respondents included cIeri cal assistance as part of middle
management time for completion. Legal time was not included in any of these time estimates.
1./ No data were obtained by ISR on Section D. Costs were assumed by EPA to be similar for Sections
C and D since basic production data should be of the same order of difficulty to obtain for primary
(section C) or secondary (section D) processors.
1/ As little data were available on importers, sections E and F are assumed by EPA to be similar
to sections C and D.
.!/ Sections G and H have been greatly modified since the ISR pre-test. Hence the ISR obtained
estimates for these sections no longer apply. EPA staff reestimated the ISR time estimates based
on the changes made to the sections and previous experience with similar information.
Source:
Time estimates - ISR Repart, Design and Testing of Asbestos Use Reporting Form, June 30,
1978.
Median time estimates - EPA
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TABLE 2
MEDIAN TIME AND COST ESTIMATES FOR FORM
7710-36 FOR PRIMARY PROCESSORS
Relevant Reporting
Section
Median Time
Estimates (Hours)
Per Site
~~/
of Form
0.5
3.0
7.0
2.0
6.0
0.5
3.0
10.0
5.0
36.0
$
A
B
C
G
H
I
J
K
Leg al Rev i ew
Total
15
90
210
60
180
15
60
300
150
$1,080
Cost of Form 7710-36
Per Plant Site
$1,080
Number
of Sites 1/
121
Total Cost
To Segment
$130,680
~/ primary Processors with integrated secondary processor operations
will also report Section D. This quantity is unknown, however, so no
estimate of cost is included.
~/ Weighted average hourly cost of $30 is used to reflect combined
costs of management, legal and clerical assistance. (provided by EPA)
2/ Estimate excludes seven establishments which were positively
identified as belonging to firms with 10 or less employees. These
establishments are exempted from reporting per the small business
definition of this rule. This estimate of small businesses is a minimum
estimate as there may be firms in the unclassified segment that also
qualify as small businesses. These small firms were identified
utilizing the methodology previously discussed (pages 13-16) and the
financial data sources previously mentioned on page 12.
Note:
If the small business exemption were not applied, the cost for
primary processors would be 128 establishments at $1,080 per
report for a total cost of $138,240.
21
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TABLE 3
MEDIAN TIME AND COST ESTIMATES FOR
FORM 7710-36 FOR MINERS AND MILLERS
Relevant Per Site
Reporting Respondents (Hours) Median Time
Section D E Estimates (Hours) Cost2/
A 0.08 0.25 0.2 $ 5
B 0.50 0.33 0.4 13
G 2.01/ 60
H 6. oll 180
I 0.08 0.08 2
J 0.08 3.0 1.5 45
K 9.0 9.0 270
Review of Form 5.0 150
Total 24.0 $720
Cost of
Form 7710-36 Number Total Cost
Per Plant Site Of Sites1/ to Segment
$720 5 $3,600
.1/
See footnote 4 of Table 1 for explanation.
1/ Weighted average hourly cost of $30 is used to reflect combined costs
of management, legal, and clerical assistance. (Provided by EPA)
1/ Six mine and mill sites are currently active, one of which is exempted
from the 8(a) requirement per the small business definition of 10 or less
employees. One other mill operates on an intermittent basis. The small
firm was identified utilizing the methodology previously discussed (pages
13-16), and the financial data sources mentioned on page 12.
Note:
If the small business exemption were not applied, the cost for
miners and millers would be 6 establishments at $720 per
establishment for a total cost for $4,320.
Source:
Respondent time estimates - ISR Report, Design and Testing
of Asbestos Use Reporting, June 30, 1978.
22
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TABLE 4
MEDIAN TIME AND COST ESTIMATES FOR
FORMS 7710-36 AND 7710-37 FOR SECONDARY PROCESSORS
FORM 7710-37
Median Time
Estimates (Hours)l/
Per Plant
Cost2/
Section
Part 1
Rest of Form
Legal Review
Total
of Form
0.5
3.0
0.5
4.0
$ 15
90
15
$120
Cost of Form
Per Plant Site
Number
of Sites3/
Cost
to Segment
$120
5,385
$646,200
FORM 7710-36
Relevant Reporting
Sections
Median Time
Estimates (Hours)
Per Plant
Cost
A
D
G
H
I
J
K
Legal Review
Total
of Form
.5
7.0
2.0
6.0
.5
2.0
10.0
5.0
33.0
$ 15
210
60
180
15
60
300
150
$9902/
Cost of Form
Per Plant Site
Number
of Sites4/
-
Cost
to Segment
$990
1,077
$1,066,230
Total cost for Secondary Processors:
$ 646,200
1,066,230
$1,712,430
EPA Form 7710-37
EPA Form 7710-36
23
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1/
EPA Form 7710-37 time estimates were provided by EPA.
1/ Weighted average hourly cost of $30 is used to include costs of
management, legal and clerical assistance. (Provided by EPA)
2/ EPA assumed that approximately 40% (out of 8974 establishments)
of the secondary processors are small (10 or fewer employees) and
exempt from reporting.
~/ Of the secondary processors completing EPA Form 7710-37,
approximately 20% will be required, according to EPA, to complete EPA
Form 7710-36 during the second phase.
Note:
If the small business exemption were not applied, the cost for
secondary processors would be 8,974 establishments at $120 per report
for the first phase = $1,076,880 plus 1795 establishments at $990
per report for the second phase = $1,777,050 for a total of $2,853,930.
24
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TABLE 5
MEDIAN TIME AND COST ESTIMATES
FOR FORM 7710-36 FOR BULK ASBESTOS IMPORTERS
Relevant
Reporting
Section
Median Time
Estimates (Hours)
A
B
G
H
I
Legal Review
Total
of Form
.5
3.0
2.0
6.0
.5
5.0
TI':"O
Per Site
Cost,l/
$ 15
90
60
180
15
150
$510
Cost of Form 7710-36
Per Plant Site
Number
of Sites
$510
361
Total Cost
to Segment~/
$184,110
1/ Weighted average hourly cost of $30 is us~d to reflect combined
costs of middle management, legal and clerical assistance. (Provided
by EPA)
1/ Data were not sufficient to identify small businesses. Due to
this limitation and to the possibility that some portion of the
identified 361 firms are import agents, (and therefore not required
to report), these costs could be overstated.
25
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TABLE 6
MEDIAN TIME AND COST ESTIMATES
FOR FORMS 7710-36 AND 7710-37 FOR IMPORTERS
OF ASBESTOS MIXTURES OR ARTICLES
CONTAINING ASBESTOS
FORM 7710-37
Median Time
Estimates (Hours)l/
Cost2/
Section
Part 1
Rest
Legal Review
Total
of Form
.5
3.0
.5
4.0
$15
90
15
$TIO
Cost of Form
Per Plant Site
Number
of Sites
Cost
To Segment
$120
365
$43,800
EPA FORM 7710-36
Relevant Reporting
Sections
Median Time
Estimates (Hours)
Cost2/
A
E or F3/
G
H
I
Legal Review of Form
Total
.5
7.0
2.0
6.0
.5
5.0
n:o
$ 15
210
60
180
15
150
$630
Cost of Form
Per Plant Site
Number
of Sites4/
-
Cost
To Segment
630
73
$45,990
Total Estimated Cost to Importers of Asbestos Mixtures or Articles
Containing Asbestos:
$43,800
45,990
$89,790
EPA Form 7710-37
EPA Form 7710-36
26
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11 EPA Form 7710-37 time estimates were provided by EPA.
~I Weighted average hourly cost of $30 is used to reflect combined
costs of management, legal and clerical assistance. (Provided by EPA)
lIAs nonbulk importers could not be broken out into importers of
asbestos mixtures and importers of articles containing asbestos
components, these segments are considered together as a single segment
in the cost analysis. It is recognized that some importers will be
required to complete Sections E and F. This number, however, is unknown.
110f the importers completing Form 7710-37, approximately 20% will be
required, according to EPA, to complete Form 7710-36 during the second
phase.
27-
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TABLE 7
TOTAL ESTIMATED INDUSTRY IMPACT
Segment
Cost Per Total Seg-
Plant Site ment Cost
$ 720 $ 3,600
$1080 130,680
$ 120 646,200
$ 990 1,066,230
$ 510 184,110
Miners/Millers
Primary Processors
Secondary Processors
Form 7710-37
Secondary Processors
Form 7710-36
Bulk Importers
Importers of Asbestos
Mixtures and Articles
Containing Asbestos
Components
Form 7710-37
$ 120
43,800
Importers of Asbestos
Mixtures and Articles
Containing Asbestos
Components
Form 7710-36
$ 630
45,990
Total
$2,120,6201/
Form 7710-36 Cost:
Form 7710-37 Cost:
$1,430,620
$ 690,000
1/ With small business exemption removed, the total cost would increase
to $3,270,400.
28
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IV.
LIMITATIONS OF ANALYSIS
The analysis conducted for this study relied heavily on inputs
from other studies, hence the results presented herein are closely
tied to those inputs. The major sources used have certain limitations
which affected the completeness of this study's results.
Three specific areas of limited data sufficiency arose. They are
related to the reporting time estimates, identification of the firms
in the asbestos industry, and sales and employment figures for firms
in the industry.
(1)
Unit Reporting Cost Data
The original ISR pre-test consisted of eight asbestos
industry firms completing EPA Form 7710-36, answering questions
on the clarity of the form, and reporting the time (or estimated
time) required to complete each section. Although the pre-test
size of eight may not be adequate for analysis purposes, it is
to be noted that its primary purpose was to obtain an idea of
the clarity of Form 7710-36. Firms were permitted to use "moc~n
data rather than actual data to complete the form. The use of
"mock" dat. suggests that some of the time estimates provided
were speculative, and not based on an attempt to obtain the actual
data needed.
The pre-test did not include any research into the time
needed to claim confidentiality on EPA Form 7710-36 although the
procedures to claim confidentiality are relatively simple and
legal review time is included in the estimate.
Reporting times and labor rates for clerical, middle
management, and legal/senior management hours were not provided
during the pre-test in a complete or consistent manner. As a
result, assumptions were made by EPA staff on the amount of
clerical and legal time involved in completing the form. Also,
standard industrial hourly labor rates had to be used.
The ISR pre-test resul ted in a wide range of responses. This
was in part related to the clarity of certain sections of the
form, a major issue for study in the pre-test. Industry perceived
a lack of clarity in the instructions for some sections of Form
7710-36, and thus were unable to provide consistent answers for
those sections.
It should be noted that during the course of this project,
the structure and content of Form 7710-36 underwent revision by
EPA staff. EPA determined median time estimates for those
sections which were changed substantially. Time estimates were
31
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also developed by EPA for those sections for which adequate data
were collected. Estimates were based on EPA experience with other
similar forms. Thus, the time estimates that were used are a
mixture of industry and EPA figures.
These variations in the time estimates were eliminated by
EPA staff by using the median time estimates for each section.
Due to the limited number of pre-test respondents, it was
not possible to conduct any type of correlation analysis.
(2)
Identification of Firms in the Asbestos Industry
The GCA Master List was intended to provide a listing of
companies who do, or may, process asbestos and is to be used to
direct the reporting form to appropriate firms after promulgation
of the rule. This list was not intended to be an all-inclusive
list of the entire universe of firms in the asbestos industry.
Efforts were made to augment the list by the use of other
sources. These included: Research Triangle Institute (RTI) which
provided the names of 122 primary processors; the U.S. Bureau of
Mines provided a list of 128 primary processors; the Mine Safety
and Health Administration provided information on three
addi tional miners/millers; and the U.S. Customs Service identified
a large number of firms importing bulk asbestos and asbestos
mixtures and articles containing asbestos components.
The identification of all secondary processors is one of
the purposes of the section 8(a) rule. An attempt was made to
estimate the number of secondary processors for this study by
using the total employment figures for secondary processors
developed in the Weston Report.
Weston's estimate of 300,000 for total secondary processor
employment was based on n a thorough rev iew of all sources,"
although the Weston Report points out that "the sources of data
were not all consistent, and at times differed in their estimate
of number of locations." In addition, the Weston Report included
wholesalers as secondary processors, contrary to this proposed
rule which excludes wholesalers.
(3)
Employment and Sales Data
Another major limitation, which precluded developing
economic impact estimates for the identified firms, is the
unavailability of sales and employment data. There are miners
and millers employment data but not sales data; in the importer
category there are a large number of firms for which no sales
and employment could be identified. Finally, a relatively small
number of primary processors remain unclassified as to employment
and sales.
32
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APPENDIX A
MEMORANDUM
SUBJECT:
Statistics for Companies with 10 or Fewer Employees
FROM:
Chemical Information Reporting Branch
TO:
The Public Record
Chemical Information Reporting Branch (CIRB) staff prepared the
following review of industries to assess the potential impact of a
small business exemption on the effectiveness of the proposed section
Sea) asbestos reporting rule. The rule proposes to exempt reports
from plant sites that employ ten or fewer employees. A review of the
potentially affected industries indicates that under this definition,
an average of 43% of the plant sites in each industry would be excluded.
However, on the average, those plant sites account for less than 3% of
the total annual sales and employees within each industry.
Previous work by an EPA contractor, GCA, identified 54 four-digit
manufacturing industries in the Standard Industrial Classification
Manual, U.S. Bureau of the Census, in which asbestos may be processed
to manufacture an end product (see attached GCA final report titled
II Identify Members of the Asbestos Industry"). The purpose of the SIC
lists was to provide a very approximate means of identifying the kinds
of asbestos processors potentially subject to the rule so that copies
of the final rule and form could be mailed to potential respondents.
The exercise was necessary because at present only
of asbestos can be identified with any precision.
estimate of the number of secondary processors was
Asbestos Information Association by Roy A. Weston.
primary processors
The only available
prepared for the
That report, based
33
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on uncertain data, estimated there were 12,000 secondary processors in
1976. In the section 8(a) proposal, an updated estimate that is based
on the same methodology used by Weston indicates there may be almost
9,000 secondary processors. Due to the potentially large number of
firms and the absence of any identifying list, GCA prepared the listing
of SIC codes to better describe the parameters of potentially affected
industries.
To develop the estimated impact of the small business exclusion, CIRB
simply totalled the annual sales, number of employees, and number of
plant sites for all SIC codes, and then averaged those totals for all
SIC codes.
The figures in Table 1 are data from 1975 that were published by Dun
& Bradstreet for the Small Business Administration. The first column
is a listing of SIC codes from the GCA report. In the second column,
the figures describe the percentage of sales by companies in those
four-digit SIC dodes who employ 10 or fewer employees. In the third
column, the figures describe the percentage of employees who work in
companies employing 10 or fewer employees. In the fourth column, the
figures describe the percentage of manufacturing establishments in
each SIC code which employ 10 or fewer workers.
34
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TABLE 1
SALES AND EMPIDYMENl' PERCENl'AGES FOR CG1PANIES WITH
TEN OR FEWER EMPLOYEES IN SELEX:TED SIC CODES
SIC Code % of SIC Sales % of SIC workers % of SIC fi:rms
2891 3.9 5.7
2952 2.8 2.9 49
3292 .2 .3 38
3293 2.9 2.6 41
2261 4.7 2.2 34
2262 2.9 2.6 42
2621 .1 .1 20
2631 .4 .1 19
2645 3.2 3.7 37
2649 4.2 3.6 40
2661 .8 .9 51
2821 1.3 1.5 39
2851 2.9 3.2 46
2899 4.1 5.9 61
2951 14.4 11.4 46
3069 2.2 1.7 38
3079 4.7 4.6 45
3272 6.4 8.8 59
3291 1.5 1.1 43
3295 4.3 4.7 39
3296 .2 .3 39
3433 1.4 1.2 41
3443 1.4 1.2 29
3444 7.4 8.4 51
3482 6.1 4.1 73
3483 .4 .3 41
3484 2.1 2.0 57
3567 3.3 2.8 37
3569 3.5 3.5 47
3612 .1 .1 31
3613 1.2 1.1 44
3621 .2 .2 39
3622 1.2 1.3 45
3623 1.4 2.1 41
3629 2.0 1.7 43
3631 .5 .7 47
3632 .1 .3 43
3634 .6 .5 45
3643 1.0 .6 34
3674 1.4 .9 49
35
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3676 4.5 4.3 27
3694 1.0 1.0 50
3699 10.7 9.7 59
3714 .5 .5 45
3724 .1 .1 18
3731 1.3 .3 32
3732 6.8 8.2 67
3743 2.1 .2 30
3751 1.7 2.0 67
3764 .1 .5 33
3769 6.3 5.3 33
3811 2.8 3.2 49
AVERAGE 2.7% 2.6% 42.6%
36
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271
'0 "0' I J. "8CI~'Onrl Act...."" ~o.
REPORT DOCUMENTATION 1. AEP'OAT HO. I~
PAGE EPA-560/4-81-001
.
.. 'ntle enet Subtltlo S. ltollO", CO\;
Decer.1.er 17,1980
!:conomic Impact Analysis for the TSCA Section 8 (a)
Rule Reporting Commercial & Industrial U",cs of Asbestos L
7. AutI>Or
-------
United States
Environmental Protection
Agency
Official Business
Penalty for Private Use
$300
Washington DC 20460
"
Special Fourth-Class Rate
Book
Postage and Fees Paid
EPA
Permit No. G-35
EPA 560/4-81-001
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