FINAL REPORT
ECONOMIC IMPACT AND SMALL BUSINESS
DEFINITION ANALYSIS FOR THE FINAL
TSCA SECTION 8(a) PRELIMINARY
ASSESSMENT INFORMATION RULE
Prepared for
Regulatory Impacts Branch
Office of Pesticides and Toxic Substances
U.5. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
July 1981
ICF INCORPORATED 1850 K Street, Northwest,
Suite 950, Washington, D. C. 20006
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Preparation of this document was completed
prior to the January 22, 1982 effective date
of the EPA Administrator's Order 2200 and
consequently did not necessarily undergo the
peer review procedures described therein. The
document received peer review according to
procedures in place prior to that date and
received canolete administrative review-
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FINAL REPORT
ECONOMIC. IMPACT AND SMALL BUSINESS DEFINITION ANALYSIS FOR THE
FINAL TSCA SECTION 8(a>"PRELIMINARY ASSESSMENT INFORMATION RULE
PREPARED FOR
REGULATORY IMPACTS BRANCH
OFFICE OF-PESTICIDES AND TOXIC SUBSTANCES
U.S. ENVIRONMENTAL PROTECTION AGENCY
401 M STREET, S.W.
WASHINGTON, D.C. 20460
JULY 1981
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TABLE OF CONTENTS
PAGE
I. Executive Summary 1
A. Introduction 1
B. Methodology 1
C. Unit Costs 2
D. Reporting by Selected Processors 2
E. Small Business Definition 3
F. Total Cost and Economic Impact 5
G. Sensitivity Analysis 5
II. Introduction 6
III. Methodology to Estimate Costs to Manufacturers 7
A. Methodology 7
B. Exceptions 10
C. Key Methodological Assumptions 11
IV. Unit Cost Estimates 13
A. Reporting by Manufacturers 13
1. Fixed Costs 14
2. Variable Costs 14
3. Changes in the Final Form 17
B. Reporting by Selected Processors 18
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TABLE OF CONTENTS (continued)
PAGE
V. Analysis of Options for Small Business Definition 21
A. EPA Policy 21
B. Criteria for Determining the Definition of Small Business .... 21
C. The Production Volume Criterion 22
D. Options for Small Business Definitions 22
E. Small Business Definition 23
VI. Total Cost and Economic Impact 25
A. Total Industry Costs 25
B. Economic Impact 25
VII. Sensitivity Analysis 47
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LIST OF TABLES
PAGE
Table 1 Estimated Fixed Cost of Reporting Per Site 15
Table 2 Variable Costs of Reporting Per Chemical 16
Table 3 Estimated Cost to Processors of Reporting 19
Table 4 Baseline: No Small Business Exemption or Small
Quantity Exemption 32
Table 5 No Small Business Exemption; 500 Kilogram Small Quantity
Exemption 33
Table 6 Small Business Definition: $1 Million Sales Limit
and 100,000 Pounds Production Limit; 500 Kilogram
Small Quantity Exemption 34
Table 7 Small Business Definition: $3 Million Sales Limit
and 100,000 Pounds Production Limit; 500 Kilogram
Small Quantity Exemption 35
Table 8 Small Business Definition: $5 Million Sales Limit
and 100,000 Pounds Production Limit; 500 Kilogram
Small Quantity Exemption 36
Table 9 Small Business Definition: $10 Million Sales Limit
and 100,000 Pounds Production Limit; 500 Kilogram
Small Quantity Exemption 37
Table 10 Small Business Definition: $30 Million Sales Limit
and 100,000 Pounds Production Limit; 500 Kilogram
Small Quantity Exemption 38
Table 11 Small Business Definition: $50 Million Sales Limit
and 100,000 Pounds Production Limit; 500 Kilogram
Small Quantity Exemption 39
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LIST OF TABLES (continued)
PAGE
Table 12 Small Business Definition: $1 Million Sales Limit
and 1,000,000 Pounds Production Limit; 500 Kilogram
Small Quantity Exemption 40
Table 13 Small Business Definition: $3 Million Sales Limit
and 1,000,000 Pounds Production Limit; 500 Kilogram
Small Quantity Exemption 41
Table 14 Small Business Definition: $5 Million Sales Limit
and 1,000,000 Pounds Production Limit; 500 Kilogram
Small Quantity Exemption 42
Table 15 Small Business Definition: $10 Million Sales Limit
and 1,000,000 Pounds Production Limit; 500 Kilogram
Small Quantity Exemption 43
Table 16 Small Business Definition: $30 Million Sales Limit
and 1,000,000 Pounds Production Limit; 500 Kilogram
Small Quantity Exemption 44
Table 17 Small Business Definition: $50 Million Sales Limit
and 1,000,000 Pounds Production Limit; 500 Kilogram
Small Quantity Exemption 45
Table 18 Summary of Total Costs Under Various Small Business
Definitions 46
Table 19 "Middle Range" Cost Estimates for Inventory-Type Small
Business Definition 49
Table 20 "Lower Bound" Cost Estimates for Inventory-Type Small
Business Definition ... 49
iv
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LIST OF FIGURES
PAGE
Figure 1 Flow Chart for Classifying Data 8
Figure 2 Total Cost Versus Size of Exemption 27
Figure 3 Total Reporting Companies Versus Size of Exemption .... 28
Figure 4 Average Impact on a Firm Which Must Report 29
Figure 5 Effect of Small Business Exemption on Number of Companies
Required to Report 30
Figure 6 Impact on Most Affected Company in Each Sales Category . . 31
Figure 7 Effect of Missing Data Assumptions 48
Figure 8 Effect of Profit Assumption on Average Impact 51
Figure 9 Effect of Cost Assumption in Total Costs 52
Figure 10 Effect of Cost Assumption on Average Impact 53
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I. EXECUTIVE SUMMARY
A. INTRODUCTION
Under section 8(a) of the Toxic Substances Control Act (TSCA), the Envi-
ronmental Protection Agency (EPA) is authorized to require firms to report
information related to the volume of production, production processes, work
and environmental exposure, and other information concerning the production of
certain chemicals. (See the preamble to the final rule for an explanation of
how chemicals were chosen.) Because small chemical manufacturers might not be
able to sustain the additional costs associated with such reporting, however,
section 8(a) also requires that small manufacturers and processors (as defined
by the Administrator) be excluded from these reporting requirements, unless
the chemicals involved have been proposed for certain regulatory actions.
The section 8(a) Preliminary Assessment Information Rule is designed to
gather general production, use, and other information on exposure from
manufacturers and importers of about 2,000 chemicals as well as from some
processors of those chemicals. This information is intended to aid
priority-setting and risk assessment for these chemicals. This report details
the results of an analysis of the cost and economic impact of the Preliminary
Assessment Information Rule and examines various small business definitions as
required by section 8(a) of TSCA, in order to determine the definition of
small business for this rule.
B. METHODOLOGY
To analyze the cost of the rule to manufacturers, the list of chemicals
included in the rule was merged with the TSCA Chemical Substance Inventory1-1
yielding a list of plant sites which produce those chemicals. Plant-site
information was then aggregated to the firm headquarters level and combined
with the firm's annual sales data from the Dun and Bradstreet files. Both
fixed and variable costs of reporting for the Preliminary Assessment
Information Rule were estimated. The estimates were used to determine the
total cost of the rule to industry. Furthermore, the impact of the rule on
individual companies was estimated by comparing the average company's costs of
reporting with its profits, which were estimated to be six percent of sales.
1JInformation received under the Inventory Reporting Regulations, 40 CFR
710 (42 FR 64572, December 23, 1977).
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We made several assumptions because Dun and Bradstreet sales information
was not available for all Inventory plant sites, and because production volume
was unknown for some sites. The most conservative assumptions were chosen so
that the analysis would overestimate rather than underestimate the cost.
These assumptions included:
(1) If production volume of a chemical is unknown at a
plant site that qualifies for an exemption based on
its parent company's sales, the plant site will have
to report on the chemical.
(2) If sales information is unknown for the parent company
of a plant site that manufactures a chemical in
quantities below the production volume limit, the
plant site will have to report on the chemical.
(3) If both production volume and sales information are
missing, the plant site will have to report on the
chemical.
In Chapter III, we discuss these assumptions in detail.
C. UNIT COSTS
Unit reporting costs have been divided into fixed cost (e.g.,
familiarization with the reporting requirements) and variable cost (e.g.,
estimating off-site use to complete a form). Because these costs were based
on a standard process for obtaining data to complete the forms, the changes in
the form made between the initial proposal and the final rule had no
measurable impact on the reporting costs. In addition, changes in the content
and format of the final form, which is simpler than the proposed form, tended
to offset the addition of costs that were not included in the economic
analysis of the proposed form. Thus, the total fixed costs for manufacturers
of the Preliminary Assessment Information Rule are estimated to be $480 per
production site. Variable costs of reporting are estimated to be $420 per
chemical produced at that site.
D. REPORTING BY SELECTED PROCESSORS
After EPA reviews and compiles the reports from manufacturers, the Agency
may find that industry reported insufficient information on customer use. In
such a situation, the rule provides that EPA may require selected processors
of the chemical to complete a separate form. We expect it will cost
processors approximately $255 per site plus $100 per report to provide this
information.
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E. SMALL BUSINESS DEFINITION
EPA's policy in setting a small business definition has been to balance
the relative burden of providing information against the needs for that infor-
mation. In the past,2J EPA has explored several parameters (company sales,
sales per chemical, assets, employment, production, and number of sites per
firm) for a small business definition. The past examination concluded that
company annual dollar sales alone or combined with another parameter were
generally the most reasonable criteria to use to define a "small business."
For this rule, small size as defined by dollar sales alone is not a
sufficient reason to exempt a company from reporting, however. Production of
a large quantity of a chemical may indicate a significant degree of human and
environmental exposure and, possibly, a risk that should be assessed.
Although a large production quantity does' not necessarily indicate significant
exposures, it may indicate widespread use of the chemical and thus the
potential for significant release. For this reason, EPA needs information
regarding large-volume chemicals even from small manufacturers. Therefore,
the small business definition includes a provision that if production of a
chemical exceeds a certain limit, the plant site would have to report on the
chemical, regardless of company size.
For this rule, EPA does not consider production of an extremely small
quantity of a given chemical to be significant enough to justify a reporting
requirement. Therefore, a plant site need not report on a chemical that it
produces in quantities below 500 kilograms, regardless of company size.
Thus, the effects of various small business definitions consisting of a
single annual sales figure combined with a production volume limit, and the
small quantity exemption were examined in this report. Fourteen different
cases were examined.
Baseline (no small business or small quantity exemption.)
No small business exemption; 500 kilogram small quantity
exemption.
$1 Million sales limit and 100,000 pounds production limit;
500 kilogram small quantity exemption.
$3 Million sales limit and 100,000 pounds production limit;
500 kilogram small quantity exemption.
2JSee Analysis of Options for Definition of Small Business, and Estimated
Cost of the Initial Section 8(a) Reporting Requirement, Arthur D. Little, EPA
Report Number 561/1-77-001, November 1977.
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$5 Million sales limit and 100,000 pounds production limit;
500 kilogram small quantity exemption.
$10 Million sales limit and 100,000 pounds production
limit; 500 kilogram small quantity exemption.
$30 Million sales limit and 100,000 pounds production
limit; 500 kilogram small quantity exemption.
$50 Million sales limit and 100,000 pounds production
limit; 500 kilogram small quantity exemption.
$1 Million sales limit and 1,000,000 pounds production
limit; 500 kilogram small quantity exemption.
$3 Million sales limit and 1,000,000 pounds production
limit; 500 kilogram small quantity exemption.
$5 Million sales limit and 1,000,000 pounds production
limit; 500 kilogram small quantity exemption.
$10 Million sales limit and 1,000,000 pounds production
limit; 500 kilogram small quantity exemption.
$30 Million sales limit and 1,000,000 pounds production
limit; 500 kilogram small quantity exemption.
$50 Million sales limit and 1,000,000 pounds production
limit; 500 kilogram small quantity exemption.
After reviewing the impacts of the various alternatives, and analyzing the
costs associated with each definition, the Agency has chosen for purposes of
the section 8(a) Preliminary Assessment Information Rule to define a
manufacturer or processor plant site as small in respect to a given chemical
when:
a. total annual sales of the parent company (on all
products) are less than $30 million, and
b. the plant site's annual production (or amount
processed) of the chemical is less than 100,000 pounds.
Annual sales figures are based on the sum of all plant sites owned or
controlled by the parent company of the reporting plant site. A plant site is
exempt from reporting on a chemical if these criteria are met.
Processors of selected chemicals may also be required to report under
certain circumstances and are also covered by the small business exemption.
We believe that the financial characteristics of manufacturers and processors
are similar; in fact, many processors are also manufacturers and vice versa.
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Therefore, the $30 million annual sales small business definition should also
apply to processors. Similarly, whether manufactured or processed, the quan-
tity of 100,000 pounds at a single site is significant and should be reported.
F. TOTAL COST AND ECONOMIC IMPACT
Approximately 820 firms are subject to the Preliminary Assessment Infor-
mation rule when the small business definition is $30 million with a 100,000
pound production limit. The total cost of this rule is expected to be about
$4.4 million.
The small business exemption decreases the number of reporting companies
with sales below $30 million from 286 (Table 5) to 103 (Table 10). Of the 183
firms exempted, however, production data are missing for 91. Some of these
may still have to report because of large production volume, but the number of
such companies is not expected to be great because 54 of the 91 are extremely
small companies with sales under $5 million.
G. SENSITIVITY ANALYSIS
A sensitivity analysis was performed on the possible error introduced by
the assumptions that plant sites with missing data will be required to report
(see page 2). At a small business definition of $30 million, relaxing
assumptions 1, 2, and 3 would reduce industry's total compliance cost from
$4.4 million to $3.6 million. In this case, only 627 firms would report under
the rule.
The total cost of the rule is relatively insensitive to the level of the
small business definition, because over 80 percent of the reports which must
be filed will be generated by companies with sales greater than $30 million.
With no small business exemption or small quantity exemption, the cost of the
rule is $5.0 million; with a $50 million and 1,000,000 pound small business
exemption, its cost is $4.3 million.
The total cost and impacts of the rule change in direct proportion to
changes in assumptions regarding the cost of the form and the profitability of
the industry. The total cost is particularly dependent on the estimated cost
to submit the form. This depends greatly on the assumptions of which
personnel complete the form.
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II. INTRODUCTION
Under section 8(a) of the Toxic Substances Control Act, the Administrator
is authorized to require firms to report to the Environmental Protection
Agency information related to the volume of production, production processes,
worker and environmental exposure, and other information concerning the
production of certain chemicals.
The section 8(a) Preliminary Assessment Information Rule is designed to
gather general production and use information and other information on
exposure to aid initial priority-setting and risk assessment of chemicals.
The rule initially applies to the manufacturers and importers of about 2,000
chemicals. It also contains provisions to require reports from processors of
certain chemicals if the Agency determines that more information is needed to
complete the preliminary assessment.
This report details the results of an analysis of the total cost and eco-
nomic impact of the Preliminary Assessment Information Rule. The impact is
estimated by comparing the average company*s costs of reporting with its
profits, which in turn are estimated as six percent of the company's sales.
This report also examines the different impacts resulting from various small
business definitions. This latter analysis was used by EPA to determine the
small business definition in the Preliminary Assessment Information Rule.
The report is divided into seven sections: Executive Summary,
Introduction, Methodology to Estimate Costs to Manufacturers, Unit Cost
Estimates, Total Cost and Economic Impact Analysis, Analysis of Options for
Small Business Definition, and Sensitivity Analysis. The methodology section
contains a description of key assumptions which have an effect on the final
results. Although the effects of these assumptions on the analysis have been
explored wherever possible (see Section VII), a proper understanding of the
assumptions is crucial to a correct interpretation of the results.
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III. METHODOLOGY TO ESTIMATE COSTS TO MANUFACTURERS
A. METHODOLOGY
In order to determine the costs to industry of the rule and its impact on
chemical companies of various sizes, two data bases were merged—the list of
chemicals the rule covers and the TSCA Inventory. The result was a list of
plant sites which had reported producing these chemicals.
The data thus obtained on plant site production were organized by parent
company. These data were then combined with the company's annual sales data
taken, whenever available, from Dun and Bradstreet files. The result was one
list identifying each company by Dun and Bradstreet number, and showing parent
company sales and section 8(a) production data by site. In this discussion,
we refer to this list as the production/sales list.
Figure 1 displays the logic used in sorting the companies, plant sites,
and chemicals for this analysis.
Data on the production/sales list were sorted into groups of companies
with similar sales. For each sales category, we showed the number of sites,
and production volumes at those sites, for each company. In this discussion,
we refer to these as the sales lists. The sales categories by dollar figures
were as follows:
$ 0 -
less
than
$ 1
million
1 -
less
than
3
million
3 -
less
than
5
million
5 -
less
than
10
million
10 -
less
than
30
million
30 -
less
than
50
million
50 -
less
than
100
million
100 -
less
than
500
million
500 million or more
Two additional categories for companies with missing sales figures were also
included, one with production volume greater than or equal to the cut-off
production volume, and one with production volume below the cut-off volume for
the specific chart.
Within each sales category, four subcategories were established:
(1) if sales category is not exempt,
(2) if sales category is exempt up to 500 kilograms
production,
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(3) if sales category is exempt up to 100,000 pounds of
production, and
(4) if sales category is exempt up to 1,000,000 pounds of
production.
The first subcategory listed every company, its number of sites, and the num-
ber of chemicals it produces. The second subcategory listed the companies
with the number of sites and chemicals for which production is over 500
kilograms. The third subcategory listed the companies with the number of
sites and chemicals for which production is over 100,000 pounds. And the last
subcategory listed companies, sites, and chemicals produced in quantities over
1,000,000 pounds.
The next step was to count the number of companies, sites, reports, and
dollar sales shown on each sales list. The results of the count were tran-
scribed onto charts summarizing the cost and impact of each small business
definition (see Tables 4 through 17 in Chapter VI). For example, to find out
how many sites belonging to companies with $0 to $1 million in sales will be
required to submit reports under an exemption of $30 million-100,000 pounds
production, we proceeded in this way: We referred to the $0 to $1 million
sales list and counted the number of sites listed in the over 100,000 pounds
production subcategory. This figure represents the number of sites required
to report. We then entered that figure in the $0 to $1 million block in Table
10, the $30 million-100,000 pound exemption chart. If we wanted the same
information for companies with sales in the $30 to $50 million range, we would
reference the $30 to $50 million dollar sales list, count the number of sites
in the subcategory, "if sales category is exempt up to 500 kilograms
production," and enter that figure in the appropriate block in Table 10. We
would reference this subcategory because the 500 kilogram exemption applies to
all companies regardless of size.
Total cost of reporting was calculated by multiplying the fixed cost of
reporting times the number of plant sites. That figure was then added to the
variable cost of reporting multiplied by the number of chemical reports.
To evaluate the impact of the Rule on a company, the total cost of
reporting was estimated as a percent of profit. Using an estimated profit
margin of six percent of sales,3-1 the calculation for each company is:
Total Cost
x 100
Annual Sales x .06
3JCharles H. Kline and Co., Inc., Kline Guide to the Chemical Industry,
4th ed., 1980, p. 32.
ICF Incorporated, Chemical Industry Financial Data Base, unpublished.
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B. EXCEPTIONS
Six hundred forty-seven plant sites on the production/sales list were not
identified by ultimate Dun and Bradstreet numbers, and thus were not associ-
ated with a parent company. To resolve the problem, both the plant site
production/sales list and the sales lists were alphabetized and searched
manually for the name of each unidentified entry. Of the 647 sites, 294 were
eventually identified by this method. Thus, the 294 sites were additional
sites belonging to parent companies whose names had been previously entered
on the production/sales list. Sixty-five other unidentified plant sites were
found to be associated with parent companies that had not been previously
listed. The names of those parent companies were added to the sales lists
along with the plant sites. Two hundred eighty-eight plant sites of the
original 647 remain unidentified by parent company; 63 of these are also
missing production volumes. To maintain the most conservative assumption,
the 288 unidentified sites were included in a "Missing" column.
Two hundred six companies supplied production data but lacked sales data.
(See column labeled "Missing Sales" on Table 4 in Chapter VI.) Of the 206,
194 produce chemicals in quantities greater than the 500 kilogram small
quantity exemption. When the production volume of these companies exceeds the
small business exemption limit, they will be required to file reports.
Therefore, they were included in the "Missing Sales (Over Production Limit)"
category. When their production volume fell below the limit, they were
included in the "Missing Sales (Under Production Limit)" category. In the
latter case, it is still not known if these companies will be required to
submit reports. We assumed that these companies would have to report and then
tested the sensitivity of our total cost estimates to this assumption (see
Chapter VII).
Other information was also occasionally missing. For example, the volume
of chemicals produced by certain companies at some of their sites was unknown.
If it was established fact that such companies must file reports on these
chemicals because their sales figures disqualify them from a small business
exemption, then we assumed that reports should be submitted on the chemicals
in question. (This assumes that they are produced in quantities over 500
kilograms (1,100 pounds). This assumption is based on analysis showing that
over 90 percent of all chemicals with known production on the production/sales
list are produced in quantities over 500 kilograms.) In the case of companies
which do qualify for an exemption based on sales, it is not known if they must
file reports on chemicals for which production data are missing. These chemi-
cals were included in the "Missing Production" category.
Thus, the numbers in the "Missing Production" category vary with the size
of the small business exemption. A company with $40 million in sales, for
example, must report on chemicals produced--except those produced in quanti-
ties under 500 kilograms--if the exemption is set at $30 million. But if the
exemption is raised to $50 million, it is not known if the company will have
to submit reports on chemicals for which it did not report production volume.
In the latter case only, missing production data are categorized as such.
Figure 1 above illustrates the process of classifying sites and reports.
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C. KEY METHODOLOGICAL ASSUMPTIONS
Certain assumptions had to be made with regard to the missing data we have
just described in order to calculate the total cost and economic impact
figures for the various small business definitions under consideration. In
each case, we chose the most conservative assumption so that the analysis
would overestimate rather than underestimate the cost. We discuss these
assumptions below:
Assumption 1. The industry cost estimates (see Tables 4 through
17) were calculated under the assumption that if a
plant site's production volume information for a
given chemical is unknown, the plant site will have
to report, even if it qualifies for an exemption
based on sales.
All chemicals produced by a company whose production volume information
was missing were included in the "Missing Production" category when we did not
know if the company would be required to report because it qualified for an
exemption based on sales. In calculating the total cost to industry, we
assumed that the chemicals in this category were produced in quantities suf-
ficient to require reporting regardless of company size. Information on pro-
duction volume may have been unavailable for the following reasons: (a) pro-
duction volume was claimed to be confidential, and (b) the company was a small
business and did not have to report production.
We further assumed that a company which did not produce a given chemical
in 1977 would not produce it during the reporting year for this rule.*J
However, these chemicals may be batch process chemicals which might be
produced in subsequent years. If, at the time of this reporting requirement,
they were in production, then they would be reported. The additional costs to
industry of reporting these chemicals was calculated for the purpose of the
sensitivity analysis (see Section VII).
Most of the chemicals on the list are high-volume chemicals. It is,
therefore, not unreasonable to expect that production may indeed exceed
100,000 pounds, even for smaller firms. In our opinion, this assumption does
not significantly overstate the expected number of reports from smaller com-
panies or the costs involved in submitting them.
UJIn some cases, the Inventory allowed manufacturers to report a
chemical if they did not produce the chemical during the period to be reported.
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Assumption 2. Sales information on certain firms was unavailable.
Thus, they could not be categorized for purposes of
evaluating the small business definition (see the
category labeled "Missing Sales" on Tables 4 through
17 in Chapter VI). In estimating the total cost, it
was assumed that plant sites belong to these
companies would be required to report, even if
production volume of the reportable chemical were
under the production limit.
Sales information was unavailable for two reasons. First, sales informa-
tion was unavailable from the Dun and Bradstreet files. Second, the
production/sales list showed a plant site or subsidiary whose parent company
could not be determined from reference texts. In line with our previous
conservative assumptions, we assumed that plant sites of companies for which
sales data are lacking will have to report, regardless of production volume of
the reportable chemicals. We made the same assumption when sales were unkown
because the parent company could not be identified. (The effect of making the
opposite assumption is analyzed in Section VII of this report). It is likely
that this assumption overstates the cost of the rule because some of the firms
in the category probably fall below the sales level of the small business
definition. If firms in this category are above the level of the small busi-
ness definition, the total cost of the rule is unaffected.
Assumption 3. The industry cost estimates were calculated under
the assumption that if both parent company sales
and production volume were missing for a given
chemical, a report on the chemical will have to be
filed.
These chemicals were included in the "Missing Production" category.
Impact Estimates
Total cost provides an easily understood gross cost figure for the entire
industry. However, as can be seen in Section VI, total cost to the industry
varies only slightly with changes in the small business definition, because
over 80 percent of the total reporting burden falls to larger firms with sales
greater than $30 million. This insensitivity of the total industry cost to
the size of the small business definition can be misleading because providing
a small business exemption significantly reduces the reporting burden for
firms in the smaller sales categories.
An estimate of the impact on each segment was evaluated by calculating the
average reporting cost as a percent of profits.
The formula used to calculate the average impact was:
(Average number of sites x $480) + (Average number of reports x $420)
Average sales x .06
where $480 is the cost per site, $420 is the cost per report, and .06 is the
profit margin.
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IV. UNIT COST ESTIMATES
A. REPORTING BY MANUFACTURERS5-1
Before the Preliminary Assessment Information Rule was initially proposed
in February of 1980, a limited number of industry interviews were conducted to
estimate reporting time and cost. In general, because the respondents were
unfamiliar with the Section 8(a) reporting requirements, they had difficulty
framing their responses or estimating costs. Thus, an alternative cost
estimating procedure was formulated. This approach was to identify a typical
process by which a company would gather the required information. The process
is described below. On the basis of this process, cost estimates were
formulated for the original proposal.
Although the specific reporting requirements have changed between the
proposal and the final rule, the process for gathering information did not
change. While comments indicated that the costs identified in the proposal
were too low because they did not take certain activities into account,
changes in the final rule alleviate problems identified by the public. Thus
ICF believes that the cost estimates previously published for the proposed
rule are reasonable estimates for the final rule. (Figures 9 and 10 in
Chapter VII show the sensitivity of the analysis to the cost assumption.)
In estimating reporting costs, emphasis was given to the costs to a firm
with annual sales of between $1 million and $50 million—the range under con-
sideration for the small business definition. Reporting costs have been
divided into fixed costs (e.g., familiarization with the reporting
requirements), and variable costs (e.g., estimating off-site use to complete a
form for a given chemical). Fully loaded6-1 costs of personnel are estimated
to average as follows:
5JThis section is based on work done by Arthur D. Little, Inc. (ADL)
under Contract No. 68-01-4717. ICF Incorporated updated ADL's estimates after
reviewing available ADL information and assessing the changes in the final
form.
Senior Officer
Attorney
Marketing Staff
$40 per hour
$40 per hour
$30 per hour
Technical Staff
Production Engineer
Secretary
$25 per hour
$25 per hour
$10 per hour
6JFully loaded costs are defined as wages plus fringe benefits.
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1. Fixed Costs
The total fixed costs of Preliminary Assessment Information reporting are
estimated to be $480 per production site. Most of the smaller companies would
have only one plant site, so the $^80 fixed cost would be the total fixed cost
for the company.
Three steps were included in the fixed cost estimate: becoming familiar
with the form and the regulations, determining which chemicals are produced,
and preparing and reviewing the complete set of forms before submission to the
EPA. Because of the publicity surrounding TSCA and the chemical industry's
apprehension about how EPA will implement the law, it is assumed that top
management and legal staffs of chemical manufacturers will devote more than
cursory attention to the Preliminary Assessment Information forms. Thus, we
have estimated that senior officers will dedicate at least one hour to
familiarizing themselves with the form and deciding who should be involved in
"shepherding" it through the company, and one hour reviewing a package of all
completed forms to be submitted to EPA. Similarly, we estimate that the
corporate attorney (either an employee or outside counsel) will spend two
hours becoming familiar with the requirements and two hours reviewing the
completed package of forms. The senior officer and the attorney will be
concerned with providing a complete response to EPA questions and determining
which items are confidential.
We have assumed that the senior officer will delegate most of the work to
a person on the technical staff who will need two hours to become familiar
with the requirements and decide how best to gather the information, and two
hours to review the completed package of forms with the senior officer.
Presumably, a technical staff person will take the company's initial section
8(b) Inventory list and check it against the list of 2,000 chemicals for which
a report is required under the Preliminary Assessment Information Rule. In
addition, he will have to make sure that the plant site has not ceased
production of chemicals it listed on the Inventory or commenced production of
new chemicals on the list since it submitted its Inventory list. This task is
estimated to require two hours of the technical staff person's time.
Completing the data common to all forms, xeroxing them, collating the forms
when received from the technical staff and then reviewing the complete package
at the technical level is estimated to require two hours for the technical
staff and four hours for a secretary. The fixed costs are summarized in Table
1.
2. Variable Costs
Variable costs of reporting are estimated to be $420 per chemical for each
plant site (see Table 2). These costs arise from the preparation and reviews
of each individual form that must be submitted to EPA. Preparation of each of
the two parts of the form is included separately in the variable cost
estimate: Part A--answering the questions about on-site use and exposure, and
Part B--answering the questions about off-site use and exposure. For on-site
-------
-15-
Table 1
ESTIMATED FIXED COST OF REPORTING PER SITE
(Per Company for Most Companies)
Task
A. FAMILIARIZATION
Managerial Staff
Legal Staff
Technical Staff
B. DETERMINE CHEMICALS PRODUCED
Technical Staff
C. FINAL PREPARATION AND
REVIEW OF PACKAGE
Managerial Staff
Legal Staff
Technical Staff
Secretary
. TOTAL
Hours Cost/Hour Task Cost
1 $40 $ 40
2 40 80
2 _25 50
$170
2 25 50
50
1 40 40
2 40 80
4 25 100
4 10 40
260
18 $480
Source: Arthur D. Little, Inc. 1979 estimates based upon the EPA OPTS Draft
Preliminary Assessment Information Rule dated September 10, 1979.
-------
-16-
Table 2
VARIABLE COSTS OF REPORTING PER CHEMICAL
Task Hours
Preparation and review of form
Part A. PLANT SITE USE AND EXPO-
SURE-RELATED INFORMATION
Technical Staff 4
Production Engineer 2
Cost/Hour
$25
25
Task Cost
$100
50
$150
Part B. OFF-SITE USE AND EXPO-
SURE-RELATED INFORMATION
Technical Staff
Production Engineer
Marketing Staff
4
2
4
25
25
30
100
50
120
270
TOTAL
$420
Source:
Arthur D. Little, Inc. 1979 estimates based upon the EPA OPTS Draft
Preliminary Assessment Information Rule dated September 10, 1979.
-------
-17-
data, the technical staff person must identify the appropriate production
engineer to interview; the engineer must then gather the information
required. We estimate that the production engineer would spend two hours on
this task and that the technical staff person would spend two hours completing
the task and an additional two hours of analysis.
Off-site data is more complicated, but it is likely that many respondents
would answer "unknown" when they cannot easily ascertain quantities. The
technical staff person would discuss with the production engineer the type of
process (enclosed, controlled release, or open) used by customers.
Approximately two hours would be required to interview the production engineer
about the type of processes customers use, followed by an additional two hours
of analysis.
It is estimated that four hours of marketing staff time would be required
to analyze sales records to try to determine the off-site data to within 50
percent accuracy. We have assumed that companies reporting would attempt to
provide these data rather than answer simply that they do not know.
3. Changes in the Final Form
Both the fixed and variable cost estimates in this report were initially
developed based on a draft of the reporting form contained in the February
1980 proposed regulation. Industry commented that the proposed rule's
estimated costs per company were too low. This may be true for two general
reasons. One reason is that the proposal incorrectly stated that costs were
estimated per company; in fact, the costs were estimated per plant site.
Thus, the proposal's cost estimates would be low for any company that had more
than one plant site with a reporting requirement. However, this error does
not affect the cost estimates in the proposal's economic analysis.
The second general reason commenters gave for the proposal's cost
estimates being low was that time to perform certain required activities was
not included.
For example, industry indicated that substantiating confidentiality claims
under the proposed regulation would be complex, difficult, and costly. EPA
has changed this part of the regulation so that companies may claim confiden-
tiality simply by signing a statement of certification.
Industry noted that time was not included to compile customer lists;
however, the final rule eliminates this provision. Industry also noted that
the proposed rule's cost estimates did not include time to identify chemicals
listed by category rather than by CAS number and chemical name; lengthy
start-up time for reporting by plant sites that manufacture many chemicals;
time to re-aggregate data recorded for a fiscal year to a calendar year; and
-------
-18-
time to work at both plant site and headquarters. The final rule changes each
of these provisions to alleviate the need for extra reporting time.
Because the reporting requirements and the form have been altered to
alleviate many of the problems industry brought up, the original cost estimate
closely approximates the cost of the final rule.
ICF has analyzed the sensitivity of its economic impact estimates to its
unit cost estimates. The results of this analysis, performed by doubling and
halving, in turn, the unit cost estimates, appear in Figures 9 and 10 in
Chapter VII.
B. REPORTING BY SELECTED PROCESSORS
After EPA reviews and compiles the manufacturers' reports, the Agency may
find that manufacturers did not provide sufficient information on customer
uses of certain chemicals. If manufacturers reported customer uses as
"unknown" for more than 20 percent of the processed quantity of a given
chemical, EPA will require processors of the chemical to complete a separate
form.
For processors, completing the form should cost approximately $255 per
plant site plus $100 per chemical per site (see Table 3). To gather the
required information, processors will use a procedure similar to the one
described for manufacturers. However, it will take less time to complete a
processor's form because the form is simpler and no off-site use and exposure
information is required.
Cost per site. We have assumed that a senior officer of the plant site,
a corporate attorney or outside counsel, and a member of the technical staff
will each spend about one hour familiarizing themselves with the form and
deciding who should complete it. Then, a member of the technical staff will
spend two hours checking the chemicals produced at the site against the list
published in Subpart C (712.45) for which reporting is required. Checking and
completing the package after the information has been gathered is estimated to
take one hour of technical staff time and one hour of secretarial time. A
technical staff member will spend an additional one-half hour each reviewing
the complete packages with a senior officer and lawyer. As illustrated on
Table 3, the total expense for this process will be about $255.
Cost per chemical per site. Whereas manufacturers must report on both
their own uses and customer uses, processors must report only on their own
uses. In addition, the information processors must provide is not as detailed.
Therefore, we estimate that the form can be completed in a total of about four
hours per chemical at a cost of $100.
-------
-19-
Table 3
ESTIMATED COST TO PROCESSORS OF REPORTING
Task
A. FAMILIARIZATION
Fixed Cost (Per Site)
Hours Cost/Hour
Managerial
Legal
Technical Staff
$40
40
25
Task Cost
$ 40
40
25
B. DETERMINE CHEMICALS PRODUCED
Technical Staff
25
50
C. FINAL PREPARATION AND REVIEW
OF PACKAGE
Managerial Staff
Legal Staff
Technical Staff
Secretary
1/2
1/2
2
1
40
40
25
10
20
20
50
10
TOTAL COST PER SITE
$255
Variable Cost (Per Chemical Per Site)
D. PREPARATION AND REVIEW OF FORM;
PLANT SITE USE AND EXPOSURE
Technical Staff
Production Engineer
$25
25
$ 50
50
TOTAL COST PER CHEMICAL 'PER SITE
$100
-------
-20-
A technical staff member must identify the appropriate production engineer
with whom to discuss the form. This is estimated to take approximately one
hour. The production engineer must then gather the required information and
fill in the form--a task estimated to take two hours. .The technical staff
member will then analyze and review the information. Table 3 summarizes this
process.
-------
-21-
V. ANALYSIS OF OPTIONS FOR SMALL BUSINESS DEFINITION
A. EPA'S POLICY
Section 8(a) of TSCA requires that small manufacturers and processors (as
defined by the Administrator) be excluded from the reporting requirements of
section 8(a) rules, except in certain circumstances. The Agency's policy in
setting a small business definition has been to balance the relative burden of
providing information against the need for that information.7-1
B. CRITERIA FOR DETERMINING THE DEFINITION OF "SMALL BUSINESS"
In trying to identify criteria to define a company as "small" for the TSCA
Inventory, the Agency explored several parameters including company sales,
sales per chemical, assets, employment, and number of sites. A study
concluded that company sales alone or combined with another parameter are the
most reasonable criteria to define "small."8-1 For the Inventory, small was
defined by both sales and production volume. The rationale for choosing these
criteria over other possible measures has not changed and therefore the
discussion will not be repeated here.
For the present rule, the Agency studied companies with sales from $0 to
$50 million. Over 90 percent of all chemical firms have sales in this range.
However, of firms affected by this rule, fewer than 50 percent have sales in
this range because the chemicals this rule covers are primarily high-volume
chemicals, produced by larger firms. In this analysis, production volumes is
combined with sales in the alternative definitions of "small."
Several factors were examined to determine what the sales and production
levels for the definition of "small" should be. These factors included
estimated number of firms at each level, number of reports per firm, total
costs, and economic impact on the firms measured as a percent of profits (see
Tables 4 through 17 in Chapter VI).
7JSee Inventory Reporting Regulations 42 FR 64573 (1977), Premanufacture
Notification Requirements and Review Procedures, 44 FR 2254 (1979),
Submission of Notice of Manufacture or Importation of PBBs and Tris, 44 FR
59107 (1979).
8JSee Analysis of Options for Definition of Small Business, and Estimated
Cost of the Initial Section 8(a) Reporting Requirement, Arthur D. Little,
Incorporated, EPA Report No. 561/1-77-001, November 1977.
-------
-22-
C. THE PRODUCTION VOLUME CRITERION
High production volume alone does not indicate significant exposure, but
may indicate widespread use and thus the potential for release of significant
quantities. Consequently, we examined production limits of 100,000 and
1,000,000 pounds (below which companies would not report) in combination with
sales volume in this analysis of the small business definition.
For similar reasons, EPA agreed with industry comments on the proposal
that production of an extremely small quantity of a given chemical would be
unlikely to pose significant exposure, and thus should not be reported for
this rule. In the final rule, no plant site must report on a chemical
produced in quantities below 500 kilograms.
D. OPTIONS FOR SMALL BUSINESS DEFINITIONS
The options we examined for the small business definition were various
annual sales figures combined with production volume limits. All of the plant
sites with parent firms with total annual sales above the sales cutoff of the
small business definition are required to report. When its parent firm falls
below the sales cutoff of the small business definition, a plant site need
only report on a chemical production greater than or equal to the production
limit. Fourteen different cases are examined in this report:
Baseline (no small business or small quantity exemption.)
No small business exemption; 500 kilogram small quantity
exemption.
$1 Million sales limit and 100,000 pounds production limit;
500 kilogram small quantity exemption.
$3 Million sales limit and 100,000 pounds production limit;
500 kilogram small quantity exemption.
$5 Million sales limit and 100,000 pounds production limit;
500 kilogram small quantity exemption.
$10 Million sales limit and 100,000 pounds production
limit; 500 kilogram small quantity exemption.
$30 Million sales limit and 100,000 pounds production
limit; 500 kilogram small quantity exemption.
$50 Million sales limit and 100,000 pounds production
limit; 500 kilogram small quantity exemption.
$1 Million sales limit and 1,000,000 pounds production
limit; 500 kilogram small quantity exemption.
-------
-23-
$3 Million sales limit and 1,000,000 pounds production
limit; 500 kilogram small quantity exemption.
$5 Million sales limit and 1,000,000 pounds production
limit; 500 kilogram small quantity exemption.
$10 Million sales limit and 1,000,000 pounds production
limit; 500 kilogram small quantity exemption.
$30 Million sales limit and 1,000,000 pounds production
limit; 500 kilogram small quantity exemption.
$50 Million sales limit and 1,000,000 pounds production
limit; 500 kilogram small quantity exemption.
E. SMALL BUSINESS DEFINITION
To qualify as small with respect to a given chemical under the section
8(a) Preliminary Assessment Rule, a plant site must meet the following
criteria:
a. total annual sales of the parent company (on all
products) are less than $30 million, and
b. total annual production (or amount processed) of the
chemical at the plant site is less than 100,000 pounds.
Annual sales figures are based on the sum of all of the plant sites owned
or controlled by the reporting parent company.
The small business exemption is separate from the small quantity
exemption. Under the small quantity exemption, reports on chemicals produced
in quantities of 500 kg or less per plant site are not required, regardless of
company size.
Because a purpose of this rule is to identify general exposure potentials
to set EPA's preliminary priorities and assess risks, more detailed informa-
tion is not needed for this rule. Therefore, a relatively high sales cut-off
level has been adopted. However, because another purpose of this rule is to
identify potentially high exposures, it is necessary to specify a production
limit of 100,000 pounds above which a company would have to report regardless
of sales.
Several factors led to the value of $30 million as a cutoff. First, firms
under $30 million in sales generally have fewer technical staff available to
-------
-24-
help meet reporting requirements.9-1 Second, the vast majority of reports
will be filed by companies above the $30 million level, so that a substantial
amount of information will be reported even with a $30 million cutoff. A
small business definition higher than $30 million would mean that a larger
amount of information would be lost. Third, above $30 million, the estimated
median impact as a percent of profits drops below 0.1 percent.
9jS0CMA comments on proposed PMN regulations, March 26, 1979, p. 35.
-------
-25-
VI. TOTAL COST AND ECONOMIC IMPACT
A. TOTAL INDUSTRY COSTS
The total cost to industry was determined for 14 small business defini-
tions (see Tables 4 through 17 and summary Table 18). These tables show that
the cost to manufacturers, using the assumptions discussed in Section III,
could range from $4.3 to $5.0 million depending on the exemption criteria
selected.
If no small business or small quantity exemptions are allowed, the total
cost to manufacturers of the Preliminary Assessment Information Rule will be
$5.0 million (Table 4). Under these conditions, 959 companies representing a
total of 1,881 plant sites would be subject to the rule (see Table 4).
With the small business definition set at $30 million with a production
volume limit of 100,000 pounds, the total cost of the Rule to manufacturers is
$4.4 million. Under this definition, 1,717 plant sites representing 820 firms
would be subject to the rule (see Table 10). Ninety-one of the firms with
sales below $30 million did not provide production data. These firms may also
be exempt from reporting.
The change in total cost between the benchmark cost (no small business
definition) and the most lenient definition under consideration ($50 million
and 1,000,000 pounds) does not exceed 16 percent ($4.3 million versus $5.0
million). This is partially attributable to the fact that, because of their
production volume, some companies will have to report no matter what the size
of the dollar sales exemption. It is also due to the fact that if there were
no exemptions, plant sites belonging to companies with sales of $30 million or
more will submit over 80 percent of the individual chemical reports. These
companies represent only 55 percent of the.companies with plant sites required
to report for this rule. The 80 percent and 55 percent figures are derived by
summing the number of companies over $30 million on Table 4 and dividing by
the total number of companies and reports, not including those with missing
production or sales.
B. ECONOMIC IMPACT
The economic impact of the Preliminary Assessment Information Rule on
individual companies varies greatly across sales categories (see Figure 4).
The average impact statistics, measured as a percent of company profits,
appear in Tables 4 through 17 and summary Table 18.
The total number of firms reporting is only reduced 15 percent by providing
a small business exemption. It goes from 959 with no exemptions to 820 with a
$30 million, 100,000 pound exemption (Figure 3). But the number of firms with
sales below $30 million reporting is reduced 64 percent by providing the
exemption (see Figure 5). With no small business exemption and a 500 kilogram
small quantity exemption, 286 firms under $30 million must report; with a $30
-------
-26-
million, 100,000 pound exemption, only 103 with sales under $30 million must
report. Of the 183 exempted, however, production data are missing for 91.
Some of these may still have to report because of large production volume.
This number is not expected to be great, however, as 54 of the 91 are
extremely small companies with sales under $5 million.
-------
- 27 -
FIGURE 2
TOTAL COST VS. SIZE OF EXEMPTION
0-,
I L_
^ j-(No Exemption)
\~nl ~r'
q--
TP
J:
i —i
No Exempt-ion Except 500
JCi lo.gr am J SmalJ Quantity .
Exemption)
(Production Limit of 100,000
(Production Limit of 1,000,000
- !
Pounds)-I - r -
3-i
i--
i !
i i-
- i
i i-
- i I
1—
2~
l-
i !
h i
"I"
-jr.
i
i-
i i-i
i i
I
I i i
I i ! ' i 1
.a/
i
o
10
30
50
Size of Exemotion (Millions of Dollars)
No small business exemption or small quantity exemption.
For all other sizes of exemption, the 500 kilogram small
quantity exemption applies regardless of company size.
-------
FIGURE 1
FLOW CHART FOR CLASSIFYING
DATA
prl«te lalei category
/s
cut-off) ratrqory
7\
Y -- Yes, N — No.
-------
Total Number
of Reporting
Companies
-------
8
7
6
5
4
3
2
1
0
FIijUkis 4
AVERAGE IMPACT ON A FIRM WHICH MUST REPORT
Number of Companies if Sales Category
is Exempt
up to
100,000 Pounds
s
' Production
Number of Companies if Sales Category
is Exempt
up to
1,000,000 Pounds
i
Production
!
II
1
Number of Companies if Sales Category is not Exempt
Number of Companies if Sales Category is not Exempt, Except for 500
Kilogram Exemption
0-1
1-3
3-5
.10 .IB
b/ b/
.03 .03 .004 -004
5-io ~ io-3o so^tr- ScFtob lob-5do SooT
Size of Company (Millions of Dollars)
a/
Average of only three companies of this size affected under 1,000,000 pound exemption.
b/The two types of companies displayed here are the same as those for size range 50-100.
VO
-------
FIGURE 5
EFFECT OF SMALL BUSINESS EXEMPTION ON NUMBER OF COMPANIES REQUIRED TO REPORT*
Number of
Companies
Known to
be Required
to Report
250
200
150
100
50
E2! 40
St
EB9
EEl
Number of Companies if Sales Category is not Exempt
Number of Companies if Sales Category is not Exempt, Except for 500
Kilogram Exemption
Number of Companies if Sales Category is Exempt up to 100,000 Pounds Production
Number of Companies if Sales Category is Exempt up to 1,000,000 Pounds Production
50 49
i
21 21
10
Size of
5-10 10-30 30-50
Company (Millions of Dollars)
50-100 100-
500
238
S
—I
dl_il
500+
*0f the 183 companies exempted by a $30 million, 100,000 pound small business definition,
production data are missing for 91. Some of these may still have to report due to large
production volume, but this number is not expected to be great, since 54 of the 91 have
sales under $5 million.
-------
- 31 -
FIGURE 6
IMPACT ON MOST AFFECTED COMPANY IN EACH SALES CATEGORY
15
10
Impact
(Cost as
a Percent
of Profit)
(No Small Business Exemption Except 500 Kilogram!
~r "(TT- T~"."---I-i .... ! T .1 , • [
,J 1' ! Exemption)-!— : —:—!—'
lion
"100", 000 "Poum
Exemption )1—;
50-100 100-500 500+
30-50
10-30
3-5
5-10
] -3
0-1
Size of Company (Millions of Dollars)
-------
Table 4
BASELINE (NO SMALL BUSINESS EXEMPTION OR SMALL QUANTITY EXEMPTION)
1
1
1
iMissing
1 Missing 1
1 0-1M
1 1-3M
1 3-5M
1 5-10M
10-30M
30-50M
50-100M
1100-500M
500+M
1 Sales
IProductionl
Total 1
Number of Firms
52
80
5°
55
75
21
36
! 83
238
206
63 !
959 !
.Number of
Plant Sites
1 56
1 86
1 51
1 62
86
30
50
1 137
1,035
1 213
1 75 I
1,881 1
.Number of
. Individual
j 253
506
222
331
425
168
272
767
5,315
894
503
9,656 ]
. Reports
.Average Number
.of Reports/Fino
1 4.87
1 6.33
1 4.44
1 6.02
5.66
8.00
7.56
1 9.24
22.33
1 4.34
1 — 1
10.07 I
.Range of Number
of Reports
1 1-17
1 1-70
1 1-33
1 1-44
1-49
1-30
1-50
1 1-92
1-244
1
1 ~ 1
1-244 |
.Total Cost ($)
133,140
253,800
117,720
168,780
219,780
84,960
138,240
387,900
2,729,100
477,720
24 7,260
4,958,400
.Range of Cost
900-
900-
900-
! 900-
900-
900-
900-
900-
1,320-
900-
Per Firm ($)
4,260
14,760
10,140
18,960
21,540
14,040
22,440
39,120
45,120
45,120
1 Ave rage Impact
1 las % of Profit)
1 7.8
1 3.1
1 1.
1 .7
.29
.18
.096
1 .030
.004
1
1 — 1
1
IPer Firm
1 Range of Impact
1(as % of Profit)
IPer Firm
1,5~
101.6
0.5-
40.2
.3-
4.2
.15-
5.3
.06-
3.6
.04-
.69
.02-
.46
.0030-
.58
0-
.08
1
1 — 1
1
-------
Table S
NO SMALL BUSINESS EXEMPTION; 500 KILOGRAM SMALL QUANTITY EXEMPTION
1 Missing
1 Missing 1
1 0- 1M
1 1- 3M
1 3-5M
1 5-10M
1 10-30M
30-50M
50-100M
1100-500M
500+M
1 Sales
1 Production 1
Total I
.Number of Cos.
40
J 76
49
52
! 69
21
34
81
233
194
63
912 !
.Number of
.Plant Sites
1 45
1 82
1 50
1 60
1 80
29
49
1 135
1,020
1 198
1 75 I
1,823 I
Number of
.Individual
158
348
206
228
381
166
260
626
5,064
862
719
9,018 !
.Reports
.Average Number
.of Reports/Co.
1 4.0
1 4.6
1 4.2
1 4.4
1 5.5
7.9
7.6
1 7.7
21.7
1
1 " 1
9.89 I
.Range of Number
.of Reports
1 1-9
1 1-34
1 1-23
1 1-44
1 1-49
1-30
1-49
1 1-135
1-244
1
1 — 1
1-244 |
.Total Cost ($)
J 87,960
j185,520
110,520
124,560
198,420
84,960
132,720
[327,720
2,616,480
457,080
337,980 1
4,662,600
.Range of Cost
900-
900-
900-
900-
900-
900-
900-
900-
1,320-
900- !
Per Firm ($)
4,260
14,760
10,140
18,960
21,540
4,040
22,020
39,120
45,120
116,280
lAverage Impact
1(as % of Profit)
1 7.1
1 2.3
1 1.0
1 .59
1 .29
.18
.10
1 .030
.004
1
| |
1
|Per Firm
1 Range of Impact
1(as % of Profit)
|Per Firm
1.6-
12.8
| 5.23-
13.7
1 °-3~
4.2
! *15~
5.27
j .06-
3.6
.04-
.69
.02-
.46
.003-
.58
0-
.08
1
1 ~ 1
— 1
-------
Table 6
SHALL BUSINESS DEFINITION; $1 MILLION SALES LIMIT AND 100,000 POUNDS PRODUCTION LIMIT} SOO KILOGRAM SHALL QUANTITY EXEMPTION
1 Missing
1 Hissing
1 Sales (Over
ISales (Under
1 Hissing
1 0-1M
1 1-3M
3-5M
1 5-10M
10-30M
1 30-50M
S0-100M
100-500M
500+M
1100,000 lbs.)
1100,000 lbs.)
1 Production
Total 1
Number of Cos.
j 11
76
49
| 52
69
21
34
81
233
155
1
39
77
897
.Number of
.Plant Sites
1 11
1 82
50
1 eo
80
1 29
49
135
1,020
t 157
1
1
1 41
1
1 90
1,804 I
Number of
1
1
. Individual
J 21
J 348
206
! 228
381
166
260
626
5,064
537
325
800
8,965
Reports
1
.Average Number
,of Reports/Co.
1 2.18
1 4.6
4.2
I 4.4
5.5
1 7.9
7.6
7.7
21.7
1
1
1
1
9.99 I
Range of Number
.of Reports
1 1-B
1 1-34
1-23
1 1-44
1-49
1 1-30
1-49
1-135
1-244
1
1
1
1
1
1-244 I
.Total Cost <$)
j15,360
185,520
110,520
124,560
198,420
*83,640
132,720
327,720
2,616,480
300,900
1
156,180
379,200
4,631,220 J
! Range of
1
1
.Cost Per
900-
900-
900-
900-
900-
900-
900-
900-
1,320-
900- ]
.Firm ($)
3,840
14,760
10,140
18,960
21,540
14,040
22,020
59,100
116,280
1
116,280 j
'Average impact
1
! (as I of Profit)
.Per Firm
1 4.7
1 2.3
1.0
1 .59
.29
1 .18
.10
.030
.004
1
1
1
" 1
J Range of Impact
. (as % of Profit)
' 1.9-
1 °-3~
0.3-
.15-
.06-
J .04-
.02-
.003-
0-
.Per Firm
12.8
13.7
5.3
5.3
3.6
j .69
.46
. 58
.08
1
-------
Table 7
SMALL BUSINESS DEFINITION: $3 MILLION SALES LIMIT AfjD 100,000 POUNDS PRODUCTION LIMIT; 500 KILOGRAM SMALL QUANTITY EXEMPTION
1
1 Missing
Missing
1
1 Sales (Over
Sales (Under
1 Missing
1 0—1M
1-3M
3-5M
1 5-10M
10-30M
30-50M
50-100M
100-500M
500+M
1100,000 lbs.)
100,000 lbs.)
1 Production
Total 1
.Number of Cos.
1
! 11
15
49
! 52
69
21
34
81
233
155
39
104
863
.Number of
.Plant Sites
i
i ii
i
15
50
1 60
80
29
49
135
1,020
1 157
41
1 118
1,765 I
.Number of
i
.Individual
24
42
206
228
381
166
260
626
5,064
! 537
325
976
8,835 J
.Reports
1
.Average Number
.of Reports/Co.
1
1 2.18
1
2.80
4.2
1 4.4
5.5
7.9
7.6
7.7
21.7
1
—
1
10.24 |
.Range of Number
.of Reports
1
1 1-8
1
1-7
1-23
1 1-44
1-49
1-30
1-49
1-135
1-244
1
—
1
1-244 |
Total Cost ($)
J15,360
24,840
110,520
124,560
198,420
83,640
132,720
327,720
2,616,480
300,900
156,180
466,560
4,557,900
1 Range of
ICost Per
iFirm ($)
900-
[3,840
900-
3,420
900-
10,140
900-
18,960
900-
21,540
900-
14,040
900-
22,020
900-
59,100
1,320-
116,280
1
—
1
900-
116,280
1 Ave rage Impact
1
1(as % of Prof-
1 4.7
1.4
1.0
1 .59
.29
.18
.10
.030
.004
1
—
1
|
lit) Per Firm
1
1 Range of Impact
1(as t of Prof-
1 i t) Pe r Fi rm
! 1*~
.6-
0.3-
.15-
.06-
.04-
.02-
.003-
0-
12.8
2.85
4.2
5.3
3.6
.69
.46
.652
.08
-------
Table 8
SMALL BUSINESS DEFINITION: $5 MILLION SALES LIMIT AND 100,000 POUNDS PRODUCTION LIMIT; 500 KILOGRAM SMALL QUANTITY EXEMPTION
1
1
1 0-1M
1 1-3M
1 3-5M
1 5-10M
1 10-30M
1 30-50M
50-100M
100-500M
500+M
1 Missing
1 Sales (Over
1100,000 lbs.)
1 Missing
1 Sales (Under
1100,000 lbs.)
Missing
Production
Total I
.Nunber of Cos.
1
11
-i
15
22
52
69
21
34
81
233
155
39
117
849 1
.Number of
.Plant Sites
1
1 11
1
|
1 15
1 22
1 60
1 80
1 29
49
135
1,020
1 157
1 41
132
1,751 1
. Number of
.Individual
.Reports
1
24
1
|
42
4°
228
381
166
260
626
5,064
1 537
324
1,063
8,756
.Average Number
.of Reports/Co.
1
1 2.18
1
-\
1 2.80
1 1.82
1 4.4
1 5.5
1 7.9
7.6
7.7
21.7
1
1
—
10.31 I
.Range of Number
.of Reports
1
1 1-8
1
—t
1 1-7
1 1-5
1 1-44
1 1-49
1 1-30
1-49
1-135
1-244
1
1
—
1-244 I
.Total Cost ($)
15,360
-|
24,840
27,360
124,560
198,420
83,640
132,720
327,720
2,616,480
! 300,900
156,180
509,820
4,518,000 j
.Range of Cost
.Per Firm ($)
900-
J 3,840
-|
900-
3,420
900-
2,580
900-
18,960
900-
21,540
900-
14,040
900-
22,020
900-
59,100
1,320-
116,280
1
1
--
900-
116,280
1 Ave rage Impact
1(as % of Prof-
1 it) Per Firm
1
1 4.7
1
-1
1 1.4
1 .53
1 .59
1 .29
1 .18
.10
.030
.004
1
1
—
1
1 Range of Impact
1(as % of Prof-
|it) Per Firm
1.9-
12.8
.64-
2.85
.38-
1.05
.15-
5.3
.06-
3.6
.04-
.69
.02-
.46
.003-
.652
0-
.08
1
1
—
1
-------
Table 9
SMALL BUSINESS DEFINITION: $10 MILLION SALES LIMIT AND 100,000 POUNDS PRODUCTION LIMIT; 500 KILOGRAM SMALL QUANTITY EXEMPTION
1
1
1 0-1M
1-3M
1 3-5M
1 5-10M
1 10-30M
1 30-50M
50-100M
100-500M
500+M
1 Missing
1 Sales (Over
1100,000 lbs.)
Missing
Sales (Under
100,000 lbs.)
1 Missing
1 Production
Total I
¦ Number of Cos.
1
11
15
j 22
' 24
69
! 21
34
81
233
1 155
39
j 129
833 [
.Number of
.Plant Sites
1
1 11
1
15
1 22
1 27
1 B0
1 29
49
135
1,020
1 157
41
1 146
1,732 I
.Number of
.Individual
Reports
1
24
1
_j
42
40
67
! 381
166
260
626
5,064
537
325
1,157
8,689
Average Number
.of Reports/Co.
1
1 2.18
1
2.80
1 1.82
1 2.79
1 5.5
1 7.9
7.6
7.7
21.7
1
—
1
10.43 I
.Range of Number
¦of Reports
1
1 1-8
1
1-7
1 1-5
1 1-22
1 1-49
1 1-30
1-49
1-135
2-244
1
—
1
1-244 |
Total Cost ($)
J15,360
_J
24,840
[27,360
41,100
198,420
83,640
132,720
327,720
2,616,480
300,900
156,180
[ 556,020
4,480,740 j
1 Range of
ICost Per
IFirm ($)
900-
[3,840
|
900-
3,420
j 900-
2,580
900-
9,720
900-
21,540
900-
14,040
900-
22,020
900-
59,100
1,320-
116,280
1
--
1
900-
116,280
1 Ave rage Impact
1 (as % of Prof-
lit) Per Firm
1
1 4.7
1
-1
1.4
1 .53
1 .43
1 .29
1 .18
.10
.030
.004
1
—
1
" 1
1 Range of Impact
1(as » of Prof-
|it) Per Firm
! 1.9-
12.8
.64-
2.85
.375-
1.05
! "16"
1.76
.06-
3.6
.043-
.69
.02-
.46
.003-
.58
0-
.08
1
--
1
— 1
-------
Table 10
SMALL BUSINESS DEFINITIONS: $30 MILLION SALES LIMIT AND 100,000 POUNDS PRODUCTION LIMIT; 500 KILOGRAM SMALL QUANTITY EXEMPTION
1
1 Missing
Missing
1 1
1
1 0-1M
1 1-3M
1 3-5M
1 5-10M
1 10-30M
1 30-50M
50-100M
100-500M
500+M
1 Sales (Over
1100,000 lbs.)
Sales (Under
100,000 lbs.)
1 Missing I
1Productionl
Total I
.Number of Cos.
1
H
-|
! 15
22
24
1 31
| 21
34
81
233
155
39
1 1
154
820
.Number of
.Plant Sites
t
1 11
1
H
1 15
1 22
1 27
1 33
1 29
49
135
1,020
1 157
41
H 1—
I 1
1 178 I
1 1
1,717 I
.Number of
1
H 1—
1 1
.Individual
.Reports
24
1
-)
42
40
! 67
70
166
260
626
5,064
537
325
J 1,368 [
1 1
8,589
.Average Number
.of Reports/Co.
1
1 2.18
1
1 2.80
1 1.82
1 2.79
1 2.26
1 7.9
7.6
7.7
21.7
1
—
1—
1 1
1 1
10.47 I
Range of Number
.of Reports
1
1 1-8
1
-|
1 1-7
1 1-5
1 1-22
1 1-11
1 1-30
1-49
1-135
1-244
1
~
A 1—
1 1
1 1
1-244 I
.Total Cost ($)
15,360
H
!24,840
27,360
41,100
45,240
83,640
132,720
327,720
2,616,480
300,900
156,180
"1 1—
660,000 4
431,540
1 Range of
900-
900-
900-
900-
900-
900-
900-
900-
1,320-
H 1—
1 1
900- !
iFirm ($)
3,840
3,420
2,580
9,720
5,100
14,040
22,020
59,100
116,280
1 1
116,280
1 Ave rage Impact
1
H 1—
1 1
1(as % of Prof-
1 4.7
1 1.4
1 .53
1 .43
i .14
1 .18
.10
.030
.004
|
1
lit) Per Firm
1
-1
1 1
1 Range of Impact
1(as » of Prof-
1 it) Per Firm
J 1.9-
12.8
] .64-
2.85
.375-
1.05
.16-
1.76
! -o5~
.85
.04-
.69
.02-
.46
.003-
.582
0-
.08
1
—
H 1—
1 1
1 1
— 1
-------
Table 11
SMALL BUSINESS DEFINITION: $50 MILLION SALES LIMIT AND 100,000 POUNDS PRODUCTION LIMIT; 500 KILOGRAM SMALL QUANTITY EXEMPTION
1
1
1 0-1M
1 1-3M
1 3-5M
1 5-10M
1 10-30M
1 30-50M
50-100M
100-500M
500+M
1 Missing
1 Sales (Over
1100,000 lbs.)
Missing
Sales (Under
100,000 lbs.)
Missing
Production
Total I
.Number of Cos.
1
11
15
! 22
! 24
31
10
34
81
233
155
39
160
815 !
. Nimber of
.Plant Sites
1
1 11
1
|
1 15
1 22
1 27
1 33
1 14
49
135
1,020
1 157
41
189
1.713 |
.Number of
. Individual
.Reports
1
24
1
-|
42
40
67
70
50
260
626
5,064
537
325
1,448
8,553 !
.Average Number
.of Reports/Co.
1
1 2.18
1
H
1 2.80
1 1.82
1 2.79
1 2.26
1 5.00
7.6
7.7
21.7
1
—
—
10.49 I
.Range of Number
.of Reports
1
1 1-8
1
-(
1 1-7
1 1-5
1 1-22
1 1-11
1 1-21
1-49
1-135
1-244
1
—
—
1-244 |
.Total Cost ($)
15,360
-J
24,840
27,360
41,100
45,240
27,720
132,720
327,720
2,616,480
300,900
156,180
698,880
4,414,500 [
1 Range of
ICost Per
IFirm ($)
900-
J 3,840
H
900-
3,420
900-
2,580
900-
9,720
900-
5,100
900-
10,260
900-
22,020
900-
59,100
1,320-
116,280
1
—
—
900-
116,280
1 Ave rage Impact
1(as % of Prof-
1 it) Per Firm
1
1 4.7
1
H
1 1.4
1 .53
1 .43
1 .14
1 .13
.10
.030
.004
1
—
--
— 1
1 Range of Impact
1(as % of Prof-
1 it) Per Firm
1,9~
12.8
.64-
2.85
! .375-
1.05
.16-
1.76
.05-
.85
.043-
.35
.02-
.46
.003-
.58
0-
.08
1
~
—
— 1
-------
Table 12
SMALL BUSINESS DEFINITION: $1 MILLION SALES LIMIT AND 1.000.000 POUNDS PRODUCTION LIMIT, 500 KILOGRAM SMALL QUANTITY EXEMPTION
1
|
Missing
1 Missing
1
1 0-1M
1-3M
3-5M
5-10M
10-30M
30-50M
50-100M
100-500M
500+M
Sales (Over
100,000 lbs.)
ISaleo (Under
1100,000 lbs.)
1 Missing
.Number of Cos.
1
3
—1
76
49
52
69
21
34
81
233
105
89
1
77
889
.Number of
1
82
~t
.Plant Sites
1 3
1
H
50
60
80
29
49
135
1,020
105
1 93
1 90
1
1.796 I
.Number of
1
-i
1
. Individual
.Reports
8
1
H
348
206
228
381
166
260
626
5,064
271
591
800
1
8,949 J
.Average Number
.of Reports/Co.
1
1 2.7
1
~i
4.60
4.20
4.40
5.50
7.90
7.60
7.70
21.70
—
1
H
1
1
10.07 |
.Range of Number
.of Reports
1
1 1-6
1
H
1-34
1-23
1-44
1-49
1-30
1-49
1-135
1-244
—
1
-1
1
1
1-244 |
¦Total Cost ($)
[4,000
H
185,520
110,520
124,560
198,420
83,640
132,720
327,720
2,616,480
164,220
292,860
H
379,200
4,620,660
1 Range of
ICost Per
iFirm (t)
900-
3,000
H
900-
14,760
900-
10,140
900-
18,960
900-
21,540
900-
14,040
900-
22,020
900-
59,100
1,320-
116,280
—
1
H
1
1
900- j
116,280
1 Average Impact
1
"I
1(as % of Prof-
llt) Per Firm
1 S.8
1
i
2.3
1.0
.59
.29
.18
.10
.030
.004
--
1
1
1
— 1
1 Range of Impact
1 {as t of Prof-
lit) Per Firm
! 2-6~
10.0
0.5-
13.7
0.3-
4.20
.15-
5.30
.06-
3.60
.04-
.69
.02-
.46
.003-
.58
0-
.08
—
1
-1
1
1
— 1
-------
Table 13
SHALL BUSINESS DEFINITION I $3 MILLION SALES LIMIT AND 1,000,000 POUNDS PRODUCTION LIMIT; 500 KILOGRAM SMALL QUANTITY EXEMPTION
1
Missing
1 Missing
1
1 0-1M
1-3M
J 3-5M
1 5-10M
10-30M
1 30-50M
50-100M
100-500M
500+M
Sales (Over
100,000 lbs.)
1 Sales (Under
1100,000 lbs.)
1 Missing
.Number of Cos.
1
[ 3
H
7
! 49
! 52
69
| 21
34
81
233
105
89
104
847 j
.Number of
.Plant Sites
1
1 3
1
H
7
1 50
1 60
80
1 29
49
135
1,020
105
1 93
1 118
1,749 |
.Number of
1
.Individual
.Reports
a
1
-1
14
206
228
381
166
260
626
5,064
271
J 591
976
8,791 j
•Average Number
of Reports/Co.
1
1 2.7
1
~1
2.00
1 4.20
1 4.40
5.50
1 7.90
7.6
7.70
21.7
--
1
1
10.38 |
.Range of Number
.of Reports
1
1 1-6
1
-|
1-3
1 1-23
1 1-4 4
1-49
1 1-30
1-49
1-135
1-244
--
1
--
1-244 I
.Total Cost ($)
4,800
-i
9,240
J110,520
124,560
198,420
83,640
132,720
327,720
2,616,480
164,220
292,860
466,560
4,531,740 [
1 Range of
ICost Per
1 Firm ($)
900-
3,000
H
900-
1,740
900-
10,140
900-
18,960
900-
21,540
900-
14,040
900-
22,020
900-
59,100
1,320-
116,280
—
1
1
900-
116,280
lAverage Impact
1
1(as 1 of Prof-
|it) Per Firm
1 5.8
1
H
1.2
1 1.0
1 .59
.29
1 .18
.10
0.03
0.004
—
1
1
~ 1
iRange of Impact
1(as % of Prof-
llt) Per Firm
2.6-
10.0
.75-
1.04
0.3-
4.20
! a5_
5.30
.06-
3.60
.04-
.69
.02-
.46
0.003-
.58
0.00-
.08
—
1
1
— 1
-------
Table 14
SMALL BUSINESS DEFINITION: $5 MILLION SALES LIHIT AND 1,000,000 POUNDS PRODUCTION LIMIT* 500 KILOGRAM SMALL QUANTITY EXEMPTION
1
1 Missing
1 Missing
1
1 0-1M
1-3M
3-5M
1 5-10M
1 10-30M
1 30-50M
50-100M
100-500M
500+M
1 Sales (Over
1100,000 lbs.)
ISales (Under
1100,000 lbs.)
1 Missing
Total I
Number of Cos.
1
3
-)
7
7
! 52
! 69
! 21
34
81
233
105
89
117
818
.Number of
.Plant Sites
1
1 3
1
-J
7
7
1 60
1 80
1 29
49
135
1,020
1 105
1 93
1 132
1,720 I
.Number of
1
.Individual
.Reports
8
1
14
10
228
381
166
260
626
5,064
271
1 591
1,063
8,682 !
.Average Number
.of Reports/Firm
1
1 2.7
1
2.00
1.43
1 4.40
1 5.50
1 7.90
7.60
7.70
21.7
1
1
1
10.61 |
.Range of Number
.of Reports
1
1 1-6
1
1-3
1-3
1 1-44
1 1-49
1 1-30
1-49
1-135
1-244
1
1
1
2-244 I
Total Cost (S)
4,800
-)
9,240
7,560
124,560
198,420
83,640
132,720
327,720
2,616,480
164,220
292,860
509,820
4,472,040
1 Range of
ICost Per
iFIrm ($)
900-
3,000
H
900-
1,740
900-
1,740
900-
18,960
900-
21,540
900-
14,040
900-
22,020
900-
59,100
1,320-
116,280
1
1
1
900-
116,280
lAverage Impact
1
I(as % of Prof-
|it) Per Firm
1 5.8
1
-|
1.2
.47
1 .59
1 .29
1 .18
.10
0.03
0.004
1
1
1
— 1
|Range of Impact
1 (as » of Prof-
lit) Per Firm
2.6-
10.0
.75-
1.04
.336-
.725
. 15-
5.3
0.06-
3.60
.04-
.69
.02-
.46
0.003-
.58
0.00-
0.08
1
1
1
— 1
-------
Table 15
SMALL BUSINESS DEFINITION: 110 MILLION SALES LIMIT AND 1,000,000 POUNDS PRODUCTION LIMITj 500 KILOGRAM SMALL QUANTITY EXEMPTION
1
1
1 0-1M
1-3M
3-5M
1 5-10M
1 10-30M
1 30-50M
50-100M
100-500M
500+M
1 Missing
1 Sales (Over
1100,000 lbs.)
1 Missing
1 Sales (Under
1100,000 lbs.)
t Missing
1 Production
Total |
.Number of Cos.
1
J 3
|
7
7
! 10
J 69
21
34
81
233
J 105
1
89
129
768
.Number of
.Plant Sites
1
1 3
-|
7
7
11
80
1 29
49
135
1,020
1 105
H
1
1 93
1 146
1,665 1
Number of
. Individual
.Reports
1
J e
l
-1
14
10
32
361
166
260
626
5,064
271
-t
1
591
1
! 1,157
8,580 J
.Average Number
.of Reports/Co.
l
1 2.7
1
H
2.00
1.43
1 3.20
1 5.50
1 7.90
7.60
7.70
21.7
1
-I
1
1
1
10.89 |
.Range of Number
.of Reports
1
1 1-16
1
1-3
1-3
1 1-16
1 1-49
1 1-30
1-49
1-135
1-244
1
H
1
1
1
1-244 1
.Total Cost (3)
4,600
9,240
7,560
16,720
196,420
j 83,640
132,720
327,720
2,616,460
164,220
H
292,860
556,020
4,412,400
1 Range of
ICost Per
1 Firm (t)
j 900-
3,000
-|
900-
1,740
900-
1,740
j 900-
7,200
900-
21,540
900-
14,040
900-
22,020
900-
59,100
1,320-
116,280
1
1
1
1
900-
116,280
1 Average Impact
1 (as % of Prof-
|it) Per Firm
1
1 5.6
1
-I
1.2
.47
1 .44
1 .29
1 .18
.10
.030
.004
1
~\
1
1
1
-- 1
1 Range of Impact
1 (as » of Prof-
|it) Per Firm
2.61-
10.0
.75-
1.04
.336-
.725
! -19"
1.3
.065-
3.59
.04-
.69
.02-
.46
.003-
.58
0-
0.08
1
H
1
1
1
— 1
-------
Table 16
SHALL BUSINESS DEFINITION I $30 MILLION SALES LIMIT AND 1,000,000 POUNDS PRODUCTION LIMIT; SCO KILOGRAM SMALL QUANTITY EXEMPTION
1
1
1 0-1M
1-3M
3-5M
1 5-10M
1 10-30M
1 30-50M
50-100M
100-500M
500+M
1 Missing
1 Sales (Over
1100,000 lbs.)
1 MlBSirig
ISales (Under
1100,000 lbs.)
1 Missing
1 Product ion
Total |
Number of Cos.
1
! 3
7
7
! 10
! 18
! 21
34
81
233
! 105
1
89
! 154
762 j
.Number of
.Plant Sites
1
1 3
1
7
7
1 11
1 18
1 29
49
135
1,020
1 105
1
1
1 93
1
1 178
1,655 1
Number of
, Individual
.Reports
1
8
1
14
10
32
26
166
260
626
5,064
271
| .
1
! 591
1
1,368
8,436
.Average Number
,of Reports/Co.
1
1 2.7
1
2.00
1.43
t 3.20
1 1.44
1 7.90
7.60
7.70
21.7
1
1
1
1
1
11.07 I
•Range of Number
.of Reports
1
1 1-6
1
1-3
1-3
1 1-16
1 1-6
1 1-30
1-49
1-135
1-244
1
1
1
1 1
1
1
1-244 |
Total Cost ($>
4, BOO
9,240
7,560
18,720
19,560
!83,640
132,720
327,720
2,616,480
164,220
1
292,860
660,000
4,337,520
1 Range of
ICost Per
1 Firm ($)
900-
!3,000
\ |
900-
1,740
900-
1,740
900-
7,200
900-
3,000
900-
14,040
900-
22,020
900-
59,100
1,320-
116,280
1
I
1
1
1
900-
116,280
lAverage Impact
1(as % of Prof-
llt) Per Firm
1
1 5.8
1
-4 1
1.2
.47
1 .44
1 .12
1 .18
.10
.03
.004
1
1
1
1
1
" 1
(Range of Impact
1 (as I of Prof-
|it) Per Firm
2.6-
10.0
.75-
1.04
.336-
.725
.19-
1.3
.06-
.5
.04-
.69
.02-
.46
.003-
.58
0-
.08
1
1
1
1
" 1
-------
Table 17
SHALL BUSINESS DEFINITION: $50 MILLION SALES LIMIT AND 1,000,000 POUNDS PRODUCTION LIMIT] 500 KILOGRAM SMALL QUANTITY EXEMPTION
1 0-1M
1-3M
3-5M
1 5-10M
1 10-30M
1 30-50M
SO-IOOM
100-500M
500+M
1 Missing
1 Sales (Over
1100,000 lbs.)
Missing
Sales {Under
100,000 lbs.)
1 Missing
1 Production
Total I
Number of Cob.
3
7
7
! 10
! 18
7
34
81
233
! 105
89
160
754 j
.Number of
.Plant Sites
1 3
7
7
1 11
1 18
1 9
49
135
1,020
1 105
93
1 189
1,646 |
.Number of
Individual
.Reports
1 8
14
10
32
26
I 19
260
626
5,064
271
591
1,448
8,369
.Average Number
.of Reports/Co.
1 2.7
2.00
1.43
1 3.20
1 1.44
1 2.71
7.60
7.70
12.7
1
—
1
11.10 I
.Range of Number
.of Reports
1 1-6
1-3
1-3
1 1-16
1 1-6
1 1-5
1-49
1-135
1-244
1
—
1
1-244 |
Total Cost (t|
4,800
9,240
7,560
18,720
]19,560
12,300
132,720
327,720
2,616,480
164,220
292,860
698,880
4,305,060
.Range of
.Total Cost ($)
900-
.3,000
900-
1,740
900-
1,740
J 900-
7,200
900-
| 3,000
900-
2,580
900-
22,020
900-
59,100
1,320-
116,280
1
—
1
900-
116,280 J
Average Impact
(as I of Profit)
1 5.8
1.2
0.47
1 .44
1 .12
1 .08
.10
.03
.004
1
—
1
1
.Range of Impact
. (as % of Profit)
! 2.6-
18.0
.75-
1.04
.336-
.725
1 -19~
1.3
.06-
.5
.03-
.11
.02-
.46
.003-
.58
0-
.08
1
—
1
-- 1
-------
Table 18
suh..».w jp josio
UNDER VARIOUS SMALL BUSINESS DEFINITIONS
EXEMPTION SIZE
None
No ne
(except
500
ki lo-
gr am
exemp-
tion)
$1M -
100K lbs
t3M -
10 OK lbs.
$5M -
100K lbs.
110M -
LOOK lbs.
| $30M -
1 100K lbs.
$50M -
10OK lbB.
i $1M -
I 1,OOOK lbB.
$3(1 -
1, OOOK lbs.
1 t5M -
11,000K lbe.
$10M -
1.000K lbs.
$3 0M -
1, OOOK lbs.
j (50M - |
11, OOOK lbs. |
|Total
I Number
|of Re-
Iport-
1
| Com-
Ipaniee
959
912
897
863
849
833
I 820
815
| 889
847
I 818
788
76 2
1 754 |
| Total
|of Re-
Iport-
1i ng
I Plants
1,881
1,823
1,804
1,765
1,751
1,732
1 1,717
L,7L3
1 1,796
1,749
1 1,720
1,685
1,655
1 1,646 |
|Total
|of Re-
Iporte
9,656
9,018
8,965
8,835
8,756
8,689
1 8,589
8,553
1 8,949
8,791
I 8,682
8, 580
8,4J6
1 8,3o9 |
|Total
| Co St
I(l,000i
4,958.4
i)
4,662.6
4,631.2
4,557.9
4,518
4,480.7
I 4,431.5
4,414.5
| 4,620.7
4,531.7
1 4,472
4,412.4
4,337.5
1 4,305.1 |
COMPANY SIZE
1
IfcO-lM
IIU-3M
l$3-5M
IS5-10M
1&10-30M
|$30-50M
|$50-100M
|$100-500M
I J500+M
| Average Impact (Cost as
Ipercent of profit)
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
.With no exemptions except
.500 kilogram exception--
.Table 5
7.1
1 2-3
1
1
1.0
1
1
.59
1
1
.29
1
1
. 18
1
1
. 10
1
1
.03
1
1
.004
1
1
With $30 million, 100,000/
.lb. exempt ion--Table 10
4.7
1 1-4
.53
I *43
• 14
.18
. 10
.03
.004
(Most affected company (Cost
|ae percent of profit)
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
With no exemptions except
.500 kilogram exemption - Tab
12.8
e
13.7
1
1 4-2
I
5,3
|
3.6
|
.69
|
.4 6
1
.58
|
.08
|
|With £3 0 million, 100,000/
jib. exemption From Table 10
12.8
1 2.9
1
1 1-1
1
I 1.8
1
I .85
1
| .69
1
I .46
1
I .58
1
| .08
1
-------
-47-
VII. SENSITIVITY ANALYSIS
We performed a sensitivity analysis to determine the possible error
introduced by the three missing-data assumptions discussed in Section III. We
progressively relaxed the assumptions to determine the cost range for the six
small business definitions which assume a 100,000 pound production limit.
These cases will provide a narrow range in which the true cost of the Rule
will be found. The results are summarized in Figure 7.
The "middle range" estimates are found by relaxing assumptions 1 and 3.
Assumption 1 states that if the production volume information is unknown for a
company which qualifies for an exemption based on sales, the firm would have
to report. Assumption 3 states that if production and sales data are both
missing, the firm would have to report. (Assumptions 1 and 3 must be relaxed
simultaneously, because firms with missing sales and production were
classified together with "Missing Production" firms.) In relaxing assumptions
1 and 3, the opposite assumptions were made: firms whose production volume
was unknown.and who qualify for an exemption based on sales, or whose
production and sales were both unknown, were now counted as not having to
report unless there is no small business exemption. These estimates are
calculated by subtracting the total cost estimate for the "Missing Production"
category from the total industry cost estimate shown in the last column of
Tables 4-17. Table 19 shows these "middle range" estimates for small business
definitions of $1 million, $3 million, $5 million, $10 million, $30 million,
and $50 million. Changing only this assumption, the total cost of the
Preliminary Assessment Information Rule ranges from $3,715,620 when the small
business definition is set at $50 million to $4,958,400 with no small business
exclusion.
The "lower bound" estimates are calculated by relaxing assumptions 1, 2
and 3 simultaneously. Under assumption 2, all companies for which annual
sales figures were unavailable were assumed to have to report even if they
produced chemicals in quantities under 100,000 lbs. In relaxing assumption 2,
the opposite assumption was made: all firms for which annual sales figures
were unavailable, but which produce chemicals in quantities under 100,000 lbs,
were assumed not to report. Relaxing both assumptions means that total cost
in the "Missing Production" and "Missing Sales (Under 100,000 lbs.)"
categories would fall to zero (unless there is no small business exemption, in
which case all companies must report). Therefore, the cost estimate for the
"Missing Production" and "Missing Sales (Under 100,000 lbs.)" categories in
Tables 4 through 17 is subtracted from the total. Table 20 shows these "lower
bound" ranges for the $1 million, $3 million, $5 million, $10 million, $30
million, and $50 million small business definitions. The total cost of the
Preliminary Assessment Information Rule with both assumptions relaxed ranges
from $3,559,440 when the small business definition is set at $50 million to
$4,958,400 when no small business exclusions are allowed. The assumptions
-------
5. 0
4. 5
Total Cost
to Industry
(Millions
of Dollars)
4.0
3. 5
3.0
- 48 -
FIGURE 7
EFFECT OF MISSING DATA ASSUMPTIONS
Exemption) ' 1
i i
I I , ' I ! I I 1 1
No Exemption Except '500 Kilogram Small-Quantity Exemption)
I . 'I . ! , I
I ! I
Most Conservative' Range) '— -,
j !i_! 5 !
(Middle 'Range—Relax Assump-" ;
-
tions.,l.and_3)
(Low Range—Relax
I ¦ -I - - l
tions-L,-2^_. and—3)
i - i J—i
5/,
t r
0 1 3 5 10 30 50
Size of Exemption (Millions of Dollars) (Assumes Limit of 100,000 Pounds'
No small business exemption or small quantity exemption. For all other
sizes of exemption, the 500 kilogram small quantity exemption applies
regardless of company size.
-------
-49-
Table 19
"MIDDLE RANGE" COST ESTIMATES-^
FOR INVENTORY-TYPE SMALL BUSINESS DEFINITION
Small Business Definition Middle Range
Baseline-no exemptions $4,958,400
$0 Million (with 500 kg exemption) $4,662,600
$1 Million (with 500 kg exemption) $4,252,020
$3 Million (with 500 kg exemption) $4,091,340
$5 Million (with 500 kg exemption) $4,008,180
$10 Million (with 500 kg exemption) $3,924,680
$30 Million (with 500 kg exemption) $3,771,500
$50 Million (with 500 kg exemption) $3,715,620
fl /
-Total industry cost assuming firms whose production
volume information was unknown do not have to report.
Production volume limit is 100,000 pounds.
Table 20
"LOWER BOUND" COST ESTIMATES-''
FOR INVENTORY-TYPE SMALL BUSINESS DEFINITION
Small Business Definition Lower Range
Baseline-no exemptions $4,958,400
$0 Million (with 500 kg exemption) $4,662,600
$1 Million (with 500 kg exemption) $4,095,840
$3 Million (with 500 kg exemption) $3,935,160
$5 Million (with 500 kg exemption) $3,852,000
$10 Million (with 500 kg exemption) $3,768,500
$30 Million (with 500 kg exemption) $3,615,320
$50 Million (with 500 kg exemption) $3,559,440
a /
-Total industry cost assuming firms whose production
volume information was unknown or whose sales volume
for chemicals under 100,000 pounds do not have to
report. Production volume is 100,000 pounds.
-------
-50-
are not relaxed in the no-exemption case, because all firms would have to
report on all chemicals.
Relaxing both assumptions changes the total cost of the rule less than 20
percent. The cost and impact of the rule are more sensitive to possible
errors in the industry profitability assumption and the unit cost estimate. A
firm which is only half as profitable as the assumed six percent of sales
would be doubly affected by the rule. Similarly, a firm which spends twice as
much time as forecasted to fill out the form would be doubly affected. The
impact on firms over $30 million in sales would still be negligible, however.
Figures 8, 9, and 10 demonstrate this effect.
Chemicals listed on the inventory as having no production in 1977 were
assumed to still have no production and thus no reporting requirements. If
production of these chemicals at these sites has resumed, 69 sites producing
790 chemicals would be affected. The cost of reporting on these sites for
these chemicals would be $713,540.
-------
-51-
FIGURE 8
EFFECT OF PROFIT ASSUMPTION ON AVERAGE IMPACT*
(Profits = 2 Percent of, Sales)
(Cost as
of P
rofltf6
Profits = 6 Percent of Sales)
Profit's ="10 iPercent of "Sales) ,
0-1
1-3
_l (
3-5 5-10 10-30 30-50 50-100
Size of Company (Millions of Dollars)
100-500 500+
* Assumes no small business exemption except the 500 kilogram exemption,
Chemical industry profits as a percent of sales have fallen between 2
10 percent in each of the last 20 years.
and
-------
-52-
FIGURE 9
EFFECT OF COST ASSUMPTION ON TOTAL CQSTS*
(Costs of $960/Site-and-$840/Report^
(Costs |of $480/Site and $420/Report)
0- 0 1 3 5 10 30 50
Size of Exemption (Millions of Dollars)
*Assun»es limit of 100,000 pounds. This figure doubles and halves our
unit cost estimates in turn, to show the sensitivity of total industry
costs to these estimates,
a/
- No small business exemption or small quantity exemption. For all
other sizes of exemption, the 500 kilogram small quantity exemption
applies regardless of company size.
-------
- 53-
FIGURE 10
EFFECT OF COST ASSUMPTION ON AVERAGE IMPACT*
15
1 V
(Costs-, of-$960/Site and $840/Reportl
! -I M i ! i i I ! I I I-
10
Average
Impact
(Cost as
Percent
of Profits)
Costs of $480/Site and $420/Report)
losts of"$240/Sate aWd
~ " S21C/ReportJ—;
0-1
1-3
3-5
5-10
10-30
30-50
50-100 100-500 500+
Size of Company (Millions of Dollars)
*Assumes no small business exemption except 500 kilogram exemption.
------- |