Economics Analysis of Reporting Requirements Under the Toxic Substances Control Act

Section 8 of the Toxic Substances Control Act provides EPA with the authority to promulgate rules requiring manufacturers and processors of chemical substances to report information on chemical identity and structure, production, processing, use, exposure, disposal, and health and environmental effects. EPA currently requires manufacturers (including importers) to provide information on the production and use of chemicals in commerce under the Chemical Data Reporting requirements (40 CFR part 711). CDR data are an important input into EPA’s chemical risk evaluation and risk management program. EPA is currently developing a related rulemaking, called Tiered Data Reporting, to better collect the information needed for the chemical prioritization process.

ERG developed economic analyses in support of both CDR and TDR to estimate the reporting burden and costs to chemical manufacturers, importers, processors, and EPA. We used market research and other sources such as current CDR data, Toxics Release Inventory data, and chemical import/export data to quantify the universe of potentially affected chemicals, chemical reports, sites, and parent companies. Our economists developed models to estimate the unit and total reporting burden and cost (including savings) of multiple regulatory options, and analyzed the potential for the reporting requirements to impact small businesses. Our evaluations included analysis of the benefits of streamlining reporter requirements, increasing data quality, and improving the data collected to support the implementation of TSCA, and of risk evaluation and prioritization efforts.