2599ss01

Supporting Statement for an Information Collection Request (ICR)
Under the Paperwork Reduction Act (PRA)

1. EXECUTIVE SUMMARY
1(a). Identification of the Information Collection – Title and Numbers
Title: Regulation of Persistent, Bioaccumulative, and Toxic Chemicals under TSCA
Section 6(h) (Proposed Rule; RIN 2070-AK34)
ICR Numbers: EPA ICR No.: 2599.01; OMB Control No.: 2070-NEW.
EPA Form Numbers: No required forms for ICR activities
Docket ID Number: EPA-HQ-OPPT-2019-0080.
1(b). Docket Information
The information collection request (ICR) that explains the information collection activities and
related burden and cost estimates, as well as other supporting documents related to the ICR,
are available in the docket established for the rulemaking. The docket can be viewed online at
http://www.regulations.gov or in person at the EPA Docket Center, West William Jefferson
Clinton Bldg., Rm. 3334, 1301 Constitution Ave., NW., Washington, DC. The telephone
number for the Docket Center is (202) 566-1744. For additional information about EPA’s public
docket, visit http://www.epa.gov/dockets.
1(c). ICR Status
This is a new ICR that addresses the information collection activities that are contained in a
proposed rule. Under the Paperwork Reduction Act (PRA), 44 U.S.C. 3501 et seq., an agency
may not conduct or sponsor, and a person is not required to respond to, a collection of
information, unless it displays a currently valid control number issued by the Office of
Management and Budget (OMB). The OMB control numbers are displayed either by
publication in the Federal Register or by other appropriate means, such as on the related
collection instrument or form, if applicable. The display of OMB control numbers for certain
EPA regulations is consolidated in 40 CFR part 9.
Before submitting an ICR to OMB for review and approval under the PRA, an agency must
solicit comments pursuant to PRA §3506(c)(2)(A) and 5 CFR 1320.8(d)(1). After considering
comments received on the draft ICR, the agency must submit the ICR to OMB for review and
approval according to the procedures prescribed in 5 CFR 1320.12. In announcing the
submission of the final ICR to OMB for review and approval, the agency must provide another
opportunity for public review and comments on the revised ICR pursuant to 5 CFR 1320.12(c).
1(a). Abstract
The Environmental Protection Agency (EPA) is proposing a rule under section 6(h) of the Toxic
Substances Control Act (TSCA) concerning prohibitions and restrictions on four chemical
substances. These chemical substances are decabromodiphenyl ether (DecaBDE) (Chemical
Abstract Services Number (CASRN) 1163-19-5), phenol, isopropylated phosphate (3:1) (PIP

(3:1)) (CASRN 68937-41-7), 2,4,6-tris(tert-butyl)phenol (2,4,6-TTBP) (CASRN 732-26-3), and
pentachlorothiophenol (PCTP) (CASRN 133-49-3).
For DecaBDE, the proposed rule would prohibit the manufacture (including import),
processing, and distribution in commerce of DecaBDE, and products and articles to which
DecaBDE has been added except for the following:
• Processing and distribution in commerce for recycling of plastic from products or
articles containing DecaBDE, where no DecaBDE is added during the recycling
process;
• Processing and distribution in commerce of DecaBDE in finished products or articles
made of plastic recycled from products or articles containing DecaBDE, where no
DecaBDE was added during the production of the products or articles made of
recycled plastic;
• Replacement parts for automobiles and other motor vehicles and aircraft and
aerospace vehicles to which DecaBDE has been added;
• Manufacture, processing, and distribution in commerce for use in new aerospace parts
for a period of three years; and
• Manufacture, processing, and distribution in commerce for use in curtains in the
hospitality industry for a period of 18 months.
Each person who manufactures, processes, or distributes in commerce DecaBDE, and
products and articles to which DecaBDE has been added, would be required to keep for 3
years ordinary business records that demonstrate compliance with the prohibitions,
restrictions, and other provisions of the rule.
For PIP (3:1), the proposed rule would prohibit processing and distribution in commerce of the
chemical substance, and products containing the chemical substance except for the following:
• Processing and distribution in commerce for use in aviation hydraulic fluid;
• Processing and distribution in commerce for use in lubricants and greases; and
• New and replacement parts for automobiles and other motor vehicles to which PIP
(3:1) has been added.
In addition, the proposed rule would prohibit releases to water from the remaining
processing, distribution in commerce, and commercial use activities. Persons manufacturing,
processing, and distributing PIP (3:1), and products containing PIP (3:1), in commerce would
be required to notify their customers of these restrictions. In addition, manufacturers,
processors, and distributors would be required to keep for 3 years ordinary business records
that demonstrate compliance with the prohibitions, restrictions, and other provisions of the rule,
including records demonstrating that notification to their customers was provided.
For 2,4,6-TTBP, the proposed rule would prohibit the distribution in commerce of 2,4,6-TTBP
and products containing 2,4,6-TTBP in any container with a volume of less than 55 gallons, in
order to effectively prevent the use of 2,4,6-TTBP as a fuel additive or fuel injector cleaner by
consumers. In addition, the processing and distribution in commerce of 2,4,6-TTBP, and
products containing 2,4,6-TTBP, for use as an oil or lubricant additive would be prohibited,
regardless of container size. Distributors of 2,4,6-TTBP would be required to keep for 3 years
ordinary business records that demonstrate compliance with the prohibitions, restrictions, and
other provisions of the rule.
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For PCTP, the proposed rule would prohibit the manufacture (including import), processing,
and distribution in commerce of PCTP, and products containing PCTP, in concentrations that
exceed 1% by weight. Manufacturers, processors, and distributors of PCTP would be required
to keep for 3 years ordinary business records that demonstrate compliance with the
prohibition.
EPA is proposing this rule under section 6(h) of TSCA, which requires expedited action under
TSCA section 6(a) for PBT chemicals that meet certain statutory criteria and human and
environmental exposure to which is likely. The statute also requires EPA to issue a proposed
rule by June 22, 2019, and a final rule no later than 18 months after the proposal.
The portions of the proposed rule that trigger this Information Collection Request (ICR) consist
of a downstream notification of the prohibitions in the rule for PIP (3:1) and a recordkeeping
requirement for all four PBT chemicals proposed to be regulated.
Legal authority: The Toxic Substances Control Act (TSCA), 15 U.S.C. §§2605(a) and 2605(h).
Respondents/affected entities: Entities potentially affected by this ICR include persons that
manufacture, process, or distribute in commerce DecaBDE, PIP (3:1), 2,4,6-TTBP, or PCTP
for any use.
Respondent’s obligation to respond: Respondents are not obligated to respond or report to
EPA.
Confidentiality of responses: Not applicable. No information is submitted to EPA.
Estimated total number of potential respondents: 81
Frequency of response: On occasion to third parties as needed.
Estimated total annual burden: 50.2 hours. Burden is defined at 5 CFR 1320.3(b).
Estimated total annual costs: $3,940
Changes in the estimates: Not applicable. This is a request for a new OMB Control Number.

2. NECESSITY OF THE INFORMATION COLLECTION
2(a). Related Legal and/or Administrative Requirements
TSCA – Section 6(h) of TSCA (15 U.S.C. § 2605(h)) directs EPA to take action under section
6(a) on certain PBT chemical substances. Under section 6(h), EPA must address risks and
reduce exposure to these PBT chemicals to the extent practicable. Section 6(a) authorizes
EPA to:
(1) Prohibit or limit manufacture, processing, or distribution in commerce;

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(2) Prohibit or limit the manufacture, processing, or distribution in commerce of the
chemical substance above a specified concentration;
(3) Require minimum warnings and instructions with respect to use, distribution, or
disposal;
(4) Require manufacturers or processors to make and retain records;
(5) Prohibit or regulate any manner of commercial use;
(6) Prohibit or regulate any manner of disposal; and/or
(7) Require manufacturers or processors to give notice of the unreasonable risk of injury,
and to recall products if required.
The proposed rule’s provisions are described in the previous section.
2(b). Necessity of the Information Collection
The information collection activities covered by this ICR are necessary in order to enhance the
exposure reductions that are directed by section 6(h).
Without the downstream notification requirement for PIP (3:1), there is a greater likelihood that
non-prohibited uses of PIP (3:1) could be diverted to the prohibited use and that users would
be buying materials that they do not realize contain PIP (3:1) because they would not be aware
of the prohibitions. This could result in inadequate exposure reductions. In order to ensure
awareness of the prohibitions and improve the likelihood PIP (3:1) and products containing PIP
(3:1) are not used in applications where its use is prohibited under the proposed rule, the
manufacturers, importers, processors, and distributors of products that contain PIP (3:1)
designed for uses that are not prohibited will be required to notify downstream purchasers
about the uses that are prohibited. Downstream notification will also be necessary for effective
enforcement of the rule as it provides a record of notification on use restrictions down the
supply chain via Safety Data Sheet. Safety Data Sheets are already required by the
Occupational Safety and Health Administration (OSHA). Therefore, this additional information
should not substantially increase the burden on these companies.
EPA also has authority under section 6 of TSCA to require recordkeeping related to the
regulatory requirements imposed by EPA. This is important where, as here, such records and
reports are necessary for effective enforcement of the section 6 rule.
2(c). Uses, Users, and Purpose of the Information Collection
EPA. This information collection will provide EPA with information only upon inspection of such
materials. There are no reporting requirements to submit information to EPA under the
information collection activities.
Downstream Companies. Under the proposed rule, manufacturers, processors, and
distributors of PIP (3:1) must notify companies downstream upon shipment of PIP (3:1) about
the prohibited use under the proposed rule. The information submitted to downstream
companies would provide knowledge and awareness of the prohibited use to these companies.
The regulated entities would also compile and retain records that are necessary as a reference
for EPA or authorized entities. These records demonstrate that the entities throughout the PIP
(3:1) supply chain are aware of the prohibitions and that companies upstream can show what
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entities they supply to and therefore what entities they would need to notify of the prohibitions.
The records compiled and maintained by the regulated entities would also demonstrate
compliance with the use restrictions and distribution requirements for all 4 of the chemical
substances subject to the proposal. These recordkeeping requirements are necessary to
permit the EPA to conduct its enforcement activities and to ensure compliance within the
regulated community.
3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
3(a). Non-Duplication
EPA’s collection pursuant to the section 6(a) regulations do not duplicate any other collection.
There is no other Federal program that requires the information collection activities related to
the prohibitions under the proposed rule.
3(b). Public Notice Required Prior to ICR Submission to OMB
The notice of proposed rulemaking serves as the public notice for this ICR. Interested parties
should submit comments referencing Docket ID No. EPA-HQ-OPPT-2019-0080 to the address
listed at the end of this document. Responses will be taken into account in developing the final
rulemaking.
3(c). Consultations
In September 2017, EPA held a public meeting via webinar on TSCA section 6(h) and the 5
chemical substances that EPA had preliminarily determined met the statutory criteria (with the
exception of the exposure criterion). In November 2017, EPA participated in a roundtable
discussion with small businesses hosted by the Small Business Administration.
EPA also met with state and local officials early in the process of developing the proposed
action. In October 2017, EPA made a presentation on TSCA section 6(h) and the 5 chemical
substances to state and local government officials participating in a regularly-scheduled
quarterly conference call on TSCA topics.
EPA also consulted with tribal officials during the development of this action. EPA consulted
with representatives of Tribes via teleconference on August 31, 2018, and September 6, 2018,
concerning the prospective regulation of the 5 identified PBT chemicals under TSCA section
6(h). Tribal members were encouraged to provide additional comments after the conference,
and EPA received two comments. EPA also met with the National Tribal Toxics Council
(NTTC) in Washington, DC and via teleconference. During the NTTC meeting, EPA provided
background information on the available regulatory options under 6(a) and a summary of the
information gathered on the five PBT chemicals. Officials from NTTC expressed support for
EPA regulations to reduce exposures to the general population and susceptible
subpopulations. Information pertaining to the tribal consultations can be found in the public
docket (Docket EPA-HQ-OPPT-2019-0080).

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3(d). Effects of Less Frequent Collection
Due to the nature of the triggering events that initiate information collection activities under the
proposed rule, less frequent collection is not feasible. The proposed rule only includes
reporting information to third parties and does not require reporting information to EPA.
3(e). Small Entity Flexibility
EPA believes that the downstream notification and recordkeeping requirements do not unduly
burden small businesses. EPA concludes that the proposed rule has no significant impacts on
any of the entities subject to downstream notification as firms subject to this requirement have
a cost-revenue impact of less than 1 percent.
3(f).

General PRA Related Guidelines

This ICR is consistent with OMB’s general guidelines. Records that would be required by this
proposed rule would have to be maintained for 3 years. Therefore, this ICR does not exceed
the Paperwork Reduction Act guidelines at 5 CFR 1320.5.
3(g). Confidentiality
EPA will not be collecting any information. Therefore, confidential information will not be
submitted to EPA.
3(h). Sensitive Questions
The information collection activities do not include questions of a sensitive nature.
4. AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND

INFORMATION MANAGEMENT
4(a). Agency Activities
There will be no agency collection activities under the proposed rule. There will only be third
party notification and recordkeeping requirements.
4(b). Estimated Agency Costs
This collection requires third party notification and recordkeeping. EPA will not receive or
process any information as a result of the collection. Therefore, EPA estimates that it costs the
Agency approximately $0 to carry out the activities associated with the information collection
activities covered by this ICR.
4(b)(i). Collection Schedule
There is no collection of information by EPA included under the proposed rule. Therefore,
collections occur only by third parties and will occur as needed via Safety Data Sheet.

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4(b)(ii).

Use of Technology to Facilitate Collection Activities

There will be no information collection by EPA. Therefore, there is no need for any technology
facilitation under the proposed rule related to information collection activities. The
recordkeeping requirement does not specify a particular technology or method of retaining the
required information. The collection of information by third parties will occur via Safety Data
Sheet.

5. The RESPONDENTS AND INFORMATION COLLECTION (IC) ACTIVITIES
For each respondent category, this section of the ICR describes the respondents, the
information collection activities and related estimates for burden and costs associated with
those activities.
5(a). Methodology for Estimating Respondent Burden and Costs
The collection specifies third party notification and/or recordkeeping requirements on persons
who manufacturer, process, or distribute the four chemicals subject to the proposed rule. The
North American Industrial Classification System (NAICS) codes associated with industries
most likely affected by the proposed rule’s paperwork requirements are described below:
313320
324110
324191
325110
325199
325211
325510
325520
325612
325991
325998
326113
326130
326150
326199
331420
333112
334220
334290
335929
336111
336411
339113
339920
423110
423120

Fabric Coating Mills
Petroleum Refineries
Petroleum Lubricating Oil and Grease Manufacturing
Petrochemical Manufacturing
All Other Basic Organic Chemical Manufacturing
Plastics Material and Resin Manufacturing
Paint and Coating Manufacturing
Adhesive Manufacturing
Polish and Other Sanitation Good Manufacturing
Custom Compounding of Purchased Resins
All Other Miscellaneous Chemical Product and Preparation Manufacturing
Unlaminated Plastics Film and Sheet (except Packaging) Manufacturing
Laminated Plastics Plate, Sheet (except Packaging), and Shape Manufacturing
Urethane and Other Foam Product (except Polystyrene) Manufacturing
All Other Plastics Product Manufacturing
Copper Rolling, Drawing, Extruding, and Alloying
Lawn and Garden Tractor and Home Lawn and Garden Equipment
Manufacturing
Radio and Television Broadcasting and Wireless Communications Equipment
Other Communications Equipment Manufacturing
Other Communication and Energy Wire Manufacturing
Automobile Manufacturing
Aircraft Manufacturing
Surgical Appliance and Supplies Manufacturing
Sporting and Athletic Goods Manufacturing
Automobile and Other Motor Vehicle Merchant Wholesalers
Motor Vehicle Supplies and New Parts Merchant Wholesalers
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423620
423910
423920
424340
424690
424720
424910
441110
442110
448130
451120
523910
532289

Household Appliances, Electric Housewares, and Consumer Electronics
Merchant
Sporting and Recreational Goods and Supplies Merchant Wholesalers
Toy and Hobby Goods and Supplies Merchant Wholesalers
Footwear Merchant Wholesalers
Other Chemical and Allied Products Merchant Wholesalers
Petroleum and Petroleum Products Merchant Wholesalers (except Bulk Stations
and Terminals)
Farm Supplies Merchant Wholesalers
New Car Dealers
Furniture Stores
Children’s and Infant’s Clothing Store
Hobby, Toy, and Game Stores
Miscellaneous Intermediation
All Other Consumer Goods Rental

The proposed rule would require that each person subject to the rule maintain records for a
period of 3 years that demonstrate compliance with the requirements of the rule. In addition,
the rule would require downstream notification related to PIP (3:1). Persons who manufacture,
process, and distribute PIP (3:1) to notify companies to whom PIP (3:1) is shipped that the
processing and distribution in commerce of PIP (3:1) for any use is prohibited except for the
following uses: (1) aviation hydraulic fluid; (2) lubricants and greases; and (3) new and
replacement parts in the automotive industry.
Number of Entities Affected
EPA developed estimates for number of manufacturers (including importers), processors, and
distributors affected, based on EPA’s Public 2016 Chemical Data Reporting (CDR) data (EPA
2017) and EPA’s 2017 Toxics Release Inventory Program dataset (EPA 2018). Details about
this estimation can be found in the economic analysis for the proposed rulemaking (Docket ID
No. EPA-HQ-OPPT-2019-0080). Note that some entities are associated with more than one
chemical or role, thus the total (showing unique entities) does not sum.
Table 5-1: Summary of Number of Entities Affected
Chemical

Total Manufacturers, Processors and
Distributors Identified

DecaBDE
PCTP
PIP (3:1)
2,4,6-TTBP
TOTAL

45
6
29
12
81

Note:
Total does not sum because of overlap between chemicals.

Rule Familiarization Burden
EPA assumes that each manufacturer (including importers), processor, and distributor of
products that contain the regulated chemicals will spend a half an hour (0.5 hours) becoming
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familiar with the requirements of the rule and developing an understanding of what actions are
necessary to comply with the downstream notification and recordkeeping requirements. EPA
conservatively assumes that this is an annually recurring cost, to account for staff turnover and
other changes at the company which may require a regularly updated understanding of rule
requirements.
Downstream Notification Burden
Downstream notification is considered a third-party notification. EPA estimates that
downstream notification is accomplished through an annotation to already existing chemical
SDSs that each manufacturer, distributor, or importer provides to downstream users under the
Hazard Communication Standard (HCS) (29 CFR 1910.1200). Therefore, burden to amend the
SDS is estimated as a one-time burden.
For PIP (3:1), EPA estimates that it will require 1 hour of technical labor for each affected
manufacturer, importer, and processor of PIP (3:1) and products that contain PIP (3:1) to make
the necessary annotations to the SDSs. This burden is a one-time burden. That is, once an
SDS is annotated, the action would not need to be repeated. EPA was unable to estimate the
potential for new products to enter the market which might require annotation of additional
SDSs over the time period of the ICR. The burden is estimated to occur during the first year of
the ICR only. To develop an estimate of average annual burden across the time period of the
ICR, EPA divided the burden per response equally across the three years. Therefore, average
burden per respondent for each year is calculated as 1 hour/3 years = .33 hours/year.
Recordkeeping Burden
Under the proposed rule, manufacturers (including importers), processors and distributors of
the chemicals subject to the rule must obtain and retain, for a period of 3 years from the date
the record is generated, ordinary business records, such as bills of lading, invoices, or
comparable documents which demonstrate compliance with this rule.
Firms are likely to keep these records as part of their customary business practices. For
example, the Internal Revenue Service recommends that firms keep invoices in order to
document their assets, expenses, gross receipts, and purchases (U.S. Internal Revenue
Service 2015) Therefore, the recordkeeping requirements are not assumed to impose any
additional burden on these firms.
Costs
EPA assumes no direct costs are associated with this collection. Labor costs are based on
fully loaded wage rates. The estimated professional wage rate for manufacturers (including
importers), processors and distributors is $78.63, which was estimated as shown in Table 5-2.

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Table 5-2: Technical Wage Rates
Labor
Category

Data Sources

Professional /
Technical

BLS ECEC, Private
Manufacturing
industries,
“Professional and
related"

Date

18Sept

Wage1

$46.60

Fringes as
% Wage1

52%

Over-head
% wage2

17%

Fringe +
Overhead
Factor

1.69

Loaded
Wages

$78.63

Source(s):
1
Employer Costs for Employee Compensation Supplementary Tables: Sept 2018 (BLS 2018)
Note(s):
2
An overhead rate of 17% is used based on assumptions in Wage Rates for Economic Analysis of the Toxics Release Inventory Program
(Rice, C. 2002)
Values in table may not sum due to rounding

5(b). Information Collections
IC #1: PBT downstream notification and recordkeeping activities
This Information Collection would be required for the proposed rule for Persistent,
Bioaccumulative, and Toxic Chemicals. Respondent NAICS Codes associated with industries
most likely affected by the paperwork requirements are listed in section 5(a).
Information Collection Activities
Under the proposed rule, EPA imposes downstream notification requirements on
manufacturers, processors, and distributors of PIP (3:1); and limited recordkeeping
requirements on manufacturers, processors, and distributors of all the PBT chemicals
proposed to be regulated. For PIP (3:1), the proposed rule would require that each person who
manufactures (including imports), processes, or distributes in commerce PIP (3:1) for nonprohibited uses to notify companies to whom the chemical was shipped of the prohibitions
under the rule, via the SDS. Additionally, manufacturers (including importers), processors and
distributors of the chemicals subject to the rule must obtain and retain, for a period of 3 years
from the date the record is generated, ordinary business records, such as bills of lading,
invoices, or comparable documents that demonstrate compliance with this rule.
In addition to the requirements, EPA also expects that each manufacturer (including
importers), processor, and distributor of the regulated chemicals will incur burden becoming
familiar with the requirements of the rule and developing an understanding of what actions are
necessary to comply with the downstream notification and recordkeeping requirements.
Details on the burden estimate calculations per activity are presented in section 5(a). The table
below presents the estimated average annual burden for each activity.

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Table 5-3: IC# 1. PBT Manufacturers, Processors, Distributors Downstream Notification and
Recordkeeping Activities
Activity/Respondent

81

Annual Burden
per Response
(hours)
0.50

29
81

Number of
Respondents

Rule Familiarization / all
Downstream Notification / PIP
(3:1)
Recordkeeping / all
TOTAL

Total Annual
Burden (hours)

Annual Cost

40.5

$3,180

0.33

9.67

$760

0

0
50.2

$0
$3,940

6. PRA Burden Statement
Under the PRA, burden is defined at 5 CFR 1320.3(b).
This is a new, rule-related information collection. Under the proposed rule for PBT chemicals,
the total burden requested for this ICR is 50.2 hours per year, or 150.5 hours over the 3-year
ICR period. The total annual cost burden requested for this ICR is $3,940 per year or $11,800
over the 3-year ICR period. According to the Paperwork Reduction Act, “burden” means the
total time, effort, or financial resources expended by persons to generate, maintain, retain, or
disclose or provide information to or for a Federal agency. For this collection it includes such
activities as annual familiarization with requirements, recordkeeping, and notification
requirements. An agency may not conduct or sponsor, and a person is not required to respond
to, a collection of information unless it displays a currently valid OMB control number. The
OMB control numbers for EPA’s regulations in title 40 of the CFR, after appearing in the
Federal Register, are listed in 40 CFR part 9 and included on the related collection instrument
or form, if applicable.
The Agency has established a docket for this rulemaking, which includes this rule related ICR,
under Docket ID No. EPA-HQ-OPPT-2019-0080, which is available for online viewing at
http://www.regulations.gov, or in-person viewing at the EPA Docket Center (EPA/DC), EPA
William Jefferson Clinton West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.
The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday
through Friday, excluding legal holidays. The telephone number for the Reading Room is (202)
566-1744, and the telephone number for the Pollution Prevention and Toxics Docket is (202)
566-0280.
You may submit comments regarding the accuracy of the provided burden estimates and any
suggested methods for minimizing respondent burden, including the use of automated
collection techniques. Comments, referencing Docket ID No. EPA-HQ-OPPT-2019-0080 and
OMB Control No. 2070-NEW (EPA ICR No. 2599.01), may be submitted to the OPPT Docket,
Environmental Protection Agency Docket Center (EPA/DC), Mail code: 28221T, 1200
Pennsylvania Ave., NW, Washington, DC 20460 and to OMB, addressed to “OMB Desk Officer
for EPA” and referencing OMB Control No. 2070- NEW (EPA ICR No. 2599.01), via email to
[email protected].

Page 11 of 12

References
Rice, C. (2002). Wage Rates for Economic Analysis of the Toxics Release Inventory Program.
In Office of Environmental Information: U.S. Environmental Protection Agency (Ed.).
U.S. Bureau of Labor Statistics (BLS). (2018). Employer Costs for Employee Compensation
Supplementary Tables, September 2018.
U.S. Environmental Protection Agency (EPA). (2017). 2016 Non-confidential Chemical
Reporting Data (CDR) Database.
U.S. Environmental Protection Agency (EPA). (2018). Toxics Release Inventory (TRI) Basic
Plus Data Files: Calendar Years 1987 - 2017.
U.S. Internal Revenue Service. (2015). Starting a Business and Keeping Records.

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