OMB is approving
this ICR for a level of burden hours greater than EPA requested to
account for the statutorially mandated information collection
activities that are covered by the PRA. EPA excluded the specific
reporting requirements from their supporting statement asserting
that they are not covered by the PRA. As indicated in meetings with
EPA, EPA must demonstrate to OMB why reporting requirements
reiterated in an EPA notice verbatim from a statute (in this case,
the Asbestos Information Act) are excluded from the Act. O
recognizes that there is no discretion in approving requirements
that come directly without interpretation or embellishments from
the law, however this does not mean, as EPA concludes, that they
are excluded from the PRA. An important purpose of the ACt is to
inform the public of the information burden imposed upon them
whether discretionary or Congressionally mandated (see 48 FR
13666). OMB will reconsider this action if EPA can demonstrate how
OMB's interpretation is incorrect. NOTE: OMB's burden estimate is
based on five hours per respondant (bas on estimates in EPA's draft
notice) instead of 1.5 hours.
Inventory as of this Action
Requested
Previously Approved
12/31/1989
12/31/1989
460
0
0
2,300
0
0
0
0
0
THE ASBESTOS INFORMATION ACT (AIA)
REQUIRES ASBESTOS MANUFACTURERS AND PROCESSORS TO SUBMIT CERTAIN
IDENTIFYING INFORMATION ABOUT THEIR ASBESTOS AND/OR
ASBESTOS-CONTAINING PRODUCTS TO EPA. EPA HAS ASKED RESPONDENTS TO
FURNISH A SUMMARY OF THE INFORMATION REQUIRED BY THE AC TO HELP THE
AGENCY ORGANIZE THE DATA.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.