Justification for Non-substantive Change

Request for a Non-Substantive Change

to an Existing Approved Information Collection

(EPA ICR No. 1884.09; OMB Control No. 2070-0162)

I. Introduction

Why is EPA Requesting a Non-Substantive Change?

EPA is requesting a non-substantive change in order to implement minor revisions to the EPA Form 7740-8 Chemical Data Reporting (CDR) Form U, as well as to implement revisions to the Instructions Manual and the electronic reporting tool User Guides intended to help submitters complete their submissions. EPA is not otherwise modifying the information collection requirements or agency paperwork burden estimates.

These changes are non-substantive because, although they are different than the 2012 reporting information, they were fully addressed in the 2011 CDR rule and conform to the requirements phase-in that OMB reviewed under Executive Order 12866 and approved at that time.

II. Background

In August 2011, EPA published an amendment to the existing CDR rule (formerly known as Inventory Update Rule or IUR), that added new requirements and thresholds, some of which were effective in the 2012 reporting cycle and others that are effective in the 2016 reporting cycle.

III. Description of Non-Substantive Changes

What Information Collection Request (ICR) is EPA changing?

ICR Title:	Partial Update of the TSCA Section 8(b) Inventory Data Base, Production and Site Reports (Chemical Data Reporting)
ICR Numbers:	EPA ICR No. 1884.08; OMB Control No. 2070-0162

What is the current status of this ICR?

This ICR is currently approved through October 31, 2018.

What are the changes that EPA is making to this collection of information?

The 2011 amendments in the CDR contained changes that are effective in 2016: 1) the threshold for reporting process and use information is lowered to 25,000 pounds; 2) the total annual production volume is reported for all reporting years since the last reporting year (for 2016, years 2012-2015); and 3) the threshold for reporting manufacturing, processing and use information for certain regulated chemicals is lowered to 2,500 pounds.

EPA is revising the Form U to reflect the change in the number of years annual production volume must be reported. Blocks 2.B.20.a., 2.B.20.b. and 2.B.20.c. will request past production volumes for the calendar years since the last reporting period (currently 2012, 2013, and 2014). The Paperwork Reduction Act Notice will also be revised to reflect the pubic burden in the current ICR.

EPA is also updating the Instructions for Reporting to clarify the changes for the 2016 reporting, as described in the 2011 CDR rule.

For submission of CDR information, EPA provides an electronic, web-based tool (e-CDRweb). Updated User Guides will be available to help the regulated community navigate through the

e-CDRweb tool in order to comply with the requirements of the CDR rule.

Will this change impact the annual ICR burden estimate?

No. The current ICR annual burden will not change. The estimated burden for 2016 CDR reporting was presented in the ICR renewal that was approved by OMB on October 14, 2015 (ICR Ref. No. 201501-2070-002).

What is the expected non-paperwork impact of this change?

None. The Form U plus the corresponding Instructions for Reporting and e-CDRweb User Guides were available for the 2012 submission period. This change is to update the data collection form and relevant guidance that is intended to help submitters complete the submission as required in the CDR rule and approved already by OMB.

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