Justification for Industry Beta-Testing of Chemical Data Reporting (CDR) Electronic Reporting Tool

Request for Approval under the “Generic Clearance for the Collection of Routine Customer Feedback” (OMB Control Number: 2010-0042)

TITLE OF INFORMATION COLLECTION: Industry Beta-Testing of Chemical Data Reporting (CDR) Electronic Reporting Tool

PURPOSE:

Under the Toxic Substances Control Act (TSCA), EPA collects manufacturing, processing, and use information from chemical manufacturers through the Chemical Data Reporting (CDR) rule. CDR submissions must be made electronically using the web-based reporting tool, called e-CDRweb, and submitted through EPA’s electronic data submission portal, Central Data Exchange (CDX). The next CDR submission period starts June 1, 2020. EPA has updated the e-CDRweb reporting tool to improve usability and incorporate changes for data reporting based on feedback from past CDR submission periods and a forthcoming regulation finalizing several regulatory updates (“TSCA Chemical Data Reporting Revisions”).

Ahead of the start of the upcoming submission period on June 1, 2020, EPA plans to provide the opportunity for 25 industry reporters to beta-test the updated e-CDRweb reporting tool. The focus of the beta-testing is the functionality of the reporting tool and associated processes, in order to ensure it works properly for the upcoming submission period. Comments on the regulatory requirements will not be solicited during the beta-testing period.

EPA is very interested in obtaining feedback on the usability and performance of the e-CDRweb reporting tool. EPA will provide testing participants with dummy accounts within CDX which will enable them to access the testing version of the reporting tool. Participants will be able to submit feedback to EPA throughout the testing period through the test reporting tool and via email (See Attachment A for example instructions). EPA will improve the reporting tool based on the user experience of the beta-testing.

DESCRIPTION OF RESPONDENTS:

The universe of potential respondents is chemical manufacturers, or industry reporters, who are interested in improvements to the reporting tool. In the past, has conducted similar beta-testing prior to the CDR submission and relies on user feedback to enhance the reporting tool. Respondents for beta-testing the e-CDRweb tool ahead of the 2020 submission period will be identified during EPA’s public outreach regarding the revisions to CDR. For example, as described in the preamble to the proposed CDR revisions (84 FR 17692), EPA will host a webinar to describe the revised reporting requirements and introduce the updated e-CDRweb reporting tool. During the webinar, EPA will announce the opportunity for beta-testing eCDR web and provide information on how to express interest. If more than 25 participants express interest, EPA will select 25 representing the range of types of companies that report under CDR. EPA will base this selection on past reporting under CDR by the company. Statistical methods will not be used in this selection.

TYPE OF COLLECTION: (Check one)

[ ] Customer Comment Card/Complaint Form [ ] Customer Satisfaction Survey

[X] Usability Testing (e.g., Website or Software) [ ] Small Discussion Group

[ ] Focus Group [ ] Other: ______________________

CERTIFICATION:

I certify the following to be true:

1. The collection is voluntary.

2. The collection is low-burden for respondents and low-cost for the Federal Government.

3. The collection is non-controversial and does not raise issues of concern to other federal agencies.

4. The results are not intended to be disseminated to the public.

5. Information gathered will not be used for the purpose of substantially informing influential policy decisions.

6. The collection is targeted to the solicitation of opinions from respondents who have experience with the program or may have experience with the program in the future.

Name :_Meredith Viola Comnes__

To assist review, please provide answers to the following question:

Personally Identifiable Information:

1. Is personally identifiable information (PII) collected? [ ] Yes [X] No

2. If Yes, is the information that will be collected included in records that are subject to the Privacy Act of 1974? [ ] Yes [ ] No

3. If Applicable, has a System or Records Notice been published? [ ] Yes [ ] No

Gifts or Payments:

Is an incentive (e.g., money or reimbursement of expenses, token of appreciation) provided to participants? [ ] Yes [ X ] No

BURDEN HOURS

EPA estimates a 10-hour average per participant.

Category of Respondent	No. of Respondents	Participation Time	Burden Hours
Volunteer Private sector reporters to the CDR	25 respondents	10 hours each	250 hours
Totals:	25 respondents	10 hours	250 hours

FEDERAL COST: The estimated one-time cost to the Federal government is 8 hours at $89/hour technical rate = $712

Paperwork Reduction Act Notice: This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. (OMB Control No. 2010-0042). Responses to this collection of information are voluntary. 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 public reporting and recordkeeping burden for this collection of information is estimated to be 10 hours per response. Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden including through the use of automated collection techniques to the Director, Regulatory Support Division, U.S. Environmental Protection Agency (2821T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460.  Include the OMB control number in any correspondence.  Do not send the completed form to this address.

Attachment A:

Draft: Slide for instructions for Beta Testing

Testing Resources:

• How to access CDR on our Test environment

  • Navigate to: https://test.epacdx.net/

  • Enter User ID and Password

  • Select CSPP “Primary Authorized Official” or “Secondary Authorized Official”

  • Select “TSCA Chemical Data Reporting (CDR)”

  • Click “OK”

• Testing Contacts

  • Please contact Chris, with any testing questions or to report bugs/issues.

  • Chris Gorder

    • Phone: 202-564-0170

    • Email: gorder.chris@epa.gov

Issue Classification	Description
Bug	Functionality that is either missing or not working according to design specifications.
Enhancement	Application behavior that the user believes are implied in the design, yet no specification exists.
New Feature	A request for new application functionality.
Improvement	An improvement or change to an existing feature.

Paperwork Reduction Act Notice: This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. (OMB Control No. 2010-0042). Responses to this collection of information are voluntary. 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 public reporting and recordkeeping burden for this collection of information is estimated to be 10 hours per response. Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden including through the use of automated collection techniques to the Director, Regulatory Support Division, U.S. Environmental Protection Agency (2821T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460.  Include the OMB control number in any correspondence.  Do not send the completed form to this address.

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