Attachment E

Date:

26 December 2017

From:

Pamela Moseley/DC/USEPA/US

To:

Eric Brewer
Artic Slope Mission Services, LLC
Email: brewer.eric@epa.gov
Subject: Request for Assistance; Request for Contractor Access to TSCA CBI
ICR

On December 19, 2017, EPA published a Notice in the Federal Register (82 FR 60194) titled
“Agency Information Collection Activities; Proposed Renewal of an Existing Collection (EPA
ICR No. 1250-11) Comment Request.” (See
https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0318). This Notice refers to
EPA's intention to request renewed Office of Management and Budget (OMB) clearance of an
information collection related to reporting and recordkeeping requirements for companies under
contract to the Environmental Protection Agency to provide certain services, whose employees
must have access to Toxic Substances Control Act (TSCA) confidential business information to
perform their duties.
In addition to public notice and comment requirement that the above Notice initiates, OMB
regulations at 5 CFR 1320.8(d)(1)) require agencies to consult with potential respondents and
data users about specific aspects of an information collection request (ICR) before submitting it
to OMB for review and approval, regardless, in the case of ICR renewals, of whether changes
have or have not been made to the collection activity.
As part of this required consultation, I am contacting you to solicit your input. Please note that if
you take this opportunity to provide input, your name, affiliation, e-mail address, phone number
and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the
ICR supporting statement, which will be a public document. In addition, the OMB Desk
Examiner for the ICR in question may contact you to verify the accuracy of any comments EPA
identifies in the ICR.
EPA solicits your input on the following questions:
Are the data that EPA seeks under this ICR available from any public source, or already
collected by another EPA office or by another agency? If so, where can the data be found?
Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?
Would you be interested in an electronic/data submission option? What type of alternative
would you be most likely to utilize – web form, diskette, CD-ROM?

For electronic submission, how should signature requirements be handled – Private Key
Infrastructure, PINS and passwords, signed paper cover sheet?
How does TSCA CBI affect your choice or use of an electronic medium? Would you be more
inclined to submit TSCA CBI on diskette than on paper and what benefits would you realize
(e.g., burden reduction, greater efficiency in compiling information, etc).
Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs
associated with paperwork)? Are the Bureau of Labor Statistics (BLS) labor rates accurate? If
you have any reason to consider the BLS labor rates as used by EPA inaccurate or inappropriate,
explain your rationale.
To access the Federal Register Notice, the ICR supporting document, and any public comments
received to date, go to:
o www.regulations.gov/
o enter EPA-HQ-OPPT-2017-0318 in the Enter Keyword or ID field
o click on "Search"
o then click on any of the documents listed within the docket to read the document; you will be
most interested in the Supporting Statement, identified by its title beginning "Information
Collection Request…"
Your response will be greatly appreciated. If you have any comments in response to the above
questions, or with respect to any other part of the information collection, please respond by
return e-mail by January 26, 2018. EPA will consider those responses, as well as any public
comment received in response to the Federal Register Notice identified above, in preparing a
final document for OMB review.
Thank you for your assistance.
Sincerely yours,
Pamela Moseley
Environmental Protection Specialist
Information Management Division/Office of Pollution Prevention and Toxics/Office of
Prevention, Pesticides and Toxic Substances Environmental Protection Agency
Washington, DC 20460
202-564-8956

Date:

26 Decemer 2017

From:

Pamela Moseley/DC/USEPA/US

To:

Alice Tome
Abt Associates Inc.
Email: alice_tome@abtassoc.com
Subject: Request for Assistance; Request for Contractor Access to TSCA CBI
ICR

On December 19, 2017, EPA published a Notice in the Federal Register (82 FR 60194)
titled “Agency Information Collection Activities; Proposed Renewal of an Existing Collection
(EPA ICR No. 1250-11) Comment Request.” (See
https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0318). This Notice refers to
EPA's intention to request renewed Office of Management and Budget (OMB) clearance of an
information collection related to reporting and recordkeeping requirements for companies under
contract to the Environmental Protection Agency to provide certain services, whose employees
must have access to Toxic Substances Control Act (TSCA) confidential business information to
perform their duties.
In addition to public notice and comment requirement that the above Notice initiates, OMB
regulations at 5 CFR 1320.8(d)(1)) require agencies to consult with potential respondents and
data users about specific aspects of an information collection request (ICR) before submitting it
to OMB for review and approval, regardless, in the case of ICR renewals, of whether changes
have or have not been made to the collection activity.
As part of this required consultation, I am contacting you to solicit your input. Please note that if
you take this opportunity to provide input, your name, affiliation, e-mail address, phone number
and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the
ICR supporting statement, which will be a public document. In addition, the OMB Desk
Examiner for the ICR in question may contact you to verify the accuracy of any comments EPA
identifies in the ICR.
EPA solicits your input on the following questions:
Are the data that EPA seeks under this ICR available from any public source, or already
collected by another EPA office or by another agency? If so, where can the data be found?
Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?
Would you be interested in an electronic/data submission option? What type of alternative
would you be most likely to utilize – web form, diskette, CD-ROM?

For electronic submission, how should signature requirements be handled – Private Key
Infrastructure, PINS and passwords, signed paper cover sheet?
How does TSCA CBI affect your choice or use of an electronic medium? Would you be more
inclined to submit TSCA CBI on diskette than on paper and what benefits would you realize
(e.g., burden reduction, greater efficiency in compiling information, etc).
Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs
associated with paperwork)? Are the Bureau of Labor Statistics (BLS) labor rates accurate? If
you have any reason to consider the BLS labor rates as used by EPA inaccurate or inappropriate,
explain your rationale.
To access the Federal Register Notice, the ICR supporting document, and any public comments
received to date, go to:
o www.regulations.gov/
o enter EPA-HQ-OPPT-2017-0318 in the Enter Keyword or ID field
o click on "Search"
o then click on any of the documents listed within the docket to read the document; you will be
most interested in the Supporting Statement, identified by its title beginning "Information
Collection Request…"
Your response will be greatly appreciated. If you have any comments in response to the above
questions, or with respect to any other part of the information collection, please respond by
return e-mail by January 26, 2018. EPA will consider those responses, as well as any public
comment received in response to the Federal Register Notice identified above, in preparing a
final document for OMB review.
Thank you for your assistance.
Sincerely yours,
Pamela Moseley
Environmental Protection Specialist
Information Management Division/Office of Pollution Prevention and Toxics/Office of
Prevention, Pesticides and Toxic Substances Environmental Protection Agency
Washington, DC 20460
202-564-8956

Date:

26 December 2017

From:

Pamela Moseley/DC/USEPA/US

To:

Caroline Tuckhorn
Avanti Corporation
Email: Tuckhorn.Caroline@epa.gov
Subject: Request for Assistance; Request for Contractor Access to TSCA CBI
ICR

On December 19, 2017, EPA published a Notice in the Federal Register (82 FR 60194)
titled “Agency Information Collection Activities; Proposed Renewal of an Existing Collection
(EPA ICR No. 1250-11) Comment Request.” (See
https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0318). This Notice refers to
EPA's intention to request renewed Office of Management and Budget (OMB) clearance of an
information collection related to reporting and recordkeeping requirements for companies under
contract to the Environmental Protection Agency to provide certain services, whose employees
must have access to Toxic Substances Control Act (TSCA) confidential business information to
perform their duties.
In addition to public notice and comment requirement that the above Notice initiates, OMB
regulations at 5 CFR 1320.8(d)(1)) require agencies to consult with potential respondents and
data users about specific aspects of an information collection request (ICR) before submitting it
to OMB for review and approval, regardless, in the case of ICR renewals, of whether changes
have or have not been made to the collection activity.
As part of this required consultation, I am contacting you to solicit your input. Please note that if
you take this opportunity to provide input, your name, affiliation, e-mail address, phone number
and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the
ICR supporting statement, which will be a public document. In addition, the OMB Desk
Examiner for the ICR in question may contact you to verify the accuracy of any comments EPA
identifies in the ICR.
EPA solicits your input on the following questions:
Are the data that EPA seeks under this ICR available from any public source, or already
collected by another EPA office or by another agency? If so, where can the data be found?
Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?
Would you be interested in an electronic/data submission option? What type of alternative
would you be most likely to utilize – web form, diskette, CD-ROM?

For electronic submission, how should signature requirements be handled – Private Key
Infrastructure, PINS and passwords, signed paper cover sheet?
How does TSCA CBI affect your choice or use of an electronic medium? Would you be more
inclined to submit TSCA CBI on diskette than on paper and what benefits would you realize
(e.g., burden reduction, greater efficiency in compiling information, etc).
Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs
associated with paperwork)? Are the Bureau of Labor Statistics (BLS) labor rates accurate? If
you have any reason to consider the BLS labor rates as used by EPA inaccurate or inappropriate,
explain your rationale.
To access the Federal Register Notice, the ICR supporting document, and any public comments
received to date, go to:
o www.regulations.gov/
o enter EPA-HQ-OPPT-2017-0318 in the Enter Keyword or ID field
o click on "Search"
o then click on any of the documents listed within the docket to read the document; you will be
most interested in the Supporting Statement, identified by its title beginning "Information
Collection Request…"
Your response will be greatly appreciated. If you have any comments in response to the above
questions, or with respect to any other part of the information collection, please respond by
return e-mail by January 26, 2018. EPA will consider those responses, as well as any public
comment received in response to the Federal Register Notice identified above, in preparing a
final document for OMB review.
Thank you for your assistance.
Sincerely yours,
Pamela Moseley
Environmental Protection Specialist
Information Management Division/Office of Pollution Prevention and Toxics/Office of
Prevention, Pesticides and Toxic Substances Environmental Protection Agency
Washington, DC 20460
202-564-8956

Date:

26 December 2017

From:

Pamela Moseley/DC/USEPA/US

To:

Vincent J. Brown
Battelle Memorial Institute
Email: brownv@battelle.org
Subject: Request for Assistance; Request for Contractor Access to TSCA CBI
ICR

On December 19, 2017, EPA published a Notice in the Federal Register (82 FR 60194)
titled “Agency Information Collection Activities; Proposed Renewal of an Existing Collection
(EPA ICR No. 1250-11) Comment Request.” (See
https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0318). This Notice refers to
EPA's intention to request renewed Office of Management and Budget (OMB) clearance of an
information collection related to reporting and recordkeeping requirements for companies under
contract to the Environmental Protection Agency to provide certain services, whose employees
must have access to Toxic Substances Control Act (TSCA) confidential business information to
perform their duties.
In addition to public notice and comment requirement that the above Notice initiates, OMB
regulations at 5 CFR 1320.8(d)(1)) require agencies to consult with potential respondents and
data users about specific aspects of an information collection request (ICR) before submitting it
to OMB for review and approval, regardless, in the case of ICR renewals, of whether changes
have or have not been made to the collection activity.
As part of this required consultation, I am contacting you to solicit your input. Please note that if
you take this opportunity to provide input, your name, affiliation, e-mail address, phone number
and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the
ICR supporting statement, which will be a public document. In addition, the OMB Desk
Examiner for the ICR in question may contact you to verify the accuracy of any comments EPA
identifies in the ICR.
EPA solicits your input on the following questions:
Are the data that EPA seeks under this ICR available from any public source, or already
collected by another EPA office or by another agency? If so, where can the data be found?
Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?
Would you be interested in an electronic/data submission option? What type of alternative
would you be most likely to utilize – web form, diskette, CD-ROM?

For electronic submission, how should signature requirements be handled – Private Key
Infrastructure, PINS and passwords, signed paper cover sheet?
How does TSCA CBI affect your choice or use of an electronic medium? Would you be more
inclined to submit TSCA CBI on diskette than on paper and what benefits would you realize
(e.g., burden reduction, greater efficiency in compiling information, etc).
Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs
associated with paperwork)? Are the Bureau of Labor Statistics (BLS) labor rates accurate? If
you have any reason to consider the BLS labor rates as used by EPA inaccurate or inappropriate,
explain your rationale.
To access the Federal Register Notice, the ICR supporting document, and any public comments
received to date, go to:
o www.regulations.gov/
o enter EPA-HQ-OPPT-2017-0318 in the Enter Keyword or ID field
o click on "Search"
o then click on any of the documents listed within the docket to read the document; you will be
most interested in the Supporting Statement, identified by its title beginning "Information
Collection Request…"
Your response will be greatly appreciated. If you have any comments in response to the above
questions, or with respect to any other part of the information collection, please respond by
return e-mail by January 26, 2018. EPA will consider those responses, as well as any public
comment received in response to the Federal Register Notice identified above, in preparing a
final document for OMB review.
Thank you for your assistance.
Sincerely yours,
Pamela Moseley
Environmental Protection Specialist
Information Management Division/Office of Pollution Prevention and Toxics/Office of
Prevention, Pesticides and Toxic Substances Environmental Protection Agency
Washington, DC 20460
202-564-8956

Date:

26 December 2017

From:

Pamela Moseley/DC/USEPA/US

To:

Brian Gabel
Chemical Abstracts Service
Email: bgabel@cas.org
Subject: Request for Assistance; Request for Contractor Access to TSCA CBI
ICR

On December 19, 2017, EPA published a Notice in the Federal Register (82 FR 60194)
titled “Agency Information Collection Activities; Proposed Renewal of an Existing Collection
(EPA ICR No. 1250-11) Comment Request.” (See
https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0318). This Notice refers to
EPA's intention to request renewed Office of Management and Budget (OMB) clearance of an
information collection related to reporting and recordkeeping requirements for companies under
contract to the Environmental Protection Agency to provide certain services, whose employees
must have access to Toxic Substances Control Act (TSCA) confidential business information to
perform their duties.
In addition to public notice and comment requirement that the above Notice initiates, OMB
regulations at 5 CFR 1320.8(d)(1)) require agencies to consult with potential respondents and
data users about specific aspects of an information collection request (ICR) before submitting it
to OMB for review and approval, regardless, in the case of ICR renewals, of whether changes
have or have not been made to the collection activity.
As part of this required consultation, I am contacting you to solicit your input. Please note that if
you take this opportunity to provide input, your name, affiliation, e-mail address, phone number
and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the
ICR supporting statement, which will be a public document. In addition, the OMB Desk
Examiner for the ICR in question may contact you to verify the accuracy of any comments EPA
identifies in the ICR.
EPA solicits your input on the following questions:
Are the data that EPA seeks under this ICR available from any public source, or already
collected by another EPA office or by another agency? If so, where can the data be found?
Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?
Would you be interested in an electronic/data submission option? What type of alternative
would you be most likely to utilize – web form, diskette, CD-ROM?

For electronic submission, how should signature requirements be handled – Private Key
Infrastructure, PINS and passwords, signed paper cover sheet?
How does TSCA CBI affect your choice or use of an electronic medium? Would you be more
inclined to submit TSCA CBI on diskette than on paper and what benefits would you realize
(e.g., burden reduction, greater efficiency in compiling information, etc).
Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs
associated with paperwork)? Are the Bureau of Labor Statistics (BLS) labor rates accurate? If
you have any reason to consider the BLS labor rates as used by EPA inaccurate or inappropriate,
explain your rationale.
To access the Federal Register Notice, the ICR supporting document, and any public comments
received to date, go to:
o www.regulations.gov/
o enter EPA-HQ-OPPT-2017-0318 in the Enter Keyword or ID field
o click on "Search"
o then click on any of the documents listed within the docket to read the document; you will be
most interested in the Supporting Statement, identified by its title beginning "Information
Collection Request…"
Your response will be greatly appreciated. If you have any comments in response to the above
questions, or with respect to any other part of the information collection, please respond by
return e-mail by January 26, 2018. EPA will consider those responses, as well as any public
comment received in response to the Federal Register Notice identified above, in preparing a
final document for OMB review.
Thank you for your assistance.
Sincerely yours,
Pamela Moseley
Environmental Protection Specialist
Information Management Division/Office of Pollution Prevention and Toxics/Office of
Prevention, Pesticides and Toxic Substances Environmental Protection Agency
Washington, DC 20460
202-564-8956

Date:

26 December 2017

From:

Pamela Moseley/DC/USEPA/US

To:

Lewis Jeff Cantin
Eastern Research Group
Email: jeff.cantin@erg.com
Subject: Request for Assistance; Request for Contractor Access to TSCA CBI
ICR

On December 19, 2017, EPA published a Notice in the Federal Register (82 FR 60194)
titled “Agency Information Collection Activities; Proposed Renewal of an Existing Collection
(EPA ICR No. 1250-11) Comment Request.” (See
https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0318). This Notice refers to
EPA's intention to request renewed Office of Management and Budget (OMB) clearance of an
information collection related to reporting and recordkeeping requirements for companies under
contract to the Environmental Protection Agency to provide certain services, whose employees
must have access to Toxic Substances Control Act (TSCA) confidential business information to
perform their duties.
In addition to public notice and comment requirement that the above Notice initiates, OMB
regulations at 5 CFR 1320.8(d)(1)) require agencies to consult with potential respondents and
data users about specific aspects of an information collection request (ICR) before submitting it
to OMB for review and approval, regardless, in the case of ICR renewals, of whether changes
have or have not been made to the collection activity.
As part of this required consultation, I am contacting you to solicit your input. Please note that if
you take this opportunity to provide input, your name, affiliation, e-mail address, phone number
and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the
ICR supporting statement, which will be a public document. In addition, the OMB Desk
Examiner for the ICR in question may contact you to verify the accuracy of any comments EPA
identifies in the ICR.
EPA solicits your input on the following questions:
Are the data that EPA seeks under this ICR available from any public source, or already
collected by another EPA office or by another agency? If so, where can the data be found?
Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?
Would you be interested in an electronic/data submission option? What type of alternative
would you be most likely to utilize – web form, diskette, CD-ROM?

For electronic submission, how should signature requirements be handled – Private Key
Infrastructure, PINS and passwords, signed paper cover sheet?
How does TSCA CBI affect your choice or use of an electronic medium? Would you be more
inclined to submit TSCA CBI on diskette than on paper and what benefits would you realize
(e.g., burden reduction, greater efficiency in compiling information, etc).
Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs
associated with paperwork)? Are the Bureau of Labor Statistics (BLS) labor rates accurate? If
you have any reason to consider the BLS labor rates as used by EPA inaccurate or inappropriate,
explain your rationale.
To access the Federal Register Notice, the ICR supporting document, and any public comments
received to date, go to:
o www.regulations.gov/
o enter EPA-HQ-OPPT-2017-0318 in the Enter Keyword or ID field
o click on "Search"
o then click on any of the documents listed within the docket to read the document; you will be
most interested in the Supporting Statement, identified by its title beginning "Information
Collection Request…"
Your response will be greatly appreciated. If you have any comments in response to the above
questions, or with respect to any other part of the information collection, please respond by
return e-mail by January 26, 2018. EPA will consider those responses, as well as any public
comment received in response to the Federal Register Notice identified above, in preparing a
final document for OMB review.
Thank you for your assistance.
Sincerely yours,
Pamela Moseley
Environmental Protection Specialist
Information Management Division/Office of Pollution Prevention and Toxics/Office of
Prevention, Pesticides and Toxic Substances Environmental Protection Agency
Washington, DC 20460
202-564-8956

Date:

26 December 2017

From:

Pamela Moseley/DC/USEPA/US

To:

Carol Place
Industrial Economics Inc.
Email: CPlace@indecon.com
Subject: Request for Assistance; Request for Contractor Access to TSCA CBI
ICR

On December 19, 2017, EPA published a Notice in the Federal Register (82 FR 60194)
titled “Agency Information Collection Activities; Proposed Renewal of an Existing Collection
(EPA ICR No. 1250-11) Comment Request.” (See
https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0318). This Notice refers to
EPA's intention to request renewed Office of Management and Budget (OMB) clearance of an
information collection related to reporting and recordkeeping requirements for companies under
contract to the Environmental Protection Agency to provide certain services, whose employees
must have access to Toxic Substances Control Act (TSCA) confidential business information to
perform their duties.
In addition to public notice and comment requirement that the above Notice initiates, OMB
regulations at 5 CFR 1320.8(d)(1)) require agencies to consult with potential respondents and
data users about specific aspects of an information collection request (ICR) before submitting it
to OMB for review and approval, regardless, in the case of ICR renewals, of whether changes
have or have not been made to the collection activity.
As part of this required consultation, I am contacting you to solicit your input. Please note that if
you take this opportunity to provide input, your name, affiliation, e-mail address, phone number
and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the
ICR supporting statement, which will be a public document. In addition, the OMB Desk
Examiner for the ICR in question may contact you to verify the accuracy of any comments EPA
identifies in the ICR.
EPA solicits your input on the following questions:
Are the data that EPA seeks under this ICR available from any public source, or already
collected by another EPA office or by another agency? If so, where can the data be found?
Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?
Would you be interested in an electronic/data submission option? What type of alternative
would you be most likely to utilize – web form, diskette, CD-ROM?

For electronic submission, how should signature requirements be handled – Private Key
Infrastructure, PINS and passwords, signed paper cover sheet?
How does TSCA CBI affect your choice or use of an electronic medium? Would you be more
inclined to submit TSCA CBI on diskette than on paper and what benefits would you realize
(e.g., burden reduction, greater efficiency in compiling information, etc).
Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs
associated with paperwork)? Are the Bureau of Labor Statistics (BLS) labor rates accurate? If
you have any reason to consider the BLS labor rates as used by EPA inaccurate or inappropriate,
explain your rationale.
To access the Federal Register Notice, the ICR supporting document, and any public comments
received to date, go to:
o www.regulations.gov/
o enter EPA-HQ-OPPT-2017-0318 in the Enter Keyword or ID field
o click on "Search"
o then click on any of the documents listed within the docket to read the document; you will be
most interested in the Supporting Statement, identified by its title beginning "Information
Collection Request…"
Your response will be greatly appreciated. If you have any comments in response to the above
questions, or with respect to any other part of the information collection, please respond by
return e-mail by January 26, 2018. EPA will consider those responses, as well as any public
comment received in response to the Federal Register Notice identified above, in preparing a
final document for OMB review.
Thank you for your assistance.
Sincerely yours,
Pamela Moseley
Environmental Protection Specialist
Information Management Division/Office of Pollution Prevention and Toxics/Office of
Prevention, Pesticides and Toxic Substances Environmental Protection Agency
Washington, DC 20460
202-564-8956

Date:

26 December 2017

From:

Pamela Moseley/DC/USEPA/US

To:

Laura Morlacci
Syracuse Research Corporation
Email: lmorlacci@srcinc.com
Subject: Request for Assistance; Request for Contractor Access to TSCA CBI
ICR

On December 19, 2017, EPA published a Notice in the Federal Register (82 FR 60194)
titled “Agency Information Collection Activities; Proposed Renewal of an Existing Collection
(EPA ICR No. 1250-11) Comment Request.” (See
https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0318). This Notice refers to
EPA's intention to request renewed Office of Management and Budget (OMB) clearance of an
information collection related to reporting and recordkeeping requirements for companies under
contract to the Environmental Protection Agency to provide certain services, whose employees
must have access to Toxic Substances Control Act (TSCA) confidential business information to
perform their duties.
In addition to public notice and comment requirement that the above Notice initiates, OMB
regulations at 5 CFR 1320.8(d)(1)) require agencies to consult with potential respondents and
data users about specific aspects of an information collection request (ICR) before submitting it
to OMB for review and approval, regardless, in the case of ICR renewals, of whether changes
have or have not been made to the collection activity.
As part of this required consultation, I am contacting you to solicit your input. Please note that if
you take this opportunity to provide input, your name, affiliation, e-mail address, phone number
and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the
ICR supporting statement, which will be a public document. In addition, the OMB Desk
Examiner for the ICR in question may contact you to verify the accuracy of any comments EPA
identifies in the ICR.
EPA solicits your input on the following questions:
Are the data that EPA seeks under this ICR available from any public source, or already
collected by another EPA office or by another agency? If so, where can the data be found?
Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?
Would you be interested in an electronic/data submission option? What type of alternative
would you be most likely to utilize – web form, diskette, CD-ROM?

For electronic submission, how should signature requirements be handled – Private Key
Infrastructure, PINS and passwords, signed paper cover sheet?
How does TSCA CBI affect your choice or use of an electronic medium? Would you be more
inclined to submit TSCA CBI on diskette than on paper and what benefits would you realize
(e.g., burden reduction, greater efficiency in compiling information, etc).
Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs
associated with paperwork)? Are the Bureau of Labor Statistics (BLS) labor rates accurate? If
you have any reason to consider the BLS labor rates as used by EPA inaccurate or inappropriate,
explain your rationale.
To access the Federal Register Notice, the ICR supporting document, and any public comments
received to date, go to:
o www.regulations.gov/
o enter EPA-HQ-OPPT-2017-0318 in the Enter Keyword or ID field
o click on "Search"
o then click on any of the documents listed within the docket to read the document; you will be
most interested in the Supporting Statement, identified by its title beginning "Information
Collection Request…"
Your response will be greatly appreciated. If you have any comments in response to the above
questions, or with respect to any other part of the information collection, please respond by
return e-mail by January 26, 2018. EPA will consider those responses, as well as any public
comment received in response to the Federal Register Notice identified above, in preparing a
final document for OMB review.
Thank you for your assistance.
Sincerely yours,
Pamela Moseley
Environmental Protection Specialist
Information Management Division/Office of Pollution Prevention and Toxics/Office of
Prevention, Pesticides and Toxic Substances Environmental Protection Agency
Washington, DC 20460
202-564-8956

Date:

26 December 2017

From:

Pamela Moseley/DC/USEPA/US

To:

Elizabeth Nguyen
Versar Incorporated
Email: enguyen@versar.com
Subject: Request for Assistance; Request for Contractor Access to TSCA CBI
ICR

On December 19, 2017, EPA published a Notice in the Federal Register (82 FR 60194)
titled “Agency Information Collection Activities; Proposed Renewal of an Existing Collection
(EPA ICR No. 1250-11) Comment Request.” (See
https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0318). This Notice refers to
EPA's intention to request renewed Office of Management and Budget (OMB) clearance of an
information collection related to reporting and recordkeeping requirements for companies under
contract to the Environmental Protection Agency to provide certain services, whose employees
must have access to Toxic Substances Control Act (TSCA) confidential business information to
perform their duties.
In addition to public notice and comment requirement that the above Notice initiates, OMB
regulations at 5 CFR 1320.8(d)(1)) require agencies to consult with potential respondents and
data users about specific aspects of an information collection request (ICR) before submitting it
to OMB for review and approval, regardless, in the case of ICR renewals, of whether changes
have or have not been made to the collection activity.
As part of this required consultation, I am contacting you to solicit your input. Please note that if
you take this opportunity to provide input, your name, affiliation, e-mail address, phone number
and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the
ICR supporting statement, which will be a public document. In addition, the OMB Desk
Examiner for the ICR in question may contact you to verify the accuracy of any comments EPA
identifies in the ICR.
EPA solicits your input on the following questions:
Are the data that EPA seeks under this ICR available from any public source, or already
collected by another EPA office or by another agency? If so, where can the data be found?
Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?
Would you be interested in an electronic/data submission option? What type of alternative
would you be most likely to utilize – web form, diskette, CD-ROM?

For electronic submission, how should signature requirements be handled – Private Key
Infrastructure, PINS and passwords, signed paper cover sheet?
How does TSCA CBI affect your choice or use of an electronic medium? Would you be more
inclined to submit TSCA CBI on diskette than on paper and what benefits would you realize
(e.g., burden reduction, greater efficiency in compiling information, etc).
Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs
associated with paperwork)? Are the Bureau of Labor Statistics (BLS) labor rates accurate? If
you have any reason to consider the BLS labor rates as used by EPA inaccurate or inappropriate,
explain your rationale.
To access the Federal Register Notice, the ICR supporting document, and any public comments
received to date, go to:
o www.regulations.gov/
o enter EPA-HQ-OPPT-2017-0318 in the Enter Keyword or ID field
o click on "Search"
o then click on any of the documents listed within the docket to read the document; you will be
most interested in the Supporting Statement, identified by its title beginning "Information
Collection Request…"
Your response will be greatly appreciated. If you have any comments in response to the above
questions, or with respect to any other part of the information collection, please respond by
return e-mail by January 26, 2018. EPA will consider those responses, as well as any public
comment received in response to the Federal Register Notice identified above, in preparing a
final document for OMB review.
Thank you for your assistance.
Sincerely yours,
Pamela Moseley
Environmental Protection Specialist
Information Management Division/Office of Pollution Prevention and Toxics/Office of
Prevention, Pesticides and Toxic Substances Environmental Protection Agency
Washington, DC 20460
202-564-8956