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Mojica, Andrea
Thursday, August 02, 2018 4:02 PM
'mike_walls@americanchemistry.com'
Passe, Loraine; Mullings, Brandon
TSCA Section 8(d) Health and Safety Data Reporting: Information Collection Request (ICR)
Consultation (EPA ICR No. 0575.16, OMB Control No. 2070-0004)
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Good afternoon:
I am contacting you to solicit your comments on the renewal of the Information Collection Request (ICR) for the
collection of unpublished health and safety studies under the Environmental Protection Agency’s (EPA) TSCA section 8(d)
Health and Safety Data Reporting Rule.
The existing ICR for the TSCA section 8(d) Health and Safety Data Reporting Rule is expiring and needs to be renewed.
Entitled, “Health and Safety Data Reporting, Submission of Lists and Copies of Health and Safety Studies,” it is identified
by Office of Management and Budget (OMB) Control No. 2070‐0004. OMB requires federal agencies to consult with nine
or fewer potential respondents prior to submitting the ICR renewal to OMB for review and approval. This consultation
requirement is in addition to providing the public with 60 days to comment on the proposed collection activity. The
notice announcing the ICR renewal and solicitation of comments was published in the Federal Register on July 25, 2018
(83 FR 35271). See http://www.regulations.gov/, docket ID EPA‐HQ‐OPPT‐2017‐0646.
The Paperwork Reduction Act (PRA) requires that agencies receive OMB clearance before requesting most types of
information from the public. In order to receive OMB clearance, federal agencies prepare draft ICRs providing an
overview of the information collection and estimates of the cost and time for the public to respond. The agencies
consult with potential respondents and the public about the ICR and, where appropriate, incorporate comments
received. The draft ICR is then sent to OMB for its review and approval. These ICRs are periodically renewed.
TSCA section 8(d) authorizes the collection of lists and copies of unpublished health and safety studies. To comply with
the rule, the respondents must search their files to identify any unpublished health and safety studies in their
possession, copy and process the relevant studies, make lists of studies that are currently in progress, and review the
studies for confidential business information. TSCA as amended by the Frank R. Lautenberg Chemical Safety for the 21st
Century Act, did not modify TSCA section 8(d).
EPA solicits your input on the following questions.
1. INFORMATION COLLECTION
(a) Is the information that the Agency seeks under this ICR available from any public source, or already collected
by another office at EPA or by another agency? If yes, where can the Agency find the data?
(b) Is it clear what is required for data submission? If not, are there any suggestions for clarifying instructions?
2. BURDEN COST ANALYSIS
(a) Do you agree with EPA’s estimated burden and costs related to submitting information?
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(b) Are the Bureau of Labor Statistics (BLS) labor rates accurate? If you have any reason to consider the BLS labor
rates inaccurate or inappropriate as used by EPA, please explain your rationale.
Please note that if you take this opportunity to provide input, your name, affiliation, phone number, and any
information that you provide will be incorporated and attached to the ICR supporting statement, which will be a public
document. In addition, you may be contacted by the OMB desk examiner reviewing this ICR renewal to verify the
accuracy of any comments as reported in the ICR by EPA. To comment on this ICR, please respond to this email, or post
comments in the docket at http://www.regulations.gov/, docket ID EPA‐HQ‐OPPT‐2017‐0646.
Your timely response to the questions will be greatly appreciated. We hope to receive your responses by September 24,
2018, so we can consider those responses, along with other consultation responses and public comments resulting from
the Federal Register notice, at the same time as we prepare a final document for OMB review. Thank you for your
assistance.
Sincerely,
Andrea Mojica
Chemical Control Division
Office of Pollution Prevention and Toxics
Office of Chemical Safety and Pollution Prevention
Environmental Protection Agency
(202) 564‐0599
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Mojica, Andrea
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Mojica, Andrea
Wednesday, August 22, 2018 12:02 PM
'Howard, Brett'
RE: EPA-HQ-OPPT-2017-0646-0001
ICR-0575.16.SS.original.docx
Brett,
Thanks for the question. The supporting statements for both ICR renewals describe the methodology for the burden
estimates. Unfortunately, the supporting statement for the current renewal was not posted in the docket. We are
working to correct this issue. In the meantime I have attached the supporting statement.
Here is the link to the previous ICR renewal https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201509‐
2070‐001. Click on the link under Supporting Statement A.
Sorry for any confusion this may have caused. Please let me know if you have additional questions.
Best regards,
Andrea
From: Howard, Brett [mailto:Brett_Howard@americanchemistry.com]
Sent: Tuesday, August 21, 2018 6:09 PM
To: Mojica, Andrea
Subject: EPA‐HQ‐OPPT‐2017‐0646‐0001
Andrea –
I have a question on the EPA docket item listed in the subject. In section III, changes in estimates from the last approval,
there is the following statement:
There is a decrease of 1,303 hours in the total estimated respondent burden compared with that identified in
the ICR currently approved by OMB. This decrease reflects the realization that the methodology used in the
previous ICR overestimated the burden resulting from the addition of chemicals to the TSCA section 8(d)
rule.
I’d like to get information on the former methodology, as well as the new methodlogy so I can look at the math in a bit
more detail. Can you point me in the right direction? Thanks!
Best,
‐Brett
Brett Howard, J.D., Ph.D. | American Chemistry Council
Director, Regulatory and Technical Affairs
brett_howard@americanchemistry.com
700 2nd Street, NE | Washington, DC | 20002
O: (202) 249-6198
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www.americanchemistry.com
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File Type | application/pdf |
Author | aMojica |
File Modified | 2018-10-29 |
File Created | 2018-10-29 |