Justification for Nonsubstantive Change

1363j27.docx

Toxic Chemical Release Reporting (Change)

Justification for Nonsubstantive Change

OMB: 2025-0009

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Request for a Non-Substantive Change

to an Existing Approved Information Collection

(EPA ICR No. 1363.27; OMB Control No. 2025-0009)


I. Introduction


Why is EPA Requesting a Non-Substantive Change?

EPA is requesting a non-substantive change in order to update the instructions for EPA Forms 9350-1, 9350-2, and 9350-3 (Form R, Form A Certification Statement, and Form R Schedule 1). Additionally, EPA is repackaging five existing Q&A sources into a consolidated guidance document. EPA is not otherwise modifying the information collection requirements or agency paperwork burden estimates.


II. Description of Non-Substantive Changes


What Information Collection Request (ICR) is EPA changing?


ICR Title:

Toxic Chemical Release Reporting

ICR Numbers:

EPA ICR No. 1363.27; OMB Control No. 2025-0009


What is the current status of this ICR?

This ICR is currently approved through October 31, 2021.


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

EPA is revising the instructions to refer to Reporting Year (RY) 2018 rather than RY 2017 (i.e., changing all references to the reporting year from RY 2017 to RY 2018 and revising the what’s new information). EPA is also revising descriptive text of TRI-MEweb, the software used to prepare and submit EPA forms 9350-1, 9350-2, and 9350-3, to align with the most current version of the software. There are minor formatting and language updates to the instructions to improve readability and clarity.


EPA currently provides five Q&A documents to regulated entities (1998 EPCRA 313 Q&As, 1998 Newly Added Industries Q&A, 1999 Federal Addendum Q&A, 2004 Q&A Addendum, Frequent Questions). Some of these Q&As are out of date (e.g., refer to SIC codes rather than NAICS codes). Rather than have facilities refer to multiple Q&A documents, EPA is consolidating the documents into one document, making minor edits to align the Q&As with the current regulatory landscape requirements (e.g., mentioning North American Industry Classification System (NAICS) codes given that TRI transitioned from using Standard Industrial Classification (SIC) codes to NAICS codes in 2006). There are no substantive changes being made; this is a housekeeping effort to simplify the guidance universe via consolidation and minor maintenance.


Will this change impact the annual ICR burden estimate?

No. The current ICR annual burden will not change.

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File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleRequest for a Non-Substantive Change to an Existing Approved Information Collection
AuthorPeter Smith
File Modified0000-00-00
File Created2021-01-14

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