Justification for Nonsubstantive Change

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). 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) 2019 rather than RY 2018 (i.e., changing all references to the reporting year from RY 2018 to RY 2019 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. Additionally, there are minor formatting and language updates to the instructions to improve readability and clarity. To streamline the reporting guidance, EPA has also removed six of the seven appendices (Appendix A: Federal Facility Reporting Information;

Appendix B: Reporting Codes for EPA Form R and Instructions for Reporting Metals; Appendix C: Supplier Notification Requirements; Appendix D: TRI State, Tribal, and Regional Contacts;

Appendix E Guidance Documents; and Appendix F: Questions and Answers Regarding Facility Identification Information), retaining Appendix G: Trade Secret Submission (though, relabeling this appendix as Appendix A). EPA will continue to provide Appendix A:Trade Secret Submissions; Appendix B: Reporting Codes for EPA Form R and Instructions for Reporting Metals; and, Appendix C: Supplier Notification Requirements as separate standalone guidance documents. These separate documents are included in this change request package.

Will this change impact the annual ICR burden estimate?

No. The current ICR annual burden will not change.

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