Attachment O- Stakeholder Feedback

OMB Control No. 2070-0221

Expiration Date 5/31/2025

ATTACHMENT O

Request for Stakeholder Feedback –Consultation??

As required under 5 CFR 1320.8(d)(1), EPA staff contacted appropriate stakeholders and asked them for their assessment of the regulatory burden estimates expressed by the Agency in this ICR.

EPA sent the following correspondences to stakeholders requesting their feedback. EPA provided the ICR Consultation Questions (on page 3 and 4 of this attachment) and the ICR supporting statement as attachments in the second email.

First correspondence to stakeholders requesting their feedback:

From:

To:

Cc:

Subject: Help with the Safer Choice ICR

Date:

Dear ,

We have a favor to ask. We are writing to request your feedback on materials that describe how much time companies spend working with our program in terms of information collection activities.

The Paperwork Reduction Act (PRA) requires us to issue an Information Collection Request (ICR) through a public notice and comment process. On Wednesday, May 8^th, we will publish and solicit comment through a Federal Register Notice (FRN) explaining our work to renew the Safer Choice ICR under the PRA. The PRA also requires that we conduct consultations representing the views of those who work with the program. We are hoping that you could help us with the ICR consultation process by providing feedback.

Your responses could be quite brief if you agree that our estimates reflect a reasonable estimate of the time partners take in working with our program. Your response could be in writing via email, or we are happy to hop on a call with you.

Once the FRN is posted, we will send a more detailed ask with links and questions. We would appreciate your feedback by June 24^th. I will be out of town May 10 – May 22. In the meantime, if you have questions or would like to schedule a call, (cc’d) will respond to your email in my absence.

My thought is that a quick call with could

minimize the work involved.

Thanks very much,

Second correspondence to stakeholders requesting their feedback:

From:

To:

Cc:

Subject: RE: Help with the Safer Choice ICR

Date:

Attachments: ICR Consultation Questions.docx

Supporting Statement.docx image001.png

Hi ,

We are sending some information over to you on the Safer Choice Information Collection Request (ICR) renewal prior to our meeting next week. We can discuss this material in more detail then.

The notice announcing the ICR renewal and solicitation of comments was published in the Federal Register on May 8, 2024 (89 FR 38895). The Office of Management and Budget (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.

As a potential respondent, we would value your feedback on the questions in the attached document titled “ICR Consultation Questions.” We have attached a copy of the ICR supporting statement and all of the attachments can be found on docket EPA-HQ-OPPT-2021-0245.

If you have any comments in response to the ICR consultation questions or with respect to any other part of this ICR, please respond by June 24^th. 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.

We look forward to our call on Tuesday, and we greatly appreciate your time and participation!

Kindest

ICR consultation questions attached to the second email:

(1) Publicly Available Data

1. Is the data that the Agency seeks available from any public source, or already collected by another office at EPA or by another agency?

2. If yes, where can you find the data?
   (Does your answer indicate a true duplication, or does the input indicate that certain data elements are available, but that they do not meet our data needs very well?)

(2) Clarity of Instructions

1. The ICR is intended to require that respondents provide certain data so that the Agency can utilize them.

2. Based on the instructions (regulations, PR Notices, etc.), is it clear what you are required to do, and how to submit such data? If not, what suggestions do you have to clarify the instructions?

3. Do you understand that you are required to maintain records?

4. Considering that there is no required submission format, is it difficult to submit information in ways that are clear, logical, and easy to complete?

5. Are there forms associated with this process? Do you use them? Are they clear, logical, and easy to complete?

(3) Electronic Reporting and Record keeping

The Government Paperwork Elimination Act requires agencies make available to the public electronic reporting alternatives to paper-based submissions by 2003, unless there is a strong reason for not doing so. One such reason is that, at the present time, the Agency is unable to ensure the security of CBI that might be transmitted over the Internet.

1. What do you think about electronic alternatives to paper-based records and data submissions? Would you be interested in pursuing keeping records electronically?

2. Are you keeping your records electronically? If yes, in what format?

(4) Burden and Costs

1. Are the labor rates accurate?

2. The Agency assumes there is no capital cost associated with this activity. Is that correct?

3. Bearing in mind that the burden and cost estimates include only burden hours and costs associated with the paperwork involved with this ICR (e.g., the ICR does not include estimated burden hours and costs for conducting studies) are the estimated burden hours and labor rates accurate? If you provide burden and cost estimates that are substantially different from EPA’s, please provide an explanation of how you arrived at your estimates.

4. Are there other costs that should be accounted for that may have been missed?

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