2613.07 Consultation_Attach4

Sleasman, Katherine
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Wednesday, September 18, 2024 12:44 PM

Response Requested: Consultation on the Information Collection Request (ICR) Renewal for Toxic
Chemical Release Reporting
ICR_Consultation Questions TRI.docx

Hello All:

I am contac ng you to solicit your input on the renewal of the Informa on Collec on Request (ICR) (see a ached
ques ons). The exis ng ICR expires on June 30, 2025, for requirements pursuant to EPCRA sec on 313 tled, “Toxic
Chemical Release Repor ng,” iden fied by OMB Control No. 2070-0212. OMB requires federal agencies to consult
with nine or fewer poten al respondents prior to submi ng the ICR renewal to OMB for review and approval. This
consulta on requirement is in addi on to providing the public with 60 days to comment on the proposed collec on
ac vity. The no ce announcing the ICR renewal and solicita on of comments was published in the Federal Register
on September 18, 2024 (89 FR 76470). See h p://www.regula ons.gov/, docket ID EPA-HQ-OPPT-2020-0078, and
the ICR suppor ng statement for this renewal located in that docket for addi onal informa on.
The Paperwork Reduc on Act (PRA) requires that agencies receive Office of Management and Budget (OMB)
clearance before reques ng most types of informa on from the public. In order to receive OMB clearance, federal
agencies prepare dra ICRs providing an overview of the informa on collec on and es mates of the cost and me
for the public to respond. The agencies consult with poten al respondents and the public about the ICR and, where
appropriate, incorporate comments received. The dra ICR is then sent to OMB for its review and approval. These
ICRs are periodically renewed. This ICR renewal covers repor ng and recordkeeping requirements for certain facili es
that manufacture, process, or otherwise use specified toxic chemicals in amounts above repor ng threshold levels as
provided in 40 CFR 372.
Please provide responses back by EPA by Oct. 3, 2024.
Thank You,

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EPA ICR No. 2613.07

OMB CONTROL NO. 2070-0212

Consultation Questions for the Information Collection Request (ICR) for Toxic Chemical
Release Reporting
(1) Publicly Available Data
A. Is the data that the Agency seeks available from any public source, or already collected
by another office at EPA or by another agency?

B. 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
The ICR covers the requirement under the PBT rule for respondents to maintain records.
A. Based on the instructions (regulations, FR Notices, etc.), is it clear what you are required
to do? If not, what suggestions do you have to clarify the instructions?

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

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

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EPA ICR No. 2613.07

OMB CONTROL NO. 2070-0212

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

(4) Burden and Costs
A. Are the labor rates accurate?

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

C. 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.

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

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