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View ICR - OIRA Conclusion



2050-0072 199506-2050-003
Historical Active 198908-2050-004
EPA/OLEM
Community Right-to-Know Reporting Requirements (EPCRA Sections 311 and 312
Reinstatement with change of a previously approved collection   No
Regular
Approved without change 09/29/1995
Retrieve Notice of Action (NOA) 06/30/1995
This ICR for the third party notification requirements of EPCRA 311 and 312 is approved until 1/97. EPA should seek public comment on the burden estimates including methodologies used from respondents. In particular, EPA shall disaggregate burden estimates for Tier II filers that (1) file identical information each year, (2) provide revised, new or complex information. This latter group may be further subdivided based on different size or type (SIC code, manufacturing, non-manufacturing) to give a clear indication of the variability in burden. In addition, EPA should examine its assumption that the rate of growth for the manufac- turing sector is the same (1.4%) as the non-manufacturing sector. EPA also assumes that 5% of facilities submit MSDS/updates year- ly (page 9) without providing adequate justification. A better rationale is needed. EPA assumes responding to public requests takes only about 10 minutes. EPA shall seek comment from MSDS providers to determine if this estimate needs to be revised. EPA may seek public comment on these burden issues as it proposes revisions to this program. EPA shall follow all OMB guidance in calculating third party burdens when this ICR is renewed. EPA should provide a new Exhibit 3 to accompany the burden reestimate provided on 9/29/95.
  Inventory as of this Action Requested Previously Approved
03/31/1997 03/31/1997
0 0 0
2,956,401 0 0
0 0 0