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View ICR - OIRA Conclusion



2070-0093 200211-2070-005
Historical Active 200201-2070-001
EPA/OCSPP
Toxic Chemical Release Reporting, Recordkeeping, Supplier Notification and Petitions under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA): Renewal
Extension without change of a currently approved collection   No
Regular
Approved with change 03/10/2003
Retrieve Notice of Action (NOA) 11/27/2002
This ICR is approved until Oct 31, 2003. OMB is providing a shorter than usual clearance for several reasons. First, at the request of EPA, OMB is adjusting the clearance cycle to better harmonize with the TRI "business cycle" by moving future OMB review periods from a December/January time frame to a September/October time frame. Second, the shortened clearance cycle will provide EPA an opportunity to examine in more detail several issues that were not adequately addressed during the current review cycle. These include both the TRI burden estimates and opportunities for reducing burden and enhancing the practical utility of the data. In the current ICR submission, EPA suggested revising the burden estimates for Form R downward, from 9,612,104 hrs per year to 2,477,952 hrs per year. This revision does not reflect changes in program requirements, but rather changes in the assumptions underlying the burden calculations. These include: 1) a downward revision in the number of forms to reflect historical experience rather than analytical projections, 2) a revision to the estimate of the number of first-time filers, 3) a revision to the average time needed for form completion, from 47 to 14.5 hours per form, and 4) an additional reduction of 25% per form to reflect projected time savings from the use of the new TRI-ME software. OMB agrees that the first two revisions are appropriate, but needs further information before approving the latter two. OMB has therefore approved part of the suggested burden reduction, for a total burden of 5,566,564 hours. If EPA continues to believe that further adjustments are appropriate, they should provide additional documentation during the next ICR review cycle. This documentation should specifically address the issue of whether the revised estimates account for all categories of burden, including time for data tracking and assembly; creation, operation, and maintenance of data tracking systems; training; and compliance determinations.
  Inventory as of this Action Requested Previously Approved
10/31/2003 10/31/2003 03/31/2003
88,117 0 119,506
5,566,564 0 9,612,104
0 0 0