EPA is to be commended for the significant burden reduction contained in this ICR, and for its efforts to promulgate it in time to apply to the 1999 reporting year. In the proposed rule, EPA also proposed several other burden reducing measures, such as establishing an infinite reporting threshold for OSHA hazardous chemicals that present insignificant risks to the health of individuals in the community, to emergency responders on-site, or to the environment. EPA also requested comment on various other burden reducing measures, such as raising reporting thersholds for certain other industries (eg, motor pools), and various technical adjustments to the format and content of required reports. OMB understands that EPA intends to finalize a rule addressing these other possible revisions by the end of 1999. OMB supports this process and encourages EPA to include as much burden reduction in the final rule as it deems consistent with the purposes and requirements of EPCRA Sections 311 and 312. OMB also reminds EPA of the terms of clearance for the previous approval of this ICR. They stated that EPA should continue efforts to reexamine and seek public comment on the burden estimates contained in the ICR, and that specifically, EPA should refine its estimate of the burden for Tier II filers by differentiating those filers that file identical information each year from those that provide revised, new or complex infomration. This comment should be specifically addressed when this ICR is resubmitted in January 2000.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
02/29/2000
02/29/2000
01/31/2000
803,682
0
868,527
2,377,229
0
2,963,209
4,268,000
0
5,463,000
Section 311 requires that the owner or operator of any facility that is required to prepare or have available material safety data sheets (MSDSs) for a hazardous chemical under OSHA regulations shall submit an MSDS for such chemical, or a list of chemicals, to the LEPC, SERC, and local fire department. This submittal allows both local emergency planners/responders and the community to have information regarding the hazards of chemicals used at the facility. Section 312 requires the same owners and operators to annually report the inventories of the chemicals reported under section 311.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Comunity Right-to-Know Reporting Requirements under Section 311 and 312 of EPCRA