This ICR is approved for two years. However, OMB continues to be concerned that the current Form A is not yielding the expected reduction in burden. EPA has stated that it is seeking to increase use of the Form A by emphasizing its availability during TRI training sessions, directly contacting eligible facilities to make them aware of it as a reporting option, and modifying the reporting package in a way that makes it easier to use. However, these activities, while helpful, appear likely to yield at most modest additional burden reductions. EPA should thus: 1) further consider options for reducing TRI reporting burden through the use of the Form A, 2) incorporate such changes as it deems appropriate into the next submission of this ICR, and 3) report to OMB at that time on its consideration of burden reducing options under these terms of clearance. The previous submission of this ICR was approved with similar terms of clearance. Since then, EPA has increased the burden of the TRI program through its PBT initiative. EPA does not allow the use of Form A for PBT chemicals, reducing the number of reports that are eligible for Form A. The previous terms of clearance noted a number of burden reduction options discussed in a 1998 "Analysis of Changes to the Alternate Threshold Provisions" and the subsequent report of the Toxic Data Reporting (TDR) Committee of the National Advisory Council for Environmental Policy and Technology. These reports discussed a broad range of burden reduction options for the TRI program. Of particular relevance to Form A were the options of adjusting the level of the waste threshold from the current 500 lbs to either 1,000, 2,000, or 5,000 lbs, adjusting the activity threshold from the current 1 million lbs to either 2, 5, or 10 million lbs, and changing the categories of waste included in the waste threshold calculation (ie, excluding quantities recycles and quantities used for energy recovery). In light of the significant increase in TRI reporting burden since this ICR was last approved, and the limited progress in achieving meaningful burden reduction, EPA should seriously consider all of these options, as well as other burden reduction options not related to Form A. One promising option would be to move to either alternate year reporting, or to allow a streamlined certification of 'no significant change' in alternate years. EPA should report on its consideration of these options in the next submission of this ICR and/or the ICR for the Form R.
Inventory as of this Action
Requested
Previously Approved
03/31/2003
03/31/2003
02/28/2001
14,793
0
9,072
644,761
0
646,875
0
0
0
This ICR extends approval to collect information under the Emergency Planning and Community Right-to-Know Act (EPCRA) section 313 and section 6607 of the Pollution Prevention Act (PPA) of 1990. Respondents submit information concerning toxic chemical releases into the air, land and water.
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.
Alternate Threshold for Low Annual Reportable Amounts; Toxic Chemical Release Reporting