Reflects changes in the TRI Burden Reduction Rule, which expands eligibility for Form A reporting. The increase of 279,496 hrs in Form A is more than offset by a 402,298 hr reduction in Form R, for a net burden reduction of 122,802 hours. OMB supports EPA's decision to reduce burden without compromising the practical utility of the TRI data.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
01/31/2008
01/31/2008
01/31/2008
16,781
0
4,920
538,688
0
259,192
0
0
0
This ICR extends approval to collect information under the Emergency Planning and Community Right-fo-Know Act (EPCAR) section 313 and section 6607 or the Pollution Prevention Act (PPA of 1990. Resondents submit information concerning toxic chemical releases into the air, land and water.
The TRI final rule to expand Form A eligibility provides overall burden reduction of approximately 123,404 hours based on a decrease in the Form R burden that outweighs the increase in the Form A burden (i.e., 402,298 hours of Form R burden reduction minus 279,495 hours of Form A burden increase).
Burden hour decreases to Form R: 402,298. This figure is based on the estimated 9,501 non-PBT Form Rs converting to Form A and 2,360 PBT Form Rs converting to Form A. Each non-PBT Form R response is estimated to average 29.6 hours and each PBT Form R response is estimated to average 51.3 hours. ((9,501 x 29.6) + (2,360 x 51.3) = 402,298).
Burden hour increases to Form A: 279,495. This figure is based on the estimated 9,501 non-PBT Form Rs converting to Form A and 2,360 PBT Form Rs converting to Form A. Each non-PBT Form A response is estimated to average 20.5 hours and each PBT Form A response is estimated to average 35.9 hours. ((9,501 x 20.5) + (2,360 x 35.9) = 279,495).
EPA further recognizes that there may be some insignificant number of Form As (approximately 50) that may become newly ineligible for Form A under this final rule as a result of including Section 8.8 amounts (e.g., catastrophic events) in Form A threshold determinations; thus, causing these newly ineligible Form As to become Form Rs. For more information about new ineligibility for Form A as a result of this final rule refer to the preamble to the final rule and Chapter 6 of the Economic Analysis supporting this rule.
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.
Form 9350-2 Toxic Chemical Release Reporting, Alternate Threshold for Low Annual Reportable Amounts (Form A) (Renewal)
TRI burden Changes.doc
Toxic Chemical Release Reporting, Alternate Threshold for Low Annual Reportable Amounts (Form A) (Renewal)