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.
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)