Attachment N

Date:

August 1, 2018

From:

Adam Ross/DC/USEPA/US

To:

Mike Walls, Vice President
Regulatory and Technical Affairs
American Chemistry Council, Inc.
[email protected]
Melissa Hockstad, President and CEO
American Cleaning Institute
[email protected]
Derek Swick, MPP
Senior Policy Advisor
Regulatory and Scientific Affairs
American Petroleum Institute
[email protected]
Tim A. Brown, Esq., Vice President and General Counsel
Consumer Specialty Products Association
[email protected]
Ann M. Begley, Secretary/Co-General Counsel
Enzyme Technical Association
[email protected]
Dan Naatz, Vice President of Government Relations
Independent Petroleum Association of America
[email protected]
Jim Cooper
Vice President Petrochemicals
American Fuel and Petrochemical Manufacturers
[email protected]
William Carteaux, President
Society of the Plastics Industry, Inc.
[email protected]
Bill Allmond, Director
Government Relations
Society of Chemical Manufacturers and Affiliates Formerly the Synthetic Organic
Chemical Manufacturers Association. (SOCMA)
[email protected]

Subject:

Request for Assistance on Renewal of Information Collection Request:
"Premanufacture Review Reporting and Exemption Requirements for New
Chemical Substances and Significant New Use Reporting Requirements for
Chemical Substances" (EPA ICR No. 0574.18; OMB Control No. 2070-0012)

On July 25, 2018, EPA published a Notice in the Federal Register (83 Fed. Reg. 35269) titled
“Agency Information Collection Activities; Proposed Renewal of Existing Collection (EPA ICR
No. 0574.18); Comment Request” for the information collection request relating to
“Premanufacture Review Reporting and Exemption Requirements for New Chemical Substances
and Significant New Use Reporting Requirements for Chemical Substances” (OMB Control No.
2070-0012) (See: https://www.regulations.gov/document?D=EPA-HQ-OPPT-2017-0645-0001.)
This Notice refers to EPA's intention to request renewed Office of Management and Budget
(OMB) clearance of an information collection request related to premanufacture and significant
new use notice requirements for new chemicals under TSCA Section 5.
In addition to requesting public notice and comment, OMB regulations at 5 CFR 1320.8(d)(1))
require agencies to consult with potential respondents and data users about specific aspects of an
information collection request (ICR) before submitting it to OMB for review and approval,
regardless, in the case of ICR renewals, of whether changes have or have not been made to the
collection activity.
As part of this required consultation, I am contacting you to solicit your input. Please note that if
you take this opportunity to provide input, your name, affiliation, e-mail address, phone number
and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the
ICR supporting statement, which will be a public document. In addition, the OMB Desk
Examiner for the ICR in question may contact you to verify the accuracy of any comments EPA
identifies in the ICR.
EPA solicits your input on the following questions:
Are the data that EPA seeks under this ICR available from any public source, or already
collected by another EPA office or by another agency? If so, where can the data be found?
Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?
Do you agree with EPA's estimated burden and costs? Are the Bureau of Labor Statistics (BLS)
labor rates accurate? If you have any reason to consider the BLS labor rates as used by EPA
inaccurate or inappropriate, explain your rationale.
Do you believe EPA accurately estimated the burden for the newly published document “Points
to Consider When Preparing TSCA New Chemical Notifications”? Would you add any

additional bases for estimating the burden from this document (i.e. additional time spent beyond
review of the document)?
To access the Federal Register Notice, the ICR supporting document, and any public comments
received to date, go to:
• www.regulations.gov/
• Enter EPA-HQ-OPPT-2017-0645-0001in the Enter Keyword or ID field
• Click on "Search"
• Then click on any of the documents listed within the docket to read them; you likely will
be most interested in the Supporting Statement, identified by its title beginning
"Information Collection Request…"
Your response will be greatly appreciated. If you have any comments in response to the above
questions, or with respect to any other part of the information collection, please respond by
return e-mail by September 24, 2018. EPA will consider those responses, as well as any public
comment received in response to the Federal Register Notice identified above, in preparing a
final document for OMB review.
Thank you for your assistance.
Sincerely yours,

Adam Ross, Program Attorney
Chemical Control Division/Office of Pollution Prevention and Toxics / Office of Chemical
Safety and Pollution Prevention / Environmental Protection Agency
Washington, DC 20460
(202) 564-1625