FinalSupporting Statement to OMB Form 83-12-11-19 (002)

Supporting Statement to OMB Form 83-I, Chemical Safety and Hazard Investigation Board
12-11-19

Supporting Statement for Paperwork Reduction Act (PRA) Submissions
General Response
Supporting Statement: The CSB’s supporting statement for its PRA submission is
provided in the pages that follow.
The text of notice required under 5 CFR 1320.5(a)(i)(iv): The text of this notice is
included within the proposed rule. The proposed rule is attached hereto as Exhibit
1.
Estimated Date of Publication in the Federal Register: December 12, 2019.
Specific Information
A. Justification
1.
Explain the circumstances that make the collection of information
necessary.
CSB response: The CSB’s enabling legislation necessitates and authorizes this
collection of information. See 42 U.S.C. § 7412(r)(2)(A)-(C); 42 U.S.C. §
7412(r)(6)(C)(i)-(iii); 42 U.S.C. § 7412(r)(6)(E); 42 U.S.C. § 7412(r)(6)(L)-(O).
The CSB has been ordered by a federal court to publish a final reporting rule by
February 5, 2020. See Air Alliance of Houston, et al. v. U.S. Chemical Safety and
Hazard Investigation Board, 365 F. Supp. 3d 118, (D. D.C. Feb. 4, 2019).
Identify any legal or administrative requirements that necessitate the
collection.
CSB response: See the above response.
Attach a copy of the appropriate section of each statute and regulation
mandating or authorizing the collection of information.
CSB response: A copy of the CSB enabling legislation is attached as Exhibit 2.
The enabling legislation includes all of the provisions cited above, including and

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especially 42 U.S.C. 7412(r)(6)(C)(iii), which specifically authorizes/mandates the
proposed rule and collection of information.
2. Indicate how, by whom, and for what purpose the information is to be
used.
CSB Response: The purpose of the information is to notify the CSB of an
accidental release within its investigatory jurisdiction and to provide the CSB with
basic information concerning the accidental release. Such information is critical to
the CSB for a number of reasons, including but not limited to the following: 1) an
initial assessment of CSB jurisdiction; 2) a determination as to whether an
investigation is mandatory for purposes of 42 U.S.C. § 7412(r)(6)(E); and 3) basic
information regarding the nature of the accidental release. See subsection 1604.4
of the proposed rule.
Except for a new collection, indicate the actual use the agency has made of the
information received from the current collection.
CSB Response: This is a new collection. No response required.
3. Describe whether, and to what extent, the collection of information involves
the use of automated, electronic, mechanical, or other technological collection
techniques or other forms of information technology, e.g. permitting
electronic submission of responses, and the basis for the decision for adopting
this means of collection.
CSB Response: The proposed collection permits a reporting party to contact the
CSB by telephone or by emailing a screen-fillable .pdf reporting form. If a party
has reported an accidental release to the National Response Center pursuant to 40
CFR 302.6 (CERCLA), the reporting party is not required to submit a separate
report to the CSB; the only information required is that the reporting party send the
CSB an email with its NRC identification number. See subsection 1604.3 of the
proposed rule.
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Also describe any consideration of using information technology to reduce
burden.
CSB Response: As noted above, a reporting party may file a report by email to the
CSB, or by emailing a NRC identification number to the CSB. The CSB also
utilizes internet search engines and media reporting services to identify accidental
releases within its investigatory jurisdiction. As noted in the proposed rule, the
CSB will use these tools, as needed, to remind an owner/operator of the need to
report an accidental release if one is not filed in a timely manner.
4. Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the
purposes described in item 2 above.
CSB Response: The CSB has long sought to avoid duplicative reporting
requirements by arguing that it had alternative methods for collecting the same
information even in the absence of a rule. Specifically, the CSB has used internet
search engines and media reporting services to identify accidental releases within
its jurisdiction. Although the CSB deemed this method acceptable for many years,
the CSB is now under court order to issue its own specific reporting requirement
by February 5, 2020.
In its ANPRM, the CSB asked for comments on the following question:
“Should an initial report be made to the CSB or the National Response Center?”
The CSB received a number of comments that suggested that reports be submitted
to the National Response Center (NRC) in order to avoid duplicative reporting.
In developing this proposed rule, the CSB also considered whether accidents
reported to the NRC under other laws could satisfy the CSB’s reporting rule. CSB
considered information provided in reports it already receives from the NRC, and

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reviewed its own incident database to determine how many reports in the database,
on average, are based on reports the CSB receives from the NRC.1
The CSB determined that there is no simple method to ensure that reports
filed with NRC under other laws would satisfy the requirements of a CSB
reporting rule. The NRC collects information based on the type of event (i.e.,
storage tank accidents), not specific laws. Accordingly, there is no certain way to
determine whether information reported to the NRC under a certain law will also
satisfy CSB requirements. Some laws may seem to overlap with the CSB’s
requirements but include certain exceptions, i.e., threshold quantities. Under such
laws, if the accidental release does not meet the threshold quantity, no report will
be made to the NRC.
However, in conferring with the NRC, the CSB was able to determine that
reports under 40 CFR 302.6 (although not labeled as such) could be reliably
identified via a modified search algorithm. Accordingly, if an owner/operator
knows that it has submitted a report to the NRC under 40 CFR 302.6, the
owner/operator is not required to file a separate report with the CSB. Rather, the
owner/operator is simply required to notify the CSB of the pertinent NRC
identification number. The CSB would then use this number to ensure that its
search algorithm is capturing all pertinent accidental releases reported to the NRC.
This approach is consistent with the CSB’s legislative history, which provides
in pertinent part, that the CSB’s “reporting requirements may be coordinated with
other reporting requirements established by the Agency [EPA] (for instance, under
section 103 of CERCLA).” S. Rep. No. 101-228 at 236 (1989), reprinted in 1990
U.S.C.C.A.N. 3385, 3620.

1

This analysis is not complete.

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Moreover, the CSB’s legislative history provides:
The regulations of the Board for accident reporting may provide that any
person directed to make a report contact the National Response Center
rather than the Board directly. This will assure coordination of such
reports with responsibilities under the Comprehensive Environmental
Response, Compensation and Liability Act, the Clean Water Act and the
Hazardous Materials Transportation Act. If the National Response
Center is to be the initial point of contact under such rules, then the
Board shall assure that officials at the National Response Center
promptly notify the Board or its officers whenever an accidental release
requiring an investigation has occurred.
Id.
Other than reports submitted to the NRC under 40 CFR 302.6, the proposed rule
requires that a report be made to the CSB directly. According to CSB estimates,
the proposed rule will require approximately 200 reports per year. However, the
total number made to CSB should be fewer because some reports made to the NRC
under 40 CFR 302.6 will satisfy the CSB’s requirements.
Aside from the NRC, reports of similar information may be made pursuant
to other laws following an accidental release resulting in a fatality or serious injury
or substantial property damage. However, this information is reported pursuant to
different deadlines and requirements. Moreover, this information may not
available in sufficient time for the CSB to make a deployment decision.
For example, facilities that are subject to EPA’s Risk Management Program
(RMP) rule must report periodically on any accidental release of listed hazardous
substances. While EPA shares such information with CSB, it does not include all
accidental releases within the investigatory jurisdiction of the CSB. For examples,
reports under RMP are made only when the release exceeds a threshold limit.
Moreover, RMP-required reports are submitted to EPA long after CSB must make
a deployment decision.
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5.
If the collection of information impacts small businesses or other small
entities (Item 5 of OMB Form 83-I), describe any methods used to minimize
burden.
CSB Response: The CSB anticipates only a minimal impact on small businesses
or other small entities. There is a full discussion on this point in the regulatory
flexibility analysis section of the proposed rule. See Exhibit 1.
In addition, the CSB’s proposed rule provides a simplified method of
reporting to CSB when a report has already been made to the NRC under
CERCLA. See section 1604.3(b). The owner/operator may revise and/or update
information reported to the NRC or CSB by sending a notification with revisions to
the CSB within 30 days following the submission of accidental release report.
For one year following the effective date of the rule, the CSB will refrain
from referring violations for enforcement, unless there is a knowing failure to
report. This policy is required to allow adequate time for compliance education,
especially to smaller firms.
In addition, for one year following the effective date of the rule, the CSB
will contact any owner/operator who the CSB believes should have filed a report.
If a report is filed immediately following notification, the CSB will not refer the
failure to report under Part 1604.5.
Similarly, accidents involving small facilities with few employees require
special consideration. In some cases, the owner/operator may not be able to report
an accidental release within four hours, especially if ongoing response activities
require attention. The CSB has encountered such cases in the past and has worked
with owners and operators to accommodate exceptional circumstances. The grace
period described above will resolve such issues in a reasonable fashion for at least
one year following the date of adoption. The CSB will consider a longer-term
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approach to these unique situations and propose appropriate compliance guidance
and/or amendments to any final rule before the grace period has expired.
6. Describe the consequence to Federal program or policy activities if the
collection is not conducted or is conducted less frequently, as well as any
technical or legal obstacles to reducing burden.
Consequences—not conducting:
CSB Response: The CSB is under a Court order to publish a final rule by February
5, 2020. See Air Alliance of Houston, et al. v. U.S. Chemical Safety and Hazard
Investigation Board, 365 F. Supp. 3d 118, (D. D.C. Feb. 4, 2019). Thus, the
failure of the CSB to implement the rule (collection) could result in Court
sanctions against the CSB.
Consequences—less frequent collection:
CSB Response: The collection does not occur on a scheduled basis. Rather, an
owner or operator of a stationary source is required to report an accidental release
only if the accidental release results in a death, serious injury, or substantial
property damages.
Legal obstacles/burden:
CSB Response: There are certain challenges to reducing burden, but the CSB
would not describe these challenges as a legal obstacle. However, there is a limit to
what the CSB can do to reduce burden based on its specific statutory
responsibility.
The CSB is aware of a number of state and federal reporting requirements
that may come into play when there is a catastrophic event within the CSB’s
jurisdiction. There is some overlap between these requirements, but there are also
certain areas which differ. These differences in statutory authority/responsibility

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necessitate that CSB obtain information from reporting parties, even if this results
in some potential duplication.
Technical obstacle:
CSB Response: The CSB has not identified any specific technical obstacle to
reducing burden. The CSB is using information technology and electronic
communication to reduce burden to the extent possible. For example, the CSB will
use media reporting and internet search engines to learn of accidental releases
which may be within its jurisdiction. If the CSB does not receive a report from the
owner/operator promptly, the CSB will contact the owner to make sure the
owner/operator is aware of the requirement and to assist in compliance.
7. Explain any special circumstances that require the collection to be
conducted in a manner:
a. requiring respondents to report information to the agency more often
than quarterly;
CSB Response: Potential respondents (owner/operators) are required to
report only if an accidental release causing death, serious injuries, or
substantial property damage occurs. The proposed rule does not require
regular reporting. Many potential respondents will likely never need to
submit a report.
b. requiring respondents to prepare a written response to a collection of
information in fewer than 30 days after receipt of it;
CSB Response: Potential respondents (owner/operators) are required to
report only if an accidental release causing death, serious injuries, or
substantial property damage occurs. The proposed rule does not require
regular reporting. Many potential respondents will likely never need to
submit a report.
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c. requiring respondents to submit more than an original and two copies
of any document;
CSB Response. Not applicable. The CSB will not require an original and
two copies be submitted.
d. requiring respondents to retain records, other than health, medical,
government contract, grant-in-aid, or tax records, for more than three
years;
CSB Response: Not applicable. The collection does not include a
recordkeeping component.
e. in connection with a statistical survey, that is not designed to produce
valid and reliable results that can be generalized to the universe of
study; and
CSB Response: Not applicable. The collection is not part of a statistical
survey.
f. requiring the use of a statistical data classification that has not been
reviewed and approved by OMB.
CSB Response: Not applicable. The collection does not require the use of a
statistical data classification.
8. If applicable, provide a copy and identify the date and page number of
publication in the Federal Register of the agency's notice, required by 5 CFR
1320.8(d), soliciting comments on the information collection prior to
submission to OMB.
CSB Response: Exhibit 1 is a copy of the Notice of Proposed Rulemaking posted
for public inspection today. The attached proposed rule includes notice as required
by 5 CFR 1320.8(d). The Office of Federal Register has scheduled the proposed
rule for publication on December 12, 2019.
Summarize public comments received in response to that notice and describe
actions taken by the agency in response to these comments.
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CSB Response: No comments received as of this date.
Specifically address comments received on cost and hour burden.
CSB Response: No comment received as of this date.
Describe efforts to consult with persons outside the agency to obtain their
views on the availability of data, frequency of collection, the clarity of
instructions and recordkeeping, disclosure, or reporting format (if any), and
on the data elements to be recorded, disclosed, or reported.
CSB response: The CSB consulted with the National Response Center on the
CSB’s rule to solicit feedback on most of the above topics.
Consultation with representatives of those from whom information is to be
obtained or those who must compile records should occur at least once every 3
years - even if the collection of information activity is the same as in prior
periods. There may be circumstances that mitigate against consultation in a
specific situation. These circumstances should be explained.
CSB Response: The CSB interprets the above statement as a directive concerning
the renewal of a prior request. The CSB acknowledges the need to consult with
interested parties no longer than three years following the approval of this request.
9. Explain any decision to provide any payment or gift to respondents, other
than remuneration of contractors or grantees.
CSB Response: Not applicable. The CSB will not provide any payment or gift to
respondents. The reporting parties are under a legal duty to provide an accidental
release report. Remuneration for complying with a mandatory requirement is not
permissible.
10. Describe any assurance of confidentiality provided to respondents and the
basis for the assurance in statute, regulation, or agency policy.
CSB Response: The CSB cannot provide unconditional assurance of confidentiality
of information that is submitted in response to the rule. However, the CSB has

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included language in the rule which specifically addresses information disclosure
issues. Proposed section 1604.6 provides:
Accidental release records collected by the CSB under this rule may be
obtained by making a request in accordance with 40 CFR 1601, the CSB’s
procedures for the disclosure of records under the Freedom of Information
Act. The CSB will process and if appropriate, disclose such records, only
in accordance with 40 CFR part 1601 and relevant federal information
disclosure laws.
This subsection is included in the proposed rule to confirm that the procedure
for seeking records obtained pursuant to the rule is governed by the Freedom of
Information Act, 5 U.S.C. 552, (the FOIA), the CSB’s procedural regulations for
disclosure of records under the FOIA, 40 CFR part 1601, and any other pertinent
federal disclosure laws.
Neither 42 U.S.C. 7612(r)(6)(C)(iii) nor 42 U.S.C. 7612(r)(6)(Q), alone or in
combination, authorize the immediate disclosure of accidental release record
information apart from the requirements of the FOIA. Importantly, neither of
those two provisions, alone or in combination, authorize the immediate disclosure
of accidental release report information in order to support emergency response
and public safety operations. Such a reading would potentially conflict with the
implementation of other existing public information and safety laws, such as
EPCRA (see section 303), which are directly focused on emergency response, the
protection of public health and safety, and the public release of information to
mitigate risks to the public.
11. Provide additional justification for any questions of a sensitive nature,
such as sexual behavior and attitudes, religious beliefs, and other matters that
are commonly considered private. This justification should include the
reasons why the agency considers the questions necessary, the specific uses to
be made of the information, the explanation to be given to persons from whom
the information is requested, and any steps to be taken to obtain their consent.
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CSB Response: The proposed collection does not seek information typically
considered to be related to personal privacy, such as “sexual behavior and
attitudes, religious beliefs, and other matters that are commonly considered
private.”
12. Provide estimates of the hour burden of the collection of information.
The statement should:
a. Indicate the number of respondents, frequency of response, annual hour
burden, and an explanation of how the burden was estimated.
CSB Response:
Number of respondents: 200
Frequency of response: Most respondents will only submit a response if an
accidental release within the scope of the rule occurs during a given year. For the
vast majority of potential respondents, the frequency of responses will likely be
“none” in a given year.
Annual Hour Burden: 502
Explanation of Burden Calculation: CSB estimates that approximately 200 reports
will be submitted each year, and that each report will take approximately 15
minutes for each respondent to complete and submit to the CSB. The CSB
calculated the total annual reporting burden of 50 hours by multiplying the
estimated number of annual reports by the estimated time to complete each report.
A fuller discussion of the time burden calculation is included in the regulation
flexibility analysis of the proposed rule. See Exhibit 1.
b. Unless directed to do so, agencies should not conduct special surveys to
obtain information on which to base hour burden estimates.
CSB Response: CSB did not conduct a special survey.
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This estimate does not include first year “familiarization” costs.

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Consultation with a sample (fewer than 10) of potential respondents is
desirable.
CSB Response: CSB did not consult with a sample. However, CSB did speak with
NRC leadership in order to gain insight on the time burden on a party to submit a
report by telephone. The NRC receives approximately 30,000 reports by phone
each year.
The CSB examined standard internal NRC forms used to guide its operators
in receiving information and taking reports on accidents. The reports were similar
to reports that the CSB may receive. However, the NRC’s data requests were more
extensive than anything contemplated in the CSB’s proposed rule. Although the
NRC did not have official statistics to share, the NRC informed the CSB that the
average time it took for a caller to provide a report by phone was approximately 8
minutes.
If the hour burden on respondents is expected to vary widely because of
differences in activity, size, or complexity, show the range of estimated hour
burden and explain the reasons for the variance.
CSB Response: The time burden of respondents should not vary widely because
of differences in activity, size, or complexity. Any owner/operator who must file a
report is subject to the same requirements and burden.3
Generally, estimates should not include burden hours for customary and
usual business practices.
CSB Response: The CSB did not include costs related to customary and usual
business practices in its burden estimate.

3

If an owner/operator has already filed a report with the NRC under CERCLA, the time burden for reporting
to the CSB will be shortened because an email notice is all that is required. However, this variance is not due to a
difference in activity, size, or complexity. Rather, the lighter burden is based on having previously reported similar
facts under a different law.

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c. If the request for approval covers more than one form, provide separate
hour burden estimates for each form and aggregate the hour burdens in Item
13 of OMB Form 83-I.
CSB Response: A response is not required because the CSB is seeking approval
for one form only.
d. Provide estimates of annualized cost to respondents for the hour burdens
for collections of information, identifying and using appropriate wage rate
categories. The cost of contracting out or paying outside parties for
information collection activities should not be included here. Instead, this cost
should be included in Item 13.
CSB Response: The CSB estimated an annualized cost of $9.30 for any firm
required to submit an accidental release report.4
As noted above, the CSB first determined an estimated time burden
associated with submitting an accidental release report of 15 minutes. The CSB
then estimated an hourly labor cost to translate the time requirement into a cost
figure.
In order to determine an appropriate hourly rate, the CSB identified six
relevant occupation codes, the annual mean wage, and the meanly hour wage for
each, based on the Bureau of Labor Statistics’ May 2018 National Occupational
Employment and Wage Estimates, United States. The CSB next combined the
average hourly rate for each of the six classifications and divided that total by six.
This calculation produced an average hourly rate of $37.20. This information is
summarized in Table 1 below.
CSB then multiplied the average hourly wage ($37.20) by the total time
requirement (.25 hour) to arrive at an estimated annualized reporting cost per
business of $9.30.

4

This total does not include first-year familiarization costs. If first-year familiarizations costs were added, all
potentially impacted firms would also expend $16.74 learning about the rule.

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Capital and start-up costs include, among other items, preparations for
collecting information such as purchasing computers and software;
monitoring, sampling, drilling and testing equipment; and record storage
facilities.
CSB Response: The proposed rule will not require capital or start-up costs.
If cost estimates are expected to vary widely, agencies should present ranges
of cost burdens and explain the reasons for the variance.
CSB Response: The CSB does not anticipate that costs will vary depending on the
respondent because the costs for each reporting party are the same.
The cost of purchasing or contracting out information collection services
should be a part of this cost burden estimate.
CSB Response: The CSB does not anticipate that any such cost would be incurred.
In developing cost burden estimates, agencies may consult with a sample of
respondents (fewer than 10), utilize the 60-day pre-OMB submission public
comment process and use existing economic or regulatory impact analysis
associated with the rulemaking containing the information collection, as
appropriate.
CSB Response: The CSB has included a regulatory flexibility analysis in its
proposed rule and has relied on that analysis in preparing this response.
Generally, estimates should not include purchases of equipment or services, or
portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory
compliance with requirements not associated with the information collection,
(3) for reasons other than to provide information or keep records for the
government, or (4) as part of customary and usual business or private
practices.
CSB Response: The CSB estimate does not include purchases of equipment or
services, or portions thereof, in any of the four listed categories. The CSB does not
believe that any purchase of equipment or services is necessary.
14. Provide estimates of annualized cost to the Federal Government. Also,
provide a description of the method used to estimate cost, which should
include quantification of hours, operational expenses (such as equipment,
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overhead, printing, and support staff), and any other expense that would not
have been incurred without this collection of information.7 Agencies may also
aggregate cost estimates from paragraphs 12, 13, and 14 in a single table.
CSB Response: The CSB’s preliminary cost estimate for this collection estimate is
approximately $242,000. See preliminary summary of costs attached as Exhibit 3.
15. Explain the reasons for any program changes or adjustments reported in
Items 13 or 14 of the OMB Form 83-I.
Line 13. Annual Reporting and Recordkeeping Burden
CSB Response: The addition of 50 hours is based on a new collection
required by law.
Line 14: Annualized Cost to Respondents
CSB Response: Not applicable.
16. For collections of information whose results will be published, outline
plans for tabulation and publication. Address any complex analytical
techniques that will be used. Provide the time schedule for the entire project,
including beginning and ending dates of the collection of information,
completion of report, publication dates, and other actions.
CSB Response: Not applicable. The collection is not for purposes of collecting
information for publication.
17. If seeking approval to not display the expiration date for OMB approval of
the information collection, explain the reasons that display would be
inappropriate.
CSB Response: A response is not required because the CSB is not seeking such
approval from OMB.
18. Explain each exception to the certification statement identified in Item 19,
"Certification for Paperwork Reduction Act Submissions," of OMB Form 83I.
7

Exhibit 3 provides additional detail on the CSB estimate. The CSB notes that it already incurs certain
expenses related to tracking accidental releases for purposes similar to those in the proposed rule. The CSB has
included these ongoing expenses as part of its estimate.

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CSB notes concerning the following subsections of 5 CFR 1320.9:
(f): There is no record keeping requirement.
(g): The CSB does not yet have an OMB control number and approved form.
However, the CSB intends to inform potential respondents of the information
called for under 5 CFR 1320.8(b)(3).
(h): The CSB, an agency with less than 40 employees, is under a Court order to
publish a final rule by February 5, 2020. For several months, the CSB has focused
in this primary task. The CSB has not completed its planning for implementation.
However, CSB has prepared a preliminary cost estimate for this clearance and
considered a number of issues in the development of the proposed rule related to
the effective implementation of the rule. With the publication of the proposed rule,
the CSB focus additional time on planning for and allocating resources for the
effective and efficient management of use of the information to be collected.
(i): Not applicable.
***
B. Collection of Information for Statistical Purposes
CSB Response: This section is not applicable and therefore no response is
provided. The collection of information is not for statistical purposes.

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