COVID-19 Implications for Signing Paper Hazardous Waste Manifests

Forms and Documents

Document Name	Status
Form 8700-22 COVID-19 Implications for Signing Paper Hazardous Waste Manifests Form and Instruction	New
COVID-19 Manifest Signature Temporary Policy 5-18-20 Final For Signature.pdf Supplementary Document	2020-05-19
E Manifest_Emergency Request_EPA Determination 5-18-20 final.pdf Supporting Statement A	2020-05-19

IC Document Collections

IC ID	Document Title	Status
241892	COVID-19 Implications for Signing Paper Hazardous Waste Manifests Form and Instruction	New

ICR Details

OMB Control No: 2050-0222	ICR Reference No: 202005-2050-001
Status: Historical Active	Previous ICR Reference No:
Agency/Subagency: EPA/OLEM	Agency Tracking No: 2627.01
Title: COVID-19 Implications for Signing Paper Hazardous Waste Manifests
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 05/22/2020
OIRA Conclusion Action: Approved without change	Conclusion Date: 05/21/2020
	Date Received in OIRA: 05/19/2020
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	11/30/2020	6 Months From Approved
Responses	1,147,883	0	0
Time Burden (Hours)	0	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: Recognizing that the evolving COVID-19 public health emergency may result in potential worker shortages and that social distancing restrictions to limit the spread of COVID-19 may impede normal operations of regulated facilities and laboratories, on March 26, 2020, the Office of Enforcement and Compliance Assurance (OECA) issued a memorandum entitled COVID-19 Implications for EPAs Enforcement and Compliance Assurance Program (Temporary COVID-19 Enforcement Policy), a temporary policy regarding enforcement of environmental obligations by the U.S. Environmental Protection Agency (EPA) during this time. The policy also notes that EPA may provide additional enforcement guidance applicable to specific programs on an ongoing basis. Office of Land and Emergency Management (OLEM) and OECA are issuing additional policy to provide guidance with respect to generator signatures on paper hazardous waste manifests under RCRA resulting from the COVID-19 public health emergency. This policy supplements and incorporates by reference the Temporary COVID-19 Enforcement Policy.

Emergency Justfication: Pursuant to section 3507(j) of the Paperwork Reduction Act (PRA) (44 U.S.C. 3501 et seq.), as implemented in Office of Management and Budget (OMB) regulations at 5 CFR 1320.13, the Agency is hereby requesting emergency processing of a submission of the collection of information necessary for the timely and efficient implementation of 40 CFR 262.23(a) pursuant to EPAs authority in Resource Conservation and Recovery Act (RCRA). More specifically, the Agency seeks emergency authorization to deviate from the use and associated instruction of EPA form 8700-22/22A, which is used to obtain written generator signatures on paper hazardous waste manifests under RCRA. The deviations will allow required paperwork in a manner that is consistent with social distancing restrictions associated with the COVID-19 public health emergency.

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Authorizing Statute(s): US Code: 42 USC 69001 Name of Law: RCRA
   PL: Pub.L. 112 - 195 Oct. 5, 2012 Name of Law: Hazardous Waste Electronic Manifest Establishment Act
   US Code: 42 USC 3003 and 3004 Name of Law: SWDA
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
COVID-19 Implications for Signing Paper Hazardous Waste Manifests	8700-22, 8700-22A	Uniform Hazardous Waste Manifest ,   Uniform Hazardous Waste Continuation Manifest

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	1,147,883	0	0	1,147,883	0	0
Annual Time Burden (Hours)	0	0	0	0	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement:

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Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Yes

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Common Form ICR:  No

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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:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(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;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

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.

Certification Date: 05/19/2020

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