0795.16_ss_Attachment 5

0795.16/ 2070-0030 - Attachment 5 - PRA Consultation

From:
To:
Cc:
Subject:

Weir, Harlan
[Representative Respondent]
Passe, Loraine; Vendinello, Lynn; Reese, Recie
Toxic Substances Control Act (TSCA) Section 12(b) Export Notification Information Collection Request (ICR)
Consultation (EPA ICR No. 0795.16, OMB Control No. 2070-0030)
Thursday, March 12, 2020 4:43:00 PM

Date:

Good Afternoon:
I am contacting you to solicit your input on the renewal of the Information Collection Request (ICR)
to obtain information pursuant to the Toxic Substances Control Act (TSCA) section 12(b) export
notification requirements. 
The existing ICR for the TSCA section 12(b) export notification expires on November 30, 2020 and
will need to be renewed. Entitled, “Notification of Chemical Exports – TSCA Section 12(b),” it is
identified by OMB Control No. 2070-0030. OMB requires federal agencies to consult with nine or
fewer potential respondents prior to submitting the ICR renewal to OMB for review and approval.
This consultation requirement is in addition to providing the public with 60 days to comment on the
proposed collection activity. The notice announcing the ICR renewal and solicitation of comments
was published in the Federal Register on March 12, 2020 (85 FR 14478). See
http://www.regulations.gov/, docket ID EPA-HQ-OPPT-2015-0435-0016, and the ICR supporting
statement for this renewal located in that docket for additional information.
The Paperwork Reduction Act (PRA) requires that agencies receive Office of Management and
Budget (OMB) clearance before requesting most types of information from the public. In order to
receive OMB clearance, federal agencies prepare draft ICRs providing an overview of the information
collection and estimates of the cost and time for the public to respond. The agencies consult with
potential respondents and the public about the ICR and, where appropriate, incorporate comments
received. The draft ICR is then sent to OMB for its review and approval. These ICRs are periodically
renewed.
TSCA section 12(b) requires any person who exports or intends to export a chemical substance or
mixture that is regulated under TSCA sections 4, 5, 6 and/or 7 to notify EPA of such export or intent
to export. EPA uses the information obtained from the submitter via this collection to inform the
government of the importing country of the export. This requirement is described in more detail in
the Code of Federal Regulations (CFR) at 40 CFR part 707, subpart D. There is a decrease of 1,098
hours in the total estimated respondent burden compared with that identified in the ICR currently
approved by OMB. This decrease reflects a net change with a large decrease in burden due to the
anticipated use of e-reporting and a small increase in burden due to a greater number of
submissions.
EPA solicits your input on the following questions.  
1.

INFORMATION COLLECTION
(a) Is the information that the Agency seeks under this ICR available from any public source,
or already collected by another office at EPA or by another agency?  If yes, where can the

Agency find the data?

                (b) Is it clear what is required for data submission?  If not, are there any suggestions for
clarifying instructions?

2.           BURDEN COST ANALYSIS

(a) Do you agree with EPA’s estimated burden and costs related to submitting information?

(b) Are the Bureau of Labor Statistics (BLS) labor rates accurate? If you have any reason to
consider the BLS labor rates inaccurate or inappropriate as used by EPA, please explain your
rationale.

Please note that if you take this opportunity to provide input, your name, affiliation, phone number,
and any information that you provide will be incorporated and attached to the ICR supporting
statement, which will be a public document. In addition, you may be contacted by the OMB desk
examiner reviewing this ICR reinstatement to verify the accuracy of any comments as reported in the
ICR by EPA. To provide input on this ICR, please respond to this email by May 11, 2020 so we can
consider those responses, along with other consultation responses and public comments resulting
from the Federal Register notice, at the same time as we prepare a final document for OMB review.

Your timely response to the questions will be greatly appreciated. Thank you in advance for your
assistance.

Sincerely,

Harlan Weir
Chemical Control Division
Office of Pollution Prevention and Toxics
Office of Chemical Safety and Pollution Prevention
Environmental Protection Agency
(202) 564-9885

Note: These comments were submitted to the public docket and are provided as Attachment 3 to the ICR.
From:
To:
Cc:
Subject:
Date:

Weir, Harlan
Derek Swick
Passe, Loraine; Vendinello, Lynn; Reese, Recie
RE: Toxic Substances Control Act (TSCA) Section 12(b) Export Notification Information Collection Request (ICR)
Consultation (EPA ICR No. 0795.16, OMB Control No. 2070-0030)
Friday, May 08, 2020 12:53:00 PM

Mr. Swick,
Thank you very much for the comments.
Best regards and health,
Harlan Weir
Chemical Control Division
Office of Pollution Prevention and Toxics
Office of Chemical Safety and Pollution Prevention
Environmental Protection Agency
(202) 564-9885
From: Derek Swick
Sent: Friday, May 08, 2020 9:22 AM
To: Weir, Harlan
Cc: Passe, Loraine ; Vendinello, Lynn ; Reese,
Recie ; Derek Swick
Subject: RE: Toxic Substances Control Act (TSCA) Section 12(b) Export Notification Information
Collection Request (ICR) Consultation (EPA ICR No. 0795.16, OMB Control No. 2070-0030)
Dear Mr. Weir:
Greetings. Please see attached API comments on the TSCA 12(b) ICR. Please feel free to contact me
with any questions.
Very best regards and health,
Derek Swick
API

Derek D. Swick, PHD

Manager | Downstream Policy
American Petroleum Institute | 200 Massachusetts Ave NW | Washington, DC 20001
202.682.8341
[email protected]
www.api.org