Attachment F- Consultation

From: Edmonds, Marc
Sent: Thursday, March 25, 2021 9:06 AM
Subject: Public Comment on the Proposed Renewal of an Information Collection Request (ICR) on
TSCA fees

My name is Marc Edmonds of the Existing Chemicals Risk Management Division at
the Environmental Protection Agency (EPA). I am writing to you today to request your
assistance on an Information Collection Request (ICR). For the past few months, EPA has
been updating the ICR for the User Fees for the Administration of the Toxic Substances
Control Act (TSCA). As part of our consultation process, we are requesting comments from
industry on this ICR renewal proposal.
Our records indicate that in the past you may have participated as a representative of
your company in responding to the EPA’s questions on this ICR. The survey should only take
about 15 minutes and your response is voluntary. Should you choose to respond, we ask that
you do not submit any sensitive, confidential business information or business phone numbers
as part of your response. Here is a link to the Federal Register announcement
https://www.federalregister.gov/documents/2021/03/19/2021-05778/agency-informationcollection-activities-proposed-renewal-of-an-existing-collection-and-request-for. The ICR
supporting statement is available in the same docket as the announcement.
EPA solicits your input on the following questions related to the burden and costs associated
with the ICR:
Are the labor rates in the ICR supporting statement accurate?
The Agency assumes there is no capital cost associated with this activity.  Is that
correct? 
Are there other costs that should be accounted for that may have been missed?
EPA solicits your input on the following questions related to clarity of instructions associated
with this ICR:
The ICR is intended to require that respondents provide certain data so that the Agency
can utilize them.
Based on the instructions, is it clear what you are required to do and how to submit such
data? If not, what suggestions do you have to clarify the instructions?
Do you understand that you are required to maintain records?
Are the forms clear, logical, and easy to complete?

EPA solicits your input on the following questions related to electronic reporting and record
keeping: 
The Government Paperwork Elimination Act requires agencies make available to the
public electronic reporting alternatives to paper-based submissions by 2003.
What do you think about electronic submissions, such as the Agency’s Central Data
Exchange (CDX)? 
Are you keeping your records electronically?   If yes, in what format?
You may send your responses to the above questions to the EPA Docket EPA-HQ-OPPT2020-0616 at https://www.regulations.gov/docket/EPA-HQ-OPPT-2020-0616 or to me
directly, by Thursday, April 8, 2021.
We greatly appreciate your time and participation.
Marc Edmonds
Team Lead, Risk Management Branch 2
Existing Chemicals Risk Management Division
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency