Attachment A, Consultations

EPA ICR NO. 2585.02

OMB CONTROL NO. 2070-0218

Consultation Questions for TSCA Existing Chemical Risk Evaluation and Management; Generic
ICR for Surveys
(1) Publicly Available Data
A. Is the data that the Agency seeks available from any public source, or already collected
by another office at EPA or by another agency?

B. If yes, where can you find the data?
(Does your answer indicate a true duplication, or does the input indicate that certain data
elements are available, but that they do not meet our data needs very well?)

(2) Clarity of Instructions
A. The ICR is intended to require that respondents provide certain data so that the Agency
can utilize them.

B. Based on the instructions (regulations, PR Notices, etc.), 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?

C. Do you understand that you are required to maintain records?

D. Considering that there is no required submission format, is it difficult to submit
information in ways that are clear, logical, and easy to complete?

E. Are there forms associated with this process? Do you use them? Are they clear, logical,
and easy to complete?

(3) 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, unless there is a strong
reason for not doing so. One such reason is that, at the present time, the Agency is unable to
ensure the security of CBI that might be transmitted over the Internet.
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EPA ICR NO. 2585.02

OMB CONTROL NO. 2070-0218

A. What do you think about electronic alternatives to paper-based records and data
submissions? Would you be interested in pursuing keeping records electronically?

B. Are you keeping your records electronically? If yes, in what format?

(4) Burden and Costs
A. Are the labor rates accurate?

B. The Agency assumes there is no capital cost associated with this activity. Is that correct?

C. Bearing in mind that the burden and cost estimates include only burden hours and costs
associated with the paperwork involved with this ICR (e.g., the ICR does not include
estimated burden hours and costs for conducting studies) are the estimated burden hours
and labor rates accurate? If you provide burden and cost estimates that are substantially
different from EPA’s, please provide an explanation of how you arrived at your
estimates.

D. Are there other costs that should be accounted for that may have been missed?

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