Attachment F, Consultations

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eCDRweb
Feedback Requested: EPA"s TSCA Section 8 Information Collection Request (ICR)
Thursday, May 22, 2025 1:19:02 PM
ICR_Consultation Questions 2070-0224.pdf

Hello All:
I am contacting you to solicit your input on the renewal of an Information Collection Request (ICR)
(see attached questions). This ICR is under the Toxic Substance Control Act (TSCA) and titled
“Consolidation of Certain Reporting and Recordkeeping Under Section 8 of the Toxic Substances
Control Act (TSCA),” identified by OMB Control No. 2070-0224. 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 May 9, 2025 (90 FR 19715). See
http://www.regulations.gov/, docket ID EPA-HQ-OPPT-2021-0728. The ICR supporting statement for
this renewal located is in that docket for additional information, identified by document ID EPA-HQOPPT-2021-0728-0012.
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.
Under this ICR, this information collection request (ICR) covers reporting and recordkeeping
requirements imposed under the authorities in section 8 of the Toxic Substances Control Act (TSCA),
15 U.S.C. 2607, for persons who manufacture (the term “manufacture” includes import under TSCA)
or process chemical substances, mixtures, or chemical categories, or distribute them in commerce.
The purpose of the information collection activities is to collect data that will help the Agency
evaluate the potential for human health and environmental risks that may be caused by the
manufacture, processing, and distribution in commerce of chemical substances, mixtures, or
categories.
Please provide responses back by EPA by June 12, 2025. Responses can be emailed to
[email protected] and/or submitted to the docket identified above.
Thank you,
Stephanie Griffin
TRI Regulatory and Policy Branch
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
(202) 564-1463 | [email protected]

EPA ICR No. 2703

OMB CONTROL NO. 2070-0224

Consultation Questions for the Information Collection Request (ICR) for Consolidation of
Certain Reporting and Recordkeeping Under Section 8 of the Toxic Substances Control Act
(TSCA)
(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
The ICR covers the requirement under several rules for respondents to maintain records.
A. Based on the instructions (regulations, FR Notices, etc.), is it clear what you are required
to do? If not, what suggestions do you have to clarify the instructions?

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

(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 via email over the Internet. EPA is
currently using Central Data Exchange (CDX) to securely upload CBI information, enabling
electronic submissions.

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EPA ICR No. 2703

OMB CONTROL NO. 2070-0224

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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