Yesterday the Office of Management and Budget (OMB) approved the revision of the information collection request (ICR) supporting Pipeline and Hazardous Material Safety Administration’s (PHMSA) hazardous material shipping papers requirements. This ICR was submitted in January 2011 as part of PHMSA’s revision (HM-215K) of the Hazardous Materials Regulations (HMR) supporting harmonization of US hazmat regulations with various international regulations.
PHMSA ICR Change Requested
In the Preamble to that regulation revision PHMSA explained that (76 FR 3341):
“This final rule may result in a decrease in the annual burden and costs of OMB Control Number 2137–0034 due to amendments to the exceptions for shipping paper requirements for limited quantities of Class 3, Division 4.1, Division 4.2, Division 4.3, Division 5.1, Division 5.2, Division 6.1, Class 8, and Class 9 materials for those limited quantities that are defined as consumer commodities.”
PHMSA went on to delineate the expected reductions (the numbers in the brackets apply those changes to the previously approved ICR numbers).
• Decrease in Number of Responses 75,000,000 [185,000,000]
• Decrease in Annual Burden Hours 1,875,000 [4,625,834]
• Decrease in Annual Burden Costs $1,875,000.00 [4,635,000]
It is interesting to note that PHMSA figures industry only spends a little over $1.00 per hour filling out HAZMAT shipping papers. While that is certainly an underestimate, they also figure that it takes almost 40 hour to fill out the same paperwork. That doesn’t seem right either.
OMB Change Approved
In the almost 22 months that it took OMB to approve this ICR, they made some changes in the numbers for the burden they expected industry to bear because of this revision of the HMR. No explanation is provided for those changes. First OMB decided that there would be no changes in the number of shipping papers completed. Then they decreased the number of hours the change reduced the burden on industry by two (2) hours to a total of 4,625,846. Finally, OMB decided that industry spends no money in completing shipping papers, reducing the cost burden to $0.
It would be interesting to see a justification by OMB of the 22 months that it took to approve this ICR. Even more interesting would be the justification for the changes that OMB made in that time period.