Sunday, October 21, 2012

TSA Publishes HME ICR 60-Day Notice

The Monday Federal Register (available on line yesterday) includes a 60-day notice (77 FR 64533) from the Transportations Security Administration of their intent to submit to OMB a renewal of the information collection request supporting the Hazardous Material Endorsement (HME) credential program. Readers might remember that a short-term renewal of the HME ICR had been granted in July of this year, but OMB requested updated burden information to provide a longer term renewal.

ICR Information

This ICR notice provides the updated information requested by OMB. The table below shows the new data and the data provided in the previously approved request. Both sets of data are provided on an annual basis

New Data
Previous Data
Burden (hours)
Burden (Million $)

While this ICR notice goes into great detail why there was a change in the information being collected (and this was covered in the previously approved request) there is no indication why TSA expects the number of HME applications to continue to decline. There are also some unexplained decreases in the expected number of hours/application (3.25 vs 3.30 hours per application; minor to be sure) and burden cost per hour ($26.04/hr vs $27.52/hr; this may be partially due to rounding of the burden cost in the notice).

Industry Impact

I’m not sure where TSA gets its information to calculate the annualized number of applicants. It could be something as simple as extrapolating from the current rate of new and renewal applications (probably the most likely as this would be all internal data) or the TSA could be using some sort of survey data provided by the trucking industry or some sort of consultant. In any case an almost 2% decline in the annual number of HME applicants bodes ill for the HAZMAT transportation industry.
Unless there is an off-setting increase in the rate of application approvals (and I have not seen any TSA data on their rate of application approvals) or decrease in the number of HME revocations (no data seen there either) this means that there will be a continually shrinking pool of drivers qualified to haul HAZMAT loads. This can only lead to increased shipping costs.

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