Sunday, March 10, 2013

OMB Approves Renewal of TSA CCSP ICR

On Friday the Office of Management and Budget (OMB) announced that they had approved the information collection request (ICR) renewal submitted by TSA for their Certified Cargo Screening Program (CCSP). The ICR renewal was submitted as a revision of the currently approved collection and was approved by OMB without change from what TSA requested.

As requested by TSA the approved ICR shows a large reduction in the estimated number of expected responses and burden hours. The number of expected annual collections reduced from 724,774 to 127,050 and the hours burden reduced from 718,482 to 143,768. As TSA explained it this way in their renewal application:

“TSA estimates for expected CCSP enrollments have decreased, resulting in a reduction in estimated burden. In light of this reduction in expected CCSP enrollment, TSA eliminated the TSA-approved validation firms from the CCSP in favor of continued TSA assessments. This eliminated the collection instruments and burdens associated with these firms.”

As I noted in my blog post on the 60-day ICR notice the situation is a little more complex than that. The original ICR was based upon the interim final rule for Air Cargo Screening (74 FR 47672) which included provisions for private sector entities doing validations of facilities doing air cargo screening and included air lines in the CCSP. The final ACS rule (76 FR 51848) eliminated both of those classes of respondents; the first because of the smaller number of facilities enrolling in the program allowed TSA to do the validations in-house; the second because the airlines were covered under a separate program.

Again, we see no estimated cost burden on the regulated community for collecting, maintaining and submitting the information required under the Air Cargo Screening rule. Only the federal government could assume that there was no cost associated with these actions.

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