Tuesday, November 2, 2010

Chemical Security Awareness Training Program ICR to OMB

Yesterday the Office of Management and Budget (OMB) reported that the DHS /Sector-Specific Agency Executive Management Office (SSA EMO) had submitted an Information Collection Request (ICR) renewal application for their Chemical Security Awareness Training program last Friday. According to that report the submission coincided with the publication of the required 30-day notice in the Federal Register, unfortunately the cited notice (75 FR 52768) was actually the 60-day notice that I previously reported. I have yet to see a 30-Day Notice on this ICR in the Federal Register.

This sounds like one of those administrative snafus that occur from time to time. OMB cannot complete their review of ICR application until they look at any public comments filed on the 30-day notice and that time clock cannot start until the notice is actually published in the Federal Register. Based on the history of this (and most) ICR there won’t be any public comments to review.

The current ICR for this program (1607-0009) expired on Sunday so DHS cannot require anyone to submit the personal information needed to complete the training program. Since this is a voluntary program and the user’s employer gains the potential benefit from the user completing this information (not DHS) this ICR is not much more than a legal formality.

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