Friday, July 20, 2012

OMB Approves Changes to HME ICR

On Thursday the Office of Management and Budget announced that it had approved the extension of the information collection request (ICR) for the TSA’s Security Threat Assessment program supporting the Hazardous Material Endorsement program for the Commercial Driver’s License.

The extension request was initially published in the Federal Register in 2010 (75 FR 52961-52962) to support changes in questions being asked on the questionnaire. That notice estimated that the ICR would annually require 300,000 respondents to spend 975,000 hours providing the requested data at a cost of $27 million. The 30-day notice published in 2011 (76 FR 36560) noted that the same 300,000 respondents would spend 978,000 hours with no cost estimate provided. The approved collection notice published this week approves a collection from 300,905 respondents spending 994,096 hours at a cost of $27.4 million. There is no explanation for the change in data.

The OMB did note that “the supporting statement currently shows estimates from 2009-2011”. This explains why they only approved the current revised ICR until the end of February next year, noting that the “next submission should estimate burden hours and cost for years 2012, 2013, and 2014”.

Interestingly the ICR approval notice notes that the Agency (TSA) received public comments on the ICR. There was no indication in the 30-day ICR notice that there had been any public comments received; which also meant that there was no TSA response to those comments. The whole purpose of the ‘publish and comment’ process is to ensure that there is some form of public input into the regulatory process and that the government agencies take that input into account.

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