Saturday, March 1, 2014

EPA Publishes TRI 60-day ICR Notice

The Environmental Protection Agency (EPA) is publishing a 60-day information collection request (ICR) renewal notice in Monday’s Federal Register (79 FR 11783-11787; available on line today) for their Toxic Release Inventory program. The ICR covers the forms that covered facilities are required to use to report information under 42 USC 11023 and 42 USC 13106.

ICR Data

The ICR covers the use of 2 forms; TRI Form R with Schedule 1 and Form A 5-5-2011. The currently approved burden estimate and the new burden being submitted in this ICR are shown in the table below. This ICR notice shows a slight increase in the burden imposed by this collection.

OMB Control No: 2025-0009
Current ICR
Proposed ICR
Time Burden
Cost Burden

The cost burden is obviously not increasing from $0 to $183 Million. The OMB’s Office of Information and Regulatory Affairs (OIRA) is apparently on-again off-again about how it reports ICR cost burdens. The OIRA web page for the current ICR shows no cost burden, a blatant misrepresentation of facts.

Burden Change

The ICR notes that there are a number of factors that go into their increase in estimated burden associated with this ICR. Those include:

• Change in reporting requirements for hydrogen sulfide;
• Addition of o-nitrotoluene reporting requirements; and
• A slight increase in the number of reporting facilities.

Form Changes

The notice also reports that the EPA is making some changes to the reporting forms, but does not expect that these changes will materially change the time burden in completing the submissions. Those changes include:

• Add an optional extension to all phone numbers;
• Add an optional field to allow facilities to indicate the section of a water body that received the surface water discharge; and
• EPA proposes rewording the heading titles for 5.4.1 and 5.4.2.

Public Input

As required by 44 USC 3506(c)(2) the EPA is soliciting public comments on this ICR renewal. Comments may be submitted via the Federal eRulemaking Portal (; Docket #EPA-HQ-OEI-2013-0803). Comments should be submitted by May 2nd, 2014.


I must say that this is the most complete and informative ICR (other than the PSP ICR for CFATS which is in an entirely different category) notice that I have seen. In my opinion this is the type of information that should be included in an ICR notice every time that there is any change in the underlying collection. The EPA is to be commended for their exemplary efforts in preparing this document.

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