OMB Approves ICR Renewal for FRA EO 28

Yesterday the OMB’s Office of Information and Regulatory Affairs announced that it had approved the regular renewal of the information collection request (ICR) supporting the FRA’s Emergency Order # 28 (EO 28), the safety rules the FRA put into place after the crude oil train derailment, fire and explosions in Canada last summer.

The original ICR for EO 28 was a six-month emergency ICR granted by OIRA shortly after EO 28 was published. The table below shows the change in the burden estimates for the renewed ICR.

	Original ICR	Renewed ICR
Burden Responses	23,511,355	23,480,082
Burden Hours	1,981,133	205,404
Burden Cost	$ 0	$ 0

Part of the reduction in the burden estimate is due to the one time requirements in the EO that have already been taken care of. For example the EO requires railroads to establish a plan that identifies specific locations and circumstances when covered trains or vehicles may be left unattended; it is expected that railroads will have already established such plans so only a limited number of periodic revisions will be required.

The largest single reduction in the burden estimate comes from a change in the estimated time required to conduct train securement job briefings. The original ICR estimated that it would take 5-minutes for each briefing and the new estimate changes that to 30-seconds. The ICR supporting document (download link) does not explain the change in time, but I suspect that it is due to the fact that these briefings have been conducted numerous times with each employee so they are now recaps instead of full briefings. This specific change reduces the time burden from 1,950,000 hours to 195,000 hours.

As is typical for DOT agencies, there are not cost estimates included in the ICR or its justification.