Friday, May 1, 2015

OMB Approves Emergency FRA ICRs

Yesterday the OMB’s Office of Information and Regulatory Affairs (OIRA) reported that it had approved three emergency information collection requests (ICR) from the DOT’s Federal Railroad Administration. These ICRs support recent actions taken by the FRA to increase the safety of highly-hazardous flammable trains. These ICR’s specifically address information collection requirements for:

∙ FRA Safety Advisory 2015-01 (OMB # 2130-0607);
∙ FRA Safety Advisory 2015-02 (OMB # 2130-0608); and
∙ FRA Emergency Order No. 30 (OMB # 2130-0609).

In each case OIRA approved the emergency ICRs with an end date of October 31st, 2015. The FRA request did note that they intended to renew the ICRs for the two safety advisories in regular order, but that the ICR for the emergency order would be superseded by the ICR for HM-251, the HHFT rulemaking expected to be published later this month.

Burden Estimates

Here are the burden estimates for these three ICRs:


2130-0607
2130-0608
2130-0609
Annual Responses
351,000
50
25
Burden Hours
6,333
100
1,000


The burden estimate for 2130-0607 is based upon (WORD® download) an estimate of the number of automated reports from Wheel Impact Load Detectors (WILD) along routes traveled by affected trains. The subsequent information collection will be the submission of work orders to deal with the maintenance requirements specified in the safety advisory. There is no indication of the basis for this number of estimated WILD reports or if it takes into account the recommended (but unspecified number of) new WILD installations.

The burden estimate for 2130-0608 is based upon (WORD® download) the FRA estimate of the number of accidents involving HHFT trains each year; they are estimating 50 such accidents. This under-estimates the number of responses because the FRA may request information from both a railroad and multiple stakeholders for any given accident. The actual number of requests per accident would be difficult to estimate.


The burden estimate for 2130-0609 is based upon (WORD® download) the FRA estimate of the number of petitions the FRA expects to receive for the use of alternatives to the safety requirements outlined in the Emergency Order.

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