OMB Approves Chemical Release ICR Revision – 2-16-21

On Tuesday the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had approved a “non-substantive change request” for the information collection request (ICR) from the Chemical Safety Board for “Accidental Release Reporting”. There were no public notices published for this change.

The approved changes consisted of editorial corrections to the reporting form [.docx download link] and associated instructions [.docx download link]. As of this writing, the form and instructions on the CSB site do not reflect the changes approved this week.

Commentary

The editorial changes approved this week are non-substantive for the most part. There was one substantial revision in the opening paragraph in the instructions. The ‘current’ (on the web site) version notes that: “You are required to report an accidental release within eight hours of a qualifying event.” The original version posted to the web site said: “within four hours”; the requirement set out in the notice of proposed rulemaking, but changed in the final rule. According to the documents submitted to OIRA this change from ‘four’ to ‘eight’ was part and parcel of the other revisions made to the form this week. Interesting.

It is always encouraging to see Federal agencies take the time and effort to clean up editorial problems with their publications. Unfortunately, it looks like the CSB is going to have to go back and cleanup some the changes made in this revision. For example, in the explanation for filling out block e, ‘Describe the accidental release’, the revised form includes this exquisitely clear piece of creative writing:

“Description omaterials in process and released prior to and after the incident. and quantity of ,re, temperatureInclude equipment pressu. releasef accidental”

 And in the naming of block g in the instructions we find this editorial nightmare:

“g. Name of the materials involved in accidental release using the Chemical Abstract Service (CAS) ).Add more lines if more than two chemicals(. number(s) or other appropriate identifiersregistry”

 

I am a strong supporter of the CSB and their investigative and reporting efforts, but they have had a lot of administrative problems (see here and here) with this ICR. Someone really needs to get this fiasco under control.