Friday, July 30, 2021

Review Filing Comments on 30-day ICR Notices

Yesterday I published a short notice about the 2nd revision to an information collection notice (ICR) for the Chemical Facility Anti-Terrorism Standards (CFATS) program. In addition to the change in the end of comment date that was presumably the reason for the 2nd revision, there was also a change in the language describing how to submit comments on the ICR. This online submission of comments on the 30-day ICR notices is a change from the old method of emailing the comments to the action officer at OMB’s Office of Information and Regulatory Affairs. Comments for 60-day ICRs are still posted (except for TSA) to

Of course, it was easier still when you just had to email the comments to the OIRA action officer for the ICR. I suspect, however, that this on-line process was initiated to weed out ‘letter writing’ campaigns that many activist organizations use to ‘influence’ the OIRA approval process. Those quotes are because those organizations know that OIRA (nor any other federal agency) is actually influenced by being inundated with multiple duplicate comments. No the organizations are usually using those campaigns for fund raising efforts.

For a detailed description on how to actually follow those instructions, or an easier way that I found, see my article at CFSN Detailed Analysis - - subscription required.

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