Thursday, February 17, 2022

Review - EPA Publishes EPCRA 30-Day ICR Notice

Yesterday, the EPA published a 30-day information collection request (ICR) renewal notice in the Federal Register (87 FR 8836-8837) for “Emergency Planning and Release Notification Requirements (EPCRA Sections 302, 303, and 304)”. This renewal request does not reflect any programmatic changes, just changes in the reporting history during the period covered by the currently approved ICR.

Normally, I do not pay a great deal of attention to these routine IRC renewals. They are typically just boiler plate repeats of previously submitted data. The EPA is one of the agencies that does update its burden estimates to reflect the changes in data submission over time. This time, however, a comment in the explanation for the changes in estimate portion of the notice caught my attention:

“The reduction in state and local government burden estimate of approximately 15,607 hours annually, is attributable to the reduction in the numbers of SERCs (or TERCs) and LEPCs (or TEPCs) in this ICR compared to the previous ICR (new total of 3,052 reduced from 3,556).”

The EPA does not explain the change in the number of  SERCs/LEPCs in the supporting documents for the simple reason that they have no control over those organizations. Congress established this important chemical safety program but it has provided for little to no oversight and no organizational control of the program at the Federal level. The decline in the numbers of reported organizations in this ICR notice make it clear that Congress needs to take a closer look at this program.

For more details about the changes in the numbers being reported by EPA, including a look at the history of the numbers being reported, see my article at CFSN Detailed Analysis - - subscription required.

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