OMB Approves TSA Pipeline Security ICR Update – 7-26-22

Yesterday, the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had approved an information collection request (ICR) “Extension without change of a currently approved collection” for the TSA’s “Pipeline Corporate Security Review” (1652-0056). I do not typically review ‘extension without change’ notices except that this one was TSA and it was approved with a change from OIRA.

Looking at the approval notice I quickly spotted a significant change in the approved burden (see table below); typically, a change in burden does not make an ICR update an ‘extension without change’.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	7/31/2023	36 Months From Approved	7/31/2022
Responses	331	0	20
Time Burden (Hours)	12,830	0	180

The Supporting Document for the ICR extension notes that the TSA had come back to OIRA last summer for an emergency change to this ICR to support the second security directive for pipelines. Yep, I remember that clearly. Unfortunately, the OMB Control Number History for this ICR does not list that emergency ICR revision approval. That confused me for a bit, but it’s all clear now.

It is a good thing that I did see and start investigating the situation. The ORIA file on this ICR now contains an updated copy of the Pipeline CSR Workbook that TSA surface inspectors use to conduct their corporate security reviews (CSR). The revised cybersecurity questions are found under the ‘Checklist IT’ tab in the spreadsheet. Somewhat generic questions, but that has to be expected in a questionnaire like this.