OMB Action on CSB Accidental Release Reporting ICR

The CSB continues to have problems with its ‘Accidental Release Reporting’ information collection request. On Friday, the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had removed OMB Control # 3301-0001 “from OIRA's Inventory of Active Information Collections”, noting that the ICR extension had been improperly submitted. Later in the day OIRA announced that it had reinstated the ICR and was continuing to analyze the submission data.

According to the public record on the OIRA website, the only difference between the two data submission sets was a resubmission of the supporting document on 5-17-24. I can find no difference between that document and the version submitted on 5-14-24.

CSB published [removed from paywall] the 60-day ICR renewal notice on March 2^nd, 2023. OIRA approved an emergency extension of this information collection on April 28^th, 2023, so that it could complete the ICR approval process before the then current approval expired on April 30^th, 2023. CSB published the 30-day ICR extension notice on May 1^st, 2023. It looks like CSB published their 30-day notice and then failed to follow-up with the required supporting document for over a year.

The CSB’s authority to collect information via its Accidental Release Reporting program should have expired on June 30^th, 2023, but as a practical matter OIRA tolls expiration dates if a 30-day ICR has been submitted to allow agencies to continue to collect information pending OIRA’s increasingly-lengthy review. OIRA probably should have terminated this ICR sometime last year when it had not received the supporting documentation from CSB. Their failure to do so is probably an indication that the agency is having problems with their review process, which I suspect is part of the larger understaffing and underfunding problem of the OMB (and other government agencies).