Attachment 6

Consultation Process: EPA’s Solicitation for Comments

September 25, 2008

Dear [addressee]:

I am contacting you to solicit your comments on the renewal information
collection request (ICR) for the Partial Update of the TSCA Section 8(b)
Inventory Data Base, Production and Site Reports (OMB Control No.
2070-0162).  The Notice for the ICR renewal and solicitation of comments
was published in the Federal Register on September 5, 2008 (73 FR
51805).

The Office of Management and Budget (OMB) regulations that implement the
Paperwork Reduction Act require federal agencies proposing to renew an
ICR to consult with potential respondents and data users prior to
submitting it to OMB for review and approval.  This is to be done
regardless of whether changes have or have not been made to the
collection activity.  This consultation requirement is in addition to
providing the public with 60 days to comment on the proposed collection
activity.  

	This information collection request addresses the TSCA Section 8(b)
reporting and recordkeeping requirements associated with the Inventory
Update Reporting (IUR) rule, which is administered by the Environmental
Protection Agency (EPA) under the Toxic Substances Control Act (TSCA)
(40 CFR part 710).  Under section 8(b) (15 USC 2607), the EPA is
required to compile and keep current, via periodic inquiry, the
Inventory of Chemical Substances in Commerce (TSCA Inventory). The TSCA
Inventory is a listing of chemical substances manufactured, imported or
processed for commercial purposes in the United States. Companies that
manufacture, including import, listed chemicals may be required to
report information about these chemicals - the identity of the
chemicals, the amounts manufactured or processed, certain details about
their manufacture, and other data. This information is used by EPA and
other government agencies to identify potential use and exposure
scenarios so that they may protect human health and the environment.

Following is a list of questions regarding this ICR renewal. Your
meaningful and timely answers will help us develop this renewal ICR.  

QUESTIONS

1.	INFORMATION COLLECTION 

	Is the information that the Agency seeks under this ICR available from
any public source, or already collected by another office at EPA or by
another agency?  If yes, where can the Agency find the data?

	Is it clear what is required for data submission?  If not, are there
any suggestions for clarifying instructions?  

2.	ELECTRONIC ALTERNATIVES

	Are you interested in using an electronic reporting/data submission
option?  Current electronic reporting alternatives include the use of
encrypted Internet submissions via the EPA’s Central Data Exchange
(CDX) and magnetic media-based submissions on CD-ROM.  Where a reporting
requirement includes a signature requirement, consider whether a secure
electronic signature method (such as electronic signature credential) is
appropriate, whether a less secure method (such as the use of PINS and
passwords) would be more appropriate, or, if data are submitted on
CD-ROM or disk, whether a signed cover sheet may be sufficient for the
Agency’s purposes.

	How does CBI affect your choice or use of an electronic medium? Would
you be more inclined to submit CBI electronically (i.e., CDX, CD-ROM,
etc.) than on paper and what benefits would you realize (i.e., burden
reduction, greater efficiency in compiling the information, etc.)? 

3.	BURDEN COST ANALYSIS

Do you agree with EPA’s estimated burden and costs (note that the ICR
addresses only costs associated with paperwork)?  Are the Bureau of
Labor Statistics (BLS) labor rates accurate? If you have any reason to
consider the BLS labor rates inaccurate or inappropriate as used by EPA,
explain your rationale.

Please note that, if you take this opportunity to provide input, your
name, affiliation, phone number, and any information you provide (e.g.,
copies of emails) will be incorporated and attached to the ICR
supporting statement which will be a public document.  In addition, you
may be contacted by the OMB Desk Examiner for this ICR to verify the
accuracy of any comments as reported in the ICR by EPA.

Your response by November 4, 2008 will be greatly appreciated.  Your
timely response, along with consultation responses from others and
public comments resulting from the FR notice, will be considered as we
prepare a final document for OMB review.  Thank you for your assistance.


Sincerely, 

Chenise Farquharson

U.S. Environmental Protection Agency

EPA East, Rm 4134D

Office of Pollution Prevention and Toxics 

1200 Pennsylvania Ave NW, Mail Code-7405M

Washington, DC 20460

Phone (202) 564-7768

Fax (202) 564-4775

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