1. ExxonMobil Chemical Company
M. David Adenuga on behalf of ExxonMobil Chemical Company
moyinoluwa.d.adenuga@exxonmobil.com
Oxo Americas Regulatory Affairs Advisor


2. Eileen Conneely 
Eileen_Conneely@americanchemistry.com
American Chemistry Council
High Phthalates Panel
700 2[nd] Street NW
Washington, D.C. 20002

3. Dow Silicones Corporation
2200 W Salzburg Rd., Auburn, MI 48611 
Michele.Buckingham@dow.com; 
989.636.1243
Director EHS&S, Consumer Solutions

4. American Chemistry Council's Silicones Environmental, Health, and Safety Center (SEHSC),
700 Second St., NE Washington, DC 20002 
Karluss Thomas  - Karluss_Thomas@americanchemistry.com
Sr. Director







Subject: Title: Procedures for Requesting a Chemical Risk Evaluation under TSCA ICR Numbers [OMB Control No.: 2070-0202]
I am contacting you to solicit your comments on the renewal of the Information Collection Request (ICR) for the collection of information to accompany a manufacturer requested risk evaluation under the Environmental Protection Agency's (EPA) Risk Evaluation Rule. The Toxic Substances Control Act (TSCA) requires EPA to allow manufacturers to request that EPA conduct a risk evaluation on a chemical or group of chemicals for which they manufacturer.  The final rule outlined the criteria and information chemical manufacturers must provide for EPA to consider a chemical substance for risk evaluation. The information collection activities covered by this ICR renewal are those carried out by a chemical manufacturer in requesting a specific chemical risk evaluation under TSCA be conducted by EPA. This information is necessary in order for EPA to review information covered by chemical manufacturers and determine if the chemical substance is suitable for risk evaluation. 
      
      The Paperwork Reduction Act (PRA) requires that agencies receive Office of Management and Budget (OMB) clearance before requesting most types of information from the public.  In order to receive OMB clearance, federal agencies prepare draft ICRs providing an overview of the information collection and estimates of the cost and time for the public to respond.  The agencies consult with potential respondents and the public about the ICR and, where appropriate, incorporate comments received.  The draft ICR is then sent to OMB for its review and approval. These ICRs are periodically renewed. 
      
      The existing ICR for the Risk Evaluation rule is being renewed. Entitled, "Agency Information Collection Activities; Procedures for Requesting a Chemical Risk Evaluation under TSCA (EPA ICR No. 2559.03; OMB Control No. 2070-0202) (Renewal)". OMB requires federal agencies to consult with nine or fewer potential respondents prior to submitting the ICR renewal to OMB for review and approval.  This consultation requirement is in addition to providing the public with 60 days to comment on the proposed collection activity. The notice announcing the ICR renewal and solicitation of comments was published in the Federal Register on January 28, 2020. See docket number EPA-HQ-OPPT-2016-0654 at http://www.regulations.gov/ to access the Federal Register Notice, the ICR supporting document, and any public comments received to date. There have been no regulatory changes since the last ICR in 2017.

      Please note that, if you take this opportunity to provide input, your name, affiliation, phone number, and any information that you provide (e.g., email copies) 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 reviewing this ICR renewal to verify the accuracy of any comments as reported in the ICR by EPA. To comment on this ICR, please respond to this email, or post comments in the docket at  http://www.regulations.gov/. 
      
      EPA solicits your input on the following questions.   

1.            INFORMATION COLLECTION 

                (a) 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?

                (b) Is it clear what is required for data submission?  If not, are there any suggestions for clarifying instructions? 
2.            ELECTRONIC SUBMISSION
      (a) How would you rate your overall experience using the electronic tool (Central Data Exchange or CDX)?  

      (b) If you encountered difficulties, how can EPA improve the process? 

3.         	CLARITY OF INSTRUCTIONS
	
 The ICR is intended to requires/request that requesters provide certain data so the Agency can utilize it, based on the instructions is it clear what is required in a submission and how to submit the information?

	(b) If it is not clear, how can EPA improve the process?

4. 	BURDEN COST ANALYSIS

      (a) Do you agree with EPA's estimated burden and costs related to submitting information for a manufacturer requested risk evaluation?  

      (b) 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, please explain your rationale. 
      
      
      Your timely response to the questions will be greatly appreciated.  We hope to receive your responses by June 24, 2020 so we can consider those responses, along with other consultation responses and public comments resulting from the Federal Register notice, at the same time as we prepare a final document for OMB review.  Thank you for your assistance. 

Sincerely, 

Susanna W. Blair 
Immediate Office  -  Office of Pollution Prevention and Toxics
Phone (202) 564-4371

