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Mattheisen, Mike

From: Mattheisen, Mike

Sent: Wednesday, October 28, 2015 2:51 PM

To: Scott_Jensen@americanchemistry.com; 'gainesj@socma.com'; 

'daniel.a.turner@dupont.com'; 'wohlschlegele@api.org'; 'MSCANLAN@vermontlaw.edu'; 

'stacy@aafa.org'; 'sstein@edf.org'; 'ken@ewg.org'; 'eheyd@nrdc.org

Subject: Request for Assistance; Public Comment on the Proposed Renewal of an Information 

Collection Request (ICR) Concerning Reporting Chemical Export Information to the U.S. EPA 

under Section 12(b) of TSCA.

On October 28, 2015, the U.S. Environmental Protection Agency (EPA) published a notice in the Federal 

Register (80 FR 66000) announcing that EPA intends to submit an existing Information Collection Request 

(ICR) that is scheduled to expire in August 2016 to the Office of Management and Budget (OMB) for renewal, 

and requesting public comment. The ICR applies to section 12(b) of the Toxic Substances Control Act (TSCA), 

which requires any person who exports or intends to export a chemical substance or mixture that is regulated 

under TSCA sections 4, 5, 6 and/or 7 to notify EPA of such export or intent to export. This requirement is 

described in more detail at 40 CFR part 707, subpart D. Upon receipt of notification, EPA advises the 

government of the importing country of the U.S. regulatory action that required the notification with respect to 

that substance. EPA uses the information obtained from the submitter via this collection to advise the 

government of the importing country. (“Agency Information Collection Activities; Proposed Renewal of the 

Collection under OMB Control No. 2070‐0030, EPA ICR No. 0795.15; Comment Request.” See, 

http://www.gpo.gov/fdsys/pkg/FR-2015-10-28/pdf/2015-27470.pdf.) 

In addition to the public comment requested by the notice in the Federal Register, OMB regulations at 5 CFR 

1320.8(d)(1) require agencies to consult with potential respondents and data users about specific aspects of an 

ICR. As part of this required consultation, I am contacting you to solicit your input. Please note that if you take 

this opportunity to provide input, your name, affiliation, e‐mail address, phone number and any information you 

provide (e.g., copies of e‐mails) will be incorporated and attached to the ICR supporting statement, which will 

be a public document. In addition, the OMB Desk Examiner for the ICR in question may contact you to verify 

the accuracy of any comments EPA identifies in the ICR. 

EPA solicits your input on the following questions: 

1. Are the data that are required to be submitted under this ICR available from any other public source 

that you are aware of, or are they data already collected by another EPA office or by another 

agency? If so, where is the data publicly available? 

2. Is the data submission requirement clear? If not, do you have any suggestions for how the data 

submission can be clarified? 

3. Data is required to be submitted to the Document Control Office (DCO) at EPA Headquarters in 

Washington, D.C., by hand or by U.S. Postal Service. Is this a good method, or is there a better 

alternative? 

4. Do you have any concerns about the submission of confidential business information (CBI)? 

5. Do you agree with EPA’s estimated burden and costs? (ICRs address 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, please 

explain your rationale. 

To access the Federal Register notice, the ICR supporting document (including the economic analysis), and any 

public comments received, go to www.regulations.gov and search using EPA‐HQ‐OPPT‐2015‐0435. Click on 

any of the documents listed within the docket to read the document. 
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If you have any comments in response to the above questions, or with respect to any other part of this ICR, 

please respond by return e‐mail by COB on Monday, December 28, 2015. EPA will consider those responses, 

as well as any public comment received in response to the Federal Register notice identified above, in preparing 

a final document for OMB review. 

Mike Mattheisen 

Assistant Branch Chief 

Chemical Information and 

 Testing Branch/CCD/OPPT 

202-564-3077