ATTACHMENT 3

Copy of EPA’s Consultations Request to Potential Respondents
Date: March 26, 2009

From: Amuel Kennedy/DC/USEPA/US 

To: [Addressees]

Subject: Request for Comments on Information Collection Request Renewal for 

Notification of Substantial Risk of Injury to Health and the Environment under TSCA Section 

8(e); EPA ICR No. 0794.12, OMB Control No. 2070-0046

On February 13, 2009, EPA published a Notice in the Federal Register (74 FR 7227) for 

Notification of Substantial Risk of Injury to Health and the Environment under TSCA Section 

8(e) Request for Comment on Renewal of Information Collection Activities.; EPA ICR No. 

0794.12, OMB Control No. 2070-0046.”

(http://www.epa.gov/fedrgstr/EPA-TOX/2009/February/Day-13/t3054.htm) This Notice refers to 

EPA's intention to request renewed Office of Management and Budget (OMB) clearance of an 

information collection related to reporting and recordkeeping requirements for TSCA Section 

8(e) submissions.

In addition to public notice and comment requirement that the above Notice initiates, OMB 

regulations at 5 CFR 1320.8(d)(1)) require agencies to consult with potential respondents and 

data users about specific aspects of an information collection request (ICR) before submitting it 

to OMB for review and approval, regardless, in the case of ICR renewals, of whether changes 

have or have not been made to the collection activity.

As part of this required consultation, I am contacting you to solicit your input. I will also 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:

Are the data EPA seeks under this ICR available from any public source, or already collected by 

another EPA office or by another agency? If so, where can the data be found?

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

instructions? 

Would you be interested in an electronic/data submission option? What type of alternative 

would you be most likely to utilize – web form, diskette, CD-ROM? 
For electronic submission, how should signature requirements be handled –

Private Key Infrastructure, PINS and passwords, signed paper cover sheet? 

How does TSCA CBI affect your choice or use of an electronic medium? Would you be more 

inclined to submit TSCA CBI on diskette than on paper and what benefits would you realize 

(e.g., burden reduction, greater efficiency in compiling information, etc).

Do you agree with EPA's estimated burden and costs (the ICR addresses only the 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 as used by

EPA inaccurate or inappropriate, explain your rationale.

You can access the Federal Register Notice, the ICR supporting document, and any public 

comments received to date at: http://www.regulations.gov/fdmspublic/component/main

- select Advanced Search link at the top of the page

- select Docket from drop-down menu

- select EPA in the Agency drop-down menu

- enter EPA-HQ-OPPT-2007-0378 in the Docket ID field

- scroll down to Submit

- then click on the Docket ID in the search results for a listing of the documents within the 

docket

Your timely response will be greatly appreciated. If you have any comments in response to the 

above questions, or with respect to any other part of the information collection, please respond 

by return e-mail by April 14, 2009. 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.

Thank you for your assistance. 

Sincerely yours,

Amuel Kennedy

Environmental Protection Agency