CSB Publishes 60-day ICR Renewal Notice for Chemical Incident Reporting
CSB Publishes 60-day ICR Renewal Notice for Chemical Incident Reporting
Today, the Chemical Safety and Hazard Investigation Board (CSB) published a 60-day information collection renewal notice in the Federal Register (88 FR 13086) for their “CSB Accidental Release Reporting Form”. This is the first renewal (there was a revision in 2021, but it did not change any burden information) for this collection since it was initially approved in 2020). A downward revision of the burden estimate is included in this notice.
Burden Change
This is a very short and spare notice. It provides new burden numbers without mentioning that they are changing or explaining the reason for the changes. The table below shows the original burden and the burden estimates for this renewal.
The Basis for the Change
It is not unusual for agencies to make significant changes in their burden estimates, especially on the first renewal. When the CSB published their initial estimate there was no data available upon which to base the estimate, this was a new reporting requirement. With three years since the chemical incident reporting rule went into effect, the CSB now has some actual reporting information upon which to base their new estimates. And we are in the relatively unusual position where they are able, and willing, to share regulatory reporting information.
Based upon the latest CSB reporting, there have been 231 incidents reported to the CSB under their new reporting rule between April 10th, 2020, and January 23rd, 2023. If we look at the two full years (2021 and 2022) that are included in the data, we see annual reporting numbers of 83 and 100 (average 91.5) Incidents, so the 100 reports per years looks to be a reasonable number for the purposes of this ICR renewal.
Of course, it would have been nice if the CSB had reported this supporting data in this notice.
Public Comments
The CSB is soliciting public comments on this ICR renewal. Unfortunately, the notice does not provide any information about how to submit comments, not even a Docket number for the Federal eRulemaking Portal. However, if you look at the alternative Federal Register listing for this notice, you will see (at the top of the page) a green ‘Submit Formal Comment’ box which links to the Portal with a docket number of CSB_FRDOC_0001-0028. Comments should be submitted by April 28th, 2023.