On Tuesday the OMB’s Office of Information and Regulatory
Affairs (OIRA) announced
that it had approved a “non-substantive change request” for the information
collection request (ICR) from the Chemical Safety Board for “Accidental Release
Reporting”. There were no public notices published for this change.
The approved changes consisted of editorial corrections to
form [.docx download link] and associated
instructions [.docx download link]. As of this writing, the form and
instructions on the CSB site do not reflect the changes approved this week.
The editorial changes approved this week are non-substantive
for the most part. There was one substantial revision in the opening paragraph
in the instructions. The ‘current’ (on the web site) version notes that: “You
are required to report an accidental release within eight hours of a qualifying
event.” The original version posted to the web site said: “within four hours”;
the requirement set out in the notice of proposed rulemaking, but changed in
the final rule. According to
the documents submitted to OIRA this change from ‘four’ to ‘eight’ was part
and parcel of the other revisions made to the form this week. Interesting.
It is always encouraging to see Federal agencies take the
time and effort to clean up editorial problems with their publications.
Unfortunately, it looks like the CSB is going to have to go back and cleanup
some the changes made in this revision. For example, in the explanation for
filling out block e, ‘Describe the accidental release’, the revised form
includes this exquisitely clear piece of creative writing:
“Description omaterials in process
and released prior to and after the incident. and quantity of ,re,
temperatureInclude equipment pressu. releasef accidental”
And in the naming of
block g in the instructions we find this editorial nightmare:
“g. Name of the materials involved
in accidental release using the Chemical Abstract Service (CAS) ).Add more
lines if more than two chemicals(. number(s) or other appropriate
I am a strong supporter of the CSB and their investigative
and reporting efforts, but they have had a lot of administrative problems (see here
with this ICR. Someone really needs to get this fiasco under control.