TTN/Economics & Cost Analysis Support
OAQPS Economic Analysis Resource Document
6.3 The Paperwork Reduction Act (PRA)
| In many rulemakings, various recordkeeping,
reporting, labeling, testing, and other requirements are included to help
EPA verify compliance with the rule after it has been promulgated. Under
the PRA, the Agency is required to estimate the burden hours
associated with the recordkeeping and reporting requirements and to weigh
this burden against the practical utility of the information
collection. This analysis must be presented to OMB for review in a standardized
document known as an ICR.
In general, an ICR is composed of the following elements:
- a summary of the collection of information;
- a description of the need for, and proposed use of, the information;
- a description of the likely respondents, including the number of respondents
and the frequency of response; and
- an estimate of the total annual reporting and recordkeeping burden
that will result from the information collection.
An outline for a typical ICR is presented in Table 6-3.
The ISEG analyst may play a role in or be primarily responsible for preparing
estimates of burden associated with recordkeeping and reporting requirements
presented in Section 6 of the ICR. The workgroup chair for the rulemaking
is usually responsible for preparing the remainder of the ICR. Cost and
burden estimates should reflect any reporting and recordkeeping costs
estimated in the cost section of the EIA. It is important to note, however,
that the reporting and recordkeeping costs included in the ICR are estimated
over a period of 3 years. In contrast, the reporting and recordkeeping
costs estimated in the cost section of the EIA span the entire period
of analysis considered in the EIA. These estimates should include the
total time and resources needed to
Analysts should consult the Office of Policy (OP) ICR Handbook ( EPA, 1998e)
when preparing recordkeeping and reporting cost estimates to be included
in an ICR.
- review instructions;
- develop systems for the purpose of collecting, validating,
and verifying information; processing and maintaining information;
and disclosing or providing information;
- adjust current practice to comply with the recordkeeping and
- train personnel to respond to an information collection;
- search data sources;
- complete and review the information collection; and
- transmit or disclose the information.
As part of the statement of need for the proposed action, the ICR should
also describe the practical utility of the information to be collected,
maintained, or disclosed. 5 CFR 1320 defines practical utility as the
actual...usefulness of the information to or for an agency, taking into
account its accuracy, validity, adequacy, and reliability, and the agencys
ability to process the information it collects...in a timely fashion.
Practical utility is typically established by qualitatively describing
the use of the information. The discussion of practical utility is usually
left to the workgroup.