Jul 18, 2005· Comments submitted by Howard J. Feldman, Director, Regulatory Analysis and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-OEI-2004-0006-0007
API offers comments on the ICR, which can be summarized as follows: ?EPA needs to address several aspects of burden that the Agency has so far not adequately addressed, and should undertake a new survey to more accurately characterize TRI burden; and ?It is essential that EPA follow through on its commitment to promulgate a TRI burden reduction rule.