Overview
Title
Agency Information Collection Activities; Extension of Collection; Comment Request; Notification Requirements for Coal and Wood Burning Appliances
Agencies
ELI5 AI
The Consumer Product Safety Commission wants people to share their thoughts on a rule about how information is shared for safety labels and manuals of coal and wood burning stoves. They want to make sure these guides are helpful, and people have until early February 2025 to say what they think before the current rules need a new review in March 2025.
Summary AI
The Consumer Product Safety Commission (CPSC) is seeking public comments on extending the approval of collecting information about notification requirements for coal and wood burning appliances. This involves providing important safety data on labels and manuals that come with these appliances, under the Paperwork Reduction Act of 1995. The comments are due by February 3, 2025, and the current approval from the Office of Management and Budget (OMB) is set to expire on March 31, 2025. The CPSC wants feedback on the necessity, accuracy, and methods of improving this information collection process.
Abstract
As required by the Paperwork Reduction Act of 1995, the Consumer Product Safety Commission (CPSC or Commission) requests comments on a proposed extension of approval of information collection regarding notification requirements for coal and wood burning appliances. The Office of Management and Budget (OMB) previously approved the collection of information under control number 3041-0040. OMB's most recent extension of approval will expire on March 31, 2025. The Commission will consider all comments received in response to this notice before requesting an extension of this collection of information from OMB.
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Sources
AnalysisAI
The document from the Consumer Product Safety Commission (CPSC) serves as a notice for public comments regarding the extension of an information collection process. This process pertains specifically to the notification requirements for coal and wood burning appliances. The CPSC is acting under the guidelines of the Paperwork Reduction Act of 1995 and is seeking input before requesting an extension of the existing information collection approval, which expires in March 2025.
General Summary
This Federal Register notice invites public opinion on the necessity and efficiency of the information collection mandated for manufacturers and importers of coal and wood burning appliances. The goal is to ensure that consumers have access to crucial safety information via appliance labels and manuals. This information arms users with knowledge about proper installation, operation, and maintenance to prevent accidents. The public has until February 3, 2025, to submit comments, and the CPSC has laid out specific methods for submitting these contributions.
Significant Issues or Concerns
While the document outlines the information needed from manufacturers, it lacks a detailed explanation of why this collection is necessary, which questions its practical utility. Additionally, the number of respondents and the burdens estimated by the CPSC are speculative, with little data provided to support these figures. The text also leaves unexplained the rationale behind specific clearance requirements, potentially leading to questions about their relevance and adequacy.
For a layperson, the document's use of legal and regulatory jargon without clear definitions could be intimidating or confusing. Moreover, the public is not informed about how their comments will be processed or taken into account, potentially discouraging engagement. There is also a lack of guidance on what constitutes sensitive information that should be kept from public electronic platforms, risking unnecessary disclosures.
Impact on the Public
Broadly, this notice affects consumers who rely on accurate and clear safety information for appliances that can pose significant risks if mismanaged. Should the CPSC successfully extend the approval, it signifies continued diligence in consumer safety, particularly concerning potential home hazards like fires. However, if the collection methods remain unclear or burdensome to manufacturers, the quality and availability of this information might suffer.
Impact on Specific Stakeholders
Manufacturers and importers of coal and wood burning appliances are directly impacted by the processes delineated in the document, as non-compliance might result in legal challenges or market disruptions. On the other hand, if the commentary leads to streamlining the requirements, these stakeholders could experience a reduced regulatory burden, potentially lowering costs.
Consumers stand to benefit significantly if the notice leads to improved safety protocols and clearer, more reliable information on appliance use. However, insufficient action from this process, or an overly complex compliance method, might limit these benefits.
In conclusion, while the document aims to maintain consumer protections through updated data collection, the lack of clarity and justification could weaken its intended impact unless addressed. Stakeholder participation in the commentary process could lead to constructive changes, provided their contributions are meaningfully analyzed and integrated.
Financial Assessment
In reviewing the financial aspects of the document, the total estimated annualized respondent cost is highlighted as approximately $795. This figure is derived from multiplying a total estimated annual burden of 17.5 hours by an average total hourly employee compensation rate of $45.41. The compensation rate is based on data from the U.S. Bureau of Labor Statistics concerning private industry workers in goods-producing industries. The financial computation indicates a meticulous approach to an average labor cost associated with compliance for respondents, in this case, identified as manufacturers and importers of coal and wood-burning appliances.
However, although the method for calculating this burden is clear, issues arise in connection with the assumptions made about the estimated number of respondents and the estimated time per response. It is noted in the document that there is a lack of supporting data for the estimated figures, which impacts the accuracy of the cost estimate. If, for instance, the number of annual submissions changes significantly, the projected cost of $795 could vary accordingly. This financial estimate forms a crucial part of understanding the impact of compliance but is less compelling due to such foundational uncertainties.
Further consideration could be given to elucidating the rationale behind the use of these specific rates and assumptions. This could address concerns about their accuracy and enhance the clarity of financial obligations stated. Moreover, while the cost figure is modest, expanded transparency about the calculations and underlying data would likely facilitate a more comprehensive assessment of the financial burden on responding entities.
While the financial summary appears adequate within its framework, it could benefit from a more detailed explanation of how the costs and assumptions are validated. Such enhancements could align with addressing one of the document's broader issues: the need for more extensive justification of regulatory and procedural approaches to ensure practical utility and clear communication to the public.
Issues
• The document does not provide a detailed justification for the necessity of collecting performance and technical data from manufacturers of coal and wood burning appliances, which might be necessary to establish its practical utility.
• The estimated number of respondents is based on assumptions without any supporting data, which could lead to inaccuracies in the burden estimate.
• The rationale behind the specific clearance requirements and how they were determined is not explained, which could lead to confusion or questions regarding their appropriateness.
• The text assumes a certain level of familiarity with legal and regulatory terms (e.g., 16 CFR part 1406, Section 27(e) of the Consumer Product Safety Act), which could be difficult for laypersons to understand.
• The document's language is somewhat bureaucratic and lacks clarity in parts where it discusses the obligations of manufacturers, potentially making compliance more difficult.
• There is a lack of detailed explanation of what constitutes 'confidential business information, trade secret information, or other sensitive or protected information' that should not be submitted electronically, possibly leading to inadvertent public disclosures.
• The request for public comments does not specify how the Commission intends to address the feedback received, which may discourage detailed public participation or the provision of useful information.