ed comment on an Initial Regulatory Flexibility Analysis (IRFA) and Updated Economic Analysis following the completion of a Small Business Advocacy Review (SBAR) Panel for the TSCA proposed rule for reporting and recordkeeping requirements for per- and polyfluoroalkyl substances (PFAS). 87 Fed. Reg. 72439. EPA states that it seeks public comment on all aspects of the IRFA and Updated Economic Analysis, including underlying data and assumptions in developing its estimates, as well as on certain items presented in the IRFA for public comment and related to the protection of CBI. Comments are due December 27, 2022. More information is available in our November 29, 2022, memorandum.EPA Adopts NAICS Codes For TRI Reporting: On November 28, 2022, EPA published a final rule updating the list of North American Industry Classification System (NAICS) codes subject to reporting under the Toxics Release Inventory (TRI) to reflect the Office of Management and Budget (OMB) 2022 NAICS code revision. 87 Fed. Reg. 72891. OMB updates the NAICS codes every five years. EPA is implementing the 2022 codes for TRI Reporting Year 2022 (i.e., facilities reporting to TRI are required to use 2022 NAICS codes on reports that are due by July 1, 2023). EPA notes that the actual data required by a TRI form do not change as a result of this rulemaking, nor does the rule affect the universe of TRI reporting facilities that are required to submit reports under the Emergency Planning and Community Right-to-Know Act (EPCRA). The final rule will be effective December 28, 2022.EPA’s FY 2023 Top Management Challenges Include Providing For The Safe Use Of Chemicals: Under the Reports Consolidation Act of 2000, each agency’s inspector general must prepare an annual statement summarizing what the inspector general considers to be “the most serious management and performance challenges facing the agency” and to assess briefly the agency’s progress in addressing those challenges. On November 29, 2022, EPA’s Office of Inspector