Pursuant to
Section 3204(h) of the Paperwork Reduction Act and 5 CFR 1320.13,
we have serious concerns about the need and burden of the
recordkeeping requirements for this standard. In particular, it is
not clear that inspections monthly and after each emergency for
respriators that are not routinely used are necessary to assure
that the respirator is in satisfactory working condition. OSHA has
indicated in the October 1983 Regulatory Agenda that a rulemaking
is being considered for the respiratory protection standard with a
notice of proposed rulemaking scheduled for June 1984. We therefore
provide these comments for consideration during the Agency's
deliberations. We will review the Agency's response to our concerns
when the proposed changes to the recordkeeping requirements for
this standard are submitted to OMB for review under the Paperwork
Reduction Act 5 CFR 1320.
Inventory as of this Action
Requested
Previously Approved
09/30/1985
09/30/1985
4,334
0
0
3,342,831
0
0
0
0
0
INFORMATION IS TO BE COLLECTED BY
EMPLOYERS TO ASSURE THAT EMPLOYEES WHO MUST WEAR RESPIRATORY
PROTECTIVE DEVICES ARE PROPERLY PROTECTED AN ISSUED THE TYPE OF
DEVICES APPROPRIATE TO THE HAZARD.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.