WE HAVE APPROVED
THIS COLLECTION OF INFORMATION FOR SIX MONTHS TO ALLO THE AGENCY
SUFFICIENT TIME TO ADDRESS SEVERAL QUESTIONS. FIRST, IT APPEARS
THAT OSHA FORM 71 COULD BE REPLACED BY A CERTIFICATION AS DEFINED
AT 5 CFR 1320.7(K)(1). SECOND, IT IS NOT CLEAR WHY THE RECORD OF
TESTS OF HAZARDOUS ATMOSPHERES COULD NOT BE REPLACED BY A
CERTIFICATION ATTESTING THAT THE TESTS HAD BEEN DONE AND CORRECTIVE
ACTION TAKEN IF NEEDED. THIRD, THE RECORDKEEPING REQUIREMENTS AT
1917.50, CERTIFICATION OF MARINE TERMINAL MATERIALS HANDLING
DEVICES, APPEAR TO BE CERTIFICATIONS AS DEFINED AT 5 CFR
1320.7(K)(1). IF THEY ARE, OMB APPROVAL IS NOT REQUIRED, NOR SHOULD
THESE HOURS BE INCLUDED N THE INVENTORY. FOURTH, IT IS NOT CLEAR
WHY THE RECORDS OF THE RESULTS OF TESTS OF ELEVATORS AND ESCALATORS
AT 1917.116 COULD NOT BE CERTIFICATIONS. FIFTH, IT IS NOT CLEAR WHY
THE AGENCY REQUIRES PROOF OF "FINANCIAL STABILITY" AND A DETAILED
SCHEDULE OF FEES FROM PERSONS SEEKING ACCREDITATION, AS REQUIRED AT
1919.3(B)(5) AND (6). SIXTH, TH REPORTING REQUIREMENTS AT
1919.11(E) AND (F) APPEAR TO HAVE NO PRACTICAL UTILITY,
PARTICULARLY GIVEN THE REQUIREMENTS AT 1919.11(A), (B) AND (C). THE
AGENCY SHOULD ALSO ADDRESS THESE ISSUES, IF POSSIBLE IN THE
UPCOMING PROPOSED RULES ON PARTS 1915 AND 1918.
Inventory as of this Action
Requested
Previously Approved
07/31/1987
07/31/1987
10/31/1986
27,902
0
22,040
38,254
0
35,754
0
0
0
OSHA NEEDS THIS INFORMATION TO
ACCREDIT COMPANIES TO INSPECT AND PROVIDE CERTIFICATION FOR CRANES,
DERRICKS AND ACCESSORY GEAR USED IN LONGSHORING AND SHIPYARD
INDUSTRIES AND MARINE TERMINALS. USE OF THE OSHA FORMS 70, 71, AND
72, HAS PROVEN SUCCESSFUL, AND THEIR USE HAS SERVED AS AN AID TO
THE AGENCY AND THE INDUSTRY IN TRACKING CONDITIONS GERMANE TO
EMPLOYEE SAFETY AND HEALTH.
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.