Pursuant to the
Paperwork Reduction Act, we have not approved the re porting
requirements proposed in the ETA rule issued on August 24,1990
entitled "Labor Standards for the Registration of Apprenticeship
Pro grams." The agency has not demonstrated that the paperwork
burden that would be placed on state apprenticeship agencies and
sponsors is the "least burdensome necessary for the proper
performance of the agency's functions." Further, the agency has not
demonstrated the practical utility of the proposed collection--how
the information will actually assist the agency in improving
apprenticeship program quality. ETA sha in its final rule consider
alternative, less burdensome methods of mon itoring state
apprenticeship activities and shall address the paperwor burden
concerns listed below: 1) No justification is offered to explai why
the large increase in reporting requirements is necessary to im
prove quality of state programs. 2)The agency does not discuss why
it has raised its annual burden estimates in the currently approved
sec tions. Section 29.5(b) burdens are now estimated at 4 hours per
sponso up from 2 hours. Section 29.9 requirements have at least
doubled. 3)Th additional paperwork burden proposed may be so great
as to drive spon sors and states to reduce their apprenticeship
activities. When the in formation collections in the final rule are
submitted for ETA shall place the OMB comment number 1205-0223 in
it OMB is not providing an approval number at this time.
Inventory as of this Action
Requested
Previously Approved
01/31/1991
01/31/1991
04/30/1991
192,040
0
192,040
37,086
0
37,086
0
0
0
NEEDED BY EMPLOYERS, APPRENTICES, AND
STATE APPRENTICESHIP AGENCIES TO SET FORTH LABOR STANDARDS TO
SAFEGUARD THE WELFARE OF APPRENTICES AND EXTEND THE APPLICATION OF
SUCH STANDARDS BY SUBSCRIBING POLICIES AND PROCEDURES CONCERNING
THE REGISTRATION FOR CERTAIN FEDERAL PURPOSES OF ACCEPTABLE
APPRENTICESHIP PROGRAMS.
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.