Approved as
amended by DOL's 2/5/98 memorandum to OMB. In addition, DOL/OSHA
will meet the following conditions: 1) Approval through December
1998 will allow OSHA to continue work on the validation study of
data quality in this initiative, which OMB strongly endorses. DOL
intends to continue with the on-site records audits and to complete
the anlaysis by the end of May, and will brief OMB in June on the
results of this analysis. OMB recommends that these audits of
quality be made an ongoing part of the Data Initiative. 2) Initial
results of the analysis of Overlap firms (surveyed by both BLS and
OSHA) indicate that there may be insufficient consistency between
the two data sets. DOL (BLS and OSHA) shall investigate the sources
and reasons for data discrepencies through further analysis of the
Overlap firms. This additional analysis shall be completed prior to
the next request for PRA clearance of the Data Initiative. OMB will
forward specific issues for DOL to consider in this work
separately. 3) DOL will complete comparison of the Data Initiative
data with data from the IMIS system by September 1998, and will
report on this analysis as part of the next request for clearance.
4) DOL will not field the 1998 Data Initiative until it has
developed and OMB concurs with a policy on how DOL will treat
non-responding firms and how this treatment will be communicated to
survey recipients. 5) Given the problems that the data quality
analysis shows with smaller firms and the ongoing work being done
on data quality, OMB does not at this time approve expansion of the
Data Initiative to firms with fewer than 50 employees (with the
exception of logging firms). Expansion from 60+ to 50+ employers
should be sufficient and allows for comparisons with BLS and other
standards sample strata. DOL may pilot test collection from firms
with 40-49 employees to determine the quality of these data. 6) DOL
will continue to explore means of collecting this information less
than annually from the universe, including sampling and rotating
SIC codes as well as other means of reducing burden while
maintaining data quality.
Inventory as of this Action
Requested
Previously Approved
01/31/1999
01/31/1999
02/28/1998
80,000
0
80,000
35,000
0
35,000
0
0
0
To meet the Agency's program needs,
OSHA is proposing to continue its data initiative to collect injury
and illness data and the number of workers and hours worked from
establishments in portions of the private sector and some State
government agencies.
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.