his collection
is not approved because there was no rationle given for extending
the survey beyond Phase I that addressed the questions of practical
utility and statistically valid data collection. In fact, there
does not appear to have been much thought in how Phase I fit in
with the other 2 planned phase s, as noticed by the lack of answers
to Section B that's required for any statistical survey. FRA should
obtain its report from Phase I, and then evaluate if further
surveys are needed. If so, it should be clear in its request to OMB
how the burden imposed on the railroad industry is justified. One
important way to justify surveys in OMB submissions is to show that
the methods that are used to collect the information are
statistically valid so that policies can be developed from accutate
information.
Inventory as of this Action
Requested
Previously Approved
10/31/1998
0
0
1,536
0
0
0
0
0
0
This information collection centers on
a survey of railroad, labor, and industry management to ascertain
further data regarding safety culture, especially safety programs,
throughout the rail industry.
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.