Testing Requirements for Non-Bulk Packaging
(Formerly Testing Requirements for Packaging)
(Expiration date: July 31, 2007)
Justification #2137-0572
1. Circumstances that make the collection necessary.
The current OMB inventory for the number of responses for this information collection is 15,050. This is a typographical error. The correct number of responses should be 15,500.
2. How, by whom and for what purpose the information is to be used.
Performance-oriented packaging standards allow packaging manufacturers and shippers more flexibility in selecting more economical packagings for their products, customizing the design of packagings to better suit the transportation environment that they will encounter, encourage technological innovations, decrease packaging costs, and significantly reduce the need for exemptions.
3. Consideration of improved information technology.
The burden has been made as simple as possible. The information requested is necessary to ensure safe operations. Information is considered critical in evaluating the definitive requirements, tying a particular packaging or packaging system to an individual hazardous material. Because of the inherent dangers during transport, it is necessary to verify that the packagings and methods being used are safe and will adequately protect both life and property during transportation.
The Government Paperwork Elimination Act directs agencies to allow the option of electronic filing and recordkeeping by October 2003, when practicable. Electronic filing and recordkeeping is authorized. However, PHMSA does not require these records to be submitted to us, so it is not applicable.
4. Efforts to identify duplication.
There is no duplication, as the information is unique to specific situations.
Methods used to minimize burden on small businesses or other small entities.
The collection of this information is reviewed periodically to ensure that the requirements involving safety in the transportation of hazardous materials are kept to the necessary standards to protect all parties involved.
Consequences to Federal program or policy activities if collection were conducted less frequently.
These requirements are necessary to ensure that packaging containing hazardous materials are meeting prescribed safety standards for transportation in commerce.
7. Special circumstances affecting conduct of information collection activity.
This collection of information is generally conducted in a manner consistent with the guidelines in 5 CFR 1320.5 (d)(2).
8. Efforts to consult with persons outside the agency to obtain their views.
A Notice of Proposed Rulemaking under Docket HM-224B, “Hazardous Materials: Transportation of Compressed Oxygen, Other Oxidizing Gases and Chemical Oxygen Generators on Aircraft” was published in the Federal Register on May 6, 2004 (69 FR 25470) inviting public comment on the revision of this information collection. The comment period originally closed on August 13, 2004, but was extended until December 13, 2004. No information collection-related comments were received.
9. Explanation of decision to provide any payment or gift to respondents.
There is no payment or gift to respondents associated with this collection of information.
10. Assurance of confidentiality provided to respondents.
None of the data collected contain personally identifiable information (PII) or business confidential information. Therefore, no guarantees of confidentiality are provided to applicants.
11. Additional information for questions for a sensitive nature.
Not applicable. Information is not of a sensitive nature.
12. Estimates of Burden for collection of information.
NOTE: The current OMB inventory for the number of responses for this information collection is 15,050. This correct number of responses is 15,500. This typographical error will be noted in the RISC and OIRA Consolidated Information System (ROCIS).
Estimate of responses:
Additional responses resulting from HM-224B: 15,000 responses
Annual responses prior to HM-224B: 500 responses
Revised annual responses: 15,500 responses
HM-224B Final Rule changes:
It is estimated that approximately10 packaging firms will take approximately 5 hours to test and record an average of 50 packaging design types each year for the first year, and, approximately 3 packaging design types thereafter. The design type may be for a single packaging, or a series of packagings made to the same design. Therefore, a test record is not required to be completed for each packaging, but of each design.
10 packaging firms x 50 packaging design types to test and record =
10 x 50 =
500 additional annual responses.
Estimate of annual burden hours prior to HM-224B Final Rule changes:
It is estimated that 5,000 packaging firms will take approximately 2 hours to test and record an average of 3 packaging design types each year. The design type may be for a single packaging, or a series of packagings made to the same design. Therefore, a test record is not required to be completed for each packaging, but of each design.
5,000 packaging firms x 3 packaging design types to test and record =
5,000 x 3 =
15,000 annual responses.
Estimate of annual burden hours:
Additional burden hours resulting from HM-224B: 2,500 hours
Annual burden hours prior to HM-224B: 30,000 hours
Revised annual burden hours: 32,500 hours
HM-224B Final Rule changes:
Docket HM-224 Final Rule is requiring that compressed oxygen and packages of chemical oxygen generators be placed in an outer packaging that meets certain flame penetration and thermal resistance requirements when transported aboard an aircraft. This new packaging requirement will require package design testing and recordkeeping in order to increase the level of safety associated with transportation of these materials aboard aircraft.
It is estimated that approximately10 packaging firms will take approximately 5 hours to test and record an average of 50 packaging design types each year for the first year, and, approximately 3 packaging design types thereafter. The design type may be for a single packaging, or a series of packagings made to the same design. Therefore, a test record is not required to be completed for each packaging, but of each design.
10 packaging firms x 50 packaging design types x 5 hrs to test and record =
10 x 50 x 5 =
2,500 annual burden hours (first year).
10 packaging firms x 3 packaging design types x 5 hrs to test and record =
10 x 3 x 5 =
150 annual burden hours (subsequent years).
Estimate of annual burden hours prior to HM-224B Final Rule changes:
It is estimated that 5,000 packaging firms will take approximately 2 hours to test and record an average of 3 packaging design types each year. The design type may be for a single packaging, or a series of packagings made to the same design. Therefore, a test record is not required to be completed for each packaging, but of each design.
5,000 packaging firms x 3 packaging design types x 2 hours to test and record =
5,000 x 3 x 2 =
30,000 annual burden hours.
Estimate of cost of annual burden hours:
Additional burden costs resulting from HM-224B: $ 62,500
Annual burden costs prior to HM-224B: $ 750,000
Revised annual burden costs: $ 812,500
HM-224B Final Rule changes:
It is estimated that 10 packaging firms will spend approximately $25 per hour x 5 hours to comply with testing and recordkeeping requirements for an average of 50 packaging design types the first year.
10 packaging firms x $25 per hour x 5 hours x 50 design types =
10 x $25 x 5 x 50 =
$62,500 annual burden cost.
Thereafter, 10 packaging firms will spend $25 per hour x 5 hours complying with testing and recordkeeping requirements for an average of 3 packaging design types thereafter.
10 packaging firms x $25 per hour x 5 hours x 3 design types =
10 x $25 x 5 x 5 =
$3,750 annual burden cost (first year).
Estimate of annual burden costs prior to HM-224B Final Rule changes:
An estimated 5,000 packaging firms will spend approximately $25 per hour x 2 hours complying with testing and recordkeeping requirements for an average of 3 packaging designs each year.
5,000 packaging firms x $25 per hour x 2 hours x 3 design types =
5,000 x $25 x 2 x 3 =
$750,000.00 annual burden cost (subsequent years).
Total annual cost burden to respondents resulting from collection of information.
There is no cost burden to respondents except those identified in item 12 above.
Estimate of annualized cost to the Federal government.
There is no cost to the Federal government.
Reasons for change in burden.
The change in burden is the result of the finalization of changes that were adopted as proposed in the Docket HM-224B NPRM.
NOTE: The current OMB inventory for the number of responses for this information collection is 15,050. This correct number of responses is 15,500. This typographical error will be reflected in the RISC and OIRA Consolidated Information System (ROCIS) during the electronic submittal of this Information Collection package.
Plans for tabulation, statistical analysis and publication.
There is no publication for statistical use and no statistical techniques are involved.
Display of expiration date of OMB Approval.
Approved OMB number is prominently displayed in the text of 49 CFR 171.6.
Exceptions to certification statement (OMB Form 83-I, Item 19).
There is no exception to PHMSA=s certification of this request for information collection approval.
| File Type | application/msword |
| File Title | Testing Requirements for Non-Bulk Packaging |
| Author | fosterg |
| Last Modified By | fosterg |
| File Modified | 2006-10-12 |
| File Created | 2006-10-12 |