Ss_1218-0172(2007) 08-01-07

SUPPORTING STATEMENT FOR THE
INFORMATION-COLLECTION REQUIREMENTS OF THE
STUDENT DATA FORM
(OMB CONTROL NO. 1218-0172 (August 2007))

JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary. Identify any legal or
administrative requirements that necessitate the collection. Attach a copy of the appropriate section of
each statute and regulation mandating or authorizing the collection of information.

Section 21 of the Occupational Safety and Health Act of 1970 (the “OSH Act”) (29 U.S.C. 670)
authorizes the Occupational Safety and Health Administration (“OSHA” or the “Agency”) to
conduct education and training courses. These courses must ensure an adequate number of
qualified personnel to fulfill the purposes of the Act, provide them with short-term training,
inform them of the importance and proper use of safety and health equipment, and train
employers and employees to recognize, avoid, and prevent unsafe and unhealthful working
conditions.
Under Section 21 of the Act, the OSHA Training Institute (the “Institute”) provides basic,
intermediate, and advanced training and education in occupational safety and health for Federal
and State compliance officers, Agency professionals and technical-support personnel, employers,
employees, organizations representing employees and employers, educators who develop
curricula and teach occupational safety and health courses, and representatives of professional
safety and health groups. The Institute provides courses on occupational safety and health at its
national training facility in Arlington Heights, Illinois.
Students attending Institute courses complete a one-page Student Data Form (SDF; OSHA Form
182, 8/04 edition) on the first day of class. The form provides information under five major
categories titled “Course Information,” “Personal Data,” “Employer Data,” “Emergency
Contacts,” and “Student Groups.” The OSHA Office of Training and Education compiles, for
each fiscal year, the following information from the “Course Information” and “Student Groups”
categories: Total student attendance at the Institute; the number of students attending each
training course offered by the Institute; and the types of students attending these courses (for
example, students from Federal or State occupational safety and health agencies).
2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection,
indicate the actual use the Agency has made of the information received from the current collection.

The Agency uses the information compiled from the SDF by its Office of Training and
Education to demonstrate, in an accurate and timely manner, that it is providing the training and
employee education mandated by Section 21 of the Act. This information is also helpful in
evaluating training, and in making decisions regarding program/course revisions, budget support,
and tuition costs. In addition, the information collected under the “Course Information,”
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“Personal Data,” and “Employer Data” permits the Agency to identify private-sector students so
that it can collect tuition costs from them or their employers as authorized by 31 U.S.C. 9701
(“Fees and Charges for Government Services and Things of Value”); Office of Management and
Budget Circular A-25 (“User Charges”); and 29 CFR part 1949 (“Office of Training and
Education, Occupational Safety and Health Administration”). The information in the “Personal
Data” and “Emergency Contacts” categories allows OSHA to contact students who are residing
in local hotels/motels if an emergency arises at their home or place of employment, and to alert
supervisors/alternate contacts of a trainee’s injury or illness.
3. Describe whether, and to what extent, the collection of information involves the use of automated,
electronic, mechanical, or other technological collection techniques or other forms of information
technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting
this means of collection. Also, describe any consideration of using information technology to reduce
burden.

Students must complete the SDF manually because it is not available using advanced
information technology and the collection is made in a classroom setting. OSHA is continuing
to explore electronic-information techniques for use in the future.
4. Describe efforts to identify duplication. Show specifically why any similar information already available
cannot be used or modified for use for the purposes described in Item 2 above.

The paperwork requirements of the SDF are specific to each student involved, and no other
source or agency duplicates these requirements or can make the required information available to
OSHA (i.e., the required information is available only from the student).
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I),
describe any methods used to minimize burden.

The information provided on the SDF has no direct impact on any business regardless of size
because the Agency collects the information as part of the training course attended by the student
who completes the form; accordingly, this paperwork requirement does not have a significant
impact on a substantial number of small entities.
6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is
conducted less frequently, as well as any technical or legal obstacles to reducing burden.

If OSHA could not collect the information provided on the SDF, or obtained it less frequently,
the Agency would not have a record or data to use in: Documenting its timely and full
compliance with section 21 of the Act; planning timely program/course revisions, budget
support, and tuition costs; collecting tuition from private-sector students as required by existing
federal regulations; and effectively managing student-related emergencies that arise during
training.
7. Explain any special circumstances that would cause an information collection to be conducted in a
manner:

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⋅ Requiring respondents to report information to the Agency more often than quarterly;
⋅ Requiring respondents to prepare a written response to a collection of information in fewer than
30 days after receipt of it;
⋅ Requiring respondents to submit more than an original and two copies of any document;
⋅ Requiring respondents to retain records, other than health, medical, government contract, grantin-aid, or tax records for more than three years;
⋅ In connection with a statistical survey, that is not designed to produce valid and reliable results
that can be generalized to the universe of study;
⋅ Requiring the use of a statistical data classification that has not been reviewed and approved by
OMB;
⋅ That includes a pledge of confidentiality that is not supported by authority established in statute
or regulation, that is not supported by disclosure and data security policies that are consistent with
the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible
confidential use; or
⋅ Requiring respondents to submit proprietary trade secret, or other confidential information unless
the Agency can demonstrate that it has instituted procedures to protect the information's
confidentiality to the extent permitted by law.

The Agency believes that no special circumstances exist that would cause it to collect the
information required by the SDF in a manner, or using procedures, that differ from the
description provided in Item 2 above.
8. If applicable, provide a copy and identify the data and page number of publication in the Federal Register
of the Agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection
prior to submission to OMB. Summarize public comments received in response to that notice and describe
actions taken by the Agency in response to these comments. Specifically address comments received on
cost and hour burden.
Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data,
frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if
any), and on the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must
compile records should occur at least once every 3 years -- even if the collection of information activity is
the same as in prior periods. There may be circumstances that may preclude consultation in a specific
situation. These circumstances should be explained.

As required by the Paperwork Reduction Act of 1995 (44 U.S.C. 3506(c)(2)(A)), OSHA
published a notice in the Federal Register on May 25, 2007 (72 FR 29353, Docket No. OSHA2007-0047 requesting public comment on OSHA’s Student Data Form. This notice was part of a
preclearance consultation program intended to provide those interested parties the opportunity to

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comment on OSHA’s request for an extension by the Office of Management and Budget (OMB)
of the Student Data Form. The Agency received no comments in response to its notice.
9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of
contractors or grantees.

OSHA will not provide payments or gifts to the student who completes the SDF.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in
statute, regulation, or Agency policy.

The Agency provides no assurance of confidentiality regarding the information collected by the
SDF because it believes that none of this information is confidential.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and
attitudes, religious beliefs, and other matters that are commonly considered private. This justification
should include the reasons why the Agency considers the questions necessary, the specific uses to be made
of the information, the explanation to be given to persons form whom the information is requested, and
any steps to be taken to obtain their consent.

The Agency believes that none of the information collected by the SDF is sensitive.
12. Provide estimates of the hour burden of the collection of information. The statement should:
⋅ Indicate the number of respondents, frequency of response, annual hour burden, and an
explanation of how the burden was estimated. Unless directed to do so, agencies should not
conduct special surveys to obtain information on which to base hour burden estimates.
Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour
burden on respondents is expected to vary widely because of differences in activity, size, or
complexity, show the range of estimated hour burden, and explain the reasons for the variance.
Generally, estimates should not include burden hours for customary and usual business practices.
⋅ If this request for approval covers more than one form, provide separate hour burden estimate for
estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.
⋅ Provide estimates of annualized cost to respondents for the hour burdens for collection of
information, identifying and using appropriate wage rate categories. The cost of contracting out or
paying outside parties for information collection activities should not be included here. Instead,
this cost should be included in Item 14.

About 2,000 students attended the Institute during the previous fiscal year, and each student
completed one SDF on the first day of class. OSHA estimates that it takes 5 minutes for a
student to complete the form, resulting in a total of 167 burden hours for 2,000 students to
complete the form (i.e., 2,000 forms x 5 minutes/60 = 167 hours).
The cost to students/employers associated with completing the SDF is negligible because
completion time per student is only 5 minutes (0.08 hour), the Agency collects the information as
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part of the training course attended by the student who completes the form, and the average
student will attend only that course during the fiscal year. Nevertheless, the typical federal
employee (student) attending an Institute training course is an Occupational Safety Specialist
(GS-7, step 1) with an hourly rate (including benefits) of $18.52 per hour. Assuming that the
hourly rate for non-federal employees (students) (e.g., from state-plan states or the private
sector) is similar, then the total cost to complete the SDF is $3,093 (i.e., 167 hours x $18.52 =
$3,093).
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the
collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14.)
⋅ The cost estimate should be split into two components: (a) A total capital and start-up cost
component (annualized over its expected useful life); and (b) a total operation and maintenance and
purchase of services component. The estimates should take into account costs associated with
generating, maintaining, and disclosing or providing the information. Include descriptions of
methods used to estimate major cost factors including system and technology acquisition, expected
useful life of capital equipment, the discount rate(s), and the time period over which costs will be
incurred. Capital and start-up costs include, among other items, preparations for collecting
information such as purchasing computers and software; monitoring, sampling, drilling and testing
equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and
explain the reasons for the variance. The cost of purchasing or contracting out information
collection services should be a part of this cost burden estimate. In developing cost burden
estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day
pre-OMB submission public comment process and use existing economic or regulatory impact
analysis associated with the rulemaking containing the information collection, as appropriate.
⋅ Generally, estimates should not include purchases of equipment or services, or portions thereof,
made: (1) Prior to October 1, 1995; (2) to achieve regulatory compliance with requirements not
associated with the information collection; (3) for reasons other than to provide information or
keep records for the government; or (4) as part of customary and usual business or private
practices.

Item 12 provides the total cost of the information-collection requirement associated with
completing the SDF.
14. Provide estimates of the annualized cost to the Federal Government. Also provide a description of the
method used to estimate cost, which should include quantification of hours, operational expenses (such as
equipment, overhead, printing and support staff), and any other expense that would not have been
incurred without this collection of information. Agencies also may aggregate cost estimates from Items
12, 13, and 14 into single table.

OSHA estimates that the total annual cost to the Federal government of collecting and
maintaining the information collected by the SDF is about $7,821. The Agency based this cost
on the determinations provided in the following table:

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Description

Total Hours

Hourly Rate

Cost (rounded)

1 Management
Services Specialist1

208 hours

$32.90

$6,843

1 Training and
Education Assistant2

24 hours

$22.84

$548

1 Professional3

6.8 hours

$45.58

$310

Annual record storage
costs of forms

$35/square foot x 2.0 square feet

Annual printing cost

$70
$50

Total Annual Cost:

$7,821

1

Title and grade (Management Services Specialist, GS 11, step 7); based on spending 10% of time (2080 hrs/yr
times 10% equals 208 hrs/yr, $32.90/hr times 208 hrs/yr equals $6,843.20) on tuition collection activities such as,
determining tuition status, collecting tuition from private sector students, and maintaining tuition collection financial
records.
2

Title and grade (Training and Education Assistant, GS 7, step 8); based on spending 2hrs/mo (12mo times
2hr/mo equals 24 hrs/yr; $22.84/hr times 24 hrs/yr equals $548.16) collecting and processing the SDFs into course
files, by month and fiscal year.
3

Title (Occupational Safety and Health Specialist, or Industrial Hygienist, GS 13, step 6); based on Institute
instructors spending a total of .05 hours in each of 82 courses distributing and collecting the SDFs, and answering
questions about them.
15. Explain the reasons for any program changes or adjustments reporting in Items 13 or 14 of the OMB Form
83-I.

The Agency is requesting a 250 hour burden hour adjustment decrease as a result of reducing the
number of students attending the Institute from 5,000 to 2,000 students.
16. For collections of information whose results will be published, outline plans for tabulations and publication.
Address any complex analytical techniques that will be used. Provide the time schedule for the entire
project, including beginning and ending dates of the collection of information, completion of the report,
publication dates, and other actions.

OSHA will not publish the information collected by the SDF.

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17. If seeking approval to not display the expiration date for OMB approval of the information collection,
explain the reasons that display would be inappropriate.

OSHA will publish the OMB expiration number on the OSHA form 182.
18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork
Reduction Act Submissions,” of OMB Form 83-1.

OSHA is not seeking an exception to the certification statement in Item 19.

Attachment 1: OSH Act, Section 21
Attachment 2: Title 31 U.S.C. 9701
Attachment 3: OMB Circular A-25
Attachment 4: 29 CFR 1949
Attachment 5: Student Data Form (expires 8-31-07)

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