Ss_1218-0198(10-23-07)

SUPPORTING STATEMENT FOR THE
INFORMATION COLLECTION REQUIREMENT OF THE
LOGGING OPERATIONS STANDARD (29 CFR 1910.266) 1
(OFFICE OF MANAGEMENT ANF BUDGET (OMB)
CONTROL NO. 1218-0198 (October 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.

The main purpose of the Occupational Safety and Health Act (OSH Act) (29 U.S.C. 651 et seq.)
is to “assure so far as possible every working man and woman in the Nation safe and healthful
working conditions and to preserve our human resources” (29 U.S.C. 651). To achieve this
objective, the OSH Act specifically authorizes “the development and promulgation of
occupational safety and health standards” (29 U.S.C. 651). In addition, the OSH Act specifies
that “[e]ach employer shall make, keep and preserve, and make available to the Secretary . . .
such records . . . as the Secretary . . . may prescribe by regulation as necessary or appropriate for
the enforcement of this Act . . .” (29 U.S.C. 657).
Under the authority granted by the OSH Act, the Occupational Safety and Health Administration
(“OSHA” or “the Agency”) published the Logging Operations Standard (the “Standard”) (29
CFR 1910.266). Paragraph (i)(10)(i) of the Standard specifies that employers must provide
written certification that employees and supervisors completed the required training, including
first-aid training, while paragraph (i)(10)(ii) mandates that employers retain these certificates
until replaced by more recent certificates. Items 2 and 12 below describe the specific
information-collection requirements of these paragraphs.
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.

Paragraph (f)(1)(iii) of the Standard requires the employer to assure that operating and
maintenance instructions are available on machines or in the area where the machine is being
operated. Paragraph (g)(3) requires the employer to assure that operating and maintenance
instructions are available in each vehicle.
Paragraph (i)(1) of the Standard requires employers to provide training for each employee,
including supervisors. To meet this requirement, employers must conduct the training at the
frequencies specified by paragraph (i)(2). Paragraph (i)(3) specifies that an employee’s/
supervisor’s training must consist of the following elements: Safe work practices, including the
1

The purpose of this Supporting Statement is to analyze and describe the burden hours and costs associated with
provisions of this Standard that contain paperwork requirements; this Supporting Statement does not provide
information or guidance on how to comply with, or how to enforce, the Standard.

use, operation, and maintenance of tools, machines, and vehicles the employee/supervisor uses or
operates, as well as procedures, practices, and requirements of the employer’s worksite;
recognition and control of health and safety hazards associated with the employee’s/supervisor’s
specific work tasks and logging operations in general; and the requirements of the Standard.
Paragraph (i)(10)(i) specifies that employers must verify that they are in compliance with the
training requirements in paragraph (i). This certification must be in writing and provide the
following information: The name/identifier of the employee/supervisor; the date(s) of the
training; and either the signature of the employer or the individual who conducted the training.
Paragraph (i)(10)(ii) requires employers to maintain the most recent certification for training
completed by an employee/supervisor.
Training employees/supervisors in safe work practices and to recognize and control the safety
and health hazards associated with their work tasks and overall logging operations enables them
to prevent serious accidents by using specific procedures and equipment in a safe manner to
avoid or to control dangerous exposures to these hazards.
Establishing and maintaining written certification of the training that each employee/supervisor
has received (i.e., job and first-aid) assures the employer that the training specified by the
Standard has been conducted, and at the required frequencies. With regard to first aid training,
the certification assures that the employee’s/supervisor’s training certificate is currently valid. In
addition, these records provide the most efficient means for an OSHA compliance officer to
determine whether an employer performed the required training at the necessary and appropriate
frequencies.
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.

Employers may use improved information technology when establishing and maintaining the
required record. OSHA wrote the paperwork requirements of the Standard in performanceoriented language, i.e., in terms of what data to record, not how to record the data.
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 information collection requirements in the Standard are specific to each employer and
employee involved, and no other source or agency duplicates the requirements or can make the
required information available to OSHA (i.e., the required information is available only from
employers).
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83I), describe any methods used to minimize burden.

The information collection requirements specified by the Standard do not have a significant
impact on a substantial number of small entities.

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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.

The information collection frequency specified by the Standard (i.e., retention of the written
training certification records until replaced) is the minimum frequency that the Agency believes
is necessary to assure employers and OSHA compliance officers that employees/supervisors
received the required training at the appropriate frequencies. Removing this frequency
requirement would eliminate any documentation of the training completed by an employee/
supervisor.
Explain any special circumstances that would cause an information collection to be conducted in a manner:
• 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, grant-in-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.

No special circumstances exist that require employers to collect information in the manner or
using the procedures specified by this item. The information collection requirements are
consistent with the guidelines provided in 5 CFR 1320.5.
8. If applicable, provide a copy and identify the date 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.

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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 August 22, 2007 (72 FR 47081), Docket No.
OSHA-2007-0018) requesting public comment on its proposed extension of the information
collection requirements contained in the Logging Operations Standard (29 CFR 1910.266). This
notice was part of a preclearance consultation program intended to provide those interested
parties the opportunity to comment on OSHA’s request for an extension by the Office of
Management and Budget (OMB) of a previous approval of the information collection
requirements found in the above standard. The Agency received no comments in response to its
notice to comment on this request.
9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of
contractors or grantees.

The Agency will not provide payments or gifts to the respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in
statute, regulation, or agency policy.

The paperwork requirements specified by the Standard do not require the collection of
confidential information.
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 reason why the agency considers the questions necessary, the specific uses to be made of the
information, the explanation to be given to persons from whom the information is requested, and any steps to
be taken to obtain their consent.

The paperwork requirements specified by the Standard do not require the collection of sensitive
information.
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 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 collections of information,
identifying and using appropriate wage-rate categories.

Burden Hour and Cost Determinations
The following sections summarize the burden hour and cost determinations for the information
collection requirements specified by the Standard. In determining the burden hours and cost

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associated with these requirements, OSHA estimates that the logging industry, including timber
tract operations, currently has 74,030 employees/supervisors and 11,447 logging
establishments. 2
The Agency determined average wage rates using average hourly earnings. For the relevant
occupational categories, OSHA adjusted the mean hourly earnings from the May 2006 National
Industry-Specific Occupational Employment and Wage Estimates, Occupational Employment
Statistics, Bureau of Labor Statistics, U.S. Department of Labor, to allow for fringe benefits,
which comprise about 29.4 percent of total compensation in the private sector. With wages
comprising 70.6 percent of employee compensation, the Agency multiplied wages by 1.4
(1/0.706) to derive total hourly employee compensation. Therefore, the costs of labor used in
this analysis are estimates of total hourly compensation. These estimates are:
• Material-Moving Machine and Vehicle
Operator (Supervisory)

$25.89

• Logging Equipment Operator

$21.03

• Secretary

$16.84

(A) Maintenance and Operating Instructions (§§ 1910.266(f)(1)(iii) and (g)(3))
Under paragraphs (f)(1)(iii) and (g)(3) of the Standard, employers must assure that operating and
maintenance instructions are available on machines or in the area where the machine is being
operated, and in vehicles. Based on the Regulatory Impact Analysis (RIA) for the Revisions to
the Standard, equipment manufacturers include operator’s manuals with new logging machines.
For those machines with no operating instructions in the cab, the employer will be required to
obtain and retain a manual within the immediate work area of each machine. Vehicles, however,
have special compartments to hold manuals which make the likelihood of loss or destruction of
manuals a rare event. Since the Logging Operations final rule has been in effect since 1995,
OSHA assumes that all employers are in compliance with the provision to have operating and
maintenance instructions available on machines or in the areas where the machines are being
operated.
However, OSHA realizes that there may be incidents where the instructions might be lost,
misplaced, or destroyed and need to be replaced. Therefore, for purposes of calculating burden
hours, the Agency estimates that approximately 10 percent of the establishments (1,145) will
have at least one machine manual replaced annually and that it will take a logging equipment
operator with an hourly wage rate of $21.03 approximately 10 minutes (.17 hour) to locate the
manual either on the premises or by calling the manufacturer for a replacement manual, and
placing the instructions in the equipment. 3
2

Source: County Business Patterns, United States: 2004, U.S. Department of Commerce, Economics and
Statistics Administration, U.S. Census Bureau, June 2006.
3

Regulatory Impact Analysis for the Revisions to the Pulpwood Logging Standard (29 CFR 1910.266), pp. III-910, U.S. Department of Labor, Occupational Safety and Health Administration, Office of Regulatory Analysis,

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Accordingly, the annual burden hours and cost of the paperwork requirement for
1910.266(f)(1)(iii) are:
Burden hours: 1,145 establishments x .17 hour = 195
Cost: 195 hours x $21.03 = $4,101
(B) Training Requirement, Frequency, and Content (§§ 1910.266(i)(1), (i)(2), and (i)(3))
Under paragraph (i)(1) of the Standard, employers must provide training to each employee,
including supervisors, at no cost to the employee/supervisor, while paragraph (i)(2) specifies the
frequency of the required training. In this regard, employers must train employees/supervisors:
Prior to their initial work assignment (i.e., new employee training); before they start a new work
task or operate a new tool, equipment, machine, or vehicle (i.e., new job assignment training);
and if they demonstrate unsafe job performance (i.e., retraining).
Paragraph (i)(3) specifies that an employee’s/supervisor’s training must consist of the following
elements: Safe work practices, including the use, operation, and maintenance of tools, machines,
and vehicles the employee/supervisor uses or operates, as well as procedures, practices, and
requirements of the employer’s worksite; recognition and control of health and safety hazards
associated with the employee’s/supervisor’s specific work tasks and logging operations in
general; and the requirements of the Standard. If a new employee/supervisor received prior
training consistent with the requirements of the Standard, the subsequent employer must train
that employee/supervisor only on those training elements for which they received no training or
those elements for which they require retraining.
Based on the Regulatory Impact Analysis (RIA) for the Standard, there is an estimated turnover
rate in the industry of 32 percent or approximately 23,690 (74,030 x .32 = 23,690). Only some
of these new employees will require complete new employee training because they already have
worked in the industry and the Standard requires only that they receive training in those areas in
which they have not been trained (e.g., the new employer’s worksite procedures and
requirements). Based on the RIA, approximately 25 percent of these new employees will require
complete training and the rest will need only limited training before initial assignment with a
new employer. The Standard also requires that current employees receive training in certain
situations: when they are assigned to a new job or tasks (e.g., operate a different type of logging
machine) or when they demonstrate unsafe work practices necessitating retraining. According to
the RIA, OSHA estimated that the remaining 75 percent of current employees will need these
types of training in any given year.
According to the RIA, OSHA estimated that training will take 3 hours for employees who have
never been trained (initial training for new employees) and one-half hour for training for
employees who already have received some training, who have a change in job or task
assignment, or who have demonstrated unsafe work practices necessitating retraining. The RIA
estimated that new employee training could be conducted in groups. Since most establishments
are small, the RIA estimated that new employee training would be given in groups of three. The
June 30, 1994.

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Agency believes that employers have developed the necessary training materials earlier and, as a
result, do not need to revise this material during the period covered by this ICR. Therefore, the
Agency is taking no burden hours or cost for employers to develop or revise the training
materials required by the Standard. Accordingly, the annual burden hours and cost of these
paperwork requirements are:
New employee training
Burden hours:

23,690 employees x 25% requiring complete new employee
training/3 x 3 hours = 5,923
23,690 employees x 75% requiring limited new employee training/
3 x .50 hour = 2,961

Cost:

(5,923 + 2,961) = 8,884 hours x $25.89 = $230,007

Current employee training/retraining
Burden hours:

Cost:

(74,030 employees – 23,690 (new employee (turnover)) = 50,340
existing employees x 75% requiring training/retraining x .50 hour
= 18,878 hours
18,878 hours x $25.89 = $488,751

(C) Certification of Training (§ 1910.266(i)(10)(i) and (i)(10)(ii))
Paragraph (i)(10)(i) requires employers to certify in writing that an employee/supervisor received
the training the Standard requires. Under paragraph (i)(10)(ii), employers need only maintain the
most recent certification for training (job training and first aid training) that an
employee/supervisor has received.
Based on the determinations made in section (B) above, each year employers must maintain
12,585 (74,030 – 61,445) training certifications for already trained employees/supervisors, as
well as generate and maintain 61,445 new training certifications for the employees/supervisors
who require initial training, new training, or retraining (23,690 new employees + 37,755 current
employees). Accordingly, OSHA estimates that a secretary at an hourly wage rate of $16.84 will
take one minute (.02 hour) to maintain each existing 12,585 training certifications (74,030 –
61,445) and three minutes (.05 hour) to generate and maintain each new training certification.
Therefore, the annual burden hours and cost of these paperwork requirements are:
Burden hours: 12,585 existing training certifications x .02 hour = 252
Cost:

252 hours x $16.84 = $4,244

Burden hours: 61,445 new training certifications x .05 hour = 3,072

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Cost: 3,072 hours x $16.84 = $51,732

(D) Disclosure of Training Certification Records
OSHA estimates that approximately 160 employers covered by the Standard 4 will be subject to
an OSHA inspection and required to disclose training certification records annually (see Item 14
below). OSHA estimates that it will take a supervisor 2 minutes (.03 hour) to disclose the
requested information.
Burden hours: 160 inspections x .03 hour = 5
Cost: 5 burden hours x $25.89 = $129
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 determined under Item 12 accounts for the total annual cost burden to respondents or
recordkeepers resulting from these collections of information requirements.
14. Provide estimates of 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 in a single table.

OSHA estimates that a compliance officer (GS-12, step 5), at an hourly wage rate of $36.26,
spends about five minutes (.08 hour) during an inspection reviewing the documents required by
the Standard. The Agency determines that its compliance officers will conduct about 160 such
inspections of employers regulated by the Standard during each year covered by this ICR (see
footnote 5). OSHA considers other expenses, such as equipment, overhead, and support staff
salaries, to be normal operating expenses that would occur without the paperwork requirements
specified by the Standard. Therefore, the total cost of these paperwork requirements to the
Federal government is:
Cost: 160 inspections x .08 hour x $36.26 = $464
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 per OMB Form
83-I.

OSHA is requesting an adjustment increase in the number of burden hours from 30,751 to
31,286 hours for a total increase of 535 hours. Based on updated data, the Agency found that the
number of establishments decreased; however, the number of employees increased. Table 1
below explains the proposed increase in burden hours.
4

OSHA determined the number of inspections by calculating an overall inspection rate of (1.4%) for all
employers under its jurisdiction, then applying this percentage to the number of establishments (11,447) covered by
these paperwork requirements (11,447 x .014 = 160).

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16. For collections of information whose results will be published, outline plans for tabulation, 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 information, completion of
report, publication dates, and other actions.

OSHA will not publish the information collected under the Standard.
17. If seeking approval to not display the expiration date for OMB approval of the information collection,
explain the reasons that display would be appropriate.

There are no forms on which to display an expiration date.
18. Explain each exception to the certification statement identified in Item 19 per "Certification for
Paperwork Reduction Act Submission," of OMB Form 83-I.

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

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Table 1: Requested Burden-Hour Adjustments

Information Collection
Requirement
Maintenance and Operating
Instructions (§§ 1910.266
(f)(1)(iii) and (g)(3))
Training Requirement,
Frequency, and Content (§§
1910.266(i)(1), (i)(2), and (i)(3))
Certification of Training (§§
1910.266(i)(10)(i) and (i)(10)(ii))

Disclosure of Training
Certification Records

TOTALS

Current
Burden Hours

Requested
Burden
Hours

Adjustment
to Hours

Cost Under
Item 12

Responses

Explanation of Adjustment

206

195

-11

$4,101

1,145

27,275

27,762

487

$718,758

45,652

Adjustment increase based on
updated data; the number of
employees increased from 72,732 to
74,030.

247

252

5

$4,244

12,585

Adjustment increase based on
updated data; the number of
employees increased from 72,732 to
74,030.

3,018

3,072

54

$51,732

61,445

Adjustment increase based on
updated data; the number of
employees increased.

5

5

0

$129

160

30,751

31,286

535

$778,964

120,987

10

Adjustment decrease based on
updated data; the number of
establishments decreased from
12,098 to 11,447.

OSHA estimates that approximately
164 employers/establishments
covered by the Standard will be
subject to an OSHA inspection and
required to disclose training
certification records annually (see
Item 14). OSHA estimates that it
will take a supervisor 2 minutes (.03
hour) to disclose the requested
information.