SS_1218-0226-Manlifts (10-30-07)

SUPPORTING STATEMENT FOR
THE INFORMATION COLLECTION REQUIREMENTS OF
THE STANDARD ON MANLIFTS (29 CFR 1910.68(e)) 1
OFFICE OF MANAGEMENT AND BUDGET (OMB)
CONTROL NO. 1218-0226 (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 objective of the Occupational Safety and Health Act of 1970 (i.e., “the Act”) 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 Act authorizes “the development and promulgation of occupational safety and
health standards” (29 U.S.C. 651).
With regard to recordkeeping, the 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). The Act states further that “[t]he Secretary . . . shall prescribe such rules and
regulations as [he/she] may deem necessary to carry out [his/her] responsibilities under this Act,
including rules and regulations dealing with the inspection of an employer’s establishment” (29
U.S.C. 657).
Under the authority granted by the Act, the Occupational Safety and Health Administration (i.e.,
“OSHA” or “the Agency”) published at 29 CFR 1910.68 a safety standard for general industry
regulating the use of manlifts (i.e., “the Standard"). The paperwork provisions of the Standard
specify requirements for inspecting manlifts; and developing, maintaining, and disclosing
inspection records. Items 2 and 12 below describe in detail the specific information collection
requirements of the Standard.
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 Standard specifies two paperwork requirements. The following sections describe who uses
the information collected under each requirement, as well as how they use it. The purpose of the
requirements is to reduce employees’ risk of death or serious injury by ensuring that manlifts are
in safe operating condition.

1

The purpose of this Supporting Statement is to analyze and describe the burden hours and costs associated
with a provision of this standard that contains a paperwork requirement; this Supporting Statement does not provide
information or guidance on how to comply with, or how to enforce, the provision.

Periodic Inspections and Records (paragraph (e)). This provision requires that each manlift
be inspected at least once every 30 days. The manlift inspection is to cover at least the following
items: Steps; step fastenings; rails; rail supports and fastenings; rollers and slides; belt and belt
tension; handholds and fastenings; floor landings; guardrails; lubrication; limit switches;
warning signs and lights; illumination; drive pulley; bottom (boot) pulley and clearance; pulley
supports; motor; driving mechanism; brake; electrical switches; vibration and misalignment; and
any "skip" on the up or down run when mounting a step (indicating worn gears). A certification
record of the inspection must be prepared upon completion of the inspection. The record must
contain the date of the inspection, the signature of the person who performed the inspection, and
the serial number or other identifier of the inspected manlift.
Disclosure of Inspection Certification Records.
Employers are to maintain the certification record and make it available to OSHA compliance
officers. This record provides assurance to employers, employees, and compliance officers that
manlifts were inspected as required by the Standard. The inspections are made to keep
equipment in safe operating condition, thereby preventing manlift failure while carrying
employees to elevated worksites. These records also provide the most efficient means for the
compliance officers to determine that an employer is complying with the Standard.
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 automated, electronic, mechanical, or other technological information
collection techniques, or other forms of information technology (e.g., electronic submission of
responses) when establishing and maintaining the required records. The Agency wrote the
paperwork requirements of the Standard in performance-oriented language ( i.e., in terms of
what data to collect, 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 purpose(s) described in 2 above.

The requirements to collect and maintain information are specific to each employer and
employee 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
employers).
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83I), describe the methods used to reduce the burden.

The information collection requirements specified by the Standard do 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 or is not conducted less
frequently, and any technical or legal obstacles to reducing the burden.

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The Agency believes that the information collection frequencies required by the Standard are the
minimum frequencies necessary to effectively regulate manlifts, and thereby fulfill its mandate
“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” as specified in the Act at 29 U.S.C.
651. Accordingly, if employers do not perform the required information collections, or delay in
providing this information, employees may use manlifts that are in unsafe operating condition.
7. 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-inaid, 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 statistical data classification that has not been reviewed and approved by OMB;

·

That includes a pledge of confidentially 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 prove that it has instituted procedures to protect the information's confidentially to the
extent permitted by law.

No special circumstances exist that require employers to collect information using the
procedures specified by this item. The requirements are within the guidelines set forth 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 before
submission to OMB. Summarize public comments received in response to that notice and describe actions
taken by the agency in response to those comments specifically address comments received on cost and hour
burdens.
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, revealed, 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 three years -- even if the collection of information activity is

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the same as in prior periods. There may be circumstances that mitigate against 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 September 6, 2007 (72 FR 51253, Docket No.
OSHA-2007-0020) requesting public comment on its proposed extension of the information
collection requirements contained in the Standard on Manlifts (29 CFR 1910.68(e)). 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 payments 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 involve 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 reasons 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.

None of the provisions in the Standard require 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.

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Burden-Hour and Cost Determinations
OSHA believes that the number of manlifts in use today (i.e., 3,000) is still accurate based on the
number of manlifts estimated in the previous ICR when it updated this figure based on comments
made by the only manufacturer of manlifts in the U.S.
The Agency determined average wage rates using average hourly earnings. For the relevant
occupational categories, OSHA adjusted the mean hourly earnings from the National
Compensation Survey, June 2005 issued by the 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:
•
•

Manufacturing Employee
Manufacturing Supervisor

$28.46
$35.57

Inspections and Certification Records (1910.68(e))
OSHA assumes that employers perform the required inspection on each manlift 12 times a year,
and that a manufacturing worker spends 1 hour to conduct the inspection and 3 minutes (.05
hour) to generate and maintain an inspection certification record for each manlift. Therefore, the
total annual burden-hour and cost estimates for this paperwork requirement are:
Burden hours: 3,000 manlifts x 12 inspections x 1.05 hours = 37,800 hours
Cost: 37,800 hours x $28.46 = $1,075,788
Disclosure of Inspection Certification Records
The disclosure of certification records provide the most efficient means for OSHA compliance
officers to determine that an employer is complying with the Standard.
OSHA believes that approximately 42 manlifts covered by the Standard 2 will be subject to an
OSHA inspection and the employer will be required to disclose certification records annually
(see Item 14 below). OSHA estimates that it will take a supervisor 2 minutes (.03 hour) to
disclose the requested information to a compliance officer.
Burden hours:
Cost:

42 inspections x .03 hour = 1 hour
1 burden hour x $35.57 = $36

2

OSHA estimated the number of inspections by multiplying OSHA’s inspection rate (1.4%) by the number
of manlifts covered by this ICR (i.e., 3,000 manlifts x 1.4% = 42 inspections).

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•

•

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
service 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 respondent (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 above provides the total cost of the information collection requirements specified by the
Standard.
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), 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 a single table.

OSHA estimates that a compliance officer (GS-12, step 5), with 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 inspect about 42
employers who operate manlifts regulated by the Standard during each year covered by this ICR
(see footnote 2). 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: 42 inspections x .08 hour x $36.26 = $122
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB
Form 83-1.

There are no burden hour or cost adjustments to be reported in Items 13 or 14 of the OMB Form
83-I. The Agency is requesting to retain its current burden hours at 37,801.
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

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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.

No forms are available for the Agency to display the 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 seeking an exception to the certification statement specified by Item 19 of the
OMB 83-I

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