SS_1218-0150-Final-ICR (02~19~08)

SUPPORTING STATEMENT FOR
THE STANDARD ON THE CONTROL OF HAZARDOUS ENERGY
(LOCKOUT/TAGOUT) (29 CFR 1910.147) 1
OFFICE OF MANAGEMENT AND BUDGET (OMB)
CONTROL NO. 1218-0150 (January 2008)

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).
Section 6(b)(7) of the Act specifies that “[a]ny standard promulgated under this subsection shall
prescribe the use of labels or other appropriate forms of warning as are necessary to insure that
employees are apprised of all hazards to which they are exposed, relevant symptoms and
appropriate emergency treatment, and proper conditions and precautions of safe use or
exposure.” This provision goes on to state that “[t]he Secretary, in consultation with the
Secretary of Health and Human Services, may by rule promulgated pursuant to section 553 of
title 5, United States Code, make appropriate modifications in the foregoing requirements
relating to the use of labels or other forms of warning . . . as may be warranted by experience,
information, or medical or technological developments acquired subsequent to the promulgation
of the relevant standard” (29 U.S.C. 655).
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 1910.147 a safety standard for general industry
titled “Control of Hazardous Energy (Lockout/Tagout)” (i.e., “the Standard"). The Standard
regulates control of hazardous-energy sources using lockout or tagout procedures while
employees service, maintain, or repair machines or equipment when activation, start up, or
1

The purpose of this Supporting Statement is to analyze and describe burden hours and cost 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, these provisions.

release of energy from an energy source is possible. 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 several paperwork requirements. The following sections describe who
uses the information collected under each requirement, as well as how they use it. The purpose
of these requirements is to control the release of hazardous-energy sources while employees
service, maintain, or repair machines or equipment when activation, start up, or release of energy
from an energy source is possible; proper control of hazardous-energy sources prevent death or
serious injury among these employees.
Energy-Control Procedure (paragraph (c)(4)(i)). With limited exception, employers must
document the procedures used to isolate from its energy source and render inoperative, any
machine or equipment prior to servicing, maintenance, or repair by employees. These
procedures are necessary when activation, start up, or release of stored energy from the energy
source is possible, and such release could cause injury to the employees.
Paragraph (c)(4)(ii) states that the required documentation must clearly and specifically outline
the scope, purpose, authorization, rules, and techniques employees are to use to control
hazardous energy, and the means to enforce compliance. The document must include at least the
following elements:
A) A specific statement regarding the use of the procedure;
B) Detailed procedural steps for shutting down, isolating, blocking, and securing machines or
equipment to control hazardous energy, and for placing, removing, and transferring lockout or
tagout devices, including the responsibility for doing so; and,
C) Requirements for testing a machine or equipment to determine and verify the effectiveness of
lockout or tagout devices, as well as other energy-control measures.
The employer uses the information in this document as the basis for informing and training
employees about the purpose and function of the energy-control procedures, and the safe
application, use, and removal of energy controls. In addition, this information enables employers
to effectively identify operations and processes in the workplace that require energy-control
procedures.
Periodic Inspection (paragraph (c)(6)(ii)). Under paragraph (c)(6)(i), employers are to
conduct inspections of energy-control procedures at least annually. An authorized employee
other than an authorized employee using the energy-control procedure that is the subject of the
inspection is to conduct the inspection and correct any deviations or inadequacies identified. For
procedures involving either lockout or tagout, the inspection must include a review, between the
inspector and each authorized employee, of that employee's responsibilities under the procedure;
for procedures using tagout systems, the review also involves affected employees, and includes
an assessment of the employees’ knowledge of the training elements required for these systems.
2

Paragraph (c)(6)(ii) requires employers to certify the inspection by documenting the date of the
inspection, and identifying the machine or equipment inspected and the employee who
performed the inspection.
Training and Communication (paragraph (c)(7)(iv)). Paragraph (c)(7)(i) specifies that
employers must establish a training program that enables employees to understand the purpose
and function of the energy-control procedures, and provides them with the knowledge and skills
necessary for the safe application, use, and removal of energy controls. According to paragraph
(c)(7)(i), employers are to ensure that: Authorized employees recognize the applicable
hazardous-energy sources, the type and magnitude of the energy available in the workplace, and
the methods and means necessary for energy isolation and control; affected employees obtain
instruction in the purpose and use of the energy-control procedure; and other employees who
work, or may work, near operations using the energy-control procedure receive training about
the procedure, as well as the prohibition regarding attempts to restart or reactivate machines or
equipment having locks or tags to control energy release.
Under paragraph (c)(7)(ii), when the employer uses a tagout system, the training program must
inform employees that: Tags are warning labels affixed to energy-isolating devices, and
therefore do not provide the physical restraint on those devices that locks do; they are not to
remove tags attached to an energy-isolating devices unless permitted to do so by the authorized
employee responsible for the tag, and they are never to bypass, ignore, or in any manner defeat
the tagout system; tags must be legible and understandable by authorized and affected
employees, as well as other employees who work, or may work, near operations using the
energy-control procedure; the materials used for tags, including the means of attaching them,
must withstand the environmental conditions encountered in the workplace; tags evoke a false
sense of security, and employees must understand that tags are only part of the overall energycontrol program; and they must attach tags securely to energy-isolating devices to prevent
removal of the tags during use.
Paragraph (c)(7)(iii) states that employers must retrain authorized and affected employees when
a change occurs in: Their job assignments, the machines, equipment, or processes such that a
new hazard is present; and the energy-control procedures. Employers also must provide
retraining when they have reason to believe, or periodic inspection required under paragraph
(c)(6) indicates, that deviations and inadequacies exist in an employee’s knowledge or use of
energy-control procedures. The retraining must reestablish employee proficiency and, if
necessary, introduce new or revised energy-control procedures.
Under paragraph (c)(7)(iv), employers are to certify that employees completed the required
training, and that this training is up-to-date. The certification is to contain each employee’s
name and the training date.
Training employees to recognize hazardous-energy sources and to understand the purpose and
function of the energy-control procedures, and providing them with the knowledge and skills
necessary to implement safe application, use, and removal of energy controls, enables them to
prevent serious accidents by using appropriate control procedures in a safe manner to isolate

3

these hazards. In addition, written certification of the training assures the employer that
employees receive the training specified by the Standard.
Disclosure of Inspection and Training Certification Records (paragraphs (c)(6)(ii) and
(c)(7)(iv)). The inspection records provide employers with assurance that employees can safely
and effectively service, maintain, and repair machines and equipment covered by the Standard.
These records also provide the most efficient means for an OSHA compliance officer to
determine that an employer is complying with the Standard, and that the machines and
equipment are safe for servicing, maintenance, and repair. The training records provide the most
efficient means for an OSHA compliance officer to determine whether an employer has
performed the required training.
Notification of Employees (paragraph (c)(9)). This provision requires the employer to notify
affected employees prior to applying, and after removing, a lockout or tagout device from a
machine or equipment. Such notification informs employees of the impending interruption of
the normal production operation, and serves as a reminder of the restrictions imposed on them by
the energy-control program. In addition, this requirement ensures that employees do not attempt
to reactivate a machine or piece of equipment after an authorized employee isolates its energy
source and renders it inoperative. Notifying employees after removing an energy-control device
alerts them that the machines and equipment are no longer safe for servicing, maintenance, and
repair. 2
Offsite Personnel (Contractors, etc.) (paragraph (f)(2)(i)). When the onsite employer uses an
offsite employer (e.g., a contractor) to perform the activities covered by the scope and
application of the Standard, the two employers must inform each other regarding their respective
lockout or tagout procedures. This provision ensures that each employer knows about the unique
energy-control procedures used by the other employer; this knowledge prevents any
misunderstanding regarding the implementation of lockout or tagout procedures, and the use of
lockout or tagout devices for a particular application.
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 informationcollection 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.

2

Paragraph (e)(2) requires similar notification; because of this similarity, the Agency is taking no burden
hours or cost for this provision.

4

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. The Agency has published OSHA Instruction,
Directive Number CPL 02-00-147, The Control of Hazardous Energy – Enforcement Policy and
Inspections Procedures, February 11, 2008. Although this directive establishes OSHA’s
enforcement policy for the standards addressing the control of hazardous energy, the Agency has
made the directive available to the public to assist them in complying and understanding the
requirements of the LO/TO Standard.
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.

The Agency believes that the information collection frequencies required by the Standard are the
minimum frequencies necessary to effectively regulate hazardous-energy sources, 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 by the Act at
29 U.S.C. 651. Accordingly, when employers do not perform the required information
collections, or delay in providing this information, employees may not use energy-control
procedures effectively and safely, thereby increasing their probability of death and serious injury
caused by uncontrolled release of hazardous energy.
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-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 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

5

·
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
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 October 30, 2007 (72 FR 61378, Docket No.
OSHA-2007-0075) requesting public comment on its proposed extension of the information
collection requirements contained in the Standard on the Control of Hazardous Energy
(Lockout/Tagout) at 29 CFR 1910.147 (“LO/TO Standard” or “Standard”). 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:

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·
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
For this Information Collection Request (ICR), OSHA used an industry-classification scheme
from the Regulatory Impact Analysis (RIA) performed on the final Standard.3 This scheme
classifies industries covered by the Standard into the following three groups: high-impact, lowimpact, and zero- or negligible-impact. The high-impact group consists of all manufacturing
industries (i.e., North American Industrial Classification System (NAICS) Codes 31-33 and
others corresponding to 1987 SIC Codes 20-39), while the low-impact group includes industries
in the following sectors: transportation 4 , communications 5 , utilities (i.e., electrical-generation
establishments, but not power-distribution establishments) 6 , wholesale-trade 7 , retail-food 8 , and
several industries in the service sector (i.e., personal services, business services, automotive
repair, miscellaneous repair, and amusement services. 9 Included in the zero- or negligible3

Regulatory Impact and Regulatory Flexibility Analysis of 29 CFR 1910.147 (The Control of Hazardous
Energy Sources—Lockout/Tagout), U.S. Department of Labor, OSHA, Office of Regulatory Analysis, August, 1989.
The source of these data was a contract report titled, Industry Profile Study of a Standard for Control of Hazardous
Energy Sources Including Lockout/Tagout Procedures, Eastern Research Group, May 1985.
4

This sector is comprised of industries in the following NAICS codes: 481, 484, 485, 4861, 4869, 4871,
4879, 488, 492, 532411, 561510, 561520, 5621, 621910, and 713930.
5

This sector is comprised of industries in NAICS code 517. Due to incongruence between SIC and NAICS
codes, some industries in NAICS 485310 are included in both the transportation and communications sectors; these
industries have been accounted for in the transportation sector and are excluded here to avoid double-counting of
data.
6

This sector is comprised of industries in the following NAICS codes: 221210, 221310, 221320, 221330,
486210, 562211, 562212, 562213, 562219, and 562920. Additionally, this sector excludes industries in NAICS
codes 488119, 488490, 561710, 561790, 562910, and 562998; in translating between SIC and NAICS codes, small
portions of these industries were included in the utilities sector. As only small portions of these industries are
included, they are difficulty to quantify and are excluded from this analysis.
7

This sector is comprised of industries in the following NAICS codes: 423, 424, and 425.

8

This sector is comprised of industries in the following NAICS codes: 311811, 4451, 4452, 446191,
447110, and 452910.
9

This sector is comprised of industries in the following NAICS codes: 326212, 334611, 511199, 512110,

7

impact group are industries found to have little potential for an accident involving hazardousenergy release. These industries include retail trade, finance, insurance, real estate, service, and
public-administration industries not classified as high- or low-impact groups.
In deriving establishment and employment figures for the three impact groups, the Agency
updated the total number of establishments from the previous ICR using data from the 2005
County Business Patterns. 10 The Agency applied percentages obtained from the RIA to these
updated figures to estimate the number of high- and low-impact establishments having
authorized employees, as well as the number of authorized and affected employees at these
establishments (see Tables 1 and 2).
Regarding the time estimates for performing the wide variety of information collections required
by the Standard, OSHA is using the estimates from the previous ICR. These estimates appear to
be reasonable because the Agency based them on data from the RIA which was available for
public review and comment when it was published in the final Standard. In addition, most of the
establishments engaged in performing these information collections have many years of
experiences in doing so; therefore, these times probably are upper-bound estimates.
In determining the wage rates for the various occupations that perform the paperwork
requirements, OSHA used the most recent data from Employer Costs for Employee
Compensation, Bureau of Labor Statistics (BLS), U.S. Department of Labor (DOL), March
2007. The specific wage rate for each occupation, which includes a fringe-benefit rate of 30.0
percent, is provided as follows:
•
•
•

Supervisory manufacturing worker (supervisor) 11 :
Non-supervisory manufacturing worker 12 :
Secretary 13 :

$30.37
$24.02
$21.84

The following sections summarize the methodology used to estimate the number of burden hours
and the costs resulting from the information collection requirements of the Standard.
(A) Energy-Control Procedure (paragraph (c)(4)(i))
OSHA estimates that 28,750 high-impact establishments develop new procedures annually. The
512240, 512290, 518111, 518210, 519110, 5321, 532220, 53229, 5323, 5324, 541213, 541340, 541350, 5414, 5415,
5418, 541921, 541922, 541930, 541990, 5613, 5614, 56159, 5616, 561710, 561720, 561740, 561790, 5619, 562991,
611511, 611620, 711, 713, 81111, 81112, 811198, 8112, 8113, 8114, 8121, 812210, 8123, 81292, 812990.
10
11

2005 County Business Patterns, U.S. Census Bureau, 2007.
This average wage rate was derived from all manufacturing managers in private industry.

12

This average wage rate was derived from the following employment designation: Goods producing,
production, transportation, and material moving.
13

This average wage rate was derived from the following employment designation: Office and
administrative support occupations.

8

time to perform this activity ranges from 2 to 80 hours. In addition, 43,629 low-impact
establishments will perform new procedures. The time for low-impact establishments to develop
procedures is estimated at 2 hours. (See Table 3 for specific number of establishments in each
size category for both high- and low-impact establishments; the burden hour for each size
establishment; and details as to how OSHA arrived at the number of establishments.)
Agency also estimates that, in a yearly basis, a supervisor takes from 30 minutes (.50 hour) to 20
hours to update procedures in the 287,497 high-impact establishments and 30 minutes to update
procedures in the 436,288 low-impact establishments affected. (See Table 3 for specific number
of establishments in each size category for both high- and low-impact establishments; the burden
hour for each size establishment; and details as to how OSHA arrived at the number of
establishments.)
Burden Hours:

28,750 high-impact establishments (new procedures) x range of 2 to
80 hours = 214,847 hours (See Table 3 for specific number of
establishments in each size category for both high- and low-impact
establishments; the burden hour for each size establishment; and
details as to how OSHA arrived at the number of establishments.)
43,629 low-impact establishments (new procedures) x 2 hours =
87,258 hours (See Table 3 for specific number of establishments in
each size category for both high- and low-impact establishments; the
burden hour for each size establishment; and details as to how OSHA
arrived at the number of establishments.)
287,497 high-impact establishments (updating) x range of 0.5 to 20
hours = 624,267 hours (See Table 3 for specific number of
establishments in each size category for both high- and low-impact
establishments; the burden hour for each size establishment; and
details as to how OSHA arrived at the number of establishments.)
436,288 low-impact establishments x 0.5 hour = 218,144 hours (See
Table 3 for specific number of establishments in each size category
for both high- and low-impact establishments; the burden hour for
each size establishment; and details as to how OSHA arrived at the
number of establishments.)

Total Burden Hours for (A):
Cost:

214,847 + 87,258 + 624,267 + 218,144 =
1,144,516
1,144,516 burden hours x $30.37 = $32,275,351

(B) Periodic Inspection (Paragraph (c)(6)(ii))
OSHA assumes that a supervisor takes 20 minutes (.33 hour) to inspect an establishment’s
energy-control procedure once a year, and to prepare and maintain the inspection certificate.
Therefore, the estimated total yearly burden hours and cost resulting from this paperwork

9

requirement are:
Burden Hours:
Cost:

(333,460 high-impact establishments + 436,288 low-impact
establishments) x .33 hour = 254,017 hours
254,017 burden hours x $30.37 = $7,714,496

(C) Training and Communication (Paragraph (c)(7))
The Agency estimates that 6.72 million employees covered by the Standard require training each
year (i.e., the total number of authorized and affected employees in high- and low-impact
establishments listed in Tables 1 and 2). However, OSHA is not accounting for the burden hours
and cost of developing and administering the required training because these requirements are
performance-based. Nevertheless, this provision specifies that employers must prepare,
maintain and disclose training records. The Agency assumes that, each year, employers have to
prepare and maintain training records for 23 percent (i.e., 1,545,600) of these employees (i.e.,
new employees and employees who require training), as well as maintain training records for the
remaining 5,174,400 employees. In this regard, OSHA believes that a secretary spends 3
minutes (.05 hour) preparing and maintaining the record for the 23 percent of employees who are
new or require retraining; and, another 1 minute (.02 hour) maintaining the already prepared
record for the remaining employees (77 percent). Accordingly, the annual burden hour and cost
estimates for the paperwork requirements associated with this training requirement are:
Burden Hours:
Cost:

(1,545,600 new/retrained employees x .05 hour) + (5,174,400
remaining employees x .02 hour) = 180,768 hours
180,768 burden hours x $21.84 = $3,947,973

(D) Notification of Employees (Paragraph (c)(9))
OSHA has determined that the average number of lockout or tagout events that occur annually
vary by the size of the establishment and whether the establishment is in a high-impact or lowimpact industry. OSHA estimates that there are approximately 106,059 authorized employees14
in very small, high-impact establishments who would have to notify affected employees of the
application and removal of lockout/tagout devices (since this practice was not customary and
normal in these facilities prior to the promulgation of the standard) (see Table 1). OSHA
estimates that, on average, there are 75 maintenance or servicing operations conducted annually
in each very small, high-impact establishment. For other high-impact establishments, it is
estimated that there are approximately 347,280 authorized employees in establishments who
would have to notify affected employees of the application and removal of lockout/tagout
devices (see Table 1). It is estimated that, on average, there will be 150 such maintenance or
services operations conducted annually in each of these establishments. Additionally, there are
684,388 authorized employees in low-impact establishments who would have to notify affected
employees of the application and removal of lockout/tagout devices (see Table 2). These
14

To calculate burden hours and cost, OSHA assumes that every authorized employee will notify the
affected employees. The Standard requires only that one of the authorized employees (or an employer
representative) notify the affected employees. Thus, OSHA likely overestimates the burden hours and cost
associated with this requirement.

10

employees are estimated to perform, on average, 12 maintenance or servicing operations
annually for each low-impact establishment.
OSHA estimates that a total of 68,259,081 lockout or tagout events occur annually where
notification (not customarily performed) is needed. OSHA assumes that an authorized employee
is a non-supervisory manufacturing worker who requires 15 seconds (.004 hour) to provide the
required notification (i.e., 10 seconds for applying a lockout/tagout device, and five seconds for
removing the device). Accordingly, the total annual burden hour and cost estimates for this
notification are:
High-impact, very small establishments:
106,059 authorized employees x 75 operations/year = 7,954,425 events/year
High-impact, other than very small establishments:
347,280 authorized employees x 150 operations/year = 52,092,000
events/year
Low-impact establishments:
684,388 authorized employees x 12 operations/year = 8,212,656 events/year
Burden Hours:
Cost:

68,259,081 notifications x .004 hour = 273,036 hours
273,036 burden hours x $24.02 = $6,558,325

(E) Outside Personnel (Contractors, etc.) (Paragraph (f)(2)(i))
Paragraph (f)(2)(i) requires onsite and outside (contractor) employers to notify each other of their
respective LO/TO procedures. Notification of respective LO/TO procedures takes 5 minutes (.08
hour) for the onsite and outside contractor to meet and discuss respective LO/TO procedures. As
both the onsite employer and outside contractor attend the five-minute meeting, the Agency
assumes a total of 10 minutes (.17 hour) for this requirement.
A supervisor/manager, at a wage rate of $30.37 per hour will perform the notifications. Further,
OSHA believes that contractors are involved in 10 percent of all lockout/tagout events. As
determined above, there are 68,259,081 lockout/tagout events annually that require employees to
be notified (68,259,081 x 10% = 6,825,908 notifications)
Burden Hours:
Cost:

6,825,081 LO/TO notifications x .17 hour = 1,160,404 hours
1,160,404 hours x $30.37 = $35,241,470

(F) Disclosure of Inspection and Training Certification Records (Paragraphs (c)(6)(ii) and
(c)(7))
OSHA believes that approximately 10,776 establishments covered by the Standard 15 will be
subject to an OSHA inspection and required to disclose inspection and training certification
15

OSHA estimated the number of inspections by multiplying OSHA’s inspection rate (1.4%) by the
number of establishments covered by this ICR (i.e., 769,748 establishments x 1.4% = 10,776 inspections).

11

records annually. OSHA estimates that it will take a supervisor 5 minutes (.08 hour) to gather
and disclose the requested information.
Burden Hours:
Cost:

10,776 inspections x .08 hour = 862 hours
862 burden hours x $30.37 = $26,179

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 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.

The cost determinations made under Item 12 account for the total annual cost burden to
respondents or recordkeepers resulting from these collection of information requirements.
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 $37.89,
spends about 30 minutes (.50 hour) during an inspection reviewing the documents required by
the Standard. The Agency determines that its compliance officers will inspect about 10,776
employers (see footnote 15) who have lockout/tagout programs regulated by the Standard during
each year covered by this ICR. 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: 10,776 inspections x .50 hour x $37.89 = $204,151
15. Explain the reasons for any program changes or adjustments reported in Items 12 and 13 of the
Justification?

12

OSHA is requesting a net decrease of 407,924 burden hours (from 3,421,527 to 3,013,603). This
decrease is a result of updated data showing a decrease in the number of establishments from
818,532 to 769,748 and a decrease in the number of employees from 7.72 million to 6.72 million.
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.

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 OMB
83-I

13

Table 1: Establishments and Employment in Manufacturing High-Impact Industries

Size
Category

Very
Small
Small
Medium
Large
Total

Number of Authorized Employees
In
In
Establishments
Establishments
with Compliant
without
Lockout/
Lockout/
Total
Tagout
Tagout
Programs
Programs When
When Standard
Standard
Published
Published

Number of Additional Employees Covered

Total

In Establishments
with Compliant
Lockout/Tagout
Programs When
Standard
Published

In
Establishments
without Lockout
/Tagout
Programs When
Standard
Published

Employment
Size

Total Number
of
Establishments

Number of
Establishments
Employing
Authorized
Workers

<20

228,682

228,682

1,325,743

132,574

26,515

106,059

132,574

26,515

106,059

20-99
100-249
> 249

75,570
19,361
9,847
333,460

75,570
19,361
9,847
333,460

3,319,437
2,979,578
6,042,579
13,667,337

331,944
297,958
604,258
1,366,734

149,375
193,673
543,832
913,395

182,569
104,285
60,426
453,339

663,887
595,916
1,208,516
2,600,893

298,749
387,345
1,087,664
1,800,273

365,138
208,570
120,852
800,619

Total
Number of
Employees

Source: 2005 County Business Patterns Survey. U.S. Census
Bureau, 2007.

Table 2: Establishments and Employment in Low-Impact Industries

Number of Authorized Employees

Industry

Total Number
of
Establishments

Number of
Establishments
Employing
Authorized
Workers

Total
Number of
Employees

Total

Transportation
Communications
Utilities
Wholesale Trade
Food Stores
Services
Total

229,859
49,431
12,798
429,823
235,071
1,058,790
2,015,772

229,859
49,431
12,798
37,395
15,750
91,056
436,289

3,981,292
1,226,536
212,957
5,968,929
4,552,313
14,972,006
30,914,033

175,177
282,103
27,684
202,944
29,135
658,768
1,375,811

In
Establishments
with
Compliant
Lockout /
Tagout
Programs
When
Standard
Published
92,844
141,052
13,842
99,442
14,859
329,384
691,423

Source: 2005 County Business Patterns Survey. U.S. Census
Bureau, 2005.

15

In
Establishments
without
Lockout /
Tagout
Programs
When
Standard
Published
82,333
141,052
13,842
103,501
14,276
329,384
684,388

Number of Additional Employees
Covered

Total

In
Establishments
with Compliant
Lockout /
Tagout
Programs When
Standard
Published

In
Establishments
without
Lockout /
Tagout
Programs When
Standard
Published

175,177
282,103
27,684
202,944
29,135
658,768
1,375,811

92,844
141,052
13,842
99,442
14,859
329,384
691,423

82,333
141,052
13,842
103,501
14,276
329,384
684,388

Table 3: Written Procedures Assuming Half of the Original "Percent of Establishments in Compliance When the Rule
is Published"
Establishment Calculations -- High Impact Establishments

Establishment
Size

Very Small
Small
Medium
Large
Total

Number of
Establishments

228,682
75,570
19,361
9,847
333,460

Percent of
Establishments
in Compliance
when Rule
Published
10%
23%
33%
45%

Existing
Establishments
Originally
Lacking
LOTO
Program
205,814
58,189
12,972
5,416
282,391

Existing
Establishments
with Written
LOTO
Procedures
when Rule
Published
22,868
17,381
6,389
4,431
51,069

Percent of
Establishments
with
Procedures but
without
Unwritten
Plans
10%
10%
10%
10%

Calculation of Hours for New Establishments (No Existing Program) -- High-Impact Establishments
Establishment
Number of
First Year
Total Hours
Size
Establishments
Hours
First Year
Very Small
Small
Medium
Large
Total

20,810
5,993
1,361
586
28,750

2
12
40
80

41,620
71,916
54,440
46,880
214,856

Calculation of Hours for Recurring Burden in Existing Establishments -- High-Impact Establishments
Existing
Total Hours
Establishment
Number of
Hours
Establishment
High Impact
Size
Establishments
Hours
Very Small
208,101
0.5
104,051
145,670
Small
59,927
4
239,708
311,620
Medium
13,611
12
163,332
217,773
Large
5,859
20
117,180
164,051
Total
287,498
624,271
839,114

16

Existing
Establishments
with Unwritten
Plans when Rule
Published

Total Existing
Establishments
Requiring
Revision

2,287
1,738
639
443
5,107

208,101
59,927
13,611
5,859
287,498

Annual
Firm
Turnover

10%
10%
10%
10%

New
Establishments
Requiring
Revision
20,810
5,993
1,361
586
28,750

Calculation of Hours for New Establishments (No Existing Program) -- Low-Impact Establishments
First
Number of
Total Hours
Year
Establishments
First Year
Hours
Transportation
22,986
2
45,972
Communications
4,943
2
9,886
Utilities
1,280
2
2,560
Wholesale Trade
3,739
2
7,478
Food Stores
1,575
2
3,150
Services
9,106
2
18,212
Total
43,629
87,258
Calculation of Hours for Recurring Burden in Existing Establishments -- Low-Impact Establishments
Existing
Total Hours Low
Number of
Hours
Establishment
Impact
Establishments
Hours
Transportation
Communications
Utilities
Wholesale Trade
Food Stores
Services
Total

229,859
49,431
12,798
37,395
15,750
91,056
436,289

0.5
0.5
0.5
0.5
0.5
0.5

114,930
24,716
6,399
18,698
7,875
45,528
218,146

160,901
34,602
8,959
26,176
11,025
63,739
305,402

Grand Totals
Total Hours
High-Impact
Establishments
Low-Impact
Establishments
Grand Total
Hours:

839,114
305,402
1,144,516

17

Table 4: Requested Burden-Hour Adjustments

Information
Collection
Requirement
(A) Energy-Control
Procedure (paragraph
(c)(4)(i))
High-impact
establishments
developing new
procedures

Current
Burden
Hours

Requested
Burden
Hours

Adjustment
to Hours

Cost Under
Item 12

Responses

259,006

214,847

-44,159

$6,524,903

28,750

Low-impact
establishments
developing new
procedures

87,243

87,258

15

$2,650.026

43,629

High-impact
establishments
updating
procedures

750,870

624,267

-126,603

$18,958,989

287,497

Low-impact
establishments
updating
procedures

218,107

218,144

37

$6,625,033

436,288

18

Explanation of Adjustment

The estimated number of high-impact
establishments developing new
procedures decreased from 32,917 to
28,750 based on new data derived from
the 2005 County Business Patterns.
The estimated number of low-impact
establishments developing new
procedures increased slightly from
43,621 to 43,629 based on new data
derived from the 2005 County Business
Patterns.
The estimated number of high-impact
establishments updating existing
procedures decreased from 329,168 to
287,497 based on new data derived
from the 2005 County Business
Patterns.
The estimated number of low-impact
establishments updating existing
procedures increased slightly from
436,213 to 436,288 based on new data
derived from the 2005 County Business
Patterns.

Information
Collection
Requirement
(B) Periodic
Inspection (paragraph
(c)(6)(ii)

Current
Burden
Hours
270,116

Requested
Burden
Hours
254,017

Adjustment
to Hours
-16,099

Cost Under
Item 12
$7,714,496

Responses
769,748

(C) Training and
Communication
(paragraph (c)(7))

207,668

180,768

-26,900

$3,947,973

6,720,000

(D) Notification of
Employees (paragraph
(c)(9))

310,019

273,036

-36,983

$6,558,325

68,259,081

1,317,581

1,160,404

-157,177

$35,241,470

6,825,081

917

862

-55

$26,179

10,776

3,421,527

3,013,603

-407,924

88,247,393

83,380,850

(E) Offsite Personnel
(Contractors, etc.)
(paragraph (f)(2)(i))
(F) Disclosure of
Inspection and
Training Certification
Records (under
paragraphs (c)(6)(ii)
and (c)(7))
TOTALS

19

Explanation of Adjustment
The estimated number of high-impact
establishments being inspected
annually decreased from 382,319 to
333,460 while the number of lowimpact establishments being inspected
annually rose slightly from 436,213 to
436,288 based on new data derived
from the 2005 County Business
Patterns.
Based on new data, the number of
employees covered by the Standard
who require training annually
decreased from 7.72 million to 6.72
million.
There was a decrease in the number of
employee notification from 77,504,778
to 68,259,081.
Lockout/Tagout notifications decreased
from 7,750,478 to 6,825,081.
Because the number of establishments
decreased from 818,532 to 769,748,
there is a decreased in the number of
estimated inspections and disclosures
by employers.