SS_1218-0242-PITS-Final-(05-21-08)

SUPPORTING STATEMENT FOR THE
INFORMATION COLLECTION REQUIREMENTS OF THE
STANDARD ON POWERED INDUSTRIAL TRUCKS (29 CFR 1910.178) 1
OFFICE OF MANAGEMENT AND BUDGET (OMB)
CONTROL NO. 1218-0242 (May 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 purpose of the Occupational Safety and Health Act (“the OSH Act” or “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 OSH Act specifically authorizes "the development and promulgation of
occupational safety and health standards" (29 U.S.C. 651). 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. 651).
The Act authorizes the Occupational Safety and Health Administration (“OSHA” or “the
Agency”) to issue standards that “prescribe the use of labels or other appropriate forms of
warning as are necessary to insure that employees are apprized of all hazards to which they are
exposed . . .” (29 U.S.C. 655). Additionally, the OSH Act mandates 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 Agency published a standard regulating
powered industrial trucks (29 CFR 1910.178; “the Standard”). The Standard contains several
information collection requirements addressing truck design, construction, and modification, as
well as certification of training and evaluation for truck operators. 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.

Paragraph (a)(4) of the Standard requires that employers obtain the manufacturer’s written
approval before modifying a truck in a manner that affects its capacity and safe operation; if 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 standards.

manufacturer grants such approval, the employer must revise capacity, operation, and
maintenance instruction plates, tags, and decals accordingly. For front-end attachments not
installed by the manufacturer, paragraph (a)(5) mandates that employers provide a marker on the
trucks that identifies the attachment, as well as the weight of both the truck and the attachment
when the attachment is at maximum elevation with a laterally centered load. Paragraph (a)(6)
specifies that employers must ensure that the markers required by paragraphs (a)(3) through
(a)(5) remain affixed to trucks and are legible.
Paragraphs (l)(1) through (l)(6) of the Standard contain the paperwork requirements necessary to
certify the training provided to powered industrial truck operators. Accordingly, these
paragraphs specify the following requirements for employers:
●

Paragraph (l)(1)--Ensure that trainees successfully complete the training and evaluation
requirements of paragraph (l) prior to operating a truck without direct supervision.

●

Paragraph (l)(2)--Allow trainees to operate a truck only under the direct supervision of an
individual with the knowledge, training, and experience to train operators and to evaluate
their performance, and under conditions that do not endanger other employees. The
training program must consist of formal instruction, practical training, and evaluation of
the trainee’s performance in the workplace.

●

Paragraph (l)(3)--Provide the trainees with initial training on each of 22 specified topics,
except on topics that the employer demonstrates do not apply to the safe operation of the
truck(s) in the employer’s workplace.

●

Paragraphs (l)(4)(i) and (l)(4)(ii)--Administer refresher training and evaluation on
relevant topics to operators found by observation or formal evaluation to have operated a
truck unsafely, been involved in an accident or near-miss incident, or been assigned to
operate another type of truck, or if the employer identifies a workplace condition that
could affect safe truck operation.

●

Paragraph (l)(4)(iii)--Evaluate each operator’s performance at least once every three
years.

●

Paragraph (l)(5)--Train rehires only in specific topics that they performed unsuccessfully
during an evaluation and that are appropriate to the employer’s truck(s) and workplace
conditions.

●

Paragraph (l)(6)--Certify that each operator meets the training and evaluation
requirements specified by paragraph (l). This certification must include the
operator’s name, the training date, the evaluation date, and the identity of the
individual(s) who performed the training and evaluation.

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Requiring labels (markings) of modified equipment notifies employees of the conditions under
which they can safely operate powered industrial trucks, thereby preventing such hazards as fires
and explosions caused by poorly designed electrical systems, rollovers/tipovers that result from
exceeding a truck’s stability characteristics, and falling loads that occur when loads exceed the
lifting capacities of attachments. Certification of training and evaluation provides a means of
informing employers that their employees received the training, and demonstrated the
performance necessary to operate a truck within its capacity and control limitations. Therefore,
by ensuring that employees operate only trucks that are in proper working order, and do so
safely, employers prevent possible severe injury or death of truck operators and other employees
who are in the vicinity of the trucks. Finally, these paperwork requirements are the most
efficient means for an OSHA compliance officer to determine that an employer properly notified
employees regarding the design and construction of, and modifications made to, the trucks they
are operating, and that an employer provided them with the required training.
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, including electronic recording, when
establishing or maintaining records.
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 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, or
applies only to, the employers covered by the Standard).
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 831), 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.

The Agency believes that the information collection frequencies required by the Standard are the
minimum frequencies necessary to 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 OSH 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 be at risk of serious injuries or death while operating powered industrial trucks.

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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
● 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 of the Standard 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.

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 March 7, 2008 (73 FR 12468, Docket No. OSHA2008-0003) requesting public comment on its proposed extension of the information collection
requirements contained in the Standard on Powered Industrial Trucks (29 CFR 1910.178). 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.
9. Explain any decision to provide any payments or gift to respondents, other than reenumeration of
contractors or grantees.

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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.

No such assurance is necessary because 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 information collection provisions of the Standard ask for 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
In 1998, OSHA published a final rule in which it revised the operator-training requirements
specified by paragraph (l) of the Standard (see 63 FR 66238). As part of this rulemaking, the
Agency performed a Final Economic Analysis (FEA) (see 63 FR 66262). Using data from the
FEA for the burden hour and cost estimates described below, OSHA finds that the Standard
applies to employers using an estimated 1,134,699 powered industrial trucks operated by about
1,702,048 employees. 2 There are approximately 4.8 million establishments in NAICS codes
where such trucks are used; however, the actual number of establishments using such trucks is

2

Source: County Business Patterns Survey, U.S. Census Bureau, 2005. This value reflects the overall
10.5% increase in employment across all industries from 1997 to 2005 (1,540,315 x 1.105). Additionally, the FEA
estimated that each powered industrial truck was used by an average 1.5 operators; to determine the current number
of powered industrial trucks in use, OSHA divided the estimated number of employees covered by the Standard by
1.5 (i.e., 1,702,048 ÷ 1.5).

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substantially smaller. 3 In addition, the Agency uses the following wage rates in determining the
cost of the information collection requirements specified by the Standard.
Supervisory Manufacturing Worker (Supervisor):
Manufacturing Worker:
Clerical/Secretary:

$30.82 4
$24.68 5
$21.44 6

(A) Notification of Truck Modifications (§ 1910.178(a)(4))
Based on a public comment received on a previous ICR, 7 most of the truck modifications
involve attachments covered by paragraph (a)(5) of the Standard. OSHA assumes that each year,
employers obtain manufacturers’ written approval to modify 0.2 percent of the powered
industrial trucks in a manner that affects their capacity and safe operation. For the purpose of
estimating the paperwork burden for this provision, OSHA estimates that the time involved in
seeking approval is the only collection of information (paperwork) burden involved with this
provision since the burden to affix new data plates or markings would be a usual and customary
practice by the firm that undertakes the modification or addition. OSHA estimates the approval
process takes approximately one hour. Accordingly, the annual burden hours and cost of this
paperwork requirement are:
Burden hours: 1,134,699 trucks x .002 x 1 hour = 2,269 hours
Cost: 2,269 hours x $24.68 = $55,999
(B) Notification of Front-End Attachments (§ 1910.178(a)(5))
OSHA has no information regarding the number of powered industrial trucks that have front-end
attachments installed by employers. Based on the previous public comment received, OSHA
believes that few, if any, employers have trucks that require modification to the nameplates and
markings provided by the manufacturer with the original truck. OSHA estimates that 0.1 percent
3

The previous ICR estimated that there were approximately 4.4 million establishments in SIC codes where
such trucks are used, compared to 6.9 million total establishments found in the 1997 County Business Patterns
survey. This ratio was applied to data obtained from the 2005 County Business Patterns Survey.
4

Source: Employer Costs for Employee Compensation, Supplementary Table 2. U.S. Department of Labor,
Bureau of Labor Statistics, September 2007. Class – All workers in manufacturing. Wage rate includes benefits of
29.4 percent.
5

Source: Employer Costs for Employee Compensation, Supplementary Table 2, U.S. Department of Labor,
Bureau of Labor Statistics, September 2007. Class – Production, transportation, and material moving – Production.
Wage rate includes benefits of 29.4 percent.
6

Source: Employer Costs for Employee Compensation, U.S. Department of Labor, Bureau of Labor
Statistics, September 2007. Class – Office and administrative support. Wage rate includes benefits of 29.4 percent.
7

See ICR-1218-0242(2001), Ex. 2-1.
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of all trucks in use are subject to the provision in (a)(5) of the Standard, and that a manufacturing
worker takes 30 minutes (.50 hour) to obtain the new information, prepare, and attach the data
plate. Accordingly, the annual burden hours and cost of this paperwork requirement are:
Burden hours: 1,134,699 trucks x .001 x .50 hour = 567 hours
Cost: 567 hours x $24.68 = $13,994
(C) Inspection of Markers (§ 1910.178(a)(6))
Employers incur a burden to obtain the information to replace data plates or approval markings
required by paragraphs (a)(3) through (a)(5) of the Standard, if, for example, the original
labels/markings are destroyed or otherwise become illegible. Based on a public comment
received on a previous ICR, OSHA estimates that about 20 percent (226,940) of all trucks fall
into the category of an “approved” truck and of those trucks, perhaps 1 percent require a new
data plate or marking for the reasons described above. OSHA estimates that a manufacturing
worker takes 5 minutes (.08 hour) to affix the new plates/markings. Accordingly, the annual
burden hours and cost of this paperwork requirement are:
Burden hours: 226,940 trucks x .01 x .08 hour = 182 hours
Cost: 182 hours x $24.68 = $4,492
(D) Operator Training (§ 1910.178(l)(1) through (l)(3), (l)(4)(i), (l)(4)(ii), and (l)(5))
The Agency concludes that operators who require training consist of new hires, rehires (i.e.,
received previous operator training from the same or a different employer), and other operators
who need refresher training. The following sections describe the burden hour and cost
determinations for each type of training.
Initial Training (§ 1910.178(l)(1) through (l)(3))
As determined in the FEA, the annual turnover rate among operators is 15 percent, resulting in
255,307 new hires each year that require initial training. OSHA estimates that performing initial
training takes a supervisor six hours and 10 minutes (6.17 hours), including one hour (1.00 hour)
to prepare the training materials and five hours and 10 minutes (5.17 hours) to deliver the
training; the Agency assumes that supervisors can deliver this training to groups consisting of
eight trainees, for a total of 31,913 groups (i.e., 255,307 trainees ÷ 8 trainees per group).
Therefore, the estimated annual burden hours and cost of this requirement are:
Burden hours: 31,913 groups x 6.17 hours per group = 196,903 hours
Cost: 196,903 x $30.82 = $6,068,550

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Refresher Training (§ 1910.178(l)(4)(i) and (l)(4)(ii))
According to the FEA, about 5 percent (85,102) of the trainees are operators who need refresher
training, require refresher training because they operated a truck unsafely, had an accident or
near-miss incident, or must operate another type of truck, or the employer identified a workplace
condition that could affect safe truck operation. The FEA data show that a supervisor requires
two hours and 10 minutes (2.17 hours) to train these operators, including 30 minutes (.50 hour)
to prepare the training materials and one hour and 40 minutes (1.67 hour) to deliver the training.
Thus, the total estimated burden hours and cost for these requirements are:
Burden hours: 85,102 employees x 2.17 hours per employee = 184,671 hours
Cost: 184,671 hours x $30.82 = $5,691,560
Training New Hires Who Have Had Previous Training (Rehires) (§ 1910.178(l)(5))
The FEA determined that 15 percent (255,307) of the trainees are rehires who must receive an
evaluation, followed by training on topics they performed unsuccessfully. Similar to refresher
training, the FEA estimated a supervisor requires two hours and 10 minutes (2.17 hours) to train
rehires, which includes 30 minutes (.50 hour) to prepare the training materials and one hour and
40 minutes (1.67 hour) to deliver the training to groups of eight trainees (for a total of 31,913
groups). Accordingly, the yearly estimated burden hours and cost resulting from this
requirement are:
Burden hours: 31,913 groups x 2.17 hours per group = 69,251 hours
Cost: 69,251 hours x $30.82 = $2,134,316
(E) Operator Evaluation (§ 1910.178(l)(4)(iii) and (l)(5))
Triennial Evaluation (§ 1910.178(l)(4)(iii))
Based on data from the FEA, OSHA determined that supervisors evaluate one-third (567,349) of
the operators each year, and that each evaluation takes 30 minutes (.50 hour) to perform.
Therefore, the yearly burden hour and cost estimates for conducting these evaluations are:
Burden hours: 567,349 employees x .50 hour to perform evaluation =
283,675 hours
Cost: 283,675 hours x $30.82 = $8,742,864

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Evaluating Rehires (§ 1910.178(l)(5))
OSHA estimates that a supervisor requires 10 minutes (.17 hour) each to evaluate the 255,307
rehires. 8 Accordingly, the annual estimated burden hours and cost for this requirement are:
Burden hours: 255,307 rehires x .17 hour = 43,402 hours
Cost: 43,402 hours x $30.82 = $1,337,650
Certification Records of Evaluations and Training (§ 1910.178(l)(6))
(a) Initial Training (§ 1910.178(l)(1) through (l)(3))
OSHA estimates that a secretary takes three minutes (.05 hour) to develop and maintain each
initial training certification record. The annual estimated burden hours and cost for this
requirement are:
Burden hours: 255,307 employees x .05 hour = 12,765 hours
Cost: 12,761 x $21.44 = $273,682
(b) Refresher Training (§ 1910.178(l)(4)(i) and (l)(4)(ii))
OSHA estimates that a secretary takes three minutes (.05 hour) to develop and maintain each
refresher training certification record. The annual estimated burden hours and cost for this
requirement are:
Burden hours: 85,102 employees x .05 hour = 4,255 hours
Cost: 4,254 x $21.44 = $91,227
(c) Rehires (§ 1910.178(l)(5))
OSHA estimates that a secretary takes three minutes (.05 hour) to develop and maintain each
certification record for rehires after training. The annual estimated burden hours and cost for this
requirement are:
Burden hours: 255,307 employees x .05 hour = 12,765 hours
Cost: 12,765 x $21.44 = $273,682

8

Several factors expedite this evaluation compared to a triennial evaluation; first, the rehires may have
recent training certification records available for review and, second, a short interview is often sufficient to
determine which topics require additional training.
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(d) Triennial Evaluation (§ 1910.178(l)(4)(iii))
OSHA estimates that a secretary takes three minutes (.05 hour) to develop and maintain a
certification record for each employee’s triennial evaluation. The annual estimated burden hours
and cost for this requirement are:
Burden hours: 567,349 employees x .05 hour = 28,367 hours
Cost: 28,368 hours x $21.44 = $608,210
(e) Evaluating Rehires (§ 1910.178(l)(5))
OSHA estimates that a secretary takes three minutes (.05 hour) to develop and maintain a
certification record for each rehired employee’s evaluation. The annual estimated burden hours
and cost for this requirement are:
Burden hours: 255,307 rehires x .05 hour = 12,765 hours
Cost: 12,765 hours x $21.44 = $273,682
(F) Disclosure of Evaluation and Training Certification Records
OSHA estimates that it may conduct approximately 15,886 inspections during the time period
covered by this ICR. 9 OSHA estimates that it will take a supervisor 10 minutes (.17 hour) to
disclose evaluation and training certification records (because of the number of certifications
records involved).
Burden hours: 15,886 inspections x .17 hour = 2,701 hours
Cost: 2,701 hours x $30.82 = $83,245
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
9

The Agency estimated the number of inspections by determining the inspection rate (1.4 percent) for all
establishments under the jurisdiction of the OSH Act (including both Federal OSHA and approved state-plan
agencies) and then multiplying the total number of trucks covered by the Standard by this percentage (i.e., 1,134,699
trucks x 1.4 percent = 15,886 inspections).
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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.

Employers incur costs to obtain the new data plates and “approval” markings from the
manufacturer and testing laboratory. Based on previous comments, the cost figures ranged from
free to $150 for the data plate, and $30 for markings from the testing lab. The Agency does not
believe these costs have increased dramatically, and is retaining them in this ICR. OSHA is
using an average cost of $75 for the data plates and $30 for the approval markings, or $105 for
both. As noted in item 12 (A), OSHA estimates that approximately 2,269 trucks may require a
new plate or marking.
Cost: 2,269 trucks x $105 = $238,245
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), at an hourly wage rate of $37.89,
spends about five minutes (.08 hour) during an inspection reviewing training certificates and
other paperwork requirements specified by the Standard. The Agency determines that its
compliance officers will conduct 15,886 inspections during each year covered by this ICR (see
footnote 9). OSHA considers other expenses, such as equipment, overhead, and support staff
salaries, as normal operating expenses that would occur without the collection of information
requirements specified by the Standard. Therefore, the annual total cost of these paperwork
requirements to the Federal government is:
Cost: 15,886 inspections x .08 hour x $37.89 = $48,154
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB
Form 83-1.

OSHA is proposing to increase the existing burden hour estimate of the collection of information
requirements specified by the Standard. In this regard, the Agency is proposing to increase the
current burden hour estimate from 773,205 hours to 854,538 hours, a total increase of 81,333
hours. The adjustment increase is due to updated data indicating a growth in the number of
powered industrial trucks from 999,000 to 1,134,699 and the number of operators from
1,540,315 to 1,702,048. There is also an increase in the cost burden under Item 13 (from
$210,000 to $238,245). This cost increase is also due to an increase in the number of powered
industrial trucks. Table 1 below describes each of the proposed burden hour adjustments.
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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.

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 requesting an exception to the certification statement in Item 19.

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Table 1
Proposed Burden Hour Adjustments
Current
Burden
Hours
1,998

Proposed
Burden
Hours
2,269

Adjustment
(Hours)
271

Cost Under
Item 12
$55,999

Responses
2,269

(B) Notification of Front-End
Attachments (§ 1910.178(a)(5))

500

567

67

$13,994

1,135

(C) Inspection of Data Plates or
Markers (§ 1910.178(a)(6))

160

182

22

$4,492

2,269

0

0

0

0

0

178,196

196,903

18,707

$6,068,550

31,913

167,125

184,671

17,546

$5,691,560

85,102

62,672

69,251

6,579

$2,134,316

31,913

0

0

0

0

0

256,719

283,675

26,956

$8,742,864

567,349

39,278

43,402

4,124

$1,337,650

255,307

0

0

0

0

0

Information Collection
Requirement
(A) Notification of Truck
Modifications (§ 1910.178(a)(4))

(D) Operator Training (§
1910.178(l)(1) through (l)(3),
(l)(4)(i), (l)(4)(ii), and (l)(5))
Initial Training (§ 1910.178 (l)(1)
through (l)(3))
Refresher Training (§ 1910.178
(1)(4)(i) and (l)(4)(ii))
Training New Hires Who Have
Had Previous Training (Rehires)
(§ 1910.178(1)(5))
(E) Operator Evaluation (§
1910.178(l)(4)(iii), (l)(5), and
(l)(6)

Triennial Evaluation
(§ 1910.178(1)(4)(iii))
Evaluating Rehires
(§ 1910.178(1)(5))

Certification Records of

Explanation of Adjustment
The adjustment increase is due to
updated data indicating a rise in the
number of powered industrial trucks
from 999,000 to 1,134,699.
The adjustment increase is due to
updated data indicating a rise in the
number of powered industrial trucks.
The adjustment increase is due to
updated data indicating a rise in the
number of powered industrial trucks.
The adjustment increase is due to
updated data indicating a rise in the
number of powered industrial truck
operators from 1,540,315 to 1,702,048.

The adjustment increase is due to
updated data indicating a rise in the
number of powered industrial truck
operators.

The adjustment increase is due to

Information Collection
Requirement
Evaluations and Training
(§ 1910.178(1)(6))
(a) Initial Training
(§§ 1910.178(l)(1)-(l)(3))
(b) Refresher Training (§§
(l)(4)(i) & (l)(4)(ii))
(c) Rehires (§ 1910.178(l)(5))
(d) Triennial Evaluation (§ 1910.
178(l)(4)(iii))
(e) Evaluating Rehires (§
1910.178(l)(5)
(F) Disclosure of Evaluation
and Training Certification
Records
TOTALS

Current
Burden
Hours

Proposed
Burden
Hours

Adjustment
(Hours)

Cost Under
Item 12

Responses

11,552

12,765

1,213

$273,682

255,307

3,851

4,255

404

$91,277

85,102

11,552
25,672

12,765
28,367

1,213
2,695

$273,682
$608,210

255,307
567,349

11,552

12,765

1,213

$273,682

255,307

2,378

2,701

323

$83,245

15,886

773,205

854,538

81,333

$25,653,203

2,411,515

−14−

Explanation of Adjustment
updated data indicating a rise in the
number of powered industrial truck
operators.

The adjustment increase is due to
updated data indicating a rise in the
number of establishments.