Appendix A

Appendix A PRA Cost Indicator Summary: Marine Casualty Info. and Periodic Chemical Testing
Using ARMA: Chemical Testing Calculations
		Times	Record Creation	Record Filing	Record Storage	Total	Burden Hours
PRA Task	Rule Citation	Performed	$1.145	$0.118	$0.0228	Sum ($)	$29
Post Accident Determination Documentation 1	46 CFR 4.06-5 (b), and 4.06-60	245	280.53	28.91	5.59	$464	16
Foreign Laws Program Exemption 2	46 CFR 16.207	1	1.15	0.12	0.02	$1.89	0.065
Periodic Test Result Report 3	46 CFR 16.220	87,000	99,615.00	10,266.00	1,983.60	$162,197	5,593
Reasonable Suspicion Determination Documentation 4	46 CFR 16.250 (c)	79	90.46	9.32	1.80	$145	5
Refusal-to-Test Record 5	46 CFR 16.250 (d)	3	3.44	0.35	0.07	$5.51	0.19
Employee Training Documentation 6	46 CFR 16.401 (a) and (b)	69,600	79,692.00	8,212.80	1,586.88	$129,775	4,475
Supervisor Training Documentation 7	46 CFR 16.401 (b)	17,400	19,923.00	2,053.20	396.72	$32,451	1,119

1. The ‘times performed’ is the number of times in a year the Coast Guard expects that a drug/alcohol test after a SMI would be refused. Also, the log entry is only made when the person is a crewmember of a ship that is required to have a logbook (ships that are greater than 1600 gross tons).

2. No companies have submitted applications under this program. The burden has been calculated in case any apply.

3. For the number of times performed, we assumed 8 new employees and 2 employees would apply for licenses and renewal of licenses, for 8,700 firms. The number of firms involved is based on Coast Guard estimates. The total number of times performed is therefore 87,000.

4. The times performed was determined by taking the actual 1998 number of “reasonable suspicion” tests that were performed, times the proportion of documented vessels that are greater than 1600 gross tons. Since there were 741 inspected vessels greater than 1600 gt in 1999, and 7,521 inspected vessels overall in 1999, the times performed = (741/7521)*800 = 79.

5. Number of times performed is estimated by the number of times in a year the Coast Guard expects drug/alcohol test after reasonable suspicion would be refused. Also, the log entry is only made when the person is crewmember of a ship that is required to have a logbook (ships that are greater than 1600 gross tons).

6. For number of times performed, assumed 8 new employees for 8,700 firms. The number of firms involved is a Coast Guard estimate.

7. For number of times performed, assumed 2 new supervisors for 8,700 firms. The number of firms involved is a Coast Guard estimate.

Appendix A PRA Cost Indicator Summary: Marine Casualty Info. and Periodic Chemical Testing (Continued from previous page)
Using Standard Method: Chemical Testing
		Time to Complete	Number of Times		Burden Cost
PRA Task	Rule Citation	Single Task (hours)	Performed	Burden Hours	$29
Special Post Accident Documentation 1	46 CFR 4.06-5(b)	0.083	1	0.083	$2.41
Positive Chemical Test Report to OCMI 2	46 CFR 4.06-60(d)	0.250	40	10	$290
Promulgate Policy 3	46 CFR 16.401	2	87	174	$5,046
Positive Drug/Alcohol Test Report to OCMI 5	46 CFR 16.201(c)	0.250	40	10	$290
The times performed is the number of times in a year the Coast Guard expects that a drug/alcohol test after SMI would be refused. Also, the log entry is only made when the person is crewmember of a ship that is required to have a logbook (greater than 1600 gross tons). The number of times performed is estimated from the number of positives reported on CG-2692B post a SMI. The number of times performed is estimated by assuming 1% of existing companies is the number of new companies every year, which is 1% of 8,700 = 87. Number of firms is a Coast Guard estimate. The number of times performed is estimated using the number of licensed personnel who tested positive. The number of times performed is a historical estimate using the number of licensed personnel who tested positive as reported in the MIS forms. Using Standard Method: Marine Casualty Information Collection
Requirement	Rule Citation	Time to complete task (hours)	Number of times performed	Burden hours	Burden Cost $29
Written Report of Marine Casualty1	46 CFR 4.05-10	1	4,351	4,351	$126,179
The number of times performed is based on a Coast Guard database count of the number of Forms CG-2692 (including CG-2692A & CG-2692B) that were submitted to the Coast Guard in year 2006.