Supporting statement

Supporting Statement:

OCRWM Organization Climate and Safety Conscious Work Environment

OMB Control:

This supporting statement provides additional information regarding the Department of Energy (DOE)/Office of Civilian Radioactive Waste Management (OCRWM) request for processing of the proposed information collection, OCRWM Organization Climate and Safety Conscious Work Environment. The numbered questions correspond to the order shown on the Office of Management and Budget (OMB) Form 83-I, “Instructions for Completing OMB Form 83-I.”

1. 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 information collection.

OCRWM proposes to collect information from Federal, national laboratory, and other contractor employees supporting the OCRWM mission by conducting an Organization Climate and Safety Conscious Work Environment Survey. The purpose of this information would be to assess the organizational climate and Safety Conscious Work Environment (SCWE) as part of OCRWM’s desire to continuously improve performance and comply with the employee protection requirements of 10 CFR 63.9, Employee Protection (Attachment 1), and Section 211 of the Energy Reorganization Act of 1974, as amended (42 U.S.C. 5851)(Attachment 2).

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

OCRWM will use the information collected to assess the organizational climate and Safety Conscious Work Environment. Data collected will be shared with participating Federal agencies, national laboratories, and other contractors and their employees such that employee perceptions of the organizational climate and effectiveness of management practices can be assessed, with subsequent interventions initiated as appropriate. Additionally, results will be shared with the U.S. Nuclear Regulatory Commission for its information, consistent with nuclear industry best practices.

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.

The great majority of respondents (95% or more) are expected to use electronic submissions, via a secured survey and administrated by an independent contractor. A copy of the survey instrument is attached (Attachment 3). Only employees without direct access to computer work stations will be offered the opportunity to file on paper. OCRWM has determined this to be the most cost effective means of collecting the information.

4. Describe efforts to identify duplication.

There is no other collection of information available that assesses the OCRWM organizational climate and Safety Conscious Work Environment.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

This collection will not have a significant impact on a substantial number of small entities such as small businesses, organizations, or government bodies.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

This collection of information is intended to be conducted annually. This interval allows for the timely identification of potential performance issues while allowing for the effects of management/program changes to be felt by the organization.

7. Explain any special circumstances that would cause the collection to be conducted in a manner: (a) requiring respondents to report information to the agency more often than quarterly; (b) requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it; (c) requiring respondents to submit more than an original and two copies of any document; (d) requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years; (e) 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; (f) requiring the use of statistical data classification that has not been reviewed and approved by OMB; (g) 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; (h) requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

Special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines:

Item (a): None.

Items (b): Respondents WILL be required to prepare a written response to a collection of information in fewer than 30 days after receipt.

OCRWM has consulted with its survey administrator and determined that a 3-week period is an optimal period for this survey. Response volumes for this type of survey follow a typical pattern; there is a high volume of response immediately after a survey launches followed by a period of lower response volumes. When a reminder is sent during the second week of administration, there is again a spike in response volume. Another period of a lower volume of responses ensues, and when a reminder is sent during the third week of administration, there is a final spike in response volume. Organizations typically do not receive significantly more responses in the fourth week of administration, even after a reminder is sent; one reaches a level of diminishing returns after the third week of administration. Balanced against this response pattern is the need for timeliness of reporting data and results.

Finally, the time required to take the survey is approximately 25 minutes, with respondents expected to complete the survey during work hours. Consequently, the shortened time period will not cause and undue burden on the respondents.

Item (c): None.

Item (d): None.

Item (e): None:

Item (f): None.

Item (g): None.

Item (h): None.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to the comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside DOE to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Public comments were formally solicited on March 26, 2008, Federal Register Volume 73, Number 59, Page 15997 (Attachment 4). No comments were received as a result of the Federal Register Notice.

No comments were received on the cost and hour burden.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

There are no payments or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The survey will be administered by an independent consulting firm (consultant) using a secure server provided by the consultant. Employees are advised that their responses are strictly confidential and anonymous. Per contract, the consultant is prohibited from sharing raw survey data, including individual responses, with the agency or any third party.

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 DOE 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.

There are no collections in this package involving questions that are sensitive, personal, or private in nature.

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, DOE should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample fewer than 10 potential respondents is desirable.

Approximately 1750 individuals are expected to respond to the survey. Actual numbers will fluctuate from year to year depending on staffing levels. It is expected that the survey will take 25 minutes to complete. The total hours associated with taking the survey is therefore:

(1750 respondents) X (25 minutes per respondent) = 43,750 minutes, or 730 hours.

In addition, approximately 270 hours for in-house administration, including reviewing, reporting and recordkeeping are anticipated.

The total estimated hour burden is: 730 hours + 270 hours = 1000 hours

There is no cost to the respondents, as all respondents will be Federal, contractor or national laboratory employees funded by the agency.

13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information.

There is no capital or start-up cost for this collection of information.

The total cost for contracted services to develop, perform, analyze and report is approximately $110, 000.

14. Provide estimates of annualized cost to the Federal government.

A conservative estimate of average hourly rate for participants funded by OCRWM is $60. Thus the total estimated annualized cost to the federal government is:

1000 hours (from line 12, above) x $60/hour = $60,000

Plus

$110,000 for consultant service (from line 13, above) for a total estimated annualized cost of $170,000.

15. Explain the reasons for any program changes or adjustments reported in Items 13 (or 14) of OMB Form 83-I.

Not applicable. This information collection is a new collection of information.

16. For collections whose results will be published, outline the plans for tabulation and publication.

This package contains no collections whose results will be published.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons why display would be inappropriate.

The Department is not seeking approval to not display the expiration date.

18. Explain each exception to the certification statement identified in Item 19 of OMB Form 83-I.

The Department is not requesting any exceptions to the certification statement provided in Item 19 of OMB Form 83-I.

5