1218-0010(9-2008)new

SUPPORTING STATEMENT FOR THE
INFORMATION-COLLECTION REQUIREMENTS IN
THE VINYL CHLORIDE STANDARD (29 CFR 1910.1017)
(OMB CONTROL NO. 1218-0010 (May 2008)) 1
A. 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 Occupational Safety and Health Act's (OSH Act) main objective 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." As one means in achieving this objective, the Act specifically
authorizes "the development and promulgation of occupational safety and health standards” to
ensure that employees will be furnished "employment and a place of employment . . . free from
recognized hazards that are causing or likely to cause death or serious physical harm."
For toxic substances, the OSH Act contains specific statutory language. Thus, as appropriate,
health standards are required to include provisions for monitoring and measuring employee
exposure, medical examinations and other tests, control and other technological procedures,
suitable protective equipment, labels and other appropriate forms of warning, and precautions for
safe use or exposure (paragraph (6)(b)(7)). In addition, the OSH Act specifically mandates
issuing "regulations requiring employers to maintain accurate records of employee exposures to
potentially toxic materials or other harmful physical agents which are required to be monitored
and measured," and further requires that employees exposed to concentrations over prescribed
limits be notified of this fact, and of the corrective action being taken (paragraphs (8)(c)(1) and
(c)(3)).
Pursuant to its statutory authority, the Occupational Safety and Health Administration (OSHA)
published a health standard governing employee exposure to vinyl chloride (VC) and polyvinyl
chloride (PVC) (29 CFR 1910.1017). The specific collection requirements of this standard are
fully discussed under Items 2 and 12.
VC is a flammable gas at room temperature. It is usually encountered as a cooled liquid. The
colorless liquid forms a vapor that has an ethereal odor. VC may be used as a vinyl monomer in
the manufacture of PVC and other resins, as a chemical intermediate, or as a solvent. Vinyl
chloride gas is absorbed by inhalation; skin absorption has also been suggested. Chronic
exposure to VC may cause cancer in a variety of organs, including liver, lung, brain, and kidney.
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.

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, these provisions.

Exposure Monitoring (§1910.1017(d))
Employers must perform initial monitoring to determine the extent of VC exposure in their
workplace. Initial monitoring assists employers in identifying areas of operation that may
require additional efforts to reduce employee exposure and to come into compliance with the
standard. Initial monitoring results also assist employers in determining the necessity for using
engineering controls, instituting or modifying work practices, and in selecting appropriate
respiratory protection to prevent employees from over-exposure. If the initial monitoring
exceeds the standard's action level, then the employer must conduct periodic monitoring.
Subparagraphs 1910.1017(d)(2)(i) and (d)(2)(ii) require that employers conduct exposure
monitoring at least quarterly if the results of initial exposure monitoring show that employee
exposures are above the PEL, and no less than semiannually if these results indicate exposures
that are at or above the action level.
Periodic monitoring is appropriate because minor changes in process, materials, or
environmental conditions might change the VC airborne concentration levels. By using periodic
monitoring, employers can evaluate the effectiveness of selected control methods. In addition,
these measurements remind both the employer and employees of the continuing need to protect
against the hazards that could result from employees over-exposure.
The employer must perform additional monitoring whenever there has been a change in VC
production, process, or control that may result in an increase in the release of VC. Employers
must also conduct additional monitoring when they have any reason to suspect that any
employee may be exposed to VC in excess of the action level. Such monitoring ensures that
work areas are safe, or alerts the employer that protection may still be needed. Also, exposure
monitoring will inform the examining physician about the existence and extent of potential
hazards.
Written Compliance Plan (§1910.1017(f)(2) and (f)(3))
Employers must establish and implement a written compliance plan when employees are
exposed above the VC permissible exposure limit (PEL). 2 Employers must review and/or revise
the compliance plan at least annually, to describe the program's current status. The compliance
plan must describe the methods the employer will use to reduce employee exposure to, or below,
the PEL in their workplace. The purpose of requiring an employer to establish a written
compliance plan is to effectively promote required compliance with the standard's PEL.
This requirement commits the employer to evaluating employees' exposures and developing an
organized and complete plan of reducing employee exposure to the PEL. There may be cases
when the employer cannot immediately institute the engineering and work practice controls
required by the standard, and must instead use respiratory protection as an interim measure. The
2
VC permissible exposure limit: No employee may be exposed to vinyl chloride at concentrations greater than 1 part
per million (ppm) averaged over any 8-hour period, and no employee may be exposed to VC at concentrations greater than 5 ppm
averaged over any period not exceeding 15 minutes. Also, no employee may be exposed by direct contact with liquid VC. (29
CFR 1910.1017(c)(1) and (c)(2).)

2

requirement to prepare and update a compliance plan ensures that exposure-control methods are
planned on a continuing basis, and revised as necessary.
Respiratory Program (§1910.1017(g)(2))
When respirators are required, the employer must establish a respiratory protection program in
accordance with 29 1910.134, paragraphs (b) through (d) (except (d)(1)(iii) and (d)(3)(iii)(B)(1)
and (2)) and (f) through (m). Paragraph 29 1910.134 (c) requires the employer to develop and
implement a written respiratory protection program with worksite-specific procedures and
elements for respirator use. The purpose of these requirements is to ensure that employers
establish a standardized procedure for selecting, using, and maintaining respirators for each
workplace where respirators will be used. Developing written procedures ensures that employers
develop a respirator program that meets the needs of their employees.
Emergency Plan (§1910.1017(i))
Employers must develop a written operational plan for dealing with emergencies; the plan must
address the storage, handling, and use of VC as a liquid or compressed gas. In the event of an
emergency, appropriate elements of the plan must be implemented. Emergency plans must
maximize employees' personal protection and minimize the hazards of an emergency.
Medical Surveillance (§1910.1017(k))
Medical Examinations (k)(1)(2)
Employers must provide initial examinations for each employee exposed in excess of the action
level. Medical examinations must be provided in accordance with paragraph (k) at least
annually. Each employee exposed to an emergency must also be afforded appropriate medical
surveillance.
Medical examinations and the related information collection requirements provide for periodic
monitoring of employee health. Medical exam records are used by physicians who must
examine employees exposed to VC. Without records of previous medical examinations, the
physician may not be able to determine whether employees have experienced adverse health
effects since their last examination. Further, when symptoms of organic damage appear, the
physician often needs information about the patient's previous medical conditions to make an
accurate diagnosis of the new problem, its apparent cause, and the course of treatment required.
Medical records also ensure that employees can determine whether or not treatment or other
interventions are needed for occupational exposures. The long-term maintenance of medical for
records is necessary because of the lengthy latency periods associated with the manifestation of
health effects caused by VC exposure.
Paragraph (k)(6) specifies that laboratory analyses for all biological specimens included in
medical examination shall be performed by accredited laboratories.
Physician's Written Opinion (k)(4)
3

Employers must promptly obtain a statement from the examining physician of each employee's
suitability for continued exposure to VC, including the use of personal protective equipment and
respirators. A copy of this statement must be provided to the employee.
The purpose of requiring the employer to obtain a written opinion from the examining physician
is to provide the employer with medical information to aid in determining the initial placement
of employees, and to assess an employee's ability to use protective clothing and equipment. The
physician's opinion will also provide information to the employer about whether the employee
may be suffering from over exposure to VC. The requirement that a physician's opinion be
written will ensure that the information is properly memorialized. The requirement that
employees be provided with a copy of the physician's written opinion will ensure that they are
informed of the results of the medical examination so that they can assist in determining the need
for, and evaluate the effectiveness of, treatment or other interventions.
Communication of VC Hazards (§1910.1017(l))
Warning Signs (2)
The employer must post warning signs outside regulated areas and areas containing hazardous
operations, or where emergency conditions exist. Posting warning signs serves to warn
employees that they are entering a hazardous area. Such signs warn employees that entry is
permitted only if they are authorized to do so, and there is a specific need to enter the area.
Warning signs also supplement the training employees receive under this standard.
Recordkeeping (§1910.1017(m))
Exposure Monitoring and Medical Records (i) & (iii)
Employers must maintain employee exposure and medical records. Medical and monitoring
records are maintained principally for employee access, but are designed to provide valuable
information to both employees and employers. The medical and monitoring records required by
this standard will aid employees and their physicians in determining whether or not treatment or
other interventions are needed for VC exposure. The information also will enable employers to
better ensure that employees are not being over exposed; such information may alert the
employer that steps must be taken to reduce VC exposures.
Exposure records must be maintained for at least 30 years, and medical records must be kept for
the duration of employment plus 20 years, or for a total of 30 years, whichever is longer.
Records must be kept for extended periods because of the long latency associated with VCrelated carcinogenesis (i.e., cancer). Cancer often cannot be detected until 20 or more years after
the first exposure to VC.
Transfer of Records (m)(3)
Paragraph (m)(3) of the VC Standard requires that employers who cease to do business and have
4

no successor employer transfer existing exposure-monitoring and medical records to the Director
of the National Institute for Occupational Safety and Health (NIOSH). This employer also must
notify individual employees in writing of the transfer, and comply with any additional
requirements specified in §1910.1020. These records may be used by NIOSH for research
purposes, and by employees for health assessments and other reasons.
Employee Exposure Notification (§1910.1017(n))
Employers must inform each employee of their exposure-monitoring results within 15 working
days after receiving these results. Employers may notify employees either individually in
writing or by posting the monitoring results in an appropriate location that is accessible to the
employees. In addition, if the exposure-monitoring results show that an employee's exposure
exceeds the PEL, the employer must inform the exposed employee of the corrective action the
employer is taking to prevent such overexposure.
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 as appropriate when making, keeping, and
preserving the required records. The standard is written in performance language, i.e., in term of
what data must be collected rather then how data must be collected.
`
4.

Describe efforts to identify duplication. Show specifically why any similar information already available
cannot be used or modified for use for the purposes described in Item 2 above.

The information required to be collected and maintained is specific to each employer and
employee involved, and is not available or duplicated by another source. The information
required by this standard is available only from employers. At this time, there is no indication
that any alternate information source is available.
5.

If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83I), describe any methods used to minimize burden.

The information collection does 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 not conducted or is
conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The Agency believes that the information-collection frequencies required by the Standard are the
minimum frequencies necessary to effectively monitor the exposure and health status of
employees exposed to VC, 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 OSH Act at 29 U.S.C. 651. Accordingly, if employers do
5

not perform the required information-collections, or delay in providing this information,
employees will have an increased probability of developing cancer because of their VC
exposures.
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, grantin-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 a statistical data classification that has not been reviewed and approved by
OMB;

●

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

If exposure monitoring indicates that an employee has been exposed above the PEL, regardless
of whether or not respirators are used, employers must notify the employee in writing (or by
posting the results in an appropriate location) of the exposure-monitoring results, and the steps
being taken to reduce the exposure to within the PEL. This notification must be provided to the
employee within 15 working days.
8.

If applicable, provide a copy and identify the data 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 these comments. Specifically address comments
received on cost and hour burden.
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, disclosed, 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 3 years -- even if the collection of information activity is
the same as in prior periods. There may be circumstances that may preclude 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 Federal Register on July 8, 2008, (73 FR 39050, Docket No. OSHA-2008-0021)
6

requesting public comment on its proposed extension of the information collection requirements
contained in the Vinyl Chloride Standard (29 CFR 1910.1017). 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.
To date, the Agency has received no comments on its notice.
9.

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

No payments or gifts will be provided to the respondents.
10.

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

As medical records may contain private information, OSHA and NIOSH have taken steps to
assure that the medical records data are kept confidential. Agency practices and procedures
governing OSHA access to employee medical records are contained in 29 CFR 1913.10.
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 form whom the information is requested, and
any steps to be taken to obtain their consent.

There are no provisions in this standard requiring that questions of a sensitive nature be asked.
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

According to the Directory of Chemical Producers there are 12 vinyl chloride monomer (VC)
production facilities and 20 polyvinyl chloride (PVC) polymer production facilities operating in
the United States. 3 Therefore, the total number of workers in the 12 VC facilities is 1,776, and
3

Source: SRI International, Directory of Chemical Producers, 2007. Available online at:
http://www.sriconsulting.com/DCP/Public/prod_search.htm

7

the total number of workers in the 20 PVC production facilities is 3,560. The number of
employees in both VC and PVC facilities totals 5,336.
The following hourly wage rates for the relevant occupational categories have been derived from
the National Compensation Survey (NCS), published by the Bureau of Labor Statistics. These
wages have been adjusted to reflect the fact that fringe benefits comprise roughly 29.3 percent of
total employee compensation in the private sector. 4
•
•
•
•
•

Worker:
Managers:
Supervisors:
Clerical/Secretary:
Chemical Technician:

$31.02
$45.62
$39.42
$20.02
$25.89

Table 1
SUMMARY OF BURDEN HOURS AND COSTS

Information Collection Requirements

Existing
Burden Hours

Proposed
Burden Hours

Change

Proposed Estimated
Costs

1. Initial and Periodic Monitoring

786

318

-468

$ 8,233

2. Additional Monitoring

80

32

-48

$828

3. Notification of Monitoring Results

15

7

-8

$140

(B) Written Compliance Program

240

96

-144

$3,560

(C) Respirator Program

0

0

0

$0

(D) Emergency Plan

0

0

0

$0

(1) Medical Exams

524

212

-312

$6,576

(2) Physician's Opinion

21

9

-12

$180

0

0

0

$0

69

28

-41

$500

(A) Exposure Monitoring

(E) Medical Surveillance

(F) Communication of Hazards
1. Warning Signs and Labels
(G) Recordkeeping
1. Exposure Monitoring
4

To estimate updated wage rates, OSHA compared the mean hourly wage for all workers from the July 2003 and
July 2005 National Compensation Surveys. The resulting 4.9% wage increase evidenced over this period was
applied to those wages in the previous ICR to determine updated wage rates for each occupation.

8

2. Medical Surveillance

21

8

-13

$160

3. Federal Access

1

1

0

$46

4. Federal Transfer

1

1

0

$20

1,758

712

-1,046

$20,258

Totals

(A) Exposure Monitoring (§1910.1017(d)(2) and (d)(3))

As in past information collection requests, OSHA assumes that 1% of all employees are exposed
between the action level and the permissible exposure level, and another 1% are exposed above
the PEL. Employees exposed between the action level and the PEL must be monitored quarterly,
while those exposed above the PEL must be monitored quarterly. Also, for the purposes of this
clearance, it is assumed that each employer will have one change in production, process, or
control method that may result in increased VC exposure thereby, requiring that an additional
monitoring sample to be taken.
OSHA assumes that employers use an organic vapor badge for monitoring because these badges
do not interfere with employees' work activity. An in-house laboratory technician, on average,
will spend 1 hour to administer and collect vapor badges.
1. Initial and periodic monitoring

The Vinyl Chloride standard requires employees exposed above the action level but below the
PEL to be monitored semiannually.
Burden hours: 53 employees × 2 times per year × 1 hour = 106 hours
Cost:
106 hours × $25.89 = $2,744
The Vinyl Chloride standard requires employees exposed above the PEL to be monitored
quarterly.
Burden hours: 53 employees × 4 times per year × 1 hour = 212 hours
Cost:
212 hours × $25.89 = $5,489
2. Additional monitoring
Burden hours: 32 employers × 1 time per year × 1 hour = 32 hours
Cost:
32 hours × $25.89 = $828
3. Notification of monitoring results
The standard requires employers to notify employees of their exposure-monitoring results.
Notification must occur within 15 working days after the employer receives the results either by
providing each employee with a written copy of their results or by posting the results in an
9

appropriate location that is accessible to the employees. OSHA estimates that it requires five
minutes (.08 hour) of secretary time to notify each employee exposed above the PEL.
Exposure above the action level, but below the PEL
Burden hours: 8 employers × .08 hour × 2 times per year = 1 hour
Cost:
1 hours × $20.02 hour = $20
Exposure above the PEL
Burden hours: 8 employers × .08 hour × 4 times per year = 3 hours
Cost:
3 hours × $20.02 = $60
Additional monitoring
Burden hours: 32 employers × .08 hr × 1 annually = 3 hours
Cost:
3 hours × $20.02 = $60
(B) Written Compliance Plan (§1910.1017(f)(2) and (f)(3))

Employers who cannot use engineering and work-practice controls immediately to reduce
employee VC exposures to a level at or below the PEL, must develop and implement a plan for
doing so. If this level cannot be attained using only engineering and work-practice controls, then
the written plan must explain how these controls will be used to reduce employee VC exposures
to the lowest level feasible. The plan must be written and updated annually. OSHA estimates
that 8 facilities must update their written plans annually, and that it takes eight hours of a
manger's time, and four hours of clerical time, to update an existing plan. The previous ICR
estimated that 20—or 25% of the total 80—facilities must update their written plans annually.
OSHA assumes that this ratio has remained constant.
Burden hours: 8 facilities × 12 hours × 1 annually = 96 hours
Cost:
8 facilities × ((8 manager hours × $45.62) + (4 secretary hours × $20.02)) × 1

time per year = $3,560
(C) Respiratory Program (§1910.1017(g)(2))
The standard requires that a respiratory protection program meeting the requirements of 29 CFR
1910.134 be established and maintained. The burden associated with this provision is determined
under the Respiratory Protection ICR (OMB number 1218-0099).
(D) Emergency Plan (§1910.1017(i))
Employers must develop a written plan addressing emergency situations for facilities that store,
handle, and use VC as a liquid or a compressed gas. The development of this plan applies only to
new facilities. The Agency is unaware of any new VC or PVC facilities, therefore no burden
hours have been attributed for this activity.
10

Employers must develop a written plan addressing emergency situations for facilities that store,
handle, and use VC as a liquid or a compressed gas. The development of this plan applies only
to new facilities. The Agency is unaware of any new VC or PVC facilities, therefore no burden
hours have been attributed for this activity.
(E) Medical Surveillance (§1910.1017(k))
1. Medical exams
The VC standard requires that a medical surveillance program be instituted for employees
exposed to VC in excess of the action level. Burden hours are attributed to the time employees
are away from work. OSHA assumes that a manufacturing worker would be away from work for
a total of two hours for each surveillance event. The number of employees was determined from
the number of employee monitoring records.
Burden hours: 106 employees × 1 annually × 2 hours = 212 hours
Cost:
212 hours × $31.02 = $6,576
2. Physician's written opinion (§1910.1017(k)(4))
Employers are required to obtain, and provide to each employee, a copy of a physician's
statement regarding the employee's suitability for continued exposure to VC, including use of
protective equipment and respirators if appropriate.
The Agency estimates a secretary will take five minutes (.08 hour) to give a copy of the
physician's written opinion to an affected employee. The number of exams was determined from
the figures in "Medical exams" above.
Burden hours: 106 examinations × .08 hour = 9 hours
Cost:
9 hours × $20.02 = $180
F) Communication of Hazards (§1910.1017(l))
1. Warning signs and labels

The standard requires that warning signs be provided and displayed outside, and at approaches
to, regulated areas, areas containing hazardous operations, and where an emergency exists. Since
OSHA is providing specific language in the regulation for these situations, no burden hours are
attributed to this provision.
Containers of VC, PVC, and PVC resin waste generated from reactors and other waste
contaminated with VC must be labeled. Specific language is provided by OSHA for these labels,
so no burden hours are attributed to this provision.
(G) Recordkeeping (§1910.1017(m))
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1. Exposure monitoring records and retention
Exposure monitoring records are required to include the date of monitoring, concentrations
determined, identity of the instrument and methods used, and any additional information
necessary to determine individual exposures if such exposures are determined by means other
than individual monitoring. OSHA estimates that a secretary will take approximately five
minutes (.08 hour) to maintain these records.
Exposure above the action level, but below the PEL
Burden hours: 53 employees × 2 times per year × .08 hour = 8 hours
Cost:
8 hours × $20.02 = $160
Exposure above the PEL
Burden hours: 53 employees × 4 times per year × .08 hour = 17 hours
Cost:
17 hours × $20.02 = $340
Additional monitoring
Burden hours: 32 employers × 1 annually × .08 hour = 3 hours
Cost:
3 hours × $20.02 = $60
2. Medical records
OSHA estimates that maintaining medical records requires approximately five minutes (.08
hour) of clerical time annually per record. The following equations are based on the assumptions
described under "Medical exams" above.
Burden hours: 106 employees × 1 annually × .08 hour = 8 hours
Cost:
8 hours × $20.02 = $160
3. Federal access
The VC standard requires that employers make available monitoring, measuring, and medical
records at the request of the Assistant Secretary (usually an OSHA compliance officer).
The Agency estimates that its compliance officers will conduct one inspection annually at
facilities covered by the Standard and that they will request all required records at this site. 5
OSHA believes that a manager, at $45.62 per hour, will expend approximately five minutes (0.08
hour) to inform an OSHA compliance officer of the location of the various records during an
inspection. The Agency estimates that it will request access to VC records during four

12

inspections.
Burden hours: 1 employer × .08 hour = 1 hour (rounded to one hour)
Cost:
1 hour × $45.62 = $46
4. Transfer of records
In the event that an employer ceases to do business and there is no successor employer to receive
and retain the medical and exposure records for the specified periods, these records must be
transmitted by registered mail to the Director of NIOSH. The employer also must notify each
employee individually in writing of this transfer. The employer shall also comply with any
additional requirements set forth in 29 CFR 1910.1020(h).
In the past, NIOSH has received no VC-related medical or exposure records. However, for the
purposes of this clearance, OSHA assumes that one employer will send records to NIOSH each
year, and that a secretary would spend one hour to prepare and send the records to NIOSH and to
inform employees of this transfer. Burden estimate is one hour, at a cost of $20.02, rounded
down to $20.00.
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 services 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 respondents (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.

Exposure Monitoring
Employers are required to conduct initial exposure monitoring to determine if there are any
employees exposed in excess of the action level. Results from the initial exposure monitoring
will determine if further monitoring is required. If exposure levels are above the PEL, then the
employer is required to conduct at least quarterly monitoring. If the exposure readings are above
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the action level, but at or below the PEL, then semi-annual monitoring must be conducted. (The
use of respirators cannot be considered in making these exposure determinations.)
In addition to production, process, or control changes that may result in new or additional VC
exposures and an increased exposure-monitoring requirement, monitoring must also be
conducted if the employer has any other reason to suspect that employees may be exposed in
excess of the action level. The Agency assumes that employers will use an organic vapor badge
to conduct required monitoring. The cost for the badge and the lab analysis for the badge is
estimated to be $98. 6
Exposure above the action level, but below the PEL
Cost:

53 employees × 2 times per year × $98 = $10,388

Exposure above the PEL
Cost:

53 employees × 4 times per year × $98 = $20,776

Additional monitoring
Cost:

32 employers × 1 time per year × $98 = $3,136

Medical Exams
The Agency assumes that each medical exam, which includes the physician's written opinion,
costs the employer $138. 7 Approximately 106 medical exams will be given each year at a total
cost of $14,628.
Cost:

106 examinations × $138 = $14,628

14. Provide estimates of 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), and 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 in a single table.

The costs to the Federal government are as follows:
OSHA does not take costs for other occupational expenses, such as equipment, overhead, and
support staff expenses, since these costs are normal operating expenses and would have occurred
6

The Consumer Price Index (CPI) indicated a 6.3% increase in the price of professional medical services from 2005
to 2007. The previous ICR estimated that the cost for the badge and lab analysis was $92; given the 6.3% increase
in the price of professional medical services, it was assumed that the cost of exposure monitoring increased by
6.3% as well.
7
The previous ICR estimated that the cost for each medical exam was $130. Given the 6.3% increase in the price of
professional medical services from 2005 to 2007, it was assumed that the cost of each medical exam increased by
6.3% as well.

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without these collections of information requirements.
Federal Access
In fulfilling its enforcement responsibilities under paragraph (m), the Agency estimates that a
compliance officer (GS-12, step 5), at an hourly wage rate of $31.34, 8 spends about five minutes
(0.08 hour) during an inspection reviewing the records required by the Standard. According to
footnote 4 above, OSHA believes that its compliance officers conduct 1 inspection annually. The
cost to the Federal government associated with the collection of the VC information
requirements described in this supporting statement is $3.
Costs:

1 inspection × .08 hour × $31.34 = $3

Transfer of Records to NIOSH
The VC Standard requires that if an employer ceases to do business and there is no successor employer to
maintain employee records for the required periods of time, the medical and exposure records must be
transmitted to NIOSH. Also, after the retention periods for these records end, employers must notify
NIOSH at least three months prior to disposing of records, and transmit the records to NIOSH if required
to do so by a specific occupational safety and health standard. The cost to the Federal government
consists of the costs associated with processing records transmitted to NIOSH. During the past year,
NIOSH did not receive any records from employers. However, we allowed a burden of one hour for
transfer of records to NIOSH during the period covered by this clearance. NIOSH estimated that 15
records can be processed in one hour at a cost $15.00 per hour. Therefore, the Federal cost for records
transfer is estimated to be $15.00 per year.
The total cost to the Federal government is estimated to be $18.00.
15.

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

The Agency is requesting an adjustment decrease in hours from 1,758 to 712 hours, a 1,046 burden
hour reduction. The reduction is a result of fewer VC and PVC establishments; this also resulted in
fewer estimated number of employees being exposed above the VC exposure levels. The currently
approved ICR estimates a total of 77 establishments. The proposed ICR estimates a total of 32
establishments.
The Agency is also requesting an adjustment decrease in costs from $114,000 to $48,929, a $65,072
cost reduction. The reduction is primarily the result of the decrease in the number of establishments
from 77 to 32 establishments. The reduction in establishments resulted in fewer exposure monitoring
readings (from 342 to 138 readings) and fewer medical examinations (from 262 to 106 exams).

16.
8

For collections of information whose results will be published, outline plans for tabulation, and publication.

Salary Table 2008-GS (GS-12, Step 5), U.S. Office of Personnel Management

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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 of information, completion of report, publication dates,
and other actions.

The collection of information will not be published.
17.

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

There are no forms on which to display the OMB expiration date.
18.

Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork
Reduction Act Submission," of OMB 83-I.

OSHA is not seeking such exceptions.

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