1218-0061CottonFin2008

SUPPORTING STATEMENT FOR THE
INFORMATION COLLECTION REQUIREMENTS IN
THE COTTON DUST STANDARD (29 CFR 1910.1043) 1
(Office of Management and Budget Control (OMB) No. 1218-0061
(June 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 (“OSH Act” or “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 specifically authorizes the Occupational Safety and Health Administration (“OSHA” or
“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, relevant symptoms and appropriate emergency treatment, and proper conditions and
precautions of safe use or exposure” (29 U.S.C. 655). In addition, 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).
To protect employee health, the OSH Act authorizes the Agency to develop standards that
provide for “monitoring or measuring employee exposure” to occupational hazards and
“prescribe the type and frequency of medical examinations and other tests which shall be made
available [by the employer] to employees exposed to such hazards . . . to most effectively
determine whether the health of such employees is adversely affected by such exposure” (29
U.S.C. 655). Moreover, the Act directs the Agency to issue 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 . . ." (29 U.S.C. 657). In
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; it does not provide information or guidance on how
to comply with, or how to enforce, the Standard.

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addition, the OSH Act mandates that “[e]ach employer shall make, keep and preserve, and make
available to the Secretary [of Labor] . . . such records regarding [his/her] activities relating this
Act 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 promulgated its Cotton Dust Standard as 29 CFR 1910.1043 (the "Standard"). OSHA
issued the Standard after determining that occupational exposure to cotton dust poses a health
risk to employees. This determination showed that cotton-dust exposure results in an increased
risk of developing pulmonary diseases especially byssinosis that may result in disability and
premature death. 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.

A. Exposure monitoring (§1910.1043(d))
Alternative to the vertical elutriator cotton dust sampler §1910.1043(d)(1)(iii) - If an alternative
to the vertical elutriator cotton dust sampler is used, the employer shall establish equivalency by
reference to an OSHA opinion or by documenting, based on data developed by the employer or
supplied by the manufacturer, that the alternative sampling devices meets the following criteria:
§1910.1043(d)(1)(iii)(A) - It collects respirable particulates in the same range as the
vertical elutriator (approximately 15 microns);
§1910.1043(d)(1)(iii)(B) - Replicate exposure data used to establish equivalency are
collected in side-by-side field and laboratory comparisons; and
§1910.1043(d)(1)(iii)(C) - A minimum of 100 samples over the range of 0.5 to 2 times
the permissible exposure limit are collected, and 90% of these samples have an accuracy
range of plus or minus 25 per cent of the vertical elutriator reading with a 95%
confidence level as demonstrated by a statistically valid protocol. (An acceptable
protocol for demonstrating equivalency is described in Appendix E of this section.)
Purpose: Obtaining an OSHA opinion or developing documentation to meet the specified
criteria provides assurance to employees that the alternative sampler used by an employer is as
accurate in collecting cotton dust samples as the vertical elutriator.
Initial monitoring §1910.1043(d)(2) - Each employer who has a place of employment within the
scope of paragraph (a)(1), (a)(4), or (a)(5) of this section shall conduct monitoring by obtaining
measurements which are representative of the exposure of all employees to airborne
concentrations of lint-free respirable cotton dust over an eight-hour period. The sampling
program shall include at least one determination during each shift for each work area.

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Purpose: Such monitoring allows employers to identify areas and operations that may require
additional reduction in airborne cotton dust to meet the permissible exposure limit (PEL). 2
Initial exposure monitoring results also assist employers in determining the need for engineering
controls, instituting or modifying work practices, and in selecting appropriate respiratory
protection to prevent employees from overexposure to cotton dust.
Periodic monitoring §1910.1043 (d)(3)(i) - If the initial monitoring required by paragraph (d)(2)
of this section or any subsequent monitoring reveals employee exposure to be at or below the
permissible exposure limit, the employer shall repeat the monitoring for those employees at least
annually.
§1910.1043(d)(3)(ii) - If the initial monitoring required by paragraph (d)(2) of this section or any
subsequent monitoring reveals employee exposure to be above the PEL, the employer shall
repeat the monitoring for those employees at least every six months.
Purpose: Periodic monitoring allows employers to determine if minor changes in processes,
materials, or environmental conditions result in increased concentrations of airborne cotton dust.
If so, periodic monitoring also enables employers to 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 employee overexposure
to cotton dust.
§1910.1043(d)(3)(iii) - Whenever there has been a production, process, or control change which
may result in new or additional exposure to cotton dust, or whenever the employer has any other
reason to suspect an increase in employee exposure, the employer shall repeat the monitoring
and measurements for those employees affected by the change or increase.
Purpose: Additional monitoring ensures that the workplace is safe, or alerts to the need for
increased control of airborne cotton dust.
Employee notification (§1910.1043(d)(4))
§1910.1043(d)(4)(i) - The employer must, within 15 working days after the receipt of the results
of any monitoring performed under this section, notify each affected employee of these results
either individually in writing or by posting the results in an appropriate location that is accessible
to employees.
§1910.1043(d)(4)(ii) - Whenever the results indicate that the employee's exposure exceeds the
applicable permissible exposure limit specified in paragraph (c) of this section, the employer
shall include in the written notice a statement that the permissible exposure limit was exceeded
and a description of the corrective action taken to reduce exposure below the permissible
exposure limit.
2

The PEL differs according to the type of cotton dust involved; see paragraph (c)(1) of the Standard.

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Purpose: Written notices provide assurance that employees are informed about exposure data,
and gives employees specific information about the efforts the employer is taking to lower their
exposures and furnish them with a safe and healthful workplace in accordance with section
8(c)(3) of the Act.
B. Methods of compliance (§1910.1043(e))
Compliance program §1910.1043(e)(3)(i) - Where the most recent exposure monitoring data
indicates that any employee is exposed to cotton dust levels greater than the permissible
exposure limit, the employer shall establish and implement a written program sufficient to
reduce exposures to or below the permissible exposure limit solely by means of engineering
controls and work practices as required by paragraph (e)(1) of this section.
§1910.1043(e)(3)(ii) - The written program shall include at least the following:
§1910.1043(e)(3)(ii)(A) - A description of each operation or process resulting in
employee exposure to cotton dust at levels greater than the PEL;
§1910.1043(e)(3)(ii)(B) - Engineering plans and other studies used to determine the
controls for each process;
§1910.1043(e)(3)(ii)(C) - A report of the technology considered in meeting the
permissible exposure limit;
§1910.1043(e)(3)(ii)(D) - Monitoring data obtained in accordance with paragraph (d) of
this section;
§1910.1043(e)(3)(ii)(E) - A detailed schedule for development and implementation of
engineering and work practice controls, including exposure levels projected to be
achieved by such controls;
§1910.1043(e)(3)(ii)(F) - Work practice program; and
§1910.1043(e)(3)(ii)(G) - Other relevant information.
§1910.1043(e)(3)(v) - Written programs shall be submitted, upon request, to the Assistant
Secretary and the Director, and shall be available at the worksite for examination and copying by
the Assistant Secretary, the Director, and any affected employee or their designated
representatives.
§1910.1043(e)(3)(vi) - The written program required under paragraph (e)(3) of this section shall
be revised and updated when necessary to reflect the current status of the program and current
exposure levels.
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Purpose: This requirement commits the employer to evaluating employee exposure and
establishing an organized and complete program for reducing employee exposures to or below
the PEL. Revising and updating the written program serves to remind employers to implement
and maintain the exposure control methods required by the Standard. Providing the written
programs to OSHA compliance officers ensures that employers are in compliance with the
Standard, while NIOSH may use the information for research purposes. Employees and their
designated representatives review the written programs to determine if the programs validly
represent current exposure conditions, and if employers are taking appropriate actions to control
cotton-dust exposures.
C. Respirator protection (§1910.1043(f))
Respirator program (§1910.1043(f)(2)(i)3 - The employer must implement a respiratory
protection program in accordance with 29 CFR 1910.134 (b) through (d) (except (d)(1)(iii)), and
(f) through (m).
Purpose: The purpose of these requirements is to ensure that employers establish a standardized
procedure for selecting, using, and maintaining respirators for each workplace requiring
respirator use. Developing written procedures ensures that employers implement a respirator
program that meets the needs of their employees.
D. Work practices (§1910.1043(g))
§1910.1043(g) - Each employer shall, regardless of the level of employee exposure, immediately
establish and implement a written program of work practices which shall minimize cotton dust
exposure. The following shall be included were applicable:
§1910.1043(g)(1) - Compressed air "blow down" cleaning shall be prohibited where alternative
means are feasible. Where compressed air is used for cleaning, the employees performing the
"blow down" or "blow off" shall wear suitable respirators. Employees whose presence is not
required to perform "blow down" or "blow of" shall be required to leave the area affected by the
"blow down" or "blow off" during this cleaning operation.
§1910.1043(g)(2) - Cleaning of clothing or floors with compressed air shall be prohibited.
§1910.1043(g)(3) - Floor sweeping shall be performed with a vacuum or with methods designed
to minimize dispersal of dust.
§1910.1043(g)(4) - In areas where employees are exposed to concentrations of cotton dust
greater than the permissible exposure limit, cotton and cotton waste shall be stacked, sorted,
3

OSHA accounts for the burden hours and costs resulting from the respiratory-protection requirements under the
Information Collection Request (ICR) for its Respiratory Protection Standard (§1910.134), OMB Control No. 12180099.

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baled, dumped, removed or otherwise handled by mechanical means, except where the employer
can show that it is infeasible to do so. Where infeasible, the method used for handling cotton and
cotton waste shall be the method which reduces exposure to the lowest level feasible.
Purpose: Having the programs in writing, employees have available to them the detailed workpractice procedures necessary to prevent unnecessary or excessive exposure to cotton dust.
E. Medical surveillance (§1910.1043(h))
General §1910.1043(h)(1)(i) - Each employer covered by the standard shall institute a program
of medical surveillance for all employees exposed to cotton dust.
§1910.1043(h)(1)(ii) - The employer shall assure that all medical examinations and procedures
are performed by or under the supervision of a licensed physician and are provided without cost
to the employee.
Initial examinations §1910.1043(h)(2) - The employer shall provide medical surveillance to
each employee who is or may be exposed to cotton dust. For new employees, this examination
shall be provided prior to initial assignment. The medical surveillance shall include at least the
following:
§1910.1043(h)(2)(i) - A medical history;
§1910.1043(h)(2)(ii) - The standardized questionnaire contained in Appendix B; and
§1910.1043(h)(2)(iii) - A pulmonary function measurement, including a determination of forced
vital capacity (FVC) and forced expiratory volume in one second (FEV(1)), the FEV(1)/FVC
ratio, and the percentage that the measured values of FEV(1) and FVC differ from the predicted
values, using the standard tables in Appendix C. These determinations shall be made for each
employee before the employee enters the workplace on the first day of the work week, preceded
by at least 35 hours of no exposure to cotton dust. The tests shall be repeated during the shift, no
less than 4 and no more than 10 hours after the beginning of the work shift; and, in any event, no
more than one hour after cessation of exposure. Such exposure shall be typical of the employee's
usual workplace exposure. The predicted FEV(1) and FVC for blacks shall be multiplied by 0.85
to adjust for ethnic differences.
Periodic examinations §1910.1043(h)(3)
Under these provisions, employers are to implement a medical surveillance program for every
employee exposed to cotton dust. Accordingly, employers must provide new employees
involved in textile and non-textile operations with an initial medical examination prior to their
job assignment if such an assignment exposes the employees to cotton dust. Employers involved
in textile operations must provide an annual medical examination for employees exposed to
cotton dust above the action level (AL), or a medical examination once every two years for
employees exposed to cotton dust at or below the AL and to specific types of washed cotton
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(regardless of their exposure level). Employers involved in non-textile operations also are to
provide their employees with a medical examination once every two years. Under some
conditions (e.g., specific reductions in pulmonary-function parameters, in the opinion of the
physician), employees must receive a medical examination every six months.
Purpose: Documentation and maintenance of the medical examination results provide a
continuous record of employee health. Physicians use these records to determine the extent to
which employees, since their last examination, experience health effects related to their cottondust exposure. Further, if symptoms of physical damage appear, the physician often needs
information about an employee’s previous medical conditions to make an accurate diagnosis of
the new condition, ascertain its apparent cause, and identify a course of treatment. Medical
records also permit employees to determine whether or not they need treatment, or to evaluate
the effectiveness of their employer’s exposure reduction program.
Information provided to the physician (§1910.1043(h)(4))
§1910.1043(h)(4) - Information provided to the physician. The employer shall provide the
following information to the examination physician:
§1910.1043(h)(4)(i) - A copy of this regulation and its Appendices:
§1910.1043(h)(4)(ii) - A description of the affected employee's duties as they relate to the
employee's exposure;
§1910.1043(h)(4)(iii) - The employee's exposure level or anticipated exposure level;
§1910.1043(h)(4)(iv) - A description of any personal protective equipment used or to be used;
and
§1910.1043(h)(4)(v) - Information from previous medical examinations of the affected employee
which is not readily available to the examining physician.
Purpose: Making this information available to physicians assists them in evaluating the
employee's health and fitness for specific job assignments involving cotton-dust exposure. As
noted earlier, if symptoms of physical damage appear, the physician often needs information
about an employee’s previous medical conditions to make an accurate diagnosis of the new
condition, its apparent cause, and the course of treatment required.
Physician's written opinion (§1910.1043(h)(5))
§1910.1043(h)(5)(i) - The employer shall obtain and furnish the employee with a copy of a
written opinion from the examining physician containing the following:

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§1910.1043(h)(5)(i)(A) - The results of the medical examination and tests including the
FEV(1), FVC, AND FEV(1)/FVC ratio;
§1910.1043(h)(5)(i)(B) - The physician's opinion as to whether the employee has any
detected medical conditions which would place the employee at increased risk of material
impairment of the employee's health from exposure to cotton dust;
§1910.1043(h)(5)(i)(C) - The physician's recommended limitations upon the employee's
exposure to cotton dust or upon the employee's use of respirators including a
determination of whether an employee can wear a negative pressure respirator, and where
the employee cannot, a determination of the employee's ability to wear a powered air
purifying respirator; and,
§1910.1043(h)(5)(i)(D) - A statement that the employee has been informed by the
physician of the results of the medical examination and any medical conditions which
require further examination or treatment.
§1910.1043(h)(5)(ii) - The written opinion obtained by the employer shall not reveal specific
findings or diagnoses unrelated to occupational exposure.
Purpose: 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 an employee, and to assess the employee's ability to use protective clothing and
equipment. The physician's opinion also provides information to the employer about whether or
not the employee has a condition indicating overexposure to cotton dust. The requirement that
the physician's opinion be in writing ensures that the information is properly documented for
later reference. Providing employees with a copy of the physician's written opinion informs
them of the medical examination results so that they can assist in determining the need for, and
evaluate the effectiveness of, treatment or other interventions.
F. Employee education and training (§1910.1043(i))
Training program §1910.1043(i)(1)(i) - The employer shall provide a training program for all
employees exposed to cotton dust and shall assure that each employee is informed of the
following:
§1910.1043(i)(1)(i)(A) - The acute and long term health hazards associated with
exposure to cotton dust;
§1910.1043(i)(1)(i)(B) - The names and descriptions of jobs and processes which could
result in exposure to cotton dust at or above the PEL.

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§1910.1043(i)(1)(i)(C) - The measures, including work practices required by paragraph
(g) of this section, necessary to protect the employee from exposures in excess of the
permissible exposure limit;
§1910.1043(i)(1)(i)(D) - The purpose, proper use and limitations of respirators required
by paragraph (f) of this section;
§1910.1043(i)(1)(i)(E) - The purpose for and a description of the medical surveillance
program required by paragraph (h) of this section and other information which will aid
exposed employees in understanding the hazards of cotton dust exposure; and
§1910.1043(i)(1)(i)(F) - The contents of this standard and its appendices.
§1910.1043(i)(1)(ii) - The training program shall be provided prior to initial assignment and
shall be repeated annually for each employee exposed to cotton dust, when job assignments or
work processes change and when employee performance indicates a need for retraining.
Access to training materials §1910.1043(i)(2)
§1910.1043(i)(2)(i) - Each employer shall post a copy of this section with its appendices in a
public location at the workplace, and shall, upon request, make copies available to employees.
§1910.1043(i)(2)(ii) - The employer shall provide all materials relating to the employee training
and information program to the Assistant Secretary and the Director upon request.
Purpose: Training is essential to inform employees of the health hazards of cotton-dust
exposure, and to provide them with the understanding required to minimize these health hazards.
In addition, training provides information to employees that enable them to recognize how and
where cotton-dust exposure occurs, and what steps to take, including work practices, to limit
such exposure. Another benefit of training is that it serves to explain and reinforce the
information presented to employees on warning signs and labels. This warning information will
be successful and relevant only if employees understand the information, and are aware of the
actions they must take to avoid or minimize cotton-dust exposure. The requirement to provide
the training materials to OSHA compliance officers ensures that the training materials are correct
and meet the requirements of this provision; NIOSH may use the training material for research
purposes.

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G. Signs (§1910.1043(j))
The employer shall post the following warning sign in each work area where the permissible
exposure limit for cotton dust is exceeded:
WARNING
COTTON DUST WORK AREA
MAY CAUSE ACUTE OR DELAYED
LUNG INJURY
(BYSSINOSIS)
RESPIRATORS
REQUIRED IN THIS AREA
Purpose: These signs serve to warn employees that they are in or near a hazardous area.
Warning signs also supplement the training employees receive under the Standard.
H. Recordkeeping (§1910.1043(k))
Exposure measurements §1910.1043(k)(1)
§1910.1043(k)(1)(i) - The employer shall establish and maintain an accurate record of all
measurements required by paragraph (d) of this section.
§1910.1043(k)(1)(ii) - The record shall include:
§1910.1043(k)(1)(ii)(A) 4 - A log containing the items listed in paragraph IV (a) of
Appendix A, and the dates, number, duration, and results of each of the samples taken,
including a description of the procedure used to determine representative employee
exposure;
§1910.1043(k)(1)(ii)(B) - The type of protective devices worn, if any, and length of time
worn; and
§1910.1043(k)(1)(ii)(C) - The names, social security numbers, job classifications, and
exposure levels of employees whose exposure the measurement is intended to represent.
§1910.1043(k)(1)(iii) - The employer shall maintain this record for at least 20 years.

4

An employer may instead retain a copy of the Standard and its appendices, and make this material available to
the employee if the employer references the Standard and its appendices in the record maintained for each employee.

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Medical surveillance §1910.1043(k)(2)
§1910.1043(k)(2)(i) - The employer shall establish and maintain an accurate medical record for
each employee subject to medical surveillance required by paragraph (h) of this section.
§1910.1043(k)(2)(ii) - The record shall include:
§1910.1043(k)(2)(ii)(A) - The name and social security number and description of the
duties of the employee;
§1910.1043(k)(2)(ii)(B) - A copy of the medical examination results including the
medical history, questionnaire response, results of all tests, and the physician's
recommendation;
§1910.1043(k)(2)(ii)(C) - A copy of the physician's written opinion;
§1910.1043(k)(2)(ii)(D) - Any employee medical complaints related to exposure to cotton
dust;
§1910.1043(k)(2)(ii)(E) - A copy of this standard and its appendices, except that the
employer may keep one copy of the standard and the appendices for all employees,
provided that he references the standard and appendices in the medical surveillance
record of each employee; and
§1910.1043(k)(2)(ii)(F) - A copy of the information provided to the physician as required
by paragraph (h)(4) of this section.
§1910.1043(k)(2)(iii) - The employer shall maintain this record for at least 20 years.
Purpose: This requirement provides both employers and employees with access to useful
information. The exposure monitoring and medical surveillance records required by the
Standard assist employees and their physicians in determining the need for treatment or other
interventions as a result of the employees’ exposure to cotton dust. The information also alerts
employers when employee overexposure to cotton dust occurs, thereby enabling employers to
take steps required to reduce cotton-dust exposures. Maintaining the records for a 20 year period
is necessary because of the long latency associated with the development of pulmonary diseases
caused by exposure to cotton dust.
Availability (§1910.1043(k)(3))
§1910.1043(k)(3)(i) - The employer shall make all records required to be maintained by
paragraph (k) of this section available to the Assistant Secretary and the Director for examination
and copying.
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§1910.1043(k)(3)(ii) - Employee exposure measurement records and employee medical records
required by this paragraph shall be provided upon request to employees, designated
representatives, and the Assistant Secretary in accordance with 29 CFR 1910.1020(a) through (e)
and (g) through (i).
Purpose: The OSHA compliance officer uses these records to assess employer compliance with
the major exposure monitoring and medical surveillance requirements of the Standard, while
NIOSH may compile these records for research purposes. Employees and their designated
representatives use exposure monitoring and medical surveillance records to assess an
employee’s medical status over the course of employment, to evaluate the effectiveness of the
employer's exposure reduction program, and for other reasons.
Transfer of records (§1910.1043(k)(4))
§1910.1043(k)(4)(i) - Whenever the employer ceases to do business, the successor employer
shall receive and retain all records required to be maintained by paragraph (k) of this section.
§1910.1043(k)(4)(ii) - Whenever the employer ceases to do business, and there is no successor
employer to receive and retain the records for the prescribed period, these records shall be
transmitted to the Director.
§1910.1043(k)(4)(iii) - At the expiration of the retention period for the records required to be
maintained by this section, the employer shall notify the Director at least 3 months prior to the
disposal of such records and shall transmit those records to the Director if the Director requests
them within that period.
§1910.1043(k)(4)(iv) - The employer shall also comply with any additional requirements
involving transfer of records set forth in 29 CFR 1910.1020(h).
Purpose: NIOSH may use these records for research purposes (e.g., assessing the medical
effects of long-term exposure to cotton dust). In addition, with NIOSH serving as a repository
for exposure monitoring and medical surveillance records, employees have access to their
records if needed for health or other reasons.
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. OSHA wrote the paperwork requirements of the Standard in
performance-oriented language, i.e., in terms of what data to collect, not how to collect the data.

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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 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
83-I), describe any methods used to minimize burden.

The information collection requirements of 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 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 cotton dust, 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 not perform the required information collections, or delay in providing this
information, employees will have an increased probability of developing serious or fatal
pulmonary disease because of their cotton-dust 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, grant-inaid, 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

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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.

Paragraph (d)(4) requires that the employer notify each employee in writing of exposure
monitoring results within 15 working days after receiving these results. The 15 working day
period is a reasonable time for notification in general industry with its more stable workforce and
is the time frame OSHA adopted in most of its health standards for general industry.
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 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 31, 2008 (73 FR 44774, Docket No. OSHA-2008-0015)
soliciting comments from the public and other interested parties on the information collection
requirements contained in the Standard on Cotton Dust (29 CFR 1910.1043). 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 OMB of a previous approval of
the information collection requirements found in the above Standard. The Agency has not
received any comments in response to this notice.
9.

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

The Agency will provide no 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.

To ensure that the personal information contained in medical records remains confidential,
OSHA developed §1913.10 to regulate access to these records.
11.

Provide additional justification for any questions of a sensitive nature, such as sexual behavior and

14

attitudes, religious beliefs, and other matters that are commonly considered private. This
justification should include the reason 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.

The paperwork requirements specified by the Standard do not involve 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
To estimate the number of establishments in textile operations that process cotton, the Agency
updated the Standard Industrial Classification (SIC) industry codes discussed in the previous
ICR to reflect the North American Industrial Classification System (NAICS) codes using the
U.S. Census Bureau’s Bridge between SIC and NAICS. 5 In many cases, the SIC industry sectors
described in the previous ICR comprise only a portion of a given NAICS industry as a whole;
the Bridge describes each NAICS industry and the SICs or partial SICs of which they are
comprised. To determine the number of establishments in each industry sector, it was necessary
to first determine which percentage of establishments in the overall NAICS industry was
comprised by a given SIC industry sector. This ratio was then applied to the current industry
establishments and employment statistics as listed in the 2005 County Business Patterns Survey. 6
In effort to update assumptions regarding the number of establishments covered by the Standard
and employees exposed to cotton dust, the Agency contacted the Agricultural Research Service
and the National Cotton Council. Since neither organization was able to provide updated
estimates, and given that the Agency did not receive comments on estimates in the Cotton Dust
Standard during the Standards Improvement Project – Phase II (SIPs) rulemaking (OSHA
published the final rule on January 5, 2005 (70 FR 1112)), the Agency has retained assumptions
5

Bridge Between SIC and NAICS (U.S. Census Bureau, 1997 Economic Census, Comparative Statistics.
).
6

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

15

from the previous ICR regarding the percentage of establishments processing cotton and also the
percentage of employees exposed to cotton dust. 7 Tables 1 and 2 below present data for
establishments that have textile operations that process cotton, and information for exposed
employees involved in operations that process cotton, respectively.
Non-textile operations principally involve the cottonseed processing and cotton-waste recycling
industries; only the paperwork requirements specified for medical surveillance under paragraph
(h) of the Standard apply to these industries. In consultation with the National Cottonseed
Products Association, the Agency found that 13 establishments were performing cottonseed
processing with a production workforce of roughly 250 employees, and an estimated annual
turnover rate of 35%. In an effort to update establishment and employment estimates for the
cotton-waste recycling industry, the Agency contacted the Secondary Materials and Recycled
Textiles Association (SMART). Following consultation with SMART, the Agency assumes that
the cotton-waste recycling industry contains an estimated production workforce of 1,082 8
employees and an annual employee turnover rate of 31.4%.
The Agency adopted the mean wage rates from “Employer Costs for Employee Compensation,
September 2007,” U.S. Department of Labor, Bureau of Labor Statistics
http://stats.bls.gov/home.htm. Total compensation for these occupational categories includes an
adjustment of 29.4 percent (Employer Costs for Employee Compensation, September 2007, pp.4)
for fringe benefits; this figure represents the average level of fringe benefits in the private sector.
The costs of labor used in this analysis are, therefore, estimates of total hourly compensation.
These hourly wages are:
•
•
•
•

Supervisors:
Production workers, excluding supervisors:
Secretarial workers:
Industrial hygienist technicians:

$48.17
$22.25
$23.14
$26.12

7

Source: Centaur Associates, Inc. (CAI), Technical and Economic Analysis of Regulating Occupational
Exposure to Cotton Dust, Vol. I, Exhibit 2-2, January 1983. CAI prepared this report for the 1983 Regulatory
Impact Analysis performed during a revision to the Standard.
8

Source: U.S. Census Bureau, 2005 County Business Patterns Survey: NAICS 314999 – All Other
Miscellaneous Textile Product Mills. The previous ICR update estimated that there were 1,140 production
employees in the cotton-waste recycling industry. From 2003 to 2005, employment in NAICS 314999 declined by
roughly 5.1%; it was assumed that employment in the cotton-waste recycling industry also declined by 5.1%.

16

Table 1: Estimated Number of Establishments in Textile Operations That Process Cotton
(Including Knitting Mills)

NAICS

Industry Sector

313210

Broadwoven Cotton Weaving
Broadwoven Synthetic
Weaving
Narrow Fabric Weaving

313210
313221

[a]

254 [b]

70

178

289 [c]

21

61

219 [d]

13

28

C

4 [i]

18

51

5

7

61

55

[e]

315111

69

315119

232 [e]

315191

251 [e]

315192

Knitting Mills

24 [e]

313241

143 [e]

313249

162 [e]

313312

221 [e]

313111

Yarn Spinning

313112

Winding and Throwing

313312
313113

Thread Mills

313312

286 [f]
130

[g]

13 [g]
72 [h]
18 [h]

TOTAL
[a]

% of
Establishments
Processing Cotton

No. of
Establishments
Processing Cotton

No. of
Establishments

384

Source: The CAI Report.

[b

Those establishments in SIC 2211 comprised roughly 44% of total establishments in NAICS 313210 in
the 1997 Census. In 2005, there were an estimated 578 establishments in NAICS 313210.
[c]

Those establishments in SIC 2221 comprised roughly 50% of total establishments in NAICS 313210 in
the 1997 Census. In 2005, there were an estimated 578 establishments in NAICS 313210.
[d]

Those establishments in SIC 2241 comprised roughly 99% of total establishments in NAICS 313221 in
the 1997 Census. In 2005, there were an estimated 221 establishments in NAICS 313210.
[e]

Those establishments in SIC 2250 and 2252 comprised 100% of establishments in NAICS 315111,
establishments in SIC 2252 comprised 100% of establishments in NAICS 315119, establishments in SIC 2253 and
2259 comprised 100% of establishments in NAICS 315191, establishments in SIC 2254 and 2259 comprised
100% of establishments in NAICS 315192, establishments in SIC 2257 comprised 100% of establishments in
NAICS 313241 (143), establishments in SIC 2258 and 2259 comprised 100% of establishments in NAICS
313249, and establishments in SIC 2258 and 2259 comprised 50% of establishments in NAICS 313312.
[f]
Those establishments in SIC 2281 comprised roughly 95% of total establishments in NAICS 313111 in

17

the 1997 Census. In 2005, there were an estimated 301 establishments in NAICS 313111.
[g]

Those establishments in SIC 2282 comprised 100% of establishments in NAICS 313112 and roughly 3%
of establishments in NAICS 313312 in the 1997 Census. In 2005, there were an estimated 130 establishments in
NAICS 313112 and 441 establishments in NAICS 313312.
[h]

Those establishments in SIC 2284 comprised roughly 98% of total establishments in NAICS 313113
and roughly 4% of total establishments in NAICS 313312 in the 1997 Census. In 2005, there were an estimated
74 establishments in NAICS 313113 and 441 establishments in NAICS 313312.
[i]

The previous ICR update estimated that there were 1,972 total establishments and 7 establishments
processing cotton. The Agency’s updated figures estimate 1,102 total establishments, or a 44.1% reduction in
total establishments. This 44.1% reduction was then applied to the original number of establishments processing
cotton (7).

18

Table 2: Estimated Number of Exposed Employees in Textile Operations That Process Cotton
(Including Knitting Mills)
NAICS

Industry Sector

No. of
Employees[a]

% of
No. of
No. of
Employees
Employees
Employees
Exposed to
in Establishments
Exposed to
Processing Cotton Cotton Dust [b] Cotton Dust
17,115
77
13,179

313210

Broadwoven Cotton Weaving

24,451

313210

Broadwoven Synthetic Weaving

27,786

5,835

77

4,493

313221

Narrow Fabric Weaving

9,840

1,279

77

985

C

C

353

5,759

77

4,434

930

77

716

1,685

77

1,297

315111

5,856

315119

17,858

315191

8,037
Knitting Mills

315192

1,432

313241

10,923

313249

7,687

313312

8,726

313111

Yarn Spinning

313112

Winding and Throwing

313312

31,995
18,073
524

313113

Thread Mills

313312

2,064
699

TOTAL

25,457

[a]

Source: U.S. Census Bureau, 2005 County Business Patterns Survey. Employment totals were derived
using the ratios used in Table 1 to determine the number of establishments in each industry sector. Thus, if a given
industry sector in Table 1 comprises 50% of the total number of establishments in a NAICS industry, it was
assumed that the industry sector also comprised 50% of the employees.
[b]

Source: The CAI Report.

19

The following sections summarize the methodology used for estimating the number of burden
hours and costs resulting from the information collection requirements of the Standard.
Exposure monitoring (§1910.1043(d))
Alternative cotton-dust sampler (§1910.1043(d)(1))
During the previous clearance period, no employers requested OSHA’s opinion regarding an
alternative cotton-dust sampler. Therefore, the Agency believes that no employer will make
such a request during the clearance period covered by this ICR, and is not taking burden hours
and costs for this paperwork requirement.
Initial, periodic, and additional monitoring (§1910.1043(d)(2) and (d)(3))
OSHA assumes that employers monitor each employee exposed to cotton dust during textile
operations an average of once a year; this average includes initial, periodic, and additional
exposure monitoring. From Table 2, the Agency estimates 25,457 employees are exposed to
cotton dust. As described in the Regulatory Impact Analysis (RIA) for the final Standard
(December 17, 1985, published at 50 FR 51120), employers use six vertical elutriators (or
equivalent samplers) to assess representative cotton-dust exposures for a group of 15 employees,
for a total of 1,697 samples each year (i.e., 25,457 exposed employees ÷ 15 employees per
sample × 1 sample per year)). In addition, the Agency estimates that an in-house industrialhygiene technician takes two hours (2.00 hours) to assemble, check, and disassemble the
samplers used for each group of employees, resulting in total annual burden-hour and cost
estimates of:
Burden hours: 1,697 samples × 2 hours = 3,394 hours
Cost: 3,394 hours × $26.12 = $88,651
Employee notification (§1910.1043(d)(4))
The standard requires employers to notify employees of their exposure-monitoring results.
Notification must occur within 15 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
appropriate location that is accessible to the employees. OSHA believes that such notification
requires a secretary five minutes (.08 hour) to prepare and post the results for the 384 employers
(Table 1). Accordingly, the total annual burden-hour and cost estimates for this paperwork
requirement are:
Burden hours: 384 employers × .08 hour = 31 hours
Cost: 31 hours × $23.14 = $717

20

Methods of compliance (§1910.1043(e))
Compliance program (§1910.1043(e)(3))
OSHA assumes that no new establishments will process cotton during the clearance period
covered by this ICR. Therefore, only existing establishments with poor maintenance or new
processes that result in employee exposures above the PEL will update their written compliance
programs. Accordingly, the Agency estimates, consistent with the previous ICR, that 10
establishments must revise their written compliance programs each year, and that a supervisor
requires about one hour (1.00 hour) to update such a program. Thus, the total burden-hour and
cost estimates for this paperwork requirement each year are:
Burden hours: 10 facilities × 1.00 hour = 10 hours
Cost: 10 hours × $48.17 = $482
Respirator program (§1910.1043(f)(2)(i)
Employers must implement a respiratory protection program in accordance with 29 CFR
1910.134 (b) through (d) (except (d)(1)(iii)), and (f) through (m). OSHA accounts for the burden
hours and costs resulting from the respiratory-protection requirements under the Information
Collection Request (ICR) for its Respiratory Protection Standard (§1910.134), OMB Control No.
1218-0099.
Purpose: The purpose of these requirements is to ensure that employers establish a standardized
procedure for selecting, using, and maintaining respirators for each workplace requiring
respirator use. Developing written procedures ensures that employers implement a respirator
program that meets the needs of their employees.
Work practices (§1910.1043(g))
As noted in the previous determination for compliance programs above, OSHA assumes that this
ICR will cover only existing cotton-processing establishments. Therefore, no employer will have
to develop and implement a written program of work practices to minimize employee cotton-dust
exposure during the clearance period covered by the ICR. Accordingly, the Agency is not taking
any burden hours or cost for this paperwork requirement.

21

Medical surveillance (§1910.1043(h))
Initial examinations (§1910.1043(h)(2))
With an annual employee turnover rate of 31.4% 9 , employers hire 7,993 new employees for
textile operations each year (i.e., 25,457 existing employees × 31.4% turnover rate). The two
non-textile operations, cotton-seed processing and cotton-waste recycling, have yearly employee
turnover rates of 35% 10 and 31.4% 11 , respectively; accordingly, the cottonseed processing
industry has 88 new employees annually (i.e., 250 employees × 35% turnover rate), while 340
new employees enter the cotton-waste-recycling industry annually (i.e., 1,082 existing
employees × 31.4% turnover rate). Therefore, the total number of new employees hired each
year for textile and non-textile operations is 8,421; each of these new employees must receive an
initial medical examination. Assuming that an employee takes one and one-half hours (1.50
hours) of paid time to complete an initial medical examination at an offsite medical facility, 12 the
estimated total annual burden hours and cost of this requirement are:
Burden hours: 8,421 examinations × 1.50 hours = 12,632 hours
Cost: 12,632 hours × $22.25 = $281,062
Periodic examinations (§1910.1043(h)(3))
Consistent with the previous ICR, OSHA assumes that 54% (13,747) of the 25,457 employees
exposed to cotton dust during textile operations have exposures above the AL and, therefore,
must receive at least an annual periodic medical examination. 13 In addition, only employees who
remain with an employer for at least a year require an annual periodic medical examination (i.e.,
new employees, who constitute 31.4% (4,317) of the employees exposed above the AL during
textile operations, are exempt from these examinations for one year from the date of hire).
9

Source: U.S. Bureau of Labor Statistics, Job Openings and Labor Turnover Survey (JOLTS) 2004-2007.
This value represents the average total separations rate for manufacturing industries in the United States from 2004
to 2007.
10

This value was provided as an estimate by the National Cottonseed Products Association.

11

In consultation with the Secondary Materials and Recycled Textiles Association (SMART), the Agency
was unable to identify a unique employee turnover rate for this industry. As a result, the Agency assumes that
employee turnover in the cotton-waste recycling industry is the same as manufacturing industries in the United
States as a whole.
12

This time includes 30 minutes to travel to and from the offsite facility, and an additional hour to
administer an examination. Many employers use offsite medical facilities because employees can receive their
initial medical examinations individually (i.e., in a piecemeal fashion), thereby avoiding the wasted time and
inefficiencies associated with establishing a permanent onsite medical facility or arranging for a mobile medical
facility (e.g., a van).
13

The Agency is using this percentage (54%) because it has no recent information describing cotton-dust
exposures among employees involved in textile operations.

22

Therefore, a total of 9,430 of these employees must receive an annual periodic medical
examination (i.e., 13,747 employees exposed above the AL – 4,317 new employees exposed
above the AL).
The remaining 46% (11,710) of exposed employees involved in textile operations have cottondust exposures at or below the AL; employers must administer a periodic medical examination to
these employees at least once every two years. With an annual turnover rate of 31.4%, OSHA
estimates that 5,511 14 of these employees are available two years after the hiring date for the
required medical examination; assuming that employers administer these examinations evenly
over any two-year period, then 2,756 of these employees obtain the examination each year.
OSHA assumes that exposed employees involved in non-textile operations have no cotton-dust
exposures above the AL; therefore, these employees must receive a periodic medical
examination at least once every two years. With an annual turnover rate of 35%, the Agency
estimates that 106 exposed employees engaged in cottonseed processing operations are available
two years after the hiring date for the required medical examination. The 1,082 employees in the
cotton-waste-recycling industry have a turnover rate of 31.4%, indicating that 509 of these
employees are available two years after the hiring date for periodic medical examinations. If
employers distribute these examinations equally over any two-year period, then 308 (i.e., (106 +
509) ÷ 2) of these employees receive the examination each year.
The Agency assumes that an employee takes one hour (1.00 hour) of paid time to complete a
periodic medical examination at an onsite medical facility. 15 With a total of 12,494 periodic
medical examinations to administer each year, 16 the Agency estimates the annual burden hours
and cost of this requirement to be:
Burden hours: 12,494 examinations × 1.00 hour = 12,494 hours
Cost: 12,494 hours × $22.25 = $277,992
Information provided to the physician (§1910.1043(h)(4))
The Agency believes that, for each medical examination administered to an employee, it takes a
secretary five minutes (.08 hour) to compile the required information and provide it to the
physician. With a total of 20,915 medical examinations to administer each year (i.e., 8,421 initial
examinations and 12,494 periodic examinations), the estimated total annual burden hours and
14

This number (5,511) was calculated using the following equation: 11,710 exposed employees at or below
the AL × 68.6% = 8,033 (first year), 8,033 × 68.6% (second year) = 5,511 exposed employees.
15

These employees would go to a mobile, onsite medical facility (e.g., a van) because they could receive the
medical examinations in small groups; under these conditions, employers save the time (30 minutes) and
associated cost required for employees to travel to an offsite medical facility, while making optimum use of the
onsite facility.
16

This total consists of 9,430 examinations for textile employees exposed above the AL; 2,756 textile
employees exposed at or below the AL; and 308 non-textile employees exposed at or below the AL.

23

cost of this provision are:
Burden hours: 20,915 examinations × .08 hour = 1,673 hours
Cost: 1,673 hours × $23.14 = $38,713
Physician’s written opinion (§1910.1043(h)(5))
OSHA assumes a secretary spends five minutes (.08 hour) delivering a copy of the physician’s
written opinion to each employee who receives a medical examination, as well as maintaining a
record of the opinion. For the 20,915 medical examinations that employees receive each year,
the estimated total annual burden hours and cost of this requirement are:
Burden hours: 20,915 opinions × .08 hour = 1,673 hours
Cost: 1,673 hours × $23.14 = $38,713
Employee education and training (§1910.1043(i))
OSHA believes the 25,457 exposed employees involved in textile operations receive either
initial or refresher training each year. 17 In addition, the Agency assumes that, for each training
session consisting of 20 employees, a supervisor spends 15 minutes preparing for the training
session and one hour providing the required training, for a total of one and one-quarter hours
(1.25 hours). With a total of 1,273 training sessions (i.e., 25,457 employees ÷20 employees per
session), OSHA estimates the total annual burden hours and cost of this training requirement to
be:
Burden hours: 1,273 sessions × 1.25 hours = 1,591 hours
Cost: 1,591 hours × $48.17 = $76,638
Signs (§1910.1043(j))
The provisions containing the paperwork requirements associated with signs specify the design,
format, and specific language for these materials. Therefore, OSHA is taking no burden for these
provisions because it is providing the information needed by employers to meet these
requirements. (See “Controlling Paperwork Burden on the Public,” 5 CFR 1320.3(c)(2)).

17

Refresher training is that training employers must provide at least once a year, if a change occurs in an employee’s
job assignment or work process, or if an employee’s performance indicates a need for retraining.

24

Recordkeeping (§1910.1043(k)) 18
Exposure measurements (§1910.1043(k)(1))
The Agency assumes that a secretary takes about five minutes (.08 hour) a year to establish and
maintain an employee’s exposure-monitoring record. Assuming that 25,457 employees in the
textile industry require exposure monitoring (see the determinations for “Initial, Periodic, and
Additional Monitoring (§ 1910.1043(d)(2) and (d)(3))” above), the total annual burden-hours
and cost estimates for this requirement are:
Burden hours: 25,457 employees × .08 hour = 2,037 hours
Cost: 2,037 hours × $23.14 = $47,136
Availability (§1910.1043(k)(3))
OSHA estimates that its compliance officers request records maintained under the Standard
during five inspections annually, 19 and that a supervisor spends five minutes (.08 hour)
informing the compliance officer of the location of these records. 20 In addition, the Agency
assumes that 10% (2,546) of the covered employees in the textile and non-textile industries (i.e.,
25,457 covered employees × 10% = 2,546 employees) or their designated representatives request
access to these records each year. OSHA estimates that a secretary requires five minutes (.08
hour) to make the requested record available to each employee. Therefore, the total yearly
burden hours and cost associated with making the required records available to OSHA
compliance officers and employees is:
Burden hours: (5 inspection-related requests × .08 hour) + (2,546 employeerelated requests × .08 hour) = 204 hours
Cost: (1 hour × $48.17 (supervisor)) + (204 hours × $23.14 (secretary))
= $4,740
Transfer of records (§1910.1043 (k)(4))
Based on previous ICRs, NIOSH does not receive exposure monitoring or medical surveillance
records from employers in the industries covered by the Standard. However, to account for
possible future transfers, OSHA assumes that these employers transfer three sets of records to
18

The Agency is accounting for the medical-surveillance recordkeeping requirements under the
determinations for “Physician’s written opinion (§1910.1043(h)(5))” above.
19

The Agency estimated the number of inspections by determining the inspection rate (1.4%) for all
establishments under the jurisdiction of the OSH Act (including both Federal OSHA and approved state-plan
agencies), and then multiplied the total number of establishments covered by the Standard (386) by this percentage
(i.e., 384 establishments × 1.4% = 5 inspections.)
20

The Agency assumes, based on previous history, that no NIOSH representative will request these records.

25

NIOSH, and that a secretary spends one hour (1.00 hour) preparing and sending each set of
records for the employer. Therefore, the Agency estimates the total annual burden hours and cost
of this requirement to be:
Burden hours: 3 sets of records × 1.00 hour = 3 hours
Cost: 3 hours × $23.14 per hour = $69
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.

BURDEN-HOUR AND COST DETERMINATIONS
To estimate the number of establishments in textile operations that process cotton, the Agency
updated the Standard Industrial Classification (SIC) industry codes discussed in the previous
ICR to reflect the North American Industrial Classification System (NAICS) codes using the
U.S. Census Bureau’s Bridge between SIC and NAICS. 21 In many cases, the SIC industry sectors
described in the previous ICR comprise only a portion of a given NAICS industry as a whole;
the Bridge describes each NAICS industry and the SICs or partial SICs of which they are
comprised. To determine the number of establishments in each industry sector, it was necessary
to first determine which percentage of establishments in the overall NAICS industry was
comprised by a

21

Bridge Between SIC and NAICS (U.S. Census Bureau, 1997 Economic Census, Comparative Statistics.
).

26

given SIC industry sector. This ratio was then applied to the current industry establishments and
employment statistics as listed in the 2005 County Business Patterns Survey. 22
In effort to update assumptions regarding the number of establishments covered by the Standard
and employees exposed to cotton dust, the Agency contacted the Agricultural Research Service
and the National Cotton Council. Since neither organization was able to provide updated
estimates, and given that the Agency did not receive comments on estimates in the Cotton Dust
Standard during the Standards Improvement Project – Phase II (SIPs) rulemaking (OSHA
published the final rule on January 5, 2005 (70 FR 1112)), OSHA has retained assumptions from
the previous ICR regarding the percentage of establishments processing cotton and also the
percentage of employees exposed to cotton dust. 23 Tables 1 and 2 below present data for
establishments that have textile operations that process cotton, and information for exposed
employees involved in operations that process cotton, respectively.
Non-textile operations principally involve the cottonseed processing and cotton-waste recycling
industries; only the paperwork requirements specified for medical surveillance under paragraph
(h) of the Standard apply to these industries. In consultation with the National Cottonseed
Products Association, the Agency found that 13 establishments were performing cottonseed
processing with a production workforce of roughly 250 employees, and an estimated annual
turnover rate of 35%. In an effort to update establishment and employment estimates for the
cotton-waste recycling industry, the Agency contacted the Secondary Materials and Recycled
Textiles Association (SMART). Following consultation with SMART, the Agency assumes that
the cotton-waste recycling industry contains an estimated production workforce of 1,082 24
employees and an annual employee turnover rate of 31.4%.
The Agency adopted the mean wage rates from “Employer Costs for Employee Compensation,
September 2007,” U.S. Department of Labor, Bureau of Labor Statistics
http://stats.bls.gov/home.htm. Total compensation for these occupational categories includes an
adjustment of 29.4 percent (Employer Costs for Employee Compensation, September 2007, pp.4)
for fringe benefits; this figure represents the average level of fringe benefits in the private sector.
The costs of labor used in this analysis are, therefore, estimates of total hourly compensation.
These hourly wages are:
•

Supervisors:

$48.17

22

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

23

Source: Centaur Associates, Inc. (CAI), Technical and Economic Analysis of Regulating Occupational
Exposure to Cotton Dust, Vol. I, Exhibit 2-2, January 1983. CAI prepared this report for the 1983 Regulatory
Impact Analysis performed during a revision to the Standard.
24

Source: U.S. Census Bureau, 2005 County Business Patterns Survey: NAICS 314999 – All Other
Miscellaneous Textile Product Mills. The previous ICR update estimated that there were 1,140 production
employees in the cotton-waste recycling industry. From 2003 to 2005, employment in NAICS 314999 declined by
roughly 5.1%; it was assumed that employment in the cotton-waste recycling industry also declined by 5.1%.

27

Production workers, excluding supervisors:
Secretarial workers:
Industrial hygienist technicians:

•
•
•

$22.25
$23.14
$26.12

Table 1: Estimated Number of Establishments in Textile Operations That Process Cotton
(Including Knitting Mills)
NAICS

Industry Sector

313210

Broadwoven Cotton Weaving

313210

Broadwoven Synthetic Weaving

313221

Narrow Fabric Weaving

No. of
Establishments

% of
Establishments
Processing Cotton [a]

No. of
Establishments
Processing Cotton

254 [b]

70

178

289

[c]

21

61

219

[d]

13

28

C

4 [i]

18

51

5

7

61

55

[e]

315111

69

315119

232 [e]

315191

251 [e]

315192

Knitting Mills

24 [e]

313241

143 [e]

313249

162 [e]

313312

221 [e]

313111

Yarn Spinning

313112

Winding and Throwing

313312
313113

Thread Mills

313312

286 [f]
130

[g]

13 [g]
72 [h]
18 [h]

TOTAL
[a]

384
Source: The CAI Report.

[b]

Those establishments in SIC 2211 comprised roughly 44% of total establishments in NAICS 313210 in
the 1997 Census. In 2005, there were an estimated 578 establishments in NAICS 313210.
[c]

Those establishments in SIC 2221 comprised roughly 50% of total establishments in NAICS 313210 in
the 1997 Census. In 2005, there were an estimated 578 establishments in NAICS 313210.
[d]

Those establishments in SIC 2241 comprised roughly 99% of total establishments in NAICS 313221 in
the 1997 Census. In 2005, there were an estimated 221 establishments in NAICS 313210.
[e]

Those establishments in SIC 2250 and 2252 comprised 100% of establishments in NAICS 315111,
establishments in SIC 2252 comprised 100% of establishments in NAICS 315119, establishments in SIC 2253 and
2259 comprised 100% of establishments in NAICS 315191, establishments in SIC 2254 and 2259 comprised
100% of establishments in NAICS 315192, establishments in SIC 2257 comprised 100% of establishments in
NAICS 313241 (143), establishments in SIC 2258 and 2259 comprised 100% of establishments in NAICS
313249, and establishments in SIC 2258 and 2259 comprised 50% of establishments in NAICS 313312.
[f]
Those establishments in SIC 2281 comprised roughly 95% of total establishments in NAICS 313111 in
the 1997 Census. In 2005, there were an estimated 301 establishments in NAICS 313111.

28

[g]

Those establishments in SIC 2282 comprised 100% of establishments in NAICS 313112 and roughly 3%
of establishments in NAICS 313312 in the 1997 Census. In 2005, there were an estimated 130 establishments in
NAICS 313112 and 441 establishments in NAICS 313312.
[h]

Those establishments in SIC 2284 comprised roughly 98% of total establishments in NAICS 313113 and
roughly 4% of total establishments in NAICS 313312 in the 1997 Census. In 2005, there were an estimated 74
establishments in NAICS 313113 and 441 establishments in NAICS 313312.
[h]

The previous ICR update estimated that there were 1,972 total establishments and 7 establishments
processing cotton. The agencies updated figures estimate 1,102 total establishments, or a 44.1% reduction in total
establishments. This 44.1% reduction was then applied to the original number of establishments processing cotton
(7).

29

Table 2: Estimated Number of Exposed Employees in Textile Operations That Process
Cotton (Including Knitting Mills)
NAICS

Industry Sector

No. of
Employees[a]

% of
No. of
No. of
Employees
Employees
Employees
Exposed to
in Establishments
Exposed to
Processing Cotton Cotton Dust [b] Cotton Dust
17,115
77
13,179

313210

Broadwoven Cotton Weaving

24,451

313210

Broadwoven Synthetic Weaving

27,786

5,835

77

4,493

313221

Narrow Fabric Weaving

9,840

1,279

77

985

C

C

353

5,759

77

4,434

930

77

716

1,685

77

1,297

315111

5,856

315119

17,858

315191

8,037
Knitting Mills

315192

1,432

313241

10,923

313249

7,687

313312

8,726

313111

Yarn Spinning

313112

Winding and Throwing

313312

31,995
18,073
524

313113

Thread Mills

313312

2,064
699

TOTAL

25,457

[a]

Source: U.S. Census Bureau, 2005 County Business Patterns Survey. Employment totals were derived
using the ratios used in Table 1 to determine the number of establishments in each industry sector. Thus, if a given
industry sector in Table 1 comprises 50% of the total number of establishments in a NAICS industry, it was
assumed that the industry sector also comprised 50% of the employees.
[b]

Source: The CAI Report.

30

The following sections summarize the methodology used for estimating the number of burden
hours and costs resulting from the information collection requirements of the Standard.
Exposure monitoring (§1910.1043(d))
Alternative cotton-dust sampler (§1910.1043(d)(1))
During the previous clearance period, no employers requested OSHA’s opinion regarding an
alternative cotton-dust sampler. Therefore, the Agency believes that no employer will make such
a request during the clearance period covered by this ICR, and is not taking burden hours and
cost for this paperwork requirement.
Initial, periodic, and additional monitoring (§1910.1043(d)(2) and (d)(3))
OSHA assumes that employers monitor each employee exposed to cotton dust during textile
operations an average of once a year; this average includes initial, periodic, and additional
exposure monitoring. From Table 2, the Agency estimates 25,457 employees are exposed to
cotton dust. As described in the Regulatory Impact Analysis (RIA) for the final Standard
(December 17, 1985, published at 50 FR 51120), employers use six vertical elutriators (or
equivalent samplers) to assess representative cotton-dust exposures for a group of 15 employees,
for a total of 1,697 samples each year (i.e., 25,457 exposed employees ÷ 15 employees per
sample × 1 sample per year)). In addition, the Agency estimates that an in-house industrialhygiene technician takes two hours (2.00 hours) to assemble, check, and disassemble the
samplers used for each group of employees, resulting in total annual burden-hour and cost
estimates of:
Burden hours: 1,697 samples × 2 hours = 3,394 hours
Cost: 3,394 hours × $26.12 = $88,651
Employee notification (§1910.1043(d)(4))
The standard requires employers to notify employees of their exposure-monitoring results.
Notification must occur within 15 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
appropriate location that is accessible to the employees. OSHA believes that such notification
requires a secretary five minutes (.08 hour) to prepare and post the results for the 384 employers
(Table 1). Accordingly, the total annual burden-hour and cost estimates for this paperwork
requirement are:
Burden hours: 384 employers × .08 hour = 31 hours
Cost: 31 hours × $23.14 = $717

31

Methods of compliance (§1910.1043(e))
Compliance program (§1910.1043(e)(3))
OSHA assumes that no new establishments will process cotton during the clearance period
covered by this ICR. Therefore, only existing establishments with poor maintenance or new
processes that result in employee exposures above the PEL will update their written compliance
programs. Accordingly, the Agency estimates, consistent with the previous ICR, that 10
establishments must revise their written compliance programs each year, and that a supervisor
requires about one hour (1.00 hour) to update such a program. Thus, the total burden-hour and
cost estimates for this paperwork requirement each year are:
Burden hours: 10 facilities × 1.00 hour = 10 hours
Cost: 10 hours × $48.17 = $482
Work practices (§1910.1043(g))
As noted in the previous determination for compliance programs above, OSHA assumes that this
ICR will cover only existing cotton-processing establishments. Therefore, no employer will have
to develop and implement a written program of work practices to minimize employee cotton-dust
exposure during the clearance period covered by the ICR. Accordingly, the Agency is not taking
any burden hours or cost for this paperwork requirement.
Medical surveillance (§1910.1043(h))
Initial examinations (§1910.1043(h)(2))
With an annual employee turnover rate of 31.4% 25 , employers hire 7,993 new employees for
textile operations each year (i.e., 25,457 existing employees × 31.4% turnover rate). The two
non-textile operations, cotton-seed processing and cotton-waste recycling, have yearly employee
turnover rates of 35% 26 and 31.4% 27 , respectively; accordingly, the cottonseed processing
industry has 88 new employees annually (i.e., 250 employees × 35% turnover rate), while 340
new employees enter the cotton-waste-recycling industry annually (i.e., 1,082 existing
employees × 31.4% turnover rate). Therefore, the total number of new employees hired each
year for textile and non-textile operations is 8,421; each of these new employees must receive an
25

Source: U.S. Bureau of Labor Statistics, Job Openings and Labor Turnover Survey (JOLTS) 2004-2007.
This value represents the average total separations rate for manufacturing industries in the United States from 2004
to 2007.
26

This value was provided as an estimate by the National Cottonseed Products Association.

27

In consultation with the Secondary Materials and Recycled Textiles Association (SMART), the Agency
was unable to identify a unique employee turnover rate for this industry. As a result, the Agency assumes that
employee turnover in the cotton-waste recycling industry is the same as manufacturing industries in the United
States as a whole.

32

initial medical examination. Assuming that an employee takes one and one-half hours (1.50
hours) of paid time to complete an initial medical examination at an offsite medical facility, 28 the
estimated total annual burden hours and cost of this requirement are:
Burden hours: 8,421 examinations × 1.50 hours = 12,632 hours
Cost: 12,632 hours × $22.25 = $281,062
Periodic examinations (§1910.1043(h)(3))
Consistent with the previous ICR, OSHA assumes that 54% (13,747) of the 25,457 employees
exposed to cotton dust during textile operations have exposures above the AL and, therefore,
must receive at least an annual periodic medical examination. 29 In addition, only employees who
remain with an employer for at least a year require an annual periodic medical examination (i.e.,
new employees, who constitute 31.4% (4,317) of the employees exposed above the AL during
textile operations, are exempt from these examinations for one year from the date of hire).
Therefore, a total of 9,430 of these employees must receive an annual periodic medical
examination (i.e., 13,747 employees exposed above the AL – 4,317 new employees exposed
above the AL).
The remaining 46% (11,710) of exposed employees involved in textile operations have cottondust exposures at or below the AL; employers must administer a periodic medical examination to
these employees at least once every two years. With an annual turnover rate of 31.4%, OSHA
estimates that 5,511 30 of these employees are available two years after the hiring date for the
required medical examination; assuming that employers administer these examinations evenly
over any two-year period, then 2,756 of these employees obtain the examination each year.
OSHA assumes that exposed employees involved in non-textile operations have no cotton-dust
exposures above the AL; therefore, these employees must receive a periodic medical
examination at least once every two years. With an annual turnover rate of 35%, the Agency
estimates that 106 exposed employees engaged in cottonseed processing operations are available
two years after the hiring date for the required medical examination. The 1,082 employees in the
cotton-waste-recycling industry have a turnover rate of 31.4%, indicating that 509 of these
employees are available two years after the hiring date for periodic medical examinations. If
employers distribute these examinations equally over any two-year period, then 308 (i.e., (106 +
28

This time includes 30 minutes to travel to and from the offsite facility, and an additional hour to
administer an examination. Many employers use offsite medical facilities because employees can receive their
initial medical examinations individually (i.e., in a piecemeal fashion), thereby avoiding the wasted time and
inefficiencies associated with establishing a permanent onsite medical facility or arranging for a mobile medical
facility (e.g., a van).
29

The Agency is using this percentage (54%) because it has no recent information describing cotton-dust
exposures among employees involved in textile operations.
30

This number (5,511) was calculated using the following equation: 11,710 exposed employees at or below
the AL × 68.6% = 8,033 (first year), 8,033 × 68.6% (second year) = 5,511 exposed employees.

33

509) ÷ 2) of these employees receive the examination each year.
The Agency assumes that an employee takes one hour (1.00 hour) of paid time to complete a
periodic medical examination at an onsite medical facility. 31 With a total of 12,494 periodic
medical examinations to administer each year, 32 the Agency estimates the annual burden hours
and cost of this requirement to be:
Burden hours: 12,494 examinations × 1.00 hour = 12,494 hours
Cost: 12,494 hours × $22.25 = $277,992
Information provided to the physician (§1910.1043(h)(4))
The Agency believes that, for each medical examination administered to an employee, it takes a
secretary five minutes (.08 hour) to compile the required information and provide it to the
physician. With a total of 20,915 medical examinations to administer each year (i.e., 8,421 initial
examinations and 12,494 periodic examinations), the estimated total annual burden hours and
cost of this provision are:
Burden hours: 20,915 examinations × .08 hour = 1,673 hours
Cost: 1,673 hours × $23.14 = $38,713
Physician’s written opinion (§1910.1043(h)(5))
OSHA assumes a secretary spends five minutes (.08 hour) delivering a copy of the physician’s
written opinion to each employee who receives a medical examination, as well as maintaining a
record of the opinion. For the 20,915 medical examinations that employees receive each year, the
estimated total annual burden hours and cost of this requirement are:
Burden hours: 20,915 opinions × .08 hour = 1,673 hours
Cost: 1,673 hours × $23.14 = $38,713
Employee education and training (§1910.1043(i))
OSHA believes the 25,457 exposed employees involved in textile operations receive either
initial or refresher training each year. 33 In addition, the Agency assumes that, for each training
31

These employees would go to a mobile, onsite medical facility (e.g., a van) because they could receive the
medical examinations in small groups; under these conditions, employers save the time (30 minutes) and
associated cost required for employees to travel to an offsite medical facility, while making optimum use of the
onsite facility.
32

This total consists of 9,430 examinations for textile employees exposed above the AL; 2,756 textile
employees exposed at or below the AL; and 308 non-textile employees exposed at or below the AL.
33

Refresher training is that training employers must provide at least once a year, if a change occurs in an
employee’s job assignment or work process, or if an employee’s performance indicates a need for retraining.

34

session consisting of 20 employees, a supervisor spends 15 minutes preparing for the training
session and one hour providing the required training, for a total of one and one-quarter hours
(1.25 hours). With a total of 1,273 training sessions (i.e., 25,457 employees ÷20 employees per
session), OSHA estimates the total annual burden hours and cost of this training requirement to
be:
Burden hours: 1,273 sessions × 1.25 hours = 1,591 hours
Cost: 1,591 hours × $48.17 = $76,638
Signs (§1910.1043(j))
The provisions containing the paperwork requirements associated with signs specify the design,
format, and specific language for these materials. Therefore, OSHA is taking no burden for these
provisions because it is providing the information needed by employers to meet these
requirements. (See “Controlling Paperwork Burden on the Public,” 5 CFR 1320.3(c)(2).)
Recordkeeping (§1910.1043(k)) 34
Exposure measurements (§1910.1043(k)(1))
The Agency assumes that a secretary takes about five minutes (.08 hour) a year to establish and
maintain an employee’s exposure-monitoring record. Assuming that 25,457 employees in the
textile industry require exposure monitoring (see the determinations for “Initial, Periodic, and
Additional Monitoring (§1910.1043(d)(2) and (d)(3))” above), the total annual burden-hours and
cost estimates for this requirement are:
Burden hours: 25,457 employees × .08 hour = 2,037 hours
Cost: 2,037 hours × $23.14 = $47,136

Availability (§1910.1043(k)(3))
OSHA estimates that its compliance officers request records maintained under the Standard
during five inspections annually, 35 and that a supervisor spends five minutes (.08 hour)
informing the compliance officer of the location of these records. 36 In addition, the Agency
34

The Agency is accounting for the medical-surveillance recordkeeping requirements under the
determinations for “Physician’s written opinion (§1910.1043(h)(5))” above.
35

The Agency estimated the number of inspections by determining the inspection rate (1.4%) for all
establishments under the jurisdiction of the OSH Act (including both Federal OSHA and approved state-plan
agencies), and then multiplied the total number of establishments covered by the Standard (386) by this percentage
(i.e., 384 establishments × 1.4% = 5 inspections.)
36
The Agency assumes, based on previous history, that no NIOSH representative will request these records.

35

assumes that 10% (2,546) of the covered employees in the textile and non-textile industries (i.e.,
25,457 covered employees × 10% = 2,546 employees) or their designated representatives request
access to these records each year. OSHA estimates that a secretary requires five minutes (.08
hour) to make the requested record available to each employee. Therefore, the total yearly
burden hours and cost associated with making the required records available to OSHA
compliance officers and employees is:
Burden hours: (5 inspection-related requests × .08 hour) + (2,546 employee-related
requests × .08 hour) = 204 hours
Cost: (1 hour × $48.17 (supervisor)) + (204 hours × $23.14 (secretary)) =
$4,740
Transfer of records (§1910.1043 (k)(4))
Based on previous ICRs, NIOSH does not receive exposure monitoring or medical surveillance
records from employers in the industries covered by the Standard. However, to account for
possible future transfers, OSHA assumes that these employers transfer three sets of records to
NIOSH, and that a secretary spends one hour (1.00 hour) preparing and sending each set of
records for the employer. Therefore, the Agency estimates the total annual burden hours and
cost of this requirement to be:
Burden hours: 3 sets of records × 1.00 hour = 3 hours
Cost: 3 hours × $23.14 per hour = $69
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

36

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.

Capital-Cost Determinations
From these determinations (described below), the Agency estimates that the total capital cost of
these requirements each year is $3,519,494. This total consists of $173,094 for analyzing
exposure-monitoring samples, and $3,346,400 to administer medical examinations.
(A) Exposure monitoring (§1910.1043(d))
This ICR update assumes the average cost for an OSHA-accredited laboratory to analyze a
sample of airborne cotton dust is about $17. 37 As noted above under Initial, Periodic, and
Additional Monitoring (§1910.1043(d)(2) and (d)(3)) in Item 12, industrial-hygiene technicians
conduct 1,697 collections using six vertical elutriators per collection (for a total of 10,182
samples; i.e., 6 vertical elutriators × 1,697 collections). Therefore, the annual cost to analyze the
10,182 samples collected each year is:
Cost: 10,182 samples × $17 = $173,094
(B) Medical surveillance (§1910.1043(h))
This ICR update assumes the cost of a medical examination required by the Standard to be
$160. 38 As noted above under Information provided to the physician (§1910.1043(h)(4)) in Item
12 above, the establishments covered by the Standard administer a total of 20,915 medical
examinations each year, resulting in the following annual cost:
Cost: 20,915 examinations × $160 = $3,346,400
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 Agency estimates that the total annual cost to the Federal government is $57, which consists
of $51.53 ($52, rounded) for OSHA compliance officers to review the required records during
inspections, and $5 for NIOSH to process records received from employers. Other costs, such as
37

The previous ICR estimated the cost to analyze a sample of cotton dust to be $16. The Consumer Price
Index (CPI) indicated a 6.3% increase in the price of professional medical services from 2005 to 2007; the cost to
analyze an air sample was assumed to have increased by 6.3% as well.
38
The previous ICR estimated the cost of a medical examination to be $150. The Consumer Price Index
(CPI) indicated a 6.3% increase in the price of professional medical services from 2005 to 2007; the cost of a
medical examination was assumed to have increased by 6.3% as well.

37

equipment, overhead, and support staff expenses, would occur without these collections of
information requirements; therefore, OSHA considers these costs to be normal operating
expenses.
Recordkeeping (§1910.1043(k))
Availability (§1910.1043(k)(3))
According to footnote 17, OSHA conducts eight inspections each year of the establishments
covered by the Standard. The Agency estimates that a compliance officer (GS-12, step 5), at an
hourly wage rate of $37.89 (including benefits), spends about ten minutes (.17 hour) during an
inspection reviewing the paperwork requirements of the Standard. Therefore, the cost of this
task is:
Cost: 8 inspections x .17 hour x $37.89 = $52
Transfer of records (§1910.1043(k)(4))
Based on the determinations made under Transfer of records (§1910.1029 (k)(4)) in Item 12
above, OSHA estimates that NIOSH processes three sets of records received from employers
covered by the Standard. Assuming that a NIOSH secretary (at a wage rate of $19.26 per hour)
requires five minutes (0.08 hour) processing each set of records, the total cost of this requirement
is:
Cost: 3 sets of records x .08 hour x $19.26 = $5
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 a reduction of 34,576 burden hours from 70,318 hours to 35,742 hours.
The reduction is due to the Agency updating data in Table 2 – Estimated Number of
Establishments in Textile Operations That Process Cotton (Including Knitting Mills) and Table 3
– Estimated Number of Exposed Employees in Textile Operations That Process Cotton
(Including Knitting Mills). In Table 2 there was a decrease in the number of establishments
(from 535 establishments to 384 establishments) and in Table 3 there was a decrease in the

38

number of exposed employees (from 49,628 exposed employees to 25,457 exposed employees)
in textile operations that process cotton (including knitting mills).
The Agency has also decreased the cost for exposure monitoring from $6,526,314 to $3,519,494
a total decrease of $3,006,820. The cost decrease was based on the reduction of laboratory
samples (from 19,854 to 10,182) and medical examinations (from 41,391 to 20,915). The
number of laboratory samples and medical examinations reduced as the result of the reduction in
the number of exposed employees as stated in the paragraph above.
Specifically, the Agency had updated Table 2 “Estimated Number of Exposed Employees in
Textile Operations That Process Cotton (Including Knitting Mills),” that decreased the number
of covered employees by 2,740 employees (from 52,368 to 49,628 covered employees).
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 §1910.1043.
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.

39

Table 3
Summary of Burden-Hour and Cost Estimates
Existing Burden
Hours

Proposed
Burden Hours

Change in
Hours

Estimated
Cost

0

0

0

$0

6,618

3,394

-3,224

$88,651

43

31

-12

$717

10

10

0

$482

0

0

0

$0

0

0

0

$0

49,553

25,126

-24,427

$559,054

Information Provided to the Physician

3,311

1,673

-1638

$38,713

Physician’s Written Opinion

3,311

1,673

-1,638

$38,713

3,101

1,591

-1,510

$76,638

0

0

0

$0

3,970

2,037

-1,933

$47,136

398

204

-194

$4,740

3

3

0

$69

70,318

35,742

-34,576

$854,913

Information Collection Requirement
Exposure monitoring
Alternative Cotton-Dust Sampler
Initial, Periodic, and Additional Monitoring
Employee Notification
Methods of Compliance
Compliance Program
Respirator Protection
Respirator Program
Work Practices
Medical Surveillance
Initial Examinations and Periodic
Examinations

Employee Education and Training
Signs
Recordkeeping
Exposure Measurements and Medical
Surveillance
Availability
Transfer of Records
TOTALS

40