1218-0104(2008)ss(82808)

SUPPORTING STATEMENT FOR THE
INFORMATION COLLECTION REQUIREMENTS IN
THE INORGANIC ARSENIC STANDARD (29 CFR 1910.1018) 1
(OMB CONTROL NO. 1218-0104 (July 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 Occupational Safety and Health Act’s (OSH Act) main objective is to “. . . assure so far as
possible every working man and woman in the Nation safe and healthful working conditions and
to preserve our human resources” (29 U.S.C. 651). To achieve this objective, the OSH Act
authorizes “the development and promulgation of occupational safety and health standards” (29
U.S.C. 651). The OSH Act specifically authorizes information collection by employers as
“necessary or appropriate for the enforcement of the Act or for developing information regarding
the causes and prevention of occupational accidents and illnesses” (29 U.S.C. 657).
For toxic substances, the OSH Act contains specific statutory language. Thus, as appropriate,
health standards must include provisions for monitoring and measuring employee exposure,
medical examinations and other tests, control and technological procedures, suitable protective
equipment, labels and other appropriate forms of warning, and precautions for safe use or
exposure (29 U.S.C. 655 and 657). In this regard, the OSH Act mandates "regulations requiring
employers to maintain accurate records of employee exposure to potentially toxic materials or
other harmful physical agents which are required to be monitored and measured," and further
requires that employers notify employees exposed to concentrations over prescribed limits of this
fact, and of the corrective actions they are taking (29 U.S.C. 657).
Under the authority granted by the OSH Act, the Occupational Safety and Health Administration
(OSHA) published a health standard governing employee exposure to inorganic arsenic (IA) (29
CFR 1910.1018). 2 The purpose of the Inorganic Arsenic Standard (“IA Standard” or
“Standard”) is to reduce the incidence of lung cancer caused among employees exposed to IA.
The Standard affects primarily copper smelters and some chemical facilities. The specific
information collection requirements of the Standard are fully discussed under items 2 and 12
below.
2.

Indicate how, by whom, and for what purpose the information is to be used. Except for a new

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.
2
29 CFR 1910.1018 is incorporated by reference into the Construction and Shipyard Employment standards (29 CFR
1926.1118 and 1915.1018, respectively).

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collection, indicate the actual use the agency has made of the information received from the current
collection.

A. Exposure monitoring (§1910.1018(e))
General §1910.1018(e)(1)(i) - Determinations of airborne exposure levels shall be made from air
samples that are representative of each employee's exposure to inorganic arsenic over an eight
(8) hour period.
§1910.1018(e)(1)(ii) - For the purposes of this section, employee exposure is that exposure
which would occur if the employee were not using a respirator.
§1910.1018(e)(1)(iii) - The employer shall collect full shift (for at least 7 continuous hours)
personal samples including at least one sample for each shift for each job classification in each
work area.
Initial monitoring §1910.1018(e)(2) - Each employer who has a workplace or work operation
covered by this Standard shall monitor each such workplace and work operation to accurately
determine the airborne concentration of inorganic arsenic to which employees may be exposed.
Periodic Monitoring §1910.1018(e)(3)(i) - If the initial monitoring reveals employee exposure to
be below the action level the measurements need not be repeated except as otherwise provided in
paragraph (e)(4) of this section.
§1910.1018(e)(3)(ii) - If the initial monitoring, required by this section, or subsequent
monitoring reveals employee exposure to be above the permissible exposure limit, the employer
shall repeat monitoring at least quarterly.
§1910.1018(e)(3)(iii) - If the initial monitoring, required by this section, or subsequent
monitoring reveals employee exposure to be above the action level and below the permissible
exposure limit the employer shall repeat monitoring at least every six months.
§1910.1018(e)(3)(iv) - The employer shall continue monitoring at the required frequency until at
least two consecutive measurements, taken at least seven (7) days apart, are below the action
level at which time the employer may discontinue monitoring for that employee until such time
as any of the events in paragraph (e)(4) of this section occur.
Purpose: Such monitoring allows employers to identify areas and operations that may require
additional reduction in inorganic arsenic exposure. 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 inorganic arsenic. Periodic monitoring allows employers to determine if minor
changes in processes and materials result in increased inorganic arsenic exposure. If so, periodic
monitoring also enables employers to evaluate the effectiveness of selected control methods. In
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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 inorganic arsenic.
Additional monitoring §1910.1018(e)(4) - Whenever there has been a production, process,
control or personal change which may result in new or additional exposure to inorganic arsenic,
or whenever the employer has any other reason to suspect a change which may result in new or
additional exposures to inorganic arsenic, additional monitoring which complies with paragraph
(e) of this section shall be conducted.
Purpose: Additional monitoring ensures that the workplace is safe, or alerts to the need for
increased control of inorganic arsenic.
Employee Notification §1910.1018(e)(5)(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 affected employees.
§1910.1018(e)(5)(ii) - Whenever the results indicate that the representative employee exposure
exceeds the permissible exposure limit, 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 to or below the permissible exposure limit.
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. Compliance Program (§1910.1018(g)(2))
§1910.1018(g)(2)(i) - The employer shall establish and implement a written program to reduce
exposures to or below the permissible exposure limit by means of engineering and work practice
controls.
§1910.1018(g)(2)(ii) - Written plans for these compliance programs shall include at least the
following:
§1910.1018(g)(2)(ii)(A) - A description of each operation in which inorganic arsenic is
emitted; e.g. machinery used, material processed, controls in place, crew size, operating
procedures and maintenance practices;
§1910.1018(g)(2)(ii)(B) - Engineering plans and studies used to determine methods
selected for controlling exposure to inorganic arsenic;
§1910.1018(g)(2)(ii)(C) - A report of the technology considered in meeting the
permissible exposure limit;
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§1910.1018(g)(2)(ii)(D) - Monitoring data;
§1910.1018(g)(2)(ii)(E) - A detailed schedule for implementation of the engineering
controls and work practices that cannot be implemented immediately and for the adaption
and implementation of any additional engineering and work practices necessary to meet
the permissible exposure limit;
§1910.1018(g)(2)(ii)(F) - Whenever the employer will not achieve the permissible
exposure limit with engineering controls and work practices by December 31, 1979, the
employer shall include in the compliance plan an analysis of the effectiveness of the
various controls, shall install engineering controls and institute work practices on the
quickest schedule feasible, and shall include in the compliance plan and implement a
program to minimize the discomfort and maximize the effectiveness of respirator use;
and
§1910.1018(g)(2)(ii)(G) - Other relevant information.
§1910.1018(g)(2)(iii) - Written plans for such a program 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, Director, any affected employee or authorized employee
representatives.
§1910.1018(g)(2)(iv) - The plans required by this paragraph must be revised and updated at least
annually to reflect the current status of the program.
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
inorganic arsenic exposures.
C. Respirator Program (§1910.1018(h)(2))
§1910.1018(h)(2)(i) - 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: To ensure that employers establish a standardized procedure for selecting, using, and
maintaining respirators for each workplace where respirators will be used. Developing written
procedures ensures that employers implement a respirator program that meets the needs of their
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employees. Burden hours and costs resulting from these program requirements are incurred
under the ICR for OSHA’s Respiratory-Protection Standard (29 CFR 1910.134), OMB Control
Number 1218-0099.
D. Protective work clothing and equipment (§1910.1018(j))
§1910.1018(j)(2)(vi) - The employer shall inform in writing any person who cleans or launders
clothing required by this section, of the potentially harmful effects including the carcinogenic
effects of exposure to inorganic arsenic.
§1910.1018(j)(2)(vii) - The employer shall assure that the containers of contaminated protective
clothing and equipment in the workplace or which are to be removed from the workplace are
labeled as follows:
CAUTION: Clothing contaminated with inorganic arsenic; do not remove dust by blowing or
shaking. Dispose of inorganic arsenic contaminated wash water in accordance with applicable
local, State or Federal regulations.
Purpose: This information allows personnel who handle IA-contaminated clothing and
equipment to protect themselves from the potentially harmful effects of IA.
E. Housekeeping (§1910.1018(k))
Housekeeping plan §1910.1018(k)(4) - A written housekeeping and maintenance plan shall be
kept which shall list appropriate frequencies for carrying out housekeeping operations, and for
cleaning and maintaining dust collection equipment. The plan shall be available for inspection by
the Assistant Secretary.
Maintenance of equipment §1910.1018(k)(5) - Periodic cleaning of dust collection and
ventilation equipment and checks of their effectiveness shall be carried out to maintain the
effectiveness of the system and a notation kept of the last check of effectiveness and cleaning or
maintenance.
Purpose: The purpose of this provision is to inform employees who handle inorganic arsenic
contaminated items of the potential hazards involved. OSHA believes that it is critically
important that employees be made aware of the hazards associated with potential inorganic
exposures. By alerting employers and employees who are involved in disposing of inorganic
arsenic contaminated material of the potential hazards of inorganic arsenic exposure, they will be
better able to implement protective measures.
F. Medical Surveillance (§1910.1018(n))
§1910.1018(n)(1)(i) - Employees covered. The employer shall institute a medical surveillance
program for the following employees:
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§1910.1018(n)(1)(i)(A) - All employees who are or will be exposed above the action
level, without regard to the use of respirators, at least 30 days per year; and
§1910.1018(n)(1)(i)(B) - All employees who have been exposed above the action level,
without regard to respirator use, for 30 days or more per year for a total of 10 years or
more of combined employment with the employer or predecessor employers prior to or
after the effective date of this Standard. The determination of exposures prior to the
effective date of this standard shall be based upon prior exposure records, comparison
with the first measurements taken after the effective date of this standard, or comparison
with records of exposures in areas with similar processes, extent of engineering controls
utilized and materials used by that employer.
Initial examinations §1910.1018 (n)(2) - By December 1, 1978, for employees initially covered
by the medical provisions of this section, or thereafter at the time of initial assignment to an area
where the employee is likely to be exposed over the action level at least 30 days per year, the
employer shall provide each affected employee an opportunity for a medical examination,
including at least the following elements:
§1910.1018(n)(2)(i) - A work history and a medical history which shall include a smoking
history and the presence and degree of respiratory symptoms such as breathlessness, cough,
sputum production and wheezing.
§1910.1018(n)(2)(ii) - A medical examination which shall include at least the following:
§1910.1018(n)(2)(ii)(A) - A standard posterior-anterior chest x-ray;
§1910.1018(n)(2)(ii)(B) - A nasal and skin examination; and
§1910.1018(n)(2)(ii)(C) - Other examinations which the physician believes appropriate
because of the employees exposure to inorganic arsenic or because of required respirator
use.
Periodic examinations §1910.1018(n)(3)
§1910.1018(n)(3)(i) - Examinations must be provided in accordance with this paragraph at least
annually.
§1910.1018(n)(3)(ii) - Whenever a covered employee has not taken the examinations specified in
paragraphs (n)(2)(i) and (n)(2)(ii) of this section within six (6) months preceding the termination
of employment, the employer shall provide such examinations to the employee upon termination
of employment.
Additional examinations §1910.1018(n)(4)
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If the employee for any reason develops signs or symptoms commonly associated with exposure
to inorganic arsenic the employer shall provide an appropriate examination and emergency
medical treatment.
Purpose: The medical surveillance program specified by the Standard enables employers to
determine if any employees have underlying health conditions that place them at increased risk if
exposed to inorganic arsenic so that they can take appropriate preventive measures; and identify
any diseases that occur as a result of inorganic arsenic exposure.
Documentation and maintenance of medical surveillance results provide a continuous record of
employee health. A physician may use these records to determine the extent to which
employees, subsequent to their last medical examination, experience health effects related to
inorganic arsenic exposure. Further, if symptoms appear potentially as the result of inorganic
arsenic exposure, 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 §1910.1018(n)(5) – The employer shall provide the
following information to the examining physician:
§1910.1018(n)(5)(i) - A copy of this Standard and its appendices;
§1910.1018(n)(5)(ii) - A description of the affected employee's duties as they relate to the
employee's exposure;
§1910.1018(n)(5)(iii) - The employee's representative exposure level or anticipated exposure
level;
§1910.1018(n)(5)(iv) - A description of any personal protective equipment used or to be used;
and
§1910.1018(n)(5)(v) - Information from previous medical examinations of the affected employee
which is not readily available to the examining physician.
Purpose: Making the required information available to the physician will aid in the evaluation
of the employee’s health and fitness for particular job assignments involving inorganic arsenic
exposure. If symptoms of organic damage appear, the physician often needs information about
an employee’s previous medical conditions to make an accurate diagnosis of the new condition,
to ascertain its apparent cause, and to identify a course of treatment. Employees can use these
records to determine whether or not they need treatment and to evaluate the effectiveness of their
employer's exposure-control program.
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Physician’s written opinion §1910.1018(n)(6)
§1910.1018(n)(6)(i) - The employer shall obtain a written opinion from the examining physician
which shall include:
§1910.1018(n)(6)(i)(A) - The results of the medical examination and tests performed;
§1910.1018(n)(6)(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 inorganic arsenic;
§1910.1018(n)(6)(i)(C) - Any recommended limitations upon the employee's exposure to
inorganic arsenic or upon the use of protective clothing or equipment such as respirators;
and
§1910.1018(n)(6)(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 explanation or treatment.
§1910.1018(n)(6)(ii) - The employer shall instruct the physician not to reveal in the written
opinion specific findings or diagnoses unrelated to occupational exposure.
§1910.1018(n)(6)(iii) - The employer shall provide a copy of the written opinion to the affected
employee.
Purpose: To aid in determining the initial placement of employees, and to assess an employee’s
ability to use protective clothing and equipment. The physician’s written opinion will also
provide information to the employer about whether or not the employee has a medical condition
indicating overexposure to IA. The requirement that the physician’s opinion be written will
ensure that the information is properly memorialized for later reference. The requirement that
employees be provided with a copy of the medical opinion will ensure that they are informed of
the results of the medical examination so that they can assist in determining the need for, and
evaluate the effectiveness of, treatment or other interventions.

G. Employee information and training (§1910.1018(o))
Training Program §1910.1018(o)(1)
§1910.1018(o)(1)(i) - The employer shall institute a training program for all employees who are
subject to exposure to inorganic arsenic above the action level without regard to respirator use,
or for whom there is the possibility of skin or eye irritation from inorganic arsenic. The employer
shall assure that those employees participate in the training program.
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§1910.1018(o)(1)(ii) - The training program shall be provided by October 1, 1978, for employees
covered by this provision, at the time of initial assignment for those subsequently covered by this
provision, and at least annually for other covered employees thereafter; and the employer shall
assure that each employee is informed of the following:
§1910.1018(o)(1)(ii)(A) - The information contained in Appendix A;
§1910.1018(o)(1)(ii)(B) - The quantity, location, manner of use, storage, sources of
exposure, and the specific nature of operations which could result in exposure to
inorganic arsenic as well as any necessary protective steps;
§1910.1018(o)(1)(ii)(C) - The purpose, proper use, and limitation of respirators;
§1910.1018(o)(1)(ii)(D) - The purpose and a description of the medical surveillance
program as required by paragraph (n) of this section;
§1910.1018(o)(1)(ii)(E) - The engineering controls and work practices associated with
the employee's job assignment; and
§1910.1018(o)(1)(ii)(F) - A review of this Standard.
Purpose: Training is essential to inform employees of the hazards to which they are exposed,
including the location and sources of inorganic arsenic exposure; the training also provides them
with information they can use to minimize the health hazards of inorganic arsenic, such as
effective work practices. Training also serves to explain and reinforce the information presented
to employees on signs, labels, and material safety data sheets (MSDSs), which will be useful and
effective only when employees understand the health hazards of inorganic arsenic and are aware
of the actions they can take to avoid or minimize inorganic arsenic exposures.
Access to training materials §1910.1018(o)(2)
§1910.1018(o)(2)(i) - The employer shall make readily available to all affected employees a
copy of this Standard and its appendices.
§1910.1018(o)(2)(ii) - The employer shall provide; upon request, all materials relating to the
employee information and training program to the Assistant Secretary and the Director.
Purpose: This provision reinforces the requirements of the training program, and permits
OSHA to determine the extent to which an employer is complying with these requirements.
H. Signs and labels (§1910.1018(p))

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Signs §1910.1018(p)(2)(i) - The employer shall post signs demarcating regulated areas bearing
the legend; “DANGER: INORGANIC ARSENIC- CANCER HAZARD. AUTHORIZED
PERSONNEL ONLY. NO SMOKING OR EATING. RESPIRATOR REQUIRED.”
Labels §1910.1018(p)(3) - The employer shall apply precautionary labels to all shipping and
storage containers of inorganic arsenic, and to all products containing inorganic arsenic except
when the inorganic arsenic in the product is bound in such a manner so as to make unlikely the
possibility of airborne exposure to inorganic arsenic. (Possible examples of products not
requiring labels are semiconductors, light emitting diodes and glass). The label shall bear the
following legend; “DANGER: CONTAINS INORGANIC ARSENIC-CANCER HAZARD.
HARMFUL IF INHALED OR SWALLOWED. USE ONLY WITH ADEQUATE
VENTILATION OR RESPIRATORY PROTECTION.”
Purpose: Warning signs and labels inform employees that they are near a hazardous area, and
that they are permitted to enter the area only if they are authorized to do so. Warning signs and
labels also supplement the training employees receive under the Standard.
I. Recordkeeping (§1910.1018(q))
Exposure monitoring §1910.1018(q)(1)(i) - The employer shall establish and maintain an
accurate record of all monitoring required by paragraph (e) of this section.
§1910.1018(q)(1)(ii) - This record shall include:
§1910.1018(q)(1)(ii)(A) - The date(s), number, duration location, and results of each of
the samples taken, including a description of the sampling procedure used to determine
representative employee exposure where applicable;
§1910.1018(q)(1)(ii)(B) - A description of the sampling and analytical methods used and
evidence of their accuracy;
§1910.1018(q)(1)(ii)(C) - The type of respiratory protective devices worn, if any;
§1910.1018(q)(1)(ii)(D) - Name, social security number, and job classification of the
employees monitored and of all other employees whose exposure the measurement is
intended to represent; and
§1910.1018(q)(1)(ii)(E) - The environmental variables that could affect the measurement
of the employee's exposure.
§1910.1018(q)(1)(iii) - The employer shall maintain these monitoring records for at least 40
years or for the duration of employment plus 20 years, whichever, is longer.
Medical surveillance §1910.1018(q)(2)
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§1910.1018(q)(2)(i) - The employer shall establish and maintain an accurate record for each
employee subject to medical surveillance as required by paragraph (n) of this section.
§1910.1018(q)(2)(ii) - This record shall include:
§1910.1018(q)(2)(ii)(A) - The name, social security number, and description of duties of
the employee;
§1910.1018(q)(2)(ii)(B) - A copy of the physician's written opinions;
§1910.1018(q)(2)(ii)(C) - Results of any exposure monitoring done for that employee and
the representative exposure levels supplied to the physician; and
§1910.1018(q)(2)(ii)(D) - Any employee medical complaints related to exposure to
inorganic arsenic.
§1910.1018(q)(2)(iii) - The employer shall in addition keep, or assure that the examining
physician keeps, the following medical records;
§1910.1018(q)(2)(iii)(A) - A copy of the medical examination results including medical
and work history required under paragraph (n) of this section;
§1910.1018(q)(2)(iii)(B) - A description of the laboratory procedures and a copy of any
standards or guidelines used to interpret the test results or references to that information;
§1910.1018(q)(2)(iii)(C) - The initial X-ray;
§1910.1018(q)(2)(iii)(D) - The X-rays for the most recent 5 years; and
§1910.1018(q)(2)(iii)(E) - Any X-rays with a demonstrated abnormality and all
subsequent X-rays;
§1910.1018(q)(2)(iv) - The employer shall maintain or assure that the physician maintains those
medical records for at least 40 years, or for the duration of employment plus 20 years whichever
is longer.
Purpose: Medical and exposure-monitoring records are maintained principally for employee
access, but also are designed to provide valuable information to both employees and employers.
The medical and exposure-monitoring records required by this Standard will aid the employee
and their physicians in determining whether or not treatment or other interventions are needed as
a result of employee exposure to inorganic arsenic. The information also will enable employers
to better ensure that employees are not being overexposed to inorganic arsenic; such information
may alert the employer that steps must be taken to reduce inorganic arsenic exposures.

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Availability §1910.1018(q)(3)
§1910.1018(q)(3)(i) - The employer shall make available upon request all records required to be
maintained by paragraph (q) of this section to the Assistant Secretary and the Director for
examination and copying.
§1910.1018(q)(3)(ii) - 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)-(e) and (g)-(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 (§1910.1018(q)(4)
§1910.1018(q)(4)(i) - Whenever the employer ceases to do business, the successor employer
shall receive and retain all records required to be maintained by this section.
§1910.1018(q)(4)(ii) - Whenever the employer ceases to do business and there is no successor
employer to receive and retain the records required to be maintained by this section for the
prescribed period, these records shall be transmitted to the Director.
§1910.1018(q)(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 he requests them
within that period.
§1910.1018(q)(4)(iv) - The employer shall also comply with any additional requirements
involving the transfer of records set in 29 CFR 1910.1020(h).
Purpose: These records may be used by NIOSH for research purposes, and by employees for
health assessments and 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 as appropriate when making, keeping, and
preserving required records. The Standard is written in performance-oriented language, i.e., in
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terms of what data must be collected rather then how data must be collected.
4.

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

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

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

The information collection does not have a significant impact on a substantial number of small
entities.
6.

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

The information collection frequencies specified by the Standard are the minimum OSHA believes
are necessary to ensure that employers and OSHA can effectively monitor the exposure and health
status of employees exposed to inorganic arsenic.
7.

Explain any special circumstances that would cause an information collection to be conducted in a manner:
•

requiring respondents to report information to the agency more often than quarterly;

•

requiring respondents to prepare a written response to a collection of information in fewer than 30 days after
receipt of it;

•

requiring respondents to submit more than an original and two copies of any document;

•

requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax
records for more than three years;

•

in connection with a statistical survey, that is not designed to produce valid and reliable results that can be

•

generalized to the universe of study;

•

requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

•

that includes a pledge of confidentiality that is not supported by authority established in statute or regulation,
that is not supported by disclosure and data security policies that are consistent with the pledge, or which
unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

•

requiring respondents to submit proprietary trade secret, or other confidential information unless the agency
can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent
permitted by law.

Employers are required to inform each employee in writing or by posting of the exposure-monitoring
results that represent the employee’s exposures within 15 working days after receiving the results. If
these results indicate that the employee has been exposed above the PEL, this written notification
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must also include a statement that the PEL was exceeded and a description of the corrective action
the employer has taken to reduce the employee’s exposure to or below the PEL.
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 notice on September 26, 2008 ((73 FR 55871, Docket No. OSHA-2008-0036))
requesting public comment on its extension of the information collection requirements contained in
the Standard on Inorganic arsenic. This notice was part of a preclearance consultation program
intended to provide those interested parties the opportunity to comment on OSHA’s request for an
extension by the Office of Management and Budget (OMB) of a previous approval of the
information collection requirements found in the Standard above. The Agency has not received
comments in response to the notice.
9.

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

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

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

As medical records contain personal information, OSHA and NIOSH have taken steps to assure that
the medical data in these records are kept confidential. Agency practices and procedures governing
access to employee medical records are contained in 29 CFR 1913.10.
•

Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes,
religious beliefs, and other matters that are commonly considered private. This justification should include the
reasons why the agency considers the questions necessary, the specific uses to be made of the information, the
explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain
their consent.

There are no provisions in the Standard require 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

14

(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. The cost of contracting out or
paying outside parties for information collection activities should not be included here. Instead, this
cost should be included in Item 13.

Table 1
Summary of Burden Hours and Cost Estimates
Existing
Burden
Hours

Requested
Burden
Hours

1. Initial and periodic monitoring

6

2

-4

$96

2. Additional monitoring

1

1

0

$48

3. Employee notification

3

1

-2

$23

(B) Compliance program

72

36

-36

$1,434

(C) Respirator program

0

0

0

0

(D) Protective work clothing and equipment

3

1

-2

$23

(E) Housekeeping

32

2

-30

$90

3,656

262

-3,394

$7,931

2. Information provided to the physician

175

13

-162

$301

3. Physician’s written opinion

175

13

-162

$301

(G) Employee information and training

0

0

0

0

(H) Signs and labels

0

0

.0

0

1. Exposure monitoring and medical
surveillance

720

52

-668

$1,203

2. Availability

17

1

-16

$30

3. Transfer of records

1

1

0

$23

Information Collection Requirement

Change

Estimated
Cost

(A) Exposure monitoring

(F) Medical surveillance
1. General

(I) Recordkeeping

15

TOTAL

4,861

385

-4,476

$11,503

The following hourly wage rates for the relevant occupational categories have been derived from the
National Compensation Survey (NCS), published by the Bureau of Labor Statistics. 3 These wages
have been adjusted to reflect the fact that fringe benefits comprise roughly 29.3 percent of total
employee compensation in the private sector. 4 The costs of labor used in this analysis are therefore
estimates of total hourly compensation. These hourly wages are:
Professional/Manager/Supervisor
Worker
Clerical/Secretary

$48.17 5
$30.27 6
$23.14 7

The following sections summarize the methodology used for estimating the number of burden hours associated
with information collection.
(A) Exposure monitoring (§ 1910.1018(e))
1. Initial and Periodic Monitoring
The Agency estimates that all three covered employers 8 will have employees exposed above the PEL. 9 OSHA
also assumes that employers use vapor badges to collect exposure-monitoring samples, and that a supervisor,
earning $48.17 per hour, will take 10 minutes (.17 hour) to administer and collect vapor badges.
Burden hours: 3 employers × 4 samples/year × .17 hours = 2 hours
Cost:
2 hours × $48.17 = $96
2. Additional Monitoring
The Agency assumes that 10% of employers each year will have a change in inorganic arsenic production,
3

Source: Bureau of Labor Statistics, National Compensation Survey: Occupational Wages in the United States, June
2005 Supplementary Tables. Published July 2006. Supplementary Table 1.1: United States, selected occupations: Mean
hourly earnings and percentiles, all workers, National Compensation Survey, June 2005.
4
Source: Bureau of Labor Statistics. Employer Costs for Employee Compensation – December 2007. March 12, 2008.
5
Executive, administrative and managerial
6
Production employee
7
Administrative support, including clerical
8
SRI Consulting, Directory of Chemical Producers: Copper (II) arsenate, chromated.
http://www.sriconsulting.com/DCP/Public/prod_search.htm
9
The Agency assumed in previous ICR updates that, based on information from the Inflationary Impact Statements for
this Standard, 26.9% of employers covered by this ICR have employees exposed to inorganic arsenic above the action
level. Additionally, an OSHA report cited in previous ICR updates and titled “Sampling Activity by Substance”
determined that 14.1% of establishments have inorganic arsenic exposures that exceeded the PEL; the Agency assumed
in previous ICR updates that the 14.1% of employers whose employees are exposed to inorganic arsenic above the PEL
will perform exposure monitoring once a quarter. To determine the number of employers with employees exposed above
the action level, but at or below the PEL, the Agency previously subtracted the 14.1% percent of employees exposed
above the PEL from 26.9%, resulting in 12.8%. It was assumed that those employers will perform semi-annual exposure
monitoring because their employees are exposed to inorganic arsenic between the action level and the PEL. Given the
dramatic decrease in the number of employers and employees covered by the Standard, OSHA assumed conservatively
that all employers would have employees exposed above the action level but at or below the PEL, as well as employees
exposed above the PEL. As such, each employer would perform exposure monitoring once a quarter.

16

processes, controls, or personnel that may result in new or additional employee exposure to inorganic arsenic,
and that this change will require one airborne sample to assess the inorganic arsenic level in the affected work
area. OSHA also assumes that employers use vapor badges to collect exposure-monitoring samples, and that a
supervisor, earning $48.17 per hour, will take 10 minutes (.17 hour) to administer and collect vapor badges.
Burden hours: 3 employers × 10% × 1 sample/year × .17 hour = 1 hour (rounded up)
Cost:
1 hour × $48.17 = $48
3. Employee Notification
Employers must provide written notification or posting of exposure-monitoring results to each employee
exposed to inorganic arsenic above the action level. As discussed under “Initial and Periodic Monitoring,” the
Agency estimates that 3 employers have exposure limits above the PEL requiring quarterly monitoring.
Finally, one employer (3 × 10%; rounded up) will conduct additional monitoring. OSHA estimates that a
secretary, earning $23.14 per hour, will take 5 minutes (.08 hour) to prepare and post each notification.
Burden hours: ((3 employers × 4 samples/year) + 1 employers) × .08 hour = 1 hour
Cost:
1 hour × $23.14 = $23
(B) Compliance program (§ 1910.1018(g)(2))
Employers must establish and implement a written compliance program to reduce inorganic arsenic exposures
to or below the PEL using engineering and work-practice controls. The written compliance plans for these
programs must be updated annually. The plans must include the information specified in paragraph (g)(2)(ii).
As the Standard has been effective since 1978, OSHA assumes that these plans have already been developed,
and must only be updated. According to the analysis performed under “Initial and Periodic Monitoring”
above, the Agency estimates that 3 employers have employee exposures above the PELs. OSHA estimates
that 8 hours of supervisory time (at $48.17 per hour) and 4 hours of secretarial time (at $23.14 per hour) are
needed to update each plan once.
Burden hour: (8 hours + 4 hours) × 3 employers × 1 updates/year = 36 hours
Cost:
((3 employers × 8 hours x $48.17) + (3 employers x 4 hours × $23.14)) × 1
updates/year = $1,434
(C) Respirator program (§1910.1018(h)(2))
The Standard requires employers to implement a respiratory-protection program in accordance with the
provisions of OSHA’s Respiratory-Protection Standard (29 CFR 1910.134). The burden for this requirement
is taken under the ICR for the Respiratory-Protection Standard, OMB Control Number 1218-0099.
(D) Protective work clothing and equipment (§1910.1018(j)(vi))
Employers must notify anyone who cleans protective clothing or equipment of the hazards from inorganic
arsenic exposure. OSHA assumes that each employer would provide this notification in writing once a year,
and that a secretary (at a wage rate of $23.14 per hour) would take 5 minutes (.08 hour) to type and deliver
the notice.
Burden hours: 3 employers × 1 notification/year × .08 hour = 1 hour
Cost:
1 hour × $23.14 = $23

17

(E) Housekeeping plans (§1910.1018(k)(4))
Employers must keep a written housekeeping and maintenance plan that lists appropriate frequencies for
specific housekeeping activities and for maintaining dust-collection equipment. As the Standard has been
effective since 1978, OSHA assumes that these plans have already been developed, and must only be updated
periodically (on average, about once a year); therefore, no cost has been incurred for developing the plans.
OSHA estimates that updating and maintaining the plans once each year takes a supervisor (at a wage rate of
$48.17 per hour) 30 minutes (.5 hour) and a secretary (earning $23.14 an hour) 15 minutes (.25 hour).
Burden hours: (.5 hour + .25 hour) × 3 employers × 1 update/year = 2 hours
Cost:
((3 employers x .5 hour x $48.17) + (3 employers × .25 hours × $23.14)) × 1
update/year = $90
(F) Medical surveillance (§1910.1018(n))
1. General
The Standard requires annual medical examinations for employees exposed to levels of inorganic arsenic
above the action level. The Agency estimates that 529 employees are exposed to inorganic arsenic. 10 Using
exposure percentages described under “Initial and Periodic Monitoring,” of the 529 exposed employees;
14.1% (75) are exposed above the PEL, and 12.8% (68) are exposed above the action level but below the
PEL. Also, OSHA assumes that 10% of the 143 employees exposed above the action level (14) will require
additional medical examinations. These examinations are administered if an employee has not had an
examination within 6 months of terminating employment or if the employee develops signs or symptoms of
an inorganic arsenic-related disease.
The burden hours for medical examinations represents the time an employee is away from the job. For the
examinations administered under this Standard, the Agency estimates that an employee (at a wage rate of
$30.27 per hour) will be away from the job 1 hour and 40 minutes (1.67 hours).
Burden hours: 157 medical examinations × 1.67 hours = 262 hours
Cost:
262 hours × $30.27 = $7,931
2. Information provided to the physician
Employers must provide the examining physician with specific information on each employee who receives a
medical examination. The Agency assumes that, for each medical examination administered to a covered
employee, it takes a secretary (at a wage rate of $23.14 per hour) 5 minutes (.08 hour) to compile the required
information and provide it to the physician. Based on the analysis performed under “General” above, this
Standard requires that 157 medical examinations be administered each year.
Burden hours: 157 examinations × .08 hour = 13 hours
Cost:
13 hours × $23.14 = $301
3. Physician’s written opinion

10

The previous ICR update estimated that there were 7,400 exposed employees employed in 42 establishments, or an
average of 176 employees per employer. OSHA assumed that this ratio of employees per employer has remained stable
since the previous ICR update.

18

OSHA assumes a secretary earning $23.14 an hour will take 5 minutes (.08 hour) for a secretary to deliver a
copy of the physician’s written opinion to each covered employee. Based on the analysis performed under
“Information provided to the physician” above, 157 medical examinations will be administered each year,
resulting in the same number of opinions that must be delivered to covered employees.
Burden hours: 157 examinations × .08 hour = 13 hours
Cost:
13 hours × $23.14 = $268
(G) Employee information and training (§1910.1018(o))
The Standard’s training requirements are performance-oriented; therefore, no burden hours are incurred from
this provision.
(H) Signs and labels (§1910.1018(p))
The Standard requires that warning signs demarcate regulated areas. The Standard also requires that all
containers used to ship or store inorganic arsenic, and most products consisting of Inorganic arsenic, have
warning labels. The Standard provides specific language for the required signs and labels; therefore no burden
has been taken for this provision because OSHA is providing the required information. (See the final rule
entitled “Controlling Paperwork Burden on the Public,” 5 CFR 1320.3(c)(2).)
(I) Recordkeeping (§1910.1018(q))
1. Exposure monitoring and Medical surveillance
Employers must establish and maintain an accurate record of all exposure monitoring and medical
examinations required by the Standard. Based on the estimated employee exposure levels previously
discussed under “Medical surveillance, General” above, OSHA estimates that 75 employees are exposed
above the PEL requiring that quarterly monitoring records be generated for these employees. Also, another 68
employees are exposed above the action level but below the PEL and requiring semi-annual exposure
monitoring records. In addition, the Agency estimates that 10% of the 529 employees (53 employees) are
monitored as a result of “Additional monitoring.”
As described in the analysis described under “Medical surveillance, General” above, a physician administers
157 medical examinations annually. OSHA estimates that a secretary (at a wage rate of $23.14 per hour) will
spend 5 minutes (.08 hour) annually developing and maintaining each record.
Burden hours: ((75 employees × 4 samples/year) + (68 employees × 2 samples/year) + (53
employees × 1 sample/year) + 157 medical examinations) × .08 = 52 hours
Cost:
52 hours × $23.14 = $1,203
2. Availability
Employers must provide, on request, all records required by the Standard to OSHA compliance officers and
NIOSH for examination and copying. In addition, employers must provide employee medical and exposuremonitoring records to employees and employee representatives on request. The Agency estimates that
compliance officers make a request for inorganic arsenic-related records during one inspection annually, and
that professional, at a wage rate of $48.17 per hour, will spend 5 minutes (.08 hour) informing an OSHA

19

compliance officer of the location of requested records during an inspection. 11 In addition, the Agency
assumes that 10% of the covered employees (those employees exposed above the action level, as well as their
representatives and former employees) will request medical and exposure-monitoring records each year.
Based on the analysis performed under “Employee Notification” above, the total number of covered
employees is 143; 10% of this total is 14 employees. OSHA estimates that it will take a secretary (at a wage
rate $23.14 per hour) 5 minutes (.08 hour) to make these records available to these employees.
Burden hours: (1 inspection × .08 hour) + (14 employees × .08 hour) = 1 hour
Cost:
(1 inspection × .08 hour × $48.17) + (14 employees × .08 hour × $23.14) = $30
3. Transfer of records
If an employer ceases to do business and no successor employer is available to retain the records required by
the Standard for the prescribed period, these records must be transferred to NIOSH. Other employers, before
disposing of these records at the end of the specified retention periods, must notify NIOSH of the impending
disposal, and transfer the records to NIOSH if it requests the records within 3 months of being so notified.
OSHA estimates that 1 hour would be spent transferring these records by all employers who are covered by
the Standard during this clearance period, and that record transfer would be performed by a secretary earning
$23.14 per hour.
Burden hours: 1 hour
Cost:
1 hour × $23.14 = $23

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the
collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

•

•

•

The cost estimate should be split into two components: (a) a total capital and start-up cost component
(annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services
component. The estimates should take into account costs associated with generating, maintaining, and
disclosing or providing the information. Include descriptions of methods used to estimate major cost factors
including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and
the time period over which costs will be incurred. Capital and start-up costs include, among other items,
preparations for collecting information such as purchasing computers and software; monitoring, sampling,
drilling and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the
reasons for the variance. The cost of purchasing or contracting out information collection services should be a
part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of
respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing
economic or regulatory impact analysis associated with the rulemaking containing the information collection,
as appropriate.
Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1)
prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the
information collection, (3) for reasons other than to provide information or keep records for the government,
or (4) as part of customary and usual business or private practices.

11

OSHA estimated the number of inspections by determining the inspection rate (1.4%) for all facilities under the
jurisdiction of the OSH Act (including both Federal OSHA and approved state-plan agencies), and then multiplied the
total number of facilities regulated by the inorganic arsenic Standard (3) by this percentage (i.e., .014 × 3 = .04
inspections (rounded to 1)).

20

CAPITAL COST DETERMINATIONS
1. Exposure monitoring
Employers are required to conduct initial exposure monitoring to determine if any employees are exposed to
inorganic arsenic in excess of the action level. Results from initial exposure monitoring will determine if
further monitoring is required. If exposure levels are above the action level but below the PEL, the employer
must conduct exposure monitoring at least once every 6 months (semiannually); for employees exposed above
the PEL, the employer must perform exposure monitoring at least quarterly. Employers must also conduct
additional monitoring if a change occurs in inorganic arsenic production, processes, controls, or personal that
may result in new or additional employee exposures to inorganic arsenic, of if they suspect that a change may
result in new or additional employee exposures to inorganic arsenic.
OSHA assumes that vapor badges will be used for exposure monitoring; based on estimates in previous ICRs,
the cost of each badge, including laboratory analyses, is $98 for each sample (Wearing the monitoring badge
is not expected to affect the employee’s work.). 12 According to the analysis performed under “Exposure
Monitoring” above, employers collect 4 samples each year.
Cost:

3 x 4 samples × $98 = $1,176

2. Additional monitoring
The agency assumes that 10% of employers will conduct additional monitoring if a change occurs in
inorganic arsenic production, processes, controls, or personal that may result in new or additional employee
exposures to inorganic arsenic each year. This change will requires one airborne sample to assess the
inorganic level in the affected work area.
Burden hours: 3 employers × 10% × 1 sample/year × $98 = $29
2. Medical Examinations
Depending on the employee’s length of exposure to inorganic arsenic above the action level, medical
examinations must be administered annually. In addition, examinations must be provided to employees who
have not had an examination within 6 months of terminating employment, or if they develop signs or
symptoms of inorganic arsenic-related disease. The Agency estimates the cost of the basic medical
examination at $138, and the cost for one chest x-ray at $58. 13 Only 1 chest x-ray is required annually for each
of these employees, regardless of the frequency specified for the medical examinations. Based on the analysis
conducted under “Medical Records” above, 157 medical examinations are administered to 143 covered
employees each year.
Cost:
14.

(157 medical examinations × $138) + (143 chest x-rays × $58) = $29,960

Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used

12

The Consumer Price Index (CPI) indicated a 6.3% increase in the price of professional medical services from 2005 to
2007. The previous ICR estimated that the cost of each badge, including laboratory analysis, was $92; given the 6.3%
increase in the price of professional medical services, it was assumed that the cost of each badge and laboratory analysis
increased by 6.3% as well.
13
The previous ICR estimated that the cost of each medical examination was $130, including one x-ray costing $54;
given the 6.3% increase in the price of professional medical services described previously, it was assumed that the cost
of a medical examination and x-ray increased by 6.3% as well.

21

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.

OSHA does not take costs for other occupational expenses, such as equipment, overhead, and support
staff expenses, because these costs are normal operating expenses and would have occurred without
these collections of information requirements.
1. Federal access

Burden hours: 1
Cost: $37

OSHA estimates that an OSHA compliance officer (GS-12/5), with an hourly wage rate of $36.91,
spends 5 minutes (.08 hour) reviewing Inorganic arsenic-related information during an inspection.
Based on the analysis performed under "Availability" above, OSHA determined that employers
covered by the Inorganic arsenic Standard receive 1 inspection each year.
Burden hours: 1 inspection x .08 hour = 1 hour
Cost: 1 hour x $36.91 = $37
3. Transfer of records

Burden hours: 1
Cost: $2

If an employer ceases to do business and no successor employer is available to retain the records
required by the Standard for the prescribed period, these records must be transferred to NIOSH.
Other employers, before disposing of these records at the end of the specified retention periods, must
notify NIOSH of the impending disposal, and transfer the records to NIOSH if it requests the records
within 3 months of being so notified.
The cost of this provision to the Federal government consists of NIOSH processing records received
from employers who: Cease to do business and have no successor to retain the required records;
notify NIOSH at the end of the specified retention periods that they are going to dispose of the
records and NIOSH requests the records. For this clearance period, OSHA assumes that NIOSH will
receive 3 records from all employers covered by the Standard, and that a secretary (at a wage rate of
$20.81 per hour) will take 5 minutes (.08 hour) to process each record.
Burden hours: 3 records x .08 hours = 1 hour
Cost: 1 hour x .08 hour x $20.81 = $2
15.

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

The Agency is decreasing the burden hours by -4,476 hours (from 4,861 hours to 385 hours). The
Agency reduced the number of employers covered by the standard from 42 employers to 3 employers. The
reduction is the result of a significant decline in arsenic consumption in the United States.
According to the United States Geological Survey (USGS), nearly all of current domestic arsenic
demand is used to create compounds for wood preservation. After a voluntary agreement between
the wood-preserving industry and the Environmental Protection Agency (EPA) the wood preserving
22

industry agreed to stop using chromated copper arsenate (CCA) for decks and other outdoor
residential finishing which decreased the United States consumption of arsenic from 21,600 tons in
2003 to 4,500 tons in 2007. In addition, the Agency is also decreasing the cost from $396,000 to
$31,165, as a result of the decline of arsenic consumption in the United States.
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 of information, completion of report, publication dates,
and other actions.

The information collected under the inorganic arsenic Standard will not be published.
17.

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

OSHA is not seeking such approval.
18.

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

OSHA is not seeking an exception to the certification statement in Item #19.

23