SS_1218-0202-Hazwoper(02-08-09)

SUPPORTING STATEMENT FOR THE INFORMATION
COLLECTION REQUIREMENTS OF THE
HAZARDOUS WASTE OPERATIONS AND EMERGENCY
RESPONSE (HAZWOPER) STANDARD
(29 CFR 1910.120) 1
OFFICE OF MANAGEMENT AND BUDGET (OMB)
CONTROL NO. 1218-0202 (February 2009)

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 objective of the Occupational Safety and Health Act of 1970 (i.e., “the 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 Act authorizes “the development and promulgation of occupational safety and
health standards” (29 U.S.C. 651).
Section 6(b)(7) of the Act specifies that “[a]ny standard promulgated under this subsection shall
prescribe the use of labels or other appropriate forms of warning as are necessary to insure that
employees are apprised of all hazards to which they are exposed, relevant symptoms and
appropriate emergency treatment, and proper conditions and precautions of safe use or
exposure.” This provision goes on to state that “[t]he Secretary, in consultation with the
Secretary of Health and Human Services, may by rule promulgated pursuant to section 553 of
title 5, United States Code, make appropriate modifications in the foregoing requirements
relating to the use of labels or other forms of warning . . . as may be warranted by experience,
information, or medical or technological developments acquired subsequent to the promulgation
of the relevant standard” (29 U.S.C. 655).
With regard to recordkeeping, the Act specifies 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). 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. 657).

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The purpose of this Supporting Statement is to analyze and describe the burden hours and cost associated with
provisions of this Standard that contain paperwork requirements; this Supporting Statement does not provide
information or guidance on how to comply with, or how to enforce, these provisions.

In addition, Section 126(e) of the "Superfund Amendments and Reauthorization Act of 1986"
(SARA) (Public Law 99-499) which became law on October 17, 1986, required the Secretary of
Labor, pursuant to Section 6 of the Act, to promulgate standards for the safety and health
protection of employees engaged in hazardous waste operations and emergency response.
Section 126(a) of SARA also specified that those standards were to become effective a year after
publication. Section 126(b) lists 11 worker protection provisions that the Secretary of Labor had
to include in OSHA's final standard. Those provisions require OSHA to address the preparation
of various written programs, plans and records; the training of employees; the monitoring of
airborne hazards; the conduct of medical surveillance; and the distribution of information to
employees. The provisions also require the collection of information from employers engaged in
hazardous waste operations and their emergency response to such operations. The final standard
covers the provisions mandated in SARA.
Therefore, under the authority granted by the SARA and the OSH Act, the Occupational Safety
and Health Administration (i.e., “OSHA” or “the Agency”) published at 29 CFR 1910.120 a
standard for general industry regulating the operation of hazardous waste operations (i.e.,
“HAZWOPER” or” the Standard"). Item 12 below describes 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.

The Standard specifies a number of collection of information (paperwork) requirements. Each
provision is described in detail in #12 below. Employers can use the information collected under
the HAZWOPER rule to develop the various programs the Standard requires and to ensure that
their employees are trained properly about the safety and health hazards associated with
hazardous waste operations and emergency response to hazardous waste releases. OSHA will
use the records developed in response to this Standard to find adequate compliance with the
safety and health provisions. The employer's failure to collect and distribute the information
required in this Standard will affect significantly OSHA's effort to control and reduce injuries
and fatalities. Such failure would also be contrary to the direction Congress provided in SARA.
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 burdens.

Employers may use automated, electronic, mechanical, or other technological information
collection techniques, or other forms of information technology (e.g., electronic submission of
responses) when establishing and maintaining the required records. The Agency wrote the
paperwork requirements of the Standard in performance-oriented language (i.e., in terms of what
data to collect, not how to record the data). Advanced data processing programs permit easier
accessibility to collected information during OSHA inspections. They also permit the storage of
collected information at locations other than the place of inspection if the employer can deliver

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the data quickly to the place of inspection (i.e., e-mail, telefax, or other electronic data transfer
method).
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.

To prevent duplication of effort, OSHA coordinated the preparation of this rule with appropriate
individuals from Federal OSHA, state OSHA programs, U.S. Department of Transportation
(DOT) and the U.S. Environmental Protection Agency (EPA). OSHA reviewed standards
addressing similar hazardous waste operations and emergency response in industries regulated
by other parts of title 29 (i.e., 29 CFR Part 1926, Safety and Health Regulations for the
Construction Industry) and parts of title 40 (EPA) and title 49 (DOT) of the CFR to ensure no
duplication of effort. The employer may use efforts to comply with other Federal regulations to
comply with this regulation. OSHA also reviewed the various state plan program regulations for
hazardous waste operations and emergency response to ensure no duplication of effort by
employers is necessary or required. EPA regulations addressing similar operations for worker
populations not covered by OSHA (i.e., 40 CFR 311) are identical to OSHA's requirement but
not duplicative due to the worker populations regulated by EPA. The EPA regulates state and
local government employees engaged in hazardous waste operations and emergency response in
those states that have Federal OSHA jurisdiction (i.e., non-state-plan states). OSHA will
recognize any applicable information the employer develops or collects under other Federal
regulations as being acceptable in meeting the requirements of this Standard.
5. If the collection of information impacts small businesses or other small entities, describe any methods used
to minimize burden.

The information collection requirements specified by the Standard do not have a significant
impact on a substantial number of small entities. The final standard uses performance language
whenever possible to provide compliance flexibility to employers and reduce the impact on small
businesses. Performance language may require the use of a level of safety and health technical
competence not always available to small business employers. To reduce this burden upon small
businesses or other small entities, OSHA developed and uses non-mandatory appendices to this
Standard to provide useful compliance information and guidance to small businesses and other
small entities. Further, many states, through Federal grants, provide consultation programs to
assist small businesses in their compliance efforts.
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 regulate hazardous waste operations, 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 in the Act at
29 U.S.C. 651. The frequencies of the collections in the OSHA rule are sometimes less than
those mandated originally by SARA. There is a provision in SARA that permitted OSHA to
reduce the frequency of collection based upon public comment presented during rulemaking.
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The record supported certain reductions. Any frequency less than what OSHA requires in the
rule would render the Standard ineffective and would be in violation of SARA.
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
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.

No special circumstances exist that require employers to collect information using the
procedures specified by this item. The requirements are within the guidelines set forth in 5 CFR
1320.5.
8. If applicable, provide a copy and identify the data and page number of publication in the Federal Register
of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection
prior to submission to OMB. Summarize public comments received in response to that notice and
describe actions taken by the agency in response to these comments. Specifically address comments
received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of
data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting
format (if any), and on the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must
compile records should occur at least once every 3 years -- even if the collection of information activity is
the same as in prior periods. There may be circumstances that may preclude consultation in a specific
situation. These circumstances should be explained.

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As required by the Paperwork Reduction Act of 1995 (44 U.S.C. 3506(c)(2)(A)), OSHA
published a notice in the Federal Register on December 18, 2008 (73 FR 77072, Docket No.
OSHA-2008-0049) requesting public comment on its proposal to extend the Office of
Management and Budget’s approval of the information collection requirements specified by the
Standard on Hazardous Waste Operations and Emergency Response (HAZWOPER) (29 CFR
1910.120). This notice was part of a preclearance consultation program that provided the
general public and government agencies with an opportunity to comment. The Agency received
no comments in response to its notice.
9. Explain any decision to provide any payments or gift to respondents, other than reenumeration of
contractors or grantees.

The Agency will not provide 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.

The paperwork requirements specified by the Standard do not involve confidential information.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and
attitudes, religious beliefs, and other matters that are commonly considered private. This justification should
include the reasons why the agency considers the questions necessary, the specific uses to be made of the
information, the explanation to be given to persons from whom the information is requested, and any steps to
be taken to obtain their consent.

None of the 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
(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.

•

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 14.

Burden Hour and Cost Determinations
Estimates of the burden hours and annual costs for each information collection requirement are
shown below. Data are based upon information from the Environmental Protection Agency
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(EPA), the Bureau of Labor Statistics (BLS), the National Fire Protection Association (NFPA),
and from the Regulatory Flexibility Analysis (December 14, 1988) prepared for the rule. For
example, the number of sites is based upon data provided by the EPA at various Web sites cited.
OSHA relied on EPA’s 2004 publication, “Cleaning Up the Nation’s Waste Sites.” The
estimated number of hours for each required task is based upon OSHA's estimate of the time it
would take an average safety or health professional to perform the required task. The final
estimated burden hours are based upon simple multiplication of the estimated number of hours
needed for each task times the estimated number of sites or individuals regulated by the specific
requirement.
The Agency determined the average wage rates for “Occupational Health and Safety Specialists
and Technicians” using average hourly earning, including benefits, to represent the cost of
employee time. An average hourly wage rate of $33.78 was derived from the National
Compensation Survey (NCS), published by the Bureau of Labor Statistics. 2 This wage has been
adjusted to reflect the fact that fringe benefits comprise roughly 29.3 percent of total employee
compensation in the private sector. 3 The costs of labor used in this analysis are, therefore,
estimates of total hourly compensation.
The HAZWOPER rule applies to employers engaged in three types of operations:
Type 1: clean-up sites covered by paragraphs (b) through (o);
Type 2: storage, treatment and disposal (STD) sites (Resource Conservation and Recovery Act)
(RCRA) sites covered by paragraph (p); and
Type 3: emergency responders (police and fire departments) covered by paragraph (q).
TYPE 1: In preparing the burden hour estimates for the collection of information requirements in
the HAZWOPER rule, OSHA still assumes that employers now engaged in operations at 90
percent of the cleanup sites are performing this type of work during the period covered when the
last burden hour estimates were made in 2006. Therefore, they have already completed a
number of collection of information activities that were “one time” activities such as developing
a written safety and health program, however, they may have to modify or update their program.
OSHA assumes that employers at 10 percent of the clean-up sites will have to modify or update
their programs and employers at another 10 percent will prepare a program for the first time.
TYPE 2: OSHA estimates that employers on 65 percent of the sites classified as STD sites
(RCRA) have already performed the information collection activities required in paragraph (p).
2

Source: Bureau of Labor Statistics. National Compensation Survey: Occupational Wages in the United
States, June 2006. Table 2. Full-time civilian workers: Mean and median hourly, weekly, and annual earnings and
mean weekly and annual hours, United States. Published June 2007.
3

Source: Bureau of Labor Statistics. Employer Costs for Employee Compensation – December 2007.
March 12, 2008.

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This rate is less than the rate (90 percent) estimated for clean-up sites because OSHA believes
that there may be some non-permitted STD sites; i.e., sites for which EPA has yet to issue a
permit for work to begin. Employers at those sites most likely have not completed any of the
information collection activities required by paragraph (p) of the HAZWOPER rule.
TYPE 3: OSHA estimates that 90 percent of the employers covered by the requirements
applicable to emergency response operations in paragraph (q) have completed their obligations
with respect to information collection activities. The majority of requirements under paragraph
(q) address training and education standards that the emergency response community (police and
fire) implements as a usual and customary activity and, therefore, would have performed these
activities prior to promulgation of 29 CFR 1910.120.
Estimating the Number of Sites
The numbers of actual sites covered by this rule have been taken from EPA’s figures in Exhibit
1-1 in “Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends,” 2004 Edition,
supplemented where possible as indicated below. Based upon current figures, there are 150,143
sites remaining to be remediated. EPA has estimated that the current inventory of uncontrolled
waste sites could be remediated within 70 years and that the current inventory of RCRA
remediation sites could be remediated within 30 years. Without a detailed analysis of how many
sites will be active during each of the next 70 years, OSHA has decided to take the total number
of sites to be remediated in each category and to divide that figure by either 70 or 30 to
determine the average number of active sites/year/category over the estimated remediation time.
OSHA will use that average figure in ascertaining its estimated annual information collection
burden for each category of sites.
TYPE 1: Based on EPA, there are 456 current National Priorities List (NPL) sites undergoing
remediation. OSHA recognizes that there are far more Superfund clean-up sites that have been
identified and that will eventually be placed on the NPL; however, OSHA is only using the NPL
figure for this estimate since this figure represents more accurately the actual number of sites
that are or will become active during the approval period for this notice. In addition, it is
estimated that there are 6,400 Department of Defense sites, 5,000 Department of Energy sites,
more than 3,000 other civilian Federal agency sites, and 23,000 state-identified sites that OSHA
would consider covered by paragraphs (b) through (o) of the rule. As stated above, EPA
estimates that it will take approximately 70 years to remediate these sites. Therefore, the total
number of uncontrolled hazardous waste sites upon which OSHA could potentially impose a
collection burden is now 37,856. Since EPA estimates that it will take 70 years to remediate this
total inventory of sites, OSHA is dividing 37,856 by the 70-year figure to estimate an average
annual number of potential worksites at 541 per year over the next 70 years.

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TYPE 2: Similarly, EPA estimates that there are 3,521 potential RCRA corrective action sites 4
and 108,766 RCRA Underground Storage Tank remediation sites 5 that OSHA would consider
covered by paragraph (p) of this rule. The total potential RCRA remediation sites covered by
OSHA would be 112,287. EPA estimates that it will take about 30 years to remediate these sites.
Using the same method described above, OSHA has determined that there will be approximately
3,743 RCRA sites under remediation each year (112,287/30).
TYPE 3: With respect to the requirements for emergency response, OSHA believes that the
number of emergency response units has remained constant over the past several years. 6 Based
upon this assumption, OSHA believes that the total number of emergency response units and
employees remains unchanged from the last submission. OSHA will be using the figures of
30,528 emergency response units and 1,691,200 emergency response employees for this
submission. It should be noted that at least half of these workers are employed by state and local
governments of states that do not have a state plan in effect, or they are paid volunteers. These
workers are not covered by the OSHA rules, and the burden associated with their numbers is
being eliminated in this paperwork submission.
(A) TYPE 1 -- Clean Up Sites
1. Written Safety and Health Program
Paragraph 1910.120(b)(1)(i) requires employers to develop and implement a written safety and
health program for their employees involved in hazardous waste operations. The program shall
be designed to identify, evaluate, and control safety and health hazards, and provide for
emergency response to hazardous waste operations. The following elements of the program are
specified in 1910.120(b)(1)(ii): (A) an organizational structure (1910.120(b)(2)(i) and (ii)); (B) a
comprehensive work plan (1910.120(b)(3)(iv), (v), and (vi)); (C) a site-specific safety and health
plan that need not repeat the employer's standard operating procedures required in paragraph
(b)(1)(ii)(F) of this section (1910.120(b)(4)(i) and (ii), (c)(1), (d)(2) and (d)(3), (g)(5), and
(p)(1)); (D) the safety and health training program (1910.120(e)(1)); (E) the medical surveillance
program (1910.120(f)(1), (f)(3), and (f)(4)); (F) the employer's standard operating procedures for

4

Source: U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response. 2020
Corrective Action Universe. September 30, 2007. EPA estimates that Federal facilities comprise approximately 6
percent of a total 3,746 facilities that are expected to require corrective action.
5

Source: U.S. Environmental Protection Agency, Office of Underground Storage Tanks. FY 2007 Annual
Report on the Underground Storage Tank Program, page 4. April 2008.
6

According to the National Fire Protection Association, the total number of firefighters and fire departments
has remained fairly stable over the past twenty years. While the Agency has been unable to identify specific data
regarding the number of emergency response units covered by the Standard, it seems reasonable to assume that this
number has remained relatively stable as well.
http://www.nfpa.org/itemDetail.asp?categoryID=955&itemID=23688&URL=Research%20&%20Reports/Fire%20
statistics/The%20U.S.%20fire%20service

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safety and health; and (G) any necessary interface between general program and site specific
activities.
(A) Estimated time to develop an organizational structure:
(B) Estimated time to develop a comprehensive work plan:
(C) Estimated time to develop a site-specific safety and health plan:
(D) Estimated time to develop a safety and health training program:
(E) Estimated time to develop a medical surveillance program:
(F) Estimated time to develop SOP for safety and health:
(G) Estimated time for any necessary interface between general
program and site specific activities:

.5 hour per site
.5 hour per site
2 hours per site
8 hours per site
4 hours per site
4 hours per site
4 hours per site
23 hours (Total)

Burden hours: 541 sites × 10% of employers preparing program for first time ×
23 hours = 1,244 hours
Cost: 1,244 hours x $33.78 = $42,022
(B) Estimated time to develop a comprehensive work plan:
.5 hour per site
(C) Estimated time to develop a site-specific safety and health plan:
1 hour per site
(G) Estimated time for any necessary interface between
4 hours per site
General program and site specific activities:
5.5 hours per site (TOTAL)
Burden hours: 541 sites × 10% modifying/updating × 5.5 hours = 298 hours
Cost: 298 hours x $33.78 = $10,066
Therefore, the total burden hours for written safety and health programs are 1,542 and the
cost is $52,088.
2. Informing contractors, subcontractors of emergency response procedures
Paragraph 1910.120(b)(1)(iv) requires employers who retain contractor or subcontractor services
for work in hazardous waste operations to inform those contractors, subcontractors, or their
representatives of the site emergency response procedures and any potential fire, explosion,
health, safety or other hazards of the hazardous waste operation identified by the employer,
including those identified in the employer's information program.
Paragraph 1910.120(b)(1)(v) requires the employer to make available the written safety and
health program (required by #1 above) to any contractor or subcontractor or their representative
who will be involved with the hazardous waste operation; to employees; to employee designated
representatives; to OSHA personnel; and to personnel of other Federal, state, or local agencies
with regulatory authority over the site.

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Burden hours: 541 sites × 1 hour to inform of the site emergency response
procedures and to make the written safety and health program
available = 541 hours
Cost: 541 hours x $33.78 = $18,275
3. Pre-entry briefings on safety and health programs
Paragraph 1910.120(b)(4)(iii) requires that employers conduct pre-entry briefings prior to site
entry, and at such other times as necessary to ensure that employees are aware of the site safety
and health plan and that this plan is being followed.
OSHA believes that it is a usual and customary practice at all sites to have briefings; however,
because the briefing required in this rule is based on a safety and health program that may
contain information that is not usual and customary, OSHA estimates the burden for this
provision at one hour.
Burden hours: 541 sites × 1 hour to conduct pre-entry briefings = 541 hours
Burden hours: 541 sites × 8 hours to evaluate hazardous waste sites = 4,328 hours
The total burden hours for pre-entry briefings on safety and health programs are 4,869
Cost: 4,869 hours x $33.78 = $164,475
.
4. Preparation of training/providing training
Paragraphs 1910.120(e)(1) and (e)(3) require that all employees working on a site which
contains hazardous substances, health hazards, or safety hazards, as well as supervisors and
management responsible for the site, receive training before they are permitted to engage in
hazardous waste operations that could expose them to hazardous substances, safety, or health
hazards.
Paragraph (e)(3)(i) requires that general site workers (such as equipment operators, general
laborers and supervisory personnel) engaged in hazardous substance removal or other activities
which expose or potentially expose workers to hazardous substances and health hazards shall
receive a minimum of 40 hours of instruction off the site, and a minimum of three days actual
field experience under the direct supervision of a trained experienced supervisor.
Paragraph (e)(3)(ii) requires that workers on site only occasionally for a specific limited task
(such as, but not limited to, ground water monitoring, land surveying, or geophysical surveying)
and who are unlikely to be exposed over permissible exposure limits and published exposure
limits shall receive a minimum of 24 hours of instruction off the site, and a minimum of one day
actual field experience under the direct supervision of a trained, experienced supervisor.

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Paragraph (e)(3)(iii) requires that workers who regularly work in areas which have been
monitored and fully characterized (indicating that exposures are under permissible exposure
limits and published exposure limits, and where respirators are not necessary), and the
characterization indicates that there are no health hazards or the possibility of an emergency
developing, shall receive a minimum of 24 hours of instruction off the site, and a minimum of
one day actual field experience under the direct supervision of a trained, experienced supervisor.
Paragraph (e)(3)(iv) requires that workers with 24 hours of training who are covered by
paragraphs (e)(3)(ii) and (e)(3)(iii) of this section, and who become general site workers or who
are required to wear respirators, have an additional 16 hours or two days of off-site training to
total the 40 hours of training specified in (e)(3)(i).
OSHA estimates that there are a total of 10,820 clean-up employees (an average of 20 per site)
of which 10 percent or an estimated 1,082 would be new employees requiring the
aforementioned initial training. The Agency assumes that 70 percent of the 1,082 (757) would
be routine site employee laborers who would require 64 hours of training, and 25 percent (271)
would be routine site employees with minimal exposure, requiring 32 hours of initial training.
Burden hours: 757 × 64 hours = 48,448 hours
Burden hours: 271 × 32 hours = 8,672 hours
Therefore, the total burden hours for preparation of training/providing training are 57,120.
Cost: 57,120 hours x $33.78 = $1,929,514
5. Supervisor training
Paragraph (e)(4) requires that on-site management and supervisors directly responsible for, or
who supervise employees engaged in hazardous waste operations receive 40 hours initial training
and three days of supervised field experience (the training may be reduced to 24 hours and one
day if the only area of their responsibility is employees covered by paragraphs (e)(3)(ii) and
(e)(3)(iii)) and at least eight additional hours of specialized training at the time of job assignment
on such topics as, but no limited to, the employer's safety and health program, personal
protective equipment program, spill containment program, and health hazard monitoring
procedure and techniques.
OSHA assumes that the remaining 5% of the new 1,082 (54) employees would be supervisors:
Burden hours: 54 × 64 hours = 3,456 hours
Cost: 3,456 hours x $33.78 = $116,744

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6. Certification of training
Paragraph 1910.120(e)(6) requires a written certification for employees and supervisors who
have received and successfully completed the training and field experience specified in
paragraphs (e)(1) through (e)(4). A written certificate shall be given to each person so certified.
Burden hours: 1,082 employees × 5 min. (.08 hour) = 87 hours
Cost: 87 hours x $33.78 = $2,939
7. Refresher training
Paragraph 1910.120(e)(8) requires that employees specified in paragraph (e)(1) of this section,
and managers and supervisors specified in paragraph (e)(4) of this section, shall receive eight
hours of refresher training annually on the items specified in paragraph (e)(2) and/or (e)(4) of
this section, any critique of incidents that have occurred in the past year that can serve as training
examples of related work, and other relevant topics.
Burden hours: (10,820 employees - 1,082 new employees) = 9,738 employees × 8
hours of refresher training = 77,904 hours
Cost: 77,904 hours x $33.78 = $2,631,597
8. Medical exam frequency
Paragraph 1910.120(f)(3) requires certain employees to receive medical exams based on the
criteria in the medical surveillance program of the safety and health program (see (b)(1) above).
Paragraph 1910.120(f)(4) details the content of the medical exam and paragraph 1910.120(f)(6)
requires that certain information be provided to the attending physician and to each employee.
As OSHA previously estimated, there are 10,820 clean-up employees. OSHA estimates that it
will take 1.5 hours for a medical exam, including travel time, and 15 minutes (.25 hr.) for the
employer to provide the necessary information to the physician for a total of 1.75 hours.
According to the RIA, it was estimated that 75 percent of employees and supervisors were
receiving annual medical examinations as a usual and customary business practice.
Burden hours: 10,820 employees × 25% need medical exams × 1.75 hours to
perform exam = 4,734 hours
Cost: 4,734 hours x $33.78 = $159,915
9. Written physician opinion to the employee
Paragraphs 1910.120(f)(7) and 1910.120(f)(8)(i) requires the employer to provide the employee
with a copy of the written physician opinion. The information which has been given to the
physician in (f)(6) must be maintained.

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The Agency estimates that it will take 10 minutes (.17 hour) to furnish the employee with the
written opinion, and to develop and maintain the employee medical record.
Burden hours: 10,820 employees × .17 hours = 1,839 hours
Cost: 1,839 hours x $33.78 = $62,121
10. Monitoring program requirements
Paragraph 1910.120(h) requires employers to develop a monitoring program. The program
specifies the: (1) Type of monitoring, (2) the frequency, and (3) the employees to be monitored.
The HAZWOPER Standard prescribes the criteria for the three elements. This information is
used in the elements of the safety and health program required in 1910.120(b)(1) described
above. This information is also used in the briefings required in 1910.120 (b)(4)(iii) and to fulfill
the requirements of 1910.120(c)(7). Based on the RIA, it takes four hours to conduct the
monitoring at each site. Note that most monitoring is done by automatic machines (monitors)
which record the results or by a personal badge worn by employees.
Burden hours: 541 sites × 4 hours for employers to develop a monitoring program
= 2,164 hours
Cost: 2,164 hours x $33.78 = $73,100
11. Decontamination procedures
Paragraph 1910.120(k)(2)(i) requires employers to develop a decontamination procedure and to
communicate it to employees and implement it before any employees or equipment may enter
areas on site where a potential for exposure to hazardous substances exists.
Burden hours: 541 sites × 6 hours to develop a decontamination procedure and to
communicate it to employees = 3,246 hours
Cost: 3,246 hours x $33.78 = $109,650
12. Emergency action plan
Paragraph 1910.120(l)(1)(i) requires that employers develop and implement an emergency action
plan to handle anticipated emergencies prior to the commencement of hazardous waste
operations. The plan shall be in writing and available for inspection and copying by employees,
their representatives, OSHA personnel and other government agencies with relevant
responsibilities.
As discussed under TYPE 1, OSHA assumes that all employers are already in compliance with
this provision. However, OSHA is using a 10 percent turnover rate to account for new
employers (sites). For the existing 541 sites, OSHA estimates that it takes one minute (.02 hr.)
to maintain the plan.

13

Burden hours: 541 sites × 10% × 8 hours to prepare and maintain emergency
action plan = 433 hours
Burden hours: 541 existing plans × .02 hours to maintain plan = 11 hours
The total burden hours for the emergency action plan are 444.
Cost: 444 hours x $33.78 = $14,998
.13. Marking water containers as containing drinking water
Paragraph 1910.120(n)(1)(iii) requires that any container used to distribute drinking water shall
be clearly marked as to the nature of its contents and not used for any other purpose.
OSHA assumes that employers have completed developing appropriate language to fulfill the
requirement. OSHA assumes this task will take 10 minutes (.17 hours).
Burden hours: 541 sites × 10% new × 10 containers per site × .17 hours to mark =
92 hours
Cost: 92 hours x $33.78 = $3,108
14. Marking of outlets for non-potable water
Paragraph 1910.120(n)(2)(i) requires that outlets for non-potable water, such as water for
firefighting purposes, be identified to indicate clearly that the water is unsafe and is not to be
used for drinking, washing, or cooking purposes.
Burden hours: 541 sites × 10% new × 10 outlets per site × .17 hours to mark = 92
hours
Cost: 92 hours $ 33.78 = $3,108
15. New technology requirements
Paragraph 1910.120(o) requires employers to develop and implement procedures for the
introduction of new technologies and equipment developed for improved employee protection.
As discussed above under TYPE 1, OSHA assumes that all employers are already in compliance
with this provision. However, OSHA is using a 10 percent turnover rate to account for new
employers (sites) and estimates that it takes 6 hours to develop and implement procedures for the
introduction of new technologies and equipment for improved employee protection.
Burden hours: 541 sites × 10% new × 6 hours to develop and implement
procedures = 325 hours
Cost: 325 hours x $33.78 = $10,979

14

(B) TYPE 2-- RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) (EPAPERMITTED STD) SITES
16. Safety and Health Program
Paragraph 1910.120(p)(1) requires RCRA (STD) site employers to develop and implement a
safety and health program. As part of this safety and health program, employers are required to
develop a training program as specified in paragraph 1910.120(p)(7)(i), and an emergency
response plan as specified in paragraph 1910.120(p)(8).
As stated under the TYPE 2 discussion above, OSHA estimates that 65 percent of the sites have
already completed this requirement.
Burden hours: 3,743 sites × 35% new sites × 6 hours per site = 7,860 hours
Cost: 7,860 hours x $33.78 = $265,511
In addition, the Agency estimates that 10 percent of the sites may need to update/modify their
plans, and that it will take 2 hours to update or modify these plans.
Burden hours: 3,743 sites × 10% × 2 hours = 749 hours
Therefore, the total burden hours for the Safety and Health Program are 8,609.
Cost: 8,609 hours x $33.78 = $290,812
17. Hazard communication program
Paragraph 1910.120(p)(2) requires RCRA (STD) sites employers to develop a hazard
communication program.
Burden hours: 3,743 sites × 35% new sites × 6 hours per site = 7,860 hours
Cost: 7,860 hours x $33.78 = $265,511
18. Medical surveillance program
Paragraph 1910.120(p)(3) requires RCRA (STD) site employers to provide employee medical
exams as specified in paragraph 1910.120(f).
Based on the previous paperwork packages, and using the same methodology for employees in
Type 1, OSHA estimates that there are an estimated 56,145 STD site employees (15 per site).
OSHA also estimates that it will take 1.5 hours for a medical exam, including travel time, and 15
minutes (.25 hr.) for the employer to provide the necessary information to the physician. The
Agency also estimates that it will take 10 minutes (.17 hour) to furnish the employee with the
written opinion, and to develop and maintain the employee medical record. Based on the RIA, it

15

is estimated that, on average, 70 percent of the RCRA employees and supervisors receive annual
medical reexaminations as a usual and customary business practice.
Burden hours: 56,145 × 30% × 1.92 hrs. = 32,340 hours
Cost: 32,340 hours x $33.78 = $1,092,445
19. Decontamination program
Paragraph 1910.120(p)(4) requires RCRA (STD) site employers to develop a decontamination
program.
Burden hours: 3,743 sites × 35% new sites × 6 hours per site = 7,860 hours
Cost: 7,860 hours x $33.78 = $265,511
20. New technology program
Paragraph 1910.120(p)(5) requires the employer to develop and implement procedures meeting
the requirements of paragraph (o) of this section (i.e., introducing new and innovative equipment
into the workplace).
Burden hours: 3,743 sites × 35% new sites × 6 hours per site = 7,860 hours
Cost: 7,860 hours x $33.78 = $265,511
21. Material handling program
Paragraph 1910.120(p)(6) requires employers whose employees will be handling drums or
containers to develop and implement procedures meeting the requirements of paragraphs
1910.120(j)(1)(ii) through (viii), (j)(1)(xi), (j)(3) and (j)(8) of this section prior to the employees
starting such work.
Burden hours: 3,743 sites × 35% new sites × 6 hours per site = 7,860 hours
Cost: 7,860 hours x $33.78 = $265,511

16

22. Implementation of training program
Paragraph 1910.120(p)(7)(i) requires the employer to develop and implement a training program,
which is part of the employer's safety and health program, for new employees exposed to health
hazards or hazardous substances at STD operations to enable the employees to perform their
assigned duties and functions in a safe and healthful manner so as not to endanger themselves or
other employees. The initial training shall be for 24 hours and refresher training shall be for
eight hours annually. It is estimated that 56,145 STD employees will need training. 7
Employees who have received the initial training required by this paragraph shall be given a
written certificate attesting that they have successfully completed the necessary training. This
certificate will also fulfill employer obligations under paragraph 1910.120(p)(8)(iii)(C) which
requires the employer to certify that each covered employee has attended and successfully
completed the training required in paragraph (p)(8)(iii) of this section, or shall certify the
employee's competency at least yearly. The method used to demonstrate competency for
certification of training shall be recorded and maintained by the employer.
Based on the RIA, the Agency estimates, on average, initial training of new employees will
involve training 2 new employees per session
Burden hours: (56,145 STD employees × 10% new employees)/2 × 24 hours of
training = 67,374 hours
The Agency estimates, on average, refresher training of current employees will involve training
10 employees per session.
Burden hours: 56,145 current STD employees/10 × 8 hours of refresher training =
44,916 hours
Burden hours: 56,145 STD employees × 10% new employees × .05 hours to
generate and maintain certification record = 281 hours
Burden hours: 56,145 current STD employees × .02 hours to maintain
certification records = 1,123 hours

7

Employees referenced in paragraphs 1910.120(p)(8)(iii)(A), (training for emergency response employees)
and paragraph 1910.120(p)(8)(iii)(B) (training employee members of STD facility emergency response
organizations) are included in the 56,145 STD employees.

17

Therefore, the total burden hours for the implementation of a training program are 113,694.
Cost: 113,694 hours x $33.78 = $3,840,583
(C) TYPE 3 -- EMERGENCY RESPONSE WORKERS
23. Emergency response plan
Paragraph 1910.120(q)(1) requires that an emergency response plan be developed and
implemented to handle anticipated emergencies prior to the commencement of emergency
response operations. The plan shall be in writing and available for inspection and copying by
employees, their representatives, and OSHA personnel. Employers who will evacuate their
employees from the danger area when an emergency occurs, and who do not permit any of their
employees to assist in handling the emergency, are exempt from the requirements of this
paragraph if they provide an emergency action plan complying with 29 CFR 1910.38(a).
Burden hours: 30,528 emergency response organizations × 50% not covered by
OSHA (state and local employees) × 10% required to develop new
emergency response plan × 8 hours to prepare plan = 12,211 hours
Cost: 12,211 hours x $33.78 = $412,488
24. First responder training “at the awareness level”
Paragraph 1910.120(q)(6)(i) describes “first responders at the awareness level” as individuals
who are likely to witness or discover a hazardous substance release and who have been trained to
initiate an emergency response sequence by notifying the proper authorities of the release. They
would take no further action beyond notifying the authorities of the release. First responders at
the awareness level shall have sufficient training or have had sufficient experience to objectively
demonstrate competency.
The Agency estimates that there are a total of 1,691,200 emergency response employees.
However, OSHA assumes that half of these employees are state and local government employees
not covered by the Standard. Therefore, of the 1,691,200 emergency response employees, only
845,600 employees would be impacted by the Standard.
While the Agency has an estimated number of emergency response employees who would be
affected by the provisions under 1910.120(q), the Agency has no clear means to categorize these
employees into the various training categories specified under 1910.120(q)(6)(i)-(v).
To determine the number of employees in the various training categories, OSHA reviewed the
RIA to develop a percentage of total emergency response employees for each of the training
categories. OSHA estimates that 56% of the total 845,600 employees covered by OSHA, or
473,536 employees, would be first responders at the awareness level.

18

For initial training, the Agency estimates a 10 percent turnover rate; therefore, 47,354 employees
would require initial training. The Agency estimates that it would take 3 hours of training.
Burden hours: 47,354 employees × 3 hours of training = 142,062 hours
Cost: 142,062 hours x $33.78 = $ 4,798,854
25. First responder training “at the operations level” and certification of training
Paragraph 1910.120(q)(6)(ii): “First responders at the operations level” are individuals who
respond to releases or potential releases of hazardous substances as part of the initial response to
the site for the purpose of protecting nearby persons, property, or the environment from the
effects of the release. They are trained to respond in a defensive fashion without actually trying
to stop the release. Their function is to contain the release from a safe distance, keep it from
spreading, and prevent exposures. First responders at the operational level shall have received at
least eight hours of training or have had sufficient experience to objectively demonstrate
competency in six areas, in addition to those listed for the awareness level; the employer shall so
certify their competency.
The Agency estimates that 41% of the 845,600 employees, or 346,696 employees, would require
first operations level training.
For initial training, the Agency estimates a 10% turnover rate; therefore, 34,670 employees
would require initial training. The Standard states that first responder operations’ training
requires at least 8 hours of training.
Burden hours: 34,670 employees × 8 hours of training = 277,360 hours
The Agency also estimates another 3 minutes (.05 hour) to generate and maintain the
certification record.
Burden hours: 34,670 employees × .05 hours = 1,734 hours
Therefore, the total burden hours for first responder training at the operations level are 279,094.
Cost: 279,094 x $33.78 = $9,427,795
26. Hazardous material technician training and certification of training
Paragraph 1910.120(q)(6)(iii): “ Hazardous materials technicians” are individuals who respond
to releases or potential releases for the purpose of stopping the release. They assume a more
aggressive role than a first responder at the operations level in that they will approach the point
of release in order to plug, patch or otherwise stop the release of a hazardous substance.
Hazardous materials technicians shall have received at least 24 hours of training equal to the first

19

responder operations level and, in addition, have competency in nine additional areas; the
employer shall so certify their competency.
Paragraph 1910.120(q)(6)(iv): “Hazardous materials specialists” are individuals who respond
with, and who provide, technical support to, hazardous materials technicians. Their duties
parallel those of the hazardous materials technician; however, those duties require a more
directed or specific knowledge of the various substances they may be called upon to contain. The
hazardous materials specialist would also act as the site liaison with Federal, state, local and
other government authorities in regards to site activities. Hazardous materials specialists shall
have received at least 24 hours of training at the technician level, and have competency in nine
additional areas; the employer shall so certify their competency.
Paragraph 1910.120(q)(6)(v): “Incident commanders,” who will assume control of the incident
scene beyond the first responder awareness level, shall receive at least 24 hours of training equal
to the first responder operations level and have competency in six additional; the employer shall
so certify their competency.
As these three categories all require at least 24 hours of training, they have been combined; they
account for approximately 3 percent of the total 845,600 emergency response employees, or
25,368 employees.
For initial training, the Agency estimates a 10 percent turnover rate; therefore, 2,537 employees
would require initial training. The Standard states these training categories would require at least
24 hours of training.
Burden hours: 2,537 employees × 24 hours = 60,888 hours
Written Training Certification:
Burden hours: 2,537 emergency response employees × .05 hours to generate and
maintain record = 127 hours
Therefore, the total burden hours for hazardous material technician training and certification of
training are 61,015.
Cost: 61,015 hours x $33.78 = $2,061,087
27. Refresher training
Paragraph 1910.120(q)(8)(i) requires that those employees who are trained in accordance with
paragraph (q)(6) of this section receive annual refresher training of sufficient content and
duration to maintain their competencies, or that they demonstrate competency in those areas at
least yearly.

20

The Agency estimates that the refresher training time, on average, is 2.5 hours per sessions of 10
employees.
Burden hours: 845,600 emergency response employees/10 sessions × 2.5 hours =
211,400 hours
Cost: 211,400 hours x $33.78 = $7,141,092
28. Statement of competency
Paragraph 1910.120(q)(8)(ii) requires that a statement be made of the training or competency,
and that the employer shall keep a record of the methodology used to demonstrate competency.
Burden hours: 845,600 emergency response employees × .17 hours per responder
= 143,752 hours
Cost: 143,752 hours x $33.78 = $4,855,942
29. Baseline physical exams for members of organized and designated HAZMAT team and
hazardous materials specialists
Paragraph 1910.120(q)(9) requires that members of an organized and designated HAZMAT team
and hazardous materials specialists receive a baseline physical examination.
Based on the RIA, OSHA estimates that 3,000 HAZMAT employees will take 1.5 hours for a
medical exam, including travel time, and 15 minutes (.25 hr.) for the employer to provide the
necessary information to the physician. The Agency also estimates that it will take 10 minutes
(.17 hour) to furnish the employee with the written opinion, and to develop and maintain the
employee medical record.
Burden hours: 3,000 employees × 1.92 hours = 5,760 hours
Cost: 5,760 hours x $33.78 = $194,573
30. Disclosure of written safety and health programs, emergency action plans, emergency
response plans and training certification records
OSHA estimates that approximately 487 sites/employers/units covered by the Standard may be
subject to an OSHA inspection, and the employer may be required to disclose written safety and
health programs, emergency action plans, emergency response plans and training certification

21

records annually. 8 OSHA estimates that it will take a manager 15 minutes (.25 hour) to disclose
all documents.
Burden hours: 487 sites/employers/units × .25 hour = 122 hours
Cost: 122 hours x $33.78 = $4,121
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.

Costs under item 13 for complying with the Hazardous Waste Operations and Emergency
Response standard are included under those costs in Item 12, except for the costs of medical
exams. Medical exams cost $138 each. 9 OSHA estimates that 22,549 employees will receive
annual medical exams.
TYPE 1: 10,820 employees × .25 = 2,705
TYPE 2: 56,145 employees × .30 = 16,844
8

The Agency estimated the number of inspections by determining the inspection rate (1.4%) for all clean-up
sites (541), RCRA (STD) sites (3,743), and emergency response units (30,528) or a total of 34,812 and then
multiplying the total number of sites/employers/units by this percentage (i.e., 34,812 sites/employers/units × 1.4% =
487 sites/employers/units inspected).
9

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 a medical exam was $130; given the 6.3% increase
in the price of professional medical services, it was assumed that the cost of medical examinations increased by
6.3% as well.

22

TYPE 3: HAZMAT employees = 3,000
Cost: 22,549 employees × $138/exam = $3,111,762
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.

OSHA estimates that a compliance officer (GS-12, step 5), with an hourly wage rate of $39.70
spends about 15 minutes (.25 hour) during an inspection reviewing the documents required by
the Standard. The Agency has determines that its compliance officers will inspect about 487
sites/employers/units regulated by the Standard during each year covered by this ICR. OSHA
considers other expenses, such as equipment, overhead, and support staff salaries, to be normal
operating expenses that would occur without the paperwork requirements specified by the
Standards. Therefore, the total cost of the paperwork requirements to the Federal government is:
Cost: 487 inspections × .25 hour × $39.70 = $4,833
15. Explain the reasons for any program changes or adjustments.

The Agency is requesting an adjustment decrease of 35,648 burden hours from the previous
submission (from 1,235,602 hours to 1,199,954 hours). This decrease is primarily a result of a
decline in the number of sites to be remediated. See Table 1 below for the rationale of burden
hour changes. There is also a decrease in the cost under Item 13 from $3,351,000 to $3,111,762
(-$239,238). This decrease occurred due to a reduction in the number of employees requiring
medical exams although the cost of an exam increased from $130 to $138.
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.

OSHA will not publish the information collected under the Standard.
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.

No forms are available for the Agency to display the expiration date.
18. Explain each exception to the certification statement in ROCIS.

OSHA is not requesting an exception to the certification statement in ROCIS.

23

TABLE 1
Hazardous Waste Operations and Emergency Response
Rationale for Burden Hour Changes 10

Collection of Information

Current
Burden
Hours

Proposed
Burden
Hours

Adjustment

Responses

Explanation of Adjustment

CLEAN-UP SITES
1

Written safety and health program -1910.120(b)(1)(i)

2

Informing contractors,
subcontractors emergency response
procedures -1910.120(b)(1)(iv)

3

Pre-entry briefings on S&H
programs –
1910.120(b)(4)(iii)

4

Preparation training/providing
training -- 1910.120(e)(1)(i)

5

Supervisor training -- 1910.120(e)(4)

6

Certification of training –
1910.120(e)(6)

1,542

1,542

0

108

No change.

541

541

0

541

No change.

4,869

4,869

0

1,082

No change.

57,120

57,120

0

1,028

No change.

3,456

3,456

0

54

No change.

87

87

0

1,082

No change.

10

The HAZWOPER rule applies to employers engaged in three types of operations: Type 1: clean-up sites covered by paragraphs (b) through (o); Type 2:
storage, treatment and disposal (STD) sites (Resource Conservation and Recovery Act) (RCRA) sites covered by paragraph (p); and Type 3: emergency
responders (police and fire departments) covered by paragraph (q).

24

Collection of Information

7

Refresher training -- 1910.120(e)(8)

8

Current
Burden
Hours

Proposed
Burden
Hours

Adjustment

Responses

Explanation of Adjustment

77,904

77,904

0

9,738

No change.

Medical exam frequency -1910.120(f)(3)

4,734

4,734

0

2,705

No change.

9

Written physician opinion to the
employee -- 1910.120(f)(7)(i)

1,839

1,839

0

10,820

No change.

10

Monitoring program requirements -1910.120(h)

2,164

2,164

0

541

No change.

11

Decontamination procedures
-- 1910.120(k)(2)(i)

3,246

3,246

0

541

No change.

12

Emergency action plan -1910.120(l)(1)(i)

444

444

0

595

No change.

13

Marking water containers as
containing drinking water -1910.120(n)(1)(iii)

92

92

0

541

No change.

14

Marking of outlets for nonpotable
water -- 1910.120(n)(2)(i)

92

92

0

541

No change.

15

New technology requirements -1910.120(o)

325

325

0

54

No change.

158,455

158,455

0

29,971

TOTALS FOR
CLEAN-UP SITES

25

Collection of Information

Current
Burden
Hours

Proposed
Burden
Hours

Adjustment

Responses

Explanation of Adjustment

RCRA (STD) SITES
16

Safety and Health Program -1910.120(p)(1)

10,258

8,609

-1,649

1,684

The decrease is due to a decline in the number of
potential RCRA corrective action sites from 4,460
to 3,743.

9,366

7,860

- 1,506

1,310

The decrease is due to a decline in the number of
potential RCRA corrective action sites from 4,460
to 3,743.

38,534

32,340

- 6,194

16,844

The decrease is due to a decline in the number of
STD employees from 66,900 to 56,145. The
decline is a result of fewer STD sites.

17

Hazard communication program -1910.120(p)(2)

18

Medical surveillance program -1910.120(p)(3)

19

Decontamination program -1910.120(p)(4)

9,366

7,860

- 1,506

1,310

The decrease is due to a decline in the number of
potential RCRA corrective action sites from 4,460
to 3,743.

20

New technology program -1910.120(p)(5)

9,366

7,860

-1,506

1,310

The decrease is due to a decline in the number of
potential RCRA corrective action sites from 4,460
to 3,743.

21

Material handling program
1910.120(p)(6)

9,366

7,860

-1,506

1,310

The decrease is due to a decline in the number of
potential RCRA corrective action sites from 4,460
to 3,743.

22

Implementation of training program
-- 1910.120(p)(7)(i)

135,473

113,694

- 21,779

72,989

The decrease is due to a decline in the number of
STD employees from 66,900 to 56,145. The
decline is a result of fewer STD sites.

TOTALS FOR
RCRA (STD) SITES

221,729

186,083

-35,646

96,757

26

Collection of Information

Current
Burden
Hours

Proposed
Burden
Hours

Adjustment

Responses

Explanation of Adjustment

EMERGENCY RESPONSE OPERATIONS
23

Emergency response plan -1910.120(q)(1)

24
25

12,211

0

1,526

First responder training “at the
awareness level” – 1910.120(q)(6)(i)

142,062

142,062

0

47,354

No change.

First responder training “at the
operations level” -1910.120(q)(6)(ii)

277,360

277,360

0

34,670

No change.

1,734

1,734

34.670

No change.

61,015

61,015

0

5,074

No change.

Certification of training

26

No change.

12,211

Hazardous material technician
training -- 1910.120(q)(6)(iii)
Certification of training.

27

Refresher training -1910.120(q)(8)(i)

211,400

211,400

0

84,560

No change.

28

Statement of competency -1910.120(q)(8)(ii)

143,752

143,752

0

845,600

No change.

27

Collection of Information

29

30

Current
Burden
Hours

Proposed
Burden
Hours

Adjustment

Responses

Explanation of Adjustment

Baseline physical exams for
members of organized and
designated HAZMAT team and
hazardous materials specialists –
1910.120(q)(9)

5,760

5,760

0

3,000

TOTALS FOR EMERGENCY
RESPONSE OPERATIONS

855,294

855,294

0

1,021,818

124

122

-2

487

CLEAN-UP SITES

158,455

158,455

0

29,971

RCRA (STD) SITES

221,729

186,083

-35,646

96,757

EMERGENCY RESPONSE
OPERATIONS

855,294

855,294

0

1,021,818

124

122

-2

487

1,235,602

1,199,954

-35,648

1,149,033

Disclosure of written safety and
health programs, emergency action
plans, emergency response plans,
and training certification records

DISCLOSURE OF WRITTEN
PLANS AND CERTIFICATION
RECORDS

28

No change.

The decrease is due to a decline in the number of
potential RCRA corrective action sites from 4,460
to 3,743.