DBCP-Final (02-18-09)

SUPPORTING STATEMENT FOR THE
INFORMATION COLLECTION REQUIREMENTS IN
THE 1,2-DIBROMO-3-CHLOROPROPANE (DBCP) STANDARD
(29 CFR 1910.1044)
(OFFICE OF MANAGEMENT AND BUDGET (OMB)) CONTROL NO. 1218-0101
(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 Occupational Safety and Health Act (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). As one means in achieving this objective, the
OSH Act specifically authorizes ”the development and promulgation of occupational safety and
health standards” (29 U.S.C. 651) to ensure that employees will be furnished employment and a
place of employment free from recognized hazards that are causing or likely to cause death or
serious physical harm.”
For toxic substances, the OSH Act contains specific statutory language. Thus, as appropriate,
health standards must include provisions for monitoring and measuring employee exposure,
medical examinations and other tests, control and other technological procedures, suitable
protective equipment, labels and other appropriate forms of warning, and precautions for safe use
or exposure (29 U.S.C. 655). In addition, the OSH Act specifically mandates issuing regulations
requiring employers to maintain accurate records of employee exposures to potentially toxic
materials or other harmful physical agents that are required to be monitored and measured, and
further requires that employees exposed to concentrations over prescribed limits be notified of
this fact, and of the corrective action being taken (29 U.S.C. 657).
Using the statutory authority granted to it by the OSH Act, the Occupational Safety and Health
Administration (OSHA) published a health standard governing employee exposure to 1,2dibromo-3-chloropropane (DBCP) in 1978 (29 CFR 1910.1044 1 ). OSHA published the DBCP
Standard (also referred to as “the Standard” based on scientific studies demonstrating that DBCP
is a potent carcinogen in experimental animals and causes sterility and infertility in humans.
OSHA limited exposure to DBCP to the lowest feasible level, i.e., an 8-hour time weighted
average exposure limit of 1 part of DBCP per billion parts of air (1 ppb); this exposure level (1
ppb) is the permissible exposure limit (PEL). The 1979 TSCA (Toxic Substances Control Act)
Inventory identified 3 companies producing 1,000 lbs of DBCP in 1977, and 1 DBCP importer,
but provided no information on import volumes.
1

Please see the copy of the DBCP Standard attached to this supporting statement. Note that the DBCP
Standards for Shipyards (29 CFR 1915.1044) and Construction (29 CFR 1926.1144) incorporate by reference the
General Industry DBCP Standard (29 CFR 1910.1044).

The Environmental Protection Agency (EPA) registered DBCP as a soil fumigant for controlling
nematodes during growth of field crops, vegetables, fruits and nuts, greenhouse and nursery
crops, and turf. In 1977, the EPA suspended all registration of DBCP-based end-use products,
except fumigants for Hawaiian pineapples; EPA revoked this exception in 1985. According to
the Eleventh Report on Carcinogens, January 31, 2005, compiled by the National Toxicology
Program 2 no current production data are available for DBCP.
The purpose of DBCP Standard is to provide protection for employees from the adverse health
effects caused by occupational exposure to DBCP. To ensure that employees are receiving this
protection, the Standard requires employers to provide OSHA with access to various records.
Items 2 and 12 below list and fully discuss the specific information collection requirements
specified by 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.

Exposure Monitoring (§1910.1044(f))
Employers must perform initial monitoring to determine the extent of DBCP exposure in their
workplaces. 3 Initial monitoring enables employers to identify areas of operation that may
require additional efforts to reduce employee exposure to DBCP and, therefore, helps them come
into compliance with the Standard. Initial monitoring results also assist employers in
determining the need for engineering controls, instituting or modifying work practices, and
selecting appropriate respiratory protection to prevent employees from overexposure to DBCP.
If the initial monitoring finds that DBCP is at or below the PEL, the employer must repeat these
measurements at least every 6 months. If the initial monitoring indicates that DBCP exposure is
in excess of the PEL, the employer must repeat these measurements at least quarterly; areas in
which employee exposures exceed the PEL are regulated areas. Quarterly monitoring must
continue until 2 consecutive measurements, taken at least 7 days apart, are below the PEL, after
which the employer must monitor at least every 6 months. Periodic monitoring allows
employers to evaluate the effectiveness of exposure-control methods. In addition, these
measurements remind both the employer and employees of the continuing need to protect against
the hazards that could result from an employee’s overexposure to DBCP. Periodic monitoring
also informs the physician responsible for medical surveillance of the existence and extent of a
potential source of occupational disease.

2
3

Operated by the Department of Health and Human Services.
Initial and periodic monitoring must be representative of each employee=s exposure to DBCP.

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Employers must perform additional monitoring if any change occurs in production, processes,
controls, or personnel that may result in new or increased employee exposures to DBCP, or if the
employer reasonably suspects that any other condition could result in such exposure. Additional
monitoring ensures that the workplace is safe or alerts the employer to increase the employee
protection.
Paragraph 1910.1044(f)(5) requires that employers must inform each employee of their
exposure-monitoring results within 15 working days after receiving these results. Employers
may notify employees either individually in writing or by posting the monitoring results in an
appropriate location that is accessible to the employees. In addition, if the exposure-monitoring
results show that an employee’s exposure exceeds the PEL, the employer must inform the
exposed employee of the corrective action the employer is taking to prevent such overexposure.
Notification provides employees with information about the efforts the employer is taking to
lower their DBCP exposures and to furnish them with a safe and healthful workplace in
accordance with section 8(c)(3) of the Act.
Written Compliance Program (§1910.1044(g)(2))
Employers must establish and implement a written program to reduce employee DBCP exposure
to or below the PEL using engineering and work-practice controls. This program must also
include a detailed schedule for developing and implementing engineering and work-practice
controls. Employers must, at least, review and/or revise the compliance plan at least annually, to
describe the programs current status. On request, the written plan must be provided to OSHA,
the National Institute for Occupational Safety and Health (NIOSH), affected employees, and
designated employee representatives.
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.
Updating the program serves to remind employers to implement and maintain the exposurecontrol methods required by the Standard.
Respiratory Program (§1910.1044(h)(2))
If employers require respirator use, they must establish a respiratory-protection program in
accordance with 29 CFR 1910.134, paragraphs (b) through (d) (except (d)(1)(iii)), and (f)
through (m)). Paragraph (c) of 29 CFR 1910.134 requires the employer to develop and
implement a written respiratory-protection program with worksite-specific procedures and
elements for respirator use. The purpose of these requirements is to ensure that employers
establish a standardized procedure for selecting, using, and maintaining respirators for each
workplace requiring respirator use. Developing written procedures ensures that employers
implement a respirator program that meets the needs of their employees. OSHA incurs the

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burden hours and costs resulting from these program requirements under the ICR for OSHA’s
Respiratory Protection Standard (29 CFR 1910.134), OMB Control Number 1218-0099.
Written Emergency-Situation Plan (§ 1910.1044(i)(1))
The employers must develop and implement a written plan describing the emergency response to
accidental releases of DBCP. This plan provides employees with personal-protection and
evacuation information that minimizes their exposure to DBCP in these situations.
Removal and Storage of Protective Clothing and Equipments (§1910.1044(j)(2)(v))
If the employer is going to remove containers housing DBCP-contaminated protective devices
and work clothing from change rooms or the workplace for cleaning, maintenance, or disposal,
the containers must bear a label in accordance with paragraph (o) (3) of the section that reads:
Danger: 1,2-Dibromo-3-chloropropane. Cancer hazard. This information allows personnel who
handle DBCP-contaminated device and clothing to protect themselves from the harmful effects
of DBCP.
Notifying the Laundry Personnel (§1910.1044(j)(3)(ii))
Employers must notify laundry personnel who clean or launder protective clothing of the
potential harmful effects of DBCP. This information allows such personnel to protect
themselves from DBCP exposure.
Medical Surveillance (§1910.1044(m))
General (§1910.1044(m)(1), (m)(2), and (m)(3))
The Standard requires employers to provide a medical surveillance program for employees who
work in regulated areas and employees exposed to DBCP during emergency situations.
Employers must provide employees with medical examinations for employees: When initially
assigned to a regulated area; annually thereafter for as long as they are assigned to a regulated
area; and if they develop signs or symptoms commonly associated with exposure to DBCP. The
results of medical examinations administered under this program must be documented and
maintained.
Documentation and maintenance of medical-examination results provide a continuous record of
employee health. Physicians use these records to determine the extent to which employees have
experienced DBCP-related health effects since their last examination. Further, 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, ascertain its apparent
cause, and identify a course of treatment. Medical records also permit employees to determine

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whether or not they need treatment, or to evaluate the effectiveness of their employer's exposurereduction program.
Information Provided to the Physician (§1910.1044(m)(4))
The employer must provide the physician who examines each employee with the following
information: A copy of the Standard, including the appendices; a description of the employees
duties as they relate to the employee’s DBCP exposure; the level of DBCP exposure to which the
employee is exposed; and a description of personal protective equipment that the employee uses
or will use.
Making the required information available to the physician will aid in the evaluation of the
employee=s health and fitness for specific job assignments involving DBCP exposure. As noted
earlier, 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 the course of treatment required. Medical records
also ensure that employees can determine the need for treatment or other interventions, and to
evaluate the effectiveness of the employer's exposure-reduction program.
Physician's Written Opinion (§1910.1044(m)(5))
Employers must provide a copy of the physician's written opinion to each employee. This
opinion must contain the following information: The results of the medical examination; the
physician’s opinion indicating if the employee has any medical conditions that may place the
employee at increased risk of material impairment to health from continued DBCP exposure; and
any recommended limitations on the employee's DBCP exposure or on the use of protective
clothing or equipment such as respirators. This provision requires the employer to instruct the
physician not to reveal certain information to the employer.
The purpose of requiring the employer to obtain a written opinion from the physician is to
provide the employer with medical information to aid in determining the initial placement of
employees, and to assess an employee's ability to use protective clothing and equipment. The
physician's opinion also provides the employer with information about whether or not the
employee has a condition indicating overexposure to DBCP. The requirement that a physician's
opinion be written will properly memorialize the information for later retrieval if needed. The
requirement to provide employees with a copy of the physician’s written opinion will ensure that
they are informed of the results of the medical examination so that they can assist in determining
the need for, and evaluate the effectiveness of, treatment or other interventions.
Employee Information and Training (§1910.1044(n))
Employers must provide training to employees who may be exposed to DBCP, and they must
assure that employee participate in the training program. The training must include the
following topics: The information contained in the substance safety data sheet for DBCP (in
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Appendix A of the Standard); the quantity, location, manner of use, release, or storage of DBCP;
the specific characteristics of operations that could result in DBCP exposure; steps required to
protect against DBCP exposure; the purpose, proper use, and limitations of required respiratoryprotective equipment; the purpose for, and a description of, the required medical-surveillance
program; and a review of the Standard, including the appendices. The employer must ensure that
a copy of the Standard and its appendices are available to employees who require training, and
must provide the material used for the required training to OSHA compliance officers and
NIOSH on request.
Training is essential to inform employees of the hazards to which they are exposed, and to
provide them with information they can use to minimize the health hazards of DBCP. Training,
as well as having a copy of the Standard and its appendices available, also serves to explain and
reinforce the information presented to employees on signs, labels and safety data sheets; these
documents (signs, labels and safety data sheets) will be useful and effective only if employees
understand the health hazards of DBCP and are aware of the actions they can take to avoid or
minimize DBCP exposure. Providing OSHA compliance officers and NIOSH with the training
materials ensures that employees receive the required training.
Signs and Labels (§1910.1044(o))
The employer must post warning signs indicating the location of regulated areas. The signs must
read as follows: Danger: 1,2-Dibromo-3-chloropropane, followed by the appropriate trade or
common names of the substance, then the words Cancer hazard. Authorized personnel only.
Respirator required. Employers also must apply warning labels to all containers housing DBCP
or products consisting of DBCP that read: Danger: 1,2-Dibromo-3-chloropropane. Cancer
hazard.
Posting warning signs serves to warn employees that they are in or near a regulated area. Such
signs warn employees that they can enter a regulated area only if they have authority to do so
and a specific need exists to enter the area. Warning signs also supplement the training
employees receive under the Standard. Warning labels inform downstream employers and
employees of the hazards associated with exposure to DBCP and DBCP-containing products,
alert them to prevent exposure to the contaminants, and, if such exposure is unavoidable, provide
notice to downstream employers that they must comply with the requirements specified by the
Standard.
Recordkeeping (§1910.1044(p))
Exposure-Monitoring and Medical-Surveillance Records (§1910.1044(p)(1) and (p)(2))
Employers must establish and maintain exposure-monitoring records and medical-surveillance
records. This requirement provides both employers and employees with access to useful
information. The exposure-monitoring and medical-surveillance records required by the
Standard assist employees and their physicians in determining the need for treatment or other
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interventions as a result of the employee’s exposure to DBCP. The information also will enable
the employers to better ensure that employees are not being overexposed to DBCP; such
information may alert the employer that steps must be taken to reduce DBCP exposures.
Employers must maintain exposure-monitoring and medical-surveillance records for at least 40
years, or the duration of employment plus 20 years, whichever is longer. OSHA requires
maintenance of these records for this extended period because of the long latency associated with
the development of DBCP-related cancers, sterility, and infertility.
Availability (§1910.1044(p)(3))
On request, employers must make available to an OSHA compliance officer and NIOSH any
records maintained according to the Standard, including training materials, for examination and
copying. In addition, employers must provide exposure-monitoring and medical-surveillance
records to employees and their designated representatives on request.
The OSHA compliance officer uses these records to assess employer compliance with the major
requirements of the Standard, while NIOSH may compile these records for research purposes.
Employees and their designated representatives use exposure-monitoring and medicalsurveillance records to assess employee 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 (§1910.1044(p)(4))
Employers who cease to do business and have no successor employer must transmit exposuremonitoring and medical-surveillance records to NIOSH. Employers who remain in business for
the duration of the retention periods must transmit the records to NIOSH. In addition, all
employers also must comply with any additional requirements specified in 29 CFR
1910.1020(h).
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 when making, keeping, and preserving the
required records. The Standard is written in performance-oriented language, i.e., in terms of
what data to collect rather then how to collect the data.
4.

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

The requirements to collect and maintain information are specific to each employer and
employee involved, and no other source or agency duplicates these requirements or can make the
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required information available to OSHA (i.e., the required information is available only from
employers).
5.

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

The burden of these requirements is an equal obligation for employers who have establishments
or operations in which exposures could occur. Because of the manner in which the standard is
written, the employer can choose to respond to this requirement in a way that is best suited to
their work environment. The requirements are based on performance, and compliance is judged
accordingly. There are no set requirements for how the information is documented or
maintained.
6.

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

The Agency believes that the information collection frequencies required by the Standard are the
minimum frequencies necessary to effectively monitor the exposure and health status of
employees exposed to DBCP, and thereby fulfill its mandate “to assure so far as possible every
working man and woman in the Nation safe and healthful working conditions and to preserve our
human resources” as specified by the OSH Act at 29 U.S.C. 651. Accordingly, if employers do
not perform the required information collections, or delay in providing this information,
employees will have an increased probability of developing cancer because of their DBCP
exposures.
7.

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

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

•

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

•

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

•

requiring respondents to retain records, other than health, medical, government contract,
grant-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

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•

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

If exposure monitoring indicates that an employee has been exposed above the PEL, regardless
of whether or not respirators are used, employers must notify the employee individually in
writing (or by posting the results in an appropriate location) of the exposure-monitoring results,
and the steps being taken to reduce the exposure to within the PEL. This notification must be
provided to the employee within 15 working days.
Posting enhances the collective knowledge in the workplace of employee exposures; which in
turn enhances each employee’s understanding of his/her own exposure. Posting the results
facilitates other employees, their designated representatives, supervisor and employers in
becoming aware of exposure levels within the workplace.

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 October 8, 2008 (73 FR 58983, Docket No. OSHA-20080038) requesting public comment on its extension of the information collection requirements
contained in the Standard on 1,2-dibromo-3-chloropropane (29 CFR 1910.1044). This notice
was part of a preclearance consultation program intended to provide those interested parties the
opportunity to comment. The Agency received no comments in response to its notice.
9.

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

The Agency will provide no payments or gifts to the respondents.
10.

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

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To ensure that the personal information contained in medical-surveillance records remains
confidential, OSHA developed 29 CFR 1913.10 to regulate access to these records.
11.

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

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 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 14.

After extensive research, OSHA found no U. S. employer who currently produces DBCP or
DBCP-based end-use products, most likely because the EPA registration suspension for this
substance remains in effect (see discussion under Item 1 above); therefore, no cost or time
burdens accrue to employers under the Standard. The Agency requests one hour for OMB to
approve the information collection provisions of the Standard so that it can enforce the
paperwork requirements of the Standard if EPA lifts the suspension or technology develops new
applications for DBCP. The Standards paperwork requirements are:
Exposure Monitoring
Initial Monitoring (§ 1910.1044(f)(2))
Periodic Monitoring (§ 1910.1044(f)(3))
Additional Monitoring (§ 1910.1044(f)(4))
Notification of Results (§ 1910.1044(f)(5))
Compliance Program (§ 1910.1044(g)(2))
Respiratory Program (§1910.1044(h)(2))
Emergency Situations Written Plan (§1910.1044(i)(1)(i)(6))
Removal and Storage of Protective Clothing and Equipment (§ 910.1044(j)(2)(v))
Notifying Laundry (§ 1910.1044(j)(3)(ii))
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Medical Surveillance
Initial Examinations (§ 1910.1044(m)(1))
Periodic Examinations (§ 1910.1044(m)(2))
Additional Examinations (§ 1910.1044(m)(3))
Information Provided to Physician (§ 1910.1044(m)(4))
Physician=s Written Opinion (§ 1910.1044(m)(5))
Training Program (§ 1910.1044(n)(1))
Signs and Labels (§ 1910.1044(o))
Recordkeeping
Monitoring Records (§1910.1044(p)(1))
Medical Records (§ 1910.1044(p)(2))
Availability (§ 1910.1044(p)(3)(ii))
Transfer of Records (§ 1910.1044(p)(4))
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.

As noted above in Item 12, no employers are currently producing or using DBCP; therefore, the
Standard imposes no cost burdens on employers.

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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.

As noted above in Item 12, no employers are producing DBCP or DBCP-based end-use
products; therefore, the Agency has no annualized costs associated with enforcing the Standard.
15.

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

There are no adjustments or program changes.
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 currently collects no information under the DBCP 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.

OSHA is not seeking such approval. There are no forms on which to display the expiration date.
18.

Explain each exception to the certification statement in ROCIS.

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

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