Ss-blasting 1218-0217 Feb 17 09

SUPPORTING STATEMENT FOR THE
INFORMATION COLLECTION REQUIREMENTS CONTAINED
IN THE STANDARD ON BLASTING AND THE USE OF EXPLOSIVES,
29 CFR PART 1926, SUBPART U 1
(OFFICE OF MANAGEMENT AND BUDGET (OMB))
CONTROL NO. 1218-0217 (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 purpose of the Occupational Safety and Health Act (OSH Act) is to “assure as far as
possible every working man and woman in the Nation safe and healthful working conditions and
to preserve our human resources” (29 U.S.C. 651). To achieve this objective, the OSH Act
specifically authorizes “the development and promulgation of occupational safety and health
standards” (29 U.S.C. 651). In addition, the OSH 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).
Under the Authority granted by the OSH Act, the Occupational Safety and Health
Administration (“OSHA” or “the Agency”) published a standard under 29 CFR Part 1926,
Subpart U (Blasting and the Use of Explosives) (“Blasting Operations”) to protect employees
who work with and around blasting operations. Items 2 and 12 below list and describe the
specific information collection requirements contained in this Subpart.
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.

Subpart U contains several information collection requirements. Each of the following
paragraphs lists and describes the information collection requirements contained in Blasting
Operations.
§ 1926.900(d)
The employer must ensure that explosives not in use are kept in a locked magazine and are
unavailable to persons not authorized to handle the explosives. The employer must maintain an
inventory and use record of all explosives in use and not in use. The employer must contact the
appropriate authorities in the event of loss, theft, or unauthorized entry into a magazine.

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

This requirement ensures that all explosives are accounted for and that they are being kept in a
safe and secure place, away from unauthorized users. This level of control is necessary to
prevent unintended or unlawful detonation of explosives and resultant injuries to and fatalities of
working men and women.
The language was adopted from ANSI M28.1–1969, paragraph 7.1.5 (modified) and reflects the
national consensus as well as the usual and customary industry practices in existence since
before the time of OSHA’s creation and continuing through today. Storage and inventory
requirements are also found under the Justice Department, Bureau of Alcohol, Tobacco and
Firearms in 27 CFR part 555.
§ 1926.900(i)
Employees authorized to prepare explosive charges or conduct blasting operations shall use
every reasonable precaution including, but not limited to, visual and audible warning signals,
flags, or barricades, to ensure employee safety.
OSHA does not believe this is a collection of information since employers may use physical
means such as barricades or flags to ensure employee safety.
In addition, this language was adopted from ANSI A10.7-1970, paragraph 6.1.8 and reflects the
national consensus as well as the usual and customary industry practices in existence since
before the time of OSHA’s creation and continuing through today.
§ 1926.900(k)(3)(i)
Employers must prominently display adequate signs warning against the use of mobile radio
transmitters on all roads within 1,000 feet of blasting operations. Whenever adherence to the
1,000-foot distance would create an operational handicap, a competent person shall be consulted
to evaluate the particular situation, and alternative provisions may be made which are adequately
designed to prevent any premature firing of electric blasting caps. A description of any such
alternatives shall be reduced to writing and shall be certified as meeting the purposes of this
subdivision by the competent person consulted. The description shall be maintained at the
construction site during the duration of the work, and shall be available for inspection by
representatives of the Secretary of Labor.
This information is needed to protect the working men and women from exposure to premature
detonation of blasting operations on their roadside construction projects.
The language was adopted from ANSI A10.7–1970, paragraph 6.1.13 (2 & 3) (modified) and
reflects the national consensus. In addition, the US Department of Transportation’s Manual of
Uniform Traffic Control Devices-2000, including errata (MUTCD) at chapter 6F paragraph
6F.37, 38, 39 and 40, requires signs specifying the “Blasting Zone Ahead,” “End of Blasting
Zone,” and “Turn Off 2-way Radio and Phone.”
In the past, the Agency has used estimates that perhaps as many as 3,000 contractors a year
include blasting operations in their projects. The Agency received anecdotal information from

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the industry that questions OSHA’s estimates. According to the anecdotal information, it
appears that the number of construction sites that include blasting operations is far greater than
the 3,000 formerly considered. The range of numbers runs from a low of 10,000 to 20,000 sites
a year to a high of 40,000 to 50,000 sites a year. These numbers produce an annual average of
30,000 sites.
No matter the magnitude of the number of sites nationally, the subset of that number where
signage would create an operational handicap and require the employer to consult a competent
person who creates and certifies an alternative is extremely small. Technology has evolved since
the time this requirement was first promulgated. The Agency has received anecdotal information
from industry indicating that the vast majority of blasting operations, if not all in construction
today, use non-electric blasting methods. Mobile radio transmitters cannot cause the premature
firing of such non-electric blasting methods.
The Agency estimates that, even though the number of sites overall is far larger than earlier
estimates indicated, the number of sites experiencing the operational handicap and requiring a
certified alternative remain the same, 160 sites nationwide. The Agency has heard no
information anecdotal or otherwise suggesting that this number has increased and some
indication that it may have decreased or disappeared.
§ 1926.900(o)
Employers must notify the operators and/or owners when blasting operations are in the proximity
of overhead power lines, communication lines, utility lines, or other services and structures in
order to protect working men and women from the unintended damage and collapse of, as well
as contact with, such things. Blasting operations shall not be carried on until measures for safe
control have been taken.
This standard is necessary to protect working men and women from the hazards associated with
the unintended destruction of power, communication, and utility lines, as well as other related
services and structures.
OSHA believes that this requirement does not create an additional burden on employers. The
language was adopted from ANSI A10.7-1970, paragraph 6.1.10 (modified) and reflects the
national consensus as well as the usual and customary industry practices in existence since
before the time of OSHA’s creation and continuing through today. Similar language is also
found in the US Army Corps of Engineers regulation, 25.A.6 of 03/1967.
§ 1926.901(d)
Blasters shall be required to furnish satisfactory evidence of competency in handling explosives
and performing in a safe manner the type of blasting that will be required. This requirement is of
primary importance for protecting working men and women including the blasters themselves
when construction work involves the use of explosives and blasting agents.
OSHA believes that this requirement creates no additional burden on employers. It is usual and
customary for employers to obtain the assurances discussed in this section from blasters as a
condition of employment. This language came from ANSI A10.7-1970, paragraph 6.2.5 and
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reflects the national consensus as well as the usual and customary industry practices in existence
since before the time of OSHA’s creation and continuing through today.
§ 1926.902(h)
Employers must ensure that every vehicle or conveyance used for transporting explosives shall
be marked or placarded on both sides, the front, and the rear with the word “Explosives” in red
letters. The lettering shall be placed on a white background and be not less than 4 inches in
height. In addition to the marking or placarding, the motor vehicle or conveyance may display a
red flag, readily visible in all directions, 18 inches by 30 inches, with the word “explosives”
painted, stamped, or sewed thereon, in white letters, at least 6 inches in height.
These markings and placards serve to warn employees, who may otherwise not know, that they
are entering an area where explosives are present or working next to a vehicle used to transport
explosives on their construction site. OSHA does not believe this is a collection of information
since the Standard provides specific information to the employer to disclose to the public (5 CFR
1320.3(c)(1)).
This language was adopted from ANSI A10.7–1970, paragraph 4.1.4 and reflects the national
consensus as well as the usual and customary industry practices in existence since before the
time of OSHA’s creation and continuing through today. This language is also found in the US
Army Corps of Engineers regulation, 25.D.02 of 03/1967 (modified). In addition, Department of
Transportation regulations at 49 CFR 516-527 holds specific requirements for placarding motor
vehicles transporting explosives outside of private facilities.
§ 1926.903(d)
The employer must notify the hoist operator prior to transporting explosives or blasting agents in
a shaft conveyance. Notification ensures that the hoist operator uses all necessary precautions
when transporting explosives and blasting agents thus preventing accidental explosions and
injuries.
This requirement is necessary to protect working men and women, including hoist operators,
from the hazards associated with moving explosives on hoists.
This requirement was adopted from ANSI A10.7-1970, paragraph 4.2.4 and reflects the national
consensus, as well as the usual and customary industry practices, in existence since before the
time of OSHA’s creation and continuing through today. The Agency has received no
information describing the frequency of this occurrence other than it was extremely limited.
Additionally, OSHA’s underground construction standard, § 1926.800(e) Notification facilitates
the notice required in § 1926.903(d). The underground construction standard states that the
employer shall establish and maintain direct communications for coordination of activities with
other employers whose operations at the jobsite affect or may affect the safety of employees
underground (§ 1926.800(e)(2)).

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§ 1926.903(e)
Employers must perform weekly inspections on the electrical system of trucks used for
underground transportation of explosives. The weekly inspection is to detect any failure in the
system which would constitute an electrical hazard. The most recent certification of inspection
must be maintained and must include the date of inspection, a serial number or other identifier of
the truck inspected, and the signature of the person performing the inspection.
This requirement is necessary to protect workers underground from electrical system hazards
associated with underground transportation of explosives in trucks.
This language was adopted from the US Army Corps of Engineers regulation 25.D.03 of
03/1967. The Agency has received no information anecdotal or otherwise suggesting its estimate
of only one project a year using trucks to transport explosives underground is erroneous. It has
received anecdotal suggestions that the industry has not used trucks for explosives transportation
for decades and does not use trucks in this manner underground today.
§ 1926.903(m)
Each powder car or conveyance built for the purpose of transporting explosives and blasting
agents shall bear a reflectorized sign on each side with the word “Explosives” in letters, not less
than 4 inches in height; upon a background of sharply contrasting color. These signs serve to
warn employees, who may otherwise not know, that explosives and blasting agents are present.
OSHA does not believe this is a collection of information since the Standard provides specific
information to the employer (5 CFR 1320.3(c)(1)) for protecting working men and women on the
site. In addition, this language was adopted from ANSI A10.1–1970, paragraph 4.2.11 and
reflects the national consensus as well as the usual and customary industry practices in existence
since before the time of OSHA’s creation and continuing through today.
§ 1926.905(a)
Procedures that permit safe and efficient loading shall be established before loading is started.
This requirement ensures the protection of men and women working on construction sites where
blasting operations are conducted.
OSHA believes that this requirement is essential to employee protection and safe blasting
operations. It is usual and customary for blasting employers to have the required procedures in
place as part of their knowledge, practice and experience. This language was adopted from
ANSI A10.7-1970, paragraph 6.2.5 and reflects the national consensus as well as the usual and
customary industry practices in existence since before the time of OSHA’s creation and
continuing through today.

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§ 1926.905(p)
Paragraph (p) requires the employer to post warning signs indicating a blast area. These signs
must be maintained at all approaches to the blast area. The warning sign lettering shall not be
less than 4 inches in height on a contrasting background.
OSHA does not believe this is a collection of information since the Standard provides sufficient
information to the employer (5 CFR 1320.3(c)(1)) for protecting working men and women on the
site. This requirement ensures the protection of men and women working on construction sites
where blasting operations are conducted.
The language was adopted from ANSI A10.7–1970, paragraph 6.3.16 and reflects the national
consensus as well as the usual and customary industry practices in existence since before the
time of OSHA’s creation and continuing through today.
§ 1926.905(t)
Under § 1926.905(t), the blaster must maintain an accurate and up-to-date record of explosives,
blasting agents, and blasting supplies used in a blast. In addition, the employer must also
maintain an accurate running inventory of all explosives and blasting agents stored on the
operation. These records will ensure that all explosives, blasting agents and blasting supplies are
accounted for.
This requirement is necessary to protect working men and women in the proximity of blasting
operations from hazards of misplaced explosives, the unintended detonation of duds, and the
hazards of temporary storage of explosives.
This requirement was adopted from language in ANSI A10.7-1970, paragraph 6.3.20 and reflects
the national consensus as well as the usual and customary industry practices in existence since
before the time of OSHA’s creation and continuing through today. In addition, the Department
of Justice, Bureau of Alcohol, Tobacco and Firearms, requires inventory and recordkeeping at 27
CFR part 555. Section 107 requires that a licensee or permittee keep records of all acquisitions
and dispositions of explosive materials and section 127 requires them to maintain a daily
summary of magazine transactions (27 CFR 555.107 & 127).
§ 1926.909(a)
Employers must post a code of blasting signals, similar to Table U-1 below, on one or more
conspicuous places at the operation. Additionally, all employees shall familiarize themselves
with the code and conform to it at all times. Danger signs shall also be placed at suitable
locations.

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TABLE U-1
WARNING SIGNAL – A 1-minute series of long blasts 5 minutes prior to blast signal.
BLASTING SIGNAL – A series of short blasts 1 minutes prior to the shot.
ALL CLEAR SIGNAL – A prolonged blast following the inspection of blast area.
OSHA does not believe this is a collection of information since the Standard provides specific
information to the employer for disclosure to (5 CFR 1320.3(c)(1)) employees in proximity to
blasting operations.
Further, the posting of blasting signals and dangers signs are adopted from ANSI A10.7–1970,
paragraph 7.1 and reflects the national consensus as well as the usual and customary industry
practices in existence since before the time of OSHA’s creation and continuing through today.
Therefore, the Agency is not taking burden hours or costs for these provisions.
3.

Describe whether, and to what extent, the collection of information involves the use of automated,
electronic, mechanical, or other technical collection techniques or other forms of information technology,
e.g., permitting electronic submission of responses, and the basis for the decision of adopting this means
of collection. Also, describe any consideration of using information technology to reduce the burdens.

Employers may use any available technology to establish and maintain the documents specified
by the Subpart. The Agency wrote the paperwork requirements in performance oriented
language, i.e., in terms of what data to collect, not how to record 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.

OSHA has examined related information collection requirements of other agencies involved in
the regulation of explosives and has determined that OSHA’s information collection
requirements in this Subpart do not require the employer to duplicate information requested by
other agencies. The information collection requirements of the Subpart are specific to each
employer involved and the required information is available only from the parties designated in
the Subpart.
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 Subpart do not have a significant
impact on a substantial number of small entities.
6.

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

The Agency believes that the information collection frequencies required by the Subpart are the
minimum frequencies necessary to 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 OSH Act at 29 U.S.C. 651. Accordingly, if employers do not
perform the information collection required by 29 CFR part 1926, subpart U or delay in
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providing this information, employees are at risk of serious injuries or death while working with
or around blasting operations.
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 statistical data classification that has not been reviewed and approved
by OMB;

•

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

•

No special circumstances exist that require employers to collect information in the manner or
using the procedures specified by this item; the paperwork requirements in the Subpart conform
to the guidelines set forth in 5 CFR 1320.5.
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 before submission to OMB. Summarize public comments received in response to that notice
and describe actions taken by the agency in response to those 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, revealed, 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 three years -- even if the collection of information
activity is the same as in prior periods. There may be circumstances that mitigate against 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 notice in the Federal Register on December 8, 2008 (73 FR 74525, Docket No.
OSHA-2008-0045) requesting public comment on its proposed extension of the information
collection requirements specified by the Standard on Blasting and the Use of Explosives (29

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CFR part 1926, subpart U). This notice is part of a preclearance consultation program 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 remuneration 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 Subpart 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.

The paperwork requirements specified by the Subpart do not involve sensitive information.
12. Provide estimates of the hour burden of the collection of information. The statement should:
•

Indicate the number of respondents, frequency of response, annual hour burden, and an
explanation of how the burden was estimated. Unless directed to do so, agencies should not
conduct special surveys to obtain information on which to base hour burden estimates.
Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour
burden on respondents is expected to vary widely because of differences in activity, size, or
complexity, show the range of estimated hour burden, and explain the reasons for the
variance. Generally, estimates should not include burden hours for customary and usual
business practices.

•

If this request for approval covers more than one form, provide separate hour burden
estimates for each form.

•

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.

Below is a summary of the annual burden hour and cost estimates for the paragraphs of the
Subpart that contain a paperwork requirement described under Item 2 above. OSHA is not
listing those collections of information that are usual and customary under Item 12 since these
provisions do not create an additional burden on employers. 2

2

Rules implementing the Paperwork Reduction Act are found at 5 CFR Part 1320. 5 CFR 1320.3(b)(2)
states, “The time, effort and financial recourse necessary to comply with a collection of information that would be
incurred by a person in the normal course of their activities will be excluded from the definition of “burden” if the
Agency demonstrates that the reporting, recordkeeping, or disclosure activities needed to comply are usual and
customary.”

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The Agency is using a wage rate of $37.08 for a construction supervisor, $29.54 for a
construction employee, and $23.27 for a clerical employee. The Agency adopted the mean wage
rates from: Employer Costs for Employee Compensation, June 2008, U.S. Department of Labor,
and Bureau of Labor Statistics http://status.bls.gov/home.htm. Total compensation for these
occupational categories includes an adjustment of 29.4 percent for fringe benefits; this figure
represents the average level of fringe benefits in the private sector. The costs of labor used in
this analysis are, therefore, estimates of total hourly compensation.
§ 1926.900(k)(3)(i)
This Subpart requires a prominent display of adequate warning signs against the use of mobile
transmitters. If the signs are infeasible, an alternative method needs to be developed to prevent
premature detonation. OSHA estimates the number of blasting operations nationally is between
10,000 and 50,000. In spite of such numbers, the agency has received no information, anecdotal
or otherwise, that more blasting operations would need an alternative method. Therefore, the
Agency maintains its estimate that 160 of these sites would be inadequate for signs and would
require an alternative method be developed (i.e., closing roads completely to vehicular traffic).
OSHA estimates that it would take 8 hours to develop and certify an alternative plan. It
estimates that maintaining the plan on site and producing it for inspection by the Agency are
clerical functions taking a minimum amount of time. A search of Agency records indicate that
29 CFR 1926.900(k)(3)(i) has been cited 20 times in the last 10 years or approximately 1.8 times
a year. For the sake of estimation, the Agency agrees that more employers than those cited were
asked to produce the certified alternative plan and uses 5 requests a year as its frequency
estimate. The Agency estimates that filing, retrieving, and photocopying these several sheets of
paper would take a file clerk only 5 minutes (.08 hrs).
Burden hours to create and certify: 160 sites x 8 hours = 1,280 hours.
Costs: 1,280 hours x $37.08 = $47,462
Burden hours to maintain/produce at jobsite: 5 sites x .08 hours = 1 hour (rounded)
Costs: 1 hour x $23.27 = $23.00
Total Burden Hours: 1,280 create/certify + 1 hour maintain/produce = 1,281
hours
Total Costs: $47,462 (create/certify) + $23.00 (maintain/produce) = $47,485
§ 1926.903(e)
Paragraph (e) requires the employer to perform weekly inspections on the electrical system of
trucks used for underground transportation of explosives. The employer must also maintain the
most recent certification record.
OSHA staff with explosives background believes there is only one employer using a truck to
transport explosives underground. It is estimated that it takes a truck mechanic 10 minutes (0.17
hour) a week to have the truck’s electrical system checked and prepare the certification records.
Upon inspection, it will take 5 minutes (.08 hour) per week to file and maintain the most recent

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certified inspection record. Therefore, the employer will expend 15 minutes (.25 hour) weekly to
check the electrical system and to prepare and maintain the necessary certification.
Burden hours: 1 employer x .25 hour x 52 weeks = 13 hours
Costs: 13 hours x $29.54 = $384
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),
use 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.

Where signs can be used to provide required safety warnings and communications, the Agency
estimates that it would cost approximately $50.00 to purchase each sign. Pricing information is
available on the internet. The signs are reusable. The number of signs required would vary for
each worksite; however, it is estimated that at least four signs would be needed at each site.
Therefore, each of the 3,000 estimated employers would need at least 4 signs and an estimated
third of that number would need signs for an additional site.
Sign Purchase Costs: 3,000 + 1,000 employers x $50 (cost per sign) x 4 number
of signs) = $800,000.
14.

Provide estimates of the 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 into a single table.

The Agency estimates that a compliance officer (GS-12, step 5), at an hourly wage rate of
$37.89, spends about 60 minutes (1 hour) during an inspection reviewing the documents required
by Subpart U. OSHA determines that its compliance officers will conduct 10 such inspections

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during each year covered by this ICR. 3 In making this cost determination, the Agency does not
account for other occupational costs (e.g., equipment, overhead, and support staff expenses)
because it considers these costs to be normal expenses that would occur without the collection of
information requirements specified by Subpart U. Therefore, the total cost of these paperwork
requirements to the Federal government is:
Cost: 10 inspections x 1 hour x $37.89 = $379
15.

Explain the reasons for any program changes or adjustments.

There is an adjustment increase of 1 hour. In the previous ICR, the Agency calculated the
burden under 1926.900(k)(3)(i) to produce and maintain an alternative plan in lieu of signs at .40
hour. In this ICR, the Agency has rounded the calculation up to 1 hour which increases the
current burden hour from 1,293 to 1,294.
16.

For collections of information whose results will be published, outline plans for tabulations, 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 Subpart.
17.

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

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

Explain each exception to the certification statement in ROCIS.

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

3

OSHA estimated the number of inspections by researching the IMIS data for Agency inspection
experience over the last 10 years and by estimating that the trend would continue for the life of this ICR. There
were 97 inspections where 29 CFR part 1926, subpart U was cited between October 1, 1994 and July 31, 2005.
Allowing for a few incompliance inspections, the Agency estimates 10 inspections per year.

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