Ss_1218-0070(05-26-09)

SUPPORTING STATEMENT FOR
THE INFORMATION COLLECTION REQUIREMENT ON
REPORTS OF INJURIES TO EMPLOYEES OPERATING
MECHANICAL POWER PRESSES (29 CFR 1910.217(g)) 1
OFFICE OF MANAGEMENT AND BUDGET (OMB)
CONTROL NO. 1218-0070 (May 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 (“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).
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).
Under the authority granted by the Act, the Occupational Safety and Health Administration
(“OSHA” or “the Agency”) published a provision at 29 CFR 1910.217(g) for general industry
titled “Reports of Injuries to Employees Operating Mechanical Power Presses” (“the
Provision"). 2 Items 2 and 12 below describe in detail the specific information collection
requirement of the Provision.
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.

In the event an employee is injured while operating a mechanical power press, 29 CFR
1910.217(g) requires an employer to provide information to OSHA regarding the accident within
1

The purpose of this Supporting Statement is to analyze and describe the burden hours and costs associated
with this Provision that contains a paperwork requirement; this Supporting Statement does not provide information
or guidance on how to comply with, or how to enforce, the Provision.
2

The Agency has additional collections of information with different OMB Control Numbers in its
Standard on Mechanical Power Presses (e.g., inspection, maintenance, and modification of presses (29 CFR
1910.217(e)(1)(i) and (ii)) (OMB Control No. 1218-0229) and Presence sensing device initiation (PSDI) (29 CFR
1910.217(h)) (OMB Control No. 1218-0143)).

30 days of the accident. This information includes the employer’s and employee’s names,
workplace address and location, injury sustained, task being performed when the injury occurred,
number of operators required for the operation and the number of operators provided with
controls and safeguards, cause of the accident, type of clutch, safeguard(s), and feeding
method(s) used, and means used to actuate the press stroke. OSHA’s Directorate of Safety
Standards Programs (currently, the Directorate of Standards and Guidance), or the State agency
administering a plan approved by the Assistant Secretary of Labor for Occupational Safety and
Health, collects the information. These reports are a source of up-to-date information on power
press machines. Particularly, this information identifies the equipment used and conditions
associated with these injuries.
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 reporting or maintaining records associated with the information collection
requirement in 29 CFR 1910.217(g). The Agency wrote the paperwork requirement of the
Standard in performance-oriented language (i.e., in terms of what data to collect, not how to
record the data). Approximately 8 percent of the reports were received by email.
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 OSHA 300 log requires employers to record the name and job title of the employee, as well
as the date of injury, location of injury, and a description of the injury. It does not, however,
require the employer to provide details such as the type of clutch, safeguard(s), and feeding
method(s) used, and the means used to actuate the press stroke. Thus, much of the information
required by 29 CFR 1910.217(g) is not otherwise required to be provided to OSHA. This
additional information is particularly useful to OSHA in understanding the causes of injuries
related to the operation of mechanical power presses.
5. If the collection of information impacts small businesses or other small entities, describe any methods used
to minimize burden.

The information collection requirement specified by the Provision does not have a significant
impact on a substantial number of small entities.
6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is
conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The collection of information is for the purpose of employee safety and health in the workplace
and is the minimum amount necessary and appropriate. Employers submit information when an
employee is injured when operating a mechanical power press.

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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 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 secrets, or other confidential information unless
the agency can demonstrate 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 using the procedures
specified by this item. The requirement is within 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 prior
to 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, 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 notice in the Federal Register on March 26, 2009 (74 FR 13266, Docket No. OSHA2009-0006) requesting public comment on its proposal to extend the Office of Management and
Budget’s (OMB) approval of the information collection requirement specified by 29 CFR
1910.217(g) (Reports of injuries to employees operating mechanical power presses). This
notice was part of a preclearance consultation program to provide the general public and
government agencies with an opportunity to comment on OSHA’s request for an extension by
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OMB of a previous approval of the information collection requirement found in the Provision.
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 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 requirement specified by the Provision does not require the collection of
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 Provision does not require providing 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
The burden hours are calculated by multiplying the estimated total number of responses per year
by the average time per response. In the past three years, OSHA’s Directorate of Standards and
Guidance (previously named the Directorate of Safety Standards Programs) received 113 reports
of injuries to employees operating mechanical power presses (an average of approximately 38
annually).
OSHA estimates that it takes an employer 15 minutes (.25 hour) to obtain information and to
prepare the written report; and five minutes (.08 hour) for a secretary to submit the report to
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OSHA. The time per response (.33 hour [.25 + .08]) is considered reasonable based on informal
discussions with employers who have submitted these reports.
The Agency determined average wage rates for the Provision using the following hourly wage
rates for the relevant occupational categories which were derived from the May 2007 National
Industry-Specific Occupational Employment and Wage Estimates published by the Bureau of
Labor Statistics. These wages have been adjusted to reflect the fact that fringe benefits comprise
roughly 29.3 percent of total employee compensation in the private sector. The costs of labor
used in this analysis are; therefore, estimates of total hourly compensation. These hourly wages
are:
•
•

Blue collar supervisor: $32.86
Clerical worker:
$23.88
Burden hours:

38 reports x .25 hour = 10 hours
38 reports x .08 hour = 3 hours
13 hours

Cost: 10 hours x $32.86 = $329
3 hours x $23.88 = $ 72
$401
13. Provide an estimate for 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 collections services
should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult
with a sample of respondent (fewer than 10), utilize the 60-day pre-OMB submission public comment
process and use existing economic or regulatory impact analysis associated with the rulemaking
containing the information collection, as appropriate.

•

Generally, estimates should not include purchases of equipment or services, or portions thereof, made:
(1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with
the information collection, (3) for reasons other than to provide information or keep records for the
government, or (4) as part of customary and usual business or private practices.

The cost determinations made under Item 12 account for the total annual cost burden to
respondents or recordkeepers resulting from these collection of information requirements.
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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
in a single table.

OSHA estimates that a Safety Specialist (GS-12, step 5), with an hourly wage rate of $39.70,
spends an average of 15 minutes (.25 hour) reviewing each injury report. The Agency receives
an average of 38 reports annually. Therefore, the total cost of these paperwork requirements to
the Federal government is:
Cost: 38 reports x .25 hour x $39.70 = $377
15. Explain the reasons for any program changes or adjustments.

The Agency reports an adjustment decrease of 3 burden hours (from 16 to 13 hours). This
decrease is a result of a decline in the number of reports received by OSHA annually.
16. For collections of information whose results will be published, outline plans for tabulation, and
publication. Address any complex analytical techniques that will be used. Provide the time schedule for the
entire project, including beginning and ending dates of the collection information, completion of report,
publication dates, and other actions.

OSHA will not publish the information collected under the Provision.
17. If seeking approval to not display the expiration date for OMB approval of the information collection,
explain the reasons that display would be appropriate.

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

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

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