OMB0006_justification.2009

OMB0006_justification.2009.doc

Safety Standard for Omnidirectional Citizens Band Base Station Antennas, 16 CFR Part 1204

OMB: 3041-0006

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Information Collection Request (ICR)

Standard for Omnidirectional CB Base Antennas

Supporting Statement


  1. Justification


  1. Information to be collected and circumstances that make the collection of information necessary


In 1982, the Consumer Product Safety Commission estimated that during the period from 1979 to 1981, about 45 to 50 persons each year were electrocuted when an omnidirectional citizens band base station antenna came into contact with overhead electrical power lines while the antenna was being erected or removed from its site. The Commission also estimated that during the same period more than 25 persons each year sustained serious injuries when omnidirectional citizens band base station antennas contacted overhead power lines.


To address these risks of death and injury, the Commission issued the Safety Standard for Omnidirectional Citizens Band Antennas in 1982. The standard contains performance tests to demonstrate that an antenna will not transmit a harmful electric current if it contacts an electric power line with a voltage of 14,500 volts phase-to-ground. The standard is codified at 16 C.F.R. Part 1204, Subpart A.


Certification regulations implementing the standard require manufacturers, importers, and private labelers of antennas subject to the standard to perform tests to demonstrate that those products comply with the standard, and to maintain records of those tests. The certification regulations are codified at 16 C.F.R. Part 1204, Subpart B.


  1. Use and sharing of collected information


The Commission uses the information compiled and maintained by manufacturers, importers, and private labelers of antennas subject to the standard to determine whether the products they produce or import comply with the requirements of the standard. The Commission also uses this information to obtain corrective actions if omnidirectional citizens band base station antennas fail to comply with the standard in a manner that creates a substantial risk of injury to the public.


  1. Use of information technology (IT) in information collection


Manufacturers, importers, and private labelers of antennas that are subject to the standard may establish and maintain the records required by the certification regulations by any appropriate means, including automated, electronic, mechanical, or other forms of information technology. Those records must be maintained for at least three years from the date of creation of the records, and must be made available to any designated employee of the Commission upon request.


  1. Efforts to identify duplication


Until the Commission issued the Safety Standard for Omnidirectional Citizen Band Base Station Antennas, the information required by the certification regulations did not exist. No source exists for the information required by the certification regulations other than manufacturers, importers, and private labelers of antennas subject to the standard.


  1. Impact on small businesses


In 1993, the Commission reviewed the Safety Standard for Omnidirectional Citizens Band Base Station Antennas and certification regulations in accordance with provisions of section 610 of the Regulatory Flexibility Act (5 U.S.C. 610). The Commission concluded that the standard and certification rules did not have a significant economic impact on a substantial number of small businesses (March 24, 1993, 58 FR 15815).


  1. Consequences to Federal program or policy activities if collection is

not conducted or is conducted less frequently


When the Commission issued the standard, it estimated that its requirements could be expected to prevent approximately eight deaths and eight other injuries a year. If manufacturers, importers, and private labelers of antennas subject to the standard did not perform the testing required by the standard and certification regulations, the number and severity of injuries resulting from accidental contact of omnidirectional citizens band base station antennas with overhead powerlines could increase.


If manufacturers, importers, and private labelers did not establish and maintain the records of testing required by the certification regulations, the Commission could obtain that information only by collecting samples of antennas and performing its own tests of those samples.


The certification regulations allow manufacturers, importers, or private labelers to use either the tests in the standard or other reasonable test procedures. Those regulations also allow the manufacturer to define production lots and sample from those production lots in any manner that provides a high degree of assurance that all antennas manufactured during the applicable production interval will pass the standard.


  1. Special circumstances requiring respondents to report information more often than quarterly or to prepare responses in fewer than 30 days


The collection of information in the standard and certification regulations is not conducted under any of the conditions described in item seven.


  1. Agency’s Federal Register Notice and related information


A Federal Register Notice was published July 8, 2009. Comments were not received in response to this notice.


  1. Decision to provide payment or gift


The Commission does not provide any payment or gift to firms which perform the testing and maintain the records required by the standard and certification regulations.


  1. Assurance of confidentiality


If the Commission collects any information from a manufacturer, importer, or private labeler from records that are required by the certification regulations and the firm claims that such information is trade secret or confidential business information, that information is subject to the Commission’s procedures for withholding confidential information from public disclosure. Those procedures are codified at 16 C.F.R. Part 1015, Subpart B. If such information is requested under the provisions of the Freedom of Information Act, the manufacturer, importer, or private labeler is notified and given the opportunity to respond before the Commission releases the information.


  1. Questions of a sensitive nature


The standard for omnidirectional citizens band base station antennas and certification regulations does not require manufacturers, importers, or private labelers to provide any information of a sensitive nature.


  1. Estimate of hour burden to respondents


The Commission staff estimates that about five firms are subject to the testing and recordkeeping requirements of the certification regulations. The Commission staff estimates further that the annual testing and recordkeeping burden imposed by the regulations on each of these firms on average is approximately 220 hours. Thus, the total annual burden imposed by the certification regulations on all manufacturers, importers and private labelers of omnidirectional citizens band base station antennas is about 1,100 hours.


The Commission staff estimates that the average hourly cost to reporting firms for the time required to perform the required testing and maintain the required records is about $54.88/hour (average total compensation for management, professional, and related for all workers, goods-producing industries (private industry), Bureau of Labor Statistics, September 2008) times 1,100 hours, or an annual cost to the industry of approximately $60,400.


  1. Estimate of total annual cost burden to respondents


The only costs to manufacturers, importers, and private labelers of omnidirectional citizens band base station antennas associated with the collection of information in the standard and certification regulations are those described in item 12, above.


  1. Estimate of annualized costs to the federal government


During a typical year, the Commission expends approximately 40 staff hours reviewing records required to be maintained by the certification regulations for omnidirectional citizens band base station antennas. The annual costs to the Federal government of the collection of information in these regulations is estimated to be $79.84/hour therefore a total compensation of $3,200. This assumes a Federal government employee with GS14/5 rank and a 29.9 percent cost of benefits (OPM Salary Table 2009-DCB).


  1. Program changes or adjustments


No change has been made to the collection of information in the Safety Standard for Omnidirectional Citizens Band Base Station Antennas and certification regulations since it was last approved by OMB.


  1. Plans for tabulation and publication


The Commission will not publish the results of this collection of information.


  1. Rationale for not displaying the expiration date for OMB approval


The Commission does not seek to avoid display of the expiration date for the OMB approval of this collection of information.


  1. Exception to the certification statement


Not applicable.


  1. Collections of Information Employing Statistical Methods


Not applicable.











File Typeapplication/msword
File TitleSupporting Statement
AuthorPreferred Customer
Last Modified Bylglatz
File Modified2009-09-17
File Created2009-03-20

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