Ss_1218-0200 (12-14-09)

SUPPORTING STATEMENT FOR
THE INFORMATION COLLECTION REQUIREMENTS FOR
THE STANDARD ON PROCESS SAFETY MANAGEMENT
OF HIGHLY HAZARDOUS CHEMICALS
(29 CFR 1910.119) 1
OFFICE OF MANAGEMENT AND BUDGET (OMB)
CONTROL NO. 1218-0200 (November 2009)

JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary. Identify any legal or
administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each
statute and regulation mandating or authorizing the collection of information.

The main objective of the Occupational Safety and Health Act of 1970 (i.e., “the Act”) is to
“assure so far as possible every working man and woman in the Nation safe and healthful
working conditions and to preserve our human resources” (29 U.S.C. 651). To achieve this
objective, the Act authorizes “the development and promulgation of occupational safety and
health standards” (29 U.S.C. 651).
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).
The Clean Air Act Amendments (“CAAA”) of 1990 required the Occupational Safety and
Health Administration (“OSHA” or “the Agency”) to develop a standard on Process Safety
Management of Highly Hazardous Chemicals (“the PSM Standard” or “the Standard”)
containing certain minimum requirements to prevent accidental releases of chemicals that could
pose a threat to workers. Under the authority granted by the Act, OSHA published the PSM
Standard at 29 CFR 1910.119. The Standard, rather than setting specific engineering
requirements, emphasizes the application of documented management controls; using the
controls, companies address the risk associated with handling or working near highly hazardous
chemicals. The Standard contains a number of paperwork requirements such as developing
written process safety information, procedures and management practices; updating operating
procedures and safe work practices; evaluating safety history and policies of contractors;
conducting periodic evaluations; and documenting worker training. Items 2 and 12 below
describe in detail the specific information collection requirements of the Standard.

1

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

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection,
indicate the actual use the agency has made of the information received from the current collection.

The collections of information in the PSM Standard are necessary for implementing the
requirements of the Standard. The information is used by employers to assure that processes
using highly hazardous chemicals with the potential for a catastrophic release are operated as
safely as possible. The employer must thoroughly consider all facets of a process, as well as the
involvement of workers in that process. Employers analyze processes so that they can identify,
evaluate, and control problems that could lead to a major release, fire, or explosion. The
Standard specifies several paperwork requirements. The purpose of these requirements is to
ensure that employers collect the information necessary to control and reduce injuries and
fatalities in workplaces that have the potential for highly hazardous chemical catastrophes. The
following sections describe in detail the collection of information requirements in the Standard.
(A) Employee Participation (paragraph (c)). Employers are required by paragraph
(c)(1) to develop a written plan of action regarding the implementation of the employee
participation required by this paragraph. Paragraph (c)(2) requires employers to consult with
workers and their representatives on the conduct and development of process hazard analyses
and on the development of the other elements of process safety management in the Standard.
Under paragraph (c)(3) employers must provide access to process hazard analyses and other
information to workers and their representatives. 2
(B) Process Safety Information (paragraph (d)). Paragraph (d) requires employers to
complete a compilation of written process safety information prior to conducting a process
hazard analysis. The compilation of written process safety information, which includes
information on the hazards of chemicals, the technology of the process, and the equipment, is to
enable the employer and workers involved in operating the process to identify and understand the
hazards posed by processes involving highly hazardous chemicals.
(C) Process Hazard Analysis (paragraph (e)(1)). Paragraph (e)(1) requires the
employer to perform an initial process hazard analysis on processes covered by the Standard.
The evaluation must be appropriate to the complexity of the process and must identify, evaluate,
and control the hazards involved in the process.
(D) Resolution of Hazards (paragraph (e)(5)). Paragraph (e)(5) requires
documentation of the actions the employer takes to resolve the findings and recommendations of
the team that performed the process hazard analysis, including a schedule for completing these
actions. In addition, the employer is to communicate this information to affected operating,
maintenance, and other workers whose work assignments are in the process.

2

In the 1999 ICR, OSHA indicated that the on-going burden of worker participation required by paragraph
(c) is included in other elements of the Standard and, therefore, no burden hours were assigned to this paragraph.
Comments to the ICR concurred with the Agency’s assessment regarding this burden.

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(E) Updating, Revalidating, and Retaining the Process Hazard Analysis
(paragraphs (e)(6) and (e)(7)). Paragraph (e)(6) requires that the initial process hazard analysis
be updated and revalidated by a team at least every 5 years. Paragraph (e)(7) requires the
employer to retain process hazard analyses for the life of each process covered by this section, as
well as the documented resolution of recommendations described in paragraph (e)(5).
(F) Operating Procedures (paragraphs (f)(1) - (f)(4)). Paragraph (f)(1) requires the
employer to develop and implement written operating procedures that provide clear instructions
for safely conducting activities involved in each covered process consistent with the process
safety information. Paragraph (f)(2) requires the employer to make the operating procedures
readily accessible to workers who work in or maintain a process. Paragraph (f)(3) requires the
employer to review the operating procedures as often as necessary to assure that they reflect
current operating practice, and that the employer certify annually that these operating procedures
are current and accurate. Paragraph (f)(4) requires the employer to develop and implement safe
work practices that provide for the control of hazards during operations such as lockout/tagout;
confined-space entry; opening process equipment or piping; and control over entrance into a
facility by maintenance, contractor, laboratory, or other support personnel. These safe practices
apply to both the employer’s workers and contractor workers.
(G) Training (Initial, Refresher, and Documentation) (paragraphs (g)(1) - (g)(3)).
Paragraph (g)(1) requires employers to train workers presently involved in operating a process
before they become involved in operating a newly assigned process. The training shall
emphasize specific safety and health hazards; emergency operations, including shutdown; and
safe work practices applicable to the worker’s job tasks. Paragraph (g)(2) requires that the
employer provide refresher training at least every 3 years, and more often if necessary.
Paragraph (g)(3) requires the employer to prepare a record that contains the name of worker, the
date of training, and the means used to verify that the worker understood the training. 3
(H) Contractors (paragraphs (h)(2)(i) - (h)(2)(iv), (h)(2)(vi), (h)(3)(iii), and
(h)(3)(v)). This paragraph imposes collection of information requirements on both employers
and on contractors. Paragraph (h)(2)(i) requires employers, when selecting a contractor, to
obtain and evaluate information regarding the contract employer’s safety performance and
programs. Paragraph (h)(2)(ii) requires that the employer inform contract employers of known
potential fire, explosion, or toxic release hazards related to the contractor’s work and the process.
Paragraph (h)(2)(iii) requires that the employer explain to contract employers the applicable
provisions of the emergency action plan required by paragraph (n) of the Standard. Paragraph
(h)(2)(iv) requires the employer to develop and implement safe work practices consistent with
paragraph (f)(4) to control the entrance, presence and exit of contract employers and contract
workers in covered process areas. 4 Paragraph (h)(2)(vi) requires the employer to maintain a
3

OSHA finds that the training requirements in paragraphs (g)(2) and (g)(3), as well as the training
requirements in paragraphs (h)(3)(i) and (h)(3)(ii), (j)(3), and (l)(3) are performance-oriented requirements.
Performance-oriented training requirements are not included in burden-hour and cost described in Item 12.
4

The burden-hour and cost estimates associated with paragraph (h)(2)(iv) are included in the estimates for
paragraph (f) in Item 12.

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contract worker injury and illness log related to the contractor’s work in process areas.
Paragraph (h)(3)(iii) requires the contract employer to document: that contract workers have
been trained to perform their work practices safely and are knowledgeable about the fire,
explosion, and toxic hazards in the workplace; and the identity of the contract worker who
received the training, the date of training, and the means used to verify that the worker
understood the training. 5 Paragraph (h)(3)(v) requires the contractor to advise the employer of
any unique hazard presented by the contract employer’s work, or any hazards found by the
contract employer’s work.
(I) Written Procedures, Inspections, and Testing (paragraphs (j)(2) and (j)(4)(iv)).
Paragraph (j)(2) requires the employer to establish written procedures to maintain the on-going
integrity of process equipment. Paragraph (j)(4)(iv) requires that employers document
inspections and tests performed on process equipment. The documentation shall identify the date
of the inspection or test, the name of the person who performed the inspection or test, the serial
number or other identifier of the equipment on which the inspection or test was performed, a
description of the inspection or test performed, and the results of the inspection or test.
(J) Hot Work Permit (paragraph (k)(2)). Paragraph (k)(2) requires the employer to
provide the following information on permits issued for hot work operations conducted on or
near a covered process: the date(s) authorized for hot work, the identity of the object on which
hot work is to be performed, and documentation that the appropriate fire protection and
prevention plans have been implemented. The permit must be kept on file until completion of
the hot work operations.
(K) Management of Change (paragraphs (l)(1),(l)(4), and (l)(5)). Paragraph (l)(1)
requires the employer to establish and implement written procedures to manage changes (except
for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and
for changes to facilities that affect a covered process. Paragraph (l)(4) requires the employer to
update the procedures and practices set forth in paragraph (d) of the Standard if a change in
paragraph (l) results in a change to the process safety information. Similarly, paragraph (l)(5)
requires the employer to update the relevant information in paragraph (f) of the Standard if a
change in paragraph (l) results in a change to the operating procedures and practices. 6
(L) Incident Investigation (paragraphs (m)(4)–(m)(7)). Paragraph (m)(4) requires
that a report be prepared at the conclusion of any incident investigation, and that the report
include, at a minimum, the date of the incident; the date the investigation began; a description of
the incident; the factors that contributed to the incident; and any recommendations resulting from
the investigation. Paragraph (m)(5) specifies that the employer must document resolutions and
corrective measures taken with regard to the findings and recommendations provided in an
5

In Item 12, OSHA is accounting for the training documentation requirements for contract employers
specified by paragraph (h)(3)(iii) under the training documentation provision of paragraph (g)(3).
6

The burden hour and cost estimates for the information and training requirements specified by paragraph
(l)(3) are included in the estimates for paragraph (g)(2) in Item 12.

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incident investigation report, while paragraph (m)(6) states that the employer must allow affected
personnel (including contract workers), whose job tasks are relevant to the incident findings, to
review the report. Paragraph (m)(7) requires that incident investigation reports be retained for 5
years.
(M) Emergency Planning and Response (paragraph (n)). Paragraph (n) requires the
employer to establish and implement an emergency action plan in accordance with the provisions
of 29 CFR 1910.38(a). In addition, the emergency action plan shall include procedures for
handling small releases.
(N) Compliance Audits (paragraphs (o)(1) and (o)(3) – (o)(5)). Under paragraph
(o)(1), employers are required to certify that they have evaluated compliance with the provisions
of this section at least every 3 years to ensure that the procedures and practices developed under
the Standard are adequate and are being followed. Paragraph (o)(3) requires that a report of the
audit findings be developed, while paragraph (o)(4) states that the employer must promptly
determine and document an appropriate response to each of the findings of the compliance audit,
and document that the deficiencies have been corrected. Paragraph (o)(5) requires that the last 2
reports be retained.
(O) Records Disclosure. Employers must disclose records required by the Standard to
an OSHA compliance officer during an OSHA inspection.
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 automated, electronic, mechanical, or other technological information
collection techniques, or other forms of information technology (e.g., electronic submission of
responses), when establishing and maintaining the required records. The Agency wrote the
paperwork requirements of the Standard in performance-oriented language (i.e., in terms of what
data to collect, not how to record the data).
4. Describe efforts to identify duplication. Show specifically why any similar information already available
cannot be used or modified for use for the purpose(s) described in Item 2 above.

Section 304 of the Clean Air Act Amendments (CAAA) required that the Secretary of Labor and
the Administrator of the Environmental Protection Agency (EPA) promulgate a chemical process
safety standard to prevent accidental releases of chemicals that could pose a threat to workers,
including development of a list of highly hazardous chemicals that include toxic, flammable,
highly reactive and explosive substances. The CAAA also specified the minimum elements to
be covered by the Standard. The Standard does not duplicate another standard.
Some information developed under OSHA's Hazard Communication Standard duplicates the
requirements in the PSM Standard. However, OSHA will accept the information collected under
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the Hazard Communication Standard, or similar information developed in response to the
requirements of other agencies, provided it fulfills the requirements of the PSM Standard.
5. If the collection of information impacts small businesses or other small entities, describe any methods used
to minimize burden.

Small firms account for approximately 10 percent of the total costs of the PSM Standard. OSHA
specifically addressed small business concerns in the Standard. For example, a small business
might control its on-site inventory of highly hazardous chemicals by ordering more frequent,
smaller shipments so that they do not exceed the threshold for coverage specified in the
Standard. Also, they may segregate their inventory by dispersing storage around the worksite so
that release of a highly hazardous chemical from one storage area would not cause the release of
other hazardous chemicals stored on site. Moreover, small employers who use several batch
processes may be able to use a generic approach to process hazard analysis to further reduce the
estimated cost of compliance. For example, a generic process hazard analysis may be used if a
representative chemical process can be documented for the range of batch processes involved.
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 the burden.

The Agency believes that the information collection frequencies required by the Standard are the
minimum frequencies necessary to effectively regulate process safety management of highly
hazardous chemicals and, thereby, 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 by the Act at 29 U.S.C. 651. The Standard also directly carries
out the explicit requirements of the CAAA.
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

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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
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 requirements are 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 September 10, 2009 (74 FR 46621, Docket No.
OSHA-2009-0016) requesting public comment on its proposal to extend the Office of
Management and Budget’s approval of the information collection requirements contained in the
PSM Standard (29 CFR 1910.119). The notice was part of a preclearance consultation program
that provided interested parties with an opportunity to comment on OSHA’s request for an
extension by OMB of a previous approval of the information collection requirements found in
the PSM Standard. The Agency did not receive any comments regarding the proposed
information collection request.
9. Explain any decision to provide any payments or gift to respondents, other than reenumeration of
contractors or grantees.

The Agency will not provide payments or gifts to the respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in
statute, regulation, or agency policy.

Paragraph (p)(1) of the Standard states that employers must provide the specified information to
individuals involved in meeting the paperwork requirements of the Standard. To protect the
confidentiality of this information, OSHA incorporated the disclosure procedures in the Hazard
Communications Standard at 29 CFR 1910.1200(i)(1) through (i)(12), into paragraph (p)(2) of
the Standard.
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

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information, the explanation to be given to persons from whom the information is requested, and any steps to
be taken to obtain their consent.

None of the provisions in the Standard require sensitive information.
12. Provide estimates of the hour burden of the collection of information. The statement should:
·

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

·

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

·

Provide estimates of annualized cost to respondents for the hour burdens for collections of
information, identifying and using appropriate wage rate categories. The cost of contracting out or
paying outside parties for information collection activities should not be included here. Instead, this
cost should be included in Item 14.

Burden-Hour and Cost Determinations
OSHA is relying on information in EPA’s Risk Management Program (RMP) database to
estimate the number of establishments and processes that must comply with the paperwork
requirements for the Standard. For purposes of determining the paperwork burden of the PSM
Standard, the Agency estimates that there are about 7,562 establishments with a PSM-covered
process and a total of about 11,504 covered processes. In addition, the Agency estimates that
there are over 456 new PSM-covered processes each year.
All establishments in certain industries (chemical manufacturers, for example) are required by
the RMP standard to report information about their chemical inventories and risk management
plans to EPA. In addition, any establishment with chemical inventories that meet or exceed
EPA’s RMP threshold quantities (for chemicals and flammables) must also supply information.
The required information is extensive and includes: whether a process is covered by OSHA’s
PSM Standard; the establishment’s industry classification (NAICS); number of full-time
workers; and the chemical(s) or flammable(s) on site that are covered by EPA’s standard. The
RMP final standard had a list of 77 chemicals and explosives, and more than 60 flammable
substances that were covered, although regulation of flammables and explosives was later
revised.
The estimates of PSM-affected establishments and processes presented in the first paragraph
above represent a substantial decrease from the Agency’s 2006 estimates, which were about
38,000 establishments and 180,000 processes. As discussed below (in Background), the
reductions are due mainly to efforts of affected employers to find substitute substances for the
PSM chemicals and to reduce inventories of chemicals and flammables, but also because the
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original estimates by the Agency of the average number of processes per establishment proved to
be much higher than was consistent with, or supported by, data in the RMP database today. In
addition, after the PSM Standard was promulgated and paperwork packages were updated every
three years, OSHA had increased the estimated number of affected establishments proportionate
to increases reported in the number of establishments in an industry over time. In other words, if
the number of establishments in an industry increased from 10,000 to 12,000 between 1994 and
2006, OSHA increased the estimated number of PSM-affected establishments and processes in
that industry by 20 percent.
Most RPM chemicals are also on OSHA’s list of chemicals covered by the PSM Standard. A
few chemicals (chlorine, ammonia, flammable liquids, sulfur dioxide) account for as much as 80
percent of the sites reporting to RMP (see “Accident Epidemiology and the RMP Rule,”
Wharton, December 18, 2007, Table 2.2B, page 69;
http://opim.wharton.upenn.edu/risk/library/2007_EPA-Wharton_RMPRule.pdf), which is also
consistent with OSHA’s analysis of its PSM Standard. Hence, for purposes of counting
paperwork burden, the Agency concludes that the two agencies’ lists of chemicals can essentially
be the same, and that RMP data captures information providing a reasonable estimate of
establishments covered by the PSM Standard, with adjustments explained below.
As of June 1, 2009, the RMP database contained reports from 13,424 sites; of these, 7,184
establishments with 10,469 processes are covered under OSHA’s PSM Standard. A separate
count of “Level 3 Programs” proved to be about equal to the number of PSM-covered
establishments. There were 2,306 PSM-covered establishments which had between one and 19
workers, which was the criterion used by both EPA and OSHA to identify “small” plants or
employers affected by their respective standards.
Three states--California, Delaware, and New Jersey--have their own PSM regulations which
employers must follow. These regulations pre-date OSHA’s, and employers in these states were
not included in the Regulatory Impact Analysis accompanying OSHA’s final PSM Standard.
There are 882 sites in the three states in the RMP database. Subtracting these from the 7,184
PSM-covered sites in the RMP database leaves 6,302 PSM-covered sites with 9,587 processes
(assuming one process per site in the three states).
Since OSHA’s threshold quantities specified by the PSM Standard are typically five to ten times
less than those in EPA’s standard, there may be a significant number of establishments that are
covered under the PSM Standard, but not by EPA’s RMP standard. These sites would not have
to report information to EPA under the RMP standard and would, therefore, not be included in
the number of PSM-covered sites and processes. There are two reasons to conclude that the
RMP database contains most PSM-covered sites and processes. First, most of the large
employers in RMP, measured by the number of workers, have PSM-covered processes. In the
RMP database, there are 860 sites with more than 500 workers. Of these, 832 report that they
have a PSM-covered process. Of the 1,672 employers reporting to RMP with more than 250
workers, 1,598 have a PSM-covered process.

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Secondly, the RMP regulation requires all employers in ten NAICS industries to report to RMP,
regardless of inventories of chemical or flammable substances. The ten NAICS industries are:
32211 Pulp mills; 32411 Petroleum refineries; 32511 Petrochemical manufacturing; 325181
Alkalies and chlorine manufacturing; 325188 All other basic inorganic chemical manufacturing;
325192 Cyclic crude and intermediate manufacturing; 325199 All other basic organic chemical
manufacturing; 325211 Plastics material and resin manufacturing; 325311 Nitrogenous fertilizer
manufacturing; and 32532 Pesticide and other agricultural chemical manufacturing. For these 10
NAICS industries reporting into RMP, 95 percent of employers say that they have a PSMcovered process. From this comparison of industries with a high concentration of chemical
processes, the Agency believes that the RMP database is collecting information on all of the
PSM-covered sites.
The Agency has also estimated the number of employers who are covered by the PSM Standard
but not RMP using inspection data from its Integrated Management Information System (IMIS)
for all employers who received a violation under the Standard between January 2006 and
December 31, 2007. There were 257 such records, of which 232 were records of employers
required to have RMP programs. (The remaining 22 employers were in construction or service
industries that did not own, or were not the employers at, the establishment; these employers
would not appear in the RMP database.) Of the remaining 232 records in the OSHA IMIS files,
193, or about 83 percent, of the employers or sites were found in the RMP database. Based on
that data, the Agency estimates that there are 7,562 PSM-covered establishments (6,302
establishments from the RMP analysis described above multiplied by 1.20 7 ) with 11,504
processes (10,469 processes from the RMP analysis described above multiplied by 1.20). Of the
39 employers with violations of the PSM Standard who were not in RMP, most were small
establishments (about 15 percent had fewer than 20 workers, compared to about 3.5 percent of
those employers who were also found in RMP).
Over the five-year period from 1999 to 2004, there were about 1,500 new establishments that
registered or reported information in EPA’s RMP database, or about 300 per year. The Agency
is relying on these data to estimate the annual number of new PSM-covered establishments and
processes.
Background
OSHA proposed its PSM Standard in 1990. The Preliminary Regulatory Impact Analysis
(PRIA) estimated that there were 27,725 affected establishments, and that most of these
establishments would have two to four processes each (Table IV-5, page IV-14, PRIA). The
analysis did not include establishments and processes in California, New Jersey, and Delaware
which already had their own state regulations. Following public comment and hearings, OSHA
issued its final PSM Standard in 1992. The Regulatory Impact Analysis (RIA) in the final
Standard estimated that there were 29,939 affected establishments. Large establishments (20 or
more workers) were estimated to have between four and 23 covered processes, depending on the
7

This correction factor is the number of OSHA-covered establishments (232) divided by the number of
RMP-covered establishments (193).

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industry, or an average of about 10 covered processes each, while small establishments were
estimated to have an average of about two covered processes each (range: 1 to 5) (Table B-4,
Appendix B, RIA).
The PSM Standard had a list of chemicals, each with a threshold quantity (TQ) that triggers an
establishment’s involvement in the Standard. In addition, if an establishment has as much as
10,000 pounds of flammable liquids or gases, it must also comply with the Standard’s
provisions, unless the flammable material is hydrocarbons used for workplace consumption (heat
or transportation, for example), or the flammable is stored in atmospheric tanks below its boiling
point. Retail facilities, normally unmanned, remote sites, and oil and gas well drilling and
servicing operations were also exempt from the Standard.
EPA published its related Risk Management Plan final standard in 1996. EPA had a list of 77
toxic chemicals, 63 flammable substances, and Dept. of Transportation 1.1 explosives in the
scope of its rule. Because EPA’s concern was to protect the environment and public health
beyond the site’s fence line, its threshold quantities are considerably greater than OSHA’s.
The Economic Analysis for the RPM rule estimated that there were about 66,000 affected
establishments with about 92,000 processes. Of these, about 25,500 establishments with 43,800
processes qualified as Level 3 programs which would also fall under the PSM Standard. In
1998, EPA revised the scope of the RPM standard to exempt explosives and flammables used as
fuels or sold at retail facilities. Since EPA had originally estimated that the RMP rule affected
12,500 propane retailers and 17,000 consumers of propane, these establishments were not
required to report an RMP to EPA.
In 1998, EPA revised the scope of its RMP standard in regard to flammables (explosives were
also delisted). EPA exempted from threshold determination regulated flammable substances in
gasoline and naturally occurring hydrocarbon mixtures prior to initial processing. EPA also
exempted flammable mixtures that do not have a National Fire Protection Association
flammability hazard rating of 4, and also exempted transportation and storage operations
(Federal Register Vol. 63, No. 3, Jan. 6, 1998). OSHA has a broader definition of flammables in
the scope of the PSM Standard, including Class 1B and 1C flammables (see 29 CFR
1910.106(a)(19)), but that Standard also exempts the use of hydrocarbons consumed as fuel, and
transfer and storage of flammables at atmospheric pressure below a flammable’s boiling
temperature.
Under RMP, affected establishments had five years within which to report, or register,
information on their sites and processes to EPA. After the first reporting period, between 19992000, EPA had received reports from 15,145 sites. Of these, 7,108 establishments were for
Level 3 programs, and 7,482 establishments were covered under the PSM Standard. As can be
seen, the 15,145 figure is much lower than the original estimate made by EPA. EPA expected
the number of establishments reporting might be considerably less than the original estimate: “In
New Jersey, 52 percent of the manufacturers that initially registered under the state law changed

−11−

substances or quantities before the full requirements were in effect. In Delaware, the attrition
rate was 30 percent” (RMP Economic Analysis, p. 3-14, May 21, 1996).
In the second wave of RMP reporting in 2004-05, 12,065 establishments reported to EPA. Of
these, 6,055 had Level 3 programs and 6,278 were covered under the PSM Standard. (Source:
Wharton report cited above, Table 2.1, page 67 and Table 6.1 page 206.)
The updated industry profile is as follows:
Estimated Number of Existing Establishments:
7,562
Estimated Number of New Establishments:
300
Estimated Number of Existing Processes:
11,504
Estimated Number of New Processes:
456
In estimating the cost of the paperwork requirements to respondents, the Agency used average
hourly compensation rates to represent the cost of worker time. For the relevant occupational
categories, mean hourly wages from the 2007 National Compensation Survey by the Bureau of
Labor Statistics have been adjusted to account for private-sector fringe benefits of 29.2 % of total
compensation. These hourly compensation rates are:
Engineers:
- Level III:
$46.77
- Level IV:
$54.65
- Level V:
$66.97
- Level VI:
$80.20
Blue-collar supervisor: $29.55
Production workers: $22.06
Service workers:
$16.00
Clerical workers:
$20.41
(A) Employee Participation (paragraph (c)). In the 1999 ICR, OSHA indicated that the ongoing burden of employee participation required by paragraph (c) is included in other elements
of the Standard and, therefore, no burden hours were assigned to this paragraph. Comments to
the ICR concurred with the Agency’s assessment regarding this burden.
(B) Process Safety Information (paragraph (d)). Based on the compliance schedule specified
in paragraphs (e)(1)(i)-(e)(1)(v) of the Standard, OSHA believes only new establishments need
to compile the written process safety information required by this provision. Therefore, the
Agency is determining burden-hour and cost estimates only for new establishments. For each of
these establishments, this task requires 50 hours each from a level IV engineer and a blue-collar
supervisor, as well as 54 hours each from 2 production workers, for a total of 208 hours per
establishment. The total cost per establishment is $6,593 (i.e., $2,733 for a level IV engineer
($54.65/hour x 50 hours), $1,478 for a blue-collar supervisor ($29.55/hour x 50 hours), and
$2,382 for 2 production workers ($22.06/hour x 108 hours (54 hours each)). The Agency
estimates the annual total burden hours and cost for these establishments to be:
−12−

Burden hours: 300 new establishments x 208 hours = 62,400 hours
Cost: 300 new establishments x $6,593 = $1,977,900
(C) Process Hazard Analysis (paragraph (e)(1)). Only new establishments need to perform
an initial process hazard analysis for each covered process. Accordingly, for each of these
establishments, this task requires 100 hours each from a level IV engineer and a blue-collar
supervisor, as well as 18 hours each from 2 production workers, for a total of 236 hours per
establishment. The total cost for each of these establishments is $9,214 (i.e., $5,465 for a level
IV engineer ($54.65/hour x 100 hours), $2,955 for a blue-collar supervisor ($29.55/hour x 100
hours), and $794 for 2 production workers ($22.06/hour x 36 hours (18 hours each)). The
estimated total burden hours and cost for these establishments each year are:
Burden hours: 300 new establishments x 236 hours = 70,800 hours
Cost: 300 new establishments x $9,214 = $2,764,200
(D) Resolution of Hazards (paragraph (e)(5)). Documenting how and when the employer
resolves the findings and recommendations of the team that conducted the process hazard
analysis, and communicating this information to the appropriate workers, takes a level IV
engineer 22 hours per establishment. As this provision addresses initial process hazard analyses,
only new establishments are affected. The Agency determined the annual estimated burden
hours and cost for this provision as follows:
Burden hours: 300 new establishments x 22 hours = 6,600 hours
Cost: 6,600 hours x $54.65 = $360,690
(E) Updating, Revalidating, and Retaining the Process Hazard Analysis (paragraphs (e)(6)
and (e)(7)). Updating or revalidating the hazard analysis for each existing process every 5 years
(i.e., 20%, or 2,301, of processes per year), and retaining process-analysis information and the
documents specified by paragraph (e)(5), requires 50 hours each from a level IV engineer and a
level VI engineer, for a total of 100 hours per process. The total cost per process is $6,743 (i.e.,
$2,733 for a level IV engineer ($54.65/hour x 50 hours) and $4,010 for a level VI engineer
($80.20/hour x 50 hours)). For the covered process, the estimated burden hours and cost each
year is: 8
Burden hours: 2,301 existing processes x 100 hours = 230,100 hours
Cost: 2,301 existing processes x $6,743 = $15,515,643
(F) Operating Procedures (paragraph (f)(1)-(f)(4)). It takes a level IV engineer 22 hours to
develop written operating procedures and safe work practices to control the movement of the
8

Although these paragraphs do not explicitly require that employers retain these records, OSHA is taking
burden for record retention because it believes the 5-year updating and revalidation requirement specified by
paragraph (e)(6) implies that employers must retain these records.

−13−

contractor and its workers in process areas for each of the 456 new processes and 11,504 existing
processes (for a total of 11,960 processes). The yearly burden hours and cost for this provision
are estimated to be:
Burden hours: 11,960 processes x 22 hours = 263,120 hours
Cost: 263,120 hours x $54.65 = $14,379,508
(G) Training (Initial, Refresher, and Documentation) (paragraphs (g)(1)-(g)(3)). The
Agency estimates that the Standard covers approximately 1,420,000 existing workers. OSHA
assumes that the worker turnover rate for the affected establishments is 10% (142,000) of the
workers per year, and that the 142,000 replacement workers require initial training under
paragraph (g)(1). In addition, paragraph (g)(2) requires that existing workers receive refresher
training at least once every 3 years, for an annual total of 473,333 workers (i.e., one-third of
1,420,000 workers). Accordingly, a clerical worker takes 3 minutes (.05 hours) to generate and
maintain the training record specified by paragraph (g)(3) for each of these workers. The
estimated annual burden hours and cost for this provision are: 9
Burden hours: (142,000 workers + 473,333 workers = 615,333) x .05 hours =
30,767 hours
Cost: 30,767 hours x $20.41 = $627,954
(H) Contractors (paragraphs (h)(2)(i)-(h)(2)(iv), (h)(2)(vi), (h)(3)(iii)), and (h)(3)(v).
Paragraph (h) imposes collections of information on both employers and contractors. Obtaining
and evaluating information regarding a contractor’s safety performance and programs, informing
a contractor of the specified hazards and the applicable provisions of the emergency action plan,
developing and implementing safe work practices to control the entrance, presence and exit of
contract employers and contract workers in covered process areas, maintaining a contract worker
injury and illness log, documenting that contract workers have been trained to perform their
work practices safely, and requiring the contractor to advise the employer of any unique hazard
presented by the contract employer’s work, or any hazards found by the contract employer’s
work requires 50 hours each from a level IV engineer, a blue-collar supervisor, and 2 production
workers, for a total of 200 hours per establishment. In addition, the Agency finds that these
paperwork requirements affect 50 percent of, or 3,781, existing establishments each year. The
total cost per establishment is $6,417 (i.e., $2,733 for a level IV engineer ($54.65/hour x 50
hours), $1,478 for a blue-collar supervisor ($29.55/hour x 50 hours), and $2,206 for 2 production
workers ($22.06/hour x 100 hours (50 hours each))). OSHA estimates the total burden hours and
cost for these establishments each year to be:
Burden hours: 3,781 establishments x 200 hours = 756,200 hours
Cost: 3,781 establishments x $6,417 = $24,262,677

9

While these paragraphs contain no explicit record-retention requirement, the Agency is accounting for this
burden because the 3-year cycle specified by paragraph (g)(2) implies such a requirement.

−14−

(I) Written Procedures, Inspections, and Testing (paragraphs (j)(2) and (j)(4)(iv)). OSHA
finds that 456 new processes and 11,504 existing processes (for a total of 11,960 processes) must
establish and implement the required written procedures, and to document each inspection and
test performed on process equipment (including the specified information). For each of these
processes, this task requires 8 hours of a level III engineer’s time, 8.5 hours of a blue-collar
supervisor’s time, and 130 hours of a service worker’s time, for a total of 146.5 hours per
establishment. The total cost for each of these processes is $2,706 (i.e., $374 for a level III
engineer ($46.77/hour x 8 hours), $251 for a blue-collar supervisor ($29.55/hour x 8.5 hours),
and $2,080 for a service worker ($16.00/hour x 130 hours)). The estimated total burden hours
and cost for these processes each year are:
Burden hours: 11,960 processes x 146.5 hours = 1,752,140 hours
Cost: 11,960 processes x $2,706 = $32,363,760
(J) Hot Work Permits (paragraph (k)). The Agency estimates that small establishments issue
6 hot work permits per year for each covered process, while large establishments issue twice as
many per year for each process due to the additional complexity of their operations. Each of the
2,427 small establishments averages 1 process, and thus issues a total of 6 permits annually,
while each of the 5,135 large establishments averages 1.8 processes, and thus issues a total of
21.6 (12 x 1.8) hot permits annually. In addition, a blue-collar supervisor, earning $29.55 per
hour, takes 6 minutes (0.1 hours) to complete this task. The annual burden-hour and cost
estimates for these establishments are:
Burden hours: ((5,135 large establishments x 21.6 permits = 110,916) + (2,427 small
establishments x 6 permits = 14,562) = 125,478 x 0.1 hour = 12,548
hours
Cost: 12,548 hours x $29.55 = $370,793
(K) Management of Change (paragraphs (l)(1), (l)(4), and (l)(5)). To estimate the burden
hours and cost associated with developing written management-of-change procedures and
updating process safety information and operating procedures, the Agency determined that, of
the 7,562 total establishments affected by this requirement, 5,135 establishments are large and
2,427 establishments are small.
Based on the estimate that affected small establishments average one covered process each, the
Agency determined the total estimated burden hours ranged from 9.9 hours to 29.7 hours for
these establishments, depending on the complexity of the process. The Agency estimated on
average each small establishment would require 6.0 hours for a level IV engineer, earning $54.65
per hour, and 12.3 hours for production workers earning $22.06 per hour. The total burden unit
hours per establishment are, therefore, 18.3 hours. The 2,427 small establishments will incur a
total burden of 44,414 hours and a total cost of $1,453,773, determined as follows:
Burden hours: 2,427 establishments x 18.3 unit hours = 44,414 hours
Cost: 2,427 x ((6 hours x $54.65 for a level IV engineer) + (12.3 hours x
$22.06 for production workers)) = $1,453,773
−15−

For the large establishments, the Agency estimated that the number of hours would be higher in
proportion to the average number of covered processes per establishment (1.8 for large
establishments, compared to 1.0 for small establishments). To account for the greater
complexity of processes utilized by large establishments, the Agency also increased the
estimated burden hours for large establishments by a factor of three. Based on these
assumptions, the Agency estimated that large establishments would require on average 32.4
hours (6.0 x 1.8 x 3) for a level IV engineer, earning $54.65 per hour, and 66.4 hours (12.3 x 1.8
x 3) hours for production workers, earning $22.06 per hour. The total burden hours for each
large establishment are, therefore, 98.8 hours, resulting in total burden hours for all
establishments of 507,338 hours and a cost of $16,616,860, determined as follows:
Burden hours: 5,135 establishments x 98.8 hours = 507,338 hours
Cost: 5,135 establishments x ((32.4 hours x $54.65 for a level IV engineer) +
(66.4 hours x $22.06 for production workers)) = $16,616,860
In summary, for small and large establishments combined, the total burden hours for the
management-of-change information collection requirements is 551,752 hours, with an estimated
cost of $18,070,633.
(L) Incident Investigations (paragraphs (m)(4)-(m)(7)). To prepare an incident investigation
report containing the specified information, document resolutions and corrective actions, provide
the report for review by workers whose job tasks are relevant to the incident findings, and retain
the reports for 5 years requires 16 hours from a level V engineer, 48 hours from a level IV
engineer, 32 hours from a blue-collar supervisor, and 4 hours from a clerical worker, for a total
of 100 hours to perform these tasks for each incident. 10 The Agency finds that each of the 7,562
existing establishments has 1 reportable incident each year, 11 for a total of 7,562 incidents
annually. The total cost per establishment is $4,723 (i.e., $1,072 for a level V engineer
($66.97/hour x 16 hours), $2,623 for a level IV engineer ($54.65 x 48 hours), $946 for a bluecollar supervisor ($29.55/hour x 32 hours), and $82 for a clerical worker ($20.41/hour x 4
hours)). The Agency determines that the total burden-hour and cost estimates for these
establishments each year are:
Burden hours: 7,562 establishments x 100 hours = 756,200 hours
Cost: 7,562 establishments x $4,723 = $35,715,326
(M) Emergency Planning and Response (paragraph (n)). It takes 1 hour of a level V
engineer’s time (at $66.97 per hour) to establish an emergency action plan that includes
procedures for handling small releases. OSHA believes that this requirement affects only new
establishments because existing establishments have already established action plans. The yearly
burden hours and cost for these establishments are estimated to be:
10

The 100-hour estimate is based on comments submitted in response to the 1996 ICR.

11

From the original RIA.

−16−

Burden hours: 300 new establishments x 1 hour = 300 hours
Cost: 300 hours x $66.97 = $20,091
(N) Compliance Audits (paragraphs (o)(1) and (o)(3)–(o)(5)). Certifying compliance with
the standard once every 3 years after conducting a compliance audit, developing a report of the
audit findings, determining and documenting an appropriate response to each of the audit
findings, documenting that any deficiencies have been corrected, and retaining the last 2 audit
reports, takes 32 hours from a level V engineer, 48 hours from a level IV engineer, 32 hours
from a blue-collar supervisor, and 8 hours from a clerical worker, for a total of 120 hours to
complete these paperwork tasks. The Agency estimates that 2,521 establishments are affected by
these provisions each year (7,562 12 divided by 3). The total cost per establishment is $5,875
(i.e., $2,143 for a level V engineer ($66.97/hour x 32 hours), $2,623 for a level IV engineer
($54.65 x 48 hours), $946 for a blue-collar supervisor ($29.55/hour x 32 hours), and $163 for a
clerical worker ($20.41/hour x 8 hours). For each year, the estimated total burden hours and cost
for these establishments are:
Burden hours: 2,521 establishments x 120 hours = 302,520 hours
Cost: 2,521 establishments x $5,875 = $14,810,875
(O) Records Disclosure. As noted in Item 14 below, the Agency believes that approximately
110 establishments are subject to an OSHA inspection during which the employer may have to
disclose the records required by the Standard to an OSHA compliance officer. It takes 15
minutes (.25 hours) of a level III engineer’s time (at $46.79 per hour) to make this disclosure.
The annual burden hours and cost for this task are estimated to be:
Burden hours: 110 establishments x .25 hour = 28 hours
Cost: 28 hours x $46.77 = $1,310
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
service 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 respondent (fewer than 10), utilize the 60-day pre-OMB submission public comment
12

The Agency arrived at this number by applying the compliance rate used in the original RIA to the new
estimated number of affected establishments.

−17−

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.
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 may also aggregate cost estimates from Items 12, 13, and 14
into a single table.

OSHA estimates that a compliance officer (GS-12, step 5), with an hourly wage rate of $37.90,
spends about 30 minutes (.5 hours) during an inspection reviewing the documents required by
the Standard. The Agency determined that its compliance officers will conduct approximately
110 inspections during each year covered by this ICR. 13 OSHA considers other expenses, such
as equipment, overhead, and support staff salaries to be normal operating expenses that would
occur without the paperwork requirements specified by the Standard. Therefore, the total annual
cost of these paperwork requirements to the Federal government is:
Cost: 110 inspections x .5 hour x $37.90 = $2,085
15. Explain the reasons for any program changes or adjustments.

The Agency reports an adjustment decrease of 43,057,245 hours from the previous submission
(from 47,852,750 hours to 4,795,505 hours). In determining the hours associated with this ICR,
OSHA relied on information in the Environmental Protection Agency’s (EPA) Risk Management
Program (RMP) database to estimate the number of establishments and processes that must
comply with paperwork requirements for the PSM Standard. The reductions in establishments
and processes are due mainly to efforts of affected employers to find substitute substances for the
PSM-covered chemicals and to reduce inventories of chemicals and flammables, but also
because the original estimates by the Agency of the average number of processes per
establishment proved to be much higher than was consistent with, or supported by, data in the
RMP database today. In addition, after the PSM Standard was promulgated and paperwork
packages were updated every three years, OSHA had increased the estimated number of affected
establishments proportionate to increases reported in the number of establishments in an industry
over time. For example, if the number of establishments in an industry increased from 10,000 to
13

The Agency estimated the number of inspections by determining the overall inspection rate (1.4%) for
establishments covered by the Act (including both Federal OSHA and approved state-plan agencies), and then
multiplying the total number of establishments regulated under the Standard (7,562 + 300) by this percentage (i.e.,
7,862 establishments x 1.4% = 110 establishment inspected per year).

−18−

12,000 between 1994 and 2006, OSHA increased the estimated number of PSM-affected
establishments in that industry by 20 percent. Table 1 below provides the rationale for each of
these burden hour 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 will not publish the information collected under the Standard.
17. If seeking approval to not display the expiration date for OMB approval of the information collection,
explain the reasons that display would be inappropriate.

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

OSHA is not seeking an exception to the certification statement.

−19−

Table 1. Requested Burden Hour Adjustments

Information Collection
Requirement
(A) Employee
Participation (paragraph
(c))

(B) Process Safety
Information (paragraph
(d))
(C) Process Hazard
Analysis (paragraph
(e)(1))
(D) Resolution of
Hazards (paragraph
(e)(5))
(E) Updating,
Revalidating, and
Retaining the Process
Hazard Analysis
(paragraphs (e)(6) and
(e)(7))
(F) Operating
Procedures (paragraph
(f)(1)-(f)(4))
(G) Training (Initial,
Refresher, and
Documentation)
(paragraphs (g)(1)(g)(3))
(H) Contractors
(paragraphs (h)(2)(i)–
(h)(2)(iii), (h)(2)(vi), and
(h)(3)(iii))

Current
Burden
Hours

Proposed
Burden
Hours

Adjustment
(Hours)

Proposed Cost

Responses

Explanation of Adjustment
OSHA believes that the on-going
burden of employee participation
required by paragraph (c) is included in
other elements of the Standard and
therefore, no burden hours were
assigned to this paragraph.
The number of new establishments
decreased from 2,734 to 300.

0

0

0

$0

0

568,672

62,400

-506,272

$1,977,900

300

645,224

70,800

-574,424

$2,764,200

300

The number of new establishments
decreased from 2,734 to 300.

60,148

6,600

-53,548

$360,690

300

The number of new establishments
decreased from 2,734 to 300.

3,636,000

230,100

-3,405,900

$15,515,643

2,301

The number of current processes
decreased from 181,802 to 11,504.

2,021,426

263,120

-1,758,306

$14,379,508

11,960

55,250

30,767

-24,483

$627,954

615,333

4,607,200

756,200

-3,851,000

$24,262,677

3,781

−20−

The number of new processes
decreased from 13,090 to 456.
The number of employees receiving
training was reduced from 1.1 million
to 615,333 employees.

The number of existing establishments
decreased from 37,717 to 7,562.

Current
Burden
Hours
13,330,768

Proposed
Burden
Hours
1,752,140

Adjustment
(Hours)
-11,578,628

Proposed Cost
$32,363,760

Responses
11,960

670,254

12,578

-657,676

$370,793

125,478

(K) Management of
Change (paragraphs
(l)(1), (l)(4) and (l)(5))
(L) Incident
Investigations
(paragraphs (m)(4)–
(m)(7))
(M) Emergency
Planning and Response
(paragraph (n))
(N) Compliance Audits
(paragraphs (o)(1) and
(o)(3)–(o)(5))
(O) Records Disclosure

18,564,911

551,752

-18,013,159

$18,070,633

7,562

2,454,500

756,200

-1,698,300

$35,715,326

7,562

2,734

300

-2,434

$20,091

300

1,235,520

302,520

-933,000

$14,810,875

2,521

The number of existing establishments
declined from 37,790 to 7,562.

143

28

-115

$1,310

110

The number of existing establishments
declined from 37,790 to 7,562.

TOTALS

47,852,750

4,795,505

-43,057,245

$161,241,360

789,768

Information Collection
Requirement
(I) Written Procedures,
Inspections, and Testing
(paragraphs (j)(2) and
(j)(4)(iv))
(J) Hot Work Permits
(paragraph (k))

−21−

Explanation of Adjustment
The number of new and existing
processes decreased from 13,090 to
11,504.
The number of new and existing
establishments was reduced from 2,734
and 37,790, respectively to 300 and
7,562.
The number of existing establishments
decreased from 37,717 to 7,562.
The number of existing establishments
decreased from 37,717 to 7,562.

The number of new establishments
decreased from 2,734 to 300.