PATeacher SectionA

The Epidemiology and Impact of Workplace Violence in Pennsylvania Teachers and Paraprofessionals

Request for Office of Management and Budget Review and

Approval for Federally Sponsored Data Collection

Section A

Project officer: Hope Tiesman, MSPH, PhD

Epidemiologist

National Institute for Occupational Safety and Health

Division of Safety Research

1095 Willowdale Road, MS 1811

Morgantown, WV, 26505

Phone: 304-285-6067

Fax: 304-285-6235

E-mail: [email protected]

June 2009

Table of Contents

A. Justification

A1. Circumstances Making the Collection of Information Necessary……………………..

A2. Purpose and Use of Information Collection

A3. Use of Improved Information Technology and Burden Reduction

A4. Efforts to Identify Duplication and Use of Similar Information

A5. Impact on Small Businesses or Other Small Entities

A6. Consequences of Collecting the Information Less Frequently

A7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

A8. Comments in Response to the Federal Register Notice and Efforts to

Consult Outside the Agency

A9. Explanation of Any Payment or Gift to Respondents

A10. Assurance of Confidentiality Provided to Respondents

A11. Justification for Sensitive Questions

A12. Estimates of Annualized Burden Hours and Costs

A13. Estimates of Other Total Annual Cost Burden to Respondents or Record

Keepers

A14. Annualized Cost to the Government

A15. Explanation for Program Changes or Adjustments

A16. Plans for Tabulation and Publication and Project Time Schedule

A17. Reason(s) Display of OMB Expiration Date is Inappropriate

A18. Exceptions to Certification for Paperwork Reduction Act Submissions

Appendices

Appendix A Section 20(a)(1) of the Occupational Safety and Health Act

Appendix B Federal Register Notice

Appendix C Workplace Violence in Pennsylvania Teachers & Paraprofessionals Survey

Appendix D External Peer Review Comments

Appendix E HSRB Approval Letter

Appendix F 60 day FRN comments

Appendix G Partner List

Appendix H Reminder Postcard

A. Justification

A.1 Circumstances Making the Collection of Information Necessary

Under the Public Law 91-596 (Section 20[a][1]), the National Institute for Occupational Safety and Health (NIOSH) is tasked with conducting research relating to occupational safety and health (Appendix A). In order to achieve our goal of counting the instances of and describing the circumstances and outcomes of workplace violence incidents in Pennsylvania teachers and paraprofessionals, we need to collect information as described in this OMB supporting statement.

The educational services industry is the second largest U.S. industry with approximately 13.3 million workers. Educational workers are at an increased risk for several occupational injuries and illnesses including respiratory disease from microbial contaminants, infectious diseases, stress-related chronic diseases, and violence. While approximately 3.2 million people teach in U.S. public schools, the nation will need to recruit an additional 2.8 million over the next eight years owing to baby-boomer retirement, growing student enrollment and staff turnover (Wallis, 2008). In light of this belief, it is important to protect the health and safety of the professionals who educate and care for our youth.

Violence in U.S. schools is widely recognized as a community threat and major public health concern. In recent years, several high-profile school shootings have generated mass media attention; however, these types of fatal violent events while tragic, are rare. The National Center for Education Statistics (NCES) recently released the 2007 Indicators of School Crime and Safety and found that between July 1, 2005 and June 30, 2006, there were 14 homicides of youth while at school (Dinkes et al., 2007). This results in a rate of one homicide per 3.2 million students (2007). A recent report from Centers for Disease Control showed that between July 1999 and June 2006, school-associated student homicide rates have decreased significantly from 0.07 per 100,000 students to 0.03 per 100,000 students (Modzeleski, et al., 2008). While students, teachers, and other school employees are at minimal risk for being killed while in the school environment, they may be at an increased risk for theft of personal property, verbal threats of physical harm, bullying, abuse, physical assault, and injury.

In the last decade, such violent nonfatal victimizations have increased and these upward trends are also apparent in the U.S. school system (Elliott et al., 1998). In 2005, students aged 12 to 18 were victims of over 1.5 million nonfatal crimes while at school including theft, physical assault, sexual abuse, and rape (Dinkes et al., 2007). Violent victimizations are not limited to physical events. Annually, an estimated 30% of U.S. 6th to 10th graders are involved in some sort of non-physical violence, such as bullying (Nansel et al., 2001). Bullying has been shown to have detrimental long-term effects including low self-esteem, depression, and social isolation that continue into adulthood (Rigby, 1996).

Approximately two million American workers are victims of workplace violence each year (BJS, 2001). While workplace violence is now recognized as a leading cause of fatality and injury in the workplace, only recently has this become a priority area for employers, labor unions, and employees. From 1999 to 2003, teachers were the victims of approximately 183,000 nonfatal crimes including 119,000 thefts and 65,000 violent crimes such as rape and assault (Dinkes et al., 2006). On average, this translates to an annual rate of 39 crimes per 1,000 teachers (25 thefts and 14 violent crimes) (2006). The extant evidence indicates that working in a school environment carries an excess risk for becoming a victim of workplace violence; however, employees within the educational system are rarely the focus of workplace violence studies.

Collecting data on nonfatal workplace violence assault injuries using police records is problematic because less than half of all nonfatal violent workplace assaults are reported to the police (Duhart, 2001). Therefore, early studies of workplace violence in the education field relied on worker compensation records to examine nonfatal assault injuries. One such study in California found that school employees reported an assault injury rate 3.5 times higher than the average rate for the state (Peek-Asa et al., 1997). Another state-based analysis of workers compensation records in West Virginia showed that teachers had a significantly higher risk for severe physical assault injuries compared to other occupations (males proportional injury ratio (PIR) = 33.1, 95%CI=8.5-129.4; females PIR=4.9, 95%CI=2.0-11.9) (Islam et al., 2003). Though it is recognized that the use of worker compensation claims to enumerate workplace violence in education workers grossly underestimates the problem.

Another limitation of using worker compensation records to study workplace violence in the education field is the exclusion of non-physical forms of violence such as threats, bullying, and harassment. This type of workplace violence can be even more prevalent than the physical forms. One study of registered nurses in Minnesota found that the prevalence of physical violence while on the job was 13% and the prevalence of non-physical violence was nearly 3 times larger (38.9%) (Gerberich et al., 2004). DeVoe et al. found that teachers were more than twice as likely to be threatened with injury than physically assaulted by their student (2003). However, since these events do no result in a physical injury or medical claim, they are rarely reported to workers compensation. This type of data can only be collected using self-reported event data in a survey or interview format.

Due to this, studies have moved towards primary data collection. To the best of our knowledge, there has been a single study focusing on the epidemiological features of workplace violence in the education field (Gerberich et al, 2007). The University of Minnesota’s Center for Violence Prevention and Control recently completed a comprehensive epidemiological study of the etiology and consequences of violence against teachers (2007). This was a large cohort study of K-12 licensed teachers in the Minnesota licensing database and incorporated a case-control analysis of risk factors for physical assault (2007). This study has complete data analysis and investigators are preparing data for publication and dissemination (2007). An important limitation of this study is the exclusion of other school workers, termed paraprofessionals. Job classifications for paraprofessionals could include teaching aides, non-instructional teaching aides, food service workers, classroom assistants, and supportive service assistants. These paraprofessionals also have high levels of interaction with students and may be at risk for workplace violence events. Including paraprofessionals in such a study is difficult because they are often considered contract employees and are not captured in commonly used databases. No known study has attempted to measure the prevalence of both physical and non-physical workplace violence events in both teachers and paraprofessionals.

Previously published studies of workplace violence in the education field are based on worker compensation data and often lack specific details and circumstances of the incident, do not consider non-physical or electronic workplace violence incidents and therefore underestimate the true magnitude of the problem, and do not include the experience of others in the education field such as teaching assistants, food service workers, or teaching aides. School violence is a complex issue and the study of workplace violence in the school setting has unique challenges. At the present time, we do not know enough about the risk factors for workplace violence among teachers and paraprofessionals to develop evidence-based prevention strategies. This study will detail the prevalence of workplace violence, the circumstances surrounding these events, and the impact of these events on quality of life and job satisfaction in teachers and paraprofessionals.

NIOSH is in a unique position to dually study teachers and paraprofessionals in Pennsylvania. Pennsylvania is not only an appropriate setting to conduct such research, but also has several strengths as well. Firstly, NIOSH’s Morgantown offices are in close physical proximity to the state of Pennsylvania; therefore making travel to union offices cost effective and convenient. Secondly, the state has a diverse topography and population ranging from very urban cities such as Philadelphia, larger cities such as Pittsburgh, and extremely rural parts of the state. Within the state there are currently 501 school districts throughout the 67 counties (PDE Website, 2009). Last school year, there were approximately 3,253 K-12 public schools serving 1,821,383 students and 123,375 teachers (PDE, 2007; Common Core of Data, 2009).

Thirdly, education unions in the state of Pennsylvania dually cover teachers and other certificate holding professionals, as well as many paraprofessionals, including teaching aides, non-instructional, including teaching aides, food service workers, classroom assistants, and supportive service assistants. Finally, recent incidents in the Philadelphia School district highlighted the problem of school violence in the city (Burd, 2008). A recent report described the school district’s disciplinary system as “plagued by inconsistencies, high turnover in personnel, and a lack of training, staff and resources” (Ceisler, 2007). In addition to the problems that urban school districts face, we know anecdotally that rural school districts also face school violence. As a result of our Partner Working Group, we learned that some rural Pennsylvania school districts report a complete teacher turnover within a few years due to the stress associated with school-based violence (Personal Communication, 2007).

Privacy Impact Assessment Information

The information for this study is being collected in order to determine eligible participants. Teachers and paraprofessionals will be identified from the Pennsylvania State Education Association (PSEA), Pittsburgh AFT (PFT), and Philadelphia AFT (PA-AFT) union member databases. The survey methodology will allow the Division of Safety Research (DSR) to randomly select potential participants and follow-back with non-responders without keeping a record or database of union’s member’s names and home addresses. No IFF is being collected. No database or website will be used and all data will be collected via paper and pencil survey.

A.2 Purpose and Use of Information Collection

Privacy Impact Assessment Information

The information for this study is being collected in order to determine eligible participants for the proposed survey. Teachers and paraprofessionals in the state of Pennsylavania will be identified from the Pennsylvania State Education Association (PSEA), Pittsburgh AFT (PFT), and Philadelphia AFT (PA-AFT) union member databases. The proposed survey methodology will allow the Division of Safety Research (DSR) to randomly select potential participants and follow-back with non-responders without keeping a record or database of union’s member’s names and home addresses. No IFF is being collected. No database or website will be used and all data will be collected via paper and pencil survey.

This project focuses on a high-risk, but understudied occupational cohort. Working in a school environment carries an excess risk for becoming a victim of workplace violence; however school workers are rarely the focus of workplace violence research. Previously published studies of workplace violence in the education field are based on worker compensation data and often lack specific details and circumstances of the incident, do not consider non-physical or electronic workplace violence incidents and therefore underestimate the true magnitude of the problem, and do not include the experience of others in the education field such as teaching assistants, food service workers, or teaching aides. At the present time, we do not know enough about the risk factors for workplace violence in the school setting to develop evidence-based prevention strategies.

This project will provide a description of the prevalence of workplace violence in teachers and paraprofessionals and allow us to measure important risk factors for physical, non-physical, and electronic workplace violence. This cross-sectional study is designed to address the following three specific aims: 1) estimate the number and prevalence proportions (rates) of physical, non-physical, and electronic workplace violence; 2) identify circumstances and risk factors for physical, non-physical, and electronic workplace violence; 3) measure the impact of workplace violence on job satisfaction and quality of life.

Study results will be used to inform and justify additional research activities in the education field and better target prevention efforts that will reduce injuries and other negative consequences resulting from workplace violence in the state of Pennsylvania. Information transfer of these results will be an integral part of this project. The transfer will be a collaborative effort of all parties involved especially the participating national unions, local union affiliates, the state of Pennsylvania, local school districts, and NIOSH’s Division of Safety Research (DSR). These state stakeholders will help decipher research findings, determine the best way to disseminate the findings to targeted audiences, and suggest areas for future research in the state of Pennsylvania. This will include presentations to our stakeholders including the Pennsylvania State Educators Association, American Federation of Teachers, the Pennsylvania Department of Education, and key school districts. Results will also be disseminated to working teachers and paraprofessionals in more publicly accessible formats such as education trade shows and trade journals. These networks will be a key component to effectively disseminating the findings from this study and translating them into practice in the state of Pennsylvania.

It is anticipated that the study results will be disseminated to other academic audiences using peer-reviewed publications and professional presentations. These products will describe the prevalence of workplace violence to those in the education field and suggest areas in need of further research. It is anticipated that the scientific community will use this information to further research in the area of workplace violence in teachers and others in the education field. In all publications and presentations, the limited generalizability will be noted.

This project has much practical utility in that it will produce and disseminate information that highlights workplace violence in the education field. Consequently, it will provide the essential groundwork for developing effective prevention programs that will reduce workplace violence events and injuries to educators and educational staff.

Funding for this project will be provided by intramural NIOSH funds. These funds will cover DSR staff time for administrative tasks such as Human Subjects Review Board (HSRB) and Office of Management and Budget (OMB) package preparation, data analysis, and product development (manuscripts, presentations, and reports). The funds will also pay for any contractor services needed for data collection procedures as well as travel for survey package compilation.

A.3 Use of Improved Information Technology and Burden Reduction

All data for this study will be collected via a paper-and-pencil questionnaire. We received input into the survey methodology for this specific worker population from a Partner Working Group consisting of union leaders, state representatives, district staff, and current K-12 teachers. Members of this group indicated that the least burdensome manner with which to collect data would be a paper-and-pencil questionnaire. Scheduling phone or face-to-face interviews would be problematic for these workers. In addition, participants may prefer to answer potentially sensitive questions in the privacy of their own homes.

This questionnaire is a modified version of a survey used in a similar worker population for the University of Minnesota’s Center for Violence Prevention and Control “Minnesota Educators Study” (Gerberich et al, 2007). Additional survey items were carefully added to the original questionnaire in consideration of what information is needed. This modified tool was reviewed by members of our Partner Working Group in order to prioritize the information of greatest potential use. The survey was also pilot tested with four federal employees and four current Pennsylvania teachers. The improved readability and comprehension of this questionnaire, as well as parsimoniously selecting additional question items, will reduce the overall burden on the participants.

A.4 Efforts to Identify Duplication and Use of Similar Information

This proposed study is unique in that it has the opportunity to collect data on a wide variety of workplace violent events, from both teachers and paraprofessionals, in a wide variety of school settings and districts. Data presently available on workplace violence in the education field is limited to workers compensation claims. These reports often do not include non-physical forms of workplace violence such as bullying or indirect threats. Also, it is widely recognized that many physical workplace violence incidents do not get reported to workers compensation - making any rate developed with these data gross underestimates. Also, the single known study utilizing primary data collection in this area was limited to certificate holding teachers. Paraprofessionals were not surveyed. Additionally, to our knowledge, this effort will be the first to collect information on electronic workplace violence (facebook, email, blogs, YouTube) on any service worker population.

Besides examining known databases, literature search engines, and national meetings; the PI has been in close contact with investigators from the University of Minnesota’s Center for Violence Prevention and Control’s Minnesota’s Educators Study to determine how the research in this area could be furthered. One of the co-investigators of this study served as an external reviewer for the HSRB approval process. Finally, close contact with the CDC’s Division of Adolescent and School Health (DASH) has been kept during the process. DASH is part of the National Center for Chronic Disease Prevention and Health Promotion and are changed with preventing health risk behaviors among young children, adolescent and young adults. While the safety and health of teachers and staff are not their primary population of interest, they have been a wealth of knowledge in regards to current violence prevention programs and activities at the local and state levels.

In short, there is not similar data either at the local or national level on physical, non-physical, and electronic workplace violence among teachers and paraprofessionals. To the best of our knowledge, there is no institution currently collecting such information.

A.5 Impact on Small Businesses or Other Small Entities

No small businesses will be involved in this data collection.

A.6 Consequences of Collecting the Information Less Frequently

Collection of this data will allow NIOSH to better understand workplace violence so as to raise awareness of contributing risk factors and enable the development of targeted and effective interventions. There are no legal obstacles to reduce the burden. Each respondent will be asked at least three times to complete the questionnaire. They will complete the survey only once. The initial request, then a reminder post-card, then a final request will be mailed to the participants homes. The request is for a one-time data collection.

A.7 Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

There are no special circumstances.

A.8 Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency (101-442)

A. A 60-day Federal Register Notice was published in the Federal register on April 22, 2009, vol. 74, No. 76, pp. 18383-18384 (see Appendix B). One public comment was received (see Appendix F).

B. Prior to the inception of this research project, the research team solicited support and advice from a variety of sources including national educational unions, local affiliate unions, state education leaders, and district staff. At that time, both national unions expressed a strong interest and desire for a study of workplace violence among teachers and paraprofessionals. In June of 2007, a Partner Working Group was developed that included members representing both national unions, local affiliates of these national unions, the Secretary of the Pennsylvania Department of Education, and other local school districts in the state of Pennsylvania. The charge of this Partner Working Group was to aid in the development, organization, and management of a research study and protocol. A face-to-face meeting was held in November, 2007. Outcomes of this meeting included input from members of the proposed survey tool (Appendix C) and advice on the proposed survey methodology.

In 2009, the study protocol was reviewed by two external peer reviewers who are knowledgeable about teacher health and safety and have previously conducted research studies in this area. The comments of the external reviewers are attached (Appendix D). The external peer reviewers were:

• Dr. Dan Mercer, PhD, Assistant Director of Research, PSEA, Harrisburg, PA, Phone: (717) 255-7038; E-mail: [email protected].

• Dr. Nancy Nachreiner, PhD, Assistant Professor, University of Minnesota School of Public Health, Minneapolis, MN, Phone: (612)625-2487; E-mail: [email protected]

A.9 Explanation of Any Payment or Gift to Respondents

This study does not provide a payment or gift to the respondents.

A.10 Assurance of Confidentiality Provided to Respondents

Privacy Impact Assessment Information

A. This submission has been reviewed for Privacy Act applicability and it has been determined that the Privacy Act does not apply.

B. After several state-level databases were proven to be not suitable to develop a comprehensive sampling frame for this research, other non-conventional approaches were examined. The unions member contact databases were deemed appropriate for this research since: (1) unions covered both teachers and paraprofessionals in the state of PA, (2) state-wide, a high percentage of teachers and paraprofessionals were union members, and (3) the unions had a strong desire and interest to complete this research. Before agreeing to partner with NIOSH in this research project, appropriate survey methodology would need to be developed since unions would not release private information, including name and home address, to NIOSH. This unique survey methodology will allow DSR to randomly select potential participants and follow-back with non-responders without gaining access to union’s member’s names and home addresses. The methodology is described below.

Each union involved with this research project manages their own specific mailing database. Each union is, and will remain, in charge of this database throughout the research project. At the start of the research project, each union will update their databases with the most up-to-date names, occupation, and mailing addresses. This is usually done in the fall, after the start of the school year. This database file will then be stripped of all identifying information. This database file could contain an occupation code, gender, an urban-rural designation code, and member ID. Member ID is a unique and randomly generated number, specific to each union. These database files will then be sent to NIOSH via Fed Ex on a password protected CD or transmitted via a secure FTP site.

Using these stripped database files, NIOSH will pull a random sample of participants, stratified by occupation, gender and urban-rural status. Participants will be selected at random without replacement. The sample of participants will be distributed using proportional allocation, which will take into account the population size distribution. Once this sample is pulled, NIOSH will randomly assign a unique ID to the potential participants. These IDs will be mapped to each specific union. For example, all 1000’s will be a Pennsylvania State Education Association (PSEA) member, all 2000’s will be a Pittsburgh AFT (PFT) member, and all 3000’s will be a Philadelphia AFT (PA-AFT) member. DSR will then send this file back to the respective unions. This database file will include all the variables that were originally sent to NIOSH, plus the newly assigned unique ID. NIOSH will also send this database file to the survey contractor.

The unions will merge this database file with their current file, matching NIOSH’s unique ID with their union member’s names and addresses, using their unique ID. At no point during the research project will NIOSH or the contractor have access to this cross-walked database file. The unions will prepare mailing labels for their chosen participants. The contractor will print the survey with an embedded NIOSH unique ID. The contractor will also prepare the survey packets to include the survey, cover letter, and postage-paid return envelope. The postage-paid return envelopes will be addressed to return directly to the contractor.

The survey packet will be sealed in a flat mailing envelope with the NIOSH unique ID embedded on the paper envelope. This envelope will be pre-stamped to return directly to each perspective union. All undeliverable survey packets will be returned to the unions since they maintain the mailing and address databases. They would update and modify the address at that point. The survey packets will be mailed via Fed Ex to the union offices located in Pittsburgh, Harrisburg, and Philadelphia.

Since unions have few support staff to dedicate to such a large survey, NIOSH will aid the unions in the mailing process. At the time of the first mailing, NIOSH staff will travel to the Pittsburgh AFT office and aid the support staff in the preparation of the survey packets for mailing. This could include aiding the support staff in the affixation of name and address labels. This work will be done at the PFT office in Pittsburgh, under union leadership. Once this process is complete, the PI will perform a final quality control measure to verify that the name, address, and unique ID listed on the mailing label corresponds to the unique ID embedded in the mailing envelope. After this quality control measure is complete, the survey packets will be mailed to potential participants.

During the first mailing NIOSH staff will also travel to Philadelphia and Harrisburg to assist the unions with the survey preparations. This could include aiding support staff in the affixation of name and address labels. This work will take place in the PA-AFT office located in Philadelphia and the PSEA office located in Harrisburg. A final quality control measure will be performed by the PI. After this quality control measure is complete, the survey packets will be mailed to the potential participants.

The survey contractor will coordinate, record, and track all incoming questionnaires and correspond with NIOSH, PSEA, PFT, and PA-AFT as needed. Again, nondeliverables will be retuned to the respective unions. The contractor will never have access to personally identifying information such as name or home address. Approximately two weeks after the initial mailing, the survey contractor will send reminder postcards to all three unions. These reminder postcards will be mailed to all participants, regardless if they have returned a survey. The unions will prepare mailing labels and send these to each participant. NIOSH staff will be available to aid the unions in the preparation of these postcards if necessary.

Approximately four weeks after the initial mailing, the survey contractor will e-mail the unions a database file of the non-responders. This database file will have the NIOSH unique ID, as well as the union’s unique ID, but no identifying information. The unions will prepare mailing labels only for the non-responders. A second survey packet will be prepared by the contractor the same methods as described above. These survey packets will be mailed to each perspective union. NIOSH staff will be available to aid the unions in the preparation of these survey packets if necessary.

C. The cover page of each questionnaire states that the information provided to NIOSH will be used for statistical and research purposes and will be summarized so that no individual is identified. Also stated is the fact that the information supplied is voluntary and there is no penalty for not providing it. A returned survey will be deemed consent to participate in the proposed research project. This survey is included in this package (Appendix C). This project has received NIOSH Human Subjects Review Board approval (HSRB).

D. Respondents are informed in the cover letter mentioned above that their participation in providing information is voluntary.

A.11 Justification for Sensitive Questions

There are questions on the survey instrument which may be considered sensitive. Information on race, ethnicity, gender, age, education, and marital status is necessary so that we can compare workplace violence prevalence rates between different socio-demographic categories of teachers and paraprofessionals. Asking participants to recall instances of workplace violence may also be sensitive, depending on the circumstance of the incident. As the survey is voluntary, respondents may refuse to answer any questions. Respondents are informed of their right to refuse participation and their right to refuse to answer individual questions in the introductory letter. While these questions may be difficult to answer for some respondents, these answers are needed to allow us to measure important risk factors for physical, non-physical, and electronic workplace violence in a large and varied sample of teachers and paraprofessionals.

A.12 Estimates of Annualized Burden Hours and Costs

A. The sample size for the survey is estimated to be approximately 5,000 teachers and paraprofessionals. The paper-and-pencil survey is a one time survey taking approximately 30 minutes to complete, resulting in an annualized burden estimate of 2,500 hours. This survey will also utilize the skills and time of a variety of union office and administrative staff for the preparation of the survey packets. The exact number of administrative staff utilized at each union location, as well as the additional work demands placed on them has yet to be determined, though our best guess is 13 individuals. It is estimated that three office support staff from the Pittsburgh Federation of Teachers, six from the Pennsylvania State Education Association, and four from the Philadelphia Federation of Teachers will be needed for a grand total of 13 support staff personnel. Additional work activities could include: preparation of the sampling frame database and non-respondent database, printing of mailing labels, affixation of mailing labels onto survey packets, and email and/or phone communication with NIOSH. For each mailing, we estimate that each of the 13 administration assistants will dedicate two hours to the mailing. So, for each mailing, a grand total of 26 hours will be burdened. There will be three separate mailings for a grand total burden of 78 burden hours.

Respondents	No. of Respondents	No. of Responses per Respondent	Average Burden per Response (in hrs)	Total Burden (in hrs)
‘Elementary and Secondary School Employees’	5,000	1	30/60	2,500
‘Office & Administrative Support Occupations’	13	3	2	78
Total	2,578

A.12.B Estimates of Annualized Burden Costs

Type of Respondent*	Total Burden Hours	Hourly Wage Rate	Total Respondent Costs
‘Elementary and Secondary School Employees’	2,500	$21.48	$53,700
‘Office and Administrative Support Occupations’	78	$14.32	$1,116.96

* These estimates are calculated using the U.S. Department of Labor’s National Industry-Specific Occupational Employment and Wage Earnings for all occupations in the Elementary and Secondary School Industry Group, May 2008. (http://www.bls.gov/oes/current/naics4_611100.htm#b00-0000).

A.13 Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers

There are no additional cost burdens for respondents.

A.14 Annualized Cost to the Government

The annualized cost to the government for this project is estimated to be $118,000. The table below summarizes a breakdown of the estimated costs.

Item	FY 2010	FY 2011	Total
Equipment and supplies1	$2,000	$2,000	$4,000
Contractual	$100,000	$0	$100,000
Travel	$7,000	$7,000	$14,000
Annualized estimate of federal costs	$109,000	$9,000	$118,000

A.15 Explanation for Program Changes or Adjustments

This is a new data collection.

A.16 Plans for Tabulation and Publication and Project Time Schedule

Clearance is being requested for 12 months, starting in May of 2010 and continuing through May of 2011. We plan to publish project results in both peer reviewed scientific journals with a high impact number. Additionally, results will be presented at national, scientific conferences with high public visibility to research audiences. Results will also be disseminated to stakeholder groups via presentation and written reports. Stakeholder groups include the Pennsylvania Department of Education, national and state-level unions, and various school districts. Finally, results will be disseminated to working teachers in more publicly accessible formats such as education trade shows and trade journals. Our projected timeline for the project is detailed in the table below.

Activity	Time Schedule
Notification of study to respondents	1 month after OMB approval
First mailing	2 months after OMB approval
Reminder postcard mailing	2.5 months after OMB approval
Final mailing	3 months after OMB approval
Finalize dataset	6 months after OMB approval
Analyses	12 months after OMB approval
Presentations to research audiences and stakeholders	18 months after OMB approval
Product and reports ready for dissemination to stakeholders (non-peer reviewed)	18 months after OMB approval
Publication(s) ready for submission to peer-review journal	24 months after OMB approval

A.17 Reason(s) Display of OMB Expiration Date is Inappropriate

The OMB expiration date will be displayed.

A.18 Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification.