Ss_1218-0205(01-25-10)

THE INFORMATION COLLECTION REQUEST FOR
PERSONAL PROTECTIVE EQUIPMENT (PPE) STANDARDS
FOR GENERAL INDUSTRY (29 CFR PART 1910, SUBPART I)) 1
OFFICE OF MANAGEMENT AND BUDGET (OMB)
CONTROL NO. 1218-0205 (January 2010)

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 (OSH 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
OSH Act authorizes “the development and promulgation of occupational safety and health
standards” (29 U.S.C. 651).
With regard to recordkeeping, the OSH Act specifies that “[e]ach employer shall make, keep and
preserve, and make available to the Secretary . . . such records . . . as the Secretary . . . may
prescribe by regulation as necessary appropriate for enforcement of this Act . . . ” (29 U.S.C.
657). The OSH 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 inspection of an employer’s establishment” (29
U.S.C. 657).
Under the authority granted by the OSH Act, the Occupational Safety and Health Administration
(OSHA) issued personal protective equipment (PPE) standards for general industry at 29 CFR
part 1910, subpart I. Section 1910.132(a) requires that PPE, including equipment for eyes, face,
head, and extremities, protective clothing, respiratory devices, and protective shields and
barriers, be provided, used, and maintained in a sanitary and reliable condition wherever it is
necessary by reason of hazards of processes or environment, chemical hazards, radiological
hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment
in the function of any part of the body through absorption, inhalation or physical contact. Items
2 and 12 below describe in detail the specific information collection requirements of subpart I.

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. This Supporting Statement
and information collection request (ICR) does not include burden hours and costs associated with the information
collection requirements in the subpart I standard on Respiratory Protection (29 CFR 1910.134) and Electrical
Protective Equipment (29 CFR 1910.137), both of which have been addressed in separate ICRs. See OMB Control
Nos. 1218-0099 and 1218-0190, respectively.

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

Subpart I specifies several paperwork requirements. The following describes the information
collection requirements in subpart I and addresses who will use the information.
Hazard Assessment and Verification (§1910.132(d))
Paragraph (d)(1) requires employers to perform a hazard assessment of the workplace to
determine if hazards are present, or likely to be present, that make the use of PPE necessary.
Where such hazards are present, employers must communicate PPE selection decisions to each
affected worker (paragraph (d)(1)(ii)).
Paragraph (d)(2) requires employers to certify in writing that they have performed the hazard
assessment. The certification must include the date and the person certifying that the hazard
assessment was conducted, and the identification of the workplace evaluated (area or location). 2
The hazard assessment assures that potential workplace hazards necessitating PPE use have been
identified and the PPE selected is appropriate for those hazards and the affected workers. The
required certification of the hazard assessment verifies that the required hazard assessment was
conducted.
Training and Verification (§1910.132(f))
Section 1910.132(f) requires that employers provide training for each worker who is required to
wear PPE. Paragraph (f)(3) requires that employers also provide retraining when there is reason
to believe that any previously trained worker does not have the understanding and skill to use
PPE properly. Circumstances where such retraining is required include changes in the workplace
that render prior training obsolete, changes in the types of PPE used, and inadequacies in the
worker’s knowledge or use of PPE that indicate the worker had not retained the requisite
understanding and skill.
Paragraph (f)(4) requires that employers certify that workers have received and understood the
PPE training required in §1910.132(f). The training certification must include the name of the
worker(s) trained, the date(s) of training, and the subject of the certification (i.e., a statement
identifying the document as a certification of training in the use of PPE).
The training certification verifies that workers have received the necessary training and know
how to properly use PPE. OSHA compliance officers may require employers to disclose the
certification records during an Agency inspection.

2

Paragraph (g) of §1910.132 specifies that the section’s hazard assessment (paragraph (d)) and training
(paragraph (f)) requirements only apply to PPE for the eyes and face, head, feet, and hands.

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The standards on PPE protection for the eyes and face (29 CFR 1910.133), head (29 CFR
1910.135, feet (29 CFR 1910.136)), and hands (29 CFR 1910.138) do not contain any separate
information collection requirements.
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 reporting or maintaining records associated with the information collection
requirements in subpart I. 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 2 above.

The information collection requirements in subpart I are specific to each employer and worker
involved, and no other source or agency duplicates the requirement or can make the required
information available to OSHA (i.e., the required information is available only from employers).
5. If the collection of information impacts small businesses or other small entities, describe any methods used
to reduce the burden.

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

The collections of information are for the purpose of worker safety and health in the workplace
and are the minimum amount necessary and appropriate.
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;

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·

requiring the use of statistical data classification that has not been reviewed and approved by OMB;

·

that includes a pledge of confidentiality that is not supported by authority established in statute or
regulation, that is not supported by disclosure and data security policies that are consistent with the
pledge, or which unnecessarily impedes sharing of data with other agencies for compatible
confidential use; or

·

requiring respondents to submit proprietary trade secret, or other confidential information unless
the agency can prove that it has instituted procedures to protect the information's confidentiality to
the extent permitted by law.

No special circumstances exist that require employers to collect information using the procedures
specified by this item. The requirement is within the guidelines set forth in 5 CFR 1320.5.
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register
of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior
to submission to OMB. Summarize public comments received in response to that notice and describe actions
taken by the agency in response to those comments. Specifically address comments received on cost and hour
burden.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of data,
frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any),
and on the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must
compile records should occur at least once every three 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 November 23, 2009 (74 FR 61175, Docket No.
OSHA-2009-0028) requesting public comment on its proposal to extend the Office of
Management and Budget’s approval of the information collection requirements found in 29 CFR
part 1910, subpart I (Personal Protective Equipment (PPE) Standards for General Industry).
This notice was part of a preclearance consultation program that provided the general public and
government agencies with an opportunity to comment. The Agency received no comments in
response to its notice.
9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of
contractors or grantees.

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

The paperwork requirements specified by subpart I do not require the collection of confidential
information.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and
attitudes, religious beliefs, and other matters that are commonly considered private. This justification should

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include the reasons why the agency considers the questions necessary, the specific uses to be made of the
information, the explanation to be given to persons from whom the information is requested, and any steps to
be taken to obtain their consent.

The provisions in subpart I do not require the collection of 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
As a preliminary matter, OSHA is increasing the number of establishments and workers affected
by the information collection requirements in subpart I. OSHA’s PPE Cost Survey provides
estimates of the percentage of establishments in each affected industry where some kind of PPE
is used and of the percentage of workers who use one or more kinds of PPE. Applying these
percentages to industry-specific establishment and employment totals from the 2006 County
Business Patterns, OSHA estimates that there are 3.5 million establishments, with 43.6 million
workers affected by the PPE standards.
In determining the wage rates for the various occupations that perform the paperwork
requirements, OSHA used the most recent data from Employer Costs for Employee
Compensation, June 2009, Bureau of Labor Statistics (BLS), U.S. Department of Labor. The
specific rate of hourly compensation for each occupation, including fringe benefits, is as follows:
Management and Professional:
Office and administrative support:

$48.87
$23.04

(A) Initial Hazard Assessments, Reassessments, and Certification of Hazard Assessments
(§1910.132(d)).
Paragraph (d) requires that all affected employers conduct a hazard assessment and make a
determination regarding their need for PPE. In the Regulatory Impact Analysis (RIA) of
OSHA’s final rule revising subpart I (59 FR 16334 (April 6, 1994)), the Agency estimated that
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the time to perform a hazard assessment ranged from 3 to 29 hours, based on the number of
workers per establishment. Establishments with 1-19 workers take 3 hours; establishments with
20-99 workers take 10 hours; establishments with 100-249 workers take 19 hours; and
establishments with 250 or more workers take 29 hours. These times include the time to
communicate PPE selection decisions to affected workers and to generate and maintain the
certification record.
Data from the Census Bureau indicates that there is a 12.4 percent annual establishment turnover
rate in the private sector. 3 There are, therefore, 434,000 “new establishments” (3.5 million x
12.4 percent) that will need to conduct an initial hazard assessment. The RIA noted that 47
percent of establishments were conducting the initial hazard assessment as a usual and customary
practice, thus, 53 percent of the 434,000 establishments (or 230,020 establishments) would incur
a burden.
Based on 2006 County Business Patterns data, OSHA estimates that 85.1 percent of the affected
establishments (195,747) have fewer than 20 workers, 12.4 percent (28,523) have between 20
and 99 workers, 1.9 percent (4,370) have between 100 and 249 workers, and .6 percent (1,380)
have 250 or more workers. 4 The total burden for this activity is calculated as follows:
Burden hours: 195,747 establishments x 3 hours
28,523 establishments x 10 hours
4,370 establishments x 19 hours
1,380 establishments x 29 hours
Cost:

= 587,241 hours
= 285,230 hours
= 83,030 hours
= 40,020 hours
995,521 hours
995,521 hours x $48.87 = $48,651,111

OSHA estimates that all establishments will need to conduct PPE hazard reassessments an
average of once every five years (20 percent per year). This estimate is based on the assumption
that firms change production processes, incorporate new technologies or open new facilities at
this rate. OSHA estimates that it will take one hour for an establishment to perform this hazard
reassessment; communicate the PPE selection decisions to affected workers; and to generate and
maintain the certification record.
Burden hours: 3.5 million establishments x .20 x 1 hour = 700,000 hours
Cost:

700,000 hours x $48.87 = $34,209,000

3

Technically, this is referred to as the “birth” rate of establishments. 2005-2006 Statistics of U.S. Business
dynamic data at http://www.census.gov/csd/susb/susbdyn.htm.
4

Estimates based on the distribution of establishments by employment size for industries affected by the
PPE standard.

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(B) Training and Verification (§ 1910.132(f)(4)).
OSHA believes that all current affected workers in general industry (43.6 million) have been
trained in the use of PPE and that employers will take one minute (.02 hour) to maintain the
certification record for each worker. (Because the training is performance-oriented it is not
subject to review under the PRA. Therefore, no burden for training has been calculated.)
BLS estimates the worker turnover rate is 41.1 percent.5 The Agency will use this rate to
account for both new hires (at existing and new establishments) and workers requiring retraining.
Thus, the Agency estimates 17,919,600 workers (41.1% of 43.6 million) to be the annual number
of new hires and those requiring retraining in any given year. In addition, a written certification
must be maintained for all existing workers which the Agency estimates to take 1 minute (.02
hour) each, and that it will take 3 minutes (.05 hour) to generate and maintain the training
documentation for each new/retrained worker.
Burden hours: 43,600,000 existing workers x .02 hour to maintain training
documentation = 872,000 hours
Cost:

872,000 hours x $23.04 = $20,090,880

Burden hours: 17,919,600 new/retrained workers x .05 hour to generate and
maintain training documentation = 895,980 hours
Cost:

895,980 hours x $23.04 = $20,643,379

In addition, OSHA estimates, based on the RIA, that technology or job changes within an
establishment will require that all workers be retrained every five years (20 percent annually).
These workers can be trained in groups of five. A certification record will have to be generated
and maintained for each group.
Burden hours: 43,600,000 workers/5 x .20 retrained annually x .05 hour to
generate and maintain training documentation = 87,200 hours
Cost:

87,200 hours x $23.04 = $2,009,088

Additionally, the Agency believes that approximately 49,000 employers will be subject to an
OSHA inspection and required to disclose hazard assessment documentation and/or training
certification records annually (see Item 14 below) which is estimated to take 2 minutes (.03
hour).

5

See BLS, Job Openings and Labor Turnover Survey (January 2009).

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Burden hours: 49,000 inspections x .03 hour to disclose training documentation =
1,470 hours
Cost:

1,470 hours x $48.87 = $71,839

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the
collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14.)
·

The cost estimate should be split into two components: (a) a total capital and start-up cost
component annualized over its expected useful life); and (b) a total operation and maintenance and
purchase of 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 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 also may 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 $40.66,
spends about 15 minutes (.25 hour) during an inspection reviewing hazard assessment and
training certification documents. The Agency has determined that its compliance officers will
conduct about 49,000 inspections during each year covered by this ICR. 6 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 cost of these paperwork requirements to the Federal government is:
6

OSHA estimated the number of inspections by determining the inspection rate (1.4%) for the number of
employers covered by this ICR (3.5 million), and then multiplying this number by 1.4% (i.e., 3,500,000 employers x
1.4% = 49,000 inspections).

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Cost: 49,000 inspections x .25 hour x $40.66 = $498,085
15. Explain the reasons for any program changes or adjustments.

OSHA is requesting an adjustment decrease in the burden hours of the paperwork requirements
in 29 CFR part 1910, subpart I from 3,953,759 hours to 3,552,171 hours, for a total decrease of
401,588 hours. The adjustment decrease is due primarily to a decrease in the number of
establishments with 20 or more workers conducting initial assessment hazards. The percentages
are much lower for the establishments with 20 or more workers. Table 1 below describes each of
the requested burden hour adjustments.
The significant increase in the number of responses is mainly due to the increase in the number

of affected workers from 33.7 million to 43.6 million workers. The rise in the estimated number
of workers using PPE is a result from retrofitting SIC-based survey data to NAICS census data
for benchmarking totals; and reweighting the PPE survey to correct earlier anomalies in the
results.
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 this subpart.
17. If seeking approval to not display the expiration date for OMB approval of the information collection,
explain the reasons that display would be appropriate.

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.

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Table 1: Requested Burden Hour Adjustments
Information
Collection
Requirement
Initial Assessment
and Reassessment
of Workplace for
Hazards
(1910.132(d)(1))
Written Certification
of Assessment
(1910.132(d)(2))
Certification of PPE
Training and
Retraining
(1910.132(f)(4))

TOTALS

Requested
Burden
Hours
995,521

Current
Burden
Hours

Adjustment

Cost Under
Item 12

Responses

Explanation of Adjustment
The adjustment decrease is due primarily
to a decrease in the number of
establishments with 20 or more workers
conducting initial assessment hazards.
Establishments with higher numbers of
workers expend more time conducting
such assessments.

1,843,451

-847,930

$48,651,111

230,020

700,000

680,000

20,000

$34,209,000

700,000

872,000

674,000

198,000

$20,090,880

43,600,000

The adjustment increase is due to an
increase in the number of affected
workers since the currently approved
ICR. Based on updated information, the
number of workers is 43.6 million (up
from 33.7 million).

895,980

687,480

208,500

$20,643,379

17,919,600

The adjustment increase is due to the
data showing the “civilian new hire rate
(aka turnover)” is 41.1 percent of the
total number of workers.

87,200

67,400

19,800

$2,009,088

1,744,000

The adjustment increase is due to an
increase in the number of affected
workers since the currently approved
ICR. Based on updated information, the
number of workers is 43.6 million (up
from 33.7million).

1,470

1,428

42

$71,839

49,000

The adjustment decrease is due to a rise
in the number of employers who may be
subject to an OSHA inspection.

3,953,759

-401,588

$125,675,297

3,552,171

10

64,242,620

The increase results from an increase in
the number of establishments from 3.2 to
3.5 million.