1215-0171 Justification for 83-C (CM-972) (2007 Clearance)

Terms of Clearance for 1215-0171

On December 18, 2007, The OMB approved the collection for 1215-0171 form (CM972).
Terms of Clearance: Within 18 months of this clearance date, DOL will report to OMB
with the feasibility of not pre-printing or collecting the miner’s social security number on
the CM-972 when the CM-972 is used for survivors’ claims that have no associated
miner’s claim. DOL should consider whether an alternate method may be used as a way
to mitigate the privacy risks of sending social security numbers through the mail.

The OWCP Black Lung Program believes it has complied with the Terms of Clearance
because the Black Lung correspondence system no longer preprints the miner’s Social
Security Number (SSN) on any BL forms in accordance with the policy of OMB. The
program discontinued the process of preprinting the SSN on all forms that previously
requested this information. The Black Lung Program uses the miner’s name and the last
four digits of the SSN only for identification and association of the CM-972 with the
appropriate claim file. The only time the program receives a survivor’s claim is after the
miner has died and when any person dies the Privacy Act no longer applies.
Nevertheless, the correspondence system does not generate either the miner’s or the
survivor’s SSN. The expiration date for this collection is December 31, 2010.